INQ00001179 - Transcript (23/07/2024): Post Office Horizon IT Inquiry - Baroness Neville-Rolfe [WITN1020]

Evidence on official site

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The Post Office Horizon IT Inquiry 23 July 2024

Tuesday, 23 July 2024

(9.45 am)

MR BEER: Good morning, sir. Can you see and hear us?

SIR WYN WILLIAMS: Yes, thank you very much.

MR BEER: Thank you. May I call Baroness Neville-Rolfe
please.

‘SIR WYN WILLIAMS: Of course.

BARONESS LUCY NEVILLE-ROLFE (sworn)
Questioned by MR BEER

MR BEER: Good morning, my name is Jason Beer and I ask
questions on behalf of the Inquiry. Can you tell us
your full name, please?

A. Baroness Lucy Neville-Rolfe.

Q. Thank you. You've kindly made a witness statement.
It's 72 pages long and is dated 26 June 2024. Can we
look at that, please. It's WITN10200100. Can you turn
to page 72, please; is that your signature?

A. tis indeed, yes.

Q. Are the contents of your witness statement true to the
best of your knowledge and belief?

A. The contents are true. It was signed on 26 June when
I was a Government Minister in the Cabinet Office. I'm
now an opposition Member of the House of Lords.

Q. Yes, thank you. By way of background, I think you were

a civil servant for 24 years between 1973 and 1997; is
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Q. I'm going to address matters chronologically, if I may,

as you've done in the first part of your witness
statement, rather than thematically, because hopefully,
in this way, we will explore all of the themes as they
arise across the 14-month period.

Can I start, however, with a high-level summary of
the entirety of your time in office. It's my summary
and I want to know from you whether I've got it right.
I'm going to split it into four stages or four periods.
That may be somewhat artificial, as there was, I think,
no neat dividing line in the four stages, no "lightbulb
moments", as you say in your witness statement, and the
issues appear to have been evolving or developing for
you.

But is this right: the first period of time, stage
‘one, lasted from appointment in mid-May 2015, until
a meeting with MPs and the Post Office in mid-July 2015,
and this period, would this be right, would be marked by
you being provided with information, principally by
ShEx, which information suggested that it was
established Government policy that Government maintained
an arm's-length approach to the Post Office, that
Horizon had been independently and extensively
investigated and that no systemic faults had been found
with it?

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that right?
Yes.

Holding positions, amongst others, as a private
secretary, a member of the Prime Minister's Policy Unit
in Number 10, and then as a director in the Deregulation
Unit in the then DTI.

Yes.

You then worked in the second stage of your career in
the private sector, holding positions as a company
secretary, a board member and as a NED, a Non-Executive
Director, including in FTSE-listed companies; is that
right?

That's correct. I was an Executive Director at Tesco

for 15 and a half years and then I also had
non-executive roles, at various times.

Then, thirdly, you were made a Member of the House of
Lords in 2013, and from 2014 until 2017, you were

a Government minister in variously the Business, Culture
and Treasury Departments?

Correct.

You held ministerial responsibility for postal affairs,

is this right, between 12 May 2015 and 13 July 2016?
Correct.

So a period of 14 months?

Correct.

I think that's a fair summary. I mean there was also
Criminal Cases Review Commission work into cases that
people were worried about.

This first stage was marked by you finding that
information, reassuring and acting in reliance on it?

I think that's largely true, yes.

Accordingly, at this early stage, you followed the
orthodox line that you had essentially inherited as part
of Government policy?

Yes, to the extent I was writing letters to MPs, for
example. But, obviously, I was aware that there were
murmurings, especially amongst a few MPs who had
particularly troublesome cases, like Mrs Hamilton --

I think the Ms Hamilton case and that was one of the
reasons I was very pleased that I was going to have

a meeting with MPs to discuss some of that.

Thank you. Then stage two, as I am going to call it,
from mid-July 2015, your faith in ShEx's advice was
beginning to wane and this led to a desire in you to
hear from different voices and for more independent
scrutiny of the Horizon issues to be undertaken than had
been offered by ShEx to date; is that fair?

That is fair, and I was also in receipt of advice --

there was this Second Sight Report that was sent to me

by one of the MPs and I was in receipt of advice from
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The Post Office Horizon IT Inquiry

ShEx on that, which I was troubled by because it seemed
to be a very cursory summary of what looked like a very
long, complicated report, which I obviously had

difficulty in understanding the ins and outs of.

Then stage three, from about September onwards, you took
the view that ShEx were failing to carry into effect

your wishes and, to an extent, seemed to be working
against you?

I think that came a bit earlier, to be honest. I was
worried in August that I wasn't getting broad enough
advice, I tried to get in officials, without success,

from the Department more broadly, and I also then asked
the new chair, Tim Parker, of the -- of POL, to take

a fresh look and undertake an independent review of all
of this. So that was actually in the August period.

But, obviously, it was carried through later. I mean,

in Government things take more time than in the private
sector.

Lastly, you determined that the only way forwards was to
secure some form of independent investigation into the
Horizon issues?

That's correct, yes, and the question was how could one
get this extra work done, recognising that there were
arguments on both sides, of course, because I was being

told in all directions that, actually, there wasn't
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particularly on individual cases, but I was looking to
them for, obviously, the kind of independent, objective
advice that, as a former civil servant, I knew was the

job of civil servants.

Thank you. With that overview in mind, can we start
with your appointment and initial briefing. I think

it's right that you were aware, even before you took up
the postal affairs brief, that concerns had been raised

by some MPs about the Horizon issue and that that issue
had been raised in Parliament; is that right?

That is right and there'd been a debate, and I'd --
there'd been a piece of correspondence I had, which

I had got in my bundle originally, about making

a statement about mediation, which I'm not sure was
whether it was eventually made, but the convention is
that, if a statement is made by a Minister in the House
of Commons, it's then repeated routinely in the House of
Lords. Although one doesn't have any influence over the
content, obviously one's name is put to it. So, out of
courtesy, it's sent to you to have a look at. So I was
aware of that.

So that prior knowledge led you, I think, upon receipt

of information from the Secretary of State as to the
range of your portfolio and the fact that it would

include postal affairs, to seek an early meeting about
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really an issue, there was no systemic problem with
Horizon, and so on. So I was trying to find a way
through to get some further work done because I just
couldn't believe that these people, who would be
seemingly sort of honest, respectable people, were, you
know -- so many of them had been prosecuted and that's
what the MPs had been telling me.
You were engaged, in relation to the Post Office, for
a relatively short period of time, 14 months, whilst you
held this ministerial brief but, would this be right,
you were concerned by the apparent approach of ShEx
Officials to align their position very closely with that
of the Post Office, rather than exercising
an independent function?
Yeah, I think I came to that view gradually because they
were obviously departmental officials, albeit slightly
separate because they were in this thing called the
Shareholder Executive, and I -- in fact, Laura Thompson,
who was my main official advice, she seemed, you know,
quite like the other officials who worked for me,
sounded very satisfactory in other areas, and, you know,
she advised me in the classic way.

