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Friday, 19 July 2024
(9.45 am)
MR BLAKE: Good morning, sir. Can you see and hear me?
SIR WYN WILLIAMS: Yes, I can, thank you.
MR BLAKE: Thank you very much. This morning we're going to
hear from Ms Swinson.
SIR WYN WILLIAMS: Yes.
JOANNE KATE SWINSON (affirmed)
Questioned by MR BLAKE
MRBLAKE: Thank you very much. Can you state your full
name, please?
My name is Joanne Kate Swinson.
Thank you very much. Ms Swinson, you should have in
front of you a witness statement?
Ido.
Is that dated 19 June 2024?
Itis.
oP
Could I ask you, please, to turn to the final page.
Yes, I've done that.
Can you confirm that is your signature?
Yes, that is my signature.
Can you confirm that that statement is true to the best
of your knowledge and belief?
Yes, the statement is true.
Thank you very much. That witness statement has
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prororopPr
oP
A. Yes, I was.
Q. Your post in both respects was covered by Jenny Willott
MP or just in respect of one of those posts?
A. In both of the ministerial posts, obviously not my
constituency work.
Q. Those are two very long ministerial titles. Did you
divide your time equally between the two?
A. The role at BIS -- Business, Innovation and Skills --
was a role that took more of my time than the Women and
Equalities role. There were more different elements to
the brief at BIS, as indeed from the title, Employment
Relations, Consumer Affairs and Postal Affairs, which
was very wide-ranging, even within those topics,
including competition policy and insolvency and European
liaison on different issues. So that had more of my
time but, obviously, the Women and Equalities role also
took time, so, across the four days that I was able to
spend on my ministerial commitments during the week,
with the other three days, obviously being spent in my
constituency working, I would say probably about 80 per
cent of my time was spent on the BIS portfolio.
Q. Thank you very much. II'm going to get into trouble with
the stenographer, I imagine, if you don't speak slightly
slower, if you may?
A. I will do my best.
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a Unique Reference Number of WITN10190100 and that will
be uploaded to the Inquiry's website?
You are formally a Liberal Democrat Member of
Parliament?
That's right.
You were an MP between 2005 and 2015 and then again
between 2017 and 2019; is that correct?
Yes.
You have been both the Deputy Leader and then
subsequently Leader of the Liberal Democrat party?
Yes, I have.
Relevant for today’s purpose, you were Parliamentary
Under-Secretary for Employment Relations, Consumer and
Postal Affairs --
(The witness nodded)
-- between 6 September 2012 and 8 May 2015; is that
correct?
That is correct.
That was during the Coalition years?
Yes.
At the same time, I think you were also Parliamentary
Under-Secretary of State for Women and Equalities?
Yes.
Some of that time, I think 18 December 2013 to 30 June
2014, you were also on maternity leave?
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Thank you. Employment relations, Consumer and Postal
Affairs. How do you divide that 80 per cent of your
time up between the three?
I think in my total ministerial time, probably about 15
per cent might have been spent on postal affairs.
I think it would also be worth noting that it was not
static, so it would depend on what the issues were at
the time. So, for example, during my time as
a Minister, I took five different Bills through the
House of Commons and Bills just eat your time. Hours,
and hours, and hours of debates in committee report
stage in Parliament but all of the preparation in terms
of the policy development, the engagement with different
groups about what goes into those Bills.
So at the points where a Bill was being taken
through, then that would be eating up a huge amount of
my time and none of those Bills that I did were in the
postal services area.
And so that -- yeah, it varied but, probably on
average, about 15 per cent on Post Office and I note
that when I came back from maternity leave, for example,
and I had the deep dives in the different areas of my
brief, I had those on six different areas of which one
was postal affairs and, of course, within postal
affairs, there was a broad range of different issues to
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be considering.
Thank you. In terms of the actual post, Minister for
Postal Affairs, did you see your role as being
accountable to Parliament for the Post Office?
Yes, definitely Parliamentary accountability was
a necessary part of the role, not least because
Parliament is one of the places where, you know -- with
the exception of Select Committees -- Post Office
officials can't actually themselves answer any
questions. So if a question was to be asked in the
House of Commons, either written or orally, then it had
to be a Minister who would be answering that. So that
Parliamentary accountability was definitely part of the
role.
You're accountable to Parliament for the Post Office.
Who is the Post Office accountable to, in your view?
Ultimately, the Post Office is accountable to its
shareholder, which the Government, and then, of course,
in terms of, you know, wider general accountability, as
a public institution, through, you know, members of the
media and others, there are ways in which that
accountability operates in other spheres too.
I'd like to take you to a passage from your witness
statement, if we could bring up on screen WITN10190100.
It's paragraph 112, that is on page 47. At
5
certainly campaigned against Post Office closures in my
constituency in East Dunbartonshire, and it struck me
this was one of the issues that didn't matter if you
were Labour, Conservative, Liberal Democrat, SNP,
whatever, you cared about your local post offices.
So that was a very contentious political issue and
I think we heard from Pat McFadden earlier this week how
obviously that was a big issue in the years immediately
preceding the Coalition Government. So, therefore,
securing the future network, stabilising that network
was a very strategically important goal.
That was obviously linked to financial
sustainability and one of those areas was the Government
services, so how to make sure the Post Office could have
a sustainable future, contracts such as the Post Office
Card Account or the Driver and Vehicle Licensing Agency,
passport renewals, these would be contracts that
Government could give to Post Office and, as a minister,
I would be engaged in discussions with other ministers
in other departments about trying to make sure Post
Office would be a provider, and there was a long-term
issue of mutualisation as well.
Thank you. Another term that we're going to come to is
“arm's length”, is that something that was ever
explained to you as to what that meant in practice
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paragraph 112 you say as follows:
"Ido find the accountability placed on
Ministers for [the Post Office] was not matched with the
levers available to Ministers to affect or influence
what [the Post Office] was doing. It was always made
clear to me that it was not for me as Minister to
interfere with operational matters, and it was only
feasible to engage with the most serious and
strategically important objective and aims of the Post
Office."
I'd like to focus on that division. Can you assist
us with how you saw operational matters; what were
operational matters for you?
I think the first thing would say is I was never
presented with, nor necessarily spent a huge amount of
time critiquing, what was operational and what was
strategic. It wasn't like there was some list of
criteria somewhere. It was a division which was
interpreted probably with a bit more fluidity than that
but, clearly, in terms of strategic matters, that would
include issues such as the size and the future
sustainability and health of the Post Office Network,
the context for this being that we had recently had very
significant Post Office closures, which every MP in
Parliament had been affected by and exercised by. I'd
6
between the Government and the Post Office or you and
the Post Office?
It wasn't defined in the sense of here's a criteria, but
it was obviously referenced -- not necessarily always
with that terminology but it was referenced in terms of
the briefings I would receive that would say, of course,
this is an operational matter. And it did -- I mean, to
me I recognised that, with the variety of things I was
dealing with as a minister, I wasn't in a position to
either have the expertise of how to run a company on
a day-to-day basis nor indeed would I have the time to
be able to do so. So that operational strategic
distinction seemed to make sense to me.
We're going to look at correspondence and we're going to
look at particular events but, structurally, what did
you see the role of ShEx being in respect of the Post
Office?
So at this time, ShEx were part of BIS and, although
they were slightly separate, I think they were on
a different floor in the building, I also viewed them
really as part of the Department, and I mean when
I initially started, I don't think I was told that there
was a specific difference, that became clear to me in my
time as Minister. But I viewed the team of officials in
ShEx, who would come and brief me on Post Office, in
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a similar way that I would view the team who would brief
me on competition policy or on employment rights, or on
insolvency, that these would be teams of officials
within the Department, who were there to support me in
my work as Minister and to fulfil the duties of the
Government Department.
And the differential with ShEx was not particularly
clear, even when, obviously, I was aware it was
a different section. I was aware there was a slightly
different culture within ShEx, it was a bit more
commercial. They probably, you know, held themselves
a little bit more as -- maybe, dare I say, sometimes
slightly superior, in that sense, you know, that they
were the ones dealing with the commercial matters and it
had obviously recruited a lot of people from corporate
finance or consultancy backgrounds.
I probably wasn't aware at the time quite the extent
to which that recruitment was not within the normal
Civil Service pools of recruitment.
We're going to see a number of ministerial submissions
and briefings. In respect of the Post Office, would
they all come from ShEx, or would other members of the
Department --
I mean, I wouldn't want to be absolutely categorical but
I think so. I think the main post office team was in
9
getting back up to speed on the different aspects of my
portfolio and, you know -- but it will have been in the
context of "Here's Richard, Will has gone somewhere
else, Richard is now briefing on Post Office".
I did realise, and I did know that he was on the
Board but I think I hadn't made the connection, until
much more recently, in these preparations, that
actually, yes, that was a very significant change in how
that was structured, and it, as I say, isn't one that
was flagged to me and I think it is one where, as I set
out in my witness statement, I think there are real
concerns about that role being combined because it means
that there is less opportunity for kind of challenge if
the other people of the Post Office team are then
reporting to him, because he was the most senior person
within that specific Post Office team.
Specifically in terms of the Non-Executive Director, the
Post Office Board member, who did you consider they were
accountable to?
Ultimately to ministers. There would obviously also be
a sort of line management responsibility through the
senior officials within ShEx and then ultimately in that
way through the Permanent Secretary of BIS. I believe
that as part of BIS, you know, Martin Donnelly, as
Permanent Secretary, would ultimately have oversight of
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ShEx and I am trying to think if there was a kind of
example of something. I mean, there would be
discussions between private offices sometimes, between
my private office and Vince's private office. So, yeah,
but, I mean, I would say the vast, vast, vast majority
would come from ShEx.
Thank you. There were some structural or personnel
changes over the time that you were in office. I think
Susannah Storey was the Post Office Shareholder
Non-Executive Director when you first started, and Will
Gibson was the head of the Post Office Shareholder Team
in ShEx, and then in 2014, Mr Callard held both of those
roles. Is that something that you noticed, the
structural change or significant change in that respect?
No, and it wasn't explicitly flagged to me. In fact,
I'm not certain I met Susannah Storey. I may have done
but I certainly did not meet with her regularly, in the
way that I met with Will Gibson, in terms of the
briefings that I was receiving in that period, in late
2012 and in 2013.
I, of course, then was away for the beginning six
months of 2014, and so when I came back from maternity
leave, Richard Callard was there, and so I presume I got
introduced to him in the catch-up days that I had
towards the end of my maternity leave, when I was
10
how ShEx was operating through the Chief Executive or
senior official within ShEx. So there would be both
a main line of accountability through the civil service
and then ultimately, obviously, for everything that goes
‘on in the Department, ministers have ultimate
responsibility.
How about in respect of the Post Office?
So, I mean, in terms of shareholder -- could you just?
Yes, in terms of that shareholder, the Non-Executive
Director, you've explained that they're accountable to
the Department. In respect of their accountability to
the Post Office, did you see another line of
accountability there?
I mean, I obviously they were -- that particular
individual was a non-executive on that Board and that
comes with specific duties as a Director, as set out in
law, in terms of oversight of a Board. All directors,
whether they're in this unusual situation of being
a civil servant who's a Director on a Board of
a Government-owned body or, indeed, any Executive or
Non-Executive Director, would have those roles and
responsibilities in terms of that accountability.
So, yeah, I mean, they would have those
responsibilities and I imagine there might be occasions
where they would perhaps recognise there would be
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aconflict. I know sometimes that Non-Executive
Director would recuse themselves from a Post Office
decision, in those circumstances.
Thank you. I'm going to move on now to early briefings
that you received on taking up your post. Could we
please start with UKGI00041975, please. You started on
6 September, this is 17 September. It is a briefing for
your meeting with the Chair and CEO of the Post Office.
It begins:
"Purpose
"This is your first meeting with Alice Perkins and
Paula Vennells ..."
It sets out there, if we scroll down, your
objectives and the purpose. One of your objectives
being:
"To understand Alice and Paula's priorities for the
business."
And what are their objectives? Those are set out
as:
"To set out her vision for the business, progress
[Post Office] is making against plan, and any key areas
of concern.
"To underline the importance of new revenue and
Government work in securing a viable future for the
network. Alice and Paula are likely to seek your
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timeshares and the, you know, issues of British Summer
Time. I mean, there was lots of, you know, bizarre
things you wouldn't necessarily assume were in the
portfolio. So I would often find out what was in my
portfolio when I would receive correspondence that I was
being asked to answer, so clearly that was in my
portfolio, and then I would have these briefings but, by
the second week in the role, I had not had all of those
briefings.
This particular meeting, as an introductory meeting
with both Alice and Paula, obviously contained in the
annexes that was referenced in that briefing note some
background information about Post Office and, therefore,
this would have been one of the first opportunities for
me to really dig into what the priorities were.
I obviously knew that -- you know, referencing, you
know, my own experience as a constituency MP and the
wider political context, that the issues around closures
and security of the network were clearly going to be
significant but the other issues there, you know, the
specifics of Government contracts and mutualisation were
brought to me in that note, and in that half-hour
meeting I was able to explore that with Alice and Paula
to some extent.
If I can stop you there, that's what is in the note.
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support in this area.”
If we scroll over the page, we can see the various
areas that are likely to come up in your discussion with
Alice Perkins and Paula Vennells. Do you recall who
drafted this at all?
I mean, I don't recall. I would imagine the first page
would often have a named civil servant on it, that would
be certainly where I would go to look at --
Yes, there isn't on this one.
In which case, I don't know but I would imagine it would
have been the ShEx team. I don't know exactly who it
would have been.
Thank you. If we scroll down, we can see the various
areas. There isn't an area here that refers to Horizon
or complaints from subpostmasters or anything along
those lines. When you started as Postal Affairs
Minister, did you have any initial briefing in respect
of the allegations that were being made by
subpostmasters -- we'll come to a specific email a bit
later on but when you first started?
So this meeting was I think in my second week in the
role and I -- you know, I was still at that point having
briefings to get up to speed on different aspects of -
even -- to be honest, even being aware of exactly what
different things fell into my portfolio. So, you know,
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What's not in the note is any briefing on Horizon.
Yes, and --
Were you in those early days briefed on issues with the
Horizon system?
No, not in a sit-down briefing. There was a piece of
correspondence which you say we're going to come to, but
no, that was not separately briefed to me.
Were you aware that the Post Office prosecuted people?
I don't believe I was at that point. In fact, I think,
I probably wasn't until the following July when I was
preparing for the oral statement in the House.
We've discussed the difference between operational
matters and serious or strategically important matters.
Where would you see the prosecution of subpostmasters
fit between those two distinctions?
I think in the normal running of the business, of any
business, you would expect that, if there were concerns
about fraud, and so on, that they would -- that would be
undertaken and done so through the usual channels. And
my assumption would have been, of course, that that
would have been done by handing information to the
police and the Crown Prosecution Service, making
decisions in the way that would happen for any other
business.
So the very specific and unusual nature of what the
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Post Office were doing was not brought to my attention
and, indeed, even very -- as late as 2015, I was kind of
asking questions to be reassured or to be very clear
about the exact nature of that and was being told that
it was the same as any other private individual or
institution that could bring prosecutions. So I don't
believe that that properly reflects how unusual that
situation was but I also don't think I was given that
information accurately that explained that situation.
When you started, whose responsibility would it have
been to have given you that information?
I think that information should have been given to me by
the relevant Civil Service officials.
At that time, who would that have been?
Well, I mean, there was a team. I think Will Gibson was
the head of that team and there was obviously number of
Civil Service officials within that team.
Could we please turn now to UKGI00001458 (sic). This is
a letter from you to another Member of Parliament, if we
start on the first page, please. II'm sorry, this is the
wrong document. Ah, it should be 49, sorry.
UKGI00001459.
A letter to a Member of Parliament, and it says as
follows:
“Thank you for your letter of 20 August to Norman
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So that's the same day as the briefing that has been
prepared that doesn't mention Horizon. Can you recall
the circumstances in which this was signed, agreed by
you?
I received a box every evening and that had a variety of
maybe 15/20 different submissions for me to read,
a diary pack, which would have included the briefing
notes for the meeting I had the next day -- all of the
meetings I had the next day -- and then also there would
be any Parliamentary Question answers, and a stack of
correspondence, and so this letter would have been in
one of those correspondence folders. I would have
reviewed this letter and signed it amongst maybe another
15 or 20 letters. And, from the documents I've been
shown by the Inquiry, which were only recently made
available, in this perspective, then I asked for
a little further information on this because I thought
it was something which, you know, would require more
information, I imagine.
I don't have a memory of the exact -- what was going
through my mind in, you know, week 2 of the job, with
a massive box to be doing that evening, but clearly
I asked for a short note on the matter to bring me up to
speed.
Can you recall who drafted this letter?
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Lamb ..."
That's your predecessor?
Mm.
"... about the independent review by forensic
accountants, of a number of individual cases raised by
former subpostmasters, who raised concerns about the
Post Office's Horizon system with their [Member of
Parliament]. I am replying as this matter now falls
within my portfolio.
"I should first note, that Post Office Limited
continues to express full confidence in the robustness
and integrity of its Horizon system and related
accounting processes. Over the past 10 years, many
millions of branch reconciliations have been carried out
with transactions and balances accurately recorded on
Horizon, by more than 25,000 different subpostmasters in
total."
The next paragraph refers to the Post Office having
agreed to an external review, and it says:
"The external review of specific individual cases is
being undertaken by a firm of forensic accountants and,
to ensure impartiality, James Arbuthnot has reviewed and
approved the appointment. I understand the review
process is now under way and I have asked to be kept
informed of developments."
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No, and I wouldn't have known who drafted the letter
because, unlike the submissions that would come to me
that would have typically a civil servant name at the
top of them, the correspondence would just be in
a folder that would have the letter that I had to sign,
and often that would be clipped in front of the letter
that it was responding to.
So we've seen the briefing to you on the day before you
meet the Chair and the CEO of the Post Office, which
doesn't mention any issue to do with Horizon. We have
this letter of the same date. Is it odd that there is
no mention of Horizon or of the underlying issues that
are referred to here in that briefing for your meeting?
Well, I didn't think it was odd at the time. Obviously,
it was a half-hour meeting with the Post Office, and it
was the first time I was meeting with the Chief
Executive and the Chair. You know, there was already
lots to cover in terms of that meeting and it clearly
wouldn't be able to cover every single aspect of
everything to do with the Post Office.
And, obviously, what I was being told in this
letter -- often the information that you would get as
a Minister, as I say, you'd find out what was in your
portfolio by what letters you were being asked to sign
at the beginning of your time as a Minister, and you
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would take the information that had been put down in the
letter as, you know, useful information for you to be
aware of, and this was explaining, obviously, that there
was an external sudden review being undertaken, so it
looked like there was something being done about
an issue that had been raised.
It was not clear to me, at that point, that this was
a wide issue in terms of the number of people affected,
in fact it was saying that there was not a large number
of people affected and, indeed, that there was action
being undertaken. So I don't think that would have
seemed odd to me at the time.
Was it a topic that was raised by Paula Vennells or
Alice Perkins at your meeting the next day, the
involvement of Second Sight or --
No.
-- complaints by subpostmasters?
No, it was not.
Could we please turn to UKGI00001457. I think this is
the email you were referring to. It's an email from
Mike Whitehead of 4 October 2012. If we scroll down, we
can see that Mike Whitehead was in the Shareholder
Executive. Was he somebody who regularly briefed you?
Yes, he was. He was part of that team.
He has sent this to -- if we scroll up, it's an email
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issues referred to in the reply. This is now attached."
So it seems as though you've agreed that letter but
have asked for a note to summarise the position.
Yes.
He also says:
"We are also currently dealing with a [Freedom of
Information Act] request from an investigative
journalist relating to our contacts with [the Post
Office] and meetings with/briefings for ministers in the
context of the integrity and performance of Horizon."
We will come on to have a look at that as well.
Sure.
The briefing can be found at UKGI00018248. Sorry,
that's the Freedom of Information one.
Can we please turn to UKGI00001458. So this is the
attachment from the email to Mr Whitehead, I'm just
going to read to you a few passages from it. In the
second paragraph, about halfway through that second
paragraph, it says:
"Since Horizon's introduction, there has been
a small trickle of cases referred to Ministers from or
‘on behalf of former [subpostmasters] who have had their
contracts terminated by [the Post Office] for financial
‘discrepancies or shortages’ (falling within the range
of theft, false accounting or negligence) who have
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account that we will see a number of times today,
Swinson MPST; is that your private office?
Yes, that's my private office, it was an email address
that went collectively to all of my private secretaries
and then the relevant private secretary, who was
covering the particular brief would respond to whichever
emails were in their brief.
So although it has your name, that doesn't mean it's
an email to you personally?
No, indeed, I would not have seen emails to Swinson
MPST. I did not have email access until the very end of
my time as a Minister. Everything was done through
paper boxes.
Okay, and who was Claire?
Claire was one of my private secretaries. At that
stage, she was the Private Secretary who covered Post
Office matters but also, if I recall rightly, some of
the consumer and competition matters, I think. But
then, later on, she took on the role as the Head of my
Private Office after Emily Cloke left.
Thank you. Mr Whitehead says as follows:
“At a recent meeting with Jo, in the context of
having signed off the attached pdf reply to John Pugh MP
[and that's the letter we just looked at], she asked for
a short note summarising the position with the Horizon
22
claimed that there are systemic faults with Horizon
which have caused the losses rather than theft or other
financial malpractice by themselves or members of their
staffifamily."
Scrolling down:
"[The Post Office] has consistently defended Horizon
‘on the basis that the system has been in place for over
10 years; in a typical month Horizon conducts around
80 million customer sessions with 230 million
transactions across the system. This is delivered
through around 35,000 counter positions in nearly 12,000
post offices which perform weekly and monthly accounting
balances. Around £175 million per day is settled to
over 700 client companies who use [the Post Office] --
a substantial flow of data to and from organisations
with regularly audited accounts. Over its extensive
period of operation the system has proved robust.
"[The Post Office] cites the cases identified by
[ex-subpostmasters] where there is some kind of
allegation in respect of Horizon as being a minuscule
proportion of the many millions of accounting events
that subpostmasters have undertaken since 2000. [The
Post Office] believes that if there were any systematic
integrity issues within the system they would have been
evident over the past 10 years. Both the [National
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Federation of SubPostmasters] and the CWU that have
expressed full confidence in the system."
Pausing there, do you recall reading this briefing?
No, I don't recall reading it. I'm certain that I will
have done, having asked for it, and that looking at it
now, I can certainly say that this would have been
a reassuring note. It was saying that there was a lot
of subpostmasters, a lot of transactions, lots of big
numbers used there, making the case that there was
a tiny proportion, a minuscule proportion, it says, and
then also it explains that there is a process in place
to try to resolve it.
So it was definitely a reassuring message that was
being given and that it wasn't, therefore, going to be
something that was going to, it seemed to me, require
attention. As I say, it's not a memory that
I specifically have but I'm pretty confident from
reading it now that that will have been how I viewed
that note.
Does it reflect conversations that you had at the time?
I mean, I imagine so. I think the other thing that's
worth just noting is that this note does not mention
prosecutions. So it is in the context of subpostmaster
contracts being terminated, which I appreciate will
still have been a massive problem and very distressing
25
Could we now then move on to the document that
I just brought up on screen, which is the submission
relating to the Freedom of Information Request. That's
UKGI00018248. So this is from Mr Whitehead. Was
Mr Whitehead the author of that previous document we
looked at? I know he sent it to you.
I mean, I can't confirm that. I think it's a fair
assumption to make but I can't be certain.
Thank you. If we scroll down, we can see the summary.
It says there's been a Freedom of Information Request
from an investigative journalist:
[It] covers the Department's engagement with Post
Office Limited with regards to concerns and criticisms
from a number of former subpostmasters who believe that
Post Office's accounting system (Horizon) is responsible
for their contracts being terminated by Post Office
Limited. The Department has always supported Post
Office Limited's assertion that the system is robust."
It then refers to Second Sight having been appointed
and it says:
"Post Office Limited is confident that the
independent review will support their view that the
system is robust and fit for purpose. However, the
review has sparked some interest, including this
[Freedom of Information Request."
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for those subpostmasters. But it also doesn't suggest
a criminal prosecution level of this.
It goes on to say:
"Accordingly, [the Post Office] has consistently and
publicly expressed full confidence in the robustness,
integrity and accuracy of Horizon and long resisted
periodic calls from former [subpostmasters] for
an independent review/audit of the integrity of the
system. A lobbying campaign group ‘Justice for
Subpostmasters Alliance’ was established in 2009 and
claims a membership of around 100 members but details
only 14 specific [complaints].”
Then it goes on to talk about potential legal action
that was going to be brought. If we scroll down over
the page, as you say, there's reference over the page to
the Post Office agreeing to commission an external
review of a small number of individual cases:
“It was agreed that this review would be conducted
by a firm of forensic accountants.
Then at the bottom it says:
"In response to any enquiries to Ministers/the
[Department] about individual cases being put forward
for review, the replies explain that any cases should be
referred to James Arbuthnot MP for consideration through
their constituency MP."
26
If we scroll over the page, we can see the request
that was made for various copies of documents that
pertained to the integrity and performance of the
Horizon and Horizon Online system. If we scroll down to
paragraph 9, the proposal is to release 28 items of
information but to withhold 10 items.
Can you recall any discussions with Mr Whitehead
about this request?
No, this was a submission in my box, alongside many
others on that evening, on whatever date that it came to
me, that I would have read and responded to with
a decision.
Could we please turn to UKGI00013747. We are now in
November. Before we were on 23 October, so we are now
in the next month. This a letter to another Member of
Parliament in respect of their constituent and, again,
it starts off by saying:
“I have noted your constituent's concerns about his
experiences as a subpostmaster but should explain that
Post Office Limited is fully confident about the
robustness and integrity of its Horizon system and
related accounting process. Since the Horizon system
was introduced in 2000, many millions of branch
reconciliations have been carried out with transactions
and balances accurately recorded on Horizon by more than
28
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25,000 different subpostmasters in total.
“lam also aware of a small number of incidents
where subpostmasters' contracts have been terminated and
in some cases court action has subsequently been taken,
following the identification of financial discrepancies
and shortages. Neither I, nor the Department are able
to comment on, or intervene in individual cases
concerning operational and contractual matters."
Then it sets out enquiries that have been made with
the Post Office and, if we scroll down, we can see at
the bottom of the second page it says:
“It is worth noting that subpostmasters are
contractually responsible for all losses occurred.”
If we go over the page, it again says:
"Whilst, as noted above, subpostmasters are
contractually liable for all losses at their branch ..."
It ends by saying:
"Should you wish to suggest that Mr Patel's case can
be examined by the forensic accountants, I recommend you
contact James Arbuthnot's office to discuss its possible
inclusion in the cases being reviewed by forensic
accountants."
Can you assist us with who would have drafted this
response?
I can't tell you a name but it would have been somebody
29
servant from the Permanent Secretary's office agreed to
look at my correspondence for a week before I saw it,
and she concluded there was a big correspondence quality
problem in the Department, and then measures were taken
to deal with it. And I remember her saying to me "This
is not what you should expect. What you should expect
is that you get the letter, you quickly scan it and you
can sign it’.
So that information had been given to me to
recognise that, although clearly I needed to be aware
and sign the correspondence, that was not something
which there would be meetings held about each individual
letter or indeed that it would be something where
I would be expected to spend a very long amount of time
‘on each letter, nor indeed Would that have been
feasible.
Irrespective of the particular individual letter, the
correspondence we've been looking at all carries the
same kind of message --
Yes.
-- a small number of cases, trickle, et cetera. What
kinds of discussions at this point in time were you
having within your Department about the accuracy of that
information?
As I say, I'd raised general concerns about the quality
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within that team at ShEx, would be my assumption,
because the way that correspondence worked was that it
came in to the Department, was processed by the
Correspondence Unit, and they then sent it to the
relevant policy team to get a draft response, and it was
then sent to my private office for printing and putting
in my box.
Would you have discussed it with anybody before agreeing
it?
No, routinely my correspondence, as I say, would be
a stack every evening in my box, after doing all of the
rest of the submissions in my box, and so the normal
process would be that I would scan the letter and sign
it. And I think it's important to actually just make
that point. Early on in my tenure as Minister, I became
very unhappy with the standard of correspondence that
I was receiving. Frequently, there would be lots of
typos, letters that I would have to send back, there
would be sentences that were not finished and it was
actually very stressful because, of course, you know, it
was taking me a long time to go through my box and then
that meant I was having to see letters more than once
and so that just expanded the amount of time that had to
be spent.
And I actually escalated that. A senior civil
30
of correspondence, this was not specifically about the
Post Office team, that was in general sense to say
correspondence is important, it needs to be accurate.
I recall taking part in workshops for Civil Service
officials where I, you know, did a little speech about
how important correspondence was because this is people
writing to their MP, and then writing to the Minister
and this is an important part of our democracy and
therefore isn't something that should be left to the
last minute and come to me three months after somebody
has actually written a letter.
So that was, in a general sense, that message was
going out there but, as I say, in terms of specific
cases and specifically in terms of Horizon, at this
stage, it was not the subject of particular meetings.
When the correspondence came to me, it was clear
that there was a process in place with the forensic
accountants, Second Sight, and so it felt to me that
that was the appropriate place for these specific issues
to be investigated, where the expertise would lie.
I clearly wasn't going to be in a situation of being
able to pick through the details of individual cases and
come to a sensible conclusion about them nor would that
have been appropriate.
If we scroll up on to the first page ~- scroll down ~
32
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sorry, thank you -- to the final paragraph on that page,
it says:
"... [have made enquiries with [the Post Office]
with regard to [the particular case]."
Now, you're not expected to have made personal
enquiries but is it slightly odd that a Member of
Parliament is conveying what they're being told by Post
Office Limited, rather than being told to approach Post
Office themselves, for example?
So, I mean, obviously the "I" in that sentence is an "I"
which obviously relates to the wider Civil Service and
so, when I read this to sign it, I take the view that
the officials have gone to Post Office. And I mean
there's two ways of dealing with a letter like this.
You can have what we call our standard lines, where you
have some pre-agreed text on an issue, particularly for
those kind of postcard campaigns, where you get dozens,
and dozens, and dozens of the same issue, where you can
just give a pro forma standard line response that's been
agreed.
But, clearly, that doesn't feel quite appropriate
when you're dealing with individual cases like this and
so I probably would have considered that it was actually
helpful to get something that was more of a bespoke
response and, to do that, I think the way to do that
33
terminal with some screens. It wouldn't have been --
the thing I remember most from that visit, I have to
say, is the Post & Go equipment, which was quite new at
that point, a little bit like the self-service areas in
supermarkets, and so I remember thinking that was quite
novel and not being sure how it was going to be received
in post offices. But I am sure I did, you know, get to
look at a Horizon terminal briefly and will have seen,
you know, a screen with different computer options on
it, probably not the most exciting part of the visit.
It's meeting with the CEO. We've seen those letters,
we've seen a growing picture of complaints from
subpostmasters, issues with Horizon. Did that come up
in conversation at all?
I don't think so. At this stage, there had been some
correspondence but, as I've explained, that
correspondence is not something which is taking a huge
amount of time to deal with, and so the real
significance of this issue did not sink in for me at
this stage in my ministerial tenure about what was
happening with Horizon. I don't think the issue of
prosecutions had particularly been raised by this point.
For me, at this stage, it was definitely in the category
of there were some people who had some concerns, Post
Office being very robust that those concerns were not
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obviously would have been for them to go to Post Office
Limited. There were obviously different ways of doing
it. So when I was an MP and I was dealing with
constituency correspondence, you know, I would write to
agencies, you know, whether it was the Pensions Service
or the Department for Work and Pensions and then close
my constituent's correspondence and then get an answer
from that agency, and then send that answer with
a covering letter.
That would have been another way to do this but, in
this case, you know, they obviously were making the
enquiries directly but they've also clearly flagged that
they've gone to Post Office to ask about this.
Thank you. Could we please turn to UKGI00001534,
please.
I'm being asked if we'd could slow down in speaking,
if possible. Thank you.
Moving now to 12 November, it appears that you
visited the Post Office Headquarters and had a meeting
with Paula Vennells and Kevin Gilliland, and that
included, if we see in the first paragraph,
a demonstration of Horizon; is that something that you
recall?
I can't say I have a vivid memory of the demonstration
of Horizon, beyond potentially seeing a computer
34
well founded and that there was a forensic process to
look into them, which was reassuring.
Thank you. I'm going to move on now to the events
leading up to Second Sight's Interim Report and can
I please take you back to your witness statement on
paragraph 21. It's page 8. I'm just going to read from
paragraph 21 of your statement. You say as follows:
"My clear memory of first realising the possible
importance of the Horizon issues was a meeting with
Paula Vennells and Alice Perkins in which I was told
about the impending publication of the Second Sight
Interim Report. I cannot be certain about the timing as
I do not have access to my Ministerial Diary but it
would most likely have been in June 2013. I recall the
genesis of the meeting being slightly mysterious. It
was not in the usual cycle of my regular catch-ups, and
unusually, I did not have a briefing note for the
meeting in my diary pack for that day. I would not
typically meet Paula Vennells and Alice Perkins
together. I cannot recall many details of the
conversation, but do have a recollection that their tone
was quiet and serious as they explained the background
to the report. I felt that they were very keen to
reassure me that they were taking it seriously but
everything was under control, and I would receive
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a further update from them shortly."
Can you assist us with the description you've used
there, “slightly mysterious"; what exactly do you mean
by that?
Normally I would have a diary pack prepared for me for
the following day and it would have each of my meetings
set out with a note/information about what to expect,
similar to the one which we saw earlier about the
meeting that I had -- the introductory meeting in the
middle of September, and this didn't have that note. So
in my mind, I was like, well, what is this about? And
it wasn't clear from it being in my diary. So fine,
okay, I mean, I did my box that evening but I was
unclear as to what the purpose of this meeting was until
I was in the meeting, and that was slightly unusual, and
therefore slightly mysterious.
You say you didn't have a briefing note. Who would you
have expected to have produced briefing note for that
meeting?
So my understanding of the process was that policy
officials would produce briefing notes for any meetings
within their policy areas, so, in this case, it would be
the ShEx team, and then my Diary Secretary, who was part
of my private office, would each day collate, you know,
a front sheet with actually what my diary looked like
37
how this came to be but my private secretaries would not
have been in a position to be able to give me full
details because they would have been asked for, you
know, an important meeting. They might have been told
a line or two as to why that was important. But -- and
I'm sure, had I been in the Department when I read that,
you know, rather than being given it to go home in my
box, and I'd asked them, they would have then told me,
that this is about the Horizon issues.
But, as I was not physically with my private
secretaries when I was reading it, because I was at
home, then it wasn't clear to me what it was until I got
there.
Thank you. If we scroll down, there's nothing you'd
like to add to that paragraph in respect of your
recollection of the actual meeting itself, is there?
I mean, I obviously remember various conversations in
the run-up to the statement in early July. What's hard
for me is to distinguish what happened in each of those
conversations. So I had some briefings in my office
within Parliament, as well as in the Department, because
‘on the day of the statement I was in Parliament a lot,
and so I had a little kind of cubbyhole type office
within Parliament, which was so small that the officials
couldn't all fit in and get a seat, so people were
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and then all of the different pages in order in one
folder that would then be given to me as my diary pack
that, as I went about my day, my job during the day,
I would take with me and be able to discard each note or
each meeting back to my private secretaries as those
meetings concluded.
And that would just mean that I would -- and it
would only come to me the night before, so it would be
part of my box, but it would mean that I had, you know,
some brief awareness of what was going to be in the
meetings. Sometimes, depending on the size of my box,
I wouldn't actually get a chance to really read the
diary pack in detail until the morning, maybe when I was
on my way into the Department but, normally, I would
have information about the different things in my diary.
So focusing again on that word "mysterious", is it
surprising for you that your own team didn't provide you
with sufficient information before that meeting or is
your concern about the meeting itself?
Well, I mean, I think, now -- you know, within the
meeting it became clear that it was a serious issue and
they were being -- yeah, as I say, very serious about
it. I mean, I don't know whether it was -- what they
were happy to have committed to paper at that point,
whether officials knew -- I mean, I don't know exactly
38
sitting on kind of printer tables and somebody was being
sitting on an upturned bin while I was being briefed on
that.
So I have a memory of these telephone calls and
briefing meetings but I don't necessarily distinguish
what happened in each one of them.
The next paragraph says:
“lL also recall that James Arbuthnot was identified
as a key MP coordinating Parlimentarians on the issue,
and I spoke with him about the issue on 3 July 2013.
Following that call I asked one of my officials, Will
Gibson, to follow up on various issues James had raised,
‘one of which was the suggestion that they should speak
with Second Sight on my behalf.”
Just to clarify, what exactly is being said in that
final sentence there; is it that Will Gibson would
liaise with Second Sight or somebody else?
Yeah, I think it would be that Will Gibson would do that
and I think there is an email that was sent between Will
and possibly POL that -- around about that time, I think
to POL, following up on that issue. I don't know what
the outcome of that was.
So you're not aware of whether they, in fact, met or
whether there was an attempt to meet them that was
rejected, or anything along those lines?
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The Post Office Horizon IT Inquiry
I don't know. I think it's possible that there was
an attempt that was rejected but I haven't seen the
documents to give me confidence on what the outcome was.
I don't recall Will coming back to me with outcomes of
that meeting but, equally, it's possible that they did
meet and he used that as part of his information for
when he was briefing me on matters.
Thank you. The Second Sight Interim Report was produced
‘on 8 July 2013, At paragraph 23, you've described the
run-up to your ministerial statement being rushed or
very rushed. Can you expand on that, please?
So obviously the Second Sight Report, if you see from
the document trail, there were lots of emails going back
and forth around Friday, 5 July and, indeed, over that
weekend and, as explained before, I was not part of that
email address. I was receiving my information from the
Department in paper form, and so I will have gone up to
the constituency as usual, with my box, on the Thursday
night but a lot of things happened after that Thursday
night box that I will then not have seen until I was
back in the Department on the Monday and then many of
those things would have been in the Monday night box.
It was a very busy time because I also, on that
Tuesday when I made the statement, was doing two other
debates in Parliament. So I was responding to a debate
41
debate pack. I can't be certain that I received the
Second Sight Report, I might have done. I think it's
likely that I probably did but I can't be as categorical
about that and, as I say, it was in amongst a lot
briefing notes -- briefing material that I was being
given and it was -- you know, as a report goes, there
was lines to take given but there was, you know, all of
the stuff which has been since used ad nauseam by Post
Office about there not being any systemic problems with
the Horizon but, clearly, that was, for me, the first
time I was reading that and therefore that seemed
reassuring.
Do you recall reading the actual report at that stage?
No, I will -- I'm certain I would not have had time to
read the full report at that stage but I think it is
entirely possible that I will have scanned through it.
I have a memory of doing so, whether it was at that
point or whether it was perhaps after the statement,
I can't be certain. But my takeaway from scanning
through it was, you know, there was quite a lot that was
impenetrable but there was obviously the summary that
I'd received which, you know, seemed to tally up from
what I saw.
Let's look at the summary. It's UKGI00001695. Let's
start on 1.4, the summary is as follows:
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about consumer protection issues relating to gift cards,
people who had been -- lost money in that issue and then
there was a one-and-a-half-hour debate that I had to
respond to on zero hours contracts and employment
protections.
So there was a lot going on and I was therefore
receiving the information that had accumulated over the
weekend in my box on that Monday night, alongside two
other debate packs and, indeed, all of the rest of the
correspondence and other submissions that were coming to
me as well.
Can we please look at UKGI00001693. It's a note from
Peter Batten, who is within the Shareholder Executive,
5 July 2013. He is emailing your private office and he
says:
"Please see attached a short covering note setting
out the key narrative and findings of the draft Second
Sight Report, [the Post Office's] proposed next steps
and handling for its release on Monday, and suggested
lines to take. A scanned copy of the report ... is
attached."
Would you have received both the briefing and the
Second Sight Report at that stage?
On the Monday night in my box. I think I received --
but I definitely will have received the briefing in that
42
"[Second Sight] report that as part of the
investigation [Post Office] voluntarily admitted to
having identified two ‘anomalies’ that affected 77
branches (0.65% of the network) and 12 branches (0.12%
of the network) respectively. The report notes that
[Post Office] took action to rectify these anomalies
once they had been identified.
"On the question of the core Horizon function,
[Second Sight] finds that the system achieves its
intended purpose and concludes that they have ‘so far
found no evidence of system wide (systemic) problems
with the Horizon software’. Additionally, the report
notes that the Horizon system, which involves over
65,000 users ‘operates smoothly for most subpostmasters
and their staff all of the time.”
Were you aware at that stage that the finding
regarding system-wide problems was only an interim
finding?
I think I knew it was an Interim Report and that there
was -- obviously, as transpired, there was further work
that Second Sight were undertaking once the Working
Group was set up.
We then have at 1.6:
"With regard to the wider aspect of operation,
[Second Sight] is more critical citing the large number
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of interfaces with linked systems ... the complexity of
some processes ... and the perceived lack of training.
"Next steps
"Though [the Post Office] see the [Second Sight]
Interim Report as being unsatisfactory in many respects,
their current thinking is to welcome the report and to
commit to work with [Second Sight], [Justice for
Subpostmasters Alliance], James Arbuthnot and other MPs
in implementing those changes and improvements.”
If we scroll over the page, we have then suggested
lines to take. The "Suggested lines to take" are as
follows, the first is:
"It is not appropriate for the [Department for
Business] to comment on the details of individual
operational business issues for the Post Office such as
those covered in this Interim Report.
"However, [the Department] welcomes the interim
report's conclusion that there is no evidence of
systemic problems with the Horizon [system]."
We see in that first bullet point there, again, the
reference to an “operational matter". Now, this is
an independent report that's been commissioned by the
Post Office. We see there that it's being addressed by
the Justice for Subpostmasters Alliance, James.
Arbuthnot, Members of Parliament; is it odd that it's
45
to do differently. It did not, at this stage, strike me
as, you know, some massive, wide issue across the Post
Office.
Looking at those suggested lines to take, on reflection,
do you agree with those lines?
Well, I mean, having seen the details provided to me by
the Inquiry, I am staggered that I made my statement to
the House of Commons on 9 July and, on 15 July, Post
Office Limited received the memo, the Clarke memo, that
said that the credibility of their key witness was
fatally undermined. I mean, this to me at the time
seemed very reasonable.
I cannot quite square in my mind how it was possible
for -- as a minister, you know, as the shareholder -- us
to be responding, me to be responding on these issues,
being given this briefing and then that, you know,
bombshell. I mean, I'm not a lawyer but when I read
that document in the briefing notes, I -- you know,
I couldn't believe it. I don't think any -- you do not
need to be a lawyer. How could anyone read that
document and not realise that this is something which
demands urgent attention and yet where did that go?
I mean, well, we know that Paula Vennells was aware
that there was problems with an unsafe witness and she
never told me.
47
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still described as an "operational matter" or that you
can't comment on details of individual operational
business issues?
It didn't strike me as odd at the time. Clearly, it was
a matter which I needed to understand to the extent that
I was making a statement in the House to respond to the
concerns being raised by MPs. But the nature of the
report was going into quite a lot of detail about issues
of training and helplines, which, yeah, did strike me as
largely operational matters. It felt like the role that
we would play, as, you know, myself and the civil
servants within the business department who were
‘obviously acting as the shareholder, was to, you know,
have confidence that it was being dealt with properly,
that the concerns being expressed by MPs were being
addressed, and that's why that welcoming of that
collaborative approach was certainly, from my
perspective, very genuine, felt like the right thing to
do, you know, in speaking with James Arbuthnot, who
seemed not entirely happy but, you know, nonetheless
very much in a spirit of goodwill to be able to work
alongside Post Office.
I mean, that seemed to me like the best way to try
to address this issue and that Post Office had
recognised that there were some things that they needed
46
Let's stick now to the chain of events that's happening
at this particular time and let's have a look at
an email from Mr Whitehead on 8 July. That's
UKGI00001748. If we could start on page 2. I'll just
take you to a couple of documents and then we'll take
have our first morning break.
If we look over the page, please. Mr Whitehead
emails your private secretary:
“Following Jo's earlier telephone call with James
Arbuthnot, suggested briefing for the Whips' Office:
"Briefing for the Whips on James Arbuthnot tabling
an Urgent Question to obtain a Ministerial statement in
response to independent review by forensic accountants
... of Post Office Limited's Horizon computer system
which records all transactions conducted across the
entire Post Office Network.
"The issues covered by the review relate to a very
small number of ex-subpostmasters whose contracts were
terminated and were subsequently convicted by the Courts
for false accounting or, in more serious cases, theft
and fraud."
Just pausing there, by this stage you are aware of
the link to criminal prosecutions?
Yes, I was obviously aware of that in the briefing that
I was receiving for preparing to give the statement in
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the House of Commons, which included also briefing on
the disclosure requirements that Post Office Limited had
to conform to as well. I don't think I had yet entirely
understood quite how exceptional the Post Office doing
their own prosecutions were, but I was aware that they
were prosecuting.
Thank you. Then the next paragraph says:
"The report confirms that no systemic problems with
the Horizon system were found but also found scope for
Post Office Limited to improve aspects of its support
and training for subpostmasters."
If we scroll down towards the bottom of the page, it
says:
"[James Arbuthnot] is seeking to imply that the
Report suggests that new evidence might be found on the
basis of which some false accounting verdicts could be
challenged/appealed.”
What was your understanding of that at that
particular stage?
I mean, very little. I mean, there was -- obviously
James Arbuthnot was keen to make sure that the case of
his constituent could be included in what would be
agreed in terms of going forward, the looking at the
issues, and, ultimately, there was agreement that those
cases would be included. So I wouldn't -- I wouldn't
49
subpostmasters as Mr Arbuthnot appeared to suggest."
Was that a view that you had, that you shared?
So I think there's two different elements of that
sentence and I strongly agreed with one of those at the
time, and I think that's the one that really stuck in my
mind at the time, which was that it was not for
Government to intervene. And I appreciate this is not
an easy thing to hear but it was -- for those people
whose lives have been ruined -- but it was something
which I did feel very strongly when I stood up in the
House of Commons to make a statement that there is
a responsibility for there to be a separation between
the judicial process and the Government and it was
absolutely right for MPs to be advocating the case of
their constituents. It was the type of thing which, you
know, I would have done, for from my constituents too,
that was absolutely the right thing for them to be
doing.
But I felt, as a minister, I was in a different
position of responsibility, vis 2 vis the court process
and its independence, and that it would be very
dangerous territory to have a minister standing at the
despatch box in the House of Commons second-guessing or
throwing doubt on the decisions that the courts had
made.
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profess, you know, a strong, detailed understanding but
the issue that there were some subpostmasters that had
experienced convictions that also wanted to be involved
in challenging those was something which was brought my
attention in that note.
Q. There's then a further version of the briefing and that
can be found at UKGI00001749 and it looks as though the
briefing has been updated. We can see there, there's
still the reference on the third paragraph down that
"The report confirms that no systemic problems with the
Horizon system were found", but then if we scroll down
it says:
"During his conversation with Jo Swinson this
morning James Arbuthnot agreed that the report was.
better than expected and acknowledged that it did not
point to any wide-scale problems with the Horizon
system.
"However he believes that the report provides
evidence that some of the convictions of subpostmasters.
who plead guilty to false accounting were unsafe and he
would like the Government to intervene to offer some
form of redress or to reopen these verdicts.
"We would strongly reject the suggestion that it is
the role of either [the Post Office] or Government to
intervene to reopen the cases of individual
50
In this -- looking at this sentence now, I can see
that the POL is also included in that and I think,
looking at this now, I wouldn't necessarily agree that
it was not the role of POL to intervene to reopen the
cases. I think that, clearly, the disclosure duty is
clear that, if evidence is found, then POL should be
proactively giving that information to anybody who has
been convicted and their defence teams. So I didn't
clock that at the time. I did strongly agree with the
advice that I was being given about ministers being
careful, and I -- that weighed on me quite strongly.
I recall in the statement that, you know, I wanted to be
constructive and helpful but there was a line that
I felt it was important that I didn't cross.
MR BLAKE: Thank you.
Sir, that might be an appropriate moment to take our
first morning break.
SIR WYN WILLIAMS: Yes, by all means, Mr Blake.
MR BLAKE: Can we come back at 11.10, please?
‘SIR WYN WILLIAMS: Fine.
(10.57 am)
(A short break)
(11.10 am)
MR BLAKE: Thank you, sir. Can you see and hear me?
SIR WYN WILLIAMS: Yes.
52
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MR BLAKE: Ms Swinson, I'd like to turn to your witness
statement. I'm going to look at page 12, paragraph 25.
It says:
"The Inquiry has shown me an email chain between
Paula Vennells and other [Post Office] executives dated
6-8 July, in which Paula Vennells comments that: 'I have
also spoken to Jo Swinson again today ... who remains
supportive about our actions and relatively relaxed
about the situation’. I cannot recall details of the
specific conversation on this date and confidently
distinguish it from others I had with Ms Vennells on
these issues. I think it was a telephone call. On
another occasion I recall Ms Vennells explaining to me
in a tone of taking me into her confidence, with
something of a pained expression, that while it was
a sad situation, the reality was that some
subpostmasters ‘had their fingers in the till’ or
something to that effect. From the context of the
concerns being raised by James Arbuthnot and other MPs
I did recognise that there was a real need for [Post
Office] to deal with and resolve the issues especially
around training and support”, et cetera.
Now, it is very important for the Inquiry for you to
be as specific as you can on this. What is your best
recollection of precisely what was said?
53
diary, I don't know exactly the date -- and that there
was Clearly telephone calls. It could have been in that
June meeting, I would have been asking questions about
this, you know, querying it because, of course, MPs are
raising concerns on behalf of their constituents, and so
this was Paula Vennells saying to me that, yeah,
basically just some of these subpostmasters are guilty.
What role did that have in the thinking that you had at
that time?
At that time, the related context is around the numbers
that I was being told, so -- and all of the briefings
were about the millions of transactions, the -- you
know, not just the 11,500 branch subpostmasters but also
all of their staff, so the tens of thousands of Horizon
users, and that this is a minuscule, tiny proportion
and, of course, the figures I was being told of how many
cases at that point, you know, there was, I think, 14 in
the one of the briefings around this point. I think
later on, even in 2015, when I asked about which
criminal cases remained that would not then be mediated,
it was 37.
So those numbers were, you know, a smallish
proportion of a very large number and it didn't seem to
me to be impossible that there would be some fraud
within the Post Office but I would have thought it would
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Just to be clear, are you asking about the telephone
call that Paula Vennells is commenting on or the second
element that was a different occasion?
The second --
I'll be really straightforward, I'm not going to be able
to give you the exact words that Paula used, it was more
than a decade ago and so what remains in my memory is
the impression that it made, not exactly the words that
she said.
But what she was trying to clearly reassure -- well,
reassure me, but explain to me, was sort of saying that,
you know, although -- and as say, these are not words,
these are my impression of what she was saying -- that,
although these might seem to be lovely people, clearly
some of them are actually just at it, is what she was
trying to convey. And it was, as I say, that tone of
“We have looked into this and, you know, it is very sad
but that is just the reality, and so we have to act".
So that's what I recall from that, as I say, with the
caveat that I don't know the exact words.
Can you assist us with the timing: is it in a similar
period to 6 to 8 July?
I'm pretty sure it will have been because this was,
a point where I had the briefing meeting in June,
I think, June at some point -- without access to the
54
have been a small amount and that the numbers that were
being given to me seemed to be small amounts.
I did ask for specific statistics. I think this was
in response to reading the briefing pack because, having
seen the emails that my private office sent on the
morning of the statement of 9 July, I think I asked for,
you know, a breakdown of how many of the subpostmasters
had been convicted of fraud or theft or false
accounting, how many cases had actually gone to court
and the subpostmaster been found not guilty.
I asked for that breakdown as was detailed in that
email but I don't think it was actually provided. And,
I have to say, one of the things that I regret is that
I didn't specifically chase that. I mean, the context
of, you know, the number of questions I would ask in any
individual ministerial box, we'd be talking dozens
because, on each submission, I might be making four or
five questions so, you know, I do recall early on with
my private office sort of saying to them, you know,
probably in September or October, "Look I keep asking
you all these questions and responding to things, how
are we keeping track of this? Am I supposed to, you
know, keep a note of what I've asked?" And I remember
my Private Secretary, Head of Private Office, Emily,
saying to me, "Look, you just have to trust us that we
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follow these things up, that's our job, and you can't
possibly know all of it".
So, I do --
ll take you ~
-- think I asked for that data, which probably would
have been quite instructive to help me understand the
context of the balance of the numbers.
I'll take you to that email correspondence shortly.
Could we, before we get to that, please, turn to
FUJ00174749. This is an internal Fujitsu email, so it's
not a document or email you will have seen at the time,
but it refers to a meeting you had and I'd just like to
see if you recall anything from that. It's FUJ00174749.
We can see at the bottom half of that page, please,
it's an email within Fujitsu and it's referring to
a conversation with Paula Vennells:
"A very good conversation -- headlines are:
"Paula is very appreciative of our support (and
recognises how much we have been supporting them).
"[The Post Office Account] have made a choice not to
engage publicly in response to the story as it hasn't
taken off that much.
"Paula described herself as being ‘mildly troubled’
by it -- which is a change from this being a top
priority a week ago.
57
answer. So the way Parliament works, which as I explain
in my statement was not necessarily well understood,
even by the BIS Parliamentary Office, let alone by —-
I think you said this was an email from Fujitsu.
If James Arbuthnot wanted to raise a question in
Parliament as an urgent question, that would be up to
the speaker to decide whether or not that should be
an urgent question and that would be answered in person
at the despatch box and the only choice the Government
would have would be whether to answer it as an urgent
question or potentially, which is what we did, was to
pre-empt that by making a ministerial statement, which
in many ways is a bit more respectful to the issue
because it is the Government coming forward and also
actually was easier from logistical perspective when
I had three debates that day, to do, to have some degree
more of control about the timing because, obviously, not
turning up for the debate on zero hours contracts would
also have been disrespectful to Parliament.
So that needed to be managed. So yeah, it always
needed to be answered in person and this was just the
difference about whether we would wait for James
Arbuthnot to lay an urgent question or whether we would
make a ministerial statement.
In respect of the second part, "Lesley has been over
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[Post Office Account] are now looking at what they
need to do in response to the report eg increase
postmaster training -- this is a work in progress for
them."
Then it's this paragraph:
"A question is going to be asked in Parliament about
the report. Jo Swinson has chosen to answer it
personally rather than have a written answer (because
she believes she can kill it more easily by being there
in person). Lesley has been over at Parliament this
morning briefing Jo (not sure if Paula was also there)."
I'm going to break that final one down into two: the
first is the reference to you being able to kill it more
easily by being there in person.
Mr Blake, you showed me this for the first time this
morning and we had a discussion about whether the word
I used on seeing this was appropriate to repeat in the
Inquiry. Let's just say this is rubbish because that's
probably more appropriate language for the Inquiry
transcript.
I mean, it's -- that was not the case. I mean, it's
wrong on various levels. I mean, the most important
being that this was not about "killing it" but also it
just is -- it just doesn't actually make sense because
it wasn't my choice ever to be able to give a written
58
Parliament this morning briefing Jo (not sure if Paula
was there)", do you recall meeting Lesley Sewell at
Parliament?
Ooh. I know there were various officials there.
I mean, I mentioned my small Parliamentary office and it
was a bit crammed but it was a small office, there was
probably at least five or six different people in there.
I would have known in particular who the ones were from
the ShEx team, who I was familiar with from being
briefed by them regularly. It’s entirely feasible and,
indeed probably likely, that there were one or two
people from POL there, in terms of giving me information
to make sure that any questions that I was asking in
advance of the statement -- to make sure that I knew
what answers to give because I knew that I would be
asked lots of questions by MPs at that point. Clearly
having a to and fro to Post Office where we had to send
emails was not going to work with the urgency of the
situation.
Do you recall if Paula Vennells was there?
I'm pretty sure she wasn't there that day. I do recall
speaking to her on the telephone and so, yeah, I mean
I probably couldn't be 100 per cent on that but I would
be 95 per cent sure she wasn't there on that day.
25 Q. We have an email from Paula Vennells about what occurred
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‘on that day. Can we please have a look at that, that's
POL00099156. That's the top email, an internal email
but she says as follows:
"I will also send over a summary of Jo Swinson's
statement in the [House of Commons]. She was good and
fielded difficult questions well for us."
Now, at that stage, did you consider it your job to
be fielding questions on behalf of the Post Office?
When those questions were being posed in Parliament,
yes, because there was no alternative. Paula Vennells
could not stand up at the despatch box in the House of
Commons so any questions about the Post Office would
need to be fielded by me, in the same way if there were
questions about the Competition and Markets Authority or
the Equality and Human Rights Commission, or any of
these other bodies that fell within my portfolio:
Parliamentary Questions needed to be responded to by
a minister.
Can we now turn to UKGI00001852. This is the email
I think you were referring to earlier. If we turn to
page 2, we see at the bottom of page 2, we see an email
from Peter Batten at ShEx to Rodric Williams at the Post
Office and that's on 9 July at 9.39 in the morning:
"L left a voicemail about the Second Sight Report.
We are likely to have to make a statement to Parliament
61
either of you on this? (I know POL often drop me off
their copy lists -- I try not to take it personally)."
If we scroll up the page, a response from
Mr Whitehead says:
"Sadly they have a habit of dropping everybody off
when we seek ‘awkward' data. I have not seen anything
and my guess is that without a chaser, they'll
unilaterally decide we don't need it!"
Can you explain your understanding, at that
particular time, of difficulties getting information
from the Post Office?
It's not something I was aware of. This issue that Mike
is expressing in the email, which I think does speak
volumes, given what we know now, was not something that
was brought my attention at the time and, as I said,
I did rely on my private office and my officials to
chase the many questions that I asked. But I, you know,
do think this is pretty shocking and I think it's -- on
two levels. I mean, just on one level that I was
answering questions in Parliament and needed information
and, you know, needed it to be able to give good answers
to the people who were asking me questions, you know,
who, let's remember, are speaking there on behalf of
their constituents who have been affected by these
issues, right?
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this lunch time. Jo Swinson's office has urgently
requested information about the number of convictions.
Will spoke to you at the end of the meeting on Friday
about this, and it would be great if you could send over
your findings as soon as possible."
If we then scroll up on the page, it sets out the
information that you were requesting:
"How many of the [subpostmasters] have had their
contracts terminated?
"How many of the [subpostmasters] were convicted of
respectively fraud, theft and false accounting?
"In each category, how many of those convicted pled
[sic] guilty?
"How many (if any) were prosecuted but found not
guilty?"
If we scroll over the page to page 1, Susan Crichton
responds internally and says, "On to it", or in fact
still to the same chain. She responds to Will Gibson
and says:
"Will -- we are working on this, will get it through
to you [as soon as possible].”
That's 9 July. We're now at 10.36.
There's then an email on 16 July, so a considerable
time after, from Peter Batten at ShEx, and he says:
"Did Susan, Rodric or Martin ever come back to
62
So that, you know, that has an importance attached
to it. So if I'm asking for that information, it should
be provided in a timely way and it certainly shouldn't
be something that needs to be chased.
But then it's also problematic because, if this is
the experience that ShEx are having, that, I think,
points to potential deeper problems with what Post
Office is willing to provide and that would raise some
alarm bells, but it's not something that was raised with
me at the time.
In terms of timing, 8 August was then the first meeting
of the Working Group and I'd like now to take you to
September. Can we look at POL00196410. Could we please
turn to page 4. There's an email, if we scroll down,
from Alan Bates, to a number of people: Paula Vennells,
Susan Crichton, Angela van den Bogerd. You were copied
in, "swinsonmpstcorrespondence", is that your
constituency email account?
No, "mpstcorrespondence" -- so like the "Swinson MPST"
address was my private office, this would be the
correspondence office for my portfolio?
Thank you. This is the correspondence that the Inquiry
has seen number of times regarding Mr Griffiths:
"This afternoon I received the following email, it
is a prime example of the thuggery being exerted on the
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defenceless subpostmasters."
If we scroll up we can see on page 3, at the bottom
of page 3, Stephen Mosley MP says that he will forward
it to you. If we keep on scrolling up, Mr Bates
responds, and he says:
"I did send a copy of my email to Jo Swinson who
I have been in contact with over subpostmaster issues
since she was appointed. I have also met with her two
predecessors ..."
Then if we go to page 1, we have Mr Mosely's letter
to you, which says:
"Dear Jo
"Please find attached a copy of correspondence
recently received from Mr Alan Bates ... regarding his
concerns relating to the suicide attempt of my
constituent Mr Martin Griffiths, subpostmaster ..."
I think you said in your statement you don't recall
seeing this correspondence; is that correct?
I don't recall seeing it and I'm very sorry about that
and it’s clearly describing incredibly tragic events.
Who would have been responsible for bringing this to
your attention?
Well, in the normal course of events, correspondence
would come to me through the correspondence office in my
stack of nightly correspondence, and so that would be
65
No, not to my knowledge. I suppose it's possible
I could have been introduced to him just as I was
leaving if it had already been confirmed that he was
taking over from Will but I think it's unlikely.