I didn't really realise until later how coordinated
that was with the Post Office. Obviously, they needed

to go to the Post Office to find out the facts,
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the problems with the Horizon IT System; is that right?
That's correct, yes.

Can we look at that, please. It will come up on the
screen for you. You can probably put that witness
statement to one side now because I won't be referring
to it very often. It will come up on the screen,
WITN10200101.

If we can go to page 2, please, and scroll down,
an email to -- and can you help us -- the email address
is "Neville-Rolfe MPST-OLD". An email sent to that
email address, where would that go to in relation to
you?
I mean, that's the private office address so all your
private secretaries have access to that.

So we shouldn't take any email that's to "Neville-Rolfe
MPST" as being an email that went directly and
personally to you?

Correct.

Is it right that you would see some of these emails if
private office chose to forward them to you or to print
them and put them in front of you?

Exactly.

Hannah Wiskin, the PPS to the Secretary of State says:

"The Secretary of State has considered carefully the

[portfolios] across BIS and has decided on the policy
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areas [that are] contained in the attached.”
If we go to page 1, please, a reply from your
private office, if we just scroll down, we can see it's
from Harriet Smith. Did you have more than one private
secretary?
She was the main one but there's a guy called Andrew who
also features, who was the sort of number 2.
Okay, so from your private secretary:
Hannah.
"The Minister is broadly content -- she has
commented as follows", and then about the fifth
paragraph down:
"The Post Office brief is troubling and I would like
an early meeting on the problems with the Horizon System
Just stopping there, does this look, therefore, like
text that has been cut into the email by your private
secretary Harriet, through the use of the word "I"?
Yes, it does. Most likely, I've written that in
manuscript on a document that she'd sent me. One of the
problems about this particular Inquiry is that there
isn't any proper paperwork on the private office. This
has been preserved, no doubt, because it came from the
Secretary of State's office but I don't think most of

the notes of my meetings and the submissions that came
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would sit as between the Commons and the Lords, ie who
will actually be speaking in the Commons, or was it
a deeper issue you were raising than that?
I think there were couple of things happening here.
First of all, I'm being allocated my portfolios, some of
which I was already doing, which were quite busy, and
obviously the Bills that I had to do, I don't think, are
mentioned here, perhaps maybe they're in an annexe.
Secondly, I knew that taking the Post Office portfolio
wasn't without difficulty. I've recorded that. And
then for good order, I needed to know who would be
answering if there were a commons debate, for example.
It turned out to be Minister Freeman, in due course.
I was always on to this point because I had to answer in
the Lords for all my other colleagues, that's one of the
sort of challenges of being a Lords minister, just the
sheer scale of work you have to do, which is not in
areas that you're responsible for.
I think at the end of the month, at the end of May, you
had an introductory meeting with members of ShEx --
Yeah.
-- and that was ahead of a meeting specifically about
the Post Office on the 2 June 2015. I think you've got
a background briefing. Can we turn that up, please.

Firstly, the covering email -- UKGI00004415 -- 29 May
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and what I wrote on them, none of that seems to be
available.

It must have all got thrown away at some point but
this looks very much like what I said and then I made
this point that obviously I know that Post Office
closures were a worry because we dealt with those when
I -- when some of the post offices -- as part of
transition, some of the post offices were coming into
‘our neighbourhood stores, which, I mean, was a positive,
to be honest.

So you say:

"The Post Office brief is troubling and I would like
an early meeting on the problems with the Horizon IT
system and the losses people are complaining about.
This will be a Parliamentary issue and it would be good
to know who will answer on postal matters in the
Commons. I dealt with Post Office closures a few years
ago at Tesco and it was very problematic with local MPs
including David Cameron -- whom luckily we were able to
help!"

So this is 18 May, within six days of you taking up
office; is that right?

That's right, yes.
The purpose of this part of the email here, was it

simply to work out where the Parliamentary business
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from Laura Thompson and, as you've said already, she was
your principal contact, is this right, within ShEx?

Yes.

To your private office, with the subject of "Briefing

for Baroness Neville-Rolfe" again, "ahead of

introductory meeting on Post Office":

"_. please find attached some background briefing
for [you] ahead of [your] introductory meeting on
Tuesday of next week."

Can we turn to the briefing itself, UKGI00004416.
This is page 1 of the attachment. It's a 28-page
document and we can't do it justice by going through all
28 pages here. I think you say in your witness
statement that, overall, you found this to be a well
prepared, clear and helpful briefing?

Correct.

Can we look, please, at page 2. This is the first
substantive page and is essentially an executive
summary. If we look at the last paragraph on that page,
it says:

"A small but vocal number of mostly former
subpostmasters have raised concerns about [Post
Office's] Horizon IT System, which they claim has caused
their businesses losses. Over two years' worth of

independent investigation has found no systemic faults
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in Horizon and there is a mediation scheme to consider
individual cases, but campaigning and media interest
persists and BBC's Panorama is due to broadcast
a programme on this on 22 June. See slide 13."

If we, just before we go to slide 13, look at
page 3, please. Do you see in the bottom left-hand side
of that slide, in bold italics the last entry:

"Government does not seek to influence [Post
Office's] day-to-day operations.”

Have you got that?

That's it.
Yeah, thanks.
Maypbe, if we can just look at that in context we can see
it's essentially a running summary.
Yeah.
Was that the orthodoxy that ShEx told you was the
essential operating position?
I think they explained, as I probably already knew, that
it was at arm's length, and we tried not to interfere
because we were trying to make them behave commercially
and that was how the model worked, and it followed from
that that we weren't influencing day-to-day operations.
I mean, that didn't rule out them asking many -- if you
look further on in the document, there's a sort of

programme of things that I should do as a new minister
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former) subpostmasters about the ... system, in 2012 the
Post Office commissioned an independent firm, Second
Sight, to examine the system for systemic laws that
could cause accounting discrepancies.

"Second Sight's Interim Report, published in July
2013, and the final report published in April 2015, both
make clear that there is [and this is underlined] no
evidence of system-wide problems with Horizon."

At this time, did you have a copy of either the
Interim Report or the final report that are mentioned
here?
I don't think so.

Therefore, did you rely on what was said; in particular,
did you rely on what we know to be a false statement
that the final report makes it clear that there was no
evidence of system-wide problems in Horizon?