Can we turn to UKGI00042677. This a Shareholder
Executive presentation from February 2014, so you would
have been on maternity leave at the time of this
presentation. It's a presentation the Inquiry has seen
before. If we could turn to page 6, please. It says,
‘on the left-hand side:
"There is a general feeling that Paula is not the
optimal person to lead [the Post Office] to deliver its
commercial strategy.
"Paula has not been able to establish good working
relationships with Jo Swinson.
"She has been unable to retain key staff."
Just pausing there, was that an accurate reflection
of your relationship?
I don't think it was. I'm not going to say there were
never any frustrations with the Post Office. I, you
know, was asking for more information on the speed of
Network Transformation to make sure that the future of
the network would be secure but, you know, I engaged
with Paula regularly and I felt we did have quite a good
working relationship, so I don't really know where that
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the normal way in which correspondence would make its
way to me. In some cases -- I think this is one that
would certainly qualify -- there would be an argument
for raising it maybe in a submission and bringing it to
my attention in a way that was more significant than one
letter among many in correspondence.
So is it your evidence it's likely that you would have
received it in a pack because it's correspondence from
a fellow Parliamentarian --
I mean --
- or you don't recall?
I think that is likely but I do not recall it and, of
course, the content is such that I think I -- you know,
I mean, my instinct is that it's the kind of thing that
you would recall. But I'm sorry, I can't give any more
detail than that because I don't have a memory of
receiving it.
Thank you. That can come down. Thank you. Now, in
terms of timing, 18 December 2013 to 30 June 2014 was
your period of maternity leave. As we discussed
earlier, in the meantime Mr Callard became the Head of
the Post Office Shareholder Team in January 2014 and he
became the Non-Executive Director on the Post Office
Board in March 2014. Had you met Mr Callard at all
before your maternity leave?
66
particular sentence has come from, and it was a big
surprise to me when I saw it come forward in the pack
and, indeed, when it was, I think, put to Alice Perkins.
"Performance as CEO and deliver of strategy plan:
"[Post Office] failed to deliver its 2010 strategic
plan ... She has shown a worrying lack of knowledge
about the detail of the new plan.
"Paula's people management has caused concern as she
appears unable to work with personalities and
approximate that differ from hers, and has failed to
build relationships with key Directors.
"Paula's performance as CEO has been questioned by
the [Post Office] Chair and by members of the Board.
"Engagement with Ministers and stakeholders
"Paula has not developed strong relationships with
stakeholders. The scale of change envisaged under the
strategic plan requires a visible, dynamic and
charismatic leader able to re-engage and energise the
relationship with stakeholders.
"This includes engaging with BIS Ministers. Over
the past year, Paula has repeatedly overpromised and
underdelivered."
You said in your statement that this wasn't
something you were aware of?
No, I mean, this is quite a shocking document to see,
68
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right? When you talk about what might be operational
matters and what might be strategic matters, I recognise
and I know this Inquiry has interrogated that
distinction, and sometimes there might be a degree of
grey area, whether something is operational or
strategic.
But "Is the Chief Executive fit to do the job?”
Really, pretty clearly, strategic, right? Right up
there with something that is strategic. And, therefore,
I just can't understand how, you know, the Department of
which I was a minister, has a slide deck which is
talking about the removal of the Chief Executive of Post
Office Limited without actually talking to ministers
about that. I mean, it just stuns me that that can be
happening.
I appreciate, you know, as I think Richard Callard
said later, there's an issue about at what stage you
might raise concerns with ministers and it probably
wouldn't be the first time you had an inkling that there
might be an issue but, at the point at which you're
creating a whole, like, PowerPoint deck about it,
clearly the time has come that ministers need to be
engaged in this discussion and I would argue not
actually just the person who was in my role as the
Parliamentary Under-Secretary of State, but this is
69
"We are starting to brief Jo more regularly on some
of the developments since her maternity leave. We will
begin this in May through catch-ups between Jo and
Jenny, as well as with private office.
"We then propose to do some high level one-hour
briefing sessions between Jo and each of her main
directorates in early June", one of those being Post
Office.
If we scroll up, please, there's an email from
Mr Callard to Peter Batten. He says as follows:
"See below, please can you start putting some
thought into this. Clearly we will have our priorities
to discuss, but you will have a better idea of what her
priorities might be than I will, as we will have to
address those as well. We might want to also think
about how many sessions we might need -- eg I want to
get her in the right place on Sparrow!"
Looking back at those early briefings, what do you
understand that to have meant? I know it's not you
that's writing it but if you reflect on the briefing
that you did ultimately receive.
I mean, I think the contrast is very illustrative here.
So we've got an email where Richard Callard is saying,
"I want to get her in the right place on Sparrow’ -- and
I didn't know what Sparrow was but obviously do now --
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something that which, at the Secretary of State level,
should have been discussed.
So I'm pretty shocked and obviously I was on
maternity leave, so I wouldn't have expected personally
to know this at this point and, just for context, about
November '13, a few weeks before I went off on maternity
leave, I received a submission about Paula Vennells'
remuneration, advising me that "We wish to retain her as
a Director and we don't think any downward pressure on
pay is appropriate at this point".
So just a matter of weeks after that, we've got to
this situation. I think that feels very strange and,
although I wouldn't have expected to know about this at
the time because I was on maternity leave, Jenny
Willott, who was covering for me, should have been
appraised, as should Vince Cable.
Let's move on to when you're going to be returning. Can
we please look at UKGI00002288, please. If we look at
the bottom email:
"An update on some plans in train to support Jo
Swinson's return from maternity leave. We expect Jo to
return to BIS/GEO around the end of June -- but will
confirm this once definitive. Jenny will continue as
Minister, taking all decisions, until Jo's return.
"Briefing Jo
70
and, if you contrast that with the note that I actually
received when coming back from maternity leave about
Post Office Limited, there is, I think, one sentence on
Horizon, which is incredibly bland. It is buried in
a paragraph called "Exceptional items’, it isn't even
highlighted as a risk, and it basically says that "The
Working Group is set up, progress is a bit slower than
we would have hope and Post Office is seeking assurance
on its position".
And, you know, that's a very kind of ‘nothing to see
here’ sort of sentence and so I just think that's
a really interesting contrast, right? You know, that he
was not actually giving me information about what was
happening in Sparrow, and we know he wasn't because now
when we look at the minutes of the Sparrow meetings,
it's actually the opposite of what I was being told.
So the Sparrow meetings were talking about reducing
the role of Second Sight, which was never mentioned to
me, even in the final conversations that we had nearly
a year later, "What about the closure of the Working
Group", right? It was never mentioned in any of the
subsequent points when, you know, knowing that Second
Sight were important to me, when I came back from
maternity leave, when I was asking questions about
Horizon in September, when I was preparing for the
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Westminster Hall debate.
I mean, if a civil servant knew that Second Sight's
investigation was important to me and that Post Office
were thinking of reducing their role, I mean that's
something he should have been warning me about that was
a problem, rather than hiding from me. And then we had
what they were planning to do with the Working Group.
Again, looking at the Sparrow minutes from that time,
around about this April 2014 period, where they were
basically saying that they were going to reinterpret how
they engaged with the Mediation Scheme within that
existing terms of reference and I mean, in a sense, when
you see that, it's no wonder that trust broke down and
that that all ground to a halt later that year. But
when that trust was breaking down, I was being briefed
by them, that this was because other people were trying
to extend the scope of the scheme.
I mean, it's Orwellian, frankly. They were saying
themselves that they were basically going to change the
way they engaged with the scheme and then told me that
other people were reinterpreting it or extending the
scope. So, I mean, to me, I just cannot understand how
a civil servant could operate in that way and I just
want to say, because I obviously have in my witness
statement been critical of Richard Callard, it is
73
general gist of our arguments.
"If you do have a word with Jo prior to the meeting
I would be grateful for any readout if you get chance."
So this seems to be a document that has been seen by
Alice Perkins at the Post Office, and it's not
a speaking note but it is some thoughts. We'll come and
look at the content but what is your general view of the
appropriateness of that being sent to your private
office for their comments before being seen or being
discussed with you?
So just to put this in context, this is about the issue
of the remuneration of a potential new Chief Finance
Officer and an amount of money that then would need to
be paid to the existing Chief Finance Officer to
encourage his exit.
And I referred just now to a submission that
I received in November 2013 which said we wish to retain
Paula Vennells, it also said we wish to retain Chris Day
as the Chief Finance Officer and we don't want any
downward pressure on their remuneration at this time
because they are both in place, and doing well.
That was just before I went on maternity leave and
then literally days after I returned from maternity
leave, having had the kind of briefing meetings where
I was brought back up to speed and no concerns raised
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totally not the experience that I had dealing with
dozens of civil servants across so many different areas
of my brief.
My general experience of dealing with civil servants
was that they were diligent, they were thoughtful, they
were respectful of Parliament, they cared about the
issues and how they affected members of the public --
Dealing with this particular individual --
-- and this was totally contrary to that.
Thank you. Could we please turn to UKG100002439,
please. We're now in August 2014. Six months have
passed since that presentation regarding the performance
of Ms Vennells. It's an email from Mr Callard to your
private office. He says:
"Claire
"Thanks for the discussion today -- very helpful.
I have attached the notes that I mentioned -- Alice saw
the first iteration, I have just sent this second
iteration to her and thought it might be expedient that
you see it sooner rather than later. I would be
grateful if you could flag any potential ‘red rags’ in
here.
"Just to be clear, this is not a speaking note as
such, it's too long for that. It's something just to
get thoughts in some sort of order but it gives you the
74
about the performance of the senior executives of the
Post Office, beyond a note in the briefing that said
they'd made some changes around HR, and so on, I then
received this note that says, "We would like you to
write to Danny Alexander to ask for exceptional
permission to appoint a new Chief Finance Officer for
Post Office Limited", on a salary which was more than
£500, and also to spend hundreds of thousands of pounds
‘on an exit payment for the existing Chief Finance
Officer, to which I, perhaps quite understandably, was
rather shocked because I'd never heard of a suggestion
that we needed to replace the Chief Finance Officer and
thought that would have been something that I perhaps
should have known about if that was the case, before the
point at which they were asking me to approach Danny
Alexander, who was the Chief Secretary of the Treasury,
for permission.
And the permission would have been needed because
the sums involved were of a level that needed approval
because they were exceptional in terms of the levels of
pay and, in the context, of course, at the time, we're
in incredibly difficult financial circumstances, the
Government making all sorts of really heartrending
decisions about budgets.
So my instinct was, you know, if I'm going to ask
76
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Danny Alexander for money it's probably not going to be
for hundreds of thousands of pounds for Post Office
Executives, when you've just told me the current Chief
Finance Officer is doing a perfectly good job.
If I could just pause you there, we're both going to get
in trouble with the Stenographer?
Okay.
Can I ask you to ideally keep your answers relatively
short and relatively slow, if possible.
Okay, so that was the context and I then had some back
and forth, when I responded to that submission, and
I said no, I'm not happy to send this letter to Danny
Alexander, and there was pushback and I think there were
some meetings with officials, I think that this was in
advance of a call that Alice Perkins was planning to
have with me that Friday.
Shall we look at the document itself?
Yes.
Let's look at it, UKGI00002440. So this is the
attachment to the email. I think your evidence is that
you didn't see this attachment?
No.
It in fact wasn't intended to be seen by you, it was
your understanding?
That's right and, indeed, they were asking my private
77
has been growing for some time, and has only recently
got to the point where it feels it needs to act in due
course.
“But this leaves the Board in a difficult place --
removing a CEO without a confident CFO capable of
holding the fort is a big risk. This makes replacing
the CFO all the more important, which explains the
Board's heightened concern and why Alice wants to talk
to you and Vince in person."
So very briefly, just to summarise, the proposal is
anew CFO because we want to replace the CEO and we
can't do that until we have a good CFO in place; is that
correct?
Yes, and that -- I mean, that is not what I was told but
that's what this note is arguing and this is clearly
after a period of time where they have done a full
recruitment process. So this is clearly at the end of
probably at least two to three months of them taking
action on this in terms of recruiting headhunters to be
able to search the field, conducting interviews, going
through all of those steps while not briefing me on it
and, even then, not telling me that they had these
concerns about the Chief Executive.
I mean, if you scroll down, he seems to posit
a question:
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office to sort of give them a bit of intelligence about
whether this would be a "red rag", presumably meaning to
a bull. And, you know -- I mean, given that it was the
Government's policy to have pay restraint in difficult
financial circumstances, you know, reading this now, you
know, it's very shocking that, you know, that this is
what they were trying to do.
And, indeed, that they hadn't been straightforward
in the note that they clearly sent me in July about why
they wanted a new Chief Finance Officer.
So let's have a read. It says:
"As you know, ShEx and the Board are clear the
current CFO is not the right person to take the company
forward given the challenges it faces."
If we skip down, it says:
"You know all that and on reflection we should have
approached you earlier. However, we want to explain to
you why we need to come and see you on this, and why
Alice and the chair of the RemCo want to meet you and
Vince.
"The difficulties on the CFO front have brought
forward the concerns the Board (and ShEx) has about the
CEO, which you need to be aware of, and which puts the
appointment of a new CFO in a wider context.
"The Board's concern over the performance of the CEO
78
"Why haven't you told me about the CEO before? Why
didn't it form part of the CFO advice?"
The bullet points there say:
"Removing the CEO is a very dangerous and
destabilising thing to do -- it's not something the
Board takes lightly so it needed to be certain before
coming to you.
“We are also conscious that the moment we tell you
about Paula, your relationship with her is irrevocably
changed.
"The Board has been monitoring the situation for
some time but until recently have felt that the balance
of risk pointed towards keeping Paula in place, given
the uncertainty and difficulty of appointing a successor
"There are a number of reasons why this balance has
now changed:
“Efforts to improve her performance have failed.
"The Board is increasingly frustrate with the lack
of progress ..."
Reference there to specific business areas like
Horizon and the strategy in general:
"This crystallised for the Board at the June away
day, where Paula very much sat back and let her team
lead -- she acts more like a [Non-Executive Director]
80
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than someone who leads from the front."
If we go over the page, please. There's a section
there on “What is wrong with the CEO?", and we see
there, for example:
"Issues like the Horizon Mediation Scheme and
Financial Services have required significantly more
oversight by the Board than one might expect as things
haven't been gripped
Then there's a section on why a new CEO would
require higher remuneration and then, "What have you
done to put measures in place to improve her
performance?"
"Alice has spent an enormous amount of time
coaching, mentoring and monitoring Paula.
"Important to note that Alice has significant
[Non-Executive Director] experience ... huge amount of
experience in knowing what can and can't be done with
both Paula and Chris.
"Paula responded to initial efforts to improve
performance ... but this has levelled off and is
ultimately about character and aptitude."
Mr Callard’s evidence to this Inquiry was that he
probably presented his case to you in accordance with
this note; is that your recollection?
Absolutely not, and it's something which I think I would
81
letter to the Treasury. So I don't know the chronology
of what conversations were then had with Vince.
Can we please then turn to UKGI00002472. We're moving
‘on a few weeks later now and this is a briefing for you
on Second Sight's thematic report, which has been
leaked.
I'll just read to you a few paragraphs from that:
"A report leaked yesterday is critical of [Post
Office's] Horizon accounting system ..."
In italics below that it says:
"It is important to stress that despite a year's
worth of investigation [the Post Office] and independent
investigators Second Sight, no systemic or technical
deficiencies have been found with the Horizon system."
If we scroll down, the same form of words is in bold
there, and it says:
"_. and the flavour of the report reflects [the
Post Office's] general concern that Second Sight has not
been as objective or forensic as they might otherwise
have been given their role."
It sets out "Further detail":
"The Mediation Scheme has been a significant concern
to [the Post Office] for some time. Whilst no
substantial issues with the Horizon system have been
found, their concerns include the following:
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have recalled because one point I would agree with from
that to note is that it's the kind of information that
would irrevocably change my relationship with Paula, and
the way in which I interpreted what she was telling me
and the assurances that she was giving me, and that, you
know, I obviously did engage with Paula on a regular
basis, and the assurances that she gave me, you know,
personal assurances, as well as in writing, on Horizon
actually were very important.
They were not received with the knowledge that she
was somebody who lacked "grip and pace" on the issue of
Horizon and, I mean, if this was the view of the BIS
civil servants, I mean, arguably probably fairly, given
what we now know, then it also I think raises questions
about how they were probing the information that they
were getting from Post Office Limited about Horizon in
general terms, if they felt that that had not been
properly gripped.
But this -- these concerns were not put to me.
I mean, I don't know exactly the chronology of what
happened. There were -- I do recall having a meeting
but I think it may have been in July shortly after the
submission. Ultimately, I was not happy to approve the
extra money but I do know that it went to the Secretary
of State, Vince Cable, who ultimately did write the
82
"They consider that independent investigators Second
Sight have ‘gone native’ and are unduly taking the side
of JFSA. This is supported by the fact that [Second
Sight] have admitted privately that they find it
emotionally difficult to opine against [subpostmasters],
regardless of the circumstances ...
"[Second] Claims in the thematic report (and the
individual reports on each case prepared by [Second
Sight]) have generally been unsubstantiated. For
example, [Second Sight] claim that power loss can lead
to data loss for the [subpostmaster], creating
discrepancies between cash accounted for in Horizon and
cash in the safe or till. There is no evidence to
support these claims.
"[Second Sight] do not sufficiently acknowledge that
the relationship between [Post Office] and
[subpostmaster] is one of principal and subcontractor
In the final bullet point on that page:
"A number of the reports written by [Second Sight]
in relation to individual cases have been rejected by
Tony Hooper, on the basis that the claims are
unsubstantiated. In such cases he has tasked [Second
Sight] with rewriting the report. It is not clear why
he has not treated this report similarly."
84
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If we go over the page, please.
"[Justice for Subpostmasters Alliance] has had
difficulty in accepting that some cases will not warrant
mediation, because the SPM was clearly at fault or was
victim of fraud by their own staff.
"Second Sight has continued to widen the scope of
the investigation rather than focus on the Horizon
system, prolonging the investigations and increasing
costs ...
"Meanwhile, whilst the Mediation Scheme continues,
expectations around possible compensation have grown to
potentially unrealistic levels."
We will see that this was sent by Mr Callard.
Perhaps we could turn to UKGI00007352, and if we start
on page 2. This was from your private office to
Mr Callard, and it says:
“The minister was grateful for this briefing and
commented that she found it very useful. I would like
to add my thanks for the quick turnaround!
"She had one question with regards to the following
paragraph: ‘A number of the reports written by [Second
Sight] in relation to individual cases have been
rejected by Tony Hooper ..."
That's the passage I just took you to:
"She'd like to know if we can ask him for more
85
reports. I'd previously been told that Second Sight's
Report's quality had been questioned by Sir Anthony
Hooper and, clearly, I think that was intended to reduce
my view of Second Sight's credibility. But I obviously
was picking up on the fact that he hadn't made any kind
of rejection of this report and, therefore, that might
suggest that he found it credible and I thought he was
a particularly important person to listen to on this
matter because he was somebody who had a great, you
know, career as a Court of Appeal judge and as somebody
who would be able to be objective, and also used to
dealing with events and cases that were complex, where
different issues were being put forward.
So I was being very questioning about that matter.
I would be keen, if it's possible, to just point to
one other thing in that briefing note, which at the
time, you know, if anything, I probably found reassuring
but, with the benefit of the subsequent information I've
seen by the Inquiry, is deeply troubling to me, which
was the point on the previous page that sets out some of
the cases that had been settled and mediated. So that
was in the note itself.
Shall we go back?
Yes, that would be really helpful.
That's UKGI00002472.
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details and wondered if the fact that he hadn't asked
the report to be rewritten meant that he had found the
report credible? She'd been keen for further
clarification on this. She commented that she found it
difficult to just accept [the Post Office's] analysis of
the report without evidence.
"For the future, please keep private office copied
in on any newsworthy developments. I think we were
fairly lucky that this story didn't gain much traction
and Jo wasn't asked to comment. It is really important
that we are aware of these kinds of events so that Jo
feels prepared and sighted on issues within her
portfolio.”
So we've highlighted two paragraphs there. Let's
start with the first of those paragraphs. Can you
assist us with what your concern was?
Well, I mean, this is one of the submissions where
I really so wish that my handwritten notes had been
preserved because, reading between the lines of the
private office email, I was not best pleased to see this
particular thing. I mean, obviously we've got the nice,
diplomatic private office bit at the beginning, saying
"It was very useful but here's the real question and
you've got to keep us informed in the future”.
So, you know, there was that paragraph about the
86
It was on the second page. So this paragraph that
starts:
"In those cases that have been mediated or settled,
POL considers it should have conducted itself better
operationally, but it is important to stress that these
are not system related."
I think I would have taken some comfort from that
fact, that the Mediation Scheme was, you know, finding
that there were issues but they were not systemic or
showing wider problems.
But when I look at the Sparrow minutes from April,
where it is minuted that they should accelerate the
specific cases that are not thematic because it might be
used to well to show the Minister, I mean, I consider
that that is, you know, a premeditated manipulation of
the Working Group process, specifically designed to
reassure me that there isn't a problem, by presenting
cases which are not representative, as one imagines in
anything like this, there might be some simpler cases,
by presenting those as representative of the vast number
of subpostmaster cases.
And -- I mean, to me, that just feels duplicitous to
actually set out to prioritise those cases so that they
can then pretend me that those are representative. And,
I mean, there maybe was a case for, you know, making the
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simple cases go first, to build everyone's confidence in
the scheme and, you know, get some cases done, but to
show them to me as if they are representative, as has
been presented in this note, I mean, as I say, again,
just feels to me the opposite of what civil servants
should be doing and the opposite of what my general
experience was of dealing with civil servants.
Thank you. If we turn back to the email chain, then.
That's UKGI00007352. I'm going to ask you about the
second of those bullet points that we looked at --
sorry, the second of the highlights that we looked at.
So that's page 2 at the bottom of that email:
"For the future, please keep private office copied
Was there a concern at that stage about the level of
information that you were being given?
Yes, I think that the genesis of this note, and the
reason why my private office is thanking them for the
quick turnaround, was that it was one that didn't come
from them to us, as would often be the case and, indeed,
you know, from the earlier letters I signed, that
I would be regularly updated on progress with the
scheme, we would have anticipated. But, instead,
I think this was in response to some media reports of
the leak of the second -- Part Two of the Second Sight
89
ask for the thematic report to be rewritten does not
suggest that he found it credible.
"Given the high number of objections that the Post
Office has flagged about Second Sight's thematic report
... itis perhaps unlikely that any report will satisfy
all parties."
Then it's the final sentence there:
"It is not, at this point in time, appropriate to
ask Tony Hooper for more details about his views on
a report that is still confidential from the perspective
of the Working Group."
Were you told this at the time?
I'm sure this will have been relayed to me, not
necessarily with this full email but possibly in a cover
note from my private office. And I think -- obviously,
there was a confidentiality issue, I could appreciate
that, but I had thought it would be very helpful at this
point to get the views of Sir Anthony Hooper because of
his objective and independent position. Clearly there
was strong pushback against that at this point from
ShEx.
You described it as pushback, looking at that final
sentence, to be told that it's not appropriate to ask
Sir Anthony Hooper for more details. Would you have
understood that formulation of words to have itself been
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Report, that went to the Working Group members and so,
you know, in response to that, myself or my private
office have then asked for a note.
So yeah, that did raise a concern and, very firmly,
officials were being told by my private office that they
needed to be more on it, in terms of making sure that
I was abreast of what was going on.
Thank you. If we turn to the response from Mr Batten on
the first page, from the Shareholder Executive, he
address the point about why hasn't Sir Anthony Hooper
rejected this. He distinguishes between what were the
case reports and what is the Second Sight thematic
report. If we scroll down it says as follows:
"The report that Richards email referred to has
become known as the ‘thematic report’ and the intention
had been that it was produced as a generic reference
document for use during the mediation process. To be
clear, although the Working Group can recommend a case
for mediation, it plays no role in that mediation, which
is between the applicant and the Post Office as the two
involved parties. There is no role for Tony Hooper in
the mediation process either. ShEx officials understand
that the mediation process does not involve the Working
Group, Tony Hooper has taken the view that Thematic
Report is outside of his remit. The fact that he didn't
90
appropriate?
I think, in the normal scheme of business, then that
would not usually be used, but I think the difference
with the Mediation Scheme is that you were dealing with,
you know, a very formal process, the CEDR have
guidelines about how it operates, it therefore was not
something that was totally familiar to me and I could
totally appreciate that there might be some boundaries
about at what point, you know, it would be appropriate
to speak to, you know, the former Court of Appeal judge.
I mean, I would note I did ask to meet Sir Anthony
Hooper a couple of months after this particular point,
and he declined to meet with me. And, in a sense, that
decision that he made rather reinforced the point that
I was being told about what was appropriate and where
that ministerial intervention could be, you know, to
what extent that was possible.
I obviously put a lot of store in Sir Anthony
Hooper's view of what was appropriate, as somebody very
esteemed with a lot of experience to be able to navigate
those boundaries.
MR BLAKE: Thank you.
Sir, that might be an appropriate moment to take our
second morning break.
25 SIRWYN WILLIAMS: Certainly.
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MR BLAKE: Can we come back just after 12.15, so shall we
say 12.177 Thank you very much.
SIR WYN WILLIAMS: By all means, yes.
MR BLAKE: Thank you very much.
(12.07 pm)
(A short break)
(12.17 pm)
MR BLAKE: Thank you, sir. I'm going to now turn to
A
preparation for the Westminster Hall debate. Can we
start with UKGI00002764. Thank you. This is a briefing
that has been prepared, and we'll come on to a question
that you ask about this briefing.
One of the questions that is put forward there --
sorry, it's zoomed out on my screen, I don't know if it
has on yours as well?
Yes, it has. My eyesight is not quite that good.
SIR WYN WILLIAMS: I haven't got it on screen at all,
Mr Blake.
MR BLAKE: It's just coming, sir.
‘SIR WYN WILLIAMS: Fine.
MR BLAKE: Sir, the second those questions, if we scroll
down, please:
“If it's not a Horizon issue that is causing the
problem, what is, 140 subpostmasters can't be wrong?"
The proposed responses are:
93
session. I put the submission, speech, [question and
answer]
I think that's the question and answer document we
have just seen.
Yes.
'... and Hooper letter to Jo overnight and she had some
comments/questions."
If we look at the Q&A, the question that's
highlighted is one of those that I've just taken you to,
which is "Why did the Post Office agree to incorporate
convicted cases", and it's the reference there to
disclosure duty. It says as follows:
"Jo feels like she needs a bit of clarity on this
element of the legal process, another one to chat about
today.”
Can you assist us, did you get that clarity?
Yes, I definitely got more clarity. I think I now have
severe questions about the accuracy of that but I felt
when I read this Q&A document that the phrase "There is
no doubt in my mind that it is being particularly
vigilant in this regard" was a strong phrase and,
therefore, it stood out to me as potentially reassuring
but I felt that, you know, in order to have confidence
in that phrase, as I was being encouraged to say this -
because the Q&A document, just so that people can
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"140 subpostmasters is less than 0.03% of the total
users of Horizon -- there are thousands of other
subpostmasters who have not made a complaint."
Reference there to:
"... investigations so far show that a large number
of the problems were caused by how the subpostmasters
themselves were using Horizon."
Over the page, please. If we scroll down to the
second of those questions, there's a further question:
"Why did Post Office agree to incorporate convicted
cases into the scheme if it knew it wasn't going to
mediate?"
One of the proposed answers there, bullet point 4:
"Post Office is, however, under an absolute duty to
immediately disclose any information which might
undermine the prosecution's case or support the case of
the defendant and Post Office has done so where
appropriate. There is no doubt in my mind that it is
being particularly vigilant in this regard as it carries
out its investigations."
If I could now take you to the covering email,
that's UKGI00000916. Thank you. It's an email from
your private office to Mr Callard and it says:
"Hi Richard,
"To be aware ahead of this morning's briefing
94
understand, is, you know, in a Westminster Hall Debate
that is an hour and a half long, you don't know exactly
what's going to come up and you have to respond to all
of the issues or as many as you possibly can that are
raised in the debate. And so the Q&A is to help you be
able to then have your answers ready to be able to, if
you like, you know, pick and mix from the different
questions that come up, in addition to any speaking
notes.
So it was drafted with a view that I would be able
to say those words and I felt that if I was potentially
going to say those words, I needed to have a little bit
more confidence in “particularly vigilant". On a basic
level that the Post Office Limited had this legal duty
to immediately disclose information and was complying
with that duty felt uncontroversial, because that's what
you would expect of any institution or public body, that
they would comply with their legal duties, but
“particularly vigilant”, I thought, yeah, well, that's
good, but what is this particular vigilance?
Now, I had a face-to-face briefing, as would be
common with any of these debate preparations, where
I would sit down with officials in advance of the
debate, and that was having read the debate pack and
then, rather than going through everything, we could
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just focus on the parts that I felt I needed to
understand better, and this was one of those.
Just pausing you there, who was that meeting with?
Definitely would have included Richard Callard, I think
it's likely it would have also included one or two other
Officials from that team. I don't think anybody from
Post Office Limited would have been there, that wouldn't
have been my expectation, but I can't be categorical on
that part.
What was said in relation to that passage that you had
concerns about?
So my memory is of being reassured. Now, I cannot tell
you exactly which words were used but I know obviously
that there had been the Altman Review, so I think itis
likely that I was reassured by being told that a QC had
examined the cases and looked at them, and there also
had been -- although I don't think I was briefed about
it specifically -- the Deloitte review.
So my memory is of being reassured that independent
reviews had been done that sounded very impressive and
thorough and comprehensive. While I can't recall
exactly which words were used, I expect that those would
have been the ones that had been referred to, if not by
name, then description of what they had done.
Thank you. Could we please now turn to UKGI00002837 and
97
"Not surprising re decision not to share the
speech."
Just looking at the distribution list, at this stage
we have Belinda Crowe and Patrick Bourke, both from the
Post Office, copied in to this distribution list. He
says, for example, at number 4:
"[Second Sight] probably need permission from the
Working Group. They have gone native but I think Jo
could possibly commit to asking Tony about it at the
risk of putting Tony in a difficult place.
Belinda/Patrick, could we have a view and a line
please?"
Number 5:
"Pass, over to POL. I know they are, or were,
a prosecuting authority but if there has been a theft or
fraud and it's in the public interest they have no real
choice. Otherwise what's the deterrent? Anyone could
put theft down to ‘the system’. Belinda, could you do
a line please?"
Is it odd that two employees of the Post Office are
in this distribution list and asked to comment within
a distribution list that includes a minister's private
office?
I think, in the first line there, it says, "[Copy]
Belinda and Patrick for expediency", so I suspect
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start at the bottom of the first page and into the
second page.
We have an email here from your private office to
Mr Callard, 16 December, and it says:
"So James [I think that's James Arbuthnot] no longer
plans to share his speech with us ahead of time as
apparently it is very inflammatory and he is worried
about putting in an email ..."
It says:
"Him and Jo had a quick catch-up in which he
‘outlined his main ‘asks’. I understand you've got
a packed day tomorrow but grateful if you could ask [the
Post Office] about some of those as Jo will need to
respond in her speech and would be good to know how warm
she should be to those asks."
We see there, for example, number 4 is:
"He'd like Second Sight to do a briefing for
[Members of Parliament] on the scheme and its progress.
Jo would like to commit to asking Tony Hooper about
this. What do you think?"
At number 5:
"He would like us to ask [the Post Office] to stop
acting as a prosecutor on these cases.”
If we turn to page 1, we have response from
Mr Callard:
98
that -- I mean, I do think it's slightly unusual.
I think the thinking, it looks like, was the debate is
‘on Wednesday, the 17th, this is the Tuesday morning,
therefore there is some quick turnaround required and so
it's for that reason. So, I mean, I'm less -- looking
at that now, I'm less, you know, appalled about that
particular aspect than accepting what POL say without
question, particularly in the context of what we know
was being said about whether or not there was grip on
the Horizon issue at the senior levels within POL.
So asking POL for their view, you know, on some
issues where they might only have the information, maybe
this isn't the best way for it to be done but the really
important thing should be civil servants, you know,
probing and, you know, making themselves confident that
they have all of the information that they need, and
that they are doing so with a degree of, you know,
critical assessment of analysis of what they're being
told.
Does this email reflect that?
No, I think this reflects a very cosy relationship.
Thank you. The Westminster Hall Debate was on
17 December, so the day after this email. We don't need
to go into what was said at the debate but do you think
you were appropriately briefed for that debate?
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At the time I felt like I had the information I needed.
I would have much preferred to have been able to meet
with Sir Anthony Hooper; I was very disappointed that
that could not happen. I did receive a letter from him
which I was able to refer to in the debate with some
basic numerical information but that was
a disappointment.
But knowing what I know now, I was absolutely not
properly briefed for the debate. You know, at that
point, Richard Callard knew from his presence on Project
Sparrow that there had been moves afoot for eight
months, by that point, to reduce the role of Second
Sight, which had never been mentioned to me. I mean, it
should have been mentioned when I returned from
maternity leave, it should have been mentioned to me in
the autumn when I was being briefed on this but, you
know, even if it hadn't been mentioned then, it
absolutely should have been mentioned to me when I was
preparing for a Westminster Hall Debate on this issue,
whereas, you will see from my comments, you know, I was
still, and remained, and was of the view that Second
Sight's Report on that process was incredibly important,
and I referred to that in my remarks in the debate.
Can we turn to UKGI00002896. By the 22 December, you
have received a letter from Alan Bates, and he raises
101
on it, despite the run-up to Christmas. Immediately
after the debate, I had had a -- as would normally be
the case -- a huddle, if you like, with my officials to
try to agree some next steps and one of the particular
issues that I had -- or ideas that I had suggested was
that we should extend an offer to MPs who had just been
questioning me and making their points forcefully in
a debate, that we should offer it to them to be able to
be involved in being privy to the information in the
Working Group and the mediation process, obviously for
their specific constituents and obviously only if that
specific constituent was happy with that situation.
And, you know, my understanding from that huddle
after the debate was that this would be taken forward by
Post Office Limited, in terms of them writing to each MP
about the issues raised and making that offer.
I mean, I remember that I had chased it in early
January, I think on 7 January --
Let's me take you to January.
Sure.
Let's move to 7 January, UKGI00002920. The bottom
email, I think, might be the one you're referring to and
it's an email from your private office to Richard
Callard:
"Jo was asking me what the timeline for getting
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concerns in the first paragraph. He says:
"Following that debate I thought I should write to
you once more to offer to meet with you to discuss the
issues involved with this matter from the perspective of
those it has affected, rather than those who seem to be
so desperately tying to keep the truth from you."
Can you assist us with those who advised you, what
their general approach was towards letters from Alan
Bates?
Well, their general approach was to draft a response.
I would often only see the letter when a draft response
had been put together, and those draft responses --
I mean at different times during my tenure as Minister,
you know, would be either more or less sort of helpful.
So in the early part of my ministerial role, there was,
you know, the Second Sight Report underway and then we
had the Working Group recently having been set up, so
there was some positive sort of engagement happening.
And I think, by this point, it was much less
positive in terms of the drafted reply and, indeed, that
was delayed in being sent because the follow-up from the
debate did not happen, in my view, in anything like the
way that it should have done.
We had a debate on 17 December, you know, Sir Alan
Bates wrote a letter on 22 December. You know, he was
102
advice from [the Post Office] on the next steps
following the Horizon debate would be."
The response is above.
"... things are in train, for example:
"[Post Office] are preparing a line-by-line rebuttal
"We are liaising with [the Post Office] to write
a letter to MPs who attended the debate ...
"We are also seeking to prepare a 'mythbusters' type
document ..."
Then:
"There is a Horizon Board subcommittee at Post
Office on Monday which I am going to, which will plot
out the way forward ... and we will update Jo next week
when we see here.”
Can we please turn to UKGI00003007. We're now on
15 January, so another week has passed. This is
an email from Mark Davies, who is the Head of
Communications at Post Office, emailing your private
office, and he says:
"I am writing to send you a note, attached, setting
out the Post Office's detailed response to the
allegations made by a number of MPs in Parliament during
the Westminster Hall Debate on the Mediation Scheme in
December. You may of course wish to table this in
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Parliament. Subject to your view we will also publish
this response on our website.”
Now, I asked you earlier about an email where
members of the Post Office were copied into
a distribution list with your private office. Is it
usual for a Head of Communications from a company like
the Post Office to be emailing your private secretary
and to suggest that you may wish to table something in
Parliament?
I think sometimes people from Post Office Limited would
contact my office if they were sending a briefing note
or information. I can see that they might do that. The
Director of Communications, perhaps more unusual. But
I think this is probably in the context of me knowing
that a note was being created by Post Office, you know,
in response to the debate. So I mean that's not
particularly concerning to me. It's a formal email.
What was concerning to me at the time, I mean
I was -- I was actually pretty furious, that -- I mean
this is 15 January. The debate was on 17 December,
right? And, you know, like most of us, okay, yeah, took
Christmas Day off and had some time with the family but
we're working hard. Sir Alan Bates was working hard
sending a letter on 22 December, and the fact that Post
Office hadn't, you know, pulled their finger out to get
105
were right and they had a very strong case against the
subpostmasters, that that information being presented to
those MPs, some of those MPs would say fair enough,
actually, I see your case; or that would not be the case
and so the MPs would be able to respond with even more
confidence that, having objectively looked at it, that
that wasn't, you know, what Post Office was saying was
wrong. So that was why I thought that was
a particularly important intervention.
Let's turn to your response to Mr Bates, and that is
UKGI00003111. So we're now on 28 January.
If I could read just from the first big paragraph on
the first page, it ends:
"The system processes 6 million transactions nearly
every working day ..."
The same lines that we've seen previously: 500,000
users, et cetera. At the bottom:
"With regard to your point about Post Office ‘taking
control of the scheme’ and withholding information, it
would seem to me that Second Sight have spent more than
two years investigating these cases."
It's rather dismissive in tone, would you agree with
that?
It clearly has, quite a lot of information but you're
right that quite a chunk of that is information that was
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this response sorted quicker than, basically, four weeks
after the debate felt to me to be, you know, ridiculous.
And I was -- I remember actually I think it was couple
of days before this, you know, I vividly remember a kind
of conversation where I was basically told that the
letter still hadn't been sent and I couldn't really
understand it.
I just want to explain also why I was so interested
in the concept of MPs being able to see the details that
were --
If you could explain quite briefly because we are
slightly out of time.
Okay. So one of the challenges here was trying to work
out where the truth lay. So I just had a Westminster
Hall Debate, where MPs were forcefully putting forward
points on behalf of their constituents, and receiving
an entirely different story from the Post Office. And
that was very difficult for me. I couldn't go into each
case and start looking through spreadsheets and try to
work out -- you know, I didn't have the skillset to do
that -- and try to work out who was right and who was
wrong but it was clear that they couldn't both be right.
And I did think that MPs being in a position where
they could at least be privy to that information would
result in one of two things: either, if the Post Office
106
used in previous circumstances and it's definitely not
taking the letter as seriously as I think required, now,
looking at it from what I know.
Are you aware of who drafted that letter?
I mean, I don't know exactly. I would imagine that it
would have had final sign-off by Richard Callard. It
may well be that one of his team produced an earlier
draft.
Knowing what you knew by that stage, do you consider
that this was an appropriate response to have sent?
Well, knowing at the time, you know, what I should have
done, is agree to the meeting with Sir Alan Bates.
I really regret that I did not do that, and I'm sorry
about that.
Why did you not do that, very briefly?
I was being advised not to, from the perspective of the
Working Group, you know, confidentiality and different
participants and, as I say, the -- Sir Anthony Hooper
declining to meet with me reinforced that perspective
somewhat. And just, you know, on a personal note, I'd
recently come back from maternity leave. The same
number of waking hours -- previously, I spent almost
every waking hour working, either in the ministerial
brief or in the constituency, and I now had some
additional responsibilities in my waking hours that
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needed to be fitted in, so additional meetings were not,
you know -- pushing back on taking more meetings than
I was being advised to do was not really top of my
agenda but I should have done so and I do regret that.
I'm going to move on now to the termination of Second
Sight. At paragraph 74 of your witness statement --
I don't think we'd need to bring it up on screen -- you
reference to a table being shown to you by Mr Callard by
that. If we could bring onto screen POL00102169, in
your statement you said you hadn't seen a copy of that
table. This is a document that would have been provided
to you subsequently to your statement; is this the
document that you were referring to?
I can't be certain but not least because it was waved in
front of my face, rather than something that I had to
look at overnight in a box, but I think it's certainly
quite possible that it could have been.
So I think in your statement you said you had no idea of
the risks involved in relation to ending the Mediation
Scheme. This is a document that addresses risks but
you've described it as something that was waved in front
of your face. Can you briefly assist us on what you
mean by "waved in front of [your] face"?
That we were in a meeting, a verbal discussion meeting,
and I think, as I say in my statement, Richard Callard
109
systemic issues with the Horizon system that could cause
these discrepancies. Rather, in most cases, that have
been investigated, the discrepancies appear to have been
caused by human error.”
If we go over the page, please. We can see here,
this is the hidden contents, so these are the comments
in comment boxes on the draft, and it's in relation to
that first part that I took you to, the part about
seeking your agreement. The comment there is "Are we
seeking her agreement?", and Mr Callard says:
"Probably not at this stage. Think this is more of
a sighting submission, and if she objects she would no
doubt say. And it's not her scheme.”
What is your view on that?
They should have sought my agreement. It was a very
significant issue and a very significant change, and
this draft document on 25 February, which was ultimately
sent to me on 4 March, was markedly different from what
finally was sent to me. So --
Perhaps we could scroll down over to the next page. We
can see some passages that don't ultimately appear.
Paragraph 9, I think you've highlighted in your
statement where it says:
"The advantages of this approach [that is mediating
all cases remaining in the scheme and releasing Second
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said that he shouldn't be showing me this but he briefly
did show me a document and he was -- yeah, giving the
impression that he was being extra helpful by showing
me, you know, additional information.
It doesn't, having looked at it now, it doesn't talk
about the risks of removing Second Sight. That was not
the way in which it was presented to me in that meeting
or subsequently in the documentation that I received.
Thank you. Let's look at the draft submission and
a later submission. Can we turn to UKGI00003390.
This should be a document that allows us to see some
tracked changes or some comments, and I will scroll down
in a second. Let's just read. So this is a submission
to you from Laura Thompson; was she a member of the ShEx
team?
Yes, she was.
“Purpose: To update you on the current state of the Post
Office's Mediation Scheme dealing with complaints about
the Horizon system, and seek your agreement to [Post
Office's] proposed approach in light of likely steps.”
Then there's a recommendation that you note the
current steps and agree to the Post Office's approach.
If we scroll down we can see there there's reference
to Second Sight:
“It remains the case that there is no evidence of
110
Sight from their engagement with the Post Office] are
that it renders the whole of the Working Group redundant
... and reduces the scope for Second Sight or the
[Justice for Subpostmasters Alliance] to continue to
broaden the scope of the agreements. However, it will
need careful handling with both participants and the
media to avoid the implementation that [the Post Office]
are seeking to ‘hide the truth’ or ‘gag’ Second Sight."
If we scroll down to the bottom of the page, there
is another part that ultimately comes out, which is:
"We therefore recommend supporting [the Post
Office's] proposed approach but it might get choppy."
If we scroll over the page, paragraph 14. It says
there:
"Whether leaked or not, the Second Sight final
report will give [the Post Office] a hook to determine
that it's time to meant the terms of Second Sight's
engagement and limit their involvement to reviewing the
specific individual cases remaining in the scheme."
"Post Office are considering optimal timing,
including a pre-emptive strike.”
Can we please turn now to UKGI00000032. This the
final version of that submission. We also have it --
I don't need to bring it up -- at UKGI00014168.
Can you assist us with how the final version causes
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you concerns?
So the initial version was going to ask for my agreement
for the changes that were being made by POL to close the
Working Group and mediate all cases. But the version
that I received does not ask me to agree it. It asked
me to note those changes. Then, it directs me to agree
about not telling Parliament about this by written
ministerial statement but that this is a finely balanced
decision and, you know, that sort of screams "This is
the bit you need to look at, worry about whether or not
to lay a written ministerial statement".
The reference to Second Sight in the initial
version, talks about limiting their involvement,
discusses about it getting choppy, that they might be
considered to have been gagged, and the version that
I received does mention very briefly that their
engagement would be terminated but in the context of
that being a kind of natural consequence of the ending
of the Working Group, and that their ongoing engagement
would be there, in terms of being funded to investigate
individual cases and also to complete their report.
There is nothing that is mentioned about them being
asked to destroy documents.
And, you know, then, I mean, the comments -- there
is also a comment where one of the civil servants
113
POL00132580 and it is a letter to you from Paula
Vennells dated 9 March 2015. You've said in your
statement this was something you requested; is that
correct?
Yes, so I did agree to make the written ministerial
statement that I was advised not to make and that the
best way to do that would be to be making a ministerial
statement including a letter from Paula Vennells, and
that was a common way of making a ministerial statement
to be able to bring information into the official
records of Parliament.
The letter says as follows:
“lam pleased to say that Post Office Limited has
now completed investigations into all the individual
cases put forward for consideration in the Scheme.
Furthermore, again I am pleased to confirm that no
evidence has been found through these investigations of
any system wide issues with Horizon.
"As a result, Post Office has now decided to put
forward for mediation all cases remaining in the Scheme
except those that have been subject to a previous Court
tuling ... This will accelerate the conclusion of the
Scheme in the interests of the applicants and ensure
that we fulfil the commitments we made to them at the
outset."
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speculates whether or not we should just ask me to
consider whether my commitments to Parliament have been
met because it would free us from having to worry about
it, which I thought was rather disrespectful to
Parliament and to, therefore, the constituents of the
Members of Parliament, you know. Obviously, civil
servants should be taking very seriously commitments
that ministers have made to Parliament. Now, in the end
they did produce that information.
I mean, it's a total changing of this submission.
So, from reading this, did I know that Post Office were
going to end the Working Group, mediate all cases, apart
from criminal cases, that would then be referred to the
Criminal Cases Review Commission? Yes, I knew that.
But did they tell me that they were going to sack Second
Sight and make them destroy documents? No. Did they
tell me that, actually, they'd been discussing limiting
and reducing the role of Second Sight for the previous,
you know, ten months or so? No. If they had said that,
would I have responded differently? Yes. And do they
think that's why I didn't put that information in the
submission? Also, yes.
Thank you. There's one final document that I'm going to
ask you about and I'll show you a couple of emails that
relate to the way that it became drafted. It's
114
It says:
"The Post Office will also continue to seek to make
an independent review by forensic accountants Second
Sight available to applicants where that has not already
been provided.”
Over the page, please. This one of the key
paragraphs that I'm going to briefly be asking you
about:
“For those applicants who have been subject of court
rulings, two important points need to be drawn out.
Firstly, we will continue to consider each of these
cases carefully, on a case-by-case basis, even though
mediation cannot overturn a court's ruling. Secondly,
as prosecutor Post Office has a continuing duty after
a prosecution has concluded to disclose immediately any
information that subsequently comes to light which might
undermine its prosecution case or support the case of
the defendant. Having now completed its reinvestigation
of each of the cases, Post Office has found no reason to
conclude that any original prosecution was unsafe.
Applicants remain able to pursue the normal legal
avenues open to them to appeal court rulings with any
further material disclosed to them, including that
produced through the Scheme.”
If we scroll down towards the end, it says:
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"The approach set out above will help bring the
mediation process to a conclusion earlier than envisaged
"One of the consequences of our presumption in
favour of mediating in as many cases as possible is that
it brings to an end the role of the Working Group ..."
I'd just like to take you through the process by
which that was drafted. If we look at POL00386985, we
can see there that Mr Davies, the Communications and
Corporate Affairs Director at the Post Office,
circulates internally a draft.
We then see, at POL00223650, an amendment to the
draft. Thank you. If we scroll down, we can see, from
Mr Williams, he makes two points:
"The fourth paragraph, final sentence [change it]
to:
“The Post Office will also continue to seek to make
an independent review available [et cetera] (we may not
be able to actually deliver the independent review once
[Second Sight] are terminated; and
"Fifth paragraph, final sentence: ‘Having now
completed its reinvestigation of each of the cases, Post
Office has found no reason to conclude that any original
prosecution was unsafe' (we should avoid talking about
appeals which have not yet been made).”
117
assurances that were given to me in writing; these were
assurances that Paula Vennells delivered to me in
person, you know, across the table, looking me in the
eye and telling me that there was no problem, that they
had investigated, that they had not found anything that
would cause concern, which I cannot square with that
email I have now seen that she sent in October 2013,
that says that she is -- you know, her concern is about
an unsafe witness and their obligations of disclosure.
So she knew about the Clarke Advice and the lack of
credibility of the key witness that they had relied on
for so many prosecutions. I mean, I consider that she
did not tell me that at the time in the summer and
autumn of 2013 to be massively problematic, nor at any
point in the subsequent 18 months in any of our
catch-ups in any of the submissions that I received, and
that she would sit and look me in the eye and give me
those assurances and then put that in writing, you know,
it just beggars belief because she knew that there were
problems with convictions, and the safety thereof
because she had been told that in the Clarke memo.
And I got this letter and I did take it at face
value, I believed the assurances and, you know, in that
first briefing note where I met with Alice Perkins and
Paula Vennells in 2012, one of the bullet points --
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We can actually see in tracked changes that change.
Can we please turn to POL00223651. This is the amended
draft and, if we turn to the second page, please, the
end of the first paragraph, we can see that tracked
change, so it originally said:
"However, Post Office has not seen any evidence that
it believes would lead to a successful appeal."
That is now amended to:
"Having now completed its reinvestigation of each of
the cases, Post Office has found no reason to conclude
that any original prosecution was unsafe."
We saw that form of words in the letter that was
tabled before Parliament.
Can you assist us with what your understanding of
that was at the time?
So, having received this letter, which, without having
seen the tracked changes, is a very specific, confident,
robust letter that says, you know, "We've investigated,
we've looked at this, we've got this duty to disclose
immediately, any information that comes to light would
be disclosed, and, of course, there's all these avenues
for appeal, and, you know, there's no reason to conclude
that any original prosecution was unsafe”.
That, to me, felt very reassuring and I just want to
be clear, as well, that this was not only a set of
118
which I remember because it was unusual -- was that
Paula Vennells is also an ordained vicar, right? And so
she was sitting there, yes, as a Chief Exec of
a national organisation, national company, but she was
also sitting there with the moral authority of somebody
who was a minister of the cloth, right, not of some kind
of slick Chief Executive who seemed to care only about
profit. I believed her. I believed her.
I did say that was the final document but just one more
document, it's UKGI00004006.
We can deal with this quite quickly, if we start on
page 3, we see, on page 3, on 20 March 2015 now, there
is a request from you in respect of you had been told,
I think, that it wasn't appropriate to receive a copy of
Second Sight's report. I think, if we turn to page 2,
we can see that you had challenged that and --
Multiple times.
-- at the bottom of that page, that email from Laura
Thompson, she says:
"Our advice remains that Government should not
receive a copy of the report. The revised drafting
emphasises two points:
[It'll] be sent to the Post Office ...
does not relate to the operation of the Horizon
system ... but rather, relates to issues which will be
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operational matters for Post Office."
Now, we started today on distinguishing between
operational matters and what were not operational
matters. Do you think that the Second Sight Report that
isn't being provided to you here, do you think that's
an operational matter or something else?
A. Well, I mean, I think -- it's hard to know, having not
received it, obviously, but I think clearly this is
an issue where there was significant concern in
Parliament and, more broadly, in the public, many
subpostmasters and the Select Committee in Parliament
has recommended that Government receive a copy.
I remember an earlier piece of correspondence,
I think to Sir Alan Bates, where I was asked to sign off
that the Government cannot compel its publication nor
would we do so, and I remember challenging that and
saying, "Well, hang on, if we could compel it, I think
I would compel it to be published. Can we compel it?”
And I was told no, we can't. And then they said,
because of the confidentiality which, you know,
I accepted, but the confidentiality argument falls apart
with the provision of it to Government, as the
shareholder. So I felt like that was an important
report that should be received by Government.
Q. Thank you. Finally, it might be suggested that
121
MR BLAKE: Thank you, sir. It's 1.00, there are unlikely to
be many significant questions from anybody. I'm just
looking around the room to see if there -- yes.
There is one question from Paula Vennells' Legal
Team and also from Mr Jacobs. I anticipate it will be
around ten minutes in total.
It's a matter for you, sir, whether we --
‘SIR WYN WILLIAMS: I think if it is ten minutes, obviously
it's sensible to complete it, subject to the transcriber
being happy to do that and then subject to having
reasonable break for lunch.
MR BLAKE: Yes. Sir, looking around the room, I think it
may actually be sensible if we take lunch. Might it be
possible perhaps to come back at 1.50?
SIR WYN WILLIAMS: Yes.
Before we take lunch, Ms Swinson, there are
references in your witness statement to you being aware
that the Criminal Cases Review Commission became
involved but, unless I've missed it, I can't actually
discern an approximate time when you first knew that.
Can you help me with that?
A. Ofcourse, Sir Wyn. My understanding of the CCRC's
involvement was around the point where I was being told
that they were going to close the Working Group and that
POL had decided to do that and --
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politicians are coming to this Inquiry, finding it very
easy to blame the Post Office, very easy to blame civil
servants but don't look enough at their own roles. What
do you think you did to contribute to the scandal?
A. There's various things that I wish I had done
differently, as I set out in my witness statement.
I should have met with Sir Alan Bates. I wished I'd
asked to meet with Second Sight directly. I wish, on
a couple of occasions, I had pushed more and probed
more, and one of those was when I was told that the Post
Office was changing their Prosecution Policy, and
I wasn't told that in a formal briefing, it was off the
cuff, and I think my response at the time was kind of
relief and "About time!" but, actually, I wish I'd asked
more questions at that point because I suspect that
there were reasons for that.
And, ultimately, if Post Office, had been frank
about that advice that they'd received, which I'm sure
must be why they changed their Prosecution Policy, about
the unsafe witness, I mean, years of anguish could have
been saved for subpostmasters. Justice could have been
years earlier, if that Clarke memo had been properly
acted upon at the time. And I didn't know about it, and
I wish I had, and I am just really sorry that -- I asked
lots of questions and it wasn't enough.
122
SIR WYN WILLIAMS: But this is 2015, basically?
A. Yes. I now know there was separate CCRC correspondence
but I don't recall knowing that at the time and
I don't -- haven't seen anything to suggest that I was
briefed on that. It did seem to me, in the discussions
about the Working Group, understandable that, if
a criminal conviction has been reached and that that
needs to be overturned, that that needs to go through
a proper judicial process, which is why the CCRC
involvement to me seemed reasonable, as a mechanism to
deliver that element of the redress that was being
sought by people who felt that they had been wronged.
SIR WYN WILLIAMS: Fine. Thank you.
So I have taken up a minute, Mr Blake. What time
shall we resume?
MR BLAKE: If we could come back at 1.50 because we do
finish early today.
SIR WYN WILLIAMS: Fine, yeah. That's fine.
(1.03 pm)
(The Short Adjournment)
(1.50 pm)
MR BLAKE: Thank you, sir. Ms Leek is going to ask the
first question.
SIR WYN WILLIAMS: Yes. Pause.
Questioned by MS LEEK
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MS LEEK: Good afternoon, Ms Swinson. Just one issue,
A
rPOoOP.O
I represent Paula Vennells.
You said this morning that Ms Vennells, and I quote,
"knew about the Clarke Advices". Just one point arising
from that: are you aware that there is no evidence to
suggest that Ms Vennells was ever shown either of the
Simon Clarke Advices by Susan Crichton or any other Post
Office lawyer before she left the Post Office?
In preparing for the Inquiry, I have been shown an email
from October 2013 where Paula Vennells emails Alice
Perkins, I think before going on leave and --
We have seen --
I don't have --
Yes.
-- the specific wording, so I may not remember
precisely, but it basically says along the lines of "My
concern about Horizon or Sparrow is our obligations of
disclosure regarding an unsafe witness", which to me
says that she knows that there was an unsafe witness and
therefore is referring to the Clarke Advice. Now if
she --
Let me stop you there, is it right to say then that the
extent of your knowledge about what Paul Vennells was
told is based on that particular email?
She certainly didn't tell me about it and I wish she had
125
email you're referring to?
Yes, and I think that email speaks for itself.
MS LEEK: Right, thank you.
‘SIR WYN WILLIAMS: = Right, thank you.
MR BLAKE: Mr Jacobs.
Questioned by MR JACOBS
MR JACOBS: Good afternoon. I represent a large number of
subpostmasters and mistresses who were ill treated by
the Post Office in this scandal.
At paragraph 131 of your witness statement you say
you felt, instead of being provided with the important
information on Post Office's motivations and plans in
a timely way -- there's no need to turn it's up:
I was being kept at arm's length and was being
managed.”
Does that sum up your general experience in the way
that you were briefed on the Horizon issue, being kept
at arm's length and managed?
Yes, I think that is what was happening, that's what
they were attempting to do. I did ask and probe on lots
of different elements of this, but the advice was, as
you will see from the documents, very clear always to
encourage me that this was an operational matter and
then reassurance was provided in various ways.
Thank you, and you've given two examples of cases where
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and she should have done.
Yes, but I'm --
Yes, it's that email.
-- trying to explore with you what you knew about what
she had been told about the Simon Clarke Advices and
I want to establish: is that based solely on that email?
From that email --
Yes?
-- to me it's clear she knew of at least the existence
of the Clarke Advice and I would have thought that any
Chief Executive being given information of that level
would have asked to then see the document on which that
came from.
Are you aware she was --
But I don't know if she did or didn't.
Right. So you don't know that she was not given a copy
of the Simon Clarke Advices. The entirety of your
knowledge is based on that email between Paula Vennells
and Alice Perkins?
I don't know if she asked for the Clarke Advice. I know
that she must have known about it's existence because
where else would she have got that information about
that unsafe witness?
I just want to establish -- it's not a difficult
question -- the extent of your knowledge is based on the
126
you weren't properly informed. You say that you weren't
told that Second Sight were to be sacked, bound by
confidentiality and records destroyed, and you would
have objected strongly if you'd known. You also talk
about you weren't told that the Chief Executive was
considered to be unfit to do the job.
In relation to that last point, you've described the
manoeuvrings of the Shareholder Executive this morning
as Omellian; is that right?
I think in the specific case that I used that language,
it was about them knowing that the Post Office was
changing its position on how it engaged with the
Mediation Scheme and then telling me that other people
were trying to reinterpret the terms of reference. And
I think another example would be there was a Select
Committee on 3 February, you know, I asked about the
outcome of that Select Committee. You know, what
happened, could I be, you know, given information about
that and I was basically told there was nothing
unexpected.
I think that would be another example when Second
Sight actually said they were concerned about unsafe
prosecutions, where I should have been given information
having asked for a readout of the Select Committee.
That's very helpful, thank you.
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In your evidence, you've confirmed, I think, that
Richard Callard was one of the people who kept you out
of the loop and you have given examples and we have
heard him writing "! want to get her in the right place
on Sparrow". I don't want to ask you about him.
Those clients that we have are interested to which
of the senior individuals within the Shareholder
Executive you blame, in addition to Mr Callard, for the
state of affairs that led to you being kept at arm's
length and managed in this way, and I'm going to give
you some names: Will Gibson, Mike Whitehead, Peter
Batten, Laura Thompson and Tim Mcinnes.
I've given you those names because those are the
names that feature in the documents we've been referred
to in your evidence. There may be some other
individuals. Do you think those individuals are to
blame and to what extent?
A. Sol have been specific in my criticism of Mr Callard
and part of the reason for that, rather than generally
naming lots of civil servants, is that, from the
documents I've seen, I can now know that he was on that
Sparrow Subcommittee and so I have good reason to
believe he knew things that he wasn't telling me. What
I don't know about those other officials is how much of
their information was therefore reliant on what Richard
129
Executive that you want to tell the Inquiry about today?
A. To be clear, I don't think a cultural solution is
sufficient but I also am supportive of the suggestions
that have come out, for example, about the Duty of
Candour. But I would also say that any official duty
like that being put in will also not be sufficient
without the right culture in place. And I do think
there was a different culture in ShEx that was not of
the usual Civil Service culture, which, as I say,
I found was generally a very helpful one that was
focused on the public good, and I think, while there is
a need obviously, to have, you know, relevant commercial
experience when you're dealing with companies, actually,
that mindset of public service is an incredibly
important part of what needs to be present in all civil
servants, even when dealing on commercial matters, and
I think that's the culture -- cultural element that is
important to instil.
MR JACOBS: Thank you. I don't have any more questions for
you.
A. Thank you.
Questioned by SIR WYN WILLIAMS
SIR WYN WILLIAMS: Ms Swinson, I just have a hypothetical
for you.