Yeah, obviously, I believed that and that was -- that
line was -- continued to be taken for some months by
ShEx and, no doubt, the Post Office.

At this point you had no information or material to know
that that was a false statement, insofar as it applied

to the final report?

No, and if you look at the pack, you know, it looks
considered, they've gone through the various things that

are going on. I mean, it looks orderly and well
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for the Post Office and I think that included --

certainly I made, you know, visits to post offices on
visibility. So but the day-to-day operations, how

things run, what the IT system did, you know, which post
offices you closed, how rapidly we transformed from the
‘old model to the new model, they regard that as a matter
for the Post Office. And I mean I supported that, as

I think I've said in my statement, that there can be

a lot of merit in allowing, you know, people to get on

with it.

I think you say in your witness statement that the model
of an arm's-length body operation with Government is not
inherently defective but it depends on the honesty and
reliability and competency of the people operating it?

It does, people on both sides, yeah.

Can we go to slide 13, which is on page 14, please.

This is the slide concerning the Horizon system and the
Mediation Scheme. On the left-hand side, it records
that:

"There has been over two years of independent
scrutiny of [the] system and no evidence of systemic
flaws has been found."

Then in the body of the text, if we look at the

first paragraph:
"Following complaints from a small number of (mostly
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organised.

The rest of the slide concerns the Mediation Scheme?
Mm.
1am going to take that as read.

I think you asked for a further briefing
specifically concerning Horizon; is that right?
Yes.
Why was that?
I think it probably dated back to that original exchange
that we looked at, you remember, that I had known on
appointment that Horizon was a problem area and so I --
and I think it was - I felt that it was a slightly
different subject to the sort of commercial and
transformational issues that are looked at, at the rest
of the pack. So it made sense to have a separate
session and I wanted a bit more information. I think
they sent me a longer submission.
We're going to look at that now, UKGI00004453. This is
the longer submission, dated 2 June 2015. Itis
a six-odd page document. So the fuller briefing about
the Post Office generally was dated 29 May. We're now
on 2 June. The "Purpose" of this document is recorded
to be a "Further briefing on the Post Office Horizon IT
System and associated Mediation Scheme, and seeking your

views on handling this matter in future", with
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a recommendation that you firstly note the briefing:
secondly, that you agree that Government should maintain
distance from this matter and resist calls for further
independent investigation; and, thirdly, that you agree
that officials, rather than ministers, should respond to
future correspondence from the JFSA.

Do you, as well as obviously noting the briefing,
agree those two recommendations, essentially?
I mean, I think certainly the third one, a letter went
off to Sir Alan Bates from an official. So, implicitly,
it's clear that I did agree that, and I think it would
fit in with my general approach. You have to look at it
in the context of how many portfolios I've got and
therefore how much correspondence and requests -- it was
a request for a meeting, I think, and I -- my general
approach was to see -- if MPs asked to see me, then
I would try and have an MP or a fellow peer, and if the
Department recommended a meeting, particularly if it was
from somebody like a trade union, then I would try and
fit those in.

I was advised, I think -- you'd have to go elsewhere
in this document -- that Justice for Subpostmasters
weren't sort of the equivalent of an accredited trade
association/state trade union, that they were

individuals and, therefore, I agreed that it made sense,
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every day.

Yes, certainly, they'd put the numbers in context, but

of course the Mediation Scheme was set up because there
were sort of acute problems in a few cases. So it's
important context but not definitive.

Paragraph 4:

"_. Second Sight began their investigations in
2012, producing their initial report in June 2013 and
their final report in April 2015. They've also
undertaken separate investigations into each of the 136
cases in the scheme. There has therefore been over two
years of independent scrutiny and in that time no
evidence of systemic flaws in Horizon has been found.”

Then, if we go forwards to paragraph 7:

"Despite JFSA's complaints and calls for a new
investigation, it is our strong recommendation that
Government should maintain the position that this is not
a matter for Government, and increase our distance from

the matter ... attempts to prolong this matter do damage

to [Post Office's] brand and cost [Post Office]

significant amounts of money in funding Second Sight and
‘operating the Mediation Scheme. We also recommend that
Government should resist any calls for further

investigation -- the matter has been comprehensively

investigated over several years and the complaints of
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within the spirit of how we organised correspondence,
for that to go from officials.

Can we look at the substance of the briefing, then,
paragraph 2:

[Post Office] commissioned an independent firm of
forensic accountants, Second Sight, to examine the
system for evidence of systemic laws which could cause
accounting discrepancies. Their initial report (in June
2013) found no evidence of systemic flaws that could
cause the issues raised. The report did find that in
some cases [Post Office] could have provided more
training and support to subpostmasters, and [Post
Office] have since made changes to address these. [Post
Office] also established a mediation scheme and invited
current and former subpostmasters to come forward ..."

Then, in paragraph 3, there's some numbers given --
136 applicants versus an estimated 68,000 users in
11,700 branches -- and:

"The vast majority of subpostmasters are using
Horizon effectively every day.”

Was that a series of statements that ShEx officials
made regularly to you: a comparison of the number of
people who had come forwards, either to JFSA or through
the Mediation Scheme, against the balance of users who

were operating the system, it was said, effectively
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JFSA have borne no fruit. Reinvestigation would be

neither value for money nor in the public interest
Then it's repeated, I think, for the third time:

"There is no evidence of systemic flaws in Horizon ..."

Second bullet point:

"There is no evidence that any of [Post Office's]
prosecutions against subpostmasters for either false
accounting or theft are unsafe. [Post Office] has got
a duty to disclose any new material that comes to light
that could support a subpostmaster's defence, and none
has emerged."

At this time, had you got any material that
suggested to you that that was a false statement?

No, I mean, I knew there were sort of enduring concerns,
but I found this reassuring, in that the Criminal Cases
Review Commission are looking at applications for review
from subpostmasters and that POL has a duty, which
obviously I was aware of from my corporate background,
to disclose material that comes to light. I mean,

that's a very important principle of British justice.

But, in particular, my question was slightly imprecise,

the statement that no material -- none -- no material

has emerged that could support a subpostmaster's
defence. I mean, you now know that, by this time, June

2015, much material had emerged within Post Office that
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might support a subpostmaster's defence, in particular,
you now know, I think, the advice that had been written
about the principal expert witness, Gareth Jenkins, that
the Post Office had relied on and the Post Office's own
conclusion that he had given evidence that was.
materially misleading and in breach of his duties to the
court. At this time, did you know any of that?
Obviously, I didn't know any of this at this time,
although I would have pursued, you know, more detail.
This is very strong advice, you know, it's not "on the
‘one hand ... on the other". ShEx haven't sought to go,
you know, into the detail of the individual cases and
explain, you know, what the concerns are. I did ask for
material on that, but that was later on in August.
We'll come to that in due course. As far as I can see
here, there's a very strong advice that there isn't
a problem, they looked into it all, there is no
evidence, and even if there is and some material comes
up, then that's going to be shipped straight off to the
Criminal Cases Review Commission.

I mean, that would have been the way I would have
read that. Obviously, we're looking back at hindsight
at the moment and I was getting this unending and, you
know -- you know, always the same advice on all of these

points from ShEx.
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the process have maintained the confidentiality of all
members of the scheme, even where individuals have
waived their own anonymity and spoken to the press or
where documents have been leaked by [Justice for
Subpostmasters Alliance]. There has been some attention
on this matter, mostly BBC's The One Show and local news.
programmes. Subject to taking legal advice [Post

Office] are now in favour of taking a more robust

approach to handling JFSA, given that it is clear JFSA
wish to derail the Mediation Scheme and prevent the

final cases from being mediated."

Then lastly paragraph 13, please -- sorry, I should
have read paragraph 9:

"We consider that a more robust and proactive
approach from [Post Office], together with a more
detached stance from Government, would be the right
approach to minimise negative press and ensure the
scheme can complete its work and close as swiftly as
possible ... Are you content with this approach?"

I think you indicated that, in the light of what you
were told, you would have been content with that
approach?
I think there was a -- I mean, obviously I may have read
this afterwards but the Mediation Scheme had been

subject to a sift, originally and then I think, as part
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Is the point you're making that this, even as a piece of
advice, contains no shades of grey: it's very black and
white?
Very black and white yes.
No evidence, no evidence, no evidence?
Correct, and, you know, these were civil servants. I'd
been a civil servant. You know, you have a duty to be
objective and truthful as a civil servant, so obviously,
you know, Government can't cope if, you know, the civil
servants aren't looking at things, you know, honestly,
which of course they may have been. You know, this is
maybe what -- this is presumably what they believed.
Over the page, please. The top bullet point, which
picks up a point you made earlier, Baroness
Neville-Rolfe:

"It is important to note that the [Federation],
which is the recognised representative organisation for
subpostmasters, does not support JFSA's arguments. The

General Secretary, George Thomson, has publicly said

that he considers JFSA members to be ‘trying it on’ and
there are their complaints are doing damage to
subpostmasters' businesses."

Then if we go on to paragraph 8, please:

"To date, [Post Office] have generally sought to

address JFSA's concerns where possible, and throughout
22

of the closing it all down, anybody who wanted to have
mediation could have mediation. So, you know, that
looks like an improvement to me.

And on the trying on, which we passed over rapidly,
when I was preparing for today, I discovered that
Thomson had actually told the Committee and the Commons
that he thought that I think, was it Mr Ridkin (sic) had
been trying it on. So there was quite recent evidence,
if you like, that no doubt officials were looking at, to
say that perhaps, you know, there was some issue. So
that's the background to that is.

But, for me, sitting and looking at all of this,
coming, I suppose, as you saw when I first got the role,
with a little bit of concern, this seemed to be very, as
you said, you know, very strong advice.

However, you know, I was a new Minister. I didn't
really decide anything definitively. We'd got BBC
Panorama coming up and also a debate, perhaps more
important, in the House of Commons.

If we go over the page, please, to paragraph 13:

"ShEx recommended that correspondence from JFSA is
handled at an official level, on the basis that they are
not a recognised organisation and that continued direct
engagement with ministers will serve to prolong their

campaign. We propose to send the response [and there's
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a draft letter at annexe C] from our team. If you would
prefer to reply personally we can adapt the response to
come from you, or (preferably) we can prepare a short
response from you politely declining the offer ... Are
you content for officials to respond from Mr Bates?"

I think you indicated that, in the light of the
draft letter and in the letter out that you've seen, the
answer is that you were, at this stage, content for
officials to respond?
I felt officials should deal with it. Obviously,
I hadn't been given all the background to Mr Bates
because, actually -- Sir Alan, as he now is -- had had
various sort of interactions with ministers over the
years. It would perhaps have been helpful to have known.
a bit more about that but that isn't in any of the
paperwork.
No. In your --
So I obviously wasn't aware of it at that time.
Thank you. In you witness statement, you rely on,
I think, five points to stand up the reasonableness of
you relying on the advice given in this submission to
you. Can I summarise them and see whether I've got it
right.

First, ministers are, as a matter of principle,

entitled to rely on the advice of officials and do so on
25

things, you know, for the post offices, both
commercially and for the postmasters --

And --

-- and for society because the Post Office -- this is

the thing you've got to remember: the Post Office is so
important in almost every village in the land.

Lastly, on the substance, you were informed that there
were no systemic problems with the system, despite years
of investigation and that the recognised union supported
the Post Office and didn't support the subpostmasters?
Correct.

In the course of the briefing, it's mentioned that the

Post Office prosecuted its own subpostmasters and that
the CCRC was reviewing some cases. You tell us in your
witness statement that you took comfort from the fact

that the CCRC was considering some convictions and that
Post Office had agreed to preserve documents
accordingly. When were you first aware that the Post
Office conducted its own prosecutions?

I think I would have been aware of that probably even
before I took over because there are various bits of
Government -- I mean, private prosecutions can be done
by organisations and the Post Office did their own in

the same way as something like the DVLA or the RSPCA,

which isn't even a Government body.
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the basis that the advice they are receiving is itself
‘objective and thorough; is that right?

That's certainly my understanding, my approach, my
assumption in dealings with the Civil Service and the
Government, yes.

Secondly, in this case, the author of this document,
Laura Thompson, appeared to you to be both competent and
across the detail?

True.

Thirdly, you were new in post and what you were being
asked to do was essentially continue what you were
advised was an established Government line?

True, and that, you know, tends to happen, that you have
these established lines which, you know, have gone --

a lot of work goes into and, as a new junior minister,

you know, you inherit those.

Fourthly, the very structure that was embedded was one
of an arm's-length body which could operate free from
political interference and, therefore, the approach
suggested was consistent with had embedded position?
Correct. I mean, I'm not so sure whether that's --

that's not particularly to do with whether you write to

Mr Bates or not but it's my whole approach to the
subject, which is to try and allow the Post Office, as

well led as we can make it, to get on and improve
26

So you were aware, even before you took up this post, as
to the Post Office's private prosecutorial function?

Itisn't something I queried. I mean, I did, in my
statement at the end, question it should have continued
in quite the way it did once you've moved from a public
sector organisation to a more private sector one, but
that's a completely different point and perhaps for

later. Obviously I knew that they were doing that.