Let's assume we are back in 2014 and the documents
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Callard was telling them or, indeed, questions they were
asking of Post Office Limited, which is why would be
reluctant to go into a more, you know, detailed kind of
naming. But because of that specific role on the Board,
you know, I have information that Richard Callard knew
about things and I would just reiterate what I said
earlier on, that my general experience of dealing with
civil servants is that they were public spirited, they
were diligent in doing their jobs. You know, I think
this seems to me to have been exceptional.
That's one of the reasons why I find it so shocking.
This is an issue that affected so many people and the
only way ministerial oversight could operate properly on
that is with, you know, frank and full advice, and
that's why I'm angry that that was not provided because
it had so many impacts on real lives.
Q. I think you've said at the conclusion of your evidence
in your statement -- no need to turn it up -- at
paragraphs 146 to 148, that there are number of
recommendations that you make. One of the things that
you say is that the solution to the way arm's-length,
government-owned bodies are viewed and looked at and
checked by the Government might be a cultural solution.
My final question for you is, from your experiences,
were there any cultural problems within the Shareholder
130
which related to the appraisal of Paula Vennells'
ability to carry on as Chief Executive had, in fact,
been drawn to your attention, all right, and let us
assume that you had been persuaded of the validity of
some of those criticisms.
Would it actually have been your decision as to
whether she would have been invited to leave the
organisation or, if not, how would the decision have
been made?
A. I certainly don't think it would have solely rested with
me ~-
‘SIR WYN WILLIAMS: Right.
A. -- because I think Vince Cable would have rightly been
involved in that decision. I do not know if it would
have been -- I mean, I -- something like that would not
have been on, you know, the whim of the Secretary of
State, so I imagine that would have been in discussion
with the Board. But, had those concerns been drawn to
my attention when I returned from maternity leave, then
that would have been a conversation with Vince, it would
have presumably been conversations with other -- you
know, with the officials from ShEx and then potentially
with the rest of the Post Office Board.
It would have totally changed the view on whether it
made sense, you know, appoint somebody else in terms of,
132
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The Post Office Horizon IT Inquiry
you know, a strong CFO. There would have been a lot of
things that were different and, of course, you know,
assurances given by Paula Vennells about Horizon, in
that context, would have been viewed very differently.
SIR WYN WILLIAMS: Yes, I'm not actually seeking to enquire
into Ms Vennells herself; I was really concerned about
the process. So if I summarised it in this way: that it
would have come to you in the first instance but,
ultimately, it would also have gone to the Secretary of
State, there would have been wide consultation and would
I be right in then adding that, ultimately, it would
have been a decision of the Secretary of State?
A. That's my understanding.
SIR WYN WILLIAMS: Fine. Yes, that's fine. Thanks very
much.
MR BLAKE: Thank you, sir.
SIR WYN WILLIAMS: Anything else, Mr Blake?
MR BLAKE: We do have some keep questions from Ms Patrick
and Ms Watt.
SIR WYN WILLIAMS: Ah, sorry. Sorry to have jumped in.
I assumed that was it. I apologise.
MS PATRICK: If Ms Watt wants to go first that's fine.
Oh, there we go.
Questioned by MS PATRICK
MS PATRICK: Ms Swinson, my name is Angela Patrick. I also
133
A. I'm afraid I don't know.
Q. You've given us your reaction about finding out about
information that was communicated in the Clarke Advice
but I just want to ask, if anyone in that room or
elsewhere in Post Office, knew about bugs, the unsafe
witness issue or that Fujitsu had remote access to Post
Office branches, was any of that information, that ought
to have been, briefed up to you before you took to your
feet on 9 July?
‘A. Just to be clear, you said bugs, the remote access issue
and you said one other thing?
Q. The unsafe witness issue.
A. The unsafe witness issue. Certainly not on the unsafe
witness issue and certainly not on remote access.
Q. No, I think we're at cross purposes. I'm not saying was
it briefed up to you.
A. Oh, right.
If they knew, should it have been briefed up to you?
A. Yes, I believe so. The remote access issue would have
been quite a technical element but, given how important
it was, then, yes, I think the significance of that
should have been. The issue of bugs, I would -- just to
be clear, within the Second Sight Report, obviously, in
July 2013, it was recognised that there were some
anomalies and indeed in my statement to the House
135
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act for a number of subpostmasters. You can see
Mrs Hamilton to my left and Mr Brentnall to my right.
I apologise, I got one of my clients names wrong there!
Ms Swinson, I apologise for the break there with the
technical difficulty. I only want to look at one
document and it's the document Mr Blake spoke to you
about this morning, the Fujitsu document, where you said
you prompted yourself to reframe your decision and your
reaction in more Parliamentary language.
I don't think we need to bring it up but I'll give
the reference so we can have it in case we need to look
at it, it's FUJ00174179, and we don't really need to
look at it, I don't think.
You said and you've admitted that you wished you'd
spoken to Second Sight, you wished you'd spoken to
Mr Bates. Just to be absolutely clear, you didn't speak
to Second Sight before the ministerial statement on
2 July2013?
No, I did not.
You said you couldn't recall Lesley Sewell being in the
room but there were many officials. I want to ask you
about a few other names to see if it might jog your
memory: Rodric Williams?
I'm not sure.
Susan Crichton?
134
I mentioned that no IT system is entirely bug free but
what's important is that if something like that is
identified, that it is rectified, and my understanding
was that that had been what had had happened. Obviously
that was my understanding, based on what I'd been told,
but that turned out not to be the case.
Indeed, in your recollection of that group that was
huddled in your room, you're being briefed in a hurry
for the debate and the conduct of the Post Office may
have been criticised by MPs, was it a briefing, in your
recollection, where both the Post Office and ShEx
officials were present?
In my recollection is not that clear but I think it's
entirely possible and, having seen the email, perhaps
there was somebody from POL there. As I say, given the
urgency of timing, if there was going to be any points
that we needed POL to confirm or, you know, explain,
that's possible. But I'm sorry, I can't be more
categorical because it was a long time ago and a lot of
people in a room.
Ina circumstance where you've got an arm's-length body
that might be subject to criticism by MPs, is there any
prospect that that would be a cause for concern for you,
that you're being briefed by both the body that might be
criticised and the individual officials?
136
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A.
The Post Office Horizon IT Inquiry
I mean, in order for me to be able to answer the
questions from MPs, I would need to understand what
POL's response would be and, obviously, I can only
really get that from POL directly. Obviously, that
could come via officials and, in the normal mode of
written submissions, that's how I would expect it to
work. But in a very time-limited scenario where
a debate is happening. If I've got a question, I'd say
"Well, hang on, what's happened here? What's the
position on this particular area?" My officials might
not know and so, yes, I wouldn't find it very unusual in
that scenario to necessarily have somebody from POL
there.
Who would you rely on to give you an independent view in
those kinds of circumstances where an arm's-length body
might be criticised in a debate?
Well, I mean, obviously the officials, you would hope,
would have some ability to, you know, have a probing and
indeed, if I was, you know, in a conversation with
somebody from POL, I was doing that myself, right?
I wasn't just saying "Oh, right you say that". I would
then potentially be able to ask a follow-up question to
them to get the understanding. I think in the case of
POL -- you know, I had a number of arm's-length bodies
that I was engaging with as a minister.
137
I mean, I can see that -- it probably wouldn't have been
my expectation at the time. The content of the
conversation that I would have had with officials, which
I would have expected was a kind of a private
conversation to understand the issues -- so I wouldn't
necessarily have expected that to be reported back to
somebody else.
Just to be absolutely clear, were you told that Fujitsu
were going to be briefed on your briefing?
No, no.
MS PATRICK: Okay. Thank you very much, Ms Swinson. I have
A.
no other questions for you.
Thank you.
Questioned by MS WATT
MS WATT: Good afternoon, Ms Swinson. I appear for the
National Federation of SubPostmasters.
Just getting into each other's view. Thank you.
Throughout your witness statement, you referenced
the briefings that you got and the meetings that you had
with George Thomson, who at the material time of
Horizon, was the General Secretary of the NFSP and the
Inquiry has heard what he has to say about it all.
We also saw a document this morning which said both
the NFSP and the Communication Workers Union had
expressed confidence in Horizon, so doubtless you took
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In the case of POL, I suppose I felt we almost had
a better opportunity to make sure we got really good
information because there was a NED on the Board who was
actually a civil servant, so we should have more
information.
Can I stop you there a minute. You would have asked
questions but, on this occasion, you hadn't read the
Second Sight Report, had you?
But I cannot categorically say that I had read it in
full. I may have scanned it at that point. I'd had
a debate pack -- well, three debate packs in my box the
previous evening and I'd been reading as much as I could
for all of those debates.
Were you relying on the officials in those circumstances
to ensure that you were getting an independent view?
Yes, the officials would be providing policy advice and
there would be a very strong view that what I was being
told by officials was factually accurate and --
If we can look at that message back to the context
there, rightly or wrongly, looking at that conversation
within Fujitsu that you wouldn't have seen, would you
expect a ministerial briefing being given in the context
where an arm's-length body was possibly going to be
criticised in Parliament to be fed back to a third-party
contractor who themselves might be subject to criticism?
138
reassurance from these positions.
You're nodding. I think --
Yes, sorry. I did and my experience of dealing with
both the NFSP and the CWU during my time as minister was
that neither organisation was shy about being critical
where they didn't agree with some things so, yes, I did
take some reassurance from the fact that they were
positive about Horizon.
So I just want to ask you a couple of questions, then,
around the Crown post offices and the Post Office's own
employees. So thinking about this, last month the
Inquiry heard evidence from Tony Kearns of the CWU that
there were approximately 9,000 Post Office employees
working at Crown post offices and using Horizon, through
that relevant period, and likely they would have been
union members, so roughly the same as the membership of
the NFSP at the time.
He didn't have figures for Crown Office employee
prosecutions, except that there was some increase and
thought that some employees probably simply left
employment when faced with shortfalls. So perhaps a bit
of a different picture, as compared to the
subpostmasters.
So you sort of anticipated some of what I'm going to
ask. Can you say what sort of engagement you had with
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The Post Office Horizon IT Inquiry
the CWU and if they ever raised Horizon with you?
I met with CWU regularly but not as frequently as with
the NFSP. I would -- maybe couple of times a year, but
I can't be certain without access to those diary
records, and I don't recall Horizon being raised by CWU,
but it's hard to be absolutely categorical. But most of
the discussions with CWU focused around some of the
transformation in the Crown estate and the network
transformation plans there and some of their concerns
about that.
So thinking about what you were coming to know and had,
in fact, you know, been put before you in relation to
the issues about Horizon, although focused on
subpostmasters, did you ever ask them about the Crown
Office employees and were you not concerned about
Horizon and how it might be affecting, effectively,
civil servants, the state's own employees?
I don't think I proactively asked the CWU about it.
I do remember one conversation with George Thomson from
NFSP but I can't tell you exactly when that was. And
it's interesting in noting the figures that you set out
because, in terms of -- you're right it's probably
a similar number but, actually, at the time, that wasn't
the way that I conceived of it, because I probably would
have considered the NFSP that the vast majority of
141
and also thank you for the detailed witness statement
that you have provided. I want to go to that first, it
should be in front of you. For the purpose of the
record, it's WITN10310100.
Now, before I ask you to look at your signature,
there's two minor clarification points to make. Could
we please have page 21, paragraph 59 of the statement on
screen. It's the last sentence, you say:
"The formal separation agreement was signed on
1 April 2012."
I understand you wish to clarify that to the fact
that the formal separation agreement was signed in
January 2012 and formal separation itself took place on
1 April 2012 with further services between the companies
ceasing thereafter.
That's correct.
On the same theme, can we turn to page 40, please.
Paragraph 119, you say:
"A few months later on 3 April 2012, two days after
the signing of the formal Separation Agreement ..."
I understand that should read, "two days after
formal separation"?
That's correct.
Thank you. That document can come down for the time
being. Dame Moya, can I ask you please to turn to
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branches and then there was a much smaller number of
Crown Offices, though obviously larger branches.
So they weren't raising it, and it wasn't something
which I proactively raised with them, to my memory.
MS WATT: Thanks very much.
MR BLAKE: Thank you, sir. Those are all our questions.
Our plan is to all stay in the room while there is
a change of witness.
SIR WYN WILLIAMS: Right, that's fine.
So thank you very much, Ms Swinson, for making
a detailed witness statement and for answering a good
many questions today, this morning and into this
afternoon. II'm very grateful to you.
THE WITNESS: Thank you very much and for all of your work.
Thank you.
(Pause)
MR STEVENS: Good afternoon, sir. Can you hear and see us?
SIR WYN WILLIAMS: Yes, I can. Thank you very much.
MR STEVENS: Thank you, sir. We're about to hear from Dame
Moya Greene.
DAME MOYA MARGUERITE GREENE (sworn)
Questioned by MR STEVENS
MR STEVENS: Please could you state your full name?
A. Moya Marguerite Greene.
Q. Thank you for attending the Inquiry today give evidence
142
page 54 of your statement; do you see a signature?
Yes.
Is that your signature?
Yes.
prop
Are the facts in that witness statement true to the best
of your knowledge and belief?
Yes.
o>
That stands as your evidence to the Inquiry. It will be
published on the Inquiry's website shortly. I am going
to ask you some questions about it. I'm not going to
ask you questions on everything but just a few of the
key points.
lll start with your background. You spent the
first part your career in the Canadian Civil Service,
rising to work in the Privy Council Office?
A. That is correct.
Q. You then served as Assistant Deputy Minister at
Transport Canada between 1991 and 1996?
A. Thatis correct.
Q. Following that, you held various roles in the private
sector, including being President and CEO of Canada Post
Corporation between 2005 and 2010?
A. Thatis correct.
2
In 2010, you became Chief Executive of Royal Mail?
A. Correct.
144
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The Post Office Horizon IT Inquiry
That's what I'm going to focus my questions on now.
First, a few very broad questions on your responsibility
as a CEO. Would you accept that ultimate responsibility
for the operation of Royal Mail, the Group, rested with
you?
Yes.
Would you agree that identifying, analysing and managing
risk is an important part of the executive running of
a company?
Yes.
In fact, it goes to the heart of the company executive,
would you agree with that?
(The witness nodded) Yes.
When running a group of companies, considering risk also
means considering risk to the subsidiaries?
Yes.
Can we please bring up your statement, page 10,
paragraph 28. Thank you. Here we see from the title,
talking about subsidiaries and group companies, you say:
"The risks associated with a subsidiary entity such
as [Post Office], whether these were legal, IT or
finance related, would be reported to ..."
It says ARC, that's Audit and Risk Committee:
and updates provided to the Royal Mail Boards
where significant risks were identified or were
145
registers that they used and, on those risk registers,
they included some reputational risks. Would
reputational risks be something that a subsidiary should
report to its parent company?
Yes. The only hesitation I have is that, at that time,
2010 to 2012, we were just actual starting to bear down
on the establishment of risk management frameworks but,
yes, generally I would agree, if there is a very big
reputational risk, it should be reported.
What about the risk that a subsidiary has pursued
a prosecution that has potentially resulted in an unsafe
conviction?
I think it depends on the scale, if that would be
considered a material risk.
Pausing there, when you say "scale", is that referring
to numbers or type of conviction?
Numbers, type of conviction, what steps the company is
taking to make sure that it doesn't happen again. It
just depends. It's only a reputational risk if, you
know, if it bears on how people view the organisation
going forward.
So when we had, as I say, the significant risk and the
sufficiently material risk to impact the Board's
financials, I think what you're saying is, when you are
referred to significant risk, it still has to be
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sufficiently material to impact the financials of the
Group."
You're distinguishing there significant risks and
risks that were sufficiently material to impact the
financials of the group. What types of significant
risks there did you have in mind? Can you give any
examples?
Yes. We had a very big pension deficit, we had a very
large pension programme and the deficit ranged between
£4 billion and £12 billion, depending upon assumptions
and time, so that was a very significant risk. We had
cash risks in the Royal Mail. There were times when,
you know, there were genuine worries that we just did
not have enough cash for the operation. We had major
risks in the operation. Having had a very good
modernisation plan, it was difficult to implement it.
That was a very big risk for the Royal Mail Group.
You know, those were sort of three major risks. We
had a regulatory framework that was archaic and out of
date and we needed a new approach entirely. That was
another major risk for Royal Mail going forward, given
a very different competitive environment. So those
would be four examples.
We heard from some witnesses from UKGI and the
Shareholder Executive last week and we saw risk
146
material to the group itself, to be reported up from the
subsidiary?
I wouldn't be categoric about that, Mr Stevens. As
I said, we were just getting started on the
establishment of risk registers and the processes that
you put in place -- bottom-up, top-down -- to try to
identify where the risks were, sifting through to
understand what was the scale of the risk. But by and
large, an Audit and Risk Committee would focus on the
big risks and these would be the material risks.
As part of forming the risk register, as you say, do you
recollect, did you ever see, on the risk register for
Royal Mail or any of its subsidiaries, risks relating to
the prosecution of subpostmasters?
No, I don't recall seeing that.
I want to now look at some of the issues relating to IT
without were funnelled through, or potentially funnelled
through, the ARC. Please could we start with
POL00030217. So this is an Ernst & Young document, it's
a management letter for the year ending 27 March 2011.
Do you recall seeing this document whilst in post at
Royal Mail?
No. It has been provided to the -- from the Inquiry to
me.
When the Inquiry provided it to you, did you read it?
148
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The Post Office Horizon IT Inquiry
Yes.
Broadly, would you have expected to be made aware of
a letter such as this in your position as Chief
Executive of Royal Mail?
Not in detail. The relationship with our external
auditors was really primarily with our Chief Financial
Officer, Matthew Lester. He and I had a very close
working relationship, so any big issues that our outside
auditors, E&Y, would have said, he would have told me
about but I wouldn't expect to be told in detail about
the management letter for the Post Office.
Can we look, please, at page 3. It's the "Executive
summary", and it says:
"The main area we would encourage management focus
on in the current year is improving the IT governance
and controlled environment.
“Within the IT environment our audit work identified
weaknesses mainly relating to the control environment
operated by [Post Office's] third party IT suppliers.
Our key recommendations can be summarised into the
following four areas:
"Improve governance of outsourcing application
management
"Improve segregation of duties within of the manage
change process
149
at Royal Mail Board minutes that you provided a couple
of times but I, of course, now know what HNG-X means:
Horizon Online.
Presumably you were aware at the time that Post Office
was rolling out a new front-end accounting software
system?
Yes, generally.
So this risk or this point says:
"There are inappropriate system privileges assigned
to the APPSUP role and SYSTEM_MANAGER role at the Oracle
database level on the branch database server (BDB)
supporting HNG-X."
It goes on to describe some more of what it
describes as “inappropriate privileged access".
We've heard a lot about APPSUP at the Inquiry and
generally about remote access. At this point in time,
2011/2012, that period, were you made aware in any
detail of Fujitsu's ability remotely to access branch
accounts in the Horizon IT System?
No, I was not. However, in the minutes of the Audit and
Risk Committee, it was raised, and it was raised,
I think, at the initiative of our Chairman, Donald
Brydon, but it was raised in a way that was put in the
context of Fujitsu not really being prepared for the
audit in the previous year. And a lot of work had to be
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"Strengthen the change management process
"Strengthen the review of privileged access.
"We also encourage management to continue to enhance
the Legal and Compliance review framework to manage
risks in relation to regulatory compliance associated
with financial services activities."
Now, in a moment, we're going to look at some ARC
meetings and I'll ask you about how this was discussed.
Before I move on to that, though, I want to ask about
one specific part of the matters that were identified.
Could we turn to page 23, please. This is just to
orientate ourselves. We can see the title is "Current
Year Recommendations -- IT Specific’, and it gives
a series of recommendations, which I don't need to take
you through. Could we please go to page 31.
In the table at the bottom, the bottom line, we see
it talking about review of privileged access to IT
functions; do you see that?
Yes.
If we go over the page, it starts with POLSAP, which is
a back-end system that I'm not going to ask you about
but, if we go forward, please, HNG-X, which we now know
as Horizon Online. HNG-X, at the time, presumably would
have been a phrase of which you were aware?
Actually, I don't recall it and it has only been raised
150
done by our outside auditor to make up for that. So it
was raised in a slightly different context and it
certainly was not emphasised.
With hindsight, looking back now, is it the type of
detail that you would have expected to be raised at the
ARC committee at Group level?
That's hard to say. We had so many very big technology
risks. As I mention in my statement, the Royal Mail
technology estate was archaic, complex. We could not
really go forward with the modernisation programme as
planned without the ability to improve it. So I am not
sure, Mr Stevens, that this access issue that came up in
the context -- in a much larger context of the audit
work that had been done for the '10/'11 year would have
received that kind of emphasis. The technology estate
in the Royal Mail Group needed to be completely
revamped. So I don't know how much emphasis this
particular, and what we see now, very important point,
would have been given.
Can we look, please, at RMG00000083.
So this is Royal Mail Group paper -- we see "Date of
ARC" -- so it's for the Audit and Risk Committee on the
8 December 2011. The author and sponsor is Chris Day,
the Chief Financial Officer of Post Office.
Contributors include Lesley Sewell and Rod Ismay. It's
152
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The Post Office Horizon IT Inquiry
title is "Update on Post Office Limited, Horizon
controls and relationship with Fujitsu".
If we could turn the page, please, in fact, sorry,
to page 3., it says, "IT controls and SAS70 assurance".
Earlier, when you were referring to audit and
a discussion at the ARC, were you referring to that
SAS70 assurance?
That is correct.
It also says this, in the middle:
"A number of IT control issues were identified
during the 2010/11 year-end audit, which were largely
centred on Fujitsu. Overall [Ernst & Young] that the
control systems were reliable, but they made certain
recommendations in the management letter following the
audit for improvements which have been implemented. The
IT control issues identified during the audit did not
relate to the integrity of accounting data in the
system. Rather, [Ernst & Young] made recommendations
about the documentation and authorisation of changes to
systems and about opportunities for streamlined
assurance.”
If we go to page 6, please -- we don't need to cover
the whole of the paper -- at the bottom of the page,
please. It talks about the annual audit by Ernst &
Young. It says:
153
needed to be corrected, but that it was not problematic
in terms of the integrity of the data that had been used
in the audit for the purpose of financial reporting.
And if I, you know, had focused on it, that's what
I would have drawn from it.
I want to come to the meeting at which this was
discussed shortly but can we also look at another point
raised on page 7. We see it talks about challenges to
Horizon, and we know, by this point, Post Office had
received at least five letters of claim in the Access
Law/Shoosmiths related matter.
I only read four.
We don't need to worry --
Okay.
You received some letters?
We did not -- but, again, vastly understated, relative
to what was the scale of the issue. But yes.
“[Post Office Limited] has, over the years, had to
dismiss and prosecute a number of subpostmasters and
Crown staff, following financial losses in branches."
Presumably by this time, December 2011, you were
already aware of Post Office's involvement in
prosecuting subpostmasters?
You know, Mr Stevens, I don't remember that but I have
read the documents, and I don't know how much I would
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"However, after additional control testing, [Ernst &
Young] confirmed that they were able to plates reliance
on the existing systems controls. Nevertheless, they
suggested certain improvements which could be made,
mainly relating to access."
Do you have any recollection of reading this paper
at the time?
I don't have any recollection of reading it and -- but
what I would say is that it's a very reassuring paper
and so, in previous minutes -- and again I don't have
any specific recollection of it -- the minutes report
that our outside auditor was annoyed that they had to do
a lot of extra work on their own initiative because
Fujitsu did not seem to be ready to do the kind of work
that was expected in a year-end audit and, as a result
e&Y did the work. They tested the systems and they
tested the control environment. They made a lot of
recommendations for improvement but they were able to
reassure the Board and the Audit and Risk Committee that
they were satisfied that there was integrity in the data
that was being used for the purposes of financial
reporting.
So it’s in a context where, what anyone would draw
from it was that there was a problem with the audit
readiness of Fujitsu but ~ and these things definitely
154
have focused on that issue at that time because, as
I mentioned to you, when it came to our Audit Committee,
it came at the initiative of our Chairman, who had read
Private Eye's article and activated the Audit and Risk
oversight of this matter. And, from the reading of the
documents that you've provided, it just -- it doesn't
come across as an issue anywhere near the scale of what
the issue was. So, in answer to your question, I don't
know if I would have focused on that.
My question was slightly different. My question was: if
you knew of Post Office's involvement in prosecuting
subpostmasters. I'm going to come to that in more
detail later, so park it there.
Okay.
Looking at paragraph 26, this refers to four broad
strands of challenge, it says:
"Prosecution and civil debt recovery actions by POL
where the defence claim Horizon is flawed -- these have
consistently been won on the facts of Horizon
transaction logs. Judges have spoken supportively of
Horizon."
Then it goes on to discuss threatened civil claims
for damages, and it says:
4 letters of claim have been received -- of
those, one is now time-barred", et cetera.
156
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The Post Office Horizon IT Inquiry
So that's the papers that went there.
Let's look at the minutes of the meeting itself
please. It's RMG00000003. So we see it's the Royal
Mail Holdings Audit and Risk Committee meeting on
8 December 2011. If we can go down slightly, please.
We see you are there listed second in attendance, and we
also have further down, Chris Day, Lesley Sewell and Rod
Ismay who were the three sponsors on that paper. Yes?
Yes.
If we can go in the paper, please, to -- if we could
turn the page, please, and again. Sorry, over the page,
please, and down, please, to (f). Pausing there. So
"Challenges to Horizon". It says:
"[Post Office Limited] has, over the years, had to
dismiss and prosecute number of subpostmasters and Crown
staff, following financial losses in branches."
So it's very similar wording to what was in the
paper. It says:
"The Committee noted the update on this matter."
Would the paper have been supplemented by anyone
speaking to it or would it simply have been read?
I don't remember but, usually, if our corporate
secretary used the word "noted", it was not discussed
and, as you can see from the minutes, there are a lot of
things on that agenda.
157
it's noting matters to be covered in the report.
In your witness statement, you say that the minutes
do not disclose Rod Ismay, who was at this meeting,
having made any statement to the committee about
Horizon, and you make the point he'd done what we now
know as the Ismay Report a year earlier.
Now, you say the minutes do not disclose it. Do you
have a positive recollection on whether Mr Ismay said or
didn't say anything at the meeting?
I don't.
What about Lesley Sewell?
No, I don't have any recollection. I don't have any
recollection of a discussion on this matter.
Shall we take, then, that your evidence on this is that
the ARC were effectively reassured by the paper which we
went to earlier?
I would think so.
Can we look, please, at POL00029114. This was
a document sent to you by the Inquiry. As you say in
your witness statement, you're listed in the
distribution list; do you have any recollection of ever
receiving this or a document like it?
No, I don't have personal recollection but I believe
that this would have been done by the Royal Mail
Internal Audit Group, led by Derek Foster with whom, you
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By that, what sort of elements of that, sorry?
Well, there were a lot of things to get through, and
some of them would have been perceived, as at that time
and on the basis of what was known and said to us at
that time, some of the other items would have been
perceived to be requiring greater allocation of time and
discussion.
Can you recall, either at this meeting or at any other
point, ever being told that Post Office had pursued
a prosecution where a subpostmaster had raised Horizon
as a defence and that subpostmaster had then been
acquitted?
I don't specifically recall that but, certainly, the
documentation that you have provided allows me to see
an email trail where, as I said, our Chairman,
Sir Donald Brydon who was also, up until the time of
Ms Perkins’ appointment, was also the Chairman of Post
Office Board, he having seen a document -- having seen
it an article in Private Eye, activated the Audit and
Risk framework inside Royal Mail. So I don't personally
recall but I can see that -- from the documents you've
provided, I have a reasonable picture of what happened.
If we go up, please, on this document, we see.
a discussion of the "Update on Horizon controls and
relationship with Fujitsu", If we scroll down, we see
158
know, we had a highly positive professional
relationship, to the point that, if there had been
anything, especially in this period of time, because
remember we're almost through all of the discussions on
separating all of the various points of intersection
between Post Office and Royal Mail. If he, Derek, had
any concern about anything not being attended to
properly, the kind of relationship we had is that he
would have spoken to me and I have no recollection of
such a conversation.
So we see it's "Review of key system controls in
Horizon", it's a draft report dated February 2012. If
we turn to page 3, please. It talks about "Master data"
at the top:
"No audit trail exists for change requests received
by Fujitsu from the Network Business Support Centre."
It says at the bottom "Implication":
It is difficult to detect and prevent inappropriate
changes being made to master data.”
Then "[Ernst & Young] Management Letter", at the
bottom. It refers to the matters identified by the
letter, and it says this:
"Progress has been made in completing the actions
arising from the [Ernst & Young] management letter. The
[Ernst & Young] recommendations that require most
160
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additional work relate to", and then it lists out what
those were.
Did anyone tell you at this point, contrary to what
had been said before, the recommendations in the
management letter remained outstanding and to be
completed?
A. I don't recall that and, in other documents that have
been provided, it seems like we were being informed as
a Board that good progress was being made.
Q. Do you know, why has there been a breakdown in
communication? Can you help us with why the Board has
been given a different story?
A. I really can't because I don't have any personal
recollection of it and I'm trying to piece it together
from the documentation that the Inquiry has provided.
There was a lot going on, as there always was in Royal
Mail, around that time and, you know, I just -- I wish
I could help more.
Q. Is potentially a problem that there was a disconnect at
this point between -- or lack of communication between
Post Office and the Royal Mail Board because of the
impending separation?
A. I don't think so because, if you look at the whole
architecture around how the separation was going to take
place, it was very well thought out. All of the various
161
SIR WYN WILLIAMS: I can.
MR STEVENS: Thank you, I'll continue.
Dame Moya, I now want to look at oversight of
criminal and civil proceedings. Please could we have
your witness statement at page 5, paragraph 13. You
say:
"The policy decision relating to Post Office
separation was taken long before I arrived at Royal
Mail. The Post Office operated in a fairly autonomous
way and had clearly done so for some time. It had its
own corporate functions including: Finance; IT; HR;
Government Relations; Company Secretary; Marketing; and
Legal."
Pausing there, what do you mean by Post Office
having its own legal function?
A. This was just an impression that I formed that in the
general corporate function areas, they had people who
specialised in those areas for the Post Office and the
impression was formed because, when we were doing all of
the work underpinning the separation, you know, we had
to think about people and the tasks that they did and
which ones of them would, under the transfer of
undertakings, go to one organisation or go to the other.
It seemed to me that, in these corporate areas --
and this, again, is just an impression that I formed --
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points of intersection had team leaders from Royal Mail
and from Post Office working together to try to assess
what would be the impact if we had to become separated,
what would be the service impact and how did we make
sure that we didn't drop the ball anywhere?
That was a very big framework that underpinned all
of the discussion that took place, quite across all --
both companies in every department. So it's hard for me
to understand, because there would have been a huge
amount of communication taking place in the context of
just trying to articulate what were the implications of
the separation in almost every single aspect, from
facilities to technology to finance to, you know, the
corporate secretariat. So it's hard for me to
understand how certain things like this did not get
flagged up more.
MR STEVENS: Sir, that's probably a good time to take the
afternoon break, as I'm coming on to a new topic. Can
I ask that we break until 3.007
SIR WYN WILLIAMS: Yes, of course.
MR STEVENS: § Thank you.
(2.50 pm)
(A short break)
(3.00 pm)
MR STEVENS: Sir, can you continue to see and hear us?
162
in these corporate areas, it was very clear that there
were some people in the legal area whose work was almost
exclusively for the Post Office, and so they would go to
the Post Office.
Q. Just continuing on, it may become relevant later, you
also say:
"The two companies operated from different
headquarters (Royal Mail at Blackfriars, London and the
Post Office at Old Street, London)."
You refer to there being almost no overlap between
staff at the two organisations.
A. That is my recollection.
Q. Can we jump forward, please, to page 35, paragraph 103.
Thank you. You're here speaking about the Ismay Report
and you refer to David Smith, the Managing Director of
Post Office, not raising it with him, and you say:
"I would have expected David Smith and Post Office
Limited's Head of Criminal Law, Rob Wilson, to conclude
that an independent review was necessary."
Pausing there, was your understanding that Rob
Wilson was the Head of Criminal Law for Post Office
Limited?
A. Yes, but I don't remember him. I have learned that
through this Inquiry, and I apologise to Mr Wilson if
I have met him but I don't remember him.
164
(41) Pages 161 - 164
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If we can bring that document down, please, and bring up
POL00046235. This is a letter I think you were given
this morning by the Inquiry and you see it's on Royal
Mail headed paper. It says "Legal Services, 3rd Floor,
6a Eccleston Street”, that looks like an address in
Victoria, London. Do you recall that being an address
operated by Royal Mail?
I don't, I'm sorry. We had a lot of sites, hundreds of
them.
You see it's sent to Maureen Moors, National Security
Team, Post Office Limited and, if we look down, please,
we see it concerns the case of Post Office Limited v
Ishaq. Now, Mr Ishaq was convicted of theft on 7 March
2013 and sentenced to 54 weeks' imprisonment. His
conviction was quashed by the Court of Appeal in
Hamilton & Others v Post Office. You'll have read from
this document that Mr Wilson gives advice and comments
‘on the charging decision.
(The witness nodded)
You're nodding your head.
Yes, yes, I'm sorry.
If we go to the end of the document, please, at the
second page. It's Rob G Wilson, Head of Criminal Law,
Criminal Law Division, and it's a Royal Mail email
address, and at the bottom we have "Royal Mail is
165
thinking there was a Criminal Law Team within the Post
Office?
Because I don't remember ever being briefed on
subpostmaster issues except, you know, very
tangentially. I remember that, from time to time,
perhaps every half year, the Board would get an overview
of security matters in Royal Mail, and everything from,
you know, whether or not we were controlling our sites
well enough, whether or not we had appropriate revenue
protection in place, whether our products were properly
designed to minimise, you know, any loss of mail because
we were regulated on, you know, the safety of the mail,
the security of the mail.
So I remember that and, in that context, I remember
hearing about offences that had been committed and,
I mean, I'm sure that it would have included an overview
for the whole group but I don't specifically remember
offences against subpostmasters.
The first occasion ~ if I may, just to clarify ~
the first occasion when it really registered with me
that, you know, there was the potential for wrongful
prosecutions of subpostmasters was when I received the
letter to me personally. I couldn't remember who --
from whom it came and it turns out, on the basis of the
evidence, on the documentation that you've provided me,
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a trading name of Royal Mail Group Limited”.
Were you aware, when you were CEO, that Rob Wilson
worked within Royal Mail itself?
I don't remember Rob Wilson but I suppose I should do.
I mean, the evidence here is that he did.
Let's go wider. Were you aware of the Criminal Law Team
in the Legal Department of Royal Mail?
I was aware of a criminal law team, yes, because we, in
Royal Mail, had offences as well as the Post Office did
so, yes, I was aware of a criminal law team.
So when you say you had offences as well, are you
talking about there where someone, maybe an employee of
Royal Mail, was accused of, say, opening envelopes or
stealing mail?
Yes, of stealing Special Delivery. You know, there are
a range of offences.
So you knew that the Criminal Law Team within Royal Mail
dealt with those types of offences or allegations?
Yes.
Were you aware that the Criminal Law Team within Royal
Mail also dealt with prosecutions against
subpostmasters?
I wasn't. I thought that was dealt with by the Criminal
Law Team in the Post Office.
Let's explore that. What basis did you have for
166
it was Lord Arbuthnot. I am just trying to explain to
you that I don't remember subpostmasters.
If I can pause you there because we'll look at when you
received that letter shortly. Given the Royal Mail
Criminal Law Team, which was within your company, was
advising and was involved in the prosecution of
subpostmasters, do you accept you should have known that
as Chief Executive?
Yes, I guess I should have known but I didn't.
Who briefed you on the extent of the role of the
Criminal Law Team within Royal Mail when you joined the
company?
When I joined the company, the senior team was in
a state of flux and I don't remember getting briefed on
this. We had -- at that point, the General Counsel was
a gentleman named Mr Evans. He wasn't there for very
long. We appointed, then, on an interim basis, Jeff
Triggs. I see from the documentation that has been
provided to me from the Inquiry that Jeff Triggs did
include some information to our audit committees on
subpostmaster prosecutions but I don't personally recall
being briefed on that.
Can we look, please, at POL00432053. So this the Master
Services Agreement relating to the separation of Royal
Mail Group and Post Office Limited. Can we turn to
168
(42) Pages 165 - 168
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page 4, please. We can see in the recitals -- the
second recital refers to it -- that there's going to be
a separation of the current corporate structure, so they
will be separate companies, and at (C) it says:
"This agreement sets out the terms on which the
Provider shall provide the Services to the Recipient and
makes provision for the transition of termination of the
Services."
So, in essence, what this is saying is, before
separation, Royal Mail provided services to Post Office
Limited. After separation, we need to transition off
those services and this provides how that will happen.
A. Correct.
Q._ I think you were involved in, I think, reviewing and
determining what services needed to go from Royal Mail
to Post Office?
A. Correct.
Q. Can we look, please, at page 147, which is part of the
first schedule to the agreement. You see "Section M",
it says, "Services to Cease", and this sets out the
services that were to cease on separation itself. So,
effectively, these services come to a stop on -- I think
it's 31 March, but ready for separation in April.
Correct?
A. Correct.
169
ironically.
Can I ask you, sir, if you don't mind staying on
screen and we'll see if it can be fixed in a short
period?
SIR WYN WILLIAMS: Yes, that's fine. [I'll just stay here,
quietly minding my own business until you tell me to pay
attention again.
MR STEVENS: Thank you, sir.
Dame Moya, I apologise. We'll try to sort this out.
(3.17 pm)
(A short break)
(3.21 pm)
MR STEVENS: Sir, can you continue and see and hear us?
SIR WYN WILLIAMS: Yes, I can.
MR STEVENS: We have hopefully resolved that matter now.
I'm going to go to a different document, actually.
Can we please bring up POL00030800.
So this a Royal Mail Group policy and we see at the
top it's Royal Mail Group, and then the business units:
Post Office, Royal Mail and Parcelforce. Yes?
A. Correct.
Q. We see the owner is Rob Wilson, Head of Criminal Law
Team?
A. Correct.
Q. If we can go over the page, please, the "Purpose" of the
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Q. We see "Workstream" on the middle column and then
"Description of services to cease". Can we please turn
to page 150. Is it possible to rotate that, please.
44 -- it appears we might be having some difficulty
with that. I hope you'll take it from me --
A. Iwill.
Q. -- 44, it says, "Legal" in the middle column and then on
the right it says, "POL Legal”, and then, over the page,
it says 49 "Legal", in the middle column, and then in
the right column it says, "Criminal Law". Then the page
after, the Service End Date is 31 March 2012.
So this document shows that it was a part of the
negotiations and agreement about the criminal law
services from Royal Mail to Post Office stopping. Is
your evidence that you weren't aware that Royal Mail was.
providing criminal law services to Post Office Limited?
A. I guess I didn't think -- it didn't register with me.
I suppose, if I, you know, think about it, maybe it was
all part of one team, but inside that team, certain
individuals worked exclusively on POL criminal legal
work and other individuals worked on Royal Mail criminal
work. I'm just not sure.
MR STEVENS: Can we bring up, please, POLO0031004.
Sorry, sir. I think we're going to have to take
a five-minute break because the system has crashed,
170
policy includes, 1.1.3:
"Applies equally to employees at every level,
whether frontline, management or executive, and to
non-employees equally, whether contractors, customers or
having no formal relationship with the Royal Mail
Group."
So would you accept this is a Group policy --
A. Yes.
Q._ -- and within its remit would be prosecutions against
subpostmasters?
A. Yes. Well, I -- yes. If it -- yes.
If we go to page 3, please.
A. The only hesitation I have, Mr Stevens, is the date of
this policy, because it was I believe in 2012, was it
not?
Q. Well, if we go back to page 1, please -- I should have
taken you to the date, for which I apologise -- it's
dated created September 2008, it's Version 3, effective
from April 2011.
A. The only reason why I think the date is important is
because, as part of the separation process and, indeed,
in preparation for a hoped-for listing of Royal Mail,
every policy in the company was updated. Every
employment policy, every facilities management policy
and, of course, this policy would have been part of
172
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that. So I think some of them went back to 2008 but
some of them were much older, and so I am -- the reason
why I am asking about the date is that, when you asked
me does it apply to subpostmasters, I guess it does, in
2011; in 2012, it probably would not.
No, indeed. We don't need to turn it up but there is
a Post Office Prosecution Policy Version 1 that is from
1 April 2012. The reference for that, sir, for your
benefit, is POL00031034.
If we can turn, then, back to page 3, paragraph 4.5,
it describes about the requirements of the Group Code of
Conduct, and says:
"In the event of any disagreement with prosecution
advice in England and Wales, or inconsistency between
prosecution and conduct decisions anywhere in the United
Kingdom, the Head of the Criminal Law Team and the Head
of the Investigation Team will consider the case and
provide guidance and advice to ensure that the Royal
Mail Group maintains a consistent prosecution policy."
So the purpose of this document was, at group level,
to ensure the two amounts you used earlier, that
someone, a Royal Mail employee accused of stealing
letters, and a subpostmaster were prosecuted in
accordance with the same policy?
Yes.
173
now, but I expect I would have.
Would you agree that it's unusual for a business to
bring private prosecutions?
It has been a thematic strand in this Inquiry but,
Ihave to say, I am not as surprised as some people are
because, you know, I had a very senior position in
Canada when I was in the Civil Service, in the
Department of Transportation, and there were specialised
police forces with investigation powers and I believe,
in some cases, prosecution powers. So I was not as
surprised about that as some people have been.
This is a private company. It may be owned by the
Government but it's a company; would you accept that
it's unusual for a company to pursue private
prosecutions?
I would accept that but, historically, you know, this
company has unusual roots. Historically, it started off
as a Government Department. So this may be a holdover
from its historical background.
Would you agree that a business exposes itself to
various risks if it brings prosecutions?
Yes, and it exposes itself to risks if it ignores
offences against it as well.
So, in bringing the prosecution, it could be criticised
in how it took the decision to prosecute; would you
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That can come down, thank you.
In your witness statement, paragraph 12, page 5, you
say:
"When I joined, my immediate priority was to resolve
these issues in a way that would allow Royal Mail to
satisfy the Financial Conduct Authority's eligibility
requirements for admission of shares to the premium
listing segment of the Official List so that the
company's shares could be traded on the London Stock
Exchange and attract investor interest."
You go on to say:
"They necessitated a programme which involved
a complete review of: Royal Mail's policies, procedures
and practices (to enable Royal Mail to comply with its
ongoing listing obligations); the finance and operations
of the company; ongoing liabilities and risks; and
competencies of the Executive Team."
Would you, as part of that and in your role as CEO,
have reviewed policies such as the prosecution policy
I just took you to?
I remember reviewing a major thick book of policies but
I cannot tell you for certain if I focused on this
particular one. But I do remember being prepared for me
a very large book of policies. So I expect that I would
have read this but I don't have a recollection of it
174
agree?
It could be.
It could be criticised for the conduct of the
prosecution?
It could be. However, if the prosecution and the
decision to prosecute is a good one and a fair one,
backed by the kind of impartiality that would be
expected, then I don't think that it necessarily
presents a big risk.
Is what you've done there: identified a risk, analysed
it and then suggested a mitigation for the risk?
Yes, but I would say, Mr Stevens, in that -- in that
framework, probably anything could be identified as.
a risk if it's not thought of properly.
There were clear and obvious risks arising from if
prosecutions aren't pursued fairly, would you agree with
that: for example, there's a risk of unsafe convictions?
Yes.
Would you agree that bringing private prosecutions calls
for thorough oversight by the executive of the company
that is pursuing those prosecutions?
Not necessarily on a case-by-case basis, no. I think if
you have competent people and if they are exercising
their duties properly, you know -- and the Executive
Team of a company cannot do every job in the company, so
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I think it depends.
Q. You said there, if you had competent people, I think the
other one was if they were doing their job properly;
would you accept the Executive Team has to have a system
in place to check both of those things, to satisfy
itself that both of those things are being done?
A. Yes.
Q. Do you think extra care needs to be taken on those
matters where the business is investigating and
prosecuting alleged crimes where it itself is the
alleged victim?
A. think, arguably, yes.
Q. What did the Royal Mail Board do in your time there to
oversee or mitigate the risk of prosecutions against
subpostmasters?
A. I think the most important thing that our Board and our
Audit and Risk Committee did, under the aegis of the
Chairman, who was, until Ms Perkins was appointed, also
Chairman of Post Office, when he read about -- in
Private Eye, he activated the risk management process of
Royal Mail, to make sure that they were apprised, that
there was an evolving situation that could indeed become
a larger risk than it was being presented at that time.
Q. Can I just pause you there. That's, I think you're
referring to where a Private Eye article was raised and
177
subpostmasters being on the risk registers?
A. I don't recall it, no, but that doesn't mean that it
wasn't and that doesn't mean that it wasn't discussed.
It was a long time ago. I don't recall it.
Q. Is the answer that the Royal Mail Board took no steps to
oversee how prosecutions against subpostmasters were
being conducted?
A. I would not say that from the evidence that you have
provided me with. As I say, the -- we had -- it was
very clear where the management of risks in subsidiaries
lay and the management of, I think, this particular set
of risks probably started in Post Office but, from
a group perspective and getting your arms around the
risks of all subsidiaries in the organisation,
I certainly remember that being a preoccupation.
I can't give you the exact date.
And I think our Board members were alert to emerging
risks and, in that context, called for information, so
that it could be assessed by the Board. Sol am sorry,
but I think you are being perhaps more categoric than
I would be on that.
Q. I want to move to a different topic and look at some of
your discussions with Paula Vennells, please. Can we
bring up POL ~~
SIR WYN WILLIAMS: Before you do that, Mr Stevens, can
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then queries were raised as to the integrity of the
Horizon IT system and the --
A. And the potential for --
Q. -- potential for civil claim. That's slightly different
from a proactive risk management approach and asking
what the Board did to satisfy itself that prosecutions
against subpostmasters were being carried out fairly.
A. Alll-can help the Inquiry with is the information that
has been provided to me because I don't have a personal
recollection but I will say that as we put in place the
risk management framework and developed the risk
register system, it was a process that cut across the
company entirely, including the subsidiaries. And so we
had a bottom-up and a top-down approach to the
identification of risks and, even though I cannot
personally recall this, but in the Legal Department,
they would have certainly flagged this up and decided
what kind of a rating to give it on the risk register.
So that's the first thing. And I think it was our Audit
and Risk Committee, under -- I think Matthew Lester was
the senior executive in charge of putting that process
in place. But this was a framework that was only just
beginning, in the 2010/2012 period.
Q. Can I just clarify: I think earlier in your evidence you
said you don't recall seeing prosecutions against
178
I just ask, because it's been wandering around in my
mind as this discussion has been going on, following
separation, Dame Moya, Post Office, in about 2013,
either reduced very dramatically, or ceased prosecuting
subpostmasters. It doesn't matter the reasons why, for
the purpose of my question. What about Royal Mail? In
the period that you were Chief Executive, between 2012
and 2018 when you ceased to be, did Royal Mail continue
to prosecute its employees if they thought that
appropriate?
A. Yes, from the information, sir, that has been provided
to me, prosecutions reduced over time, as we took other
strategies to protect the mail and to protect our
revenue, but there were prosecutions.
SIR WYN WILLIAMS: All right. Thank you.
Sorry, Mr Stevens.
MR STEVENS: Not at all, sir. Thank you.
Could we bring up the letter from Lord Arbuthnot to
you. It's POLO0105483. I think you were referring to
this letter earlier?
A. Yes, correct, sir.
Q. Can we go down, there's a -- there are two complaints in
this email. One is about the closure of a Post Office,
the second is in the second paragraph, and it says:
"lam concerned on a number of fronts. First, my
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constituents tell me that this case appears to be
a continuation of the problems that Post Office
employees have been having with the software system that
reconciled takings. I am aware of 34 individual
employees throughout the country who feel they have been
wrongly accused of fraud due to faults in this
particular system ..."
It goes on to discuss a meeting.
In your witness statement -- we don't need to bring
it up, but, sir, for you it's paragraph 112 -- you say
you have a positive recollection of this letter; is this
right?
1 do. I didn't remember that it was Lord Arbuthnot but
I remembered getting a letter around this time which
registered with me, and it registered with me because it
was different from the way in which the issue had been
described in our Audit and Risk Committee.
I think in your statement you refer to the fact that the
number, the 34 similar complaints, is that something
that triggered --
It did, yeah.
Were you concerned that there may possibly be an issue
with the prosecutions that Post Office pursued at this
point?
I didn't know about that. I was concerned that there
181
That document can come down. Thank you.
In your statement you refer to a conversation that
you remember having with Paula Vennelis thereafter. Did
you express those concerns to her?
Yes.
What did she say in response?
Well, I had suggested to Mrs Vennells that we really
needed to do a complete drains-up, root and branch
review of that system, taking into account, you know,
what people were saying about it. You know, this was
not any longer just a handful; I mean, this is
a significant group of people. And she said that the
system had been reviewed, it had been reviewed on
multiple times -- at - you know, multiple occasions,
that there was no problem with the system, that there
could be issues around keying errors but she had --
there, certainly, what I recall from the conversation --
she didn't think we needed to do the sort of independent
review that I was suggesting.
Why didn't you go ahead with an independent review
within Royal Mail?
That's a good question. I think I was somehow given
reassurance that it had been tested, it had been
reviewed but also, at that time, you know, all of the
issues, the substantive issues around separation, had
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was something wrong with the system and it -- that the
fault in the system was causing people to be falsely
charged and horribly falsely convicted. So I didn't
know that the process for the prosecutions was also the
subject of such, you know, disquieting and, you know --
But you had a concern about the convictions because of
the system?
I did. I thought, because what we were being told at
the audit committee -- and it's borne out in the
minutes -- we were told that there's no problem with the
system, and that we were also told that there were
a handful, a few people who were blaming the system but
the fault was not with the system. This caused me to
think about it in a different way.
Were you concerned that there may be claims against
Royal Mail Group?
No, not at all. I mean, it's hard for people to imagine
but, you know, we had the biggest fleet in the country.
We had thousands and thousands of suppliers. We had
lots of claims against Royal Mail. And so, you know,
I'm not -- I was not worried about claims about Royal
Mail. What I was worried about was that there might be
people who are being wrongfully convicted on the basis
of a false belief on our part that the system is, you
know, faultless.
182
been resolved. We had -- in the Post Office Board and
in the Royal Mail Board, our Executive Teams had been
given the go-ahead to sign the agreement, so the
practices and conventions and protocols that were in
place for companies that were entirely separate, those
were live and, for those two reasons, I didn't press it
further at that time.
Did you think, at that point, that that is an issue, the
allegation of potentially unsafe convictions; did you
see that as being something that totally transferred to
Post Office on separation?
Yes, because, you know, I thought that the prosecutorial
function, even if it may have come under the heading of
Royal Mail Group, I thought it was a team inside the
Royal Mail Group that carried out all of those tasks.
What do you mean by that when you say you thought it was
a team inside the Royal Mail Group --
I thought that -- well, let me try to put it in context.
When we did all of the work on the separation, in all
areas of the company, we had teams working at all levels
and there was an escalation process if there was any
issues or, you know, you couldn't get to resolution as
to how that particular area was going to be dealt with.
Nobody raised to me, in the context of that, that there
was any issue with respect to legal or criminal law, and
184
(46) Pages 181 - 184
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my assumption, perhaps wrong, was that this was a pretty
easy group of employees to move to the Post Office, my
assumption was because they had spent most of their
daily working time on Post Office matters.
So at this time, you did know there was a team in Royal
Mail working on the criminal law aspects which was to
transfer over, that's what I'm trying to -
Well, I'm just saying to you it wasn't raised to me as
an issue. I knew that there was a Royal Mail Criminal
Law Team but, perhaps wrongly, I thought, inside that
team, there were dedicated resources that were working
on criminal law matters for Post Office. That was my
assumption.
So in my conversations with Mrs Vennells, first,
I didn't know at that time that there was any issue
about the oppressive and harsh nature in which the
prosecutions were being conducted, but, secondly -- and
I think more importantly -- I thought these -- there was
a separation between prosecutorial matters inside the
Post Office versus prosecutorial matters inside the
Royal Mail.
I'm going to jump forward quite significantly in the
timeline now. Can we bring up PVEN00000500 and page 2,
please. These were documents provided by Paula Vennells
to the Inquiry to suggest that they are messages on
185
person that she has been portrayed.
So this is effectively supportive, saying you wouldn't
accuse anyone of doing anything wrong without a basis,
‘or something along those lines?
Well, I think it speaks for itself.
Can we please bring up PVEN00000533. It's another
message, it says:
"Dear Paula
“What a terrible time.
"Just tell the truth.
"I know you are a good person and friends will be
hard to find now.
“What has happened is a terrible, horrible thing.
So many lives ruined.
"Yours too.
"Just tell the truth.
"What you knew. What you thought at the time.
"What they told you!
"Any mistakes you made."
Do you recall roughly when you sent this text
message and what prompted you to send it?
I think I had been travelling and I had come back into
the country after an extended trip, and I think my
YouTube artificial intelligence was sending up things
for me to watch but I can't remember exactly.
187
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9 May 2022: do you accept these are text messages
between you and Paula Vennells?
Yes.
Can we go down, please, to the one at 8.41, and you say
at the bottom:
"Horizon is the real villain here and thank god we
finally learnt about the frailty in the system. We
think it is computerised, it is untamperable, infallible
"Not so.
"Stand tall.
"I know you are a good person and would never never
accuse anyone in the wrong."
Can I ask what you meant by that last line:
"I know you are a good person and would never never
accuse anyone in the wrong."
Well, the first thing I want to say is that I thought
this would be a private communication and I want to just
say there's a context to this. Mrs Vennells was being
vilified in the press, and we didn't know, at that time,
in 2022, what we know now, as a result of the evidence
that has emerged in this Inquiry. And so, at that time,
I could only say what I saw, and what I saw when
I worked with Mrs Vennells was a hard working executive
who was a problem solver, and not at all the kind of
186
We see, over the page, there's a reply, and then the
message starts:
"Paula,
“Am just back in the UK."
If we could then bring up PVENO0000532. We see that
message picking up there:
"Paula,
“Am just back in the UK.
“What I have learned from inquiry/Parliamentary
committee questions is very damaging.
"Nick was a poor witness."
Is that Nick Read?
Yes.
"Chairman gone. He will be next.
"When it was clear the system was at fault, the
[Post Office] should have raising a red flag, stopped
all proceedings, given people back their money and then
tried to compensate them for the ruin this caused in
their lives."
Go over the page, this is the reply:
"Yes, I agree. This has/is taking too long Moya.
The toll on everyone affected is dreadful.
“I hope you have a good break and are well.”
You then say:
"I don't know what to say. I think you knew."
188
(47) Pages 185 - 188
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What did you think Paula Vennells knew?
A. Oh, gosh. I think she knew, on the basis of the
evidence that has emerged in this Inquiry, that there
were faults in the system. I think that Post Office
Executives, including Mrs Vennells, continued to
slavishly, in my opinion, adhere to the position that
was not tenable, on the basis of the evidence presented
here, that there were no faults or, you know, if you
look at the evidence that has been given in my bundle
and has been presented to the Inquiry, going back to
2008, Fujitsu told Post Office employees, I don't know
who, that there was the ability to manipulate branch
accounts remotely.
And then, in 2010, it was -- that information went
beyond that individual exchange between Fujitsu and Post
Office. It went now into Post Office, 2011 --
Q. Sorry, I don't mean to interrupt, can I pause you there?
One thing I wanted to ask here is, there's a change from
the message I took you to first to here and you're now
saying "I think you knew". The change and the points
you're making there, what is the basis of the knowledge?
\s it things that have come out in this Inquiry?
A. Yes.
Is there anything else that you're basing that on?
A. No.
2
189
I understand there may be questions from Core
Participants. If I may just take a moment to get time
estimates, we had a slight break with the document.
(Pause)
Sir, we do have requests. Mr Henry has asked for
I think 10 to 12 minutes, and -- it's just Mr Henry,
sir.
‘SIR WYN WILLIAMS: = Right. Well, I am sure that Mr Henry
will adhere to his time estimate.
Over to you, Mr Henry.
Questioned by MR HENRY
MR HENRY: Absolutely, sir.
Dame Moya, you're a strong leader, would you agree?
A. I don't think it’s for me to say, Mr Henry.
Q. But you have clear objectives which you communicate
clearly to the people who work with you?
A. [have tried to do that, yes.
Q. Yes. You set the tone about what had to be done and how
it was to be accomplished, so far as the separation, the
investibility and the ultimate flotation, together of
course, with Sir Donald?
A. Yes, anda very strong Executive Team.
Q. Now, if it had become apparent that unpredictable
intermittent bugs, errors and defects in Horizon had led
to the prosecution, conviction and imprisonment of
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Q._ Has anything that's come out in this Inquiry made you
reflect on past events, conversations with others, when
you were in post in Royal Mail, in a different way?
A. Well, the only conversations I had were with people who
would probably be as shocked as I am that all of the
assertions and undertakings that had been given to all
of us, the Executive Team of Royal Mail, the Audit and
Risk Committee of Royal Mail, these were just not so.
So I don't think that those conversations would have
helped me. It was really -- what changed my mind was
the evidence that has come out of this Inquiry.
Q._ I perhaps didn't ask, my question is slightly different:
when you have seen something in this Inquiry and what
you've learned through the Inquiry, has any of that,
when you're looking back on conversations you may have
had with Paula Vennells in 2015, 2011, has any of that
information given you a different reflection on that
conversation, or do you see it in a different light?
A. I do see it in a different light. Because I do think
that we were misled. I think that it was grossly
understated, the gravity of the situation, and it has
had calamitous, calamitous results for people. So
I think we were misled, and this assertion continued,
you know, for a very long time.
MR STEVENS: Sir, those are all the questions I have.
190
innocent people, that would have threatened your
objectives, would it not?
A. No.
Why not?
A. Well, my objectives were to modernise the company, to
establish better relationships with our employees,
better relationships with our unions, to modernise the
technology, to try to create a company that had
a customer focus --
2
Q. Can! stop you there ~
A. Those were my objectives, and so, you know, if we were
doing something wrong, I would not shy away from it.
Q. So let's, then, proceed with that clear and unambiguous
statement. You wouldn't have shied away from it. But
it would have had a massive setback to the separation
and the investibility of the entity, would it not,
because you would have had this grotesque and appalling
scandal, wouldn't you, unfolding on your watch?
A. Well, I would say, if I knew then what I know now,
I would certainly not have managed this horrible,
grotesque -- to use your word -- in the way in which it
was managed. My view is that, when you find out that
something has been done in gross error, like this, you
put your hand up and you try to set it right as fast as
you can. And, you know, if you do that, as
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an organisation, you're far better off than if you just
let things drift and get bigger and cause more ruination
to people.
Everybody would agree with what you've just said, so why
didn't you surface the risk?
Well, I go back. I think we did. You know, if I look
at --
I'm sorry, you think you surfaced the risk?
Well, we didn't understand the risk because we were
deliberately, in my opinion, misled.
Part of it, though, you surely must accept, is that
significant risks which are contained in papers were
merely marked for noting -- so, for example, litigation
reports were marked for noting on your watch; you accept
that?
Yes, but that is not, in my opinion, Mr Henry -- and
I don't want to, you know, seem in any way
argumentative -- we knew where we had claims. We knew
what the value of those claims were, we knew how much
cash we had to reserve against those claims. We didn't
shy away from that. What we were told is that this is
a small number of claims, the likelihood of success --
I think the word that was used was "remote". This was
a gathering, gathering storm, I would say. And when we
activated the risk management system to at least surface
193
to claims. We had lots of claims. In fact, I think
£75 million was assigned to -- in one report that I saw.
So I think this was a complete mischaracterisation
of this horrible, horrible situation. And, of course,
the longer that situations like this go on, you know,
the worse it is for the poor people whose lives are
being ruined and also for the corporation who's, you
know, needing to be able to turn the page and -- I'll
stop there.
Can we go to the Ismay Report. You've got no
recollection of the Ismay Report?
No.
If it had become apparent that the Ismay Report was
a complete whitewash, that presumably, again, would have
been something that would have disrupted the separation
and flotation?
No, I don't think so, because if -- you know, as I said,
we had lots of claims. We had lots of technology risk.
The entire technology estate of the Royal Mail Group was
needing a complete revamping. So -- and our whole
approach was we will just start --
You'll just deal with it?
We'll deal with it.
But you were, again, misled? Now, are you sure that you
have absolutely nothing to do with the commission of the
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it, the way in which it was described was a gross
understatement of what it was.
I'm going to come to that but, now that you have raised
it, paragraph 137 of your statement -- no need to take
you to it -- but you said:
"Prior to separation, as I have explained above, the
narrative had focused on the audit preparedness of
Fujitsu, the small number of threatened claims by
subpostmasters and the insistence that Horizon was not
at fault. All of this now appeared to me an entirely
incorrect characterisation of the issues."
Now this was your point of view, however, in
2015/2016. Why didn't you get to grips with it before
separation; you say that you were misled?
I think we were misled. It certainly wasn't -- it was
the sort of mischaracterisation of a terrible situation,
of a gathering storm. It was a mischaracterisation that
was so great as to be incomprehensible.