But, obviously, they had a large Legal Department,
no doubt inherited from the conglomerate that was
originally Royal Mail plus the Post Office, and indeed,
I think we'd discovered elsewhere, that they'd recently
put in charge a new general counsel, which sounded like
a good idea at the time.

Did you have any concerns, therefore, that the Post
Office that a private prosecution function?

No, I don't think I'd have concerns in particular at the
private prosecution function. Although, with the
benefit of hindsight and knowing what I now know,

I think it's important that institutions like that --

you know, the thing about the -- I'm perhaps
anticipating -- but the thing about the CPS when they
took over from the police is that the CPS can look in
the round at all these cases and say "Is this sensible?"

Now, there's no reason why the Post Office couldn't have
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done that themselves and you have -- obviously, if
you're a prosecutor you have to abide by various codes
and behave properly and look at evidence and worry about
disclosure. So all of that can be done by the Post
Office. But, as I've said elsewhere, once you're
a private operation, the incentives are slightly
different and so that would be the -- that would be the
worry.

But you're asking me, at that time, the fact that
they did private prosecutions I noted, I think I knew
about it and, in any event, they have got audit
committees and all the rest of it to look at, you know,
at the progress of legal cases and prosecutions, which
I obviously knew about from having been a Non-Executive
Director and indeed an Executive Director in lots of
companies. The Prosecution Policy is something, you
know, that you would routinely take a look at, make sure
it was being done properly.
You're referring to your time in --
At Tesco but also in other companies, where I've sat on
the audit committee.
Did Tesco have a Prosecution Policy?
We certainly prosecuted quite a low of shoplifters, and
so on, and we would have -- the Compliance Committee

would have -- obviously, from time to time, would look
29

You mentioned that the -- I think did you say the
Security Director would come and report to you?
Yes.
What would he or she report?
Well, they'd write a paper on these are the things that
had happened over the last year or six months, or
whatever the period was, and, you know, we've had X
prosecutions and successful or unsuccessful, and we've
nagged away at the Home Office to help a bit more and
all that sort of stuff.
Thank you. You tell us -- and you mentioned it a moment
ago -- at paragraph 290 of your witness statement, that
the arrangements allowing the Post Office to pursue
their own prosecutions should have been ended at
privatisation when they ceased to be part of Government:
"Prosecution decisions should be made independently
and impartially whereas here there were financial
incentives for prosecuting.”
Firstly, I take it that's a view that's emerged
after your time in office --
Correct.
-- in the light of the events which have happened --
Correct.
-- and been revealed. But, secondly, why do you draw

the link between the ending of the prosecution function
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at the number of cases and the Security Officer would
come and talk to us about that sort of thing.

Was that a function of Audit and Compliance or Audit and
Risk Committee?

We didn't have a Risk Committee, we had an Audit
Committee, which was made up of Non-Executive Directors,
but I attended in my capacity as Company Secretary. And
then we also an Executive Compliance Committee, which
during the period I was Company Secretary, I used to
chair. So, you know, I was knowledgeable about that
sort of thing.

Just help us, the document can come down from the
screen, it may be an interesting point of comparison,
what level of scrutiny in a fully private company,

Tesco, was given in that committee to prosecution?

I think it would tend to look at numbers but, if you had

a sort of difficult case and arguably what we're talking
about here were quite a lot of difficult cases with

publicity, then they would have been looked at by the,
you know, by Non-Executive committees, as well as
Executive committees, and we'd have a sort of legal
annexe and, I mean, I've had that in other companies
which I've chaired or sat on as a Board. You would know
what was going on in the legal area and that would be

a combination of tribunals, prosecutions, et cetera.
30

and the event of privatisation?
Well, I think, obviously, if you're a governmental body
it's fair enough that, if there is fraud or harassment
or whatever, that, you know, you would have a Legal
Department and that could bring prosecutions or you
could take them to the CPS if you wanted them to do it.
I think once, you know, you've privatised a whole thing,
you know, you've got to set up -- you've got to have
a proper Legal Department and, as I said, I think it
must have been split between the two bodies and, in
a commercial operation, especially where there seemed to
be some sort of benefit to the Post Office from the
prosecutions in that, you know, the money -- they were
recovering money which then goes into their bottom line,
or it was sitting in an account, then that -- the, you
know, the -- there's a slight -- a sort of slight
inherent conflict of interest would be my concern.

So either you could stop prosecuting and I think
they did stop prosecuting all the Horizon related one
I even took over. I may have to check that. So it's
important that either you don't prosecute and you get
the CPS to do it or you set up a proper system of kind
of reviewing the cases to make sure that you're learning
from mistakes. And, in a commercial company like the

ones I was used to, you know, learning from mistakes was
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‘one of the big features that a Compliance Committee
would always look at, you know, have we done it this
right way? You lost a case, you know, why was that? Or
there seems to be an awtul lot of these different
things.

I remember, for example, on slips and trips in
stores, we actually changed the whole system because we
discovered we were having a great many cases on that,
and people perhaps slipping over, hurting their foot,
and then coming back and taking a legal case against us,
which took ages.

So we changed the whole system so that remedies
could actually be addressed straight away in the store,
that you would apologise to the person, take them home,
send them flowers, if necessary give them some sort of
minor element of compensation. And that stopped -- that
stopped -- it's an example of learning from mistakes --
it stopped us having so many cases and, you know,
customers getting a remedy much more quickly.

Q. You mentioned that, by the time that you were in office,
the Post Office had stopped prosecuting cases based on
Horizon.

A. Mm.

Did you know that at the time?

2

A. I mean, I'm not sure when I learnt it but I did find
33

A. The individual detail of who exactly did it. There
weren't as many prosecutions as I know many store
managers wanted, which perhaps suggests to me we were
using CPS rather than doing it ourselves but perhaps
I could come back to you on that point, if that's
permitted?

SIR WYN WILLIAMS: Yes, of course it is. Thank you.

MR BEER: Thank you.

We saw very briefly that the second annexe to the
briefing note of the 2 June 2015 was the draft letter to
Alan Bates declining a meeting with you and you accepted
the advice that you should decline the meeting and
therefore didn't meet him. You had, however, been asked
to meet Paula Vennells, by this time the CEO of the Post
Office; is that right?

A. Yes, the original briefing had a sort of table of things
that I should do as Minister, and that included meeting
the CEO, which seemed very sensible.

Q. That meeting occurred relatively early in your period in
office; it was 11 June, I think, 2015, and you received
a briefing for it two days beforehand on 9 June. Can we
look at that, please. It is UKGI00001074. 9 June.
Again, it's from Laura Thompson to you, for a meeting on
11 June. You'll see the proposed attendees additionally

included Al Cameron, Kevin Gilliland and Mark Davies.
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that out. So, given there was an uncertainty, which
became more and more apparent as we went through the
year, that was obviously good news that they weren't
continuing when you've got these outstanding cases which
were before the Criminal Cases Review Board. So that
was extreme -- obviously a sensible thing to do.

Q. Was it revealed to you that the reason that the Post
Office stopped prosecuting, or the reasons included,
that the Post Office could not find any expert witness
who would testify as to the integrity of Horizon or the
data that it produced?

A. No, I wasn't aware of that until this Inquiry.

Q. We saw that the --

SIR WYN WILLIAMS: Before we leave prosecutions, Mr Beer,
can I just -- it's a very minor point but I wanted to be
clear about it. When you were talking about your time
at Tesco, Baroness, you said, "We prosecuted
shoplifters". Just so that I'm clear, do you mean by
that that Tesco took out private prosecutions or do you
mean you reported them to the police, who then
instigated a prosecution via the CPS?

A. It's a very good question, Sir Wyn, which I'd like to
come back to you on because I wouldn't want to mislead
you. I mean, obviously prosecutions were taking place.

SIR WYN WILLIAMS: Sure.
34

Tim McInnes from ShEx would also attend.

Under "Background":

"This is your first meeting with Paula Vennells
since you became the Minister for the Post Office.
Paula has tended to meet with ministers 2-3 times per
year."

It says:

"[She] will want to give you an overview ...

"... will also want to discuss the [away day].’

Then over the page, please. "Main issues to
discuss", I'm going to speed through these: long-term
strategy; financial performance; Network Transformation;
banking; then over the page, Horizon:

"Paula may want to reassure you that [Post Office]
are handling the issues relating to the Mediation Scheme
set up in connection with their IT system, particularly
the forthcoming BBC Panorama programme ...

“It remains the case that there is no evidence of

systemic fault within the IT system. We ... have
communicated to [Post Office] that the Government
maintains that the Mediation Scheme and cases within it
are independent of Government. [Post Office] are
supportive of that approach."

So essentially a repetition of the briefing we saw

in the 2 June 2015 pack?
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Now, there is no surviving minute of this meeting,
we are told. Have you any reason to believe that the
meeting didn't track the briefing and, therefore,
firstly, Horizon formed only a small part of your
discussion; and, secondly, that you weren't told
anything other than is set out here?
Yeah, I mean, on Horizon, this would be my recollection
of what I was told by Paula and others from POL at that
time and the meeting will have -- I think was more
wide-ranging and I was interested in the transformation,
the commerce, how they were going to retail and more
general issues and the Premium Bonds were at some
stage -- I remember agreeing to go and see the Treasury
Minister, very unsuccessfully, to get the Treasury to
continue to use post offices for their -- for selling
some of their products.
Thank you. Can we move forwards in the chronology then
to the BBC Panorama programme, the Adjournment Debate,
which eventually led to a meeting between MPs and the
Post Office. Can I use your witness statement to track
this part of the chronology please, page 12,
paragraph 46.
Paragraph 46 is at the foot of the page and you say:
"On 24 June 2015, Laura Thompson sent a submission

to both me and George Freeman ... regarding a BBC
37

the problems with Horizon and that 'the past three years
have underlined the confidence we have always had in
Horizon -- it has been found to work as it should’.
Ms Vennells set out in her letter that [Post Office] had
found nothing to suggest that any conviction was unsafe,
and that [Post Office] took ‘great care’ regarding its
continuing duty of disclosure on all matters including
full cooperation with the CCRC ... This was of a piece
with the information I was being provided by ShEx. We
now know, of course, that it was seriously misleading.”
Moving on, you tell us in paragraph 51 that on the
29th Andrew Bridgen called an Adjournment Debate:

a number of MPs called constituents’

complaints. Mr Bridgen stated that he and a number of
colleagues had ‘lost all faith and trust in the Post
Office's willingness to investigate the issue ..."
criticised the Mediation Scheme, and called for a public
inquiry. George Freeman ... referred to the striking
degree of concerning expressed by Parliamentarians at
and in the lead-up to the debate, and offered to convene
a meeting between MPs and [Post Office] executives in
which the issues could be discussed."
Then moving on, please, to paragraph 52. You say:
"I understood that at least some subpostmasters were

losing, or had lost, trust and confidence in the
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Panorama programme ... which was due to be broadcast on
29 June (though it did not in fact air until 17 August)
... This was in timed to coincide with an Adjournment
Debate called by Andrew Bridgen MP, and the submission
indicated that both Mr Bridgen and James Arbuthnot were
understood to be involved in its making. It stated that
the programme was expected to be ‘highly critical’ of
[Post Office]. Ms Thompson again advised that Horizon
‘is a matter for Post Office and subpostmasters and it
would be inappropriate for Government to intervene’."

Then over the page, please, paragraph 47:

"The Post Office had fallen within my portfolio for
around seven weeks by this time and I could see
a pattern emerging: it was the consistent advice of ShEx
that these matters were independent of Government, that
[Post Office] was dealing with the various matters
appropriately, and on Horizon that there was no evidence
of any systemic problem despite rigorous independent
testing, and that I should not be interfering."

Then if we go further down the page to paragraph 50
you say, although you didn't see it at the time:

"... [have since been provided with a letter dated
26 June from Paula Vennells to George Freeman in advance
of the Adjournment Debate, in which she stated that

[Post Office] had gone to ‘great lengths’ to investigate
38

Mediation Scheme, whilst at this time ShEx officials
were telling me that 'Post Office have put a great deal

of effort to be helpful and transparent here, yet are
constantly denounced for their approach and their
apparent 'contempt' for MPs without any real evidence to
demonstrate why. They accepted the seriousness of the
situation and are committed to resolving it but are
becoming increasingly frustrated by the attacks .

You say:

"I was keen to preserve the Mediation Scheme, see
the CCRC reach conclusions and encourage engagement
between the subpostmasters and Post Office. I agree
with George Freeman that the way forward was to bring
the interested parties together and at least provide
a forum for open, frank and sensible discussion [that]
would not have happened had [you followed] ShEx's
advice."

Can I look at the exchange in which you agreed with
Mr Freeman's approach. WITN10200103, please.

Can we start with page 3, please. There's an email
from 1 July from Laura Thompson to your private office
and Mr Freeman's private office, amongst others; can we
see that? Ms Thompson says:

“Andrew ..."

He was one of those that worked in your private
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office, the person you referred to earlier; is that
right?

Yes.