So how did Mr Triggs mislead you because the reports
that you did not read and the reports notes that were
noted, that he prepared, characterised it in that way?
But he also said that the likelihood of the Post Office
being liable in these matters was not great, and he had
the advice of a very respected barrister, and so, as
I said, we ~ and we didn't shy away from assigning cash
194
Ismay Report, because the Ismay Report occurred, or
rather it was commissioned -- we have heard from
evidence, and it can be provided to you -- six days
after you assumed your post as CEO of RMG, and that
Mr David Smith commissioned it on 21 July of the year
that you took over, 2010.
Mr Ismay in evidence said that he had about two
weeks to prepare it. Did it have absolutely nothing to
do with your revamping and, as it were, stress testing
of all the systems that had to be dealt with in order to
meet the FCA eligibility requirements?
Absolutely nothing.
Thank you.
I only learned about how bad was our technology state
much later.
Now, can I go to one final thing before I close, and
this is a document that Mr Stevens took you to. It's
POL00030217.
You'll remember this is dealing with the Ernst &
Young report from 27 March 2011, and you were saying to
Mr Stevens that, essentially, the complexion was that
Fujitsu weren't prepared for the audit. In other words,
somehow or other, the message about remote access got
spun or laundered to be about Fujitsu's audit
preparedness, rather than this red flag which exists in
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the report.
It's your paragraph 73, in your witness statement,
where you say that, even if you had read it, you
wouldn't have regarded it as creating a problem with
Horizon, because you just thought that it was to do
with, as it were, hygiene concerning access.
Mr Stevens took you to page 33 of the report. Can
we go to the internal pagination, page 34. Could we go,
top left-hand -- yes -- and top box:
"Admin access parameter ADM", et cetera, et cetera,
et cetera.
I'm going to omit words and go down to the last six
lines:
"Unrestricted access to privileged IT functions
increases the risk of unauthorised/inappropriate access
which may lead to the processing or unauthorised or
erroneous transactions.”
For prosecutions that were predicated on the
integrity of the Horizon system, that was clearly a risk
that ought to have been drawn to your attention there
and then; do you agree?
I guess so, if it had been put together the way you just
have done.
But it's there in black and white.
Well, itis. It's part of a much larger document,
197
I'm going to stop you there because you have referred to
them -- it's POL00029114, POL00030482 -- again, neither
of which you claim to have seen or read, even though
you're on the circulation list, the Internal Audit
Review of Horizon.
But -- that is true, Mr Henry.
I mean, the fact is this was never bottomed out or
resolved under your leadership before separation, was
it?
I don't think that's correct. If you look at the work
that had been done, the follow-up work that had been
done by Derek Foster in the Internal Audit Group, it's
a very detailed piece of work. He set in place, in the
Post Office, a group that was charged with managing
every single item that had been raised in that
management letter, and progress was reported on
a regular basis. So I must say, I cannot agree with you
there. Even -- I did not have the primary
responsibility with the External Audit Group. That was,
of course, our Chief Financial Officer, but that does
not mean that -- the work that had been identified here.
And in fact, if you go to the audit plan of E&Y for
the following year, where they talk about how they are
going to approach a very extensive piece of work,
because now they have to present financials for the two
199
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Mr Henry. But yes, I think it should have been drawn to
our attention.
It's actually in the executive summary on page 3, one of
the opening lines of the document. You had to
strengthen the review of privileged access; do you see?
It's four lines from the bottom of the page:
"Strengthen the review of privileged access."
I mean, it ought to have been staring you, Dame
Moya, in the face, and you ought to have got a grip on
it.
I must say, I can understand why you would take that
point of view. I would only ask you to consider the
following: it was in the context of our outside auditor
telling us that they had themselves -- despite the
failures of Fujitsu in getting themselves properly
prepared to do a financial year-end close-up, that they
had themselves tested the systems and that they had
found that the systems were reliable and that there was
no integrity of data problem.
Secondly, in response to what had happened in the
2010/2011 audit, where they had had to do more work and
they were very put out about that, and it had cost more
money and had been inefficient -- in addition to that,
in response, we had set in place with Post Office
Limited a whole follow-up piece of work.
198
companies, you will see that they have put in place
measures where they would use their own software to test
every single aspect of the systems that would relate to
the reporting of data, whether in the Post Office or in
Royal Mail.
So I can understand how you would take the position
that you have taken but I would ask you to consider
those matters.
MR HENRY: Dame Moya, I have nothing further to ask you.
Thank you for answering my questions.
MR STEVENS: Sir, Ms Patrick has actually asked, as well,
for five minutes. I said before to her about asking
this question and I think it’s my error,
misunderstanding.
SIR WYN WILLIAMS: = Well, Ms Patrick, I don't want to stop
you, obviously, but is it something that's going to the
heart of the problems that I have or is it peripheral,
do you think?
MS PATRICK: I Sir, it's simply something that Dame Moya has
raised herself about her reaction to Mr Arbuthnot's
letter.
I'd like to pick up some correspondence on behalf of
Mr Julian Wilson that was sent shortly thereafter.
SIR WYN WILLIAMS: Yes, all right.
Questioned by MS PATRICK
200
(50) Pages 197 - 200
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MS PATRICK: Dame Moya, I'm going to take this as quickly as
I possibly can.
I represent some other subpostmasters who were
convicted and had their convictions overturned,
including Mr Trousdale, who sits on my right, and
Ms Hamilton, on my left.
Before I go on with the question I have, Mr Stevens
raised with you the involvement of Royal Mail Group and
Royal Mail Group Legal in prosecutions pre-separation.
Can you help us: who was responsible, at Executive level
or Board level, for oversight of the Legal Team in Royal
Mail Group?
The General Counsel.
Who did the General Counsel report to?
Me.
Thank you. Turning to the questions that I wanted to
address, the Inquiry is very familiar with Mr Wilson,
Mr Julian Wilson. His wife, Mrs Karen Wilson, is a Core
Participant. Mr Wilson died before his conviction could
be overturned in 2021 and she gave very powerful
evidence in Phase 1 as to the human impact on him of his
conviction. He'd been actively, very actively, involved
in the Justice for Subpostmasters Group before his
death.
Now, I don't want to take this too slowly. A number
201
prop
you see that there?
A. can.
Q. He is raising three questions about the appointment:
whether it's independent; whether they're going to look
first at the computer because he's saying he thinks
that's the problem; and, finally, he raises a specific
point about whether the independent review is going to
raise a particular issue about transaction management.
Can you see that there, Dame Moya?
A. Yes.
Q. So they're all questions about the independent review.
I think you've said that, by this time, you were all for
a drains-up, root-and-branch review. Dame Moya, you're
nodding. I have to say, you have to say for the -
A. [beg your pardon. Yes.
Q. So you were all for, by this point, root-and-branch
independent review, and that's what you were suggesting
to Mrs Vennells?
A. Yes.
Q. Now, can we look at the reply very quickly. The reply
you can see at POL00143463 and it doesn't come from you.
In your witness statement you say you can't recall if
you sawa reply --
A. No.
Q._ -- is that right?
203
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of our clients were prosecuted pre-separation and the
Inquiry has the documents. Mr Wilson's investigation
and trial documents appear under a Royal Mail Group
banner.
Now, you've talked about the correspondence with
Mr Arbuthnot and that changing your perception, and the
34 cases being particularly relevant to you. Now, in
your witness statement, you also deal with a letter
being received from Mrs Karen Lumley MP, on behalf of
Mr Julian Wilson -- and we won't turn it up; it's
paragraphs 127 and 128 of your witness statement. You
have said you can't recall seeing that correspondence.
If we turn it up very quickly, it's POLO0058098.
It'll come up. While it's coming up, the date on it, if
you recall, was July 2012, so, after you've seen the
letter from Mr Arbuthnot; is that fair, Dame Moya?
Yes. I think the letter -- the date there was December
2011; was that correct?
Yes, so after your perception might have changed about
these repeated claims.
Now, if we turn to page 2, we'll see Mr Wilson's
original message, and I know you've had a chance to look
at this in preparation for today. You can read it
yourself very briefly but he's reacting to the
appointment of an independent forensic accountant; can
202
Now, it's very similar -- if we scroll through the
reply when it comes up -- to a lot of correspondence the
Inquiry has seen in reply to subpostmaster messages.
It's POLO0143463. Thank you very much.
We can take it very quickly, I think. If we scan
through, you can see the first few paragraphs. It's
responding to the MP's message. You'll be aware the
email deals with the independent review. Third
paragraph: has been appointed, the scope of the
investigation is yet to be finalised:
"To ensure impartiality, Mr Arbuthnot has reviewed
and approved the appointment."
Then, I won't look at the detail, but if we can
scroll through the next four paragraphs, it’s dealing
with the specific thing he asked the independent
reviewer to consider and, if we scroll to the last of
the three paragraphs there, it ends with:
“Interruptions to service connections do not create
an issue for the Horizon system.
"Over the past ten years, many millions of branch
reconciliations have been carried out by 25,000
subpostmasters and their staff in Post Office branches
and transactions and balances accurately recorded. We
continue to have absolute confidence in the robustness
and integrity of the Horizon system, and our branch
204
(51) Pages 201 - 204
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accounting processes."
Dame Moya, if you had seen this reply, it's going
out to bat for the Post Office again, isn't it?
A. Sorry? I didn't catch that.
Q. It's going out to bat for the system again, isn't it;
it's saying the system is fine?
A. lagree.
Q._ Ifyou had seen this, after your perception had changed,
having seen the James Arbuthnot letter, would you have
been happy with this response going out in reply to
a letter to you?
A. No.
Q. Now, this is after you've seen the Arbuthnot letter.
You know this correspondence, I assume, had come in. Do
you see correspondence that comes to you?
A. Notnecessarily. Oftentimes, it is handled by the
Executive Correspondence Teams in Royal Mail and in Post
Office.
Q. Well, let's put that to one side. He's writing to you
as the Chief -- well, he's written to his MP and his MP
has directed to you as the parent, at the time he was
investigated.
Now, Mr Wilson aside, having had your perception
changed by the James Arbuthnot letter and knowing that
Royal Mail Group had been the Post Office parent for
205
A. No.
MS PATRICK: = Thank you.
Sorry, sir, there was no implication --
SIR WYN WILLIAMS: I just wanted to be clear, that's all,
about the sequence. I am now. Thank you.
MS PATRICK: = Thank you, sir.
Thank you, Dame Moya. I have no other questions.
MR STEVENS: Sir, we have also received a request from Dame
Moya's recognised legal representative to take a point
of clarification in re-examination. It's a short point.
MR BENWELL: I'm aware we are under pressure of time. It's
just a very short point.
SIR WYN WILLIAMS: Yes.
Questioned by MR BENWELL
MR BENWELL: Could we bring up Rob Wilson's witness
statement, please, which is WITN04210100, and if we
could go to page 2 of that document, please.
While that comes up, Dame Moya, you'll remember that
Mr Stevens raised the question as to the entity which
employed Rob Wilson and his role, and that that point
has been come back to on a number of occasions.
Perhaps I could just take you to paragraph 3 of his
statement, the first sentence. He says:
"In May 2002 I was appointed head of the POL CLT",
which I think is the Criminal Law Team.
207
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a very long time, did you ever look back and think "What
were we doing; did we have any role in this"?
A. I never asked that question, but I did ask questions,
going forward. But at that point, you know, we were
brushed aside, and I think the evidence that has been
provided to me in my bundles show that.
Q. Dame Moya, you asked questions but today, in response to
questions from Mr Stevens, you didn't know that Royal
Mail Group Legal had been in the thick of these
prosecutions?
A. I thought it was the Post Office Legal Team.
MS PATRICK: Okay. Dame Moya --
‘SIR WYN WILLIAMS: Who signed that letter? I can't see on
the screen.
MS PATRICK: Sir, it's not Dame Moya. It's executive
correspondence.
SIR WYN WILLIAMS: Well, I appreciate that.
MS PATRICK: Donna Gilhooly, sir.
SIR WYN WILLIAMS: Yes, so it is an answer by Royal Mail
because, by now, of course, separation has occurred,
hasn't it?
A. Yes. No, this is not Royal Mail, I don't think. I'm
not sure. It might be the Post Office.
MS PATRICK: That's why I suggested, Dame Moya, if you had
seen it, would you have agreed with it?
206
Then, about five lines down in that same paragraph,
he says:
"My main role was the responsibility for all
criminal prosecutions brought on behalf of [Post Office
Limited]."
Then perhaps we could scroll on to paragraph 4 of
that same statement, please, on the next page, where
Mr Wilson says:
"On 1 April 2012 [so at separation] I left [Post
Office Limited] and moved into Royal Mail."
So obviously we don't have his employment contract
but we do have his statement which says that, and
I wanted to draw that to the Inquiry's attention.
Obviously, Dame Moya may want to comment on that but
that may not be necessary.
A. No, I --
‘SIR WYN WILLIAMS: Well, I think I was aware of Mr Wilson's
statement and I am also aware that, during the course of
the Inquiry, there has been a degree of looseness -- if
I can put it in that way -- about precisely who worked
for whom, when.
MR BENWELL: Thank you.
SIR WYN WILLIAMS: Right, Mr Stevens. Is that it?
MR STEVENS: Yes. That's all the questions, yes.
SIR WYN WILLIAMS: I'm very grateful to you, Dame Moya, for
208
(52) Pages 205 - 208
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making your witness statement and for giving evidence
before me orally and answering a great many questions.
Thank you again.
THE WITNESS: Thank you, sir.
SIR WYN WILLIAMS: Right. We will resume on Tuesday,
Mr Stevens?
MR STEVENS: Yes, sir, thank you.
(4.23 pm)
(The hearing adjourned until 9.45 am
On Tuesday, 23 July 2024)
209
INDEX
JOANNE KATE SWINSON (affirmed) ...
Questioned by MR BLAKE ....
Questioned by MS LEEK ...
Questioned by MR JACOBS
Questioned by SIR WYN WILLIAMS ..
Questioned by MS PATRICK ....
Questioned by MS WATT ..
19 July 2024
127
131
133
139
DAME MOYA MARGUERITE GREENE (sworn) ..142
Questioned by MR STEVENS ..
Questioned by MR HENRY ...
Questioned by MS PATRICK ....
Questioned by MR BENWELL ....
210
142
191
201
207
(53) Pages 209 - 210
MR BENWELL: [3]
207/11 207/15 208/22
MR BLAKE: [21] 1/3
115 1/10 52/15 52/19
52/24 53/1 92/22 93/1
93/4 93/8 93/19 93/21
123/1 123/12 124/16
124/22 127/5 133/16
133/18 142/6
MR HENRY: [2]
191/12 200/9
MR JACOBS: [2]
127/7 131/19
MR STEVENS: [17]
142/17 142/19 142/23} I
162/17 162/21 162/25I
163/2 170/23 171/8
171/43 171/15 180/17]
190/25 200/11 207/8
208/24 209/7
MS LEEK: [2] 125/1
127/13
MS PATRICK: [11]
133/22 133/25 139/11
200/19 201/1 206/12
206/15 206/18 206/24
207/2 207/6
MS WATT: [2]
139/15 142/5
SIR WYN WILLIAMS:
[42] 1/4 1/7 52/18
52/20 52/25 92/25
93/3 93/17 93/20
123/8 123/15 124/1
124/13 124/18 124/24I
127/4 131/23 132/12
133/5 133/14 133/17
133/20 142/9 142/18
162/20 163/1 171/5
171/14 179/25 180/15}
191/8 200/15 200/24
206/13 206/17 206/19
207/4 207/13 208/17
208/23 208/25 209/5
THE WITNESS: [2]
142/14 209/4
40 [1] 152/14
"40/'11 [4] 152/14
44 [1] 152/14
13 [1] 70/6
"A[1] 85/21
‘A number [1] 85/21
‘anomalies' [1] 44/3
‘asks' [1] 98/11
‘awkward' [1] 63/6
‘discrepancies [1]
23/24
‘gag’ [1] 112/8
"gone [1] 84/2
‘had [4] 53/17
"Having [1] 117/21
‘hide [1] 112/8
[A] 53/6
"Ihave [1] 53/6
‘Justice [1] 26/9
‘mildly [1] 57/23
‘mythbusters' [1]
104/9
‘nothing [1] 72/10
‘operates [1] 44/14
‘red [1] 74/21
‘so [1] 44/10
‘taking [1] 107/18
‘the [2] 99/18 117/17
‘thematic [1] 90/15
wat [1] 85/23
0
0.03 [1] 94/1
0.12 [1] 44/4
0.65 [1] 44/4
4
1 April [4] 143/10
143/14 173/8 208/9
1.00 [1] 123/1
1.03 [1] 124/19
1.1.3 [1] 172/4
1.4 [4] 43/25
1.50 [3] 123/14
124/16 124/21
1.6 [1] 44/23
10 [3] 28/6 145/17
191/6
10 years [3] 18/13
24/8 24/25
10.36 [1] 62/22
10.57 [1] 52/21
100 [2] 26/11 60/23
103 [1] 164/13
41 [1] 153/11
11,500 [4] 55/13
11.10 [2] 52/19 52/23
112 [3] 5/25 6/1
181/10
119 [1] 143/18
12 [4] 44/4 53/2
174/2 191/6
12 billion [1] 146/10
12 November [1]
34/18
12,000 [1] 24/11
12.07 [1] 93/5
12.15 [1] 93/1
12.17 [2] 93/2 93/7
127 [1] 202/11
128 [1] 202/11
13 [1] 163/5
134 [1] 127/10
137 [1] 194/4
14 [3] 26/12 55/17
112/13
140 [2] 93/24 94/1
146 [1] 130/19
147 [1] 169/18
148 [4] 130/19
15 [2] 4/4 19/14
15 January [2]
104/17 105/20
415 July [1] 47/8
15 per cent [1] 4/20
15/20 [1] 19/6
150 [4] 170/3
16 December [1]
98/4
16 July [1] 62/23
17 December [3]
100/23 102/24 105/20}
17 September [1]
13/7
175 million [1] 24/13
47th [4] 100/3
18 [2] 2/24 119/15
18 December [1]
66/19
19 [1] 1/1
19 June [1] 1/16
1991 [4] 144/18
1996 [1] 144/18
2
2 July [4] 134/18
2.50 [1] 162/22
20 [2] 19/6 19/14
20 August [1] 17/25
20 March [1] 120/12
2000 [2] 24/22 28/23
2002 [1] 207/24
2005 [2] 2/6 144/22
2008 [3] 172/18
173/1 189/11
2009 [1] 26/10
2010 [6] 68/5 144/22
144/24 147/6 189/14
196/6
2010/11 [1] 153/11
2010/2011 [1] 198/21
2010/2012 [1] 178/23
2011 [11] 148/20
152/23 155/21 157/5
172/19 173/5 189/16
190/16 196/20 198/21
202/18
2011/2012 [1] 151/17
2012 [19] 2/16 10/20
21/21 119/25 143/10
143/13 143/14 143/19]
147/6 151/17 160/12
170/11 172/14 173/5
173/8 178/23 180/7
202/15 208/9
2013 [15] 2/24 10/20
36/14 40/10 41/9
42/14 66/19 75/17
119/7 119/14 125/10
134/18 135/24 165/14
180/3
2014 [10] 2/25 10/12
10/22 66/19 66/22
66/24 67/6 73/9 74/11
131/25
2015 [8] 2/6 2/16
17/2 55/19 115/2
120/12 124/1 190/16
2015/2016 [1] 194/13
2016 [1] 194/13
2017 [1] 2/7
2018 [1] 180/8
2019 [1] 2/7
2021 [1] 201/20
2022 [2] 186/1
186/21
2024 [3] 1/1 1/16
209/10
21 [3] 36/6 36/7
143/7
21 July [1] 196/5
22 December [3]
101/24 102/25 105/24}
23 [2] 41/9 150/11
23 July 2024 [1]
209/10
23 October [1] 28/14
230 million [1] 24/9
25 [4] 53/2
25 February [1]
411/17
25,000 [3] 18/16 29/1
204/21
26 [1] 156/15
27 March [2] 148/20
196/20
28 [2] 28/5 145/18
28 January [1]
107/11
3
3 April [1] 143/19
3 February [1]
128/16
3 July [1] 40/10
3.00 [2] 162/19
162/24
3.17 [1] 171/10
3.21 [1] 171/12
30 June [2] 2/24
66/19
34 [1] 150/15
31 March [2] 169/23
170/11
33 [4] 197/7
34 [4] 181/4 181/19
197/8 202/7
35 [4] 164/13
35,000 [1] 24/11
37 [1] 55/21
3rd [1] 165/4
40
4 March [4] 111/18
4 October [1] 21/21
4.23 [1] 209/8
4.5 [1] 173/10
40 [1] 143/17
44 [2] 170/4 170/7
47 [1] 5/25
49 [2] 17/21 170/9
5
5 July [2] 41/14
42/14
500 [1] 76/8
500,000 [1] 107/16
54 [2] 144/14 165/14
59 [1] 143/7
6
6 million [1] 107/14
6 September [2] 2/16
13/7
6-8 July [1] 53/6
65,000 [1] 44/14
6a [1] 165/5
7
7 January [1] 103/21
7 March [1] 165/13
700 [1] 24/14
73 [1] 197/2
74 [1] 109/6
75 million [1] 195/2
77 [A] 44/3
8
8 August [1] 64/11
8 December [2]
152/23 157/5
8 July [3] 41/9 48/3
54/22
8 May [1] 2/16
8.41 [1] 186/4
80 [1] 3/20
80 million [1] 24/9
80 per cent [1] 4/2
9
9 July [5] 47/8 56/6
61/23 62/22 135/9
9 March [1] 115/2
9 May [1] 186/1
9,000 [1] 140/13
9.39 [1] 61/23
9.45 [1] 1/2
9.45 am [1] 209/9
95 per cent [1] 60/24
A
ability [5] 132/2
137/18 151/18 152/11
189/12
able [34] 3/17 8/12
15/23 20/19 29/6
32/22 38/4 39/2 46/21
54/5 58/13 58/25
(54) MR BENWELL: - able
A
able... [22] 63/21
67/14 68/18 79/20
87/11 92/20 96/6 96/6
96/10 101/2 101/5
103/8 106/9 107/5
115/10 116/21 117/19}
137/1 137/22 154/2
154/18 195/8
about [236]
above [4] 29/15
104/3 117/1 194/6
abreast [1] 90/7
absolute [2] 94/14
204/24
absolutely [13] 9/24
51/14 51/17 81/25
101/8 101/18 134/16
139/8 141/6 191/12
195/25 196/8 196/12
accelerate [2] 88/12
115/22
accept [10] 86/5
145/3 168/7 172/7
175/13 175/16 177/4
186/1 193/11 193/14
accepted [1] 121/21
accepting [2] 85/3
100/7
access [23] 22/11
36/13 54/25 135/6
135/10 135/14 135/19)
141/4 150/2 150/17
151/14 151/16 151/18
152/12 154/5 155/10
196/23 197/6 197/10
197/14 197/15 198/5
198/7
accomplished [1]
191/19
accordance [2]
81/23 173/24
Accordingly [1] 26/4
account [6] 7/16 22/1
57/20 58/1 64/18
183/9
accountability [9]
5/5 5/13 5/19 5/22 6/2!
12/3 12/11 12/13
12/22
accountable [6] 5/4
5/15 5/16 5/17 11/19
12/10
accountant [1]
202/25
accountants [8] 18/5
18/21 26/19 29/19
29/22 32/18 48/13
116/3
accounted [1] 84/12
accounting [15]
18/13 23/25 24/12
24/21 27/15 28/22
48/20 49/16 50/20
56/9 62/11 83/9 151/5)
153/17 205/1
accounts [3] 24/16
151/19 189/13
accumulated [1]
42/7
accuracy [3] 26/6
31/23 95/18
accurate [3] 32/3
67/17 138/18
accurately [4] 17/9
18/15 28/25 204/23
accuse [3] 186/13
186/16 187/3
accused [3] 166/13
173/22 181/6
achieves [1] 44/9
acknowledge [1]
84/15
acknowledged [1]
50/15
acquitted [1] 158/12
across [9] 3/17 24/10
47/2 48/15 74/2 119/3
156/7 162/7 178/12
act [4] 23/7 54/18
79/2 134/1
acted [1] 122/23
acting [2] 46/13
98/23
action [5] 21/10
26/13 29/4 44/6 79/19
actions [3] 53/8
156/17 160/23
activated [4] 156/4
158/19 177/20 193/25)
actively [2] 201/22
201/22
activities [1] 150/6
acts [1] 80/25
actual [4] 5/2 39/16
43/13 147/6
actually [40] 5/9 11/8
30/14 30/20 30/25
32/11 33/23 37/25
38/12 54/15 56/9
56/12 58/24 59/15
69/13 69/24 72/1
72/13 72/16 82/9
88/23 105/19 106/3
107/4 114/17 117/19
118/1 122/14 123/13
123/19 128/22 131/13)
132/6 133/5 138/4
141/23 150/25 171/16)
198/3 200/11
ad [1] 43/8
ad nauseam [1] 43/8
add [2] 39/15 85/19
adding [1] 133/11
addition [3] 96/8
129/8 198/23
additional [5] 108/25
109/1 110/4 154/1
161/1
Additionally [1]
44/12
address [10] 22/3
41/16 46/24 64/20
71/15 90/10 165/5
165/6 165/25 201/17
addressed [2] 45/23
46/16
addresses [1] 109/20)
adhere [2] 189/6
191/9
adjourned [1] 209/9
Adjournment [1]
124/20
ADM [1] 197/10
Admin [1] 197/10
admission [1] 174/7
admitted [3] 44/2
84/4 134/14
advance [3] 60/14
77/15 96/23
advantages [1]
111/24
advice [17] 52/10
80/2 104/1 119/10
120/20 122/18 125/20
126/10 126/20 127/21
130/14 135/3 138/16
165/17 173/14 173/18}
194/24
Advices [4] 125/4
125/7 126/5 126/17
advised [4] 102/7
108/16 109/3 115/6
advising [2] 70/8
168/6
advocating [1] 51/14
aegis [1] 177/17
affairs [11] 2/14 3/12
3/12 4/2 4/5 4/24 4/25
5/3 14/16 117/10
129/9
affect [1] 6/4
affected [9] 6/25 21/8I
21/10 44/3 63/24 74/7
102/5 130/12 188/22
affecting [1] 141/16
affirmed [2] 1/8
210/2
afoot [1] 101/11
afraid [1] 135/1
after [28] 22/20 30/11
32/10 41/19 43/18
62/24 70/11 75/23
79/16 82/22 92/12
93/1 100/23 103/2
103/14 106/2 116/14
143/19 143/21 154/1
169/11 170/11 187/23
196/4 202/15 202/19
205/8 205/13
afternoon [7] 64/24
125/1 127/7 139/15
142/13 142/17 162/18}
again [21] 2/6 28/16
29/14 38/16 45/20
53/7 73/8 89/4 115/16
147/18 154/10 155/16}
157/11 163/25 171/7
195/14 195/24 199/2
205/3 205/5 209/3
against [16] 7/1
13/21 84/5 91/20
107/1 166/21 167/18
172/9 175/23 177/14
178/7 178/25 179/6
182/15 182/20 193/20
agencies [1] 34/5
agency [2] 7/16 34/8
agenda [2] 109/4
157/25
ago [4] 54/7 57/25
136/19 179/4
agree [28] 47/5 52/3
52/9 82/1 94/10 95/10
103/4 107/22 108/12
110/22 113/5 113/6
115/5 140/6 145/7
145/12 147/8 175/2
175/20 176/1 176/16
176/19 188/21 191/13}
193/4 197/21 199/17
205/7
agreed [11] 18/19
19/3 23/2 26/18 31/1
33/16 33/20 49/23
50/14 51/4 206/25
agreeing [2] 26/16
30/8
agreement [14]
49/24 110/19 111/9
111/10 111/15 113/2
143/9 143/12 143/20
168/24 169/5 169/19
170/13 184/3
agreements [1]
112/5
Ah [2] 17/21 133/20
ahead [4] 94/25 98/6
183/20 184/3
aims [1] 6/9
Alan [9] 64/15 65/14
101/25 102/8 102/24
105/23 108/12 121/14}
122/7
alarm [1] 64/9
alert [1] 179/17
Alexander [4] 76/5
76/16 77/1 77/13
Alice [20] 13/11
13/16 13/25 14/4
15/11 15/23 21/14
36/10 36/19 68/3
TAIT 75/5 77/15
78/19 79/8 81/13
81/15 119/24 125/10
126/19
all [79] 4/12 9/22
12/17 14/5 15/8 19/8
22/4 29/13 29/16
30/11 31/18 35/14
38/1 39/25 42/9 43/7
44/15 48/15 52/18
55/11 55/14 56/21
57/2 66/24 70/24
73/14 76/23 78/16
79/7 79/21 91/6 93/3
93/17 96/3 100/16
111/25 113/4 114/12
115/14 115/20 118/21
131/15 132/3 138/13
139/22 142/6 142/7
142/14 160/4 160/5
161/25 162/6 162/7
163/19 170/19 178/8
179/14 180/15 180/17
182/17 183/24 184/15)
184/19 184/19 184/20)
186/25 188/17 190/5
190/6 190/25 194/10
196/10 200/24 203/11
203/12 203/16 207/4
208/3 208/24
allegation [2] 24/20
184/9
allegations [3] 14/18
104/23 166/18
alleged [2] 177/10
177/11
Alliance [4] 45/8
45/24 85/2 112/4
Alliance’ [1] 26/10
allocation [1] 158/6
allow [1] 174/5
allows [2] 110/11
158/14
almost [6] 108/22
138/1 160/4 162/12
164/2 164/10
alone [1] 59/3
along [4] 14/15 40/25
125/16 187/4
alongside [3] 28/9
42/8 46/22
already [4] 20/17
67/3 116/4 155/22
also [76] 2/21 2/25
3/16 4/6 8/20 11/20
17/8 19/9 22/17 23/5
23/6 25/11 26/1 29/2
34/12 40/8 41/23 49/1
49/9 50/3 52/2 53/7
55/13 58/11 58/23
59/14 59/19 61/4 64/5I
65/8 71/15 75/18 76/8)
80/8 82/14 87/11 97/5
97/16 104/9 105/1
106/8 112/23 113/21
113/25 114/22 116/2
417/17 120/2 120/5
(55) able... - also
A
also... [27] 123/5
128/4 131/3 131/5
131/6 133/9 133/25
139/23 143/1 145/14
150/3 153/9 155/7
157/7 158/16 158/17
164/6 166/21 177/18
182/4 182/11 183/24
194/22 195/7 202/8
207/8 208/18
alternative [1] 61/10
although [9] 8/18
22/8 31/10 54/12
54/14 70/13 90/18
97/17 141/13
Altman [1] 97/14
always [6] 6/5 8/4
27/17 59/20 127/22
161/16
am [31] 1/2 10/1 18/8
29/2 35/7 47/7 52/21
52/23 56/22 104/13
104/21 115/13 115/16}
122/24 131/3 144/9
152/11 168/1 173/2
173/3 175/5 179/19
180/25 181/4 188/4
188/8 190/5 191/8
207/5 208/18 209/9
amended [2] 118/2
118/8
amendment [1]
117/12
among [1] 66/6
amongst [2] 19/13
43/4
amount [10] 4/16
6/15 30/23 31/14
35/18 56/1 75/13
81/13 81/16 162/10
amounts [2] 56/2
173/21
analysed [1] 176/10
analysing [1] 145/7
analysis [2] 86/5
100/18
Angela [2] 64/16
133/25
angry [1] 130/15
anguish [1] 122/20
annexes [1] 15/12
annoyed [1] 154/12
annual [1] 153/24
anomalies [2] 44/6
135/25
another [15] 7/23
12/12 17/19 19/13
28/15 34/10 53/13
95/14 104/17 112/10
128/15 128/21 146/21
155/7 187/6
answer [14] 5/9 15/6
34/7 34/8 58/7 58/8
59/1 59/10 95/2 95/3
137/1 156/8 179/5
206/19
answered [2] 59/8
59/21
answering [5] 5/12
63/20 142/11 200/10
209/2
answers [6] 19/10
60/15 63/21 77/8
94/13 96/6
Anthony [8] 87/2
90/10 91/18 91/24
92/11 92/18 101/3
108/18
anticipate [1] 123/5
anticipated [2] 89/23
140/24
any [82] 5/9 12/20
13/21 14/17 16/1
16/16 16/23 17/5
19/10 20/10 24/23
26/21 26/23 28/7
37/21 43/9 47/19
50/16 56/15 60/13
61/12 61/15 62/14
66/15 67/20 70/9
72/21 74/21 75/3
75/19 86/8 87/5 91/5
94/15 96/8 96/17
96/22 115/18 116/15
116/20 116/22 117/23)
118/6 118/11 118/20
118/23 119/14 119/15)
119/16 125/7 126/10
130/25 131/5 131/19
135/7 136/16 136/22
146/6 148/13 149/8
151/17 154/6 154/8
154/11 158/8 159/4
159/12 159/12 159/21
160/7 161/13 167/11
173/13 183/11 184/21
184/25 185/15 187/19
190/14 190/16 193/17,
206/2
anybody [4] 30/8
52/7 97/6 123/2
anyone [9] 47/20
99/17 135/4 154/23
157/20 161/3 186/13
186/16 187/3
anything [17] 14/15
40/25 57/13 63/6
87/17 88/19 102/22
119/5 124/4 133/17
159/9 160/3 160/7
176/13 187/3 189/24
190/1
anywhere [3] 156/7
162/5 173/15
apart [2] 114/12
121/21
apologise [6] 133/21
134/3 134/4 164/24
171/9 172/17
appalled [1] 100/6
appalling [1] 192/17
apparent [2] 191/23
195/13
apparently [1] 98/7
appeal [6] 87/10
92/10 116/22 118/7
118/22 165/15
appealed [1] 49/17
appeals [1] 117/25
appear [4] 111/3
111/21 139/15 202/3
appeared [2] 51/1
194/10
appears [4] 34/18
68/9 170/4 181/1
applicant [1] 90/20
applicants [4] 115/23}
116/4 116/9 116/21
application [1]
149/22
Applies [1] 172/2
apply [1] 173/4
appoint [2] 76/6
132/25
appointed [6] 27/19
65/8 168/17 177/18
204/9 207/24
appointing [1] 80/14
appointment [6]
18/23 78/24 158/17
202/25 203/3 204/12
appraisal [1] 132/1
appraised [1] 70/16
appreciate [6] 25/24
51/7 69/16 91/16 92/8
206/17
appreciative [1]
57/18
apprised [1] 177/21
approach [15] 33/8
46/17 76/15 102/8
102/10 110/20 110/22]
111/24 112/12 117/1
146/20 178/5 178/14
195/21 199/24
approached [1]
78/17
appropriate [20]
32/19 32/24 33/21
45/13 52/16 58/17
58/19 70/10 91/8
91/23 92/1 92/9 92/15
92/19 92/23 94/18
108/10 120/14 167/9
180/10
appropriately [1]
100/25
appropriateness [1]
75/8
approval [1] 76/19
approve [1] 82/23
approved [2] 18/23
204/12
approximate [2]
68/10 123/20
approximately [1]
140/13
APPSUP [2] 151/10
151/15
April [9] 73/9 88/11
143/10 143/14 143/19}
169/23 172/19 173/8
208/9
aptitude [1] 81/21
Arbuthnot [25] 18/22
26/24 40/8 45/8 45/25
46/19 48/10 48/11
49/14 49/21 50/14
51/1 53/19 59/5 59/23
98/5 168/1 180/18
181/13 202/6 202/16
204/11 205/9 205/13
205/24
Arbuthnot's [2]
29/20 200/20
ARC [7] 145/23
148/18 150/7 152/6
152/22 153/6 159/15
archaic [2] 146/19
152/9
architecture [1]
161/24
are [100] 2/3 3/6 5/21
11/11 11/14 13/18
13/18 13/25 14/3
20/13 23/6 24/1 28/13)
28/14 29/6 29/12
29/15 45/11 48/22
54/1 54/12 54/13
54/15 55/4 55/7 56/22)
57/17 58/1 61/25
62/20 63/23 64/6 71/1
75/21 78/12 80/8
80/16 84/2 84/22
86/11 88/6 88/13
88/18 88/24 89/3
93/25 94/2 96/4 99/14)
99/20 100/17 104/4
104/5 104/7 104/9
106/11 108/4 111/6
111/9 112/1 112/8
112/20 117/20 122/1
123/1 123/16 125/5
126/14 129/6 129/13
129/16 130/19 130/22)
131/25 142/6 144/5
147/24 151/9 157/6
157/24 166/11 166/15}
175/5 176/23 177/6
179/20 180/22 182/23
185/25 186/1 186/12
186/15 187/11 188/23}
190/25 193/12 195/6
195/24 199/23 207/11
area [8] 4/18 14/1
14/14 69/5 137/10
149/14 164/2 184/23
areas [16] 4/22 4/23
7/13 13/21 14/3 14/14
35/4 37/22 74/2 80/21
149/21 163/17 163/18)
163/24 164/1 184/20
aren't [1] 176/16
arguably [2] 82/13
177/12
argue [1] 69/23
arguing [1] 79/15
argument [2] 66/3
121/21
argumentative [1]
193/18
arguments [1] 75/1
arising [3] 125/4
160/24 176/15
arm's [9] 7/24 127/14
127/18 129/9 130/21
136/21 137/15 137/24)
138/23
arm's-length [2]
130/21 137/24
arms [1] 179/13
around [27] 15/18
24/8 24/11 24/13
26/11 40/20 41/14
53/22 55/10 55/18
70/22 73/9 76/3 85/11
123/3 123/6 123/12
123/23 140/10 141/7
161/17 161/24 179/13}
180/1 181/14 183/16
183/25
arrived [1] 163/8
article [3] 156/4
158/19 177/25
articulate [1] 162/11
artificial [4] 187/24
as [257]
aside [2] 205/23
206/5
ask [46] 1/18 34/13
56/3 56/15 76/5 76/25
77/8 85/25 89/9 91/1
91/9 91/23 92/11
93/12 98/12 98/22
113/2 113/5 114/1
114/24 124/22 127/20)
129/5 134/21 135/4
137/22 140/9 140/25
141/14 143/5 143/25
144/10 144/11 150/8
150/9 150/21 162/19
171/2 180/1 186/14
189/18 190/12 198/12)
200/7 200/9 206/3
asked [44] 5/10 15/6
18/24 19/16 19/23
20/24 22/24 23/3 25/5I
34/16 39/3 39/8 40/11
(56) also... - asked
A
asked... [31] 55/19
56/6 56/11 56/23 57/5)
58/6 60/16 63/17 86/1
86/10 90/3 99/21
105/3 113/5 113/23
121/14 122/8 122/14
122/24 126/12 126/20
128/16 128/24 138/6
141/18 173/3 191/5
200/11 204/15 206/3
206/7
asking [20] 17/3 54/1
55/3 56/20 60/13
63/22 64/2 67/21
72/24 76/15 77/25
98/19 99/9 100/11
103/25 116/7 130/2
173/3 178/5 200/12
asks [1] 98/15
aspect [5] 20/19
44/24 100/7 162/12
200/3
aspects [4] 11/1
14/23 49/10 185/6
assertion [2] 27/18
190/23
assertions [1] 190/6
assess [1] 162/2
assessed [1] 179/19
assessment [1]
100/18
assigned [2] 151/9
195/2
assigning [1] 194/25
assist [10] 6/11
29/23 37/2 54/21
86/16 95/16 102/7
109/22 112/25 118/14}
Assistant [1] 144/17
associated [2]
145/20 150/5
assume [4] 15/3
131/25 132/4 205/14
assumed [2] 133/21
196/4
assumption [6]
16/20 27/8 30/1 185/1
185/3 185/13
assumptions [1]
146/10
assurance [4] 72/8
153/4 153/7 153/21
assurances [8] 82/5
82/7 82/8 119/1 119/2
119/18 119/23 133/3
at [295]
attached [8] 22/23
23/1 42/16 42/21 64/1
65/13 74/17 104/21
attachment [3] 23/16
77/20 77/21
attempt [3] 40/24
41/2 65/15
attempting [1]
127/20
attendance [1] 157/6
attended [2] 104/8
160/7
attending [1] 142/25
attention [13] 17/1
25/16 47/22 50/5
63/15 65/22 66/5
132/3 132/19 171/7
197/20 198/2 208/13
attract [1] 174/10
audit [37] 26/8
145/23 148/9 149/17
151/20 151/25 152/13}
152/22 153/5 153/11
153/15 153/16 153/24)
154/15 154/19 154/24)
155/3 156/2 156/4
157/4 158/19 159/25
160/15 168/20 177/17)
178/19 181/17 182/9
190/7 194/7 196/22
196/24 198/21 199/4
199/12 199/19 199/22,
audited [1] 24/16
auditor [3] 152/1
154/12 198/13
auditors [2] 149/6
149/9
August [3] 17/25
64/11 74/11
author [2] 27/5
152/23
authorisation [1]
153/19
authority [3] 61/14
99/15 120/5
Authority's [4] 174/6
autonomous [1]
163/9
autumn [2] 101/16
119/14
available [4] 6/4
19/16 116/4 117/18
avenues [2] 116/22
118/21
average [1] 4/20
avoid [2] 112/7
117/24
aware [39] 9/8 9/9
9/17 14/24 16/8 21/3
29/2 31/10 40/23
44/16 47/23 48/22
48/24 49/5 63/12
68/24 78/23 86/11
94/25 108/4 123/17
125/5 126/14 149/2
150/24 151/4 151/17
155/22 166/2 166/6
166/8 166/10 166/20
170/15 181/4 204/7
207/11 208/17 208/18)
awareness [1] 38/10
away [6] 10/21 80/23
192/12 192/14 193/21
194/25
back [42] 4/21 10/22
11/1 30/18 36/5 38/5
41/4 41/13 41/21
52/19 62/25 71/18
72/2 72/23 75/25
77/10 80/24 87/23
89/8 93/1 108/21
109/2 123/14 124/16
131/25 138/19 138/24)
139/6 150/21 152/4
172/16 173/1 173/10
187/22 188/4 188/8
188/17 189/10 190/15}
193/6 206/1 207/21
backed [1] 176/7
background [4]
15/13 36/22 144/13
175/19
backgrounds [1]
9/16
bad [1] 196/14
balance [3] 57/7
80/12 80/16
balanced [1] 113/8
balances [4] 18/15
24/13 28/25 204/23
ball [1] 162/5
banner [1] 202/4
barred [1] 156/25
barrister [1] 194/24
based [5] 125/24
126/6 126/18 126/25
136/5
basic [2] 96/13 101/6
basically [9] 55/7
72/6 73/10 73/19
106/1 106/5 124/1
125/16 128/19
basing [1] 189/24
basis [17] 8/11 24/7
49/16 82/7 84/22
116/12 158/4 166/25
167/24 168/17 176/22
182/23 187/3 189/2
189/7 189/21 199/17
bat [2] 205/3 205/5
Bates [12] 64/15 65/4
65/14 101/25 102/9
102/25 105/23 107/10
108/12 121/14 122/7
134/16
Batten [6] 42/13
61/22 62/24 71/10
90/8 129/12
BDB [1] 151/11
be [320]
bear [1] 147/6
bears [1] 147/20
became [8] 8/23
30/15 38/21 66/21
66/23 114/25 123/18
144/24
because [96] 5/6
11/12 11/15 19/17
20/2 30/2 30/20 32/6
39/3 39/11 39/21
41/23 54/23 55/4 56/4)
56/17 58/8 58/18
58/24 59/14 59/17
60/15 61/10 64/5 66/8
66/16 70/14 72/14
73/16 73/24 75/21
76/11 76/18 76/20
79/11 82/1 85/4 86/19
87/9 88/13 91/18
95/25 96/16 102/21
106/11 109/14 114/3
119/19 119/21 120/1
121/20 122/15 124/16}
126/21 129/13 130/4
130/15 132/13 136/19}
138/3 141/22 141/24
154/13 156/1 160/3
161/13 161/21 161/23}
162/9 163/19 166/8
167/3 167/11 168/3
170/25 172/14 172/21
175/6 178/9 180/1
181/15 182/6 182/8
184/12 185/3 190/19
192/17 193/9 194/19
195/17 196/1 197/5
199/1 199/25 203/5
206/20
become [6] 90/15
162/3 164/5 177/22
191/23 195/13
been [244]
before [38] 20/8
28/14 30/8 31/2 38/8
38/18 41/15 57/9
66/25 67/9 70/6 75/9
75/22 76/14 80/1 80/6
106/4 118/13 123/16
125/8 125/11 134/17
135/8 141/12 143/5
150/9 161/4 163/8
169/9 179/25 194/13
196/16 199/8 200/12
201/7 201/19 201/23
209/2
beg [1] 203/15
beggars [1] 119/19
begin [1] 71/3
beginning [4] 10/21
20/25 86/22 178/23
begins [1] 13/9
behalf [9] 23/22
40/14 55/5 61/8 63/23
106/16 200/22 202/9
208/4
being [145] 3/19 4/15
5/3 6/23 8/16 11/12
12/18 13/15 14/18
14/24 15/6 17/4 18/21
20/21 20/24 21/4 21/5I
21/11 24/20 25/14
25/24 26/22 27/16
29/21 32/21 33/7 33/8I
34/16 35/6 35/25
36/15 37/12 38/22
39/7 40/1 40/2 40/15
41/10 43/5 43/9 45/5
45/23 46/7 46/14
46/15 46/15 47/16
52/10 52/10 53/19
55/11 55/16 56/2
57/23 57/24 58/9
58/13 58/14 58/23
60/9 61/9 64/25 71/7
72/16 73/15 75/8 75/9)
75/9 87/13 87/14
89/16 90/5 92/15
94/19 95/20 95/24
97/12 97/15 97/19
100/9 100/18 101/16
102/21 103/9 105/15
106/9 106/23 107/2
108/16 109/3 109/8
110/3 113/3 113/18
113/20 113/22 121/5
123/10 123/17 123/23)
124/11 126/11 127/11
127/14 127/14 127/17)
129/9 131/6 134/20
136/8 136/24 138/17
138/22 140/5 141/5
143/25 144/21 151/24)
154/21 158/9 160/7
160/19 161/8 161/9
164/10 165/6 167/3
168/22 174/23 177/6
177/23 178/7 179/1
179/7 179/15 179/20
182/8 182/23 184/10
185/17 186/19 194/23)
195/7 202/7 202/9
belief [4] 1/23 119/19
144/6 182/24
believe [10] 11/23
16/9 17/7 27/14 47/19}
129/23 135/19 159/23)
172/14 175/9
believed [3] 119/23
120/8 120/8
believes [4] 24/23
50/18 58/9 118/7
Belinda [4] 99/4
99/11 99/18 99/25
Belinda/Patrick [1]
99/11
bells [1] 64/9
below [2] 71/11
83/10
benefit [2] 87/18
173/9
(57) asked... - benefit
B
BENWELL [2] 207/14
210/24
bespoke [1] 33/24
best [8] 1/22 3/25
46/23 53/24 86/20
100/13 115/7 144/5
better [8] 50/15
71/13 88/4 97/2 138/2
192/6 192/7 193/1
between [35] 2/6 2/7
2/16 3/7 4/3 8/1 10/3
10/3 16/12 16/15
40/19 51/12 53/4 71/3)
71/6 84/12 84/16
86/19 90/11 90/20
121/2 126/18 143/14
144/18 144/22 146/9
160/6 161/20 161/20
164/10 173/14 180/7
185/19 186/2 189/15
beyond [3] 34/25
76/2 189/15
big [14] 7/8 25/8 31/3
68/1 79/6 107/12
146/8 146/17 147/8
148/10 149/8 152/7
162/6 176/9
bigger [1] 193/2
biggest [1] 182/18
Bill [1] 4/15
billion [2] 146/10
146/10
Bills [4] 4/9 4/10 4/14
4/17
bin [1] 40/2
BIS [10] 3/8 3/11
3/21 8/18 11/23 11/24
59/3 68/20 70/22
82/12
BIS/GEO [1] 70/22
bit [14] 6/19 9/10
9/12 14/19 35/4 59/13,
60/6 72/7 78/1 86/22
95/13 96/12 113/10
140/21
bizarre [1] 15/2
black [1] 197/24
Blackfriars [1] 164/8
BLAKE [8] 1/9 52/18
58/15 93/18 124/14
133/17 134/6 210/4
blame [4] 122/2
122/2 129/8 129/17
blaming [1] 182/12
bland [1] 72/4
Board [36] 11/6
11/18 12/15 12/17
12/19 66/24 68/13
78/12 78/22 79/4 80/6
80/11 80/19 80/23
81/7 104/12 130/4
132/18 132/23 138/3
151/1 154/19 158/18
161/9 161/11 161/21
167/6 177/13 177/16
178/6 179/5 179/17
179/19 184/1 184/2
201/11
Board's [3] 78/25
79/8 147/23
Boards [1] 145/24
bodies [3] 61/16
130/22 137/24
body [6] 12/20 96/17
136/21 136/24 137/15)
138/23
Bogerd [1] 64/16
bold [1] 83/15
bombshell [1] 47/17
book [2] 174/21
174/24
borne [1] 182/9
both [21] 2/9 3/2 3/4
10/12 12/2 15/11
24/25 42/22 75/21
77/5 81/18 99/4
106/22 112/6 136/11
136/24 139/23 140/4
162/8 177/5 177/6
bottom [23] 26/20
29/11 49/12 57/14
61/21 65/2 70/19
89/12 98/1 103/21
107/17 112/9 120/18
148/6 150/16 150/16
153/23 160/17 160/21
165/25 178/14 186/5
198/6
bottom-up [1] 148/6
bottomed [1] 199/7
bound [1] 128/2
boundaries [2] 92/8
92/21
Bourke [1] 99/4
box [23] 19/5 19/22
28/9 30/7 30/11 30/12
30/21 37/13 38/9
38/11 39/8 41/18
41/20 41/22 42/8
42/24 51/23 56/16
59/9 61/11 109/16
138/11 197/9
boxes [2] 22/13
111/7
branch [12] 18/14
28/23 29/16 55/13
151/11 151/18 183/8
189/12 203/13 203/16)
204/20 204/25
branches [8] 44/4
44/4 135/7 142/1
142/2 155/20 157/16
204/22
break [15] 48/6 52/17
52/22 58/12 92/24
93/6 123/11 134/4
162/18 162/19 162/23}
170/25 171/11 188/23
191/3
breakdown [3] 56/7
56/11 161/10
breaking [1] 73/15
Brentnall [1] 134/2
brief [10] 3/11 4/23
8/25 9/1 22/6 22/7
38/10 71/1 74/3
108/24
briefed [22] 16/3
16/7 21/23 40/2 60/10
73/15 97/17 100/25
101/9 101/16 124/5
127/17 135/8 135/16
135/18 136/8 136/24
139/9 167/3 168/10
168/14 168/22
briefing [54] 11/4
13/7 14/17 15/12 16/1
16/5 19/1 19/7 20/8
20/13 23/13 25/3
36/17 37/17 37/18
37/21 40/5 41/7 42/22
42/25 43/5 43/5 47/16
47/18 48/10 48/11
48/24 49/1 50/6 50/8
54/24 56/4 58/11 60/1
70/25 71/6 71/20
75/24 76/2 79/21 83/4
85/17 87/16 93/10
93/12 94/25 96/21
98/17 105/11 119/24
122/12 136/10 138/22]
139/9
briefings [13] 8/6
9/21 10/19 13/4 14/23
15/7 15/9 23/9 39/20
55/11 55/18 71/18
139/19
briefly [9] 35/8 79/10
106/11 108/15 109/22
110/1 113/16 116/7
202/24
bring [22] 5/24 17/6
19/23 109/7 109/9
112/24 115/10 117/1
134/10 145/17 165/1
165/1 170/23 171/17
175/3 179/24 180/18
181/9 185/23 187/6
188/5 207/15
bringing [4] 65/21
66/4 175/24 176/19
brings [2] 117/6
175/21
British [1] 15/1
broad [3] 4/25 145/2
156/15
broaden [1] 112/5
broadly [2] 121/10
149/2
broke [1] 73/13
brought [9] 15/22
17/1 26/14 27/2 50/4
63/15 75/25 78/21
208/4
brushed [1] 206/5
Brydon [2] 151/23
158/16
budgets [1] 76/24
bug [1] 136/1
bugs [4] 135/5
135/10 135/22 191/24}
build [2] 68/11 89/1
building [1] 8/20
bull [1] 78/3
bullet [6] 45/20 80/3
84/19 89/10 94/13
119/25
bundle [1] 189/9
bundles [1] 206/6
buried [1] 72/4
business [18] 3/8
13/17 13/20 16/16
16/17 16/24 45/14
45/15 46/3 46/12
80/21 92/2 160/16
171/16 171/19 175/2
175/20 177/9
busy [1] 41/23
but [255]
c
Cable [3] 70/16 82/25)
132/13
calamitous [2]
190/22 190/22
call [6] 33/15 40/11
48/9 53/12 54/2 77/15
Callard [26] 10/12
10/23 66/21 66/24
69/16 71/10 71/23
73/25 74/13 85/13
85/16 94/23 97/4 98/4,
98/25 101/10 103/24
108/6 109/8 109/25
111/10 129/2 129/8
129/18 130/1 130/5
Callard's [1] 81/22
called [2] 72/5
179/18
calls [4] 26/7 40/4
55/2 176/19
came [12] 4/21 10/22
28/10 30/3 32/16 39/1
72/23 126/13 152/12
156/2 156/3 167/24
campaign [1] 26/9
campaigned [1] 7/1
campaigns [1] 33/17
can [160] 1/3 1/4
1/10 1/20 1/22 6/11
14/2 14/13 15/25 19/2)
19/25 21/22 23/13
23/15 25/6 27/9 28/1
28/7 29/10 29/18
29/23 31/8 33/15
33/18 36/4 37/2 41/11
42/12 50/7 50/8 52/1
52/19 52/24 53/24
54/21 57/14 58/9 61/1
61/19 63/9 64/13 65/2I
66/18 67/5 69/14
70/17 71/11 77/8
81/17 83/3 84/10
85/25 86/15 88/24
90/18 93/1 93/9 95/16)
95/25 96/4 101/24
102/7 104/16 105/12
109/22 110/10 110/23)
4111/5 111/21 112/22
112/25 117/9 117/13
118/1 118/2 118/4
118/14 120/11 120/16)
121/18 123/21 129/21
134/1 134/11 137/3
138/6 138/19 139/1
140/25 142/17 142/18)
143/17 143/24 143/25)
145/17 146/6 149/12
149/20 150/12 152/20)
155/7 157/5 157/10
157/24 158/8 158/21
159/18 161/11 162/18)
162/25 163/1 164/13
165/1 168/3 168/23
168/25 169/1 169/18
170/2 170/23 171/2
171/3 171/13 171/14
171/17 171/25 173/10)
174/1 177/24 178/8
178/24 179/23 179/25)
180/22 183/1 185/23
186/4 186/14 187/6
189/17 192/10 192/25)
195/10 196/3 196/16
197/7 198/11 200/6
201/2 201/10 202/23
202/25 203/2 203/9
203/20 203/21 204/5
204/6 204/13 208/20
can't [29] 5/9 27/7
27/8 29/25 34/24 43/1
43/3 43/19 46/2 57/1
66/15 69/10 79/12
81/17 93/24 97/8
97/21 109/14 121/19
123/19 136/18 141/4
141/20 161/13 179/16
187/25 202/12 203/22)
206/13
Canada [3] 144/18
144/21 175/7
Canadian [1] 144/14
Candour [1] 131/5
cannot [14] 36/12
36/20 47/13 53/9
73/22 97/12 116/13
119/6 121/15 138/9
174/22 176/25 178/15}
(68) BENWELL - cannot
Cc
cannot... [1] 199/17
capable [1] 79/5
Card [1] 7/16
cards [1] 42/1
care [2] 120/7 177/8
cared [2] 7/5 74/6
career [2] 87/10
144/14
careful [2] 52/11
112/6
carefully [1] 116/12
carried [5] 18/14
28/24 178/7 184/15
204/21
carries [2] 31/18
94/19
carry [1] 132/2
case [38] 14/10 25/9
29/18 33/4 34/11
37/22 49/21 51/14
58/21 76/14 81/23
84/8 88/25 89/20
90/12 90/18 94/16
94/16 103/3 106/19
107/1 107/4 107/4
110/25 116/12 116/12
116/17 116/17 128/10}
134/11 136/6 137/23
138/1 165/12 173/17
176/22 176/22 181/1
cases [60] 18/5
18/20 23/21 24/18
26/17 26/22 26/23
29/4 29/7 29/21 31/21
32/14 32/22 33/22
48/20 49/25 50/25
52/5 55/17 55/20 56/9
66/2 84/21 84/23 85/3
85/22 87/12 87/21
88/3 88/13 88/18
88/19 88/21 88/23
89/1 89/2 94/11 95/11
97/16 98/23 107/21
111/2 111/25 112/19
113/4 113/21 114/12
114/13 114/14 115/15)
115/20 116/12 116/19}
117/5 117/22 118/10
123/18 127/25 175/10}
202/7
cash [6] 84/12 84/13
146/12 146/14 193/20}
194/25
catch [6] 10/24 36/16
71/3 98/10 119/16
205/4
catch-up [2] 10/24
98/10
catch-ups [3] 36/16
71/3 119/16
categoric [2] 148/3
179/20
categorical [5] 9/24
43/3 97/8 136/19
141/6
categorically [1]
138/9
category [2] 35/23
62/12
cause [4] 111/1
119/6 136/23 193/2
caused [6] 24/2 68/8
94/6 111/4 182/13
188/18
causes [1] 112/25
causing [2] 93/23
182/2
caveat [1] 54/20
CCRC [2] 124/2
124/9
CCRC's [1] 123/22
cease [3] 169/20
169/21 170/2
ceased [2] 180/4
180/8
ceasing [1] 143/15
CEDR [1] 92/5
cent [6] 3/21 4/2 4/5
4/20 60/23 60/24
Centre [1] 160/16
centred [1] 153/12
CEO [18] 13/8 20/9
35/11 68/4 68/12
78/23 78/25 79/5
79/11 80/1 80/4 81/3
81/9 144/21 145/3
166/2 174/18 196/4
certain [15] 10/16
25/4 27/8 36/12 43/1
43/14 43/19 80/6
109/14 141/4 153/13
154/4 162/15 170/19
174/22
certainly [20] 7/1
10/17 14/8 25/6 46/17
64/3 66/3 92/25
109/16 125/25 132/10}
135/13 135/14 152/3
158/13 178/17 179/15)
183/17 192/20 194/15)
cetera [8] 31/21
53/22 107/17 117/18
156/25 197/10 197/10)
197/11
CFO [9] 78/13 78/21
78/24 79/5 79/7 79/11
79/12 80/2 133/1
chain [4] 48/1 53/4
62/18 89/8
chair [5] 13/8 20/9
20/17 68/13 78/19
Chairman [7] 151/22
156/3 158/15 158/17
177/18 177/19 188/14)
challenge [2] 11/13
156/16
challenged [2] 49/17
120/16
challenged/appealed
[1] 49/17
challenges [4] 78/14
106/13 155/8 157/13
challenging [2] 50/4
121/16
chance [3] 38/12
75/3 202/22
change [17] 10/14
10/14 11/8 57/24
68/16 73/19 82/3
111/16 117/15 118/1
118/5 142/8 149/25
150/1 160/15 189/18
189/20
changed [8] 80/10
80/17 122/19 132/24
190/10 202/19 205/8
205/24
changes [10] 10/8
45/9 76/3 110/12
113/3 113/6 118/1
118/17 153/19 160/19!