"Please see attached submission [sent to the pair of

youl]. It follows up on Monday's Adjournment Debate in
the Commons on the Post Office Horizon system, which is
Baroness Neville-Rolfe's policy lead but the debate was
taken by George Freeman.

"The submission recommends how we meet the
commitment made by Government (and repeated at [Prime
Minister's Questions] today) to convene a meeting on
this matter. There are draft letters for [you] to send
to Andrew Bridgen (who called the debate) and Paula
Vennells, Post Office CEO."

Then if we go to the bottom of page 2, please --
thank you -- can you explain who the email is from and
to here?

So that's to me, myself, from my private secretary ~

So --

-- attaching a submission, yes.

-- Andrew Smith, your private secretary, using your
private office email address, sending it to you, in

a personal email; is that right?

In a personal email, probably my Parliamentary account

but obviously it's not clear from there, yes.
41

invited to the meeting. So officials, in this context,
would that be from ShEx?
Yeah.
So, so far we've got Mr Freeman and his antennae maybe
twitching a little by him saying, "I think it's
important, I strongly believe that Second Sight should
attend this meeting"; ShEx recommending strongly that
they're not, to your private office; and then you reply
about an hour later, we can see it at the top there:

"I am uneasy about overruling George Freeman and am
not sure about excluding others."

So, at this point, officials were trying to persuade
you to exclude Second Sight from the proposed meeting;
your ministerial colleague and you disagreed?
I disagreed, although in the end I think I agreed to
a meeting without Second Sight, but we'll --
But we will develop.
-- come on to that, because they went on nagging away at
it and I was keen to get the meeting to happen. Anyway,
perhaps we can -- but that's right, I was uneasy, you
know but then they had reasons, which presumably we'll
come on to.
If we scroll up, please. Your private secretary sends
your reply back to ShEx, in particular Laura Thompson.

Then scroll up, please, and then a little further, about
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Q Yes.

"Minister,

"Please find attached a submission on the Horizon
Adjournment Debate outlining next steps. Officials are
keen for the draft letters to issue [ASAP]."

Skipping a paragraph:

"George Freeman's comments as relayed by his private
office are ‘The Minister considered your advice and he
is somewhat content. However, he feels strongly that
Second Sight and George Thomson (NFSP) should be
invited. He commented that the MPs focused on Second
Sight and it would not be a satisfactory meeting without
them. He agrees that JFSA should not attend’.”

So here you're being told that there's a submission,
including draft letters, to go out to Paula Vennells and
Andrew Bridgen, who called the debate, that this has
been run past your colleague in the Commons, George
Freeman, and he said that he felt strongly that Second
Sight should be invited to attend the proposed meeting,
correct?

Correct.
Then, if we scroll up, please.

Mr Smith writing to you, about half an hour later on
the same day, saying that he had just had a call from

officials who recommend strongly that Second are not
42

an hour later, a long email from Laura Thompson. So
she's called in, or somebody from ShEx has called in,
saying, "We think it's a bad idea that Second Sight are
invited to this meeting", and then this is followed up
by a long email we'll see, taking the same point.

Laura Thompson says:

"I understand the Minister's concerns about
excluding people, and that George Freeman is in favour
of inviting Second Sight because MPs focused on them.
However, I would still recommend strongly that they are
not invited to the meeting. The legal risk to Post
Office (and, potentially, Government) is significant if
this meeting prejudices the work of the [CCRC]."

So, at this point, ShEx had had an attempt to
exclude Second Sight by calling your private office, and
they're trying again in this email, and raise a point
that there's said to be a significant risk to the Post
Office, legal risk to the Post Office, and indeed to
Government, by prejudicing the work of the CCRC by
meeting Second Sight; did you or do you understand the
logic of that position?
I mean, I don't know what I thought at the time but what
I would say is, if I'm told that something prejudices
the work of the Criminal Cases Review Commission, I take

that seriously and, clearly, officials, who at that time
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I had no reason to believe were not doing anything that
was not in my own interest, were saying that we

shouldn't have Second Sight and it seemed to me that the
key thing was to see the MPs and hear what they'd got to
say and to get them to actually talk to the Post Office,
because there seemed to be something of a stand-off
between these MPs and the Post Office, which was why

I was keen to have a meeting and hoped that it would be
constructive. Perhaps over-optimistic at the time, but
that was my approach.

Ms Thompson continues:

... we have very grave concerns that, based on
Second Sight's conduct to date, they will not respect
confidentiality or the terms of their engagement either
during the meeting or afterwards. We understand
(although cannot confirm) that they have links in to
JFSA and strongly believe their presence in the meeting
will do more harm than good."

Then she adds a second point that:

"... the Post Office are extremely worried about the
risk to their business from this meeting, particularly
around legal issues like the CCRC. I'd be concerned
that inviting Second Sight could be a red line for
them -- we would have to consider what would happen if

this were the case, but I think it is important to
45

meet the MPs and talk to them about their concerns and,
you know, not actually having Second Sight present.

I mean, that didn't seem to me to be a killer point.

The key point was to get on and have the meeting. We
could always have another meeting with Second Sight on
another occasion, if that's what turned out to be
necessary.

Thank you.

But, I mean, I have to say, in a busy day, this is going
backwards and forwards, it was probably, you know,

a snap judgement, "Let's get on, let's have the meeting
and let's invited the Post Office to come", although

they didn't in fact send the CEO, which was

a disappointment to me, as you'll see from later
documents.

We're going to come to that after the break.

Before we do, can we see what happened by looking at
your witness statement, page 16, paragraph 58, please.
Much as you told us, you say:

"The key thing, from my perspective, was to get the
MPs together in a room with Paula Vennells and [Post
Office] executives and hear what they had to say. I was
aware that the relationship between [Post Office] and
Second Sight was not healthy, and thought it would be

easier to get Ms Vennells to attend if they were not
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remember that Post Office have put in a great deal of
effort to be helpful and transparent here, yet are
constantly denounced for their approach and their
apparent 'contempt' for MPs without any real evidence to
demonstrate why. They accept the seriousness of the
situation and are committed to resolving it, but are
becoming increasingly frustrate by the attacks against
them and it is not clear what more they can do --
remembering, as we mentioned to the Minister, that [Post
Office] are effectively fighting with one hand behind

their back because they are respecting confidentiality
when others are not.”

So this is taking a separate point: never mind the
merits of the situation, the Post Office might consider
this a red line and this is another reason to exclude
Second Sight?

Yeah, I think the main point is about prejudicing
criminal work somewhere else or civil work somewhere
else. Obviously, this is perhaps the first example of
Post Office -- of ShEx very much taking strongly a Post
Office line and bringing that through, which is
interesting.