changing [4] 114/10
122/11 128/12 202/6
channels [1] 16/19
character [1] 81/21
characterisation [1]
194/11
characterised [1]
194/21
charge [1] 178/21
charged [2] 182/3
199/14
charging [1] 165/18
charismatic [1]
68/18
chase [2] 56/14
63/17
chased [2] 64/4
103/17
chaser [1] 63/7
chat [1] 95/14
check [1] 177/5
checked [1] 130/23
Chief [27] 12/1 20/16
69/7 69/12 75/12
75/14 75/19 76/6 76/9
76/12 76/16 77/3
78/10 79/23 120/3
120/7 126/11 128/5
132/2 144/24 149/3
149/6 152/24 168/8
180/7 199/20 205/20
choice [4] 57/20
58/25 59/9 99/17
choppy [2] 112/12
113/14
chosen [1] 58/7
Chris [4] 75/18 81/18
152/23 157/7
Christmas [2] 103/1
105/22
chronology [2] 82/20
83/1
chunk [1] 107/25
circulates [1] 117/11
circulation [1] 199/4
circumstance [1]
136/21
circumstances [8]
13/3 19/3 76/22 78/5
84/6 108/1 137/15
138/14
cites [1] 24/18
citing [1] 44/25
civil [34] 9/19 12/3
12/19 14/7 17/13
17/17 20/3 30/25 32/4}
33/11 46/11 73/2
73/23 74/2 74/4 82/13)
89/5 89/7 100/14
113/25 114/6 122/2
129/20 130/8 131/9
131/15 138/4 141/17
144/14 156/17 156/22}
163/4 175/7 178/4
claim [6] 84/10
155/10 156/18 156/24)
178/4 199/3
claimed [1] 24/1
claims [17] 26/11
84/7 84/14 84/22
156/22 182/15 182/20}
182/21 193/18 193/19}
193/20 193/22 194/8
195/1 195/1 195/18
202/20
Claire [3] 22/14
22/15 74/15
clarification [3] 86/4
143/6 207/10
clarify [4] 40/15
143/11 167/19 178/24,
clarity [3] 95/13
95/16 95/17
Clarke [12] 47/9
119/10 119/21 122/22
125/4 125/7 125/20
126/5 126/10 126/17
126/20 135/3
clear [33] 6/6 8/23
9/8 17/3 21/7 32/16
36/8 37/12 38/21
39/12 52/6 54/1 74/23
78/12 84/24 90/18
106/22 118/25 126/9
127/22 131/2 134/16
135/10 135/23 136/13
139/8 164/1 176/15
179/10 188/15 191/15)
192/13 207/4
clearly [31] 6/20 15/6
15/19 19/22 20/18
31/10 32/21 33/21
34/12 43/10 46/4 52/5
54/10 54/14 55/2
60/16 65/20 69/8
69/22 71/12 78/9
79/15 79/17 85/4 87/3)
91/19 107/24 121/8
163/10 191/16 197/19)
client [1] 24/14
clients [3] 129/6
134/3 202/1
clipped [1] 20/6
clock [1] 52/9
Cloke [1] 22/20
close [6] 34/6 113/3
123/24 149/7 196/16
198/16
close-up [1] 198/16
closure [2] 72/20
180/23
closures [3] 6/24 7/1
15/18
cloth [1] 120/6
CLT [1] 207/24
coaching [1] 81/14
Coalition [2] 2/19 7/9
Code [1] 173/11
collaborative [1]
46/17
collate [1] 37/24
collectively [1] 22/4
column [4] 170/1
170/7 170/9 170/10
combined [1] 11/12
come [50] 7/23 8/25
9/22 10/6 14/3 14/19
16/6 20/2 23/11 32/10}
32/23 35/13 38/8
52/19 62/25 65/24
66/18 68/1 68/2 69/22
75/6 78/18 89/19 93/1
93/11 96/3 96/8
108/21 123/14 124/16)
131/4 133/8 137/5
143/24 155/6 156/7
156/12 169/22 174/1
183/1 184/13 187/22
189/22 190/1 190/11
194/3 202/14 203/21
205/14 207/21
comes [7] 12/16
112/10 116/16 118/20)
204/2 205/15 207/18
comfort [1] 88/7
coming [10] 41/4
42/10 59/14 72/2 80/7
93/19 122/1 141/11
162/18 202/14
comment [9] 29/7
45/14 46/2 86/10
99/21 111/7 111/9
113/25 208/14
commented [2]
85/18 86/4
commenting [1] 54/2
comments [8] 53/6
(59) cannot... - comments
Cc
comments... [7] 75/9
95/7 101/20 110/12
111/6 113/24 165/17
comments/questions
[1] 95/7
commercial [5] 9/11
9/14 67/13 131/12
131/16
commission [5]
26/16 61/15 114/14
123/18 195/25
commissioned [3]
45/22 196/2 196/5
commit [3] 45/7
98/19 99/9
commitments [4]
3/18 114/2 114/7
115/24
committed [2] 38/24
167/15
committee [21] 4/11
121/11 128/16 128/17
128/24 145/23 148/9
151/21 152/6 152/22
154/19 156/2 157/4
157/19 159/4 177/17
178/20 181/17 182/9
188/10 190/8
committees [2] 5/8
168/20
common [2] 96/22
115/9
Commons [8] 4/10
5/11 47/8 49/1 51/11
51/23 61/5 61/12
communicate [1]
191/15
communicated [1]
135/3
communication [5]
139/24 161/11 161/20}
162/10 186/18
Communications [4]
104/19 105/6 105/13
117/9
companies [10]
24/14 131/13 143/14
145/14 145/19 162/8
164/7 169/4 184/5
200/1
company [25] 8/10
78/13 105/6 120/4
145/9 145/11 147/4
147/17 163/12 168/5
168/12 168/13 172/23
174/16 175/12 175/13}
175/14 175/17 176/20)
176/25 176/25 178/13
184/20 192/5 192/8
company's [1] 174/9
compared [1] 140/22
compel [4] 121/15
121/17 121/18 121/18)
compensate [1]
188/18
compensation [1]
85/11
competencies [1]
174/17
competent [2]
176/23 177/2
competition [4] 3/14
9/2 22/18 61/14
competitive [1]
146/22
complaint [1] 94/3
complaints [7] 14/15
21/17 26/12 35/12
110/18 180/22 181/19)
complete [7] 113/21
123/9 174/13 183/8
195/3 195/14 195/20
completed [5]
115/14 116/18 117/22)
118/9 161/6
completely [1]
152/16
completing [1]
160/23
complex [2] 87/12
152/9
complexion [1]
196/21
complexity [1] 45/1
compliance [2] 150/4)
150/5
comply [2] 96/18
174/14
complying [1] 96/15
comprehensive [1]
97/21
computer [4] 34/25
35/9 48/14 203/5
computerised [1]
186/8
conceived [1] 141/24
concept [1] 106/9
concern [17] 13/22
38/19 68/8 78/25 79/8)
83/18 83/22 86/16
89/15 90/4 119/6
119/8 121/9 125/17
136/23 160/7 182/6
concerned [7]
128/22 133/6 141/15
180/25 181/22 181/25)
182/15
concerning [4] 29/8
105/17 105/18 197/6
concerns [26] 11/12
16/17 18/6 27/13
28/18 31/25 35/24
35/25 46/7 46/15
53/19 55/5 65/15
69/18 75/25 78/22
79/23 82/19 83/25
97/11 102/14 113/1
132/18 141/9 165/12
183/4
conclude [5] 116/20
117/23 118/10 118/22]
164/18
concluded [3] 31/3
38/6 116/15
concludes [1] 44/10
conclusion [5] 32/23
45/18 115/22 117/2
130/17
conduct [5] 136/9
173/12 173/15 174/6
176/3
conducted [5] 26/18
48/15 88/4 179/7
185/17
conducting [1] 79/20
conducts [1] 24/8
confidence [12]
18/11 25/2 26/5 41/3
46/14 53/14 89/1
95/23 96/13 107/6
139/25 204/24
confident [6] 25/17
27/21 28/20 79/5
100/15 118/17
confidential [1]
91/10
confidentiality [5]
91/16 108/17 121/20
121/21 128/3
confidently [1] 53/10
confirm [6] 1/20 1/22
27/7 70/23 115/16
136/17
confirmed [3] 67/3
129/1 154/2
confirms [2] 49/8
50/10
conflict [1] 13/1
conform [1] 49/3
connection [1] 11/6
connections [1]
204/18
conscious [1] 80/8
consequence [1]
113/18
consequences [1]
117/4
Conservative [1] 7/4
consider [12] 11/18
61/7 84/1 88/14 108/9
114/2 116/11 119/12
173/17 198/12 200/7
204/16
considerable [1]
62/23
consideration [2]
26/24 115/15
considered [5] 33/23
113/15 128/6 141/25
147/14
considering [4] 5/1
112/20 145/14 145/15}
considers [1] 88/4
consistent [1]
173/19
consistently [3] 24/6
26/4 156/19
constituency [9] 3/5
3/20 7/2 15/17 26/25
34/4 41/18 64/18
108/24
constituent [4] 28/16
49/22 65/16 103/12
constituent's [2]
28/18 34/7
constituents [8]
51/15 51/16 55/5
63/24 103/11 106/16
114/5 181/1
constructive [1]
52/13
consultancy [1] 9/16
consultation [1]
133/10
consumer [5] 2/13
3/12 4/1 22/18 42/1
contact [3] 29/20
65/7 105/11
contacts [1] 23/8
contained [2] 15/11
193/12
content [3] 66/13
75/7 139/2
contentious [1] 7/6
contents [1] 111/6
context [33] 6/23
11/3 15/18 22/22
23/10 25/23 53/18
55/10 56/14 57/7 70/5)
75/11 76/21 77/10
78/24 100/8 105/14
113/17 133/4 138/19
138/22 151/24 152/2
152/13 152/13 154/23}
162/10 167/14 179/18}
184/18 184/24 186/19
198/13
continuation [1]
181/2
continue [11] 70/23
112/4 116/2 116/11
117/17 150/3 162/25
163/2 171/13 180/8
204/24
continued [3] 85/6
189/5 190/23
continues [2] 18/11
85/10
continuing [2]
116/14 164/5
contract [1] 208/11
contractor [1] 138/25]
contractors [1] 172/4I
contracts [11] 7/15
TINT 15/21 23/23
25/24 27/16 29/3 42/4I
48/18 59/18 62/9
contractual [1] 29/8
contractually [2]
29/13 29/16
contrary [2] 74/9
161/3
contrast [3] 71/22
72/1 72/12
contribute [1] 122/4
Contributors [1]
152/25
control [9] 36/25
59/17 107/19 149/18
153/10 153/13 153/16
154/1 154/17
controlled [1] 149/16
controlling [1] 167/8
controls [5] 153/2
153/4 154/3 158/24
160/11
conventions [1]
184/4
conversation [17]
35/14 36/21 50/13
53/10 57/16 57/17
106/5 132/20 137/19
138/20 139/3 139/5
141/19 160/10 183/2
183/17 190/18
conversations [11]
25/20 39/17 39/20
72/19 83/2 132/21
185/14 190/2 190/4
190/9 190/15
convey [1] 54/16
conveying [1] 33/7
convicted [11] 48/19
52/8 56/8 62/10 62/12I
94/10 95/11 165/13
182/3 182/23 201/4
conviction [8] 124/7
147/12 147/16 147/17)
165/15 191/25 201/19}
201/22
convictions [8] 50/3
50/19 62/2 119/20
176/17 182/6 184/9
201/4
coordinating [1] 40/9)
copied [5] 64/16 86/7
89/13 99/5 105/4
copies [1] 28/2
copy [10] 42/20 63/2
65/6 65/13 99/24
109/10 120/14 120/21
121/12 126/16
core [3] 44/8 191/41
201/18
corporate [9] 9/15
117/10 157/22 162/14)
163/11 163/17 163/24)
164/1 169/3
(60) comments... - corporate
Cc
corporation [2]
144/22 195/7
correct [22] 2/7 2/17
2/18 65/18 79/13
115/4 143/16 143/23
144/16 144/19 144/23)
144/25 153/8 169/13
169/17 169/24 169/25}
171/21 171/24 180/21
199/10 202/18
corrected [1] 155/1
correspondence [44]
8/14 15/5 16/6 19/11
19/12 20/4 30/2 30/4
30/10 30/16 31/2 31/3
31/11 31/18 32/1 32/3
32/6 32/16 34/4 34/7
35/16 35/17 42/10
57/8 64/21 64/22
65/13 65/18 65/23
65/24 65/25 66/1 66/6
66/8 121/13 124/2
200/22 202/5 202/12
204/2 205/14 205/15
205/17 206/16
cost [1] 198/22
costs [1] 85/9
cosy [1] 100/21
could [85] 1/18 5/24
7/14 7/18 12/8 13/5
17/6 17/18 21/19 27/1
28/13 34/14 34/16
47/20 48/4 49/16
49/22 55/2 57/9 61/11
62/4 64/13 67/2 67/9
73/23 74/10 74/21
77/5 85/14 91/16 92/7
92/16 94/21 96/25
97/25 98/12 99/9
99/11 99/17 99/18
101/4 106/11 106/24
107/12 109/9 109/17
4111/1 111/20 121/17
122/20 122/21 124/16}
128/18 130/13 137/5
138/12 142/23 143/6
148/18 150/11 150/15)
152/9 153/3 154/4
157/10 161/18 163/4
174/9 175/24 176/2
176/3 176/5 176/13
177/22 179/19 180/18}
183/16 186/23 188/5
197/8 201/19 207/15
207/17 207/22 208/6
couldn't [9] 39/25
47/19 60/23 106/6
106/18 106/22 134/20)
167/23 184/22
Council [1] 144/15
Counsel [3] 168/15
201/13 201/14
counter [1] 24/11
country [3] 181/5
182/18 187/23
couple [8] 48/5 92/12
106/3 114/24 122/9
140/9 141/3 151/1
course [24] 4/24 5/18)
8/6 10/21 16/20 30/20
55/4 55/16 65/23
66/13 76/21 79/3
104/25 118/21 123/22)
133/2 151/2 162/20
172/25 191/21 195/4
199/20 206/20 208/18)
court [9] 29/4 51/20
56/9 87/10 92/10
115/21 116/9 116/22
165/15
court's [1] 116/13
courts [2] 48/19
51/24
cover [4] 20/18 20/19
91/14 153/22
covered [5] 3/2 22/16
45/16 48/17 159/1
covering [5] 22/6
34/9 42/16 70/15
94/21
covers [1] 27/12
crammed [1] 60/6
crashed [1] 170/25
create [2] 192/8
204/18
created [2] 105/15
172/18
creating [3] 69/21
84/11 197/4
credibility [3] 47/10
87/4 119/11
credible [3] 86/3 87/7
91/2
Crichton [4] 62/16
64/16 125/7 134/25
crimes [1] 177/10
criminal [34] 26/2
48/23 55/20 114/13
114/14 123/18 124/7
163/4 164/18 164/21
165/23 165/24 166/6
166/8 166/10 166/17
166/20 166/23 167/1
168/5 168/11 170/10
170/13 170/16 170/20)
170/21 171/22 173/16)
184/25 185/6 185/9
185/12 207/25 208/4
criteria [2] 6/18 8/3
critical [5] 44/25
73/25 83/8 100/18
140/5
criticised [6] 136/10
136/25 137/16 138/24)
175/24 176/3
criticism [3] 129/18
136/22 138/25
criticisms [2] 27/13
132/5
critiquing [1] 6/16
cross [2] 52/14
135/15
Crowe [1] 99/4
Crown [9] 16/22
140/10 140/14 140/18}
141/8 141/14 142/2
155/20 157/15
crystallised [1] 80/23}
cubbyhole [1] 39/23
cuff [1] 122/13
cultural [4] 130/23
130/25 131/2 131/17
culture [5] 9/10
131/7 131/8 131/9
131/17
current [8] 45/6 77/3
78/13 110/17 110/22
149/15 150/12 169/3
currently [1] 23/6
customer [2] 24/9
192/9
customers [1] 172/4
cut [1] 178/12
CWU [8] 25/1 140/4
140/12 141/1 141/2
141/5 141/7 141/18
cycle [1] 36/16
D
daily [1] 185/4
damages [1] 156/23
damaging [1] 188/10
Dame [25] 142/19
142/21 143/25 163/3
171/9 180/3 191/13
198/8 200/9 200/19
201/1 202/16 203/9
203/13 205/2 206/7
206/12 206/15 206/24
207/7 207/8 207/18
208/14 208/25 210/16
Dame Moya [10]
203/9 203/13 205/2
206/7 206/12 206/15
206/24 207/18 208/14
208/25
dangerous [2] 51/22
80/4
Danny [4] 76/5 76/15
77/1 77/12
dare [1] 9/12
data [11] 24/15 57/5
63/6 84/11 153/17
154/20 155/2 160/13
160/19 198/19 200/4
database [2] 151/11
151/11
date [14] 20/11 28/10
53/10 55/1 146/20
152/21 170/11 172/13
172/17 172/20 173/3
179/16 202/14 202/17
dated [5] 1/16 53/5
115/2 160/12 172/18
David [3] 164/15
164/17 196/5
Davies [2] 104/18
117/9
day [26] 8/11 8/11
19/1 19/8 19/9 20/8
21/14 24/13 36/18
37/6 37/24 38/3 38/3
39/22 59/16 60/21
60/24 61/1 75/18
80/24 98/12 100/23
105/22 107/15 152/23
157/7
days [9] 3/17 3/19
10/24 16/3 75/23
106/4 143/19 143/21
196/3
deal [7] 31/5 35/18
53/21 120/11 195/22
195/23 202/8
dealing [19] 8/9 9/14
23/6 33/14 33/22 34/3}
74/1 74/4 74/8 87/12
89/7 92/4 110/18
130/7 131/13 131/16
140/3 196/19 204/14
deals [1] 204/8
dealt [6] 46/14
166/18 166/21 166/23}
184/23 196/10
Dear [2] 65/12 187/8
death [1] 201/24
debate [38] 41/25
42/3 42/9 43/1 59/18
73/1 93/9 96/1 96/5
96/22 96/24 96/24
100/2 100/22 100/24
100/25 101/5 101/9
101/19 101/23 102/2
102/22 102/24 103/2
103/8 103/14 104/2
104/8 104/24 105/16
105/20 106/2 106/15
136/9 137/8 137/16
138/11 138/11
debates [4] 4/11
41/25 59/16 138/13
debt [1] 156/17
decade [1] 54/7
December [14] 2/24
66/19 98/4 100/23
101/24 102/24 102/25}
104/25 105/20 105/24)
152/23 155/21 157/5
202/17
decide [2] 59/7 63/8
decided [3] 115/19
123/25 178/17
decision [14] 13/3
28/12 92/14 99/1
113/9 132/6 132/8
132/14 133/12 134/8
163/7 165/18 175/25
176/6
decisions [5] 16/23
51/24 70/24 76/24
173/15
deck [2] 69/11 69/21
declined [1] 92/13
declining [1] 108/19
dedicated [1] 185/11
deep [1] 4/22
deeper [1] 64/7
deeply [1] 87/19
defects [1] 191/24
defence [3] 52/8
156/18 158/11
defenceless [1] 65/1
defendant [2] 94/17
116/18
defended [1] 24/6
deficiencies [1]
83/14
deficit [2] 146/8
146/9
defined [1] 8/3
definitely [9] 5/5 5/13I
25/13 35/23 42/25
95/17 97/4 108/1
154/25
definitive [1] 70/23
degree [4] 59/16 69/4I
100/17 208/19
delayed [4] 102/21
deliberately [1]
193/10
deliver [5] 67/12 68/4
68/5 117/19 124/11
delivered [2] 24/10
119/2
Delivery [1] 166/15
Deloitte [1] 97/18
demands [1] 47/22
democracy [1] 32/8
Democrat [3] 2/3
2/10 7/4
demonstration [2]
34/22 34/24
den [1] 64/16
department [27] 8/21
9/4 9/6 9/23 12/5
12/11 26/22 27/17
29/6 30/3 31/4 31/23
34/6 38/14 39/6 39/21
41/17 41/21 45/13
45/17 46/12 69/10
162/8 166/7 175/8
175/18 178/16
Department's [1]
27/112
departments [1] 7/20
depend [1] 4/7
depending [2] 38/11
146/10
(61) corporation - depending
D
depends [3] 147/13
147/19 177/1
Deputy [2] 2/9
144/17
Derek [3] 159/25
160/6 199/12
describe [1] 151/13
described [8] 41/9
46/1 57/23 91/22
109/21 128/7 181/17
194/1
describes [2] 151/14
173/11
describing [1] 65/20
description [3] 37/2
97/24 170/2
designed [2] 88/16
167/11
despatch [3] 51/23
59/9 61/11
desperately [1] 102/6)
despite [3] 83/11
103/1 198/14
destabilising [1] 80/5)
destroy [2] 113/23
114/16
destroyed [1] 128/3
detail [11] 38/13 46/8
66/16 68/7 83/21
149/5 149/10 151/18
152/5 156/13 204/13
detailed [7] 50/1
56/11 104/22 130/3
142/11 143/1 199/13
details [12] 26/11
32/22 36/20 39/3
45/14 46/2 47/6 53/9
86/1 91/9 91/24 106/9
detect [1] 160/18
determine [1] 112/16
determining [1]
169/15
deterrent [1] 99/17
developed [2] 68/15
178/11
development [1]
413
developments [3]
18/25 71/2 86/8
diary [12] 19/7 36/13
36/18 37/5 37/12
37/23 37/25 38/2
38/13 38/15 55/1
141/4
did [103] 3/6 4/17 5/3
8/7 8/15 10/17 11/5
11/5 11/18 12/12
14/17 22/11 32/5 35/7)
35/13 35/19 36/17
37/13 41/5 43/3 46/9
47/1 47/22 50/15
51/10 52/9 53/20 55/8
56/3 59/11 61/7 62/25
63/16 65/6 67/24
71/21 82/6 82/25 90/4
92/11 94/10 95/10
95/16 101/4 102/22
106/23 108/13 108/15)
110/2 114/9 114/11
114/15 114/16 115/5
119/13 119/22 120/9
122/4 124/5 126/15
127/20 134/19 140/3
140/6 141/14 146/6
146/13 148/12 148/25)
153/16 154/14 154/16)
155/16 161/3 162/4
162/15 163/21 166/5
166/9 166/25 168/19
177/13 177/17 178/6
180/8 181/21 182/8
183/3 183/6 184/8
184/9 184/19 185/5
189/1 193/6 194/19
194/20 196/8 199/18
201/14 206/1 206/2
206/3
didn't [45] 7/3 20/14
37/10 37/17 38/17
46/4 52/8 52/14 55/23
56/14 71/25 77/21
80/2 86/9 89/19 90/25
106/20 114/21 122/23}
125/25 126/15 134/16)
140/6 140/18 159/9
162/5 168/9 170/17
170/17 181/13 181/25)
182/3 183/18 183/20
184/6 185/15 186/20
190/12 193/5 193/9
193/20 194/13 194/25)
205/4 206/8
died [1] 201/19
differ [1] 68/10
difference [4] 8/23
16/12 59/22 92/3
different [50] 3/10
3/15 4/9 4/13 4/22
4/23 4/25 8/20 9/9
9/10 11/1 14/23 14/25)
18/16 19/6 29/1 34/2
35/9 38/1 38/15 51/3
51/19 54/3 60/7 74/2
87/13 96/7 102/13
106/17 108/17 111/18)
127/21 131/8 133/2
140/22 146/22 152/2
156/10 161/12 164/7
171/16 178/4 179/22
181/16 182/14 190/3
190/12 190/17 190/18)
190/19
differential [1] 9/7
differently [4] 47/1
114/20 122/6 133/4
difficult [11] 61/6
76/22 78/4 79/4 84/5
86/5 99/10 106/18
126/24 146/16 160/18
difficulties [2] 63/10
78/21
difficulty [4] 80/14
85/3 134/5 170/4
ig [1] 15/15
diligent [2] 74/5
130/9
diplomatic [1] 86/22
irected [1] 205/21
directly [3] 34/12
122/8 137/4
Director [14] 10/10
11/17 12/10 12/16
12/19 12/21 13/2
66/23 70/9 80/25
81/16 105/13 117/10
164/15
directorates [1] 71/7
directors [2] 12/17
68/11
directs [1] 113/6
disagreement [1]
173/13
disappointed [1]
101/3
disappointment [1]
101/7
discard [1] 38/4
discern [1] 123/20
disclose [6] 94/15
96/15 116/15 118/19
159/3 159/7
disclosed [2] 116/23
118/21
disclosure [5] 49/2
52/5 95/12 119/9
125/18
disconnect [1]
161/19
discrepancies [4]
29/5 84/12 111/2
111/3
discuss [5] 29/20
71/13 102/3 156/22
181/8
discussed [9] 16/12
30/8 66/20 70/2 75/10
150/8 155/7 157/23
179/3
discusses [1] 113/14
discussing [1]
114/17
discussion [12] 14/3
58/16 69/23 74/16
109/24 132/17 153/6
158/7 158/24 159/13
162/7 180/2
discussions [8] 7/19
10/3 28/7 31/22 124/5
141/7 160/4 179/23
dismiss [2] 155/19
157/15
dismissive [1]
107/22
disquieting [1] 182/5
disrespectful [2]
59/19 114/4
disrupted [1] 195/15
distinction [2] 8/13
69/4
distinctions [1]
16/15
distinguish [3] 39/19
40/5 53/11
distinguishes [1]
90/11
distinguishing [2]
121/2 146/3
distressing [1] 25/25
distribution [6] 99/3
99/5 99/21 99/22
105/5 159/21
ives [1] 4/22
ide [2] 3/7 4/2
division [3] 6/11 6/18
165/24
do [114] 1/15 3/25
4/2 6/2 8/12 14/4
20/10 20/20 25/3
33/25 33/25 34/10
36/13 36/21 37/3
40/18 43/13 46/19
47/1 47/5 47/19 56/18
57/3 58/2 59/16 60/2
60/20 60/21 63/18
66/12 69/7 71/5 71/18
71/25 73/7 75/2 78/7
79/12 80/5 82/21
82/24 84/15 98/17
98/20 99/18 100/1
100/24 105/12 106/20}
108/9 108/13 108/15
109/3 109/4 114/20
115/7 121/4 121/5
121/16 122/4 123/10
123/25 124/16 127/20}
128/6 129/16 131/7
132/14 133/18 141/19}
144/1 148/11 148/21
150/18 154/6 154/12
154/14 159/3 159/7
159/7 159/21 161/10
163/14 165/6 166/4
168/7 174/23 176/25
177/8 177/13 179/25
181/13 183/8 183/18
184/16 186/1 187/20
190/18 190/19 190/19)
191/5 191/17 192/25
195/25 196/9 197/5
197/21 198/5 198/16
198/21 200/18 204/18}
205/14 208/12
document [48] 17/21
27/1 27/5 41/13 47/18
47/21 57/11 68/25
75/4 77/17 90/17 95/3}
95/19 95/25 104/10
109/11 109/13 109/20}
1410/2 110/11 111/17
114/23 120/9 120/10
126/12 134/6 134/6
134/7 139/23 143/24
148/19 148/21 158/18)
158/23 159/19 159/22)
165/1 165/17 165/22
170/12 171/16 173/20)
183/1 191/3 196/17
197/25 198/4 207/17
documentation [6]
110/8 153/19 158/14
161/15 167/25 168/18)
documents [17]
19/14 28/2 41/3 48/5
113/23 114/16 127/22!
129/14 129/21 131/25)
155/25 156/6 158/21
161/7 185/24 202/2
202/3
does [13] 25/20
25/22 63/13 90/23
91/1 100/20 113/5
113/16 120/24 127/16)
173/4 173/4 199/20
doesn't [14] 19/2
20/10 22/8 26/1 33/21
58/24 110/5 110/5
147/18 156/6 179/2
179/3 180/5 203/21
doing [20] 6/5 17/1
19/22 30/11 34/2
41/24 43/17 49/4
51/18 75/21 77/4 89/6
100/17 130/9 137/20
163/19 177/3 187/3
192/12 206/2
don't [113] 3/23 8/22
14/6 14/10 14/11 16/9)
17/6 17/8 19/20 21/11
25/4 35/15 35/21
38/23 38/25 40/5
40/21 41/1 41/4 47/19
49/3 54/20 55/1 56/12)
63/8 65/17 65/19
66/11 66/16 67/19
67/25 70/9 75/19
82/20 83/1 93/14 96/2
97/6 97/17 100/23
108/5 109/7 111/21
112/24 122/3 124/3
124/4 125/13 126/15
126/16 126/20 129/5
129/24 131/2 131/19
132/10 134/10 134/12)
134/13 135/1 141/5
141/18 148/15 150/14)
150/25 152/17 153/22)
154/8 154/10 155/13
155/24 155/25 156/8
(62) depends - don't
D
don't... [40] 157/22
158/13 158/20 159/10)
159/12 159/12 159/23
161/7 161/13 161/23
164/23 164/25 165/8
166/4 167/3 167/17
168/2 168/14 168/21
171/2 173/6 174/25
176/8 178/9 178/25
179/2 179/4 181/9
188/25 189/11 189/17
190/9 191/14 193/17
195/17 199/10 200/15)
201/25 206/22 208/11
Donald [3] 151/22
158/16 191/21
done [34] 1/19 10/16
16/19 16/21 21/5
22/12 25/5 43/2 51/16
79/16 81/11 81/17
89/2 94/17 97/20
97/24 100/13 102/23
108/12 109/4 122/5
126/1 152/1 152/14
159/5 159/24 163/10
176/10 177/6 191/18
192/23 197/23 199/11
199/12
Donna [1] 206/18
Donnelly [1] 11/24
doubt [4] 51/24 94/18)
95/20 111/13
doubtless [1] 139/25
down [51] 13/13
14/13 16/5 21/1 21/21
24/5 26/14 27/9 28/4
29/10 32/25 34/16
39/14 49/12 50/9
50/11 58/12 64/14
66/18 73/13 73/15
78/15 79/24 83/15
90/13 93/22 94/8
96/23 99/18 110/12
110/23 111/20 112/9
116/25 117/13 143/24}
147/6 148/6 157/5
157/7 157/12 158/25
165/1 165/11 174/1
178/14 180/22 183/1
186/4 197/12 208/1
downward [2] 70/9
75/20
dozens [5] 33/17
33/18 33/18 56/16
74/2
draft [13] 30/5 42/17
102/10 102/11 102/12)
108/8 110/9 111/7
411/17 117/11 117/13
118/3 160/12
drafted [9] 14/5
19/25 20/1 29/23
96/10 102/20 108/4
114/25 117/8
drafting [4] 120/21
drains [2] 183/8
203/13
drains-up [1] 183/8
dramatically [1]
180/4
draw [2] 154/23
208/13
drawn [6] 116/10
132/3 132/18 155/5
197/20 198/1
dreadful [1] 188/22
drift [1] 193/2
Driver [1] 7/16
drop [2] 63/1 162/5
dropping [1] 63/5
due [2] 79/2 181/6
Dunbartonshire [1]
7/2
duplicitous [1] 88/22
during [12] 2/19 3/18
4/8 38/3 50/13 90/17
102/13 104/23 140/4
153/11 153/16 208/18)
duties [5] 9/5 12/16
96/18 149/24 176/24
duty [9] 52/5 94/14
95/12 96/14 96/16
116/14 118/19 131/4
131/5
dynamic [1] 68/17
E
each [19] 31/12
31/15 37/6 37/24 38/4
38/5 39/19 40/6 56/17)
62/12 71/6 84/8
103/15 106/18 116/11
116/19 117/22 118/9
139/17
earlier [19] 7/7 37/8
48/9 61/20 66/21
78/17 89/21 105/3
108/7 117/2 121/13
122/22 130/7 153/5
159/6 159/16 173/21
178/24 180/20
early [10] 13/4 16/3
30/15 39/18 56/18
71/7 71/18 102/15
103/17 124/17
easier [1] 59/15
easily [2] 58/9 58/14
East [1] 7/2
easy [4] 51/8 122/2
122/2 185/2
eat [1] 4/10
eating [1] 4/16
Eccleston [1] 165/5
effect [1] 53/18
effective [1] 172/18
effectively [4] 141/16
159/15 169/22 187/2
efforts [2] 80/18
81/19
eg [2] 58/2 71/16
eg increase [1] 58/2
eight [1] 101/11
either [11] 5/11 8/10
50/24 63/1 90/22
102/14 106/25 108/23}
125/6 158/8 180/4
element [5] 54/3
95/14 124/11 131/17
135/20
elements [4] 3/10
51/3 127/21 158/1
eligibility [2] 174/6
196/11
else [8] 11/4 40/17
121/6 126/22 132/25
133/17 139/7 189/24
elsewhere [1] 135/5
email [65] 14/19
21/20 21/20 21/25
22/3 22/9 22/11 23/16
40/19 41/16 48/3 53/4
56/12 57/8 57/10
57/11 57/15 59/4
60/25 61/2 61/2 61/19
61/21 62/23 63/13
64/14 64/18 64/24
65/6 70/19 71/9 71/23
74/13 77/20 86/20
89/8 89/12 90/14
91/14 94/21 94/22
98/3 98/8 100/20
100/23 103/22 103/23
104/18 105/3 105/17
119/7 120/18 125/9
125/24 126/3 126/6
126/7 126/18 127/1
127/2 136/14 158/15
165/24 180/23 204/8
emailing [3] 42/14
104/19 105/7
emails [8] 22/7 22/10
41/13 48/8 56/5 60/18
114/24 125/10
emerged [2] 186/22
189/3
emerging [1] 179/17
Emily [2] 22/20 56/24
emotionally [1] 84/5
emphasis [2] 152/15
152/17
emphasised [1]
152/3
emphasises [1]
120/22
employed [1] 207/20
employee [3] 140/18
166/12 173/22
employees [14]
99/20 140/11 140/13
140/20 141/15 141/17I
172/2 172/4 180/9
181/3 181/5 185/2
189/11 192/6
employment [8] 2/13
3/11 4/1 9/2 42/4
140/21 172/24 208/11
empt [1] 59/12
emptive [1] 112/21
enable [1] 174/14
encourage [4] 75/15
127/23 149/14 150/3
encouraged [1]
95/24
end [17] 10/25 22/11
62/3 70/22 79/17
114/8 114/12 116/25
117/6 118/4 150/21
151/5 153/11 154/15
165/22 170/11 198/16
ending [3] 109/19
113/18 148/20
ends [3] 29/17
107/13 204/17
energise [1] 68/18
engage [4] 6/8 57/21
68/18 82/6
engaged [6] 7/19
67/23 69/23 73/11
73/20 128/12
engagement [9] 4/13
27/12 68/14 102/18
112/1 112/18 113/17
113/19 140/25
engaging [2] 68/20
137/25
England [1] 173/14
enhance [1] 150/3
enormous [1] 81/13
enough [5] 107/3
122/3 122/25 146/14
167/9
enquire [1] 133/5
enquiries [5] 26/21
29/9 33/3 33/6 34/12
ensure [6] 18/22
115/23 138/15 173/18
173/21 204/11
entire [2] 48/16
195/19
entirely [11] 43/16
46/20 49/3 60/10
106/17 136/1 136/14
146/20 178/13 184/5
194/10
entirety [1] 126/17
entity [3] 145/20
192/16 207/19
envelopes [1] 166/13
environment [5]
146/22 149/16 149/17
149/18 154/17
envisaged [2] 68/16
4117/2
Equalities [3] 2/22
3/10 3/16
Equality [1] 61/15
equally [4] 3/7 41/5
172/2 172/4
equipment [1] 35/3
Ernst [9] 148/19
153/12 153/18 153/24)
154/1 160/20 160/24
160/25 196/19
erroneous [1] 197/17
error [3] 111/4
192/23 200/13
errors [2] 183/16
191/24
escalated [1] 30/25
escalation [1] 184/21
especially [2] 53/21
160/3
essence [1] 169/9
essentially [1]
196/21
establish [4] 67/14
126/6 126/24 192/6
established [1] 26/10
establishment [2]
147/7 148/5
estate [4] 141/8
152/9 152/15 195/19
esteemed [1] 92/20
estimate [1] 191/9
estimates [1] 191/3
et [8] 31/21 53/22
107/17 117/18 156/25)
197/10 197/10 197/11
et cetera [8] 31/21
53/22 107/17 117/18
156/25 197/10 197/10}
197/11
European [1] 3/14
Evans [1] 168/16
even [19] 3/13 9/8
14/24 14/24 17/2
55/19 59/3 72/5 72/19I
79/22 101/17 107/5
116/12 131/16 178/15)
184/13 197/3 199/3
199/18
evening [6] 19/5
19/22 28/10 30/11
37/13 138/12
event [1] 173/13
events [9] 8/15 24/21
36/3 48/1 65/20 65/23
86/11 87/12 190/2
ever [11] 7/24 58/25
62/25 125/6 141/1
141/14 148/12 158/9
159/21 167/3 206/1
every [16] 6/24 19/5
20/19 30/11 107/15
108/23 162/8 162/12
167/6 172/2 172/23
172/23 172/24 176/25)
199/15 200/3
(63) don't... - every
E
everybody [2] 63/5
193/4
everyone [1] 188/22
everyone's [1] 89/1
everything [7] 12/4
20/20 22/12 36/25
96/25 144/11 167/7
evidence [36] 44/11
45/18 49/15 50/19
52/6 66/7 77/20 81/22
84/13 86/6 110/25
115/17 118/6 125/5
129/1 129/15 130/17
140/12 142/25 144/8
159/14 166/5 167/25
170/15 178/24 179/8
186/21 189/3 189/7
189/9 190/11 196/3
196/7 201/21 206/5
209/1
evident [1] 24/25
evolving [1] 177/22
ex [2] 24/19 48/18
ex-subpostmasters
[2] 24/19 48/18
exact [5] 17/4 19/20
54/6 54/20 179/16
exactly [14] 14/11
14/24 37/3 38/25
40/15 54/8 55/1 82/20
96/2 97/13 97/22
108/5 141/20 187/25
examination [1]
207/10
examined [2] 29/19
97/16
example [15] 4/8
4/21 10/2 33/9 64/25
81/4 84/10 98/16 99/6
104/4 128/15 128/21
131/4 176/17 193/13
examples [4] 127/25
129/3 146/7 146/23
except [3] 115/21
140/19 167/4
exception [1] 5/8
exceptional [5] 49/4
72/5 76/5 76/20
130/10
exchange [2] 174/10
189/15
exciting [1] 35/10
exclusively [2] 164/3
170/20
Exec [1] 120/3
executive [48] 10/10
11/17 12/1 12/9 12/15)
12/20 12/21 13/1
20/17 21/23 42/13
66/23 67/6 69/7 69/12
79/23 80/25 81/16
90/9 120/7 126/11
128/5 128/8 129/8
131/1 132/2 144/24
145/8 145/11 146/25
149/4 149/12 168/8
172/3 174/17 176/20
176/24 177/4 178/21
180/7 184/2 186/24
190/7 191/22 198/3
201/10 205/17 206/15)
executives [4] 53/5
76/1 77/3 189/5
exercised [1] 6/25
exercising [1] 176/23
exerted [1] 64/25
existence [2] 126/9
126/21
existing [4] 73/12
75/14 76/9 154/3
exists [2] 160/15
196/25
exit [2] 75/15 76/9
expand [1] 41/11
expanded [1] 30/23
expect [13] 16/17
31/6 31/6 37/7 70/21
81/7 96/17 97/22
137/6 138/22 149/10
174/24 175/1
expectation [2] 97/8
139/2
expectations [1]
85/11
expected [13] 31/14
33/5 37/18 50/15 70/4
70/13 139/4 139/6
149/2 152/5 154/15
164/17 176/8
expediency [1] 99/25
expedient [1] 74/19
experience [12]
15/17 64/6 74/1 74/4
81/16 81/17 89/7
92/20 127/16 130/7
131/13 140/3
experienced [1] 50/3
experiences [2]
28/19 130/24
expertise [2] 8/10
32/20
explain [10] 26/23
28/19 54/11 59/1 63/9)
78/17 106/8 106/11
136/17 168/1
explained [7] 7/25
12/10 17/9 35/16
36/22 41/15 194/6
explaining [2] 21/3
53/13
explains [2] 25/11
79/7
explicitly [1] 10/15
explore [3] 15/23
126/4 166/25
exposes [2] 175/20
175/22
express [2] 18/11
183/4
expressed [4] 25/2
26/5 46/15 139/25
expressing [1] 63/13
expression [1] 53/15
extend [2] 73/17
103/6
extended [1] 187/23
extending [1] 73/21
extensive [2] 24/16
199/24
extent [8] 9/17 15/24
46/5 92/17 125/23
126/25 129/17 168/10}
external [6] 18/19
18/20 21/4 26/16
149/5 199/19
extra [4] 82/24 110/3
154/13 177/8
eye [5] 119/4 119/17
158/19 177/20 177/25)
Eye's [1] 156/4
eyesight [1] 93/16
F
face [7] 96/21 96/21
109/15 109/22 109/23}
119/22 198/9
faced [1] 140/21
faces [1] 78/14
facilities [2] 162/13
172/24
fact [22] 10/15 16/9
21/9 40/23 62/17
77/23 84/3 86/1 87/5
88/8 90/25 105/24
132/2 140/7 141/12
143/11 145/11 153/3
181/18 195/1 199/7
199/22
facts [2] 144/5
156/19
factually [1] 138/18
failed [3] 68/5 68/10
80/18
failures [1] 198/15
fair [4] 27/7 107/3
176/6 202/16
fairly [5] 82/13 86/9
163/9 176/16 178/7
falling [1] 23/24
falls [2] 18/8 121/21
false [7] 23/25 48/20
49/16 50/20 56/8
62/11 182/24
falsely [2] 182/2
182/3
familiar [3] 60/9 92/7
201/17
family [2] 24/4
105/22
far [4] 44/10 94/5
191/19 193/1
fast [1] 192/24
fatally [1] 47/11
fault [5] 85/4 182/2
182/13 188/15 194/10
faultless [1] 182/25
faults [4] 24/1 181/6
189/4 189/8
favour [1] 117/5
FCA [1] 196/11
feasible [3] 6/8 31/16
60/10
feature [1] 129/14
February [4] 67/6
111/17 128/16 160/12}
fed [1] 138/24
Federation [2] 25/1
139/16
feel [3] 33/21 51/10
181/5
feeling [1] 67/11
feels [6] 70/12 79/2
86/12 88/22 89/5
95/13
feet [1] 135/9
fell [2] 14/25 61/16
fellow [1] 66/9
felt [21] 32/18 36/23
46/10 46/18 51/19
52/14 67/24 80/12
82/17 95/18 95/23
96/11 96/16 97/1
101/1 106/2 118/24
121/23 124/12 127/11
138/1
few [10] 23/17 70/6
83/4 83/7 134/22
143/19 144/11 145/2
182/12 204/6
field [1] 79/20
fielded [2] 61/6 61/13
fielding [1] 61/8
Fifth [1] 117/21
figures [3] 55/16
140/18 141/21
final [18] 1/18 33/1
40/16 58/12 72/19
84/19 91/7 91/22
108/6 112/15 112/23
112/25 114/23 117/15}
117/21 120/9 130/24
196/16
finalised [1] 204/10
finally [4] 111/19
121/25 186/7 203/6
finance [13] 9/16
75/12 75/14 75/19
76/6 76/9 76/12 77/4
78/10 145/22 162/13
163/11 174/15
financial [17] 7/12
23/23 24/3 29/5 76/22,
78/5 81/6 149/6 150/6
152/24 154/21 155/3
155/20 157/16 174/6
198/16 199/20
financials [4] 146/1
146/5 147/24 199/25
find [9] 6/2 15/4
20/23 65/13 84/4
130/11 137/11 187/12)
192/22
finding [5] 44/16
44/18 88/8 122/1
135/2
findings [2] 42/17
62/5
finds [1] 44/9
fine [12] 37/12 52/20
93/20 124/13 124/18
124/18 133/14 133/14}
133/22 142/9 171/5
205/6
finely [1] 113/8
finger [1] 105/25
fingers [1] 53/17
finish [1] 124/17
finished [1] 30/19
firm [2] 18/21 26/19
firmly [1] 90/4
first [51] 6/14 10/10
13/11 14/6 14/20
15/14 17/20 18/10
20/16 32/25 34/21
36/8 43/10 45/12
45/20 48/6 52/17
58/13 58/15 64/11
69/19 74/18 86/15
89/1 90/9 98/1 99/24
102/1 107/12 107/13
111/8 118/4 119/24
123/20 124/23 133/8
133/22 143/2 144/14
145/2 167/19 167/20
169/19 178/19 180/25}
185/14 186/17 189/19}
203/5 204/6 207/23
Firstly [1] 116/11
fit [4] 16/15 27/23
39/25 69/7
fitted [1] 109/1
five [7] 4/9 56/18
60/7 155/10 170/25
200/12 208/1
fixed [1] 171/3
flag [3] 74/21 188/16
196/25
flagged [6] 10/15
11/10 34/12 91/4
162/16 178/17
flavour [1] 83/17
flawed [1] 156/18
fleet [1] 182/18
floor [2] 8/20 165/4
flotation [2] 191/20
195/16
flow [4] 24/15
fluidity [1] 6/19
(64) everybody - fluidity
F
focus [7] 6/11 85/7
97/1 145/1 148/9
149/14 192/9
focused [8] 131/11
141/7 141/13 155/4
156/1 156/9 174/22
194/7
focusing [1] 38/16
folder [2] 20/5 38/2
folders [1] 19/12
follow [6] 40/12 57/1
199/11
follow-up [3] 102/21
198/25 199/11
following [19] 16/10
29/5 37/6 40/11 40/21
48/9 64/24 83/25
85/20 102/2 104/2
155/20 157/16 180/2
198/13 199/23
follows [11] 6/1
17/24 22/21 36/7
43/25 45/12 61/3
71/10 90/13 95/12
115/12
forcefully [2] 103/7
106/15
forces [1] 175/9
forensic [11] 18/4
18/21 26/19 29/19
29/21 32/17 36/1
48/13 83/19 116/3
202/25
form [5] 41/17 50/22
80/2 83/15 118/12
forma [1] 33/19
formal [9] 92/5
105/17 122/12 143/9
143/12 143/13 143/20)
143/22 172/5
formally [1] 2/3
formed [3] 163/16
163/19 163/25
former [5] 18/6 23/22
26/7 27/14 92/10
forming [1] 148/11
formulation [1] 91/25]
fort [1] 79/6
forth [2] 41/14 77/11
forward [21] 26/22
49/23 59/14 65/3 68/2)
78/14 78/22 87/13
93/13 103/14 104/14
106/15 115/15 115/20)
146/21 147/21 150/22)
152/10 164/13 185/22
206/4
Foster [2] 159/25
199/12
flux [1] 168/14
102/21 137/22 198/25)
144/20 149/21 153/14}
found [25] 23/13
62/14 83/14 83/25
85/18 86/2 86/4 87/7
87/17 91/2 115/17
119/5 131/10 198/18
founded [1] 36/1
four [9] 3/17 56/17
106/1 146/23 149/21
155/12 156/15 198/6
204/14
fourth [1] 117/15
frailty [1] 186/7
framework [7]
146/19 150/4 158/20
162/6 176/13 178/11
178/22
frameworks [1]
147/7
frank [2] 122/17
130/14
frankly [1] 73/18
fraud [8] 16/18 48/21
99/16 181/6
free [2] 114/3 136/1
Freedom [5] 23/6
23/14 27/3 27/10
27/25
frequently [2] 30/17
141/2
Friday [4] 1/1 41/14
62/3 77/16
friends [1] 187/11
fro [1] 60/17
front [10] 1/14 20/6
37/25 78/21 81/1
109/15 109/21 109/23)
143/3 151/5
front-end [1] 151/5
frontline [1] 172/3
fronts [1] 180/25
frustrate [1] 80/19
frustrations [1]
67/20
FUJ00174179 [1]
134/12
FUJ00174749 [2]
57/10 57/13
Fujitsu [19] 57/10
57/15 59/4 134/7
135/6 138/21 139/8
151/24 153/2 153/12
154/14 154/25 158/25)
160/16 189/11 189/15)
194/8 196/22 198/15
Fujitsu's [2] 151/18
196/24
fulfil [2] 9/5 115/24
full [11] 1/10 18/11
25/2 26/5 39/2 43/15
79/16 91/14 130/14
44/11 49/9 49/9 49/15
50/7 50/11 52/6 56/10)
116/19 117/23 118/10)
55/24 56/8 62/11 85/5)
138/10 142/23
fully [1] 28/20
function [4] 44/3
163/15 163/17 184/13}
functions [3] 150/18
163/11 197/14
funded [1] 113/20
funnelled [2] 148/17
148/17
furious [1] 105/19
further [12] 19/17
37/1 44/20 50/6 83/21
86/3 94/9 116/23
143/14 157/7 184/7
200/9
Furthermore [1]
115/16
future [8] 6/21 7/10
7/15 13/24 67/22 86/7
86/24 89/13
G
gagged [1] 113/15
gain [1] 86/9
gathering [3] 193/24
193/24 194/17
gave [2] 82/7 201/20
general [21] 5/19
31/25 32/2 32/12
67/11 74/4 75/1 75/7
80/22 82/17 83/18
89/6 102/8 102/10
127/16 130/7 139/21
163/17 168/15 201/13
201/14
generally [6] 84/9
129/19 131/10 147/8
151/7 151/16
generic [1] 90/16
genesis [2] 36/15
89/17
gentleman [1]
168/16
genuine [2] 46/18
146/13
GEO [1] 70/22
George [2] 139/20
141/19
get [33] 3/22 14/23
20/22 30/5 31/7 33/17,
33/24 34/7 35/7 38/12
39/25 57/9 62/20
71/17 71/24 74/25
75/3 77/5 89/2 91/18
95/16 105/25 112/12
129/4 137/4 137/23
158/2 162/15 167/6
184/22 191/2 193/2
194/13
getting [12] 11/1
63/10 82/16 103/25
113/14 138/15 139/17]
148/4 168/14 179/13
181/14 198/15
Gibson [8] 10/11
10/18 17/15 40/12
40/16 40/18 62/18
129/11
gift [1] 42/1
Gilhooly [1] 206/18
Gilliland [1] 34/20
gist [1] 75/1
give [20] 7/18 33/19
39/2 41/3 48/25 54/6
58/25 60/15 63/21
66/15 78/1 112/16
137/14 142/25 146/6
178/18 179/16
given [44] 17/8 17/11
39/7 43/6 43/7 47/16
78/14 80/13 82/13
83/20 89/16 91/3
119/1 126/11 126/16
129/3 129/13 133/3
135/2 135/20 136/15
161/12 165/2 168/4
183/22 184/3 188/17
189/9 190/6 190/17
gives [3] 74/25
150/13 165/17
giving [6] 52/7 60/12
72/13 82/5 110/2
209/1
go [54] 14/8 29/14
30/21 34/1 35/3 39/7
47/22 65/10 81/2 85/1
87/23 89/1 100/24
106/18 111/5 124/8
130/3 133/22 133/23
143/2 150/15 150/20
150/22 152/10 153/22}
157/5 157/10 158/23
163/23 163/23 164/3
165/22 166/6 169/15
171/16 171/25 172/12}
172/16 174/11 180/22}
183/20 184/3 186/4
188/20 193/6 195/5
195/10 196/16 197/8
197/8 197/12 199/22
201/7 207/17
go-ahead [1] 184/3
goal [1] 7/11
god [1] 186/6
goes [9] 4/14 12/4
26/3 26/13 43/6
145/11 151/13 156/22}
181/8
going [88] 1/5 3/22
7/23 8/14 8/14 9/20
13/4 15/19 16/6 19/20}
23/17 25/14 25/15
26/14 32/13 32/21
119/17 129/10 134/10)
17/12 25/14 31/9 38/2)
52/10 56/2 63/14 78/3)
127/25 128/18 128/23}
138/22 146/21 152/19}
35/6 36/3 36/6 38/10
41/13 42/6 46/8 49/23
53/2 54/5 58/6 58/12
60/18 67/19 70/17
73/10 73/19 76/25
77/1 77/5 79/20 89/9
90/7 93/8 94/11 96/3
96/12 96/25 104/13
109/5 113/2 114/12
114/15 114/23 116/7
123/24 124/22 125/11
129/10 136/16 138/23
139/9 140/24 144/9
144/10 145/1 146/21
147/21 150/7 150/21
156/12 161/16 161/24I
169/2 170/24 171/16
180/2 184/23 185/22
189/10 194/3 197/12
199/1 199/24 200/16
201/1 203/4 203/7
205/2 205/5 205/10
206/4
gone [8] 11/3 33/13
34/13 41/17 56/9 99/8)
133/9 188/14
good [28] 1/3 57/17
61/5 63/21 67/14
67/24 77/4 79/12
93/16 96/20 98/14
1425/1 127/7 129/22
131/11 138/2 139/15
142/11 142/17 146/15)
161/9 162/17 176/6
183/22 186/12 186/15}
187/11 188/23
goodwill [1] 46/21
gosh [1] 189/2
got [21] 10/23 39/12
70/11 71/23 79/2
86/21 86/24 93/17
95/17 98/11 118/19
119/22 126/22 134/3
136/21 137/8 138/2
139/19 195/10 196/23
198/9
governance [2]
149/15 149/22
government [26]
5/18 7/9 7/13 7/18 8/1
9/6 12/20 13/24 15/21
50/21 50/24 51/7
51/13 59/9 59/14
76/23 120/20 121/12
121/15 121/22 121/24)
130/22 130/23 163/12
175/13 175/18
Government's [1]
78/4
government-owned
[1] 130/22
grateful [6] 74/21
75/3 85/17 98/12
142/13 208/25
(65) flux - grateful
G
gravity [1] 190/21
great [5] 62/4 87/9
194/18 194/23 209/2
greater [1] 158/6
Greene [4] 142/20
142/21 142/24 210/16)
grey [1] 69/5
Griffiths [2] 64/23
65/16
grip [3] 82/11 100/9
198/9
gripped [2] 81/8
82/18
grips [1] 194/13
gross [2] 192/23
194/1
grossly [1] 190/20
grotesque [2] 192/17
192/21
ground [1] 73/14
group [62] 26/9
44/22 64/12 72/7
72/21 73/7 88/16 90/1
90/18 90/24 91/11
99/8 102/17 103/10
108/17 112/2 113/4
113/19 114/12 117/6
123/24 124/6 136/7
145/4 145/14 145/19
146/2 146/5 146/17
148/1 152/6 152/16
152/21 159/25 166/1
167/17 168/25 171/18
171/19 172/6 172/7
173/11 173/19 173/20)
179/13 182/16 183/12
184/14 184/15 184/17
185/2 195/19 199/12
199/14 199/19 201/8
201/9 201/12 201/23
202/3 205/25 206/9
groups [1] 4/14
growing [2] 35/12
79/1
grown [1] 85/11
guess [5] 63/7 168/9
170/17 173/4 197/22
guessing [1] 51/23
guidance [1] 173/18
guidelines [1] 92/6
guilty [5] 50/20 55/7
56/10 62/13 62/15
H
habit [1] 63/5
had [243]
hadn't [9] 11/6 78/8
86/1 87/5 101/17
105/25 106/6 109/10
138/7
half [6] 15/22 20/15
42/3 57/14 96/2 167/6I
half-hour [1] 15/22
halfway [4] 23/18
Hall [7] 73/1 93/9
96/1 100/22 101/19
104/24 106/15
halt [4] 73/14
Hamilton [3] 134/2
165/16 201/6
hand [3] 67/10
192/24 197/9
handful [2] 182/12
183/11
handing [1] 16/21
handled [1] 205/16
handling [2] 42/19
112/6
handwritten [1]
86/18
hang [2] 121/17
137/9
happen [5] 16/23
101/4 102/22 147/18
169/12
happened [10] 39/19
40/6 41/19 82/21
128/18 136/4 137/9
158/22 187/13 198/20)
happening [7] 35/21
48/1 69/15 72/14
102/18 127/19 137/8
happy [7] 38/24
46/20 77/12 82/23
103/12 123/10 205/10;
hard [11] 39/18
105/23 105/23 121/7
141/6 152/7 162/8
162/14 182/17 186/24)
187/12
harsh [1] 185/16
has [124] 1/25 11/3
18/22 19/1 21/25 22/8
23/20 24/6 24/7 24/17
26/4 27/17 27/24 29/4
32/11 43/8 50/8 52/7
53/4 58/7 58/10 59/25)
62/1 64/1 64/23 67/8
67/14 67/16 68/1 68/6
68/8 68/10 68/12
68/15 68/21 69/3
69/11 69/22 75/4
78/22 79/1 79/1 80/11
80/16 81/13 81/15
81/20 83/5 83/18
83/22 84/23 84/25
85/2 85/6 89/3 90/14
90/24 91/4 93/11
93/15 93/16 94/17
99/15 102/5 104/17
107/24 115/13 115/17)
115/19 116/4 116/14
116/15 116/19 117/23)
118/6 118/10 121/12
124/7 139/22 139/22
147/10 147/11 147/25)
148/23 150/25 155/18}
157/14 160/23 161/10
161/11 161/15 168/18
170/25 175/4 175/17
177/4 178/9 180/2
180/11 186/22 187/1
187/13 188/21 189/3
189/9 189/10 190/1
190/11 190/14 190/16}
190/21 191/5 192/23
200/11 200/19 202/2
204/3 204/9 204/11
205/21 206/5 206/20
207/21 208/19
has/is [1] 188/21
hasn't [3] 57/21
90/10 206/21
have [428]
haven't [5] 41/2 80/1
81/8 93/17 124/4
having [38] 14/22
18/18 22/23 25/5
27/19 30/22 31/23
44/3 47/6 56/4 60/17
64/6 75/24 82/21
96/24 102/17 107/6
110/5 114/3 116/18
118/9 118/16 118/16
121/7 123/10 128/24
136/14 146/15 158/18)
158/18 159/4 163/15
170/4 172/5 1814/3
183/3 205/9 205/23
he [80] 11/5 11/15
21/23 21/24 21/24
21/25 23/5 27/6 41/6
A1I7 42/14 42/14
50/18 50/20 62/24
65/3 65/5 66/22 67/3
71/10 72/12 72/14
73/5 74/14 79/24
81/22 84/23 84/25
86/1 86/2 87/5 87/7
87/7 87/9 90/9 90/11
90/25 91/2 92/13
92/14 98/7 98/10
98/22 99/5 101/25
102/1 102/25 104/20
110/1 110/1 110/2
110/3 117/14 129/21
129/23 129/23 139/22
140/18 149/7 149/9
158/18 160/6 160/8
166/5 168/16 177/19
177/20 188/14 194/21
194/22 194/23 196/7
199/13 203/3 203/5
203/6 204/15 205/21
207/23 208/2
he'd [3] 98/17 159/5
201/22
he's [4] 202/24 203/5
205/19 205/20
head [15] 10/11
17/16 22/19 56/24
66/21 104/18 105/6
164/18 164/21 165/20}
165/23 171/22 173/16}
173/16 207/24
headed [1] 165/4
headhunters [1]
79/19
heading [1] 184/13
headlines [1] 57/17
headquarters [2]
34/19 164/8
health [1] 6/22
hear [8] 1/3 1/6 51/8
52/24 142/17 142/19
162/25 171/13
heard [8] 7/7 76/11
129/4 139/22 140/12
146/24 151/15 196/2
hearing [2] 167/15
209/9
heart [2] 145/11
200/17
heartrending [1]
76/23
heightened [1] 79/8
held [4] 9/11 10/12
31/12 144/20
help [8] 57/6 96/5
117/1 123/21 161/11
161/18 178/8 201/10
helped [1] 190/10
helpful [9] 33/24
52/13 74/16 87/24
91/17 102/14 110/3
128/25 131/10
helplines [1] 46/9
Henry [10] 191/5
191/6 191/8 191/10
191/11 191/14 193/16}
198/1 199/6 210/20
her [28] 10/17 13/20
31/5 53/14 60/22 65/8)
70/8 71/2 71/6 71/13
7117 71/24 74/19
80/9 80/18 80/24
81/11 86/12 98/14
111/10 111/13 119/8
120/8 120/8 129/4
183/4 200/12 200/20
here [19] 14/14 20/13)
71/22 74/22 98/3
104/15 106/13 111/5
121/5 137/9 145/18
164/14 166/5 171/5
186/6 189/8 189/18
189/19 199/21
here’ [1] 72/11
here's [3] 8/3 11/3
86/23
hers [1] 68/10
herself [3] 57/23
133/6 200/20
hesitation [2] 147/5
172/13
Hi [1] 94/24
hidden [1] 111/6
hiding [1] 73/6
high [2] 71/5 91/3
higher [1] 81/10
highlighted [4] 72/6
86/14 95/9 111/22
highlights [1] 89/11
highly [1] 160/1
him [14] 10/24 11/15
40/10 67/2 85/25
98/10 101/4 129/4
129/5 164/16 164/23
164/25 164/25 201/21
hindsight [1] 152/4
his [26] 28/18 41/6
49/22 50/13 65/14
75/15 81/23 90/25
91/9 91/19 98/6 98/11
101/10 108/7 165/14
191/9 201/18 201/19
201/21 201/23 205/20)
205/20 207/20 207/22I
208/11 208/12
historical [1] 175/19
historically [2]
175/16 175/17
HNG [4] 150/22
150/23 151/2 151/12
HNG-X [4] 150/22
150/23 151/2 151/12
holding [1] 79/6
Holdings [1] 157/4
holdover [1] 175/18
home [2] 39/7 39/12
honest [1] 14/24
hook [1] 112/16
Hooper [14] 84/22
85/23 87/3 90/10
90/21 90/24 91/9
91/18 91/24 92/12
95/6 98/19 101/3
108/18
Hooper's [1] 92/19
hope [4] 72/8 137/17
170/5 188/23
hoped [1] 172/22
hopefully [1] 171/15
Horizon [95] 14/14
16/1 16/4 18/7 18/12
18/16 19/2 20/10
20/12 22/25 23/10
24/1 24/6 24/8 24/20
26/6 27/15 28/4 28/4
28/21 28/22 28/25
32/14 34/22 34/25
35/8 35/13 35/21 36/9I
39/9 43/10 44/8 44/12I
44/13 45/19 48/14
49/9 50/11 50/16
55/14 72/4 72/25
80/22 81/5 82/8 82/12
82/16 83/9 83/14
(66) gravity - Horizon
H
Horizon... [46] 83/24
84/12 85/7 93/23 94/2
94/7 100/10 104/2
104/12 110/19 111/1
115/18 120/24 125/17)
127/17 133/3 139/21
139/25 140/8 140/14
141/1 141/5 141/13
141/16 150/23 151/3
151/19 153/1 155/9
156/18 156/19 156/21
157/13 158/10 158/24}
159/5 160/12 178/2
186/6 191/24 194/9
197/5 197/19 199/5
204/19 204/25
Horizon's [1] 23/20
horrible [4] 187/13
192/20 195/4 195/4
horribly [1] 182/3
hour [6] 15/22 20/15
42/3 71/5 96/2 108/23)
hours [7] 4/10 4/11
4/11 42/4 59/18
108/22 108/25
House [11] 4/10 5/11
16/11 46/6 47/8 49/1
51/11 51/23 61/5
61/11 135/25
how [58] 4/2 6/12 7/7
7/14 8/10 11/8 12/1
12/7 17/7 25/18 32/6
35/6 39/1 47/13 47/20
49/4 55/16 56/7 56/9
56/21 57/19 62/8
62/10 62/12 62/14
69/10 71/16 73/10
73/22 TAIT 82/15 92/6
94/6 98/14 112/25
128/12 129/24 132/8
135/20 137/6 141/16
147/20 150/8 152/17
155/25 161/24 162/4
162/15 169/12 175/25
179/6 184/23 191/18
193/19 194/19 196/14}
199/23 200/6
however [11] 27/23
45/17 50/18 78/17
94/14 112/5 118/6
151/20 154/1 176/5
194/12
HR [2] 76/3 163/11
huddle [2] 103/3
103/13
huddled [1] 136/8
huge [5] 4/16 6/15
35/17 81/16 162/9
human [3] 61/15
111/4 201/21
hundreds [3] 76/8
77/2 165/8
hurry [1] 136/8
hygiene [1] 197/6
hypothetical [1]
131/23
l accepted [1] 121/21
I actually [2] 30/25
72/1
l agree [2] 188/21
205/7
l also [6] 8/20 17/8
40/8 41/23 131/3
133/25
lam [23] 10/1 18/8
29/2 35/7 47/7 104/13
104/21 115/13 115/16)
122/24 144/9 152/11
168/1 173/2 173/3
175/5 179/19 180/25
181/4 190/5 191/8
207/5 208/18
l anticipate [1] 123/5
I apologise [6]
133/21 134/3 134/4
164/24 171/9 172/17
l appear [1] 139/15
I appreciate [4]
25/24 51/7 69/16
206/17
larrived [1] 163/8
lask [6] 1/18 77/8
143/5 143/25 162/19
186/14
lasked [11] 19/16
19/23 40/11 55/19
56/6 56/11 57/5 63/17
105/3 122/24 128/16
lassume [1] 205/14
l assumed [1] 133/21
Ibe [2] 128/18
133/11
I became [1] 30/15
I been [1] 39/6
I beg [1] 203/15
I believe [5] 11/23
135/19 159/23 172/14)
175/9
I believed [3] 119/23
120/8 120/8
Icame [3] 4/21 10/22
72/23
I can [18] 1/4 15/25
25/6 52/1 105/12
129/21 137/3 139/1
142/18 158/21 163/41
168/3 171/14 178/8
198/11 200/6 203/2
208/20
lcan't [17] 27/7 27/8
29/25 34/24 43/1
43/19 66/15 97/8
97/21 109/14 123/19
136/18 141/4 141/20
179/16 187/25 206/13}
I cannot [10] 36/12
36/20 47/13 53/9
97/12 119/6 138/9
174/22 178/15 199/17
I certainly [3] 10/17
132/10 179/15
I clearly [1] 32/21
I close [1] 196/16
I conceived [1]
141/24
I consider [2] 88/14
119/12
I could [10] 67/2 77/5
91/16 92/7 94/21
107/12 138/12 161/18}
186/23 207/22
I couldn't [4] 47/19
106/6 106/18 167/23
I definitely [2] 42/25
95/17
I did [27] 4/17 11/5
11/5 22/11 35/7 36/17
37/13 51/10 52/9
53/20 56/3 63/16 65/6
92/11 101/4 106/23
108/13 115/5 119/22
120/9 127/20 134/19
140/3 140/6 182/8
199/18 206/3
I didn't [15] 20/14
52/8 56/14 71/25
106/20 114/21 122/23
168/9 170/17 181/13
181/25 182/3 184/6
185/15 205/4
Ido [18] 1/15 6/2
36/13 56/18 57/3
60/21 66/12 82/21
82/24 100/1 109/4
131/7 132/14 141/19
174/23 181/13 190/19}
190/19
I don't [91] 8/22 14/6
14/10 14/11 16/9 17/6
19/20 21/11 25/4
35/15 35/21 38/23
38/25 40/5 40/21 41/1
41/4 47/19 49/3 54/20
55/1 56/12 65/19
66/16 67/19 67/25
82/20 83/1 93/14 97/6
97/17 108/5 109/7
112/24 124/3 124/4
126/15 126/20 129/5
129/24 131/2 131/19
134/10 134/13 135/1
141/5 141/18 148/15
150/14 150/25 152/17
154/8 154/10 155/24
155/25 156/8 157/22
158/13 158/20 159/10
159/12 159/12 159/23}
161/7 161/13 161/23
164/23 164/25 165/8
166/4 167/3 167/17
168/2 168/14 168/21
174/25 176/8 178/9
179/2 179/4 188/25
189/11 189/17 190/9
191/14 193/17 195/17
199/10 200/15 201/25
206/22
l engaged [1] 67/23
l expect [3] 97/22
174/24 175/1
l explain [1] 59/1
I felt [11] 36/23 51/19)
52/14 67/24 95/18
95/23 96/11 97/1
101/1 121/23 138/1
I find [1] 130/11
I focused [1] 174/22
I formed [2] 163/16
163/25
I found [4] 131/10
I go [2] 193/6 201/7
I got [4] 10/23 39/12
119/22 134/3
I guess [4] 168/9
170/17 173/4 197/22
I had [35] 4/22 4/23
10/24 15/8 19/8 19/9
20/5 37/9 38/9 39/20
39/23 49/3 53/11
54/24 59/16 74/1
91/17 96/21 101/1
103/2 103/5 103/5
103/17 109/15 122/5
122/9 122/24 137/24
138/9 149/7 175/6
183/7 187/22 187/22
190/4
Ihadn't [1] 11/6
Ihave [39] 2/11 8/11
18/24 28/18 33/3
34/24 35/2 40/4 43/17,
56/13 63/6 65/7 65/8
TAIT 74/18 114/20
119/7 124/14 125/9
129/18 129/22 130/5
139/11 147/5 155/24
158/22 160/9 164/23
164/25 172/13 175/5
190/25 191/17 194/6
200/9 200/17 201/7
203/14 207/7
Ihaven't [2] 41/2
93/17
I hope [4] 170/5
limagine [5] 3/23
12/24 19/19 25/21
132/17
linitially [1] 8/22
linterpreted [1] 82/4
I joined [2] 168/13
174/4
I just [19] 27/2 69/10
72/11 73/22 73/23
85/24 106/8 106/14
118/24 126/24 131/23)
135/4 140/9 161/17
174/20 177/24 178/24I
180/1 207/4
I keep [1] 56/20
I knew [6] 44/19
60/14 60/15 114/14
185/9 192/19
I know [17] 13/1 27/6
60/4 63/1 69/3 71/19
97/13 99/14 101/8
108/3 114/11 126/20
186/12 186/15 187/11
192/19 202/22
I left [2] 61/24 208/9
I look [2] 88/11 193/6
I made [2] 41/24 47/7
I may [5] 10/16
125/15 138/10 167/19)
191/2
I mean [78] 8/7 8/21
9/24 10/2 10/5 12/8
12/14 12/23 14/6 15/2)
17/15 27/7 33/10
33/13 37/13 38/20
38/23 38/25 39/17
46/23 47/6 47/11
47/17 47/23 49/20
49/20 56/14 58/21
58/22 60/5 60/22
63/19 66/10 66/14
68/25 69/14 71/22
73/2 73/4 73/12 73/18
73/22 78/3 79/14
79/24 82/12 82/13
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88/14 88/25 89/4
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119/12 121/7 122/20
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139/1 166/5 167/16
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108/13 161/13
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36/14 52/12 53/13
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63/18 64/6 65/17 66/2
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69/16 70/12 71/22
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44/19 45/5 45/16
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199/4 199/12
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159/8 164/14 195/10
195/11 195/13 196/1
196/1 196/7
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14/14 32/9 72/5 88/17
100/13 121/5 205/3
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7/22 20/10 21/6 21/8
33/16 33/18 35/19
35/21 38/21 40/9
40/10 40/21 42/2
46/24 47/2 50/2 59/13
63/12 69/17 69/20
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152/12 155/17 156/1
156/7 156/8 181/16
181/22 184/8 184/25
185/9 185/15 203/8
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4/25 6/21 7/3 15/1
15/18 15/20 16/3
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46/8 47/15 48/17
49/24 53/12 53/21
63/25 65/7 74/7 81/5
83/24 86/12 87/13
88/9 96/4 100/12
102/4 103/5 103/16
111/14 115/18 120/25
139/5 141/13 148/16
149/8 153/10 153/16
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174/5 183/16 183/25
183/25 184/22 194/11
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45/23 45/25 57/10
57/13 57/15 57/15
58/5 58/21 58/21
60/10 63/12 63/18
64/5 64/9 65/20 66/7
66/8 66/14 67/1 67/4
67/8 71/19 72/16
73/13 73/18 74/13
74/24 74/24 75/5 77/1
78/6 80/5 81/25 82/2
87/15 91/7 91/23
93/14 93/19 93/23
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108/1 109/16 111/7
111/13 112/17 114/10
114/25 120/10 121/7
123/1 123/7 123/9
126/3 126/9 126/21
126/24 127/13 134/6
134/12 136/13 141/6
141/21 141/22 143/4
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154/9 154/23 157/3
157/3 157/17 159/1
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162/14 165/3 165/10
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171/19 172/17 172/18
175/2 175/13 175/14
176/14 180/1 180/19
181/10 182/9 182/17
187/6 191/6 191/14
196/17 197/2 197/24
197/25 198/3 198/6
199/2 199/12 200/13
200/19 202/10 202/13
202/14 203/4 204/1
204/4 204/6 204/14
205/2 205/5 205/6
206/15 206/15 207/10
207/11
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item [1] 199/15
items [4] 28/5 28/6
72/5 158/5
iteration [2] 74/18
74/19
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24/16 28/21 29/20
42/19 44/9 49/10
51/21 66/1 67/12 68/5
72/9 94/20 98/18
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118/9 121/15 128/12
147/4 148/13 163/10
163/15 172/9 174/14
175/19 180/9
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39/16 77/17 87/22
88/4 91/25 127/2
143/13 148/1 157/2
166/3 169/21 175/20
175/22 177/6 177/10
178/6 187/5
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127/5 127/6 210/8
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26/24 29/20 40/8
40/12 45/8 45/24
46/19 48/9 48/11
49/14 49/21 50/14
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98/5 205/9 205/24
January [9] 66/22
103/18 103/18 103/19)
103/21 104/17 105/20)
107/11 143/13
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70/23 71/4
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53/7 58/7 58/11 60/1
61/4 62/1 65/6 65/12
67/15 70/20 70/21
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75/2 86/10 86/11 95/6
95/13 98/10 98/13
98/19 99/8 103/25
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JOANNE [3] 1/8 1/12
210/2
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57/1 61/7 69/7 77/4
128/6 176/25 177/3
jobs [1] 130/9
jog [1] 134/22
John [1] 22/23
joined [3] 168/11
168/13 174/4
journalist [2] 23/8
27/11
judge [2] 87/10 92/10
Judges [1] 156/20
judicial [2] 51/13
124/9
Julian [3] 200/23
201/18 202/10
July [24] 1/1 16/10
39/18 40/10 41/9
41/14 42/14 47/8 47/8
48/3 53/6 54/22 56/6
61/23 62/22 62/23
78/9 82/22 134/18
135/9 135/24 196/5
202/15 209/10
July 2024 [1] 1/1
jump [2] 164/13
185/22
jumped [1] 133/20
June [10] 1/16 2/24
36/14 54/24 54/25
55/3 66/19 70/22 71/7
80/23
June 2013 [1] 36/14
just [127] 3/3 4/10
12/8 20/4 22/24 23/16
25/22 27/2 30/14
30/23 33/19 36/6 38/7
40/15 48/4 48/22 54/1
54/15 54/18 55/7
55/13 56/25 57/12
58/18 58/24 58/24
59/21 63/19 67/2
67/17 69/10 69/14
69/24 70/5 70/11
72/11 73/22 73/23
74/18 74/23 74/24
75/11 75/16 75/22
77/3 77/5 79/10 83/7
85/24 86/5 87/15
88/22 89/5 93/1 93/19)
95/4 95/9 95/25 97/1
97/3 99/3 103/6 106/8
106/14 107/12 108/20
110/13 114/1 117/7
118/24 119/19 120/9
122/24 123/2 125/1
125/4 126/24 130/6
131/23 134/16 135/4
135/10 135/22 137/21
139/8 139/17 140/9
144/11 146/13 147/6
147/19 148/4 150/11
156/6 161/17 162/11
163/16 163/25 164/5
167/19 168/1 170/22
171/5 174/20 177/24
178/22 178/24 180/1
183/11 185/8 186/18
187/10 187/16 188/4
188/8 190/8 191/2
191/6 193/1 193/4
195/21 195/22 197/5
197/22 207/4 207/12
207/22
Justice [6] 45/7
45/24 85/2 112/4
122/21 201/23
K
Karen [2] 201/18
202/9
KATE [3] 1/8 1/12
210/2
Kearns [1] 140/12
keen [4] 36/23 49/21
86/3 87/15
keep [9] 56/20 56/23
65/4 77/8 86/7 86/24
89/13 102/6 133/18
keeping [2] 56/22
80/13
kept [5] 18/24 127/14
127/17 129/2 129/9
Kevin [1] 34/20
key [11] 13/21 40/9
42/17 47/10 67/16
68/11 116/6 119/11
144/12 149/20 160/11
keying [1] 183/16
kill [2] 58/9 58/13
killing [1] 58/23
kind [25] 10/1 11/13
17/2 24/19 31/19
33/17 39/23 40/1
66/14 72/10 75/24
82/2 87/5 106/4
113/18 120/6 122/13
130/3 139/4 152/15
154/14 160/8 176/7
178/18 186/25
kinds [3] 31/22 86/11
137/15
Kingdom [1] 173/16
knew [32] 15/16
38/25 44/19 60/14
60/15 73/2 94/11
101/10 108/9 114/14
119/10 119/19 123/20}
125/4 126/4 126/9
129/23 130/5 135/5
135/18 156/11 166/17I
185/9 187/17 188/25
189/1 189/2 189/20
192/19 193/18 193/18
193/19
know [261]
knowing [9] 72/22
81/17 101/8 105/14
108/9 108/11 124/3
128/11 205/24
knowledge [9] 1/23
67/1 68/6 82/10
125/23 126/18 126/25}
144/6 189/21
known [9] 20/1 60/8
76/14 90/15 126/21
128/4 158/4 168/7
168/9
knows [1] 125/19
L
Labour [1] 7/4
lack [5] 45/2 68/6
80/19 119/10 161/20
lacked [1] 82/11
Lamb [1] 18/1
language [3] 58/19
128/10 134/9
large [8] 21/9 44/25
55/23 94/5 127/7
146/9 148/9 174/24
largely [2] 46/10
153/11
larger [4] 142/2
152/13 177/23 197/25]
last [8] 32/10 128/7
140/11 143/8 146/25
186/14 197/12 204/16)
late [2] 10/19 17/2
later [13] 14/20 22/19)
55/19 69/17 72/20
73/14 74/20 83/4
110/10 143/19 156/13}
164/5 196/15
laundered [1] 196/24
Laura [3] 110/14
120/18 129/12
law [25] 12/17 155/11
164/18 164/21 165/23)
165/24 166/6 166/8
166/10 166/17 166/20)
166/24 167/1 168/5
168/11 170/10 170/13}
170/16 171/22 173/16)
184/25 185/6 185/10
185/12 207/25
Law/Shoosmiths [1]
155/11
lawyer [3] 47/17
47/20 125/8
lay [4] 59/23 106/14
113/11 179/11
lead [5] 67/12 80/25
84/10 118/7 197/16
leader [4] 2/9 2/10
68/18 191/13
leaders [1] 162/1
leadership [1] 199/8
leading [1] 36/4
leads [1] 81/1
leak [1] 89/25
leaked [3] 83/6 83/8
112/15
learned [4] 164/23
188/9 190/14 196/14
learnt [1] 186/7
least [8] 5/6 60/7
79/18 106/24 109/14
126/9 155/10 193/25
leave [21] 2/25 4/21
10/23 10/25 66/20
66/25 67/7 70/4 70/7
70/14 70/21 71/2 72/2
72/24 75/22 75/24
101/15 108/21 125/11
132/7 132/19
leaves [1] 79/4
leaving [1] 67/3
led [3] 129/9 159/25
191/24
(70) issues... - led
L
Leek [3] 124/22
124/25 210/6
left [10] 22/20 32/9
61/24 67/10 125/8
134/2 140/20 197/9
201/6 208/9
left-hand [2] 67/10
197/9
legal [24] 26/13
95/14 96/14 96/18
116/21 123/4 145/21
150/4 163/13 163/15
164/2 165/4 166/7
170/7 170/8 170/9
170/20 178/16 184/25
201/9 201/11 206/9
206/11 207/9
length [9] 7/24
127/14 127/18 129/10}
130/21 136/21 137/15)
137/24 138/23
Lesley [7] 58/10
59/25 60/2 134/20
152/25 157/7 159/11
less [6] 11/13 94/1
100/5 100/6 102/14
102/19
Lester [2] 149/7
178/20
let [6] 59/3 80/24
125/22 132/3 184/18
193/2
let's [21] 43/24 43/24
48/1 48/2 58/18 63/23
70/17 77/19 78/11
86/14 103/19 103/21
107/10 110/9 110/13
131/25 157/2 166/6
166/25 192/13 205/19)
letter [69] 17/19
17/23 17/25 19/11
19/13 19/25 20/1 20/5)
20/6 20/11 20/22 21/2
22/24 23/2 28/15
30/13 31/7 31/13
31/15 31/17 32/11
33/14 34/9 65/10 66/6
77/12 83/1 95/6 101/4
101/25 102/11 102/25}
104/8 105/24 106/6
108/2 108/4 115/1
115/8 115/12 118/12
118/16 118/18 119/22)
148/20 149/3 149/11
153/14 160/20 160/22
160/24 161/5 165/2
167/23 168/4 180/18
180/20 181/11 181/14}
199/16 200/21 202/8
202/16 202/17 205/9
205/11 205/13 205/24
206/13
letters [11] 19/14
20/24 30/18 30/22
35/11 89/21 102/8
155/10 155/15 156/24)
173/23
level [14] 26/2 63/19
70/1 71/5 76/19 89/15)
96/14 126/11 151/11
152/6 172/2 173/20
201/10 201/11
levelled [1] 81/20
levels [6] 58/22
63/19 76/20 85/12
100/10 184/20
levers [1] 6/4
liabilities [4] 174/16
liable [2] 29/16
194/23
liaise [1] 40/17
liaising [1] 104/7
liaison [1] 3/15
Liberal [3] 2/3 2/10
7/4
Licensing [1] 7/16
lie [1] 32/20
light [5] 110/20
116/16 118/20 190/18)
190/19
lightly [4] 80/6
like [49] 5/23 6/11
6/17 21/5 33/14 33/22
35/4 37/11 37/25
39/15 46/10 46/18
46/23 50/21 53/1
57/12 64/12 64/19
69/21 76/4 80/21
80/25 81/5 85/18
85/25 88/19 95/13
96/7 98/17 98/19
98/22 100/2 101/1
102/22 103/3 105/6
105/21 117/7 121/23
131/6 132/15 136/2
159/22 161/8 162/15
165/5 192/23 195/5
200/22
likelihood [2] 193/22
194/22
likely [12] 13/25 14/3
36/14 43/3 60/11
61/25 66/7 66/12 97/5)
97/15 110/20 140/15
limit [1] 112/18
limited [34] 18/10
27/13 27/17 27/21
28/20 33/8 34/2 47/9
49/2 49/10 69/13 72/3
76/7 82/16 96/14 97/7,
103/15 105/10 115/13)
130/2 137/7 153/1
155/18 157/14 164/22)
165/11 165/12 166/1
168/25 169/11 170/16)
198/25 208/5 208/10
Limited's [3] 27/18
48/14 164/18
limiting [2] 113/13
114/17
line [13] 11/21 12/3
12/12 33/19 39/5
52/13 99/11 99/19
99/24 104/5 104/5
150/16 186/14
lines [17] 14/16
33/15 40/25 42/20
43/7 45/11 45/11 47/4
47/5 86/19 107/16
125/16 187/4 197/13
198/4 198/6 208/1
link [4] 48/23
linked [2] 7/12 45/1
list [9] 6/17 99/3 99/5
99/21 99/22 105/5
159/21 174/8 199/4
listed [2] 157/6
159/20
listen [1] 87/8
listing [3] 172/22
174/8 174/15
lists [2] 63/2 161/4
literally [1] 75/23
litigation [1] 193/13
little [7] 9/12 19/17
32/5 35/4 39/23 49/20
96/12
live [1] 184/6
lives [5] 51/9 130/16
187/14 188/19 195/6
lobbying [1] 26/9
local [1] 7/5
logistical [1] 59/15
logs [1] 156/20
London [4] 164/8
164/9 165/6 174/9
long [14] 3/6 7/21
26/6 30/21 31/14
74/24 96/2 136/19
163/8 168/17 179/4
188/21 190/24 206/1
longer [3] 98/5
183/11 195/5
look [57] 8/14 8/15
14/8 23/11 31/2 35/8
36/2 42/12 43/24 48/2
48/7 53/2 56/20 56/25)
61/1 64/13 70/18
70/18 72/15 75/7
77/17 77/19 88/11
95/8 109/16 110/9
113/10 117/8 119/17
122/3 134/5 134/11
134/13 138/19 143/5
148/16 149/12 150/7
152/20 155/7 157/2
159/18 161/23 163/3
165/11 168/3 168/23
169/18 179/22 189/9
193/6 199/10 202/22
203/4 203/20 204/13
206/1
looked [12] 21/5
22/24 27/6 37/25
54/17 89/10 89/11
97/16 107/6 110/5
118/19 130/22
looking [21] 25/5
31/18 47/4 49/23 52/1
52/3 58/1 71/18 73/8
91/22 99/3 100/5
106/19 108/3 119/3
123/3 123/12 138/20
152/4 156/15 190/15
looks [3] 50/7 100/2
165/5
loop [1] 129/3
looseness [1] 208/19)
Lord [3] 168/1
180/18 181/13
Lord Arbuthnot [3]
168/1 180/18 181/13
loss [3] 84/10 84/11
167/11
losses [5] 24/2 29/13
29/16 155/20 157/16
lost [1] 42/2
lot [23] 9/15 25/7
25/8 39/22 41/19 42/6)
43/4 43/20 46/8 92/18)
92/20 107/24 133/1
136/19 151/15 151/25}
154/13 154/17 157/24}
158/2 161/16 165/8
204/2
lots [13] 15/2 20/18
25/8 30/17 41/13
60/16 122/25 127/20
129/20 182/20 195/1
195/18 195/18
lovely [1] 54/14
lucky [1] 86/9
Lumley [4] 202/9
lunch [4] 62/1 123/11
123/13 123/16
made [36] 6/5 11/6
14/18 19/15 28/2 29/9
33/3 33/5 41/24 47/7
51/25 54/8 57/20 76/3}
87/5 92/14 94/3
104/23 113/3 114/8
115/24 117/25 132/9
132/25 149/2 151/17
153/13 153/18 154/4
154/17 159/4 160/19
160/23 161/9 187/19
190/1
mail [87] 144/24
145/4 145/24 146/12
146/17 146/21 148/13
148/22 149/4 151/1
152/8 152/16 152/21
157/4 158/20 159/24
160/6 161/17 161/21
162/1 163/9 164/8
165/4 165/7 165/24
165/25 166/1 166/3
166/7 166/9 166/13
166/14 166/17 166/21
167/7 167/11 167/12
167/13 168/4 168/11
168/25 169/10 169/15)
170/14 170/15 170/21
171/18 171/19 171/20)
172/5 172/22 173/19
173/22 174/5 174/14
177/13 177/21 179/5
180/6 180/8 180/13
182/16 182/20 182/22)
183/21 184/2 184/14
184/15 184/17 185/6
185/9 185/21 190/3
190/7 190/8 195/19
200/5 201/8 201/9
201/12 202/3 205/17
205/25 206/9 206/19
206/22 208/10
Mail's [1] 174/13
main [6] 9/25 12/3
71/6 98/11 149/14
208/3
mainly [2] 149/18
154/5
maintains [1] 173/19
major [4] 146/14
146/18 146/21 174/21
majority [2] 10/5
141/25
make [27] 7/14 7/20
8/13 27/8 30/14 49/21
51/11 58/24 59/24
60/13 60/14 61/25
66/1 67/22 114/16
115/5 115/6 116/2
117/17 130/20 138/2
143/6 147/18 152/1
159/5 162/4 177/21
makes [3] 79/6
117/14 169/7
making [18] 13/21
16/22 25/9 34/11 46/6I
56/17 59/12 76/23
88/25 90/6 100/15
103/7 103/16 115/7
115/9 142/10 189/21
209/1
malpractice [1] 24/3
manage [2] 149/24
150/4
managed [6] 59/20
127/15 127/18 129/10)
192/20 192/22
management [23]
11/21 68/8 147/7
148/20 149/11 149/14)
149/23 150/1 150/3
(74) Leek - management
management... [14]
153/14 160/20 160/24}
161/5 172/3 172/24
177/20 178/5 178/11
179/10 179/11 193/25)
199/16 203/8
MANAGER [1]
151/10
managing [3] 145/7
164/15 199/14
manipulate [1]
189/12
manipulation [1]
88/15
manoeuvrings [1]
128/8
many [32] 18/13
24/21 28/9 28/23
36/20 41/21 45/5
55/16 56/7 56/9 59/13)
62/8 62/10 62/12
62/14 63/17 66/6
71/16 74/2 96/4 117/5)
119/12 121/10 123/2
130/12 130/16 134/21
142/12 152/7 187/14
204/20 209/2
March [9] 66/24
111/18 115/2 120/12
148/20 165/13 169/23}
170/11 196/20
MARGUERITE [3]
142/21 142/24 210/16
Mark [1] 104/18
marked [2] 193/13
193/14
markedly [1] 111/18
Marketing [1] 163/12
Markets [1] 61/14
Martin [3] 11/24
62/25 65/16
massive [4] 19/22
25/25 47/2 192/15
massively [1] 119/14
master [3] 160/13
160/19 168/23
matched [1] 6/3
material [9] 43/5
116/23 139/20 146/1
146/4 147/14 147/23
148/1 148/10
maternity [19] 2/25
4/21 10/22 10/25
66/20 66/25 67/7 70/4
70/6 70/14 70/21 71/2
72/2 72/24 75/22
75/23 101/15 108/21
132/19
matter [20] 7/3 8/7
18/8 19/23 45/21 46/1
46/5 70/11 87/9 87/14)
102/4 121/6 123/7
127/23 155/11 156/5
157/19 159/13 171/15)
180/5
matters [29] 6/7 6/12
6/13 6/20 9/14 16/13
16/13 22/17 22/18
29/8 41/7 46/10 69/2
69/2 121/1 121/3
121/4 131/16 150/10
159/1 160/21 167/7
177/9 185/4 185/12
185/19 185/20 194/23}
200/8
Matthew [2] 149/7
178/20
Maureen [1] 165/10
may [29] 2/16 3/24
10/16 71/3 82/22
104/25 105/8 108/7
117/18 123/13 125/15)
129/15 136/9 138/10
164/5 167/19 175/12
175/18 181/22 182/15)
184/13 186/1 190/15
191/1 191/2 197/16
207/24 208/14 208/15
May 2002 [1] 207/24
maybe [10] 9/12 19/6
19/13 38/13 66/4
88/25 100/12 141/3
166/12 170/18
McFadden [1] 7/7
McInnes [1] 129/12
me [185] 1/3 6/6 6/6
7/2 8/8 8/13 8/23 8/25
9/2 9/4 10/15 11/10
15/15 15/22 16/7
17/12 19/6 19/23 20/2
21/7 21/12 25/15
28/11 30/21 31/5 31/9)
32/10 32/16 32/18
35/19 35/23 36/24
37/5 38/2 38/4 38/8
39/2 39/8 39/12 39/19)
41/3 41/4 41/7 42/11
43/10 46/4 46/9 46/23
47/1 47/6 47/11 47/15
47/25 52/11 52/24
53/4 53/13 53/14
54/11 54/11 55/6
55/24 56/2 56/25 57/6
58/15 60/12 61/13
63/1 63/22 64/10
65/24 66/2 68/2 69/14
70/8 70/15 72/13
72/19 72/23 73/3 73/5)
73/6 73/20 73/22
76/15 77/3 77/16 78/9)
79/21 79/22 80/1 82/4
82/5 82/7 82/19 87/19
88/17 88/22 88/24
89/3 89/5 91/13 92/7
92/13 95/22 101/13
101/15 101/18 103/7
103/19 103/25 105/14]
105/17 105/18 106/2
106/18 107/20 108/19}
110/1 110/2 110/4
110/7 111/18 111/19
113/5 113/6 113/6
114/1 114/15 114/17
118/24 119/1 119/2
119/3 119/4 119/13
119/17 119/17 123/21
124/5 124/10 125/18
125/22 125/25 126/9
127/23 128/13 129/23
130/10 132/11 137/1
148/24 149/9 158/14
160/9 162/8 162/14
163/24 167/20 167/23
167/25 168/19 170/5
170/17 171/6 173/4
174/23 178/9 179/9
180/12 181/1 181/15
181/15 182/13 184/18I
184/24 185/8 187/25
190/10 191/14 194/10
201/15 206/6 209/2
mean [92] 8/7 8/21
9/24 10/2 10/5 12/8
12/14 12/23 14/6 15/2
17/15 22/8 25/21 27/7
33/10 33/13 37/3
37/13 38/7 38/9 38/20
38/23 38/25 39/17
46/23 47/6 47/11
47/17 47/23 49/20
49/20 56/14 58/21
58/21 58/22 60/5
60/22 63/19 66/10
66/14 68/25 69/14
71/22 73/2 73/4 73/12
73/18 73/22 78/3
79/14 79/24 82/12
82/13 82/20 86/17
86/21 88/14 88/22
88/25 89/4 92/11
100/1 100/5 101/13
102/13 103/17 105/16}
105/18 105/19 108/5
109/23 113/24 114/10
119/12 121/7 122/20
132/15 137/1 137/17
139/1 163/14 166/5
167/16 179/2 179/3
182/17 183/11 184/16}
189/17 198/8 199/7
199/21
meaning [1] 78/2
means [5] 11/12
52/18 93/3 145/15
151/2
meant [6] 7/25 30/22
71/19 86/2 112/17
186/14
meantime [1] 66/21
Meanwhile [1] 85/10
measures [3] 31/4
81/11 200/2
mechanism [1]
124/10
media [3] 5/21 89/24
112/7
mediate [3] 94/12
113/4 114/12
mediated [3] 55/20
87/21 88/3
mediating [2] 111/24
117/5
mediation [20] 73/11
81/5 83/22 85/4 85/10)
88/8 90/17 90/19
90/19 90/22 90/23
92/4 103/10 104/24
109/19 110/18 115/20}
116/13 117/2 128/13
meet [13] 10/17 20/9
36/19 40/24 41/6
78/19 92/11 92/13
101/2 102/3 108/19
122/8 196/11
meeting [50] 13/8
13/11 14/21 15/10
15/10 15/23 19/8
20/13 20/15 20/16
20/18 21/14 22/22
34/19 35/11 36/9
36/15 36/18 37/9 37/9
37/14 37/15 37/19
38/5 38/18 38/19
38/21 39/4 39/16 41/5
54/24 55/3 57/12 60/2
62/3 64/11 75/2 82/21
97/3 108/12 109/24
109/24 110/7 155/6
157/2 157/4 158/8
159/3 159/9 181/8
meetings [17] 19/9
23/9 31/12 32/15 37/6
37/21 38/6 38/11 40/5)
72/15 72/17 75/24
77/14 109/1 109/2
139/19 150/8
member [8] 2/3
11/18 17/19 17/23
18/7 28/15 33/6
110/14
members [13] 5/20
9/22 24/3 26/11 45/25)
68/13 74/7 90/1 98/18
105/4 114/6 140/16
179/17
membership [2]
26/11 140/16
memo [4] 47/9 47/9
119/21 122/22
memory [12] 19/20
25/16 34/24 36/8 40/4,
43/17 54/7 66/16
97/12 97/19 134/23
142/4
mention [6] 19/2
20/10 20/12 25/22
113/16 152/8
mentioned [12] 60/5
72/18 72/21 74/17
101/13 101/14 101/15)
101/17 101/18 113/22)
136/1 156/2
mentoring [1] 81/14
merely [1] 193/13
message [12] 25/13
31/19 32/12 138/19
187/7 187/21 188/2
188/6 189/19 196/23
202/22 204/7
messages [3] 185/25
186/1 204/3
met [10] 10/16 10/18
40/23 65/8 66/24
114/3 119/24 122/7
141/2 164/25
middle [5] 37/10
153/9 170/1 170/7
170/9
might [45] 4/5 12/24
39/4 43/2 49/15 52/16
54/14 56/17 69/1 69/2
69/4 69/18 69/20
71/14 71/15 71/16
74/19 81/7 83/19 87/6
88/13 88/19 92/8
92/23 94/15 100/12
103/22 105/12 112/12)
113/14 116/16 121/25)
123/13 130/23 134/22!
136/22 136/24 137/10)
137/16 138/25 141/16)
170/4 182/22 202/19
206/23
Mike [4] 21/21 21/22
63/12 129/11
million [5] 24/9 24/9
24/13 107/14 195/2
millions [5] 18/14
24/21 28/23 55/12
204/20
mind [10] 19/21
37/11 47/13 51/6
94/18 95/20 146/6
171/2 180/2 190/10
minding [1] 171/6
mindset [1] 131/14
mi ise [1] 167/11
minister [27] 4/9 5/2
5/12 6/6 7/18 8/9 8/24)
9/5 14/17 20/23 20/25
22/12 30/15 32/7
47/14 51/19 51/22
61/18 69/11 70/24
85/17 88/14 102/13
120/6 137/25 140/4
144/17
m er's [1] 99/22
ministerial [23] 3/4
(72) management... - ministerial
ministerial... [22] 3/6
3/18 4/4 9/20 35/20
36/13 41/10 48/12
56/16 59/12 59/24
92/16 102/15 108/23
113/8 113/11 115/5
115/7 115/9 130/13
134/17 138/22
ministers [15] 6/3
6/4 7/19 11/20 12/5
23/9 23/21 26/21
52/10 68/14 68/20
69/13 69/18 69/22
114/8
Ministers/the [1]
26/21
minor [1] 143/6
minuscule [3] 24/20
25/10 55/15
minute [4] 32/10
124/14 138/6 170/25
minuted [1] 88/12
minutes [16] 72/15
73/8 88/11 123/6
123/8 151/1 151/20
154/10 154/11 157/2
157/24 159/2 159/7
182/10 191/6 200/12
mischaracterisation
[3] 194/16 194/17
195/3
mislead [1] 194/19
misled [6] 190/20
190/23 193/10 194/14}
194/15 195/24
missed [1] 123/19
mistakes [1] 187/19
mistresses [1] 127/8
misunderstanding
[1] 200/14
mitigate [1] 177/14
mitigation [1] 176/11
mix [1] 96/7
Mm [1] 18/3
mode [1] 137/5
modernisation [2]
146/16 152/10
modernise [2] 192/5
192/7
moment [5] 52/16
80/8 92/23 150/7
191/2
Monday [6] 41/21
41/22 42/8 42/19
42/24 104/13
money [6] 42/2 75/13
77/1 82/24 188/17
198/23
monitoring [2] 80/11
81/14
month [3] 24/8 28/15
140/11
monthly [1] 24/12
months [9] 10/22
32/10 74/11 79/18
92/12 101/12 114/19
119/15 143/19
Moors [1] 165/10
moral [1] 120/5
more [60] 3/9 3/10
3/15 6/19 9/10 9/12
11/7 18/16 19/18
28/25 30/22 33/24
44/25 48/20 54/6 58/9)
58/13 58/19 59/13
59/17 66/5 66/15
67/21 71/1 76/7 79/7
80/25 81/6 85/25 90/6
91/9 91/24 95/17
96/13 102/3 102/14
105/13 107/5 107/20
109/2 111/11 120/9
121/10 122/9 122/10
122/15 130/3 131/19
134/9 136/18 138/4
151/13 156/12 161/18)
162/16 179/20 185/18)
193/2 198/21 198/22
morning [19] 1/3 1/5
38/13 48/6 50/14
52/17 56/6 58/11
58/16 60/1 61/23
92/24 100/3 125/3
128/8 134/7 139/23
142/12 165/3
morning's [1] 94/25
Mosely's [1] 65/10
Mosley [1] 65/3
most [13] 6/8 11/15
35/2 35/10 36/14
44/14 58/22 105/21
111/2 141/6 160/25
177/16 185/3
motivations [1]
127/12
move [9] 13/4 27/1
36/3 70/17 103/21
109/5 150/9 179/22
185/2
moved [1] 208/10
moves [1] 101/11
moving [2] 34/18
83/3
Moya [26] 142/20
142/21 142/24 143/25)
163/3 171/9 180/3
188/21 191/13 198/9
200/9 200/19 201/1
202/16 203/9 203/13
205/2 206/7 206/12
206/15 206/24 207/7
207/18 208/14 208/25)
210/16
Moya's [1] 207/9
MP [15] 2/6 3/3 6/24
15/17 22/23 26/24
26/25 32/7 34/3 40/9
65/3 103/15 202/9
205/20 205/20
MP's [1] 204/7
MPs [19] 45/8 46/7
46/15 51/14 53/19
55/4 60/16 103/6
104/8 104/23 106/9
106/15 106/23 107/3
107/3 107/5 136/10
136/22 137/2
MPST [3] 22/2 22/11
64/19
mpstcorrespondenc
e [1] 64/19
MR [100] 1/9 10/12
22/21 23/16 27/4 27/5
28/7 29/18 48/3 48/7
51/1 52/18 58/15 63/4
64/23 65/4 65/10
65/14 65/16 66/21
66/24 71/10 74/13
81/22 85/13 85/16
90/8 93/18 94/23 98/4
98/25 107/10 109/8
111/10 117/9 117/14
123/5 124/14 127/5
127/6 129/8 129/18
133/17 134/2 134/6
134/16 142/22 148/3
152/12 155/24 159/8
164/24 165/13 165/17]
168/16 172/13 176/12
179/25 180/16 191/5
191/6 191/8 191/10
191/11 191/14 193/16
194/19 196/5 196/7
196/17 196/21 197/7
198/1 199/6 200/20
200/23 201/5 201/7
201/17 201/18 201/19)
202/2 202/6 202/10
202/16 202/21 204/11
205/23 206/8 207/14
207/19 208/8 208/17
208/23 209/6 210/4
210/8 210/18 210/20
210/24
Mr Alan [1] 65/14
Mr Arbuthnot [4]
51/1 202/6 202/16
204/11
Mr Arbuthnot's [1]
200/20
Mr Bates [3] 65/4
107/10 134/16
Mr Batten [1] 90/8
MR BLAKE [8] 1/9
52/18 58/15 93/18
124/14 133/17 134/6
210/4
Mr Brentnall [1]
134/2
Mr Callard [14] 10/12
66/21 66/24 71/10
74/13 85/13 85/16
94/23 98/4 98/25
109/8 111/10 129/8
129/18
Mr Callard's [1]
81/22
Mr David [1] 196/5
Mr Davies [1] 117/9
Mr Evans [1] 168/16
Mr Griffiths [1] 64/23
Mr Henry [10] 191/5
191/6 191/8 191/10
191/11 191/14 193/16}
198/1 199/6 210/20
Mr Ishaq [1] 165/13
Mr Ismay [2] 159/8
196/7
Mr Jacobs [2] 123/5
127/15
Mr Julian [3] 200/23
201/18 202/10
Mr Martin [1] 65/16
Mr Mosely's [1]
65/10
Mr Patel's [1] 29/18
MR STEVENS [17]
142/22 148/3 152/12
155/24 172/13 176/12)
179/25 180/16 196/17,
196/21 197/7 201/7
206/8 207/19 208/23
209/6 210/18
Mr Triggs [1] 194/19
Mr Trousdale [1]
201/5
Mr Whitehead [8]
22/21 23/16 27/4 27/5
28/7 48/3 48/7 63/4
Mr Williams [1]
117/14
Mr Wilson [6] 164/24
165/17 201/17 201/19}
205/23 208/8
Mr Wilson's [3]
202/2 202/21 208/17
Mrs [9] 134/2 183/7
185/14 186/19 186/24,
189/5 201/18 202/9
203/18
Mrs Hamilton [1]
134/2
Mrs Karen [2] 201/18
202/9
Mrs Vennells [6]
183/7 185/14 186/19
186/24 189/5 203/18
Ms [34] 1/6 1/13 53/1
53/11 53/13 74/13
123/16 124/22 124/25
125/1 125/3 125/6
131/23 133/6 133/18
133/19 133/22 133/24)
133/25 134/4 139/11
139/14 139/15 142/10)
158/17 177/18 200/11
200/15 200/25 201/6
210/6 210/12 210/14
210/22
Ms Hamilton [1]
201/6
Ms Leek [3] 124/22
124/25 210/6
Ms Patrick [4]
200/11 200/15 200/25]
210/22
Ms Perkins [1]
177/18
Ms Perkins’ [1]
158/17
Ms Swinson [10] 1/6
1/13 53/1 123/16
125/1 131/23 134/4
139/11 139/15 142/10)
Ms Vennells [6]
53/11 53/13 74/13
125/3 125/6 133/6
Ms Watt [2] 133/19
133/22
much [32] 1/5 1/10
1/13 1/25 3/22 11/7
46/21 57/19 57/22
80/24 86/9 93/2 93/4
101/2 102/19 129/24
133/15 138/12 139/11
142/1 142/5 142/10
142/14 142/18 152/13)
152/17 155/25 173/2
193/19 196/15 197/25)
204/4
multiple [3] 120/17
183/14 183/14
must [5] 122/19
126/21 193/11 198/11
199/17
mutualisation [2]
7/22 15/21
my [194] 1/12 1/21
3/4 3/9 3/15 3/18 3/19I
3/21 3/25 4/4 4/8 4/17
4/22 7/1 8/23 9/5 10/4
10/25 11/1 11/11
14/21 14/25 15/4 15/6)
15/17 16/20 17/1 18/9)
19/21 22/3 22/4 22/12
22/15 22/19 28/9 30/1
30/6 30/7 30/10 30/11
30/12 30/15 30/21
31/2 34/7 35/20 36/8
36/13 36/16 36/18
37/6 37/11 37/12
37/13 37/20 37/23
37/24 37/25 38/2 38/3I
38/3 38/5 38/9 38/11
38/14 38/15 39/1 39/7I
39/10 39/20 40/11
40/14 41/16 41/18
42/8 42/24 43/19
(73) ministerial... - my
my... [117] 46/17
47/7 47/13 50/4 51/5
51/16 54/7 54/13 56/5
56/19 56/24 58/25
59/2 60/5 61/16 63/7
63/15 63/16 63/16
64/20 64/21 65/6
65/15 65/24 66/5
66/14 67/1 69/24
73/24 74/3 74/4 76/25)
77/25 82/3 85/19
86/18 87/4 89/6 89/18
90/2 90/5 91/15 93/14,
93/16 94/18 95/20
97/8 97/12 97/19
101/20 101/23 102/13}
102/15 102/22 103/3
103/13 105/11 108/25}
109/3 109/15 109/25
111/15 113/2 114/2
122/6 122/13 123/22
125/16 129/18 130/7
130/24 132/19 133/13}
133/25 134/2 134/2
134/3 135/25 136/3
136/5 136/13 137/10
138/11 139/2 140/3
140/4 142/4 145/1
152/8 156/10 156/10
164/12 171/6 174/4
180/1 180/6 180/25
185/1 185/2 185/12
185/14 187/23 189/6
189/9 190/10 190/12
192/5 192/11 192/22
193/10 193/16 200/10}
200/13 201/5 201/6
206/6 208/3
myself [3] 46/11 90/2
137/20
mysterious [4] 36/15
37/3 37/16 38/16
N
name [9] 1/11 1/12
20/3 22/8 29/25 97/24)
133/25 142/23 166/1
named [2] 14/7
168/16
names [5] 129/11
129/13 129/14 134/3
134/22
naming [2] 129/20
130/4
narrative [2] 42/17
194/7
national [5] 24/25
120/4 120/4 139/16
165/10
native [1] 99/8
native’ [1] 84/2
natural [1] 113/18
nature [4] 16/25 17/4
46/7 185/16
nauseam [1] 43/8
navigate [1] 92/20
near [1] 156/7
nearly [3] 24/11
72/19 107/14
necessarily [12] 6/15
8/4 15/3 40/5 52/3
59/2 91/14 137/12
139/6 176/8 176/22
205/16
necessary [3] 5/6
164/19 208/15
necessitated [1]
174/12
NED [1] 138/3
need [33] 47/20
53/20 58/2 61/13 63/8
69/22 71/16 75/13
78/18 78/23 98/13
99/7 100/16 100/23
109/7 112/6 112/24
113/10 116/10 127/13)
130/18 131/12 134/10)
134/11 134/12 137/2
150/14 153/22 155/13}
169/11 173/6 181/9
194/4
needed [24] 31/10
46/5 46/25 59/20
59/21 61/17 63/20
63/21 76/12 76/18
76/19 80/6 90/6 96/12
97/1 101/1 109/1
136/17 146/20 152/16)
155/1 169/15 183/8
183/18
needing [2] 195/8
195/20
needs [8] 32/3 64/4
79/2 95/13 124/8
124/8 131/15 177/8
negligence [1] 23/25
negotiations [1]
170/13
neither [3] 29/6
140/5 199/2
network [12] 6/22
7/10 7/10 13/25 15/19)
44/4 44/5 48/16 67/22
67/23 141/8 160/16
never [13] 6/14 47/25
67/20 72/18 72/21
76/11 101/13 186/12
186/12 186/15 186/15)
199/7 206/3
Nevertheless [1]
154/3
new [13] 13/23 35/3
49/15 68/7 75/12 76/6
78/10 78/24 79/11
81/9 146/20 151/5
162/18
newsworthy [1] 86/8
next [16] 18/18 19/8
19/9 21/14 28/15 40/7
42/18 45/3 49/7 103/4
104/1 104/14 111/20
188/14 204/14 208/7
NFSP [7] 139/21
139/24 140/4 140/17
141/3 141/20 141/25
nice [1] 86/21
Nick [2] 188/11
188/12
night [6] 38/8 41/19
41/20 41/22 42/8
42/24
nightly [1] 65/25
no [86] 10/15 16/5
16/7 20/1 20/12 21/16
21/18 22/10 25/4 28/9
30/10 43/14 44/11
45/18 49/8 50/10
61/10 64/19 67/1
68/25 73/13 75/25
77/12 77/22 83/13
83/23 84/13 90/19
90/21 94/18 95/20
98/5 99/16 100/21
109/18 110/25 111/12
114/16 114/19 115/16
116/19 117/23 118/10
118/22 119/4 121/19
125/5 127/13 130/18
134/19 135/15 136/1
139/10 139/10 139/12}
148/15 148/23 151/20}
159/12 159/23 160/9
160/15 164/10 172/5
173/6 176/22 179/2
179/5 182/10 182/17
183/15 189/8 189/25
192/3 194/4 195/10
195/12 195/17 198/19}
203/24 205/12 206/22
207/1 207/3 207/7
208/16
Nobody [1] 184/24
nodded [3] 2/15
145/13 165/19
nodding [3] 140/2
165/20 203/14
non [10] 10/10 11/17
12/9 12/15 12/21 13/1
66/23 80/25 81/16
172/4
non-employees [1]
172/4
Non-Executive [8]
10/10 11/17 12/9
12/21 13/1 66/23
80/25 81/16
none [1] 4/17
nonetheless [1]
46/20
nor [7] 6/15 8/11 29/6}
31/15 32/23 119/14
121/15
normal [8] 9/18
16/16 30/12 65/23
66/1 92/2 116/21
137/5
normally [3] 37/5
38/14 103/2
Norman [1] 17/25
not [234]
note [46] 4/20 15/12
15/22 15/25 16/1
18/10 19/23 22/25
23/3 25/7 25/19 25/22,
36/17 37/7 37/10
37/17 37/18 38/4
42/12 42/16 50/5
56/23 72/1 74/23 75/6)
76/2 76/4 78/9 79/15
81/15 81/24 82/2
87/16 87/22 89/4
89/17 90/3 91/15
92/11 104/21 105/11
105/15 108/20 110/21
113/6 119/24
noted [5] 28/18 29/15)
157/19 157/23 194/21
notes [10] 19/8 37/21
43/5 44/5 44/13 47/18)
74/17 86/18 96/9
194/20
nothing [7] 39/14
113/22 128/19 195/25}
196/8 196/12 200/9
noticed [1] 10/13
noting [7] 4/6 25/22
29/12 141/21 159/1
193/13 193/14
novel [1] 35/6
November [4] 28/14
34/18 70/6 75/17
now [102] 11/4 13/4
17/18 18/8 18/24 23/1
25/6 25/18 27/1 28/13)
28/14 33/5 34/18 36/3
38/20 45/21 48/1 52/1
52/3 53/23 58/1 61/7
61/19 62/22 63/14
64/12 66/18 71/25
72/14 74/11 75/16
78/5 80/17 82/14 83/4,
93/8 94/21 95/17
96/21 97/12 97/25
100/6 101/8 104/16
105/3 107/11 108/2
108/24 109/5 110/5
112/22 114/8 115/14
115/19 116/18 117/21
118/8 118/9 119/7
120/12 121/2 124/2
125/20 129/21 143/5
145/1 148/16 150/7
150/22 151/2 152/4
152/18 156/25 159/5
159/7 163/3 165/13
171/15 175/1 185/23
186/21 187/12 189/16)
189/19 191/23 192/19}
194/3 194/10 194/12
195/24 196/16 199/25)
201/25 202/5 202/7
202/21 203/20 204/1
205/13 205/23 206/20
207/5
number [45] 2/1 9/20
17/16 18/5 21/8 21/9
22/1 26/17 27/14 29/2I
31/21 44/25 48/18
55/23 56/15 62/2
64/15 64/23 80/16
84/20 85/21 88/20
91/3 94/5 98/16 98/21
99/6 99/13 104/23
108/22 127/7 130/19
134/1 137/24 141/23
142/1 153/10 155/19
157/15 180/25 181/19}
193/22 194/8 201/25
207/21
number 4 [2] 98/16
99/6
number 5 [2] 98/21
99/13
numbers [7] 25/9
55/10 55/22 56/1 57/7
147/16 147/17
numerical [1] 101/6
fe)
objected [1] 128/4
objections [1] 91/3
objective [4] 6/9
83/19 87/11 91/19
objectively [1] 107/6
objectives [7] 13/14
13/14 13/18 191/15
192/2 192/5 192/11
objects [1] 111/12
obligations [3] 119/9
125/17 174/15
obtain [1] 48/12
obvious [1] 176/15
obviously [54] 3/4
3/16 3/19 7/8 7/12 8/4)
9/8 9/15 11/20 12/4
12/14 15/11 15/16
17/16 20/14 20/21
21/3 33/10 33/11 34/1
34/2 34/11 39/17
41/12 43/21 44/20
46/13 48/24 49/20
59/17 70/3 71/25
73/24 82/6 86/21 87/4I
91/15 92/18 97/13
103/10 103/11 114/6
121/8 123/8 131/12
135/23 136/4 137/3
137/4 137/17 142/2
(74) my... - obviously
[e)
obviously... [3]
200/16 208/11 208/14,
occasion [5] 53/13
54/3 138/7 167/19
167/20
occasions [4] 12/24
122/9 183/14 207/21
occurred [4] 29/13
60/25 196/1 206/20
October [5] 21/21
28/14 56/20 119/7
125/10
odd [7] 20/11 20/14
21/12 33/6 45/25 46/4
99/20
off [14] 22/23 28/17
57/22 63/1 63/5 70/6
81/20 105/22 108/6
121/14 122/12 169/11
175/17 193/1
offences [7] 166/9
166/11 166/16 166/18
167/15 167/18 175/23}
offer [5] 50/21 102/3
103/6 103/8 103/16
office [282]
Office's [16] 18/7
27/15 42/18 83/9
83/18 86/5 104/22
110/18 110/20 110/22)
112/12 127/12 140/10)
149/19 155/22 156/11
Officer [11] 75/13
75/14 75/19 76/6
76/10 76/12 77/4
78/10 149/7 152/24
199/20
offices [7] 7/5 10/3
24/12 35/7 140/10
140/14 142/2
official [4] 12/2
115/10 131/5 174/8
officials [32] 5/9 8/24
9/3 11/22 17/13 17/17
32/5 33/13 37/21
38/25 39/24 40/11
60/4 63/16 77/14 90/5
90/22 96/23 97/6
103/3 129/24 132/22
134/21 136/12 136/25)
137/5 137/10 137/17
138/14 138/16 138/18}
139/3
often [7] 14/7 15/4
20/6 20/22 63/1 89/20
102/11
Oftentimes [1]
205/16
Oh [4] 133/23 135/17
137/21 189/2
okay [10] 22/14
37/13 77/7 77/10
105/21 106/13 139/11
155/14 156/14 206/12)
Old [1] 164/9
older [1] 173/2
omit [1] 197/12
on [389]
once [6] 30/22 44/7
44/21 70/23 102/3
117/19
one [83] 3/3 4/23 5/7
7/3 7/13 11/9 11/10
13/14 14/9 15/14
19/12 22/15 23/14
37/8 38/1 40/6 40/11
40/13 42/3 51/4 51/5
55/18 56/13 58/12
60/11 63/19 66/2 66/5
71/5 71/7 72/3 81/7
82/1 84/17 85/20
86/17 87/16 88/18
89/19 93/13 94/13
95/9 95/14 97/2 97/5
103/4 103/22 106/13
106/25 108/7 113/25
114/23 116/6 117/4
119/25 120/9 122/10
123/4 125/1 125/4
129/2 130/11 130/20
131/10 134/3 134/5
135/11 141/19 150/10)
156/25 163/23 170/19)
174/23 176/6 176/6
177/3 180/23 186/4
189/18 195/2 196/16
198/3 205/19
one-hour [1] 71/5
ones [4] 9/14 60/8
97/23 163/22
ongoing [3] 113/19
174/15 174/16
Online [3] 28/4
150/23 151/3
only [26] 6/7 19/15
26/12 38/8 44/17 59/9)
79/1 100/12 102/11
103/11 118/25 120/7
130/13 134/5 137/3
147/5 147/19 150/25
155/12 172/13 172/20}
178/22 186/23 190/4
196/14 198/12
onto [1] 109/9
Ooh [1] 60/4
open [1] 116/22
opening [2] 166/13
198/4
operate [2] 73/23
130/13
operated [4] 149/19
163/9 164/7 165/7
operates [2] 5/22
92/6
operating [1] 12/1
operation [6] 24/17
44/24 120/24 145/4
146/14 146/15
operational [20] 6/7
6/12 6/13 6/16 8/7
8/12 16/12 29/8 45/15
45/21 46/1 46/2 46/10
69/1 69/5 121/1 121/3
121/3 121/6 127/23
operationally [1]
88/5
operations [1]
174/15
opine [1] 84/5
opinion [3] 189/6
193/10 193/16
opportunities [2]
15/14 153/20
opportunity [2] 11/13}
138/2
opposite [3] 72/16
89/5 89/6
oppressive [1]
185/16
optimal [2] 67/12
112/20
options [1] 35/9
or [138] 3/3 5/11 6/4
7/16 8/1 9/2 9/2 9/16
9/22 10/7 10/14 12/1
12/20 12/20 14/15
14/15 16/13 17/3 17/5}
19/14 20/12 21/13
21/15 23/21 23/24
23/25 24/2 24/3 29/7
31/13 34/6 38/4 38/18
39/5 40/17 40/23
40/25 41/10 43/18
46/1 48/20 50/22
50/24 51/23 53/17
54/2 56/8 56/8 56/17
56/20 57/11 59/7
59/11 59/23 60/7
60/11 61/14 61/15
62/17 62/25 66/11
69/5 73/21 75/9 83/13
83/19 84/13 85/4 88/3
88/9 90/2 94/16 96/4
96/17 97/5 99/14
99/15 100/9 102/14
103/5 105/12 107/4
108/24 110/8 110/12
112/3 112/8 112/15
113/10 114/1 114/19
116/17 121/6 125/7
125/17 126/15 130/1
132/8 135/4 135/6
136/17 138/20 145/21
145/25 147/16 148/13
148/17 151/8 157/21
158/8 159/8 159/22
161/20 163/23 166/13
166/18 167/8 167/9
172/3 172/4 173/14
177/14 180/4 184/22
184/25 187/4 189/8
190/18 196/1 196/23
196/24 197/16 197/16}
199/3 199/7 200/4
200/17 201/11
Oracle [1] 151/10
oral [1] 16/11
orally [2] 5/11 209/2
ordained [1] 120/2
order [5] 38/1 74/25
95/23 137/1 196/10
organisation [7]
120/4 132/8 140/5
147/20 163/23 179/14}
193/1
organisations [2]
24/15 164/11
orientate [1] 150/12
original [5] 116/20
117/23 118/11 118/23
202/22
originally [1] 118/5
Orwellian [2] 73/18
128/9
other [42] 3/19 5/22
7/19 7/20 9/22 11/14
15/20 16/23 17/5 24/2
25/21 41/24 42/9
42/10 45/8 53/5 53/19)
61/16 73/16 73/21
87/16 94/2 97/5 125/7
128/13 129/15 129/24}
132/21 134/22 135/11
139/12 158/5 158/8
161/7 163/23 170/21
177/3 180/12 196/22
196/23 201/3 207/7
other's [1] 139/17
others [5] 5/21 28/10
53/11 165/16 190/2
otherwise [2] 83/19
99/17
ought [4] 135/7
197/20 198/8 198/9
our [50] 23/8 32/8
33/15 48/6 52/16 53/8
57/1 57/18 71/12 75/1
92/23 105/2 117/4
119/15 120/20 125/17,
142/6 142/7 149/5
149/6 149/8 149/17
149/20 151/22 152/1
154/12 156/2 156/3
157/22 158/15 167/8
167/10 168/20 177/16}
177/16 178/19 179/17
180/13 181/17 182/24,
184/2 192/6 192/7
195/20 196/14 198/2
198/13 199/20 202/1
204/25
ourselves [1] 150/12
out [57] 11/11 12/16
13/13 13/18 13/20
15/4 18/14 20/23
28/24 29/9 32/13 37/7I
42/17 62/6 83/21
87/20 88/23 93/14
94/20 95/22 104/14
104/22 105/25 106/12)
106/14 106/20 106/21
112/10 116/10 117/1
122/6 129/2 131/4
135/2 136/6 141/21
146/19 151/5 161/1
161/25 167/24 169/5
169/20 171/9 178/7
182/9 184/15 189/22
190/1 190/11 192/22
198/22 199/7 204/21
205/3 205/5 205/10
outcome [3] 40/22
41/3 128/17
outcomes [1] 41/4
outlined [1] 98/11
outset [1] 115/25
outside [5] 90/25
149/8 152/1 154/12
198/13
outsourcing [1]
149/22
outstanding [1]
161/5
over [46] 10/8 14/2
18/13 24/7 24/14
24/16 24/25 26/14
26/15 28/1 29/14
41/14 42/7 44/13
45/10 48/7 58/10
59/25 61/4 62/4 62/16)
65/7 67/4 68/20 78/25
81/2 85/1 94/8 99/14
111/5 111/20 112/13
116/6 150/20 155/18
157/11 157/14 170/8
171/25 180/12 185/7
188/1 188/20 191/10
196/6 204/20
Overall [1] 153/12
overlap [1] 164/10
overnight [2] 95/6
109/16
overpromised [1]
68/21
oversee [2] 177/14
179/6
oversight [8] 11/25
12/17 81/7 130/13
156/5 163/3 176/20
201/11
overturn [1] 116/13
overturned [3] 124/8
201/4 201/20
overview [2] 167/6
167/16
own [12] 15/17 38/17
49/5 85/5 122/3
140/10 141/17 154/13}
(75) obviously... - own
[e)
own... [4] 163/11
163/15 171/6 200/2
owned [3] 12/20
130/22 175/12
owner [1] 171/22
Pp
pace [1] 82/11
pack [11] 19/7 36/18
37/5 38/2 38/13 43/1
56/4 66/8 68/2 96/24
138/11
packed [1] 98/12
packs [2] 42/9
138/11
page [93] 1/18 5/25
14/2 14/6 17/20 26/15
26/15 28/1 29/11
29/14 32/25 33/1 36/6
45/10 48/4 48/7 49/12
53/2 57/14 61/21
61/21 62/6 62/16
62/16 63/3 64/14 65/2
65/3 65/10 67/9 81/2
84/19 85/1 85/15
87/20 88/1 89/12 90/9
94/8 98/1 98/2 98/24
107/13 111/5 111/20
112/9 112/13 116/6
118/3 120/12 120/12
120/15 120/18 143/7
143/17 144/1 145/17
149/12 150/11 150/15}
150/20 153/3 153/4
153/22 153/23 155/8
157/11 157/11 160/13
163/5 164/13 165/23
169/1 169/18 170/3
170/8 170/10 171/25
172/12 172/16 173/10}
174/2 185/23 188/1
188/20 195/8 197/7
197/8 198/3 198/6
202/21 207/17 208/7
page 1 [4] 62/16
65/10 98/24 172/16
page 10 [1] 145/17
page 12 [1] 53/2
page 147 [1] 169/18
page 150 [1] 170/3
page 2 [9] 48/4 61/21
61/21 85/15 89/12
120/15 185/23 202/21
207/117
page 21 [1] 143/7
page 23 [1] 150/11
page 3 [10] 65/2 65/3
120/12 120/12 149/12
153/4 160/13 172/12
173/10 198/3
page 31 [1] 150/15
page 33 [1] 197/7
page 34 [1] 197/8
page 35 [1] 164/13
page 4 [2] 64/14
169/1
page 40 [1] 143/17
page 47 [1] 5/25
page 5 [2] 163/5
174/2
page 54 [1] 144/1
page 6 [2] 67/9
153/22
page 7 [1] 155/8
page 8 [1] 36/6
pages [1] 38/1
pagination [1] 197/8
paid [1] 75/14
pained [1] 53/15
paper [13] 22/13
38/24 41/17 152/21
153/23 154/6 154/9
157/8 157/10 157/18
157/20 159/15 165/4
papers [2] 157/1
193/12
paragraph [46] 5/25
6/1 18/18 23/18 23/19)
28/5 33/1 34/21 36/6
36/7 39/15 40/7 41/9
49/7 50/9 53/2 58/5
72/5 85/21 86/25 88/1
102/1 107/12 109/6
111/22 112/13 117/15)
117/21 118/4 127/10
143/7 143/18 145/18
156/15 163/5 164/13
173/10 174/2 180/24
181/10 194/4 197/2
204/9 207/22 208/1
208/6
paragraph 103 [1]
164/13
paragraph 112 [3]
5/25 6/1 181/10
Paragraph 119 [1]
143/18
paragraph 13 [1]
163/5
paragraph 131 [1]
127/10
paragraph 137 [1]
194/4
paragraph 14 [1]
112/13
paragraph 21 [2]
36/6 36/7
paragraph 23 [1]
41/9
paragraph 25 [1]
53/2
paragraph 26 [1]
156/15
paragraph 28 [1]
145/18
paragraph 4 [1]
208/6
paragraph 4.5 [1]
173/10
paragraph 59 [1]
143/7
paragraph 73 [1]
197/2
paragraph 74 [1]
109/6
paragraph 9 [2] 28/5
111/22
paragraphs [9] 83/7
86/14 86/15 116/7
130/19 202/11 204/6
204/14 204/17
paragraphs 127 [1]
202/11
paragraphs 146 [1]
130/19
parameter [1] 197/10
Parcelforce [1]
171/20
pardon [1] 203/15
parent [3] 147/4
205/21 205/25
park [1] 156/13
Parliament [41] 2/4
4/12 5/4 5/7 5/15 6/25)
17/19 17/23 18/8
28/16 33/7 39/21
39/22 39/24 41/25
45/25 58/6 58/10 59/1
59/6 59/19 60/1 60/3
61/9 61/25 63/20 74/6
98/18 104/23 105/1
105/9 113/7 114/2
114/5 114/6 114/8
115/11 118/13 121/10}
121/11 138/24
Parliamentarian [1]
66/9
Parliamentary [11]
2/12 2/21 5/5 5/13
19/10 59/3 60/5 61/17
69/25 134/9 188/9
Parlimentarians [1]
40/9
part [37] 5/6 5/13
8/18 8/21 11/24 21/24
32/4 32/8 35/10 37/23
38/9 41/6 41/15 44/1
59/25 80/2 89/25 97/9
102/15 111/8 111/8
112/10 129/19 131/15}
144/14 145/8 148/11
150/10 169/18 170/12
170/19 172/21 172/25}
174/18 182/24 193/11
197/25
Participant [1]
201/19
participants [3]
108/18 112/6 191/2
particular [26] 8/15
12/14 15/10 22/6
31/17 32/15 33/4 48/2
49/19 60/8 63/10 68/1
74/8 86/21 92/12
96/20 100/7 103/4
125/24 137/10 152/18}
174/23 179/11 181/7
184/23 203/8
particularly [12] 9/7
33/16 35/22 87/8
94/19 95/20 96/13
96/19 100/8 105/17
107/9 202/7
parties [2] 90/21 91/6
parts [1] 97/1
party [3] 2/10 138/24
149/19
Pass [1] 99/14
passage [3] 5/23
85/24 97/10
passages [2] 23/17
111/21
passed [2] 74/12
104/17
passport [1] 7/17
past [5] 18/13 24/25
68/21 190/2 204/20
Pat [4] 7/7
Patel's [1] 29/18
Patrick [11] 99/4
99/11 99/25 133/18
133/24 133/25 200/11
200/15 200/25 210/12,
210/22
Paul [1] 125/23
Paula [59] 13/12
13/25 14/4 15/11
15/23 21/13 34/20
36/10 36/19 47/23
53/5 53/6 54/2 54/6
55/6 57/16 57/18
57/23 58/11 60/1
60/20 60/25 61/10
64/15 67/11 67/14
67/24 68/15 68/21
70/7 75/18 80/9 80/13
80/24 81/14 81/18
81/19 82/3 82/6 115/1
115/8 119/2 119/25
120/2 123/4 125/2
125/10 126/18 132/1
133/3 179/23 183/3
185/24 186/2 187/8
188/3 188/7 189/1
190/16
Paula's [3] 13/16
68/8 68/12
pause [7] 77/5
124/24 142/16 168/3
177124 189/17 191/4
pausing [8] 25/3
48/22 67/17 97/3
147/15 157/12 163/14}
164/20
pay [4] 70/10 76/21
78/4 171/6
payment [1] 76/9
pdf [1] 22/23
pension [2] 146/8
146/9
Pensions [2] 34/5
34/6
people [46] 9/15
11/14 16/8 21/8 21/10
32/6 35/24 39/25 42/2I
51/8 54/14 60/7 60/12
63/22 64/15 68/8
73/16 73/21 95/25
105/10 124/12 128/13)
129/2 130/12 136/20
147/20 163/17 163/21
164/2 175/5 175/11
176/23 177/2 182/2
182/12 182/17 182/23}
183/10 183/12 188/17)
190/4 190/22 191/16
192/1 193/3 195/6
per [7] 3/20 4/2 4/5
4/20 24/13 60/23
60/24
perceived [3] 45/2
158/3 158/6
perception [4] 202/6
202/19 205/8 205/23
perfectly [1] 77/4
perform [1] 24/12
performance [10]
23/10 28/3 68/4 68/12
74/12 76/1 78/25
80/18 81/12 81/20
perhaps [18] 12/25
43/18 76/10 76/13
85/14 91/5 105/13
111/20 123/14 136/14)
140/21 167/6 179/20
185/1 185/10 190/12
207/22 208/6
period [12] 10/19
24/17 54/22 66/20
73/9 79/16 140/15
151/17 160/3 171/4
178/23 180/7
periodic [1] 26/7
peripheral [1] 200/17
Perkins [12] 13/11
14/4 21/14 36/10
36/19 68/3 75/5 77/15
119/24 125/11 126/19)
177/18
Perkins’ [1] 158/17
Permanent [3] 11/23
11/25 31/1
permission [4] 76/6
76/17 76/18 99/7
person [15] 11/15
58/10 58/14 59/8
59/21 67/12 69/24
78/13 79/9 87/8 119/3
(76) own... - person
Pp
person... [4] 186/12
186/15 187/1 187/11
personal [6] 33/5
82/8 108/20 159/23
161/13 178/9
personalities [1]
68/9
personally [8] 22/9
58/8 63/2 70/4 158/20)
167/23 168/21 178/16
personnel [1] 10/7
perspective [8]
19/16 46/18 59/15
91/10 102/4 108/16
108/19 179/13
persuaded [1] 132/4
pertained [1] 28/3
Peter [5] 42/13 61/22
62/24 71/10 129/11
Phase [1] 201/21
Phase 1 [1] 201/21
phrase [4] 95/19
95/21 95/24 150/24
physically [1] 39/10
pick [3] 32/22 96/7
200/22
picking [2] 87/5
188/6
picture [3] 35/12
140/22 158/22
piece [6] 16/5 121/13
161/14 198/25 199/13
199/24
place [27] 24/7 25/11
32/17 32/19 71/17
71/24 75/21 79/4
79/12 80/13 81/11
99/10 129/4 131/7
143/13 148/6 161/25
162/7 162/10 167/10
177/5 178/10 178/22
184/5 198/24 199/13
200/1
placed [1] 6/2
places [1] 5/7
plan [8] 13/21 68/4
68/6 68/7 68/17 142/7I
146/16 199/22
planned [1] 152/11
planning [2] 73/7
7715
plans [4] 70/20 98/6
127/12 141/9
plates [1] 154/2
play [1] 46/11
plays [1] 90/19
plead [1] 50/20
please [90] 1/11 1/18
13/6 13/6 17/18 17/20
21/19 23/15 28/13
34/14 34/15 36/5
41/11 42/12 42/16
48/7 52/19 57/9 57/14
61/1 64/13 65/13 67/9
70/18 70/18 71/9
71/11 74/10 74/11
81/2 83/3 85/1 86/7
89/13 93/22 94/8
97/25 99/12 99/19
104/16 111/5 112/22
116/6 118/2 118/3
142/23 143/7 143/17
143/25 145/17 148/18)
149/12 150/11 150/15)
150/22 152/20 153/3
153/22 153/24 157/3
157/5 157/10 157/11
157/12 157/12 158/23}
159/18 160/13 163/4
164/13 165/1 165/11
165/22 168/23 169/1
169/18 170/2 170/3
170/23 171/17 171/25)
172/12 172/16 179/23)
185/24 186/4 187/6
207/16 207/17 208/7
pleased [3] 86/20
115/13 115/16
pled [1] 62/12
plot [1] 104/13
pm [9] 93/5 93/7
124/19 124/21 162/22)
162/24 171/10 171/12)
209/8
point [65] 14/22 16/9
21/7 30/15 31/22 35/4
35/22 38/24 43/18
45/20 50/16 54/24
54/25 55/17 55/18
60/16 69/20 70/5
70/10 76/15 79/2 82/1
84/19 87/15 87/20
90/10 91/8 91/18
91/20 92/9 92/12
92/14 94/13 101/10
101/12 102/19 107/18)
119/15 122/15 123/23)
125/4 128/7 138/10
151/8 151/16 152/18
155/7 155/9 158/9
159/5 160/2 161/3
161/20 168/15 181/24}
184/8 194/12 198/12
203/7 203/16 206/4
207/9 207/10 207/12
207/20
pointed [1] 80/13
points [17] 4/15 64/7
72/22 80/3 89/10
103/7 106/16 116/10
117/14 119/25 120/22)
136/16 143/6 144/12
160/5 162/1 189/20
POL [26] 40/20 40/21
52/2 52/4 52/6 60/12
63/1 88/4 99/14 100/7)
100/10 100/11 113/3
123/25 136/15 136/17]
137/4 137/12 137/20
137/24 138/1 156/17
170/8 170/20 179/24
207/24
POL's [1] 137/3
POL00029114 [2]
159/18 199/2
POL00030217 [2]
148/19 196/18
POL00030482 [1]
199/2
POL00030800 [1]
171/17
POL00031004 [1]
170/23
POL00031034 [1]
173/9
POL00046235 [1]
165/2
POL00058098 [1]
202/13
POL00099156 [1]
61/2
POL00102169 [1]
109/9
POL00105483 [1]
180/19
POL00132580 [1]
115/1
POL00143463 [2]
203/21 204/4
POL00196410 [1]
64/13
POL00223650 [1]
117/12
POL00223651 [1]
118/2
POL00386985 [1]
117/8
POL00432053 [1]
168/23
police [2] 16/22
175/9
policies [4] 174/13
174/19 174/21 174/24
policy [23] 3/14 4/13
9/2 30/5 37/20 37/22
78/4 122/11 122/19
138/16 163/7 171/18
172/1 172/7 172/14
172/23 172/24 172/24I
172/25 173/7 173/19
173/24 174/19
political [2] 7/6 15/18
politicians [1] 122/1
POLSAP [1] 150/20
pools [1] 9/19
poor [2] 188/11
195/6
portfolio [11] 3/21
11/2 14/25 15/4 15/5
15/7 18/9 20/24 61/16}
64/21 86/13
portrayed [1] 187/1
posed [1] 61/9
posit [1] 79/24
position [14] 8/9
22/25 23/3 39/2 51/20)
72/9 91/19 106/23
128/12 137/10 149/3
175/6 189/6 200/6
positions [2] 24/11
140/1
positive [6] 102/18
102/20 140/8 159/8
160/1 181/11
possible [20] 29/20
34/17 36/8 41/1 41/5
43/16 47/13 62/5
62/21 67/1 77/9 85/11
87/15 92/17 109/17
117/5 123/14 136/14
136/18 170/3
possibly [8] 40/20
57/2 91/14 96/4 99/9
138/23 181/22 201/2
post [263]
postal [9] 2/14 3/12
4/1 4/5 4/18 4/24 4/24)
5/3 14/16
postcard [1] 33/17
postmaster [1] 58/3
posts [2] 3/3 3/4
potential [7] 26/13
64/7 74/21 75/12
167/21 178/3 178/4
potentially [11] 34/25
59/11 85/12 95/22
96/11 132/22 137/22
147/11 148/17 161/19
184/9
pounds [2] 76/8 77/2
power [1] 84/10
powerful [1] 201/20
PowerPoint [1] 69/21
powers [2] 175/9
175/10
practice [1] 7/25
practices [2] 174/14
184/4
pre [5] 33/16 59/12
112/21 201/9 202/1
pre-agreed [1] 33/16
pre-empt [1] 59/12
pre-separation [2]
201/9 202/1
preceding [1] 7/9
precisely [3] 53/25
125/16 208/20
predecessor [1] 18/2
predecessors [1]
65/9
predicated [1]
197/18
preferred [1] 101/2
premeditated [1]
88/15
premium [1] 174/7
preoccupation [1]
179/15
preparation [4] 4/12
93/9 172/22 202/23
preparations [2] 11/7
96/22
prepare [2] 104/9
196/8
prepared [10] 19/2
37/5 84/8 86/12 93/11
151/24 174/23 194/21
196/22 198/16
preparedness [2]
194/7 196/25
preparing [6] 16/11
48/25 72/25 101/19
104/5 125/9
presence [1] 101/10
present [3] 131/15
136/12 199/25
presentation [4] 67/6)
67/8 67/8 74/12
presented [8] 6/15
81/23 89/4 107/2
1410/7 177/23 189/7
189/10
presenting [2] 88/17
88/20
presents [1] 176/9
preserved [1] 86/19
President [1] 144/21
press [2] 184/6
186/20
pressure [3] 70/9
75/20 207/11
presumably [6] 78/2
132/21 150/23 151/4
155/21 195/14
presume [1] 10/23
presumption [1]
117/4
pretend [1] 88/24
pretty [8] 25/17 54/23
60/21 63/18 69/8 70/3
105/19 185/1
prevent [1] 160/18
previous [8] 27/5
87/20 108/1 114/18
115/21 138/12 151/25)
154/10
previously [3] 87/1
107/16 108/22
primarily [1] 149/6
primary [1] 199/18
prime [1] 64/25
principal [1] 84/17
printer [1] 40/1
printing [1] 30/6
prior [2] 75/2 194/6
priorities [4] 13/16
15/15 71/12 71/14
prioritise [1] 88/23
(77) person... - prioritise
P
priority [2] 57/25
174/4
private [55] 10/3 10/4
10/4 17/5 22/2 22/3
22/4 22/5 22/15 22/16
22/20 30/6 37/24 38/5
39/1 39/10 42/14 48/8
56/5 56/19 56/24
56/24 63/16 64/20
71/4 74/14 75/8 77/25
85/15 86/7 86/20
86/22 89/13 89/18
90/2 90/5 91/15 94/23,
98/3 99/22 103/23
104/19 105/5 105/7
139/4 144/20 156/4
158/19 175/3 175/12
175/14 176/19 177/20
177/25 186/18
privately [1] 84/4
privileged [6] 150/2
150/17 151/14 197/14
198/5 198/7
privileges [1] 151/9
privy [3] 103/9
106/24 144/15
pro [1] 33/19
proactive [1] 178/5
proactively [3] 52/7
141/18 142/4
probably [34] 3/20
4/4 4/19 6/19 9/11
9/17 16/10 33/23
35/10 43/3 56/20 57/5)
58/19 60/7 60/11
60/23 69/18 77/1
79/18 81/23 82/13
87/17 99/7 105/14
111/11 139/1 140/20
141/22 141/24 162/17
173/5 176/13 179/12
190/5
probe [1] 127/20
probed [1] 122/9
probing [3] 82/15
100/15 137/18
problem [14] 25/25
31/4 73/6 88/17 93/24
119/4 154/24 161/19
182/10 183/15 186/25)
197/4 198/19 203/6
problematic [3] 64/5
119/14 155/1
problems [15] 43/9
44/11 44/17 45/19
47/24 49/8 50/10
50/16 64/7 88/10 94/6
119/20 130/25 181/2
200/17
procedures [1]
174/13
proceed [1] 192/13
proceedings [2]
163/4 188/17
process [30] 18/24
25/11 28/22 30/13
32/17 36/1 37/20
51/13 51/20 79/17
88/16 90/17 90/22
90/23 92/5 95/14
101/22 103/10 117/2
117/7 124/9 133/7
149/25 150/1 172/21
177/20 178/12 178/21
182/4 184/21
processed [1] 30/3
processes [5] 18/13
45/2 107/14 148/5
205/1
processing [1]
197/16
produce [2] 37/21
114/9
produced [5] 37/18
41/8 90/16 108/7
116/24
products [1] 167/10
profess [1] 50/1
professional [1]
160/1
profit [1] 120/8
programme [3] 146/9!
152/10 174/12
progress [9] 13/20
58/3 72/7 80/20 89/22
98/18 160/23 161/9
199/16
Project [1] 101/10
prolonging [1] 85/8
prompted [2] 134/8
187/21
proper [1] 124/9
properly [13] 17/7
46/14 82/18 101/9
122/22 128/1 130/13
160/8 167/10 176/14
176/24 177/3 198/15
proportion [5] 24/21
25/10 25/10 55/15
55/23
proposal [2] 28/5
79/10
propose [1] 71/5
proposed [5] 42/18
93/25 94/13 110/20
112/12
prosecute [5] 155/19
157/15 175/25 176/6
180/9
prosecuted [4] 16/8
62/14 173/23 202/1
prosecuting [6] 49/6
99/15 155/23 156/11
177/10 180/4
prosecution [26]
16/14 16/22 26/2
116/15 116/17 116/20}
117/24 118/11 118/23
122/11 122/19 147/11
148/14 156/17 158/10
168/6 173/7 173/13
173/15 173/19 174/19
175/10 175/24 176/4
176/5 191/25
prosecution's [1]
94/16
prosecutions [31]
17/6 25/23 35/22
48/23 49/5 119/12
128/23 140/19 166/21
167/22 168/21 172/9
175/3 175/15 175/21
176/16 176/19 176/21
177/14 178/6 178/25
179/6 180/12 180/14
181/23 182/4 185/17
197/18 201/9 206/10
208/4
prosecutor [2] 98/23
116/14
prosecutorial [3]
184/12 185/19 185/20
prospect [1] 136/23
protect [2] 180/13
180/13
protection [2] 42/1
167/10
protections [1] 42/5
protocols [1] 184/4
proved [1] 24/17
provide [4] 38/17
64/8 169/6 173/18
provided [28] 47/6
56/12 64/3 109/11
116/5 121/5 127/11
127/24 130/15 143/2
145/24 148/23 148/25)
151/1 156/6 158/14
158/22 161/8 161/15
167/25 168/19 169/10
178/9 179/9 180/11
185/24 196/3 206/6
provider [2] 7/21
169/6
provides [2] 50/18
169/12
providing [2] 138/16
170/16
provision [2] 121/22
169/7
public [8] 5/20 74/7
96/17 99/16 121/10
130/8 131/11 131/14
publication [2] 36/11
121/15
publicly [2] 26/5
57/21
publish [1] 105/41
published [2] 121/18
144/9
Pugh [1] 22/23
pulled [1] 105/25
purpose [12] 2/12
13/10 13/14 27/23
37/14 44/10 110/17
143/3 155/3 171/25
173/20 180/6
purposes [2] 135/15
154/21
pursue [2] 116/21
175/14
pursued [4] 147/10
158/9 176/16 181/23
pursuing [1] 176/21
pushback [3] 77/13
91/20 91/22
pushed [1] 122/9
pushing [1] 109/2
put [28] 21/1 26/22
68/3 75/11 81/11
82/19 87/13 92/18
93/13 95/1 99/18
102/12 114/21 115/15}
115/19 119/18 131/6
141/12 148/6 151/23
178/10 184/18 192/24}
197/22 198/22 200/1
205/19 208/20
puts [1] 78/23
putting [6] 30/6
71/11 98/8 99/10
106/15 178/21
PVEN00000500 [1]
185/23
PVEN00000532 [1]
188/5
PVEN00000533 [1]
187/16
210/12 210/14 210/18
210/20 210/22 210/24I
questioning [2]
87/14 103/7
questions [54] 5/10
17/3 55/3 56/15 56/18}
56/21 60/13 60/16
61/6 61/8 61/9 61/12
61/14 61/17 63/17
63/20 63/22 72/24
82/14 93/13 93/21
94/9 95/7 95/18 96/8
122/15 122/25 123/2
130/1 131/19 133/18
137/2 138/7 139/12
140/9 142/6 142/12
144/10 144/11 145/1
145/2 188/10 190/25
191/1 200/10 201/16
203/3 203/11 206/3
206/7 206/8 207/7
208/24 209/2
quick [4] 85/19 89/19
98/10 100/4
quicker [1] 106/1
quickly [6] 31/7
120/11 201/1 202/13
203/20 204/5
quiet [1] 36/22
quietly [1] 171/6
quite [22] 9/17 33/21
35/3 35/5 43/20 46/8
47/13 49/4 52/11 57/6)
67/24 68/25 76/10
93/16 106/11 107/24
107/25 109/17 120/11
135/20 162/7 185/22
quote [1] 125/3
Q
R
QC [1] 97/15
qualify [1] 66/3
quality [3] 31/3 31/25
87/2
quashed [1] 165/15
queries [1] 178/1
querying [1] 55/4
question [35] 5/10
19/10 44/8 48/12 58/6}
59/5 59/6 59/8 59/11
59/23 79/25 85/20
86/23 93/11 94/9 95/1
95/3 95/8 100/8 123/4I
124/23 126/25 130/24}
137/8 137/22 156/8
156/10 156/10 180/6
183/22 190/12 200/13}
201/7 206/3 207/19
questioned [22] 1/9
68/12 87/2 124/25
127/6 131/22 133/24
139/14 142/22 191/11
200/25 207/14 210/4
210/6 210/8 210/10
rag [1] 78/2
rags' [1] 74/21
raise [5] 59/5 64/8
69/18 90/4 203/8
raised [33] 18/5 18/6
21/6 21/13 31/25
35/22 40/12 46/7
53/19 64/9 75/25 96/5
103/16 141/1 1441/5
142/4 150/25 151/21
151/21 151/23 152/2
152/5 155/8 158/10
177/25 178/1 184/24
185/8 194/3 199/15
200/20 201/8 207/19
raises [3] 82/14
101/25 203/6
raising [6] 55/5 66/4
142/3 164/16 188/16
203/3
range [3] 4/25 23/24
166/16
ranged [1] 146/9
ranging [1] 3/13
(78) priority - ranging
R
39/7 58/8 73/6 74/20
76/11 85/7 92/14
96/25 102/5 107/22
109/15 111/2 114/4
196/2 196/25
rating [1] 178/18
re [3] 68/18 99/1
207/10
re-engage [1] 68/18
re-examination [1]
207/10
reached [1] 124/7
reacting [1] 202/24
reaction [3] 134/9
135/2 200/20
read [32] 19/6 23/17
28/11 33/12 36/6
38/12 39/6 43/15
47/17 47/20 78/11
83/7 95/19 96/24
107/12 110/13 138/7
138/9 143/21 148/25
155/12 155/25 156/3
197/3 199/3 202/23
readiness [1] 154/25
reading [14] 25/3
25/4 25/18 39/11
86/19 114/11 138/12
154/6 154/8 156/5
readout [2] 75/3
128/24
ready [3] 96/6 154/14
169/23
real [7] 11/11 35/18
53/20 86/23 99/16
130/16 186/6
realise [2] 11/5 47/21
realising [1] 36/8
reality [2] 53/16
54/18
really [28] 8/21 15/15
38/12 51/5 54/5 67/25
69/8 72/12 76/23
86/10 86/18 87/24
100/13 106/6 108/13
109/3 122/24 133/6
134/12 137/4 138/2
149/6 151/24 152/10
161/13 167/20 183/7
190/10
reason [10] 89/18
100/5 116/19 117/23
118/10 118/22 129/19}
129/22 172/20 173/2
reasonable [4] 47/12
123/11 124/10 158/22)
reasons [5] 80/16
rather [20] 24/2 33/8
120/25 129/19 153/18}
157/21 165/16 174/25)
177/19 188/12 194/20)
43/11 43/13 56/4 78/5
122/16 130/11 180/5
184/6
reassurance [4]
127/24 140/1 140/7
183/23
reassure [5] 36/24
54/10 54/11 88/17
154/19
reassured [5] 17/3
97/12 97/15 97/19
159/15
reassuring [8] 25/7
25/13 36/2 43/12
87/17 95/22 118/24
154/9
rebuttal [1] 104/5
recall [52] 14/4 14/6
19/2 19/25 22/17 25/3
25/4 28/7 32/4 34/23
36/14 36/20 40/8 41/4
43/13 52/12 53/9
53/13 54/19 56/18
57/13 60/2 60/20
60/21 65/17 65/19
66/11 66/12 66/15
82/21 97/21 124/3
134/20 141/5 148/15
148/21 150/25 158/8
158/13 158/21 161/7
165/6 168/21 178/16
178/25 179/2 179/4
183/17 187/20 202/12)
202/15 203/22
recalled [1] 82/1
receive [8] 8/6 15/5
36/25 71/21 101/4
120/14 120/21 121/12)
received [35] 13/5
19/5 35/6 42/22 42/24
42/25 43/1 43/22 47/9)
64/24 65/14 66/8 70/7)
72/2 75/17 76/4 82/10
101/25 110/8 113/5
113/16 118/16 119/16)
121/8 121/24 122/18
152/15 155/10 155/15)
156/24 160/15 167/22)
168/4 202/9 207/8
receiving [8] 10/19
30/17 41/16 42/7
48/25 66/17 106/16
159/22
recent [1] 22/22
recently [8] 6/23 11/7
19/15 65/14 79/1
80/12 102/17 108/21
Recipient [1] 169/6
recital [1] 169/2
recitals [1] 169/1
recognise [4] 12/25
31/10 53/20 69/2
recognised [4] 8/8
46/25 135/24 207/9
recognises [1] 57/19
recollect [1] 148/12
recollection [22]
36/21 39/16 53/25
81/24 136/7 136/11
136/13 154/6 154/8
154/11 159/8 159/12
160/9 161/14 164/12
195/11
recommend [3]
29/19 90/18 112/11
recommendation [1]
110/21
recommendations
[9] 130/20 149/20
161/4
recommended [1]
121/12
reconciled [1] 181/4
reconciliations [3]
18/14 28/24 204/21
record [1] 143/4
recorded [3] 18/15
28/25 204/23
records [4] 48/15
115/11 128/3 141/5
recovery [1] 156/17
recruited [1] 9/15
recruiting [1] 79/19
recruitment [3] 9/18
9/19 79/17
rectified [1] 136/3
rectify [1] 44/6
recuse [1] 13/2
red [3] 78/2 188/16
196/25
redress [2] 50/22
124/11
reduce [2] 87/3
101/12
reduced [2] 180/4
180/12
reduces [1] 112/3
reducing [3] 72/17
73/4 114/18
redundant [1] 112/2
refer [5] 101/5
164/10 164/15 181/18
183/2
reference [16] 2/1
26/15 45/21 50/9
58/13 73/12 80/21
90/16 94/4 95/11
109/8 110/23 113/12
128/14 134/11 173/8
referenced [4] 8/4
8/5 15/12 139/18
references [1]
123/17
referencing [1] 15/16
referred [12] 20/13
159/13 159/21 159/23
174/25 178/10 181/11
150/13 150/14 153/14
153/18 154/18 160/25)
23/1 23/21 26/24
75/16 90/14 97/23
101/23 114/13 129/14}
147/25 199/1
referring [12] 21/20
57/15 61/20 103/22
109/13 125/20 127/1
147/15 153/5 153/6
177/25 180/19
refers [7] 14/14
18/18 27/19 57/12
156/15 160/21 169/2
reflect [4] 25/20
71/20 100/20 190/2
reflection [4] 47/4
67/17 78/16 190/17
reflects [3] 17/7
83/17 100/21
reframe [1] 134/8
regard [5] 33/4 44/24
94/19 95/21 107/18
regarded [1] 197/4
regarding [5] 44/17
64/23 65/14 74/12
125/18
regardless [1] 84/6
regards [2] 27/13
85/20
register [5] 148/11
148/12 170/17 178/12)
178/18
registered [3] 167/20
181/15 181/15
registers [4] 147/1
147/1 148/5 179/1
regret [3] 56/13
108/13 109/4
regular [3] 36/16
82/6 199/17
regularly [8] 10/17
21/23 24/16 60/10
67/24 71/1 89/22
141/2
regulated [1] 167/12
regulatory [2] 146/19)
150/5
reinforced [2] 92/14
108/19
reinterpret [2] 73/10
128/14
reinterpreting [1]
73/21
reinvestigation [3]
116/18 117/22 118/9
reiterate [1] 130/6
reject [1] 50/23
rejected [5] 40/25
41/2 84/21 85/23
90/11
rejection [1] 87/6
relate [6] 48/17
114/25 120/24 153/17}
161/1 200/3
related [7] 18/12
28/22 55/10 88/6
132/1 145/22 155/11
relates [2] 33/11
120/25
relating [10] 23/8
27/3 42/1 65/15
148/13 148/16 149/18)
154/5 163/7 168/24
relation [8] 84/21
85/22 97/10 109/19
111/7 128/7 141/12
150/5
relations [4] 2/13
3/12 4/1 163/12
relationship [14]
67/18 67/25 68/19
80/9 82/3 84/16
100/21 149/5 149/8
153/2 158/25 160/2
160/8 172/5
relationships [5]
67/15 68/11 68/15
192/6 192/7
relative [1] 155/16
relatively [3] 53/8
77/18 77/19
relaxed [1] 53/8
relayed [1] 91/13
release [2] 28/5
42/19
releasing [1] 111/25
relevant [8] 2/12
17/13 22/5 30/5
131/12 140/15 164/5
202/7
reliable [2] 153/13
198/18
reliance [1] 154/2
reliant [1] 129/25
relied [1] 119/11
relief [1] 122/14
reluctant [1] 130/3
rely [2] 63/16 137/14
relying [1] 138/14
remain [1] 116/21
remained [3] 55/20
101/21 161/5
remaining [3] 111/25
112/19 115/20
remains [4] 53/7 54/7
110/25 120/20
remarks [1] 101/23
RemCo [1] 78/19
remember [36] 31/5
35/2 35/5 39/17 56/23}
63/23 103/17 106/3
106/4 120/1 121/13
121/16 125/15 141/19)
155/24 157/22 160/4
164/23 164/25 166/4
167/3 167/5 167/14
167/14 167/17 167/23)
168/2 168/14 174/21
174/23 179/15 181/13}
(79) rather - remember
R
remember... [4]
183/3 187/25 196/19
207/18
remembered [1]
181/14
remit [2] 90/25 172/9
remote [7] 135/6
135/10 135/14 135/19}
151/16 193/23 196/23)
remotely [2] 151/18
189/13
removal [1] 69/12
removing [3] 79/5
80/4 110/6
remuneration [4]
70/8 75/12 75/20
81/10
renders [1] 112/2
renewals [1] 7/17
reopen [3] 50/22
50/25 52/4
repeat [1] 58/17
repeated [1] 202/20
repeatedly [1] 68/21
replace [2] 76/12
79/11
replacing [1] 79/6
replies [1] 26/23
reply [12] 22/23 23/1
102/20 188/1 188/20
203/20 203/20 203/23,
204/2 204/3 205/2
205/10
replying [1] 18/8
report [74] 4/11 36/4
36/12 36/23 41/8
41/12 42/18 42/20
42/23 43/2 43/6 43/13
43/15 44/1 44/5 44/12)
44/19 45/5 45/6 45/16)
45/22 46/8 49/8 49/15
50/10 50/14 50/18
58/2 58/7 61/24 83/5
83/8 83/17 84/7 84/24
84/25 86/2 86/3 86/6
87/6 90/1 90/13 90/14,
90/25 91/1 91/4 91/5
91/10 101/22 102/16
112/16 113/21 120/15}
120/21 121/4 121/24
135/23 138/8 147/4
154/11 159/1 159/6
160/12 164/14 195/2
195/10 195/11 195/13
196/1 196/1 196/20
197/1 197/7 201/14
report' [1] 90/15
report's [2] 45/18
87/2
reported [5] 139/6
145/22 147/9 148/1
199/16
reporting [4] 11/15
154/22 155/3 200/4
reports [9] 84/8
84/20 85/21 87/1
89/24 90/12 193/14
194/19 194/20
represent [3] 125/2
127/7 201/3
representative [5]
88/18 88/20 88/24
89/3 207/9
reputational [4]
147/2 147/3 147/9
147/19
request [8] 23/7 27/3
27/10 27/25 28/1 28/8)
120/13 207/8
requested [2] 62/2
115/3
requesting [1] 62/7
requests [2] 160/15
191/5
require [4] 19/18
25/15 81/10 160/25
required [3] 81/6
100/4 108/2
requirements [4]
49/2 173/11 174/7
196/11
requires [1] 68/17
requiring [1] 158/6
reserve [1] 193/20
resisted [1] 26/6
resolution [1] 184/22
resolve [3] 25/12
53/21 174/4
resolved [3] 171/15
184/1 199/8
resources [1] 185/11
respect [13] 3/3 8/16
9/21 10/14 12/7 12/11
14/17 24/20 28/16
39/15 59/25 120/13
184/25
respected [1] 194/24
respectful [2] 59/13
74/6
respectively [2] 44/5
62/11
respects [2] 3/2 45/5
respond [6] 22/6
42/4 46/6 96/3 98/14
107/5
responded [5] 28/11
61/17 77/11 81/19
114/20
responding [6] 20/7
41/25 47/15 47/15
56/21 204/7
responds [3] 62/17
62/18 65/5
response [30] 26/21
29/24 30/5 33/19
33/25 48/13 56/4
57/21 58/2 63/3 89/24
90/2 90/8 98/24
102/10 102/11 104/3
104/22 105/2 105/16
106/1 107/10 108/10
122/13 137/3 183/6
198/20 198/24 205/10
206/7
responses [2] 93/25
102/12
responsibilities [3]
12/22 12/24 108/25
responsibility [9]
11/21 12/6 17/10
51/12 51/20 145/2
145/3 199/19 208/3
responsible [4]
27/15 29/13 65/21
201/10
rest [3] 30/12 42/9
132/23
rested [2] 132/10
145/4
restraint [1] 78/4
result [4] 106/25
115/19 154/15 186/21
resulted [1] 147/11
results [1] 190/22
resume [2] 124/15
209/5
retain [4] 67/16 70/8
75/17 75/18
return [3] 70/21
70/22 70/24
returned [3] 75/23
101/14 132/19
returning [1] 70/17
revamped [1] 152/17
revamping [2]
195/20 196/9
revenue [3] 13/23
167/9 180/14
review [37] 18/4
18/19 18/20 18/23
21/4 26/8 26/17 26/18
26/23 27/22 27/24
48/13 48/17 97/14
97/18 114/14 116/3
117/18 117/19 123/18}
150/2 150/4 150/17
160/11 164/19 174/13
183/9 183/19 183/20
198/5 198/7 199/5
203/7 203/11 203/13
203/17 204/8
review/audit [1] 26/8
reviewed [8] 18/22
19/13 29/21 174/19
183/13 183/13 183/24
204/11
reviewer [1] 204/16
reviewing [3] 112/18
169/14 174/21
reviews [1] 97/20
revised [1] 120/21
rewriting [1] 84/24
rewritten [2] 86/2
91/1
Richard [15] 10/23
11/3 11/4 69/16 71/23}
73/25 94/24 97/4
101/10 103/23 108/6
109/25 129/2 129/25
130/5
Richards [1] 90/14
ridiculous [1] 106/2
right [48] 2/5 46/18
51/14 51/17 63/25
69/1 69/8 69/8 71/17
71/24 72/12 72/21
77/25 78/13 105/21
106/21 106/22 107/1
107/25 120/2 120/6
125/22 126/16 127/3
127/4 128/9 129/4
131/7 132/3 132/12
133/11 134/2 135/17
137/20 137/21 141/22}
142/9 170/8 170/10
180/15 181/12 191/8
192/24 200/24 201/5
203/25 208/23 209/5
rightly [3] 22/17
132/13 138/20
rights [2] 9/2 61/15
rising [1] 144/15
risk [57] 72/6 79/6
80/13 99/10 145/8
145/14 145/15 145/23
146/11 146/17 146/21
146/25 147/1 147/7
147/9 147/10 147/14
147/19 147/22 147/23}
147/25 148/5 148/8
148/9 148/11 148/12
151/8 151/21 152/22
154/19 156/4 157/4
158/20 176/9 176/10
176/11 176/14 176/17]
177/14 177/17 177/20
177/23 178/5 178/11
178/11 178/18 178/20}
179/1 181/17 190/8
193/5 193/8 193/9
193/25 195/18 197/15)
197/19
risks [29] 109/19
109/20 110/6 145/20
145/25 146/3 146/4
146/6 146/12 146/15
146/18 147/2 147/3
148/7 148/10 148/10
148/13 150/5 152/8
174/16 175/21 175/22
176/15 178/15 179/10}
179/12 179/14 179/18}
193/12
RMG [1] 196/4
RMG00000003 [1]
157/3
RMG00000083 [1]
152/20
Rob [8] 164/18
164/20 165/23 166/2
166/4 171/22 207/15
207/20
robust [5] 24/17
27/18 27/23 35/25
118/18
robustness [4] 18/11
26/5 28/21 204/24
Rod [3] 152/25 157/7
159/3
Rodric [3] 61/22
62/25 134/23
role [34] 3/8 3/9 3/10
3/16 5/3 5/6 5/14 8/16
11/12 14/22 15/8
22/19 46/10 50/24
52/4 55/8 69/24 72/18)
73/4 83/20 90/19
90/21 101/12 102/15
114/18 117/6 130/4
151/10 151/10 168/10}
174/18 206/2 207/20
208/3
roles [4] 10/13 12/21
122/3 144/20
rolling [1] 151/5
room [7] 123/3
123/12 134/21 135/4
136/8 136/20 142/7
root [3] 183/8 203/13
203/16
roots [1] 175/17
rotate [1] 170/3
roughly [2] 140/16
187/20
routinely [1] 30/10
Royal [83] 144/24
145/4 145/24 146/12
146/17 146/21 148/13)
148/22 149/4 151/1
152/8 152/16 152/21
157/3 158/20 159/24
160/6 161/16 161/21
162/1 163/8 164/8
165/3 165/7 165/24
165/25 166/1 166/3
166/7 166/9 166/13
166/17 166/20 167/7
168/4 168/11 168/24
169/10 169/15 170/14)
170/15 170/21 171/18)
171/19 171/20 172/5
172/22 173/18 173/22)
174/5 174/13 174/14
177/13 177/21 179/5
180/6 180/8 182/16
182/20 182/21 183/21
184/2 184/14 184/15
184/17 185/5 185/9
(80) remember... - Royal
R
Royal... [16] 185/21
190/3 190/7 190/8
195/19 200/5 201/8
201/9 201/11 202/3
205/17 205/25 206/8
206/19 206/22 208/10
rubbish [1] 58/18
ruin [1] 188/18
ruination [1] 193/2
ruined [3] 51/9
187/14 195/7
ruling [2] 115/22
116/13
rulings [2] 116/10
116/22
run [4] 8/10 39/18
41/10 103/1
run-up [3] 39/18
41/10 103/1
running [3] 16/16
145/8 145/14
rushed [2] 41/10
41/11
Ss
sack [1] 114/15
sacked [1] 128/2
sad [2] 53/16 54/17
Sadly [1] 63/5
safe [1] 84/13
safety [2] 119/20
167/12
said [51] 40/15 47/10
53/25 54/9 59/4 63/15)
65/17 68/23 69/17
75/17 75/18 76/2
77/12 97/10 100/9
100/24 109/10 109/18
110/1 114/19 115/2
118/5 121/19 125/3
128/22 130/6 130/17
134/7 134/14 134/20
135/10 135/11 139/23
148/4 149/9 158/4
158/15 159/8 161/4
177/2 178/25 183/12
193/4 194/5 194/22
194/25 195/17 196/7
200/12 202/12 203/12
salary [1] 76/7
same [16] 2/21 17/5
19/1 20/11 31/19
33/18 61/13 62/18
83/15 107/16 108/21
140/16 143/17 173/24}
208/1 208/7
SAS70 [2] 153/4
153/7
sat [1] 80/24
satisfied [1] 154/20
satisfy [4] 91/5 174/6
177/5 178/6
saved [1] 122/21
saw [13] 6/12 31/2
37/8 43/23 68/2 74/17
118/12 139/23 146/25)
186/23 186/23 195/2
203/23
say [98] 3/20 6/1 6/14)
8/6 9/12 10/5 11/9
16/6 20/23 25/6 25/16
26/3 26/15 30/10
31/25 32/2 32/13
34/24 35/3 36/7 37/17
38/22 43/4 54/12
54/16 54/19 56/13
58/18 67/19 73/24
80/3 89/4 93/2 95/24
96/11 96/12 100/7
107/3 108/18 109/25
111/13 115/13 120/9
125/22 127/10 128/1
130/21 131/5 131/9
136/15 137/8 137/21
138/9 139/22 140/25
143/8 143/18 145/19
147/15 147/22 148/11
152/7 154/9 159/2
159/7 159/9 159/19
163/6 164/6 164/16
166/11 166/13 174/3
174/11 175/5 176/12
178/10 179/8 179/9
181/10 183/6 184/16
186/4 186/17 186/19
186/23 188/24 188/25)
191/14 192/19 193/24}
194/14 197/3 198/11
199/17 203/14 203/14)
203/22
saying [27] 21/9 25/7
28/17 29/17 31/5
54/11 54/13 55/6
56/19 56/25 71/23
73/10 73/18 86/22
107/7 121/17 135/15
137/21 147/24 169/9
183/10 185/8 187/2
189/20 196/20 203/5
205/6
says [82] 17/23
18/19 22/21 23/5
23/19 25/10 26/20
27/10 27/20 29/11
29/14 33/2 40/7 42/15
49/7 49/13 50/12 53/3
61/3 62/17 62/19
62/24 63/4 65/3 65/5
65/11 67/9 71/10 72/6
74/14 76/4 78/11
78/15 83/10 83/16
85/16 90/13 94/23
95/12 98/4 98/9 99/6
99/24 102/1 104/20
111/10 111/23 112/13)
115/12 116/1 116/25
118/18 119/8 120/19
125/16 125/19 145/23
149/13 151/8 153/4
153/9 153/25 156/16
156/23 157/13 157/18}
160/17 160/22 165/4
169/4 169/20 170/7
170/8 170/9 170/10
173/12 180/24 187/7
207/23 208/2 208/8
208/12
scale [7] 50/16 68/16
147/13 147/15 148/8
155/17 156/7
scan [3] 30/13 31/7
204/5
scandal [3] 122/4
127/9 192/18
scanned [3] 42/20
43/16 138/10
scanning [1] 43/19
scenario [2] 137/7
137/12
schedule [1] 169/19
scheme [24] 73/11
73/17 73/20 81/5
83/22 85/10 88/8 89/2
89/23 92/2 92/4 94/11
98/18 104/24 109/20
110/18 111/13 111/25)
112/19 115/15 115/20}
115/23 116/24 128/13
scheme’ [1] 107/19
scope [7] 49/9 73/17
73/22 85/6 112/3
112/5 204/9
screams [1] 113/9
screen [10] 5/24 27/2
35/9 93/14 93/17
109/7 109/9 143/8
171/3 206/14
screens [1] 35/1
scroll [39] 13/13 14/2
14/13 21/21 21/25
26/14 27/9 28/1 28/4
29/10 32/25 32/25
39/14 45/10 49/12
50/11 62/6 62/16 63/3
64/14 65/2 71/9 79/24
83/15 90/13 93/21
94/8 110/12 110/23
111/20 112/9 112/13
116/25 117/13 158/25I
204/1 204/14 204/16
208/6
scrolling [2] 24/5
65/4
search [1] 79/20
seat [1] 39/25
second [93] 14/21
15/8 21/15 23/18
23/18 27/19 29/11
32/18 36/4 36/11
40/14 40/17 41/8
41/12 42/17 42/23
43/2 44/1 44/9 44/21
44/25 45/4 45/7 51/23)
54/2 54/4 59/25 61/24
72/18 72/22 73/2
74/18 83/5 83/13
83/18 84/1 84/3 84/7
84/8 84/10 84/15
84/20 84/23 85/6
85/21 87/1 87/4 88/1
89/10 89/11 89/25
89/25 90/12 91/4
92/24 93/21 94/9 98/2,
98/17 99/7 101/12
101/21 102/16 107/20}
109/5 110/6 110/13
110/24 111/25 112/3
112/8 112/15 112/17
113/12 114/15 114/18}
116/3 117/20 118/3
120/15 121/4 122/8
128/2 128/21 134/15
134/17 135/23 138/8
157/6 165/23 169/2
180/24 180/24
second-guessing [1]
51/23
secondly [3] 116/13
185/17 198/20
secretariat [1]
162/14
secretaries [5] 22/4
22/15 38/5 39/1 39/11
secretary [20] 2/13
2/22 11/23 11/25 22/5
22/16 37/23 48/8
56/24 69/25 70/1
76/16 82/24 105/7
132/16 133/9 133/12
139/21 157/23 163/12)
Secretary's [1] 31/1
section [4] 9/9 81/2
81/9 169/19
sector [1] 144/21
secure [1] 67/23
securing [2] 7/10
13/24
security [4] 15/19
165/10 167/7 167/13
see [106] 1/3 5/3
8/16 9/20 12/12 14/2
14/13 16/14 21/22
22/1 27/9 28/1 29/10
30/22 34/21 41/12
42/16 45/4 45/20
45/23 50/8 52/1 52/24)
57/13 57/14 61/21
61/21 65/2 68/25
71/11 72/10 73/13
74/20 77/21 78/18
81/3 85/13 86/20
98/16 101/20 102/11
104/15 105/12 106/9
107/4 110/11 110/23
4111/5 111/21 117/9
117/12 117/13 118/1
118/4 120/12 120/16
123/3 126/12 127/22
134/1 134/22 139/1
142/17 144/1 145/18
148/12 150/12 150/16)
150/18 152/18 152/21
155/8 157/3 157/6
157/24 158/14 158/21
158/23 158/25 160/11
162/25 165/3 165/10
165/12 168/18 169/1
169/19 170/1 171/3
171/13 171/18 171/22)
184/10 188/1 188/5
190/18 190/19 198/5
200/1 202/21 203/1
203/9 203/21 204/6
205/15 206/13
seeing [8] 34/25
58/17 65/18 65/19
148/15 148/21 178/25)
202/12
seek [5] 13/25 63/6
110/19 116/2 117/17
seeking [7] 49/14
72/8 104/9 111/9
111/10 112/8 133/5
seem [7] 54/14 55/23
102/5 107/20 124/5
154/14 193/17
seemed [12] 8/13
21/12 25/15 43/11
43/22 46/20 46/23
47/12 56/2 120/7
124/10 163/24
seems [5] 23/2 75/4
79/24 130/10 161/8
seen [39] 20/8 22/10
35/8 35/11 35/12 41/2)
41/20 47/6 56/5 57/11
63/6 64/23 67/8 75/4
75/9 77/23 87/19 95/4I
107/16 109/10 118/6
118/17 119/7 124/4
125/12 129/21 136/14}
138/21 158/18 158/18
190/13 199/3 202/15
204/3 205/2 205/8
205/9 205/13 206/25
segment [1] 174/8
segregation [1]
149/24
Select [5] 5/8 121/11
128/15 128/17 128/24)
self [1] 35/4
self-service [1] 35/4
send [9] 30/18 34/8
60/17 61/4 62/4 65/6
77/12 104/21 187/21
sending [3] 105/11
105/24 187/24
senior [10] 11/15
(81) Royal... - senior
Ss
senior... [9] 11/22
12/2 30/25 76/1
100/10 129/7 168/13
175/6 178/21
sense [9] 8/3 8/13
9/13 32/2 32/12 58/24)
73/12 92/13 132/25
sensible [3] 32/23
123/9 123/13
sent [21] 21/25 27/6
30/4 30/6 40/19 56/5
74/18 75/8 78/9 85/13,
102/21 106/6 108/10
111/18 111/19 119/7
120/23 159/19 165/10
187/20 200/23
sentence [13] 33/10
40/16 51/4 52/1 68/1
72/3 72/11 91/7 91/23
117/15 117/21 143/8
207/23
sentenced [1] 165/14)
sentences [1] 30/19
separate [4] 8/19
124/2 169/4 184/5
separated [1] 162/3
separately [1] 16/7
separating [1] 160/5
separation [33]
51/12 143/9 143/12
143/13 143/20 143/22)
161/22 161/24 162/12)
163/8 163/20 168/24
169/3 169/10 169/11
169/21 169/23 172/21
180/3 183/25 184/11
184/19 185/19 191/19
192/15 194/6 194/14
195/15 199/8 201/9
202/1 206/20 208/9
September [8] 2/16
13/7 13/7 37/10 56/20)
64/13 72/25 172/18
sequence [1] 207/5
series [1] 150/14
serious [6] 6/8 16/13
36/22 38/21 38/22
48/20
seriously [3] 36/24
108/2 114/7
servant [7] 12/19
14/7 20/3 31/1 73/2
73/23 138/4
servants [14] 46/12
74/2 74/4 82/13 89/5
89/7 100/14 113/25
114/7 122/3 129/20
130/8 131/16 141/17
served [1] 144/17
server [1] 151/11
service [16] 9/19
12/3 16/22 17/13
17/17 32/4 33/11 34/5)
35/4 131/9 131/14
144/14 162/4 170/11
175/7 204/18
services [18] 4/18
7/14 81/6 143/14
150/6 165/4 168/24
169/6 169/8 169/10
169/12 169/15 169/20)
169/21 169/22 170/2
170/14 170/16
session [1] 95/1
sessions [3] 24/9
71/6 71/16
set [18] 11/10 12/16
13/18 13/20 37/7
44/22 727 88/23
102/17 117/1 118/25
122/6 141/21 179/11
191/18 192/24 198/24)
199/13
setback [1] 192/15
sets [7] 13/13 29/9
62/6 83/21 87/20
169/5 169/20
setting [2] 42/16
104/21
settled [3] 24/13
87/21 88/3
severe [1] 95/18
Sewell [5] 60/2
134/20 152/25 157/7
159/11
shall [6] 77/17 87/23
93/1 124/15 159/14
169/6
share [2] 98/6 99/1
shared [1] 51/2
shareholder [17]
5/18 10/9 10/11 12/8
12/9 21/22 42/13
46/13 47/14 66/22
67/5 90/9 121/23
128/8 129/7 130/25
146/25
shares [2] 174/7
174/19
she [68] 22/16 22/19
22/24 31/3 47/24 54/9)
54/10 54/13 54/15
58/9 58/9 60/21 60/24
61/3 61/5 62/18 65/8
67/16 68/6 68/8 80/25
82/4 82/5 82/7 82/10
85/18 85/20 86/4 86/4
95/6 95/13 98/15
110/14 110/16 111/12)
111/12 119/7 119/8
119/10 119/12 119/17)
119/19 119/21 120/3
120/4 120/19 125/8
125/19 125/21 125/25)
125/25 126/1 126/5
126/9 126/14 126/15
126/16 126/20 126/21
126/22 132/7 183/6
183/12 183/16 183/18
187/1 189/2 201/20
She'd [2] 85/25 86/3
sheet [1] 37/25
ShEx [27] 8/16 8/18
8/25 9/7 9/10 9/22
10/1 10/6 10/12 11/22}
12/1 12/2 14/11 30/1
37/23 60/9 61/22
62/24 64/6 78/12
78/22 90/22 91/21
110/14 131/8 132/22
136/11
shied [1] 192/14
shocked [3] 70/3
76/11 190/5
shocking [4] 63/18
68/25 78/6 130/11
Shoosmiths [1]
155/11
short [12] 19/23
22/25 42/16 52/22
77/9 93/6 124/20
162/23 171/3 171/11
207/10 207/12
shortages [1] 29/6
shortages’ [1] 23/24
shortfalls [1] 140/21
shortly [7] 37/1 57/8
82/22 144/9 155/7
168/4 200/23
should [57] 1/13
17/12 17/21 18/10
26/23 28/19 29/18
31/6 31/6 32/9 40/13
52/6 59/7 64/2 70/2
70/15 70/16 73/5
76/14 78/16 88/4
88/12 89/6 98/15
100/14 101/14 101/15}
101/18 102/2 102/23
103/6 103/8 108/11
109/4 110/11 111/15
114/1 114/7 117/24
120/20 121/24 122/7
126/1 128/23 135/18
135/22 138/4 143/3
143/21 147/3 147/9
166/4 168/7 168/9
172/16 188/16 198/1
shouldn't [2] 64/3
110/1
show [6] 88/14 89/3
94/5 110/2 114/24
206/6
showed [1] 58/15
showing [3] 88/10
110/1 110/3
shown [6] 19/15 53/4
68/6 109/8 125/6
125/9
shows [1] 170/12
shy [4] 140/5 192/12
193/21 194/25
sic [2] 17/18 62/13
side [3] 67/10 84/2
205/19
sifting [1] 148/7
Sight [58] 21/15
27/19 32/18 36/11
40/14 40/17 41/8
41/12 42/18 42/23
43/2 44/1 44/9 44/21
44/25 45/4 45/7 61/24
72/18 72/23 83/13
83/18 84/2 84/4 84/9
84/10 84/15 84/20
84/24 85/6 85/22
89/25 90/12 98/17
99/7 101/13 102/16
107/20 109/6 110/6
110/24 112/1 112/3
112/8 112/15 113/12
114/16 114/18 116/4
117/20 121/4 122/8
128/2 128/22 134/15
134/17 135/23 138/8
Sight's [9] 36/4 73/2
83/5 87/1 87/4 91/4
101/22 112/17 120/15}
sighted [1] 86/12
sighting [1] 111/12
sign [9] 20/5 20/24
30/13 31/8 31/11
33/12 108/6 121/14
184/3
sign-off [1] 108/6
signature [5] 1/20
1/21 143/5 144/1
144/3
signed [7] 19/3 19/13
22/23 89/21 143/9
143/12 206/13
significance [2]
35/19 135/21
significant [19] 6/24
10/14 11/8 15/20 66/5)
81/15 83/22 111/16
111/16 121/9 123/2
145/25 146/3 146/5
146/11 147/22 147/25
183/12 193/12
significantly [2] 81/6
185/22
signing [1] 143/20
similar [7] 9/1 37/8
54/21 141/23 157/17
181/19 204/1
similarly [1] 84/25
Simon [3] 125/7
126/5 126/17
simple [1] 89/1
simpler [1] 88/19
simply [3] 140/20
157/21 200/19
since [7] 23/20 24/22
28/22 43/8 65/8 71/2
7412
single [4] 20/19
162/12 199/15 200/3
sink [1] 35/19
sir [57] 1/3 52/16
52/24 87/2 90/10
91/18 91/24 92/11
92/18 92/23 93/8
93/19 93/21 101/3
102/24 105/23 108/12)
108/18 121/14 122/7
123/1 123/7 123/12
123/22 124/22 131/22)
133/16 142/6 142/17
142/19 158/16 162/17
162/25 170/24 171/2
171/8 171/13 173/8
180/11 180/17 180/21
181/10 190/25 191/5
191/7 191/12 191/21
200/11 200/19 206/15]
206/18 207/3 207/6
207/8 209/4 209/7
210/10
Sir Alan [5] 102/24
105/23 108/12 121/14I
122/7
Sir Anthony [8] 87/2
90/10 91/18 91/24
92/11 92/18 101/3
108/18
Sir Donald [2] 158/16
191/21
Sir Wyn [1] 123/22
sit [3] 16/5 96/23
119/17
sites [2] 165/8 167/8
sits [1] 201/5
sitting [4] 40/1 40/2
120/3 120/5
situation [13] 12/18
17/8 17/9 32/21 53/16)
60/19 70/12 80/11
103/12 177/22 190/21
194/16 195/4
situation’ [1] 53/9
situations [1] 195/5
six [6] 4/23 10/21
60/7 74/11 196/3
197/12
Six months [1] 74/11
size [2] 6/21 38/11
Skills [1] 3/8
skillset [1] 106/20
skip [1] 78/15
slavishly [1] 189/6
slick [1] 120/7
slide [1] 69/11
slight [1] 191/3
slightly [16] 3/23
8/19 9/9 9/13 33/6
36/15 37/3 37/15
37/16 100/1 106/12
(82) senior... - slightly
s
slightly... [5] 152/2
156/10 157/5 178/4
190/12
slow [2] 34/16 77/9
slower [2] 3/24 72/7
slowly [1] 201/25
small [12] 23/21
26/17 29/2 31/21
39/24 48/18 56/1 56/2
60/5 60/6 193/22
194/8
smaller [1] 142/1
smallish [1] 55/22
Smith [3] 164/15
164/17 196/5
smoothly [1] 44/14
SNP [4] 7/4
so [281]
software [3] 151/5
181/3 200/2
software’ [1] 44/12
solely [2] 126/6
132/10
solution [3] 130/21
130/23 131/2
solver [1] 186/25
some [98] 2/24 6/17
10/7 15/12 15/24
22/17 24/19 27/24
29/4 33/16 35/1 35/15)
35/24 35/24 38/10
39/20 45/2 46/25 47/2
49/16 50/2 50/19
50/21 53/16 54/15
54/25 55/7 55/24
59/16 64/8 66/2 70/20
71/1 71/5 71/11 74/25
75/6 76/3 77/10 77/14,
79/1 80/12 83/23 85/3,
87/20 88/7 88/19 89/2
89/24 92/8 95/6 98/13,
100/4 100/11 101/5
102/18 103/4 105/22
107/3 108/24 110/11
110/12 111/21 120/6
129/11 129/15 132/5
133/18 135/24 137/18
140/6 140/7 140/19
140/20 140/24 141/7
141/9 144/10 146/24
147/2 148/16 150/7
151/13 155/15 158/3
158/5 163/10 164/2
168/20 170/4 173/1
173/2 175/5 175/10
175/11 179/22 200/22)
201/3
somebody [15] 21/23}
29/25 32/10 40/1
40/17 82/11 87/9
87/10 92/19 120/5
132/25 136/15 137/12)
137/20 139/7
somehow [2] 183/22
196/23
someone [3] 81/1
166/12 173/22
something [50] 7/24
10/2 10/13 19/18 21/5)
25/15 31/11 31/13
32/9 33/24 34/22
35/17 47/21 50/4 51/9)
53/15 53/18 63/12
63/14 64/4 64/9 68/24
69/5 69/9 70/1 73/5
74/24 76/13 80/5
81/25 92/7 105/8
109/15 109/21 115/3
121/6 132/15 136/2
142/3 147/3 181/19
182/1 184/10 187/4
190/13 192/12 192/23}
195/15 200/16 200/19)
sometimes [6] 9/12
10/3 13/1 38/11 69/4
105/10
somewhat [1] 108/20
somewhere [2] 6/18
11/3
soon [2] 62/5 62/21
sooner [1] 74/20
sorry [26] 17/20
17/21 23/13 33/1
65/19 66/15 89/11
93/14 108/13 122/24
133/20 133/20 136/18)
140/3 153/3 157/11
158/1 165/8 165/21
170/24 179/19 180/16)
189/17 193/8 205/4
207/3
sort [16] 11/21 54/11
56/19 72/11 74/25
78/1 102/14 102/18
113/9 140/24 140/25
146/18 158/1 171/9
183/18 194/16
sorted [1] 106/1
sorts [1] 76/23
sought [2] 111/15
124/12
sounded [1] 97/20
sparked [1] 27/24
Sparrow [12] 71/17
71/24 71/25 72/14
72/15 72/17 73/8
88/11 101/11 125/17
129/5 129/22
speak [5] 3/23 40/13
63/13 92/10 134/16
speaker [1] 59/7
speaking [9] 34/16
46/19 60/22 63/23
74/23 75/6 96/8
157/21 164/14
speaks [2] 127/2
187/5
Special [1] 166/15
specialised [2]
163/18 175/8
specific [27] 8/23
11/16 12/16 14/19
16/25 18/20 26/12
32/13 32/19 53/10
53/24 56/3 80/21
88/13 103/11 103/12
112/19 118/17 125/15}
128/10 129/18 130/4
150/10 150/13 154/11
203/6 204/15
Specifically [9] 11/17
25/17 32/1 32/14
56/14 88/16 97/18
158/13 167/17
specifics [1] 15/21
speculates [1] 114/1
speech [5] 32/5 95/1
98/6 98/14 99/2
speed [5] 11/1 14/23
19/24 67/21 75/25
spend [3] 3/18 31/14
76/8
spent [10] 3/19 3/21
4/5 6/15 30/24 81/13
107/20 108/22 144/13
185/3
spheres [1] 5/22
spirit [1] 46/21
spirited [1] 130/38
SPM [1] 85/4
spoke [3] 40/10 62/3
134/6
spoken [5] 53/7
134/15 134/15 156/20}
160/9
sponsor [1] 152/23
sponsors [1] 157/8
spreadsheets [1]
106/19
spun [1] 196/24
square [2] 47/13
119/6
stabilising [1] 7/10
stack [3] 19/10 30/11
65/25
staff [8] 24/4 55/14
67/16 85/5 155/20
157/16 164/11 204/22
staff’ [1] 44/15
staff/family [1] 24/4
stage [19] 4/12 22/16
32/15 35/15 35/20
35/23 42/23 43/13
43/15 44/16 47/1
48/22 49/19 61/7
69/17 89/15 99/3
108/9 111/11
staggered [1] 47/7
stakeholders [3]
68/14 68/16 68/19
stand [2] 61/11
186/11
standard [3] 30/16
33/15 33/19
standing [1] 51/22
stands [1] 144/8
staring [1] 198/8
start [14] 13/6 17/20
43/25 48/4 71/11
85/14 86/15 93/10
98/1 106/19 120/11
144/13 148/18 195/21
started [10] 8/22
10/10 13/6 14/16
14/20 17/10 121/2
148/4 175/17 179/12
starting [2] 71/1
147/6
starts [4] 28/17 88/2
150/20 188/2
state [13] 1/10 2/22
69/25 70/1 82/25
110/17 129/9 132/17
133/10 133/12 142/23}
168/14 196/14
state's [1] 141/17
statement [77] 1/14
1/22 1/24 1/25 5/24
11/11 16/11 36/5 36/7}
39/18 39/22 41/10
41/24 43/18 46/6 47/7)
48/12 48/25 51/11
52/12 53/2 56/6 59/2
59/12 59/24 60/14
61/5 61/25 65/17
68/23 73/25 109/6
109/10 109/12 109/18
109/25 111/23 113/8
113/11 115/3 115/6
115/8 115/9 122/6
123/17 127/10 130/18}
134/17 135/25 139/18
142/11 143/1 143/7
144/1 144/5 145/17
152/8 159/2 159/4
159/20 163/5 174/2
181/9 181/18 183/2
192/14 194/4 197/2
202/8 202/11 203/22
207/16 207/23 208/7
208/12 208/18 209/1
static [1] 4/7
statistics [1] 56/3
stay [2] 142/7 171/5
staying [1] 171/2
stealing [3] 166/14
166/15 173/22
stenographer [2]
3/23 77/6
Stephen [1] 65/3
steps [9] 42/18 45/3
79/21 103/4 104/1
110/20 110/22 147/17}
179/5
STEVENS [17]
142/22 148/3 152/12
155/24 172/13 176/12)
179/25 180/16 196/17
196/21 197/7 201/7
206/8 207/19 208/23
209/6 210/18
stick [1] 48/1
still [9] 14/22 25/25
46/1 50/9 62/18 91/10
101/21 106/6 147/25
Stock [1] 174/9
stood [2] 51/10 95/22
stop [9] 15/25 98/22
125/22 138/6 169/22
192/10 195/9 199/1
200/15
stopped [1] 188/16
stopping [1] 170/14
store [1] 92/18
Storey [2] 10/9 10/16
storm [2] 193/24
194/17
story [4] 57/21 86/9
106/17 161/12
straightforward [2]
54/5 78/8
strand [1] 175/4
strands [1] 156/16
strange [1] 70/12
strategic [9] 6/17
6/20 8/12 68/5 68/17
69/2 69/6 69/8 69/9
strategically [3] 6/9
7/11 16/13
strategies [1] 180/13
strategy [3] 67/13
68/4 80/22
streamlined [1]
153/20
Street [2] 164/9
165/5
strengthen [4] 150/1
150/2 198/5 198/7
stress [3] 83/11 88/5
196/9
stressful [1] 30/20
strike [4] 46/4 46/9
47/1 112/21
strong [9] 50/1 68/15
91/20 95/21 107/1
133/1 138/17 191/13
191/22
strongly [6] 50/23
51/4 51/10 52/9 52/11
128/4
struck [1] 7/2
structural [2] 10/7
10/14
structurally [1] 8/15
structure [1] 169/3
structured [1] 11/9
stuck [1] 51/5
stuff [1] 43/8
(83) slightly... - stuff
Ss
stuns [1] 69/14
subcommittee [2]
104/12 129/22
subcontractor [1]
84/17
subject [9] 32/15
105/1 115/21 116/9
123/9 123/10 136/22
138/25 182/5
submission [16] 27/2!
28/9 56/17 66/4 70/7
75/16 77/11 82/23
95/1 110/9 110/10
110/13 111/12 112/23}
114/10 114/22
submissions [8] 9/20)
19/6 20/2 30/12 42/10
86/17 119/16 137/6
subpostmaster [14]
25/23 28/19 56/10
65/7 65/16 84/11
84/17 88/21 158/10
158/11 167/4 168/21
173/23 204/3
subpostmasters [70]
14/15 14/19 16/14
18/6 18/16 21/17
23/22 24/19 24/22
25/1 25/8 26/1 26/7
26/10 27/14 29/1
29/12 29/15 35/13
44/14 45/8 45/24
48/18 49/11 50/2
50/19 51/1 53/17 55/7,
55/13 56/7 62/8 62/10)
65/1 84/5 85/2 93/24
94/1 94/3 94/6 107/2
112/4 121/11 122/21
127/8 134/1 139/16
140/23 141/14 148/14
155/19 155/23 156/12)
157/15 166/22 167/18)
167/22 168/2 168/7
172/10 173/4 177/15
178/7 179/1 179/6
180/5 194/9 201/3
201/23 204/22
subpostmasters' [1]
29/3
subsequent [3]
72/22 87/18 119/15
subsequently [6]
2/10 29/4 48/19
109/12 110/8 116/16
subsidiaries [6]
145/15 145/19 148/13}
178/13 179/10 179/14}
subsidiary [4] 145/20)
147/3 147/10 148/2
substantial [2] 24/15
83/24
substantive [1]
183/25
success [1] 193/22
successful [1] 118/7
successor [1] 80/14
such [11] 6/21 7/15
45/15 66/13 74/24
84/23 145/20 149/3
160/10 174/19 182/5
sudden [1] 21/4
sufficient [3] 38/18
131/3 131/6
sufficiently [4] 84/15
146/1 146/4 147/23
suggest [9] 26/1
29/18 51/1 87/7 91/2
105/8 124/4 125/6
185/25
suggested [11]
42/19 45/10 45/11
47/4 48/10 103/5
121/25 154/4 176/11
183/7 206/24
suggesting [2]
183/19 203/17
suggestion [3] 40/13
50/23 76/11
suggestions [1]
131/3
suggests [1] 49/15
suicide [1] 65/15
sum [1] 127/16
summarise [2] 23/3
79/10
summarised [2]
133/7 149/20
summarising [1]
22/25
summary [7] 27/9
43/21 43/24 43/25
61/4 149/13 198/3
summer [2] 15/1
119/13
sums [1] 76/19
superior [1] 9/13
supermarkets [1]
35/5
supplemented [1]
157/20
suppliers [2] 149/19
182/19
support [11] 9/4 14/1
27/22 49/10 53/22
57/18 70/20 84/14
94/16 116/17 160/16
supported [2] 27/17
84/3
supporting [3] 57/19
112/11 151/12
supportive [3] 53/8
1314/3 187/2
supportively [1]
156/20
suppose [4] 67/1
138/1 166/4 170/18
supposed [1] 56/22
sure [30] 7/14 7/20
23/12 35/6 35/7 39/6
49/21 54/23 58/11
60/1 60/13 60/14
60/21 60/24 67/22
90/6 91/13 103/20
122/18 134/24 138/2
147/18 152/12 162/5
167/16 170/22 177/21
191/8 195/24 206/23
surely [1] 193/11
surface [2] 193/5
193/25
surfaced [1] 193/8
surprise [1] 68/2
surprised [2] 175/5
175/11
surprising [2] 38/17
99/1
Susan [5] 62/16
62/25 64/16 125/7
134/25
Susannah [2] 10/9
10/16
suspect [2] 99/25
122/15
sustainability [2]
6/22 7/13
sustainable [1] 7/15
Swinson [22] 1/6 1/8
1/12 1/13 22/2 22/10
50/13 53/1 53/7 58/7
64/19 65/6 67/15
123/16 125/1 131/23
133/25 134/4 139/11
139/15 142/10 210/2
Swinson's [3] 61/4
62/1 70/21
swinsonmpstcorresp}
ondence [1] 64/17
sworn [2] 142/21
210/16
system [67] 16/4
18/7 18/12 24/7 24/10
24/17 24/24 25/2 26/9
27/15 27/18 27/23
28/4 28/21 28/22 44/9
44/11 44/13 44/17
45/19 48/14 49/9
50/11 50/17 83/9
83/14 83/24 85/8 88/6
107/14 110/19 111/1
115/18 120/25 136/1
150/21 151/6 151/9
151/10 151/19 153/18}
160/11 170/25 177/4
178/2 178/12 181/3
181/7 182/1 182/2
182/7 182/11 182/12
182/13 182/24 183/9
183/13 183/15 186/7
188/15 189/4 193/25
197/19 204/19 204/25}
205/5 205/6
system’ [1] 99/18
system-wide [1]
44/17
systematic [1] 24/23
systemic [9] 24/1
43/9 44/11 45/19 49/8)
50/10 83/13 88/9
111/1
systems [9] 45/1
153/13 153/20 154/3
154/16 196/10 198/17]
198/18 200/3
T
table [6] 104/25
105/8 109/8 109/11
119/3 150/16
tabled [1] 118/13
tables [1] 40/1
tabling [1] 48/11
take [41] 5/23 21/1
33/12 36/5 38/4 42/20)
43/7 45/11 45/11 47/4)
48/5 48/5 52/16 57/4
57/8 63/2 64/12 78/13
92/23 94/21 103/19
117/7 119/22 123/13
123/16 140/7 150/14
159/14 161/24 162/17
170/5 170/24 191/2
194/4 198/11 200/6
201/1 201/25 204/5
207/9 207/22
takeaway [1] 43/19
taken [13] 4/15 29/4
31/4 57/22 88/7 90/24
95/9 103/14 124/14
163/8 172/17 177/8
200/7
takes [1] 80/6
taking [17] 13/5
30/21 32/4 35/17
36/24 53/14 67/4
70/24 79/18 84/2
108/2 109/2 114/7
147/18 162/10 183/9
188/21
takings [1] 181/4
talk [6] 26/13 69/1
79/8 110/5 128/4
199/23
talked [1] 202/5
talking [8] 56/16
69/12 69/13 72/17
117/24 145/19 150/17,
166/12
talks [4] 113/13
153/24 155/8 160/13
tall [1] 186/11
tally [1] 43/22
tangentially [1] 167/5I
tasked [1] 84/23
tasks [2] 163/21
184/15
team [53] 8/24 9/1
9/25 10/11 11/14
11/16 14/11 17/15
17/16 17/17 21/24
30/1 30/5 32/2 37/23
38/17 60/9 66/22
80/24 97/6 108/7
110/15 123/5 162/1
165/11 166/6 166/8
166/10 166/17 166/20)
166/24 167/1 168/5
168/11 168/13 170/19)
170/19 171/23 173/16)
173/17 174/17 176/25)
177/4 184/14 184/17
185/5 185/10 185/11
190/7 191/22 201/11
206/11 207/25
teams [5] 9/3 52/8
184/2 184/20 205/17
technical [3] 83/13
134/5 135/20
technology [8] 152/7
152/9 152/15 162/13
192/8 195/18 195/19
196/14
telephone [6] 40/4
48/9 53/12 54/1 55/2
60/22
tell [15] 29/25 80/8
97/12 114/15 114/17
119/13 125/25 131/1
141/20 161/3 171/6
174/22 181/1 187/10
187/16
telling [8] 79/22 82/4
1413/7 119/4 128/13
129/23 130/1 198/14
ten [4] 114/19 123/6
123/8 204/20
tenable [1] 189/7
tens [1] 55/14
tenure [3] 30/15
35/20 102/13
term [2] 7/21 7/23
terminal [2] 35/1
35/8
terminated [8] 23/23
25/24 27/16 29/3
48/19 62/9 113/17
117/20
termination [2] 109/5
169/7
terminology [1] 8/5
terms [33] 4/12 5/2
5/19 6/20 8/5 10/18
11/17 12/8 12/9 12/17)
12/22 20/18 21/8
32/13 32/14 49/23
60/12 64/11 66/19
73/12 76/20 79/19
82/17 90/6 102/20
103/15 112/17 113/20}
(84) stuns - terms
T
terms... [5] 128/14
132/25 141/22 155/2
169/5
terrible [3] 187/9
187/13 194/16
territory [1] 51/22
test [1] 200/2
tested [4] 154/16
154/17 183/23 198/17)
testing [2] 154/1
196/9
text [3] 33/16 186/1
187/20
than [35] 3/9 6/19
18/16 24/2 28/25
30/22 33/8 39/7 50/15)
54/7 58/8 66/5 66/16
71/14 72/7 73/6 74/20
76/7 81/1 81/7 85/7
94/1 96/25 100/7
102/5 106/1 107/20
109/2 109/15 117/2
129/19 177/23 179/20}
193/1 196/25
thank [86] 1/4 1/5
1/10 1/13 1/25 3/22
4/1 5/2 7/23 10/7 13/4
14/13 17/25 22/21
27/9 33/1 34/14 34/17
36/3 39/14 41/8 49/7
52/15 52/24 64/22
66/18 66/18 74/10
89/8 90/8 92/22 93/2
93/4 93/8 93/10 94/22
97/25 100/22 110/9
114/23 117/13 121/25}
123/1 124/13 124/22
127/3 127/4 127/25
128/25 131/19 131/21
133/16 139/11 139/13
139/17 142/6 142/10
142/14 142/15 142/18)
142/19 142/25 143/1
143/24 145/18 162/21
163/2 164/14 171/8
174/1 180/15 180/17
183/1 186/6 196/13
200/10 201/16 204/4
207/2 207/5 207/6
207/7 208/22 209/3
209/4 209/7
thanking [1] 89/18
thanks [4] 74/16
85/19 133/14 142/5
that [1433]
that I [2] 43/1 52/14
that's [75] 2/5 15/25
18/2 19/1 22/3 22/24
23/14 25/21 27/3
33/19 45/22 46/16
48/1 48/3 51/5 54/19
57/1 58/18 61/1 61/2
61/23 62/22 71/20
72/10 72/11 73/4
77/25 79/15 85/24
87/25 89/9 89/12
94/22 95/3 95/8 96/16
96/19 98/5 105/16
114/21 121/5 124/18
127/19 128/25 130/11
130/15 131/17 133/13}
133/14 133/22 136/18)
137/6 142/9 143/16
143/23 145/1 145/23
152/7 155/4 157/1
162/17 171/5 177/24
178/4 178/19 183/22
185/7 190/1 199/10
200/16 203/6 203/17
206/24 207/4 208/24
theft [8] 23/25 24/2
48/20 56/8 62/11
99/15 99/18 165/13
their [62] 12/11 13/18)
18/7 22/7 23/22 24/3
26/25 27/16 27/22
28/16 29/16 32/7
36/21 37/22 44/15
45/6 47/10 49/5 51/15)
52/8 53/17 55/5 55/14)
62/8 63/2 63/24 73/4
75/9 75/20 83/20
83/25 85/5 96/18
100/11 102/8 102/10
103/7 103/11 105/25
106/16 112/1 112/18
113/13 113/16 113/19}
113/21 119/9 122/3
122/11 122/19 129/25)
130/9 141/9 154/13
176/24 177/3 185/3
188/17 188/19 200/2
201/4 204/22
them [41] 8/20 20/4
32/23 34/1 36/2 37/1
39/8 40/6 40/24 51/17
54/15 56/19 57/19
58/4 60/10 73/16 78/1
79/18 89/3 89/18
89/20 97/16 103/8
103/15 113/22 114/16)
115/24 116/22 116/23)
128/11 130/1 137/23
141/14 142/4 158/3
163/22 165/9 173/1
173/2 188/18 199/2
thematic [8] 83/5
84/7 88/13 90/12
90/24 91/1 91/4 175/4
theme [1] 143/17
themselves [12] 5/9
9/11 13/2 24/3 33/9
73/19 94/7 100/15
138/25 198/14 198/15)
198/17
then [123] 2/6 2/9
4/16 5/11 5/18 10/12
10/21 11/14 11/22
12/4 15/7 19/9 19/16
22/5 22/19 25/11
26/13 26/20 27/1
27/19 29/9 30/4 30/6
30/21 31/4 32/7 34/6
34/7 34/8 37/23 38/1
38/2 39/8 39/12 41/20
41/21 42/2 44/23
45/10 47/16 48/5 49/7
50/6 50/11 52/6 55/20
58/5 62/6 62/23 64/5
64/11 65/10 71/5 73/6
73/20 75/13 75/23
76/3 77/10 79/22 81/9
81/10 82/14 83/2 83/3
88/24 89/8 90/3 91/7
92/2 96/6 96/25 97/24
101/17 102/16 104/11
110/21 113/6 113/24
114/13 117/12 119/18
121/19 123/10 125/22
126/12 127/24 128/13
132/19 132/22 133/11
135/21 137/22 140/9
142/1 144/17 156/22
158/11 159/14 160/20
161/1 168/17 170/1
170/7 170/8 170/9
170/10 171/19 173/10}
176/8 176/11 178/1
188/1 188/5 188/17
188/24 189/14 192/13
192/19 197/21 204/13}
208/1 208/6
there [286]
there's [29] 26/15
27/10 33/14 39/14
50/6 50/8 51/3 62/23
64/14 69/17 71/9 81/2
81/9 94/9 110/21
110/23 114/23 118/21
118/22 122/5 127/13
143/6 169/2 176/17
180/22 182/10 186/19}
188/1 189/18
thereafter [3] 143/15
183/3 200/23
therefore [16] 7/9
15/13 25/14 32/9
37/16 42/6 43/11 69/9
87/6 92/6 95/22 100/4
112/11 114/5 125/20
129/25
thereof [1] 119/20
these [48] 7/17 9/3
11/7 15/7 32/19 40/4
44/6 47/15 50/22
53/12 54/12 54/13
54/14 55/7 56/21 57/1
61/16 63/24 79/22
82/19 84/14 86/11
88/5 96/22 98/23
107/21 111/2 111/6
115/17 116/11 118/21
119/1 140/1 145/21
148/10 154/25 156/18
163/24 164/1 169/22
174/5 185/18 185/24
186/1 190/8 194/23
202/20 206/9
they [139] 8/19 8/19
9/11 9/13 9/22 11/18
12/14 12/23 12/25
16/18 24/24 30/4
34/11 36/22 36/23
36/24 38/22 38/23
39/3 39/4 39/8 40/13
40/23 41/5 44/7 44/10)
46/25 49/5 58/1 63/5
73/7 73/9 73/10 73/11
73/18 73/19 73/20
74/5 74/5 74/5 74/6
TAIT 75/21 76/15
76/20 77/25 78/7 78/8)
78/9 78/10 79/16
79/22 82/10 82/15
82/15 82/17 83/19
84/1 84/4 88/9 88/12
88/23 89/3 90/5 96/18
97/24 99/8 99/14
99/16 100/12 100/16
100/16 100/17 105/11
105/12 106/22 106/24,
107/1 111/15 113/14
114/9 114/15 114/15
114/16 114/19 114/20}
119/4 119/5 119/11
121/19 122/19 123/24}
124/12 127/20 128/22}
130/1 130/8 130/8
135/18 140/6 140/7
140/15 141/1 142/3
147/1 147/2 153/13
154/2 154/3 154/12
154/16 154/16 154/17I
154/18 154/20 163/17}
163/21 164/3 169/3
174/12 176/23 177/3
177/21 178/17 180/9
181/5 185/3 185/25
187/18 198/14 198/16
198/17 198/21 198/22}
199/23 199/23 199/25}
200/1 200/2
they'd [3] 76/3
114/17 122/18
they'll [1] 63/7
they're [6] 12/10
12/18 33/7 100/18
203/4 203/11
they've [2] 34/12
34/13
thick [2] 174/21
206/9
thing [20] 6/14 25/21
35/2 46/18 51/8 51/15
51/17 66/14 80/5
86/21 87/16 100/14
135/11 177/16 178/19)
186/17 187/13 189/18
196/16 204/15
things [28] 8/8 14/25
15/3 38/15 41/19
41/22 46/25 56/13
56/21 57/1 81/7 104/4
106/25 122/5 129/23
130/6 130/20 133/2
140/6 154/25 157/25
158/2 162/15 177/5
177/6 187/24 189/22
193/2
think [223]
thinking [8] 35/5 45/6
55/8 73/4 100/2
140/11 141/11 167/1
thinks [4] 203/5
third [4] 50/9 138/24
149/19 204/8
this [386]
Thompson [3]
110/14 120/19 129/12)
Thomson [2] 139/20
141/19
thorough [2] 97/21
176/20
those [102] 3/3 3/6
3/13 4/14 4/17 4/23
7/13 10/12 12/21
12/23 13/3 13/18
14/16 15/8 16/3 16/15}
19/12 26/1 33/17
35/11 35/25 38/5
39/19 40/25 41/22
45/9 45/16 47/4 47/5
49/24 50/4 51/4 51/8
55/22 61/9 62/12 71/7I
71/15 71/18 79/21
86/15 88/3 88/20
88/23 88/24 89/10
92/21 93/21 94/9 95/9I
96/11 96/12 97/2
97/22 98/13 98/15
102/5 102/5 102/7
102/12 107/3 107/3
113/6 115/21 116/9
119/18 122/10 129/6
129/13 129/13 129/16)
129/24 132/5 132/18
137/15 138/13 138/14I
141/4 142/6 146/18
146/22 147/1 156/25
161/2 163/18 166/18
169/12 176/21 177/5
177/16 177/8 183/4
184/5 184/6 184/15
187/4 190/9 190/25
192/11 193/19 193/20)
200/8
though [9] 23/2 45/4
50/7 116/12 142/2
(85) terms... - though
T
though... [4] 150/9
178/15 193/11 199/3
thought [28] 19/17
55/25 71/12 74/19
76/13 87/7 91/17
96/19 102/2 107/8
114/4 126/10 140/20
161/25 166/23 176/14}
180/9 182/8 184/12
184/14 184/16 184/18)
185/10 185/18 186/17
187/17 197/5 206/11
thoughtful [1] 74/5
thoughts [2] 74/25
75/6
thousands [6] 55/14
76/8 77/2 94/2 182/19
182/19
threatened [3]
156/22 192/1 194/8
three [10] 3/19 4/3
32/10 59/16 79/18
138/11 146/18 157/8
203/3 204/17
through [39] 4/9 4/16
5/20 11/21 11/23 12/1
12/3 16/19 19/21
22/12 23/18 24/11
26/24 30/21 32/22
43/16 43/20 62/20
65/24 71/3 79/21
96/25 106/19 115/17
116/24 117/7 124/8
140/14 148/7 148/17
148/18 150/15 158/2
160/4 164/24 190/14
204/1 204/6 204/14
throughout [2]
139/18 181/5
throwing [1] 51/24
thuggery [1] 64/25
Thursday [2] 41/18
41/19
till [1] 84/13
[1] 53/17
Tim [1] 129/12
time [130] 2/21 2/24
3/7 3/9 3/16 3/17 3/21
4/3 4/4 4/8 4/8 4/10
4/17 6/16 8/11 8/18
8/24 9/17 10/8 15/2
17/14 20/14 20/16
20/25 21/12 22/12
25/20 30/21 30/23
31/14 31/22 35/18
40/20 41/23 43/11
43/14 44/15 46/4
47/11 48/2 51/5 51/6
52/9 55/9 55/10 57/11
58/15 62/1 62/24
63/10 63/15 64/10
67/7 69/19 69/22
70/14 73/8 75/20
76/21 79/1 79/16
80/12 81/13 83/23
87/17 91/8 91/12 98/6
101/1 105/18 105/22
106/12 108/11 112/17)
118/15 119/13 122/13)
122/14 122/23 123/20)
124/3 124/14 136/19
137/7 139/2 139/20
140/4 140/17 141/23
143/24 146/11 147/5
150/23 151/4 151/16
154/7 155/21 156/1
156/25 158/3 158/5
158/6 158/16 160/3
161/17 162/17 163/10)
167/5 167/5 177/13
177/23 179/4 180/12
181/14 183/24 184/7
185/4 185/5 185/15
186/20 186/22 187/9
187/17 190/24 191/2
191/9 203/12 205/21
206/1 207/11
time-barred [1]
156/25
time-limited [1]
137/7
timeline [2] 103/25
185/23
timely [2] 64/3
127/13
times [8] 22/1 64/23
102/13 120/17 141/3
146/12 151/2 183/14
timeshares [1] 15/1
timing [7] 36/12
54/21 59/17 64/11
66/19 112/20 136/16
tiny [2] 25/10 55/15
title [4] 3/11 145/18
150/12 153/1
titles [1] 3/6
today [11] 22/1 53/7
74/16 95/15 121/2
124/17 131/1 142/12
142/25 202/23 206/7
today's [1] 2/12
together [6] 36/20
102/12 161/14 162/2
191/20 197/22
told [47] 8/22 17/4
20/21 33/7 33/8 36/10
39/4 39/8 47/25 55/11
55/16 72/16 73/20
77/3 79/14 80/1 87/1
90/5 91/12 91/23
92/15 97/15 100/19
106/5 119/21 120/13
121/19 122/10 122/12)
123/23 125/24 126/5
128/2 128/5 128/19
136/5 138/18 139/8
149/9 149/10 158/9
182/8 182/10 182/11
187/18 189/11 193/21
toll [1] 188/22
tomorrow [1] 98/12
tone [5] 36/21 53/14
54/16 107/22 191/18
Tony [9] 84/22 85/23
90/21 90/24 91/9
98/19 99/9 99/10
140/12
too [6] 5/22 51/16
74/24 187/15 188/21
201/25
took [20] 3/9 3/17 4/9
22/19 44/6 85/24
105/21 111/8 135/8
139/25 143/13 162/7
174/20 175/25 179/5
180/12 189/19 196/6
196/17 197/7
top [10] 20/4 57/24
61/2 109/3 148/6
160/14 171/19 178/14
197/9 197/9
top-down [1] 148/6
topic [3] 21/13
162/18 179/22
topics [1] 3/13
total [6] 4/4 18/17
29/1 94/1 114/10
123/6
totally [6] 74/1 74/9
92/7 92/8 132/24
184/10
towards [5] 10/25
49/12 80/13 102/8
116/25
track [1] 56/22
tracked [4] 110/12
118/1 118/4 118/17
traction [1] 86/9
traded [1] 174/9
trading [1] 166/1
tragic [1] 65/20
trail [3] 41/13 158/15
160/15
train [2] 70/20 104/4
training [5] 45/2 46/9
49/11 53/22 58/3
transaction [2]
156/20 203/8
transactions [9]
18/15 24/10 25/8
28/24 48/15 55/12
107/14 197/17 204/23
transcriber [1] 123/9
transcript [1] 58/20
transfer [2] 163/22
185/7
transferred [1]
184/10
transformation [3]
67/22 141/8 141/9
transition [2] 169/7
169/11
transpired [1] 44/20
Transport [1] 144/18
Transportation [1]
175/8
travelling [1] 187/22
Treasury [2] 76/16
83/1
treated [2] 84/25
127/18
trial [1] 202/3
trickle [2] 23/21
31/21
tried [2] 188/18
191/17
triggered [1] 181/20
Triggs [3] 168/18
168/19 194/19
trip [1] 187/23
trouble [2] 3/22 77/6
troubled’ [1] 57/23
troubling [1] 87/19
Trousdale [1] 201/5
true [4] 1/22 1/24
144/5 199/6
trust [3] 56/25 73/13
73/15
truth [4] 102/6
106/14 187/10 187/16
truth’ [1] 112/8
try [12] 25/12 46/23
63/2 103/4 106/19
106/21 148/6 162/2
171/9 184/18 192/8
192/24
trying [13] 7/20 10/4
54/10 54/16 73/16
78/7 106/13 126/4
128/14 161/14 162/11
168/1 185/7
Tuesday [4] 41/24
100/3 209/5 209/10
turn [45] 1/18 17/18
21/19 23/15 28/13
34/14 53/1 57/9 61/19
61/20 64/14 67/5 67/9)
74/10 83/3 85/14 89/8
90/8 93/8 97/25 98/24
101/24 104/16 107/10}
110/10 112/22 118/2
118/3 120/15 127/13
130/18 143/17 143/25)
150/11 153/3 157/11
160/13 168/25 170/2
173/6 173/10 195/8
202/10 202/13 202/21
turnaround [3] 85/19
89/19 100/4
turned [1] 136/6
turning [2] 59/18
201/16
turns [1] 167/24
two [35] 3/6 3/7
16/15 33/14 39/5
41/24 42/8 44/3 51/3
58/12 60/11 63/19
65/8 79/18 86/14
89/25 90/20 97/5
99/20 106/25 107/21
116/10 117/14 120/22)
127/25 143/6 143/19
143/21 164/7 164/11
173/21 180/22 184/6
196/7 199/25
tying [1] 102/6
type [6] 39/23 51/15
104/9 147/16 147/17
152/4
types [2] 146/5
166/18
typical [1] 24/8
typically [2] 20/3
36/19
typos [1] 30/18
U
UK [2] 188/4 188/8
UKGI [1] 146/24
UKG100000032 [1]
112/22
UKGI00000916 [1]
94/22
UKG100001457 [1]
2119
UKG100001458 [2]
17/18 23/15
UKGI00001459 [1]
17/22
UKGI00001534 [1]
34/14
UKG100001693 [1]
42/12
UKGI00001695 [1]
43/24
UKGI00001748 [1]
48/4
UKGI00001749 [1]
50/7
UKG100001852 [1]
61/19
UKG100002288 [1]
70/18
UKG100002439 [1]
74110
UKG100002440 [1]
779
UKG100002472 [2]
83/3 87/25
UKG100002764 [1]
93/10
UKG100002837 [1]
97/25
UKG100002896 [1]
101/24
UKG100002920 [1]
103/21
UKG100003007 [1]
(86) though... - UKGI00003007
U
UKGI00003007... [1]
104/16
UKGI00003111 [1]
107/11
UKGI00003390 [1]
110/10
UKGI00004006 [1]
120/10
UKGI00007352 [2]
85/14 89/9
UKG100013747 [1]
28/13
UKG1I00014168 [1]
112/24
UKGI00018248 [2]
23/13 27/4
UKGI00041975 [1]
13/6
UKGI00042677 [1]
67/5
ultimate [3] 12/5
145/3 191/20
ultimately [16] 5/17
11/20 11/22 11/25
12/4 49/24 71/21
81/21 82/23 82/25
111/17 111/21 112/10}
122/17 133/9 133/11
unable [2] 67/16 68/9
unambiguous [1]
192/13
unauthorised [2]
197/15 197/16
unauthorised/inappr
opriate [1] 197/15
uncertainty [1] 80/14
unclear [1] 37/14
uncontroversial [1]
96/16
under [14] 2/13 2/22
18/24 36/25 68/16
69/25 94/14 163/22
177/17 178/20 184/13}
199/8 202/3 207/11
Under-Secretary [3]
2/13 2/22 69/25
underdelivered [1]
68/22
underline [1] 13/23
underlying [1] 20/12
undermine [2] 94/16
116/17
undermined [1]
47/11
underpinned [1]
162/6
underpinning [1]
163/20
understand [23]
13/16 18/23 46/5 57/6)
69/10 71/19 73/22
90/22 96/1 97/2 98/11
106/7 137/2 139/5
143/11 143/21 148/8
162/9 162/15 191/1
193/9 198/11 200/6
understandable [1]
124/6
understandably [1]
76/10
understanding [13]
37/20 49/18 50/1 63/9)
77/24 103/13 118/14
123/22 133/13 136/3
136/5 137/23 164/20
understated [2]
155/16 190/21
understatement [1]
194/2
understood [3] 49/4
59/2 91/25
undertaken [5] 16/19
18/21 21/4 21/11
24/22
undertaking [1]
44/21
undertakings [2]
163/23 190/6
underway [1] 102/16
unduly [1] 84/2
unexpected [1]
128/20
unfit [1] 128/6
unfolding [1] 192/18
unhappy [1] 30/16
unilaterally [1] 63/8
union [2] 139/24
140/16
unions [1] 192/7
Unique [1] 2/1
Unit [1] 30/4
United [1] 173/15
units [1] 171/19
unless [1] 123/19
unlike [1] 20/2
unlikely [3] 67/4 91/5
123/1
unpredictable [1]
191/23
unrealistic [1] 85/12
Unrestricted [1]
197/14
unsafe [18] 47/24
50/20 116/20 118/11
118/23 119/9 122/20
125/18 125/19 126/23)
128/22 135/5 135/12
135/13 135/13 147/11
176/17 184/9
unsafe’ [1] 117/24
unsatisfactory [1]
45/5
unsubstantiated [2]
84/9 84/23
untamperable [1]
186/8
until [15] 11/6 16/10
22/11 37/14 38/13
39/12 41/20 70/24
79/12 80/12 158/16
162/19 171/6 177/18
209/9
unusual [11] 12/18
16/25 17/7 37/15
100/1 105/13 120/1
137/11 175/2 175/14
175/17
unusually [1] 36/17
up [88] 4/3 4/16 5/24
10/24 11/1 13/5 14/3
14/23 19/23 21/25
27/2 32/25 35/13 36/4
39/18 40/12 40/21
41/10 41/17 43/22
44/22 51/10 57/1 59/6
59/18 61/11 62/6 63/3
65/2 65/4 69/8 71/9
72/7 75/25 87/5 96/3
96/8 98/10 102/17
102/21 103/1 109/7
112/24 124/14 127/13
127/16 130/18 134/10
135/8 135/16 135/18
137/22 145/17 148/1
148/6 152/1 152/12
158/16 158/23 162/16}
165/1 170/23 171/17
173/6 178/14 178/17
179/24 180/18 181/10
183/8 185/23 187/6
187/24 188/5 188/6
192/24 198/16 198/25]
199/11 200/22 202/10
202/13 202/14 202/14
203/13 204/2 207/15
207/18
update [7] 37/1 70/20}
104/14 110/17 153/1
157/19 158/24
updated [3] 50/8
89/22 172/23
updates [1] 145/24
uploaded [1] 2/2
upon [2] 122/23
146/10
ups [3] 36/16 71/3
119/16
upturned [1] 40/2
urgency [2] 60/18
136/16
urgent [6] 47/22
48/12 59/6 59/8 59/10
59/23
urgently [1] 62/1
us [30] 6/12 29/23
37/2 47/14 54/21
56/25 61/6 86/16
86/24 89/20 95/16
98/6 98/22 102/7
105/21 109/22 110/11
112/25 114/3 118/14
132/3 135/2 142/17
158/4 161/11 162/25
171/13 190/7 198/14
201/10
use [4] 24/14 90/17
192/21 200/2
used [19] 25/9 37/2
41/6 43/8 54/6 58/17
87/11 88/14 92/3
97/13 97/22 108/1
128/10 147/1 154/21
155/2 157/23 173/21
193/23
useful [3] 21/2 85/18
86/23
users [4] 44/14 55/15)
94/2 107/17
using [2] 94/7 140/14
usual [5] 16/19 36/16
41/18 105/6 131/9
usually [2] 92/3
157/22
Vo
validity [1] 132/4
value [2] 119/23
193/19
van [1] 64/16
varied [1] 4/19
variety [2] 8/8 19/5
various [13] 14/2
14/13 28/2 39/17
40/12 58/22 60/4
122/5 127/24 144/20
160/5 161/25 175/21
vast [5] 10/5 10/5
10/5 88/20 141/25
vastly [1] 155/16
Vehicle [1] 7/16
Vennells [45] 13/12
14/4 21/13 34/20
36/10 36/19 47/23
53/5 53/6 53/11 53/13
54/2 55/6 57/16 60/20
60/25 61/10 64/15
74/13 75/18 115/2
115/8 119/2 119/25
120/2 125/2 125/3
125/6 125/10 125/23
126/18 133/3 133/6
179/23 183/3 183/7
185/14 185/24 186/2
186/19 186/24 189/1
189/5 190/16 203/18
Vennells' [3] 70/7
123/4 132/1
verbal [1] 109/24
verdicts [2] 49/16
50/22
version [9] 50/6
112/23 112/25 113/2
113/4 113/13 113/15
172/18 173/7
versus [1] 185/20
very [125] 1/5 1/10
1/13 1/25 3/6 3/13
3/22 6/23 7/6 7/11
11/8 16/25 17/2 17/3
22/11 25/25 30/16
30/20 31/14 35/25
36/23 38/22 41/11
41/23 46/18 46/21
47/12 48/17 49/20
51/10 51/21 53/23
54/17 55/23 57/17
57/18 65/19 70/12
71/22 72/10 74/16
78/6 79/10 80/4 80/24
82/9 85/18 86/23
87/14 90/4 91/17 92/5I
92/19 93/2 93/4 97/20)
98/7 100/21 101/3
106/18 107/1 108/15
111/15 111/16 113/16)
114/7 118/17 118/24
122/1 122/2 127/22
128/25 131/10 133/4
133/14 137/7 137/11
138/17 139/11 142/5
142/10 142/13 142/14I
142/18 145/2 146/8
146/8 146/11 146/15
146/17 146/22 147/8
149/7 152/7 152/18
154/9 157/17 161/25
162/6 164/1 167/4
168/16 174/24 175/6
179/10 180/4 188/10
190/24 191/22 194/24)
198/22 199/13 199/24I
201/17 201/20 201/22
202/13 202/24 203/20)
204/1 204/4 204/5
206/1 207/12 208/25
via [1] 137/5
viable [1] 13/24
vicar [1] 120/2
victim [2] 85/5
177/11
Victoria [1] 165/6
view [26] 5/16 9/1
27/22 33/12 51/2 75/7
82/12 87/4 90/24
92/19 96/10 99/11
100/11 101/21 102/22)
105/1 111/14 132/24
137/14 138/15 138/17)
139/17 147/20 192/22)
194/12 198/12
viewed [5] 8/20 8/24
25/18 130/22 133/4
views [2] 91/9 91/18
vigilance [1] 96/20
vigilant [4] 94/19
95/21 96/13 96/19
vilified [1] 186/20
villain [1] 186/6
(87) UKG100003007... - villain
Vv
Vince [7] 70/16 78/20
79/9 82/25 83/2
132/13 132/20
Vince's [1] 10/4
vis [2] 51/20 51/20
vis a vis [1] 51/20
visible [1] 68/17
vision [1] 13/20
visit [2] 35/2 35/10
visited [1] 34/19
vivid [4] 34/24
vividly [1] 106/4
voicemail [1] 61/24
volumes [1] 63/14
voluntarily [1] 44/2
WwW
wait [1] 59/22
waking [3] 108/22
108/23 108/25
Wales [1] 173/14
wandering [1] 180/1
want [32] 9/24 71/15
71/16 71/24 73/24
75/19 78/17 78/19
79/11 106/8 118/24
126/6 126/24 129/4
129/5 131/1 134/5
134/21 135/4 140/9
143/2 148/16 150/9
155/6 163/3 179/22
186/17 186/18 193/17
200/15 201/25 208/14,
wanted [8] 50/3
52/12 59/5 78/10
189/18 201/16 207/4
208/13
wants [2] 79/8
133/22
warm [1] 98/14
warning [1] 73/5
warrant [1] 85/3
was [721]
wasn't [32] 6/17 8/3
8/9 9/17 10/15 16/10
25/14 32/21 37/12
39/12 58/25 60/21
60/24 68/23 72/14
77/23 86/10 94/11
107/7 120/14 122/12
122/25 129/23 137/21
141/23 142/3 166/23
168/16 179/3 179/3
185/8 194/15
watch [3] 187/25
192/18 193/14
Watt [4] 133/19
133/22 139/14 210/14
waved [3] 109/14
109/21 109/23
way [45] 9/1 10/18
11/23 16/23 18/24
30/2 33/25 34/10
38/14 46/23 59/1
61/13 64/3 66/1 66/2
66/5 73/20 73/23 82/4
100/13 102/23 104/14)
110/7 114/25 115/7
115/9 127/13 127/16
129/10 130/13 130/21
133/7 141/24 151/23
163/10 174/5 181/16
182/14 190/3 192/21
193/17 194/1 194/21
197/22 208/20
ways [5] 5/21 33/14
34/2 59/13 127/24
we [417]
we'd [3] 34/16 56/16
109/7
we'll [9] 14/19 48/5
75/6 93/11 168/3
171/3 171/9 195/23
202/21
we're [19] 1/5 7/23
8/14 8/14 9/20 16/6
62/22 74/11 76/21
77/5 83/3 104/16
105/23 107/11 135/15)
142/19 150/7 160/4
170/24
we've [15] 16/12 20/8
31/18 35/11 35/12
70/11 71/23 86/14
86/21 107/16 118/18
118/19 118/19 129/14)
151/15
weaknesses [1]
149/18
website [3] 2/2 105/2
144/9
Wednesday [1] 100/3
week [10] 3/18 7/7
14/21 15/8 19/21 31/2
57/25 104/14 104/17
146/25
weekend [2] 41/15
42/8
weekly [1] 24/12
weeks [5] 70/6 70/11
83/4 106/1 196/8
weeks' [1] 165/14
weighed [1] 52/11
welcome [1] 45/6
welcomes [1] 45/17
welcoming [1] 46/16
well [60] 7/22 17/15
20/14 23/11 36/1
37/11 38/20 39/21
42/11 47/6 47/23 49/3
54/10 59/2 61/6 65/23)
71/4 71/15 75/21 82/8
86/17 88/14 93/15
96/19 102/10 108/7
108/11 118/25 121/7
121/17 137/9 137/17
138/11 158/2 161/25
166/9 166/11 167/9
172/11 172/16 175/23
183/7 184/18 185/8
186/17 187/5 188/23
190/4 191/8 192/5
192/19 193/6 193/9
197/25 200/11 200/15}
205/19 205/20 206/17]
208/17
went [11] 22/4 38/3
70/6 75/22 82/24 90/1
157/1 159/16 173/1
189/14 189/16
were [259]
weren't [6] 128/1
128/1 128/5 142/3
170/15 196/22
Westminster [7] 73/1
93/9 96/1 100/22
101/19 104/24 106/14
what [196] 4/7 4/14
6/5 6/12 6/16 6/16
7/25 8/15 13/18 14/24
15/4 15/15 15/25
16/25 19/20 20/21
20/23 20/24 31/6 31/6
31/21 33/7 33/15
35/20 37/3 37/7 37/11
37/14 37/25 38/10
38/23 39/12 39/19
40/6 40/15 40/21 41/3
43/23 49/18 49/22
53/24 53/25 54/7
54/10 54/13 54/15
54/19 55/8 56/23 58/1
59/11 60/15 60/25
63/14 64/7 69/1 69/2
69/17 71/13 71/18
71/25 72/13 72/16
72/20 73/7 75/7 78/7
79/14 79/15 81/3
81/10 81/17 82/4
82/14 82/20 83/2
86/16 89/5 89/6 90/7
90/11 90/12 92/9
92/15 92/17 92/19
93/24 96/16 96/20
97/10 97/24 98/20
100/7 100/8 100/18
100/24 101/8 102/7
103/25 105/18 107/7
108/3 108/9 108/11
109/22 111/14 111/18}
118/14 121/3 122/3
124/14 125/23 126/4
126/4 127/19 127/19
128/17 129/17 129/23
129/25 130/6 131/15
136/4 136/5 137/2
138/17 139/22 140/24
140/25 141/11 145/1
146/5 147/10 147/17
147/24 148/8 151/2
151/13 152/18 154/9
154/23 155/4 155/17
156/7 157/17 158/1
158/4 158/22 159/5
159/11 161/1 161/3
162/3 162/4 162/11
163/14 166/25 169/9
169/15 176/10 177/13
178/6 178/18 180/6
182/8 182/22 183/6
183/10 183/17 184/16}
185/7 186/14 186/21
186/23 186/23 187/9
187/13 187/17 187/17}
187/18 187/21 188/9
188/25 189/1 189/21
190/10 190/13 191/18}
192/19 193/4 193/19
193/21 194/2 198/20
203/17 206/1
what's [7] 16/1 39/18
96/3 99/17 136/2
137/9 137/9
whatever [2] 7/5
28/10
when [88] 4/21 8/21
9/8 10/10 10/22 10/25
14/16 14/20 15/5
16/10 17/10 32/16
33/12 33/22 34/3
38/13 39/6 39/11 41/7
41/24 47/17 51/10
55/19 59/15 61/9 63/6)
68/2 68/3 69/1 70/17
72/2 72/15 72/22
72/23 72/24 72/25
73/12 73/15 77/3
77/11 88/11 95/19
101/14 101/16 101/18}
102/11 104/15 122/10)
123/20 128/21 131/13}
131/16 132/19 140/21
141/20 145/14 146/12)
147/15 147/22 147/24}
148/25 153/5 156/2
163/19 166/2 166/11
167/20 167/22 168/3
168/11 168/13 173/3
174/4 175/7 177/19
180/8 184/16 184/19
186/23 187/20 188/15)
190/2 190/13 190/15
192/22 193/24 204/2
208/21
when I [1] 72/25
where [71] 4/15 5/7
11/10 12/25 14/8
16/14 24/19 29/3
31/13 32/5 32/20
33/15 33/17 33/18
47/22 54/24 60/17
67/25 71/23 73/9
75/24 79/2 79/16
80/24 86/17 87/12
88/12 92/15 94/17
96/22 100/12 105/3
106/5 106/14 106/15
106/23 111/23 113/25)
116/4 119/24 121/9
121/14 123/23 125/10)
126/22 127/25 128/23)
134/7 136/11 136/21
137/7 137/15 138/23
140/6 145/25 148/7
154/23 156/18 158/10)
158/15 166/12 177/9
177/10 177/25 179/10)
193/18 197/3 198/21
199/23 200/2 208/7
whereas [1] 101/20
whether [34] 12/18
34/5 38/23 38/25
40/23 40/24 43/17
43/18 58/16 59/7
59/10 59/22 59/23
69/5 78/2 100/9
112/15 113/10 114/1
114/2 123/7 132/7
132/24 145/21 159/8
167/8 167/9 167/10
172/3 172/4 200/4
203/4 203/4 203/7
which [132] 3/12
4/23 5/18 5/21 6/18
6/24 9/18 14/10 16/6
19/3 19/7 19/15 19/18)
20/9 24/2 24/12 25/24I
27/2 31/12 33/11 35/3}
35/17 36/2 36/10 37/8
39/24 40/13 43/8
43/22 44/13 46/5 46/9
47/21 48/15 49/1
49/16 50/4 51/6 51/10
51/15 53/6 55/19 57/5I
57/24 59/1 59/11
59/12 63/13 65/11
66/1 69/11 69/11
69/20 70/1 72/4 72/18I
75/17 76/7 76/10
76/15 78/23 78/23
79/7 81/25 82/4 83/5
87/16 87/19 88/18
90/19 94/15 95/10
97/13 97/22 98/10
101/5 101/13 104/13
104/13 110/7 111/17
112/10 114/4 116/16
117/8 117/25 118/16
119/6 120/1 120/25
121/20 122/18 124/9
125/18 126/12 129/6
130/2 131/9 132/1
139/3 139/23 142/4
150/14 150/20 150/22!
150/24 153/11 153/15)
154/4 155/6 159/15
163/22 168/5 169/5
169/18 172/17 174/12!
(88) Vince - which
Ww
which... [15] 181/14
181/16 185/6 185/16
191/15 192/21 193/12)
194/1 196/25 197/16
199/3 207/16 207/19
207/25 208/12
whichever [1] 22/6
while [8] 40/2 53/15
79/21 97/21 131/11
142/7 202/14 207/18
whilst [4] 29/15
83/23 85/10 148/21
whim [1] 132/16
Whips [1] 48/11
Whips' [1] 48/10
white [1] 197/24
Whitehead [11]
21/21 21/22 22/21
23/16 27/4 27/5 28/7
48/3 48/7 63/4 129/11
whitewash [1]
195/14
who [87] 5/12 5/16
8/25 9/1 9/4 11/18
14/4 14/11 17/14 18/6)
19/25 20/1 21/23 22/5
22/14 22/16 23/22
23/25 24/14 27/14
29/23 35/24 37/17
37/23 42/2 42/13
46/12 46/19 50/20
52/7 53/7 60/8 60/9
63/22 63/23 63/24
65/6 65/21 69/24
70/15 76/16 81/1
82/11 82/25 87/9
87/11 94/3 97/3 102/5
102/7 103/6 104/8
104/18 106/21 106/21
108/4 116/9 120/6
120/7 124/12 127/8
129/2 137/14 138/3
138/25 139/20 156/3
157/8 158/16 159/3
163/17 167/23 168/10}
177/18 181/5 182/12
182/23 186/25 189/12
190/4 191/16 201/3
201/5 201/10 201/14
206/13 208/20
who's [2] 12/19
195/7
whole [7] 69/21
112/2 153/23 161/23
167/17 195/20 198/25
whom [3] 159/25
167/24 208/21
whose [5] 17/10
48/18 51/9 164/2
195/6
why [35] 39/5 46/16
78/9 78/18 78/18 79/8
80/1 80/1 80/16 81/9
84/24 89/18 90/10
94/10 95/10 106/8
107/8 108/15 114/21
122/19 124/9 130/2
130/11 130/15 161/10)
161/11 172/20 173/3
180/5 183/20 192/4
193/4 194/13 198/11
206/24
wide [8] 3/13 21/8
44/11 44/17 47/2
50/16 115/18 133/10
wide-ranging [1]
3/13
wide-scale [1] 50/16
widen [1] 85/6
wider [7] 5/19 15/18
33/11 44/24 78/24
88/10 166/6
wife [1] 201/18
will [74] 2/1 3/25
10/10 10/18 11/2 11/3
17/15 22/1 23/11 25/4
25/18 25/24 27/22
35/8 40/11 40/16
40/18 40/19 41/4
41/17 41/20 42/25
43/14 43/16 54/23
57/11 61/4 62/3 62/18)
62/20 62/20 65/3 67/4
70/22 70/23 71/2
71/12 71/13 71/14
71/14 85/3 85/13 91/5
91/13 98/13 101/20
104/13 104/14 105/1
110/12 112/5 112/16
115/22 116/2 116/11
117/1 117/17 120/25
123/5 127/22 129/11
131/6 144/8 169/4
169/12 170/6 173/17
178/10 187/11 188/14}
191/9 195/21 200/1
209/5
Williams [5] 61/22
117/14 131/22 134/23)
210/10
willing [4] 64/8
Willott [2] 3/2 70/15
Wilson [17] 164/18
164/21 164/24 165/17)
165/23 166/2 166/4
171/22 200/23 201/17)
201/18 201/18 201/19)
202/10 205/23 207/20)
208/8
Wilson's [4] 202/2
202/21 207/15 208/17)
wish [14] 29/18 70/8
75/17 75/18 86/18
104/25 105/8 122/5
122/8 122/14 122/24
125/25 143/11 161/17,
wished [3] 122/7
134/14 134/15
withhold [1] 28/6
withholding [1]
107/19
within [41] 3/13 4/24
9/4 9/10 9/18 11/16
11/22 12/2 17/17 18/9
23/24 24/24 30/1
31/23 37/22 38/20
39/21 39/24 42/13
46/12 55/25 57/15
61/16 73/11 86/12
99/21 100/10 129/7
130/25 135/23 138/21
149/17 149/24 166/3
166/17 166/20 167/1
168/5 168/11 172/9
183/21
without [12] 54/25
63/7 69/13 79/5 86/6
100/7 118/16 131/7
141/4 148/17 152/11
187/3
WITN04210100 [1]
207/16
WITN10190100 [2]
2/1 5/24
WITN10310100 [1]
143/4
witness [43] 1/14
1/25 2/15 5/23 11/11
36/5 47/10 47/24 53/1
73/24 109/6 119/9
119/11 122/6 122/20
123/17 125/18 125/19!
126/23 127/10 135/6
135/12 135/13 135/14]
139/18 142/8 142/11
143/1 144/5 145/13
159/2 159/20 163/5
165/19 174/2 181/9
188/11 197/2 202/8
202/11 203/22 207/15}
209/1
witnesses [1] 146/24
Women [3] 2/22 3/9
3/16
won [1] 156/19
won't [2] 202/10
204/13
wonder [1] 73/13
wondered [1] 86/1
word [6] 38/16 58/16
75/2 157/23 192/21
193/23
wording [2] 125/15
157/17
words [13] 54/6 54/8
54/12 54/20 83/15
91/25 96/11 96/12
97/13 97/22 118/12
196/22 197/12
work [36] 3/5 9/5
13/24 34/6 44/20 45/7
46/21 58/3 60/18 68/9
106/13 106/20 106/21
137/7 142/14 144/15
149/17 151/25 152/14
154/13 154/14 154/16}
161/1 163/20 164/2
170/21 170/22 184/19}
191/16 198/21 198/25]
199/10 199/11 199/13}
199/21 199/24
worked [6] 30/2
166/3 170/20 170/21
186/24 208/20
Workers [1] 139/24
working [37] 3/20
44/21 62/20 64/12
67/14 67/25 72/7
72/20 73/7 88/16 90/1
90/18 90/23 91/11
99/8 102/17 103/10
105/23 105/23 107/15)
108/17 108/23 112/2
113/4 113/19 114/12
117/6 123/24 124/6
140/14 149/8 162/2
184/20 185/4 185/6
185/11 186/24
works [1] 59/1
workshops [1] 32/4
Workstream [1]
170/1
worried [3] 98/7
182/21 182/22
worries [1] 146/13
worry [3] 113/10
114/3 155/13
worrying [1] 68/6
worse [1] 195/6
worth [4] 4/6 25/22
29/12 83/12
would [351]
wouldn't [23] 9/24
15/3 20/1 20/19 35/1
38/12 49/25 49/25
52/3 69/19 70/4 70/13
97/7 137/11 138/21
139/1 139/5 148/3
149/10 187/2 192/14
192/18 197/4
write [5] 34/4 76/5
82/25 102/2 104/7
writing [10] 32/7 32/7I
71/20 82/8 103/15
104/21 119/1 119/18
129/4 205/19
written [11] 5/11
32/11 58/8 58/25
84/20 85/21 113/7
113/11 115/5 137/6
205/20
wrong [13] 17/21
58/22 81/3 93/24
106/22 107/8 134/3
182/1 185/1 186/13
186/16 187/3 192/12
wronged [1] 124/12
wrongful [1] 167/21
wrongfully [1]
182/23
wrongly [3] 138/20
181/6 185/10
wrote [1] 102/25
Wyn [3] 123/22
131/22 210/10
Y
yeah [15] 4/19 10/4
12/23 38/22 40/18
46/9 55/6 59/20 60/22
90/4 96/19 105/21
110/2 124/18 181/21
year [16] 68/21 72/20
73/14 141/3 148/20
149/15 150/13 151/25)
152/14 153/11 154/15)
159/6 167/6 196/5
198/16 199/23
year's [1] 83/11
year-end [2] 153/11
198/16
years [11] 2/19 7/8
18/13 24/8 24/25
107/21 122/20 122/22!
155/18 157/14 204/20)
yes [121] 1/4 1/7 1/19)
1/21 1/24 2/8 2/11
2/20 2/23 3/1 5/5 11/8I
12/9 14/9 16/2 21/24
22/3 23/4 31/20 48/24I
52/18 52/25 61/10
77/18 79/14 87/24
89/17 93/3 93/16 95/5I
95/17 110/16 114/14
114/20 114/22 115/5
120/3 123/3 123/12
123/15 124/2 124/24
125/14 126/2 126/3
126/8 127/2 127/19
133/5 133/14 135/19
135/21 137/11 138/16)
140/3 140/6 142/18
144/2 144/4 144/7
145/6 145/10 145/13
145/16 146/8 147/5
147/8 149/1 150/19
151/7 155/17 157/8
157/9 162/20 164/23
165/21 165/21 166/8
166/10 166/15 166/19}
168/9 171/5 171/14
171/20 172/8 172/11
172/11 172/11 173/25]
175/22 176/12 176/18)
177/7 177/12 180/11
180/21 183/5 184/12
186/3 188/13 188/21
189/23 191/17 191/18)
(89) which... - yes
Y
yes... [16] 191/22
193/16 197/9 198/1
200/24 202/17 202/19
203/10 203/15 203/19)
206/19 206/22 207/13,
208/24 208/24 209/7
yesterday [1] 83/8
yet [4] 47/22 49/3
117/25 204/10
you [894]
you'd [5] 20/23 39/14
128/4 134/14 134/15
you'll [6] 165/16
170/5 195/22 196/19
204/7 207/18
you're [28] 5/15 33/5
33/22 40/23 69/20
70/17 103/22 107/24
127/1 131/13 136/8
136/24 140/2 141/22
146/3 147/24 159/20
164/14 165/20 177/24}
189/19 189/21 189/24}
190/15 191/13 193/1
199/4 203/13
you've [29] 12/10
23/2 37/2 41/9 77/3
86/24 98/11 109/21
111/22 115/2 127/25
128/7 129/1 130/17
134/14 135/2 136/21
156/6 158/21 167/25
176/10 190/14 193/4
195/10 202/5 202/15
202/22 203/12 205/13,
Young [9] 148/19
153/12 153/18 153/25}
154/2 160/20 160/24
160/25 196/20
your [159] 1/10 1/20
1/23 3/2 3/7 4/2 4/10
5/3 5/16 5/23 7/5 13/5)
13/8 13/11 13/13
13/14 13/25 14/3
17/25 18/2 20/13
20/23 20/25 21/14
22/2 22/8 28/18 31/23
36/5 36/7 38/17 38/19
39/15 41/10 42/14
48/8 49/18 53/1 53/24)
61/7 62/5 63/9 64/17
65/17 65/22 66/7
66/20 66/25 67/18
68/23 74/13 75/7 75/8
77/8 77/20 77/24 80/9
81/24 85/15 86/16
94/23 96/6 98/3
103/23 104/19 105/1
105/5 105/7 107/4
107/10 107/18 109/6
109/10 109/12 109/18)
109/22 109/23 110/19}
1114/9 111/14 111/22
115/2 118/14 123/17
125/23 126/17 126/25)
127/10 127/16 129/1
129/15 130/17 130/18)
130/24 132/3 132/6
134/8 134/8 134/22
135/2 135/8 136/7
136/8 136/10 139/9
139/18 142/14 142/23)
143/5 144/1 144/3
144/6 144/8 144/13
144/14 145/2 145/17
149/3 156/8 159/2
159/14 159/20 163/5
164/20 165/20 168/5
170/15 173/8 174/2
174/18 177/13 178/24)
179/13 179/23 181/9
181/18 183/2 192/1
192/18 192/21 192/24)
193/14 194/4 194/12
196/4 196/9 197/2
197/2 197/20 199/8
202/6 202/8 202/11
202/19 203/15 203/22
205/8 205/23 209/1
yours [2] 93/15
187/15
yourself [2] 134/8
202/24
YouTube [1] 187/24
Zz
zero [2] 42/4 59/18
zero hours [2] 42/4
59/18
zoomed [1] 93/14
(90) yes... - zoomed