But I took the view that we'd promised a meeting,

a meeting promise had then been repeated by the then

Prime Minister, David Cameron, and that I was keen to.
46

there. I also took at face value the concern that

Second Sight presented a risk of leaking what was said
at the meeting, and also thought it was important to
avoid the meeting descending into a discussion of
individual cases. The point was to have a productive
discussion between MPs and [Post Office] senior
management as part of a process to ‘get to the bottom of
the matter’, and it seemed most likely that that would
happen without Second Sight at this stage.”

Then you tell us you did later subsequently meet
with Messrs Warmington and Henderson. So some letters
went out, can we look at those, please, UKGI00004820,
a letter of 2 July to Andrew Bridgen. Scrolling down,
thank you -- just a little bit further -- sorry, no,
further up:

"lam writing as the Minister responsible ...
further to your Adjournment Debate ... I would like to
follow up on the offer [of George Freeman] by inviting
you to attend a meeting at the Department to discuss
this matter."

You mention in the next paragraph the Mediation
Scheme, and confidentiality and the importance of
maintaining it.

In the third paragraph, the fact that the CCRC has

received applications from individuals in the scheme.
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Paragraph 4, you say:

"The Government acknowledges the concerns that [MPs]
raised during the Adjournment Debate."

Paragraph 5:

"The Government wants to ensure that MPs take the
‘opportunity to raise their concerns directly with Post
Office. At the same time, the Government would like to
allow the Post Office a further opportunity to address
the very serious accusations that have been made against
it. The meeting will provide an opportunity for both
MPs and Post Office to understand each other's views
better, while maintaining the confidentiality of
individual cases and respecting the work of the CCRC."

Then over the page:

"This will be a private meeting and I will be
writing in similar terms to the Post Office to invite
them to attend."

Then can we look at POL00027 164, a letter on the
same day to Paula Vennells, the CEO of the Post Office.
If we just scroll down, you'll see it's in very similar
terms, so an equivalent letter. Both letters were, in
fact, silent, I think, on the issue of Second Sight
attendance.
I think they did say we might have another meeting or

something, on a future -- I mean, there's
49

attend", and that you found some time to speak on
Tuesday morning in advance of the meeting.

Ms Vennells continues:

"As you know, we have been open and transparent with
MPs throughout this important process and have met
Mr Bridgen previously with some of his fellow MPs.

"Regrettably, it is clear our engagement has done
little to address his concerns. Since our last meeting,
Mr Bridgen has on he occasions refused our offer of
a further meeting, most recently last week. We have
also offered every MP with a constituent in the Scheme
the opportunity to discuss with us, subject to
[consent]. Just three MPs have taken up this [offer].
over the last three years, the Post Office has
been trying to address a small number of individual,
private, complaints brought to it by (mostly) former
subpostmasters about problems they experienced whilst
working in their post offices. Despite the finding of
an initial investigation that our computer system did
not suffer from systemic flaws, we established a scheme

all cases have been comprehensively
reinvestigated and independently reviewed and all of
this work has been shared with individual applicants ...

It is worth reiterating that in none of the cases has
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a possibility -- silent, if you go over -- keep going.
So if we scroll down a little further.
Yes:

"Following this meeting we will consider whether any
additional further action or meetings required."

I think I kind of might have put that in to -
I can't remember but that --
But it doesn't explicitly say ~
It doesn't explicitly --
-- Second Sight will or will not --
It doesn't say Second Sight are being invited, it
doesn't say Second Sight aren't being invited, but it's
trying to set up a constructive conversation, try and
get two sides a little bit closer together.
Can we look at the reply from Paula Vennells.
UKG100000026, her reply of 10 July to you.

“Thank you for your letter of [the 2nd].

"Post Office is, of course, willing to attend
a meeting to discuss these matters and I note that it
has been set up for Wednesday. Unfortunately, this
coincides with a Post Office Board meeting; therefore
I hope you will accept my apologies. My colleagues,
Mark Davies, our Communications and Corporate Affairs
Director, and Patrick Bourke, who leads the Post Office

team dealing with the Scheme, will be pleased to
50

our computer system been shown to have caused the losses
complained of and in none of the cases has any evidence
medicine to suggest that convictions are unsafe."

Then over the page.

"Instead, in a majority of cases, it is clear from
the evidence that errors made in branch are responsible
for the problems that arose. In some other cases, the
Post Office acknowledges it might have done more to
support individual subpostmasters ... In a last group of
cases (thankfully a minority), regrettably,
subpostmasters have committed criminal offences, either
by dishonestly covering up losses, or by stealing money,
or both."

Skipping a paragraph:

"In cases involving a criminal conviction, our
investigations reveal that the facts on which the
convictions were based cannot be distinguished from the
says raised by applicants to the scheme. Therefore,
mediation is not appropriate as it is not capable of
producing the principal outcome sought ... because only
the courts can overturn a conviction."

Skipping a paragraph:

"As you note, a number of these applicants have
asked the [CCRC] to look into their cases and it would

be highly inappropriate to do anything which might
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interfere in its work ...

In short ... applicants to the Scheme have a choice
to sit down and mediate their case with the Post Office,
litigate the civil courts or pursue any claim of
miscarriage of justice through the established
processes. Given these clear choices ... it is not
immediately clear what the Post Office could offer
beyond restating the choices ... However, we will try to
address as many of the concerns expressed by MPs as we
can.

"Finally, and while you do not mention them in your
letter, there have been suggestions that Second Sight
should attend a meeting. As Second Sight has no
standing in the disputes between the Post Office and
applicants ... we do not consider their involvement to
be necessary or appropriate.”

So Ms Vennells seems emphatic that you and the MPs
should not meet Second Sight, yes?

Certainly she doesn't want Second Sight at that meeting.
We know that, by this time, Post Office knew there were
bugs, errors and defects within the Horizon system and
that Second Sight had discovered some of those bugs. We
know that the Post Office, by this time, knew that forms

of remote access by Fujitsu to the system were possible,

including a form of remote access by which financial
53

you're describing him -- I think later he's described as
the Government Affairs Director --
Yes.
-- whereas obviously my hope would have been that Paula
Vennells herself would have turned up, so that one could
have made some progress, rather than people who were, as
it were, managing the MPs and managing -- you know, even
tying to manage the ministers. So that -- so that was,
I think, regrettable.
We have seen the reason that Paula Vennells gave for not
being able to attend was a diary clash?
That's what that says and that's what I took at face
value --
Yes.
~ although --
Have you seen information since then?
Well, I think somebody mentioned to me, but I can't give
you chapter and verse, that, actually, there was advice
that she shouldn't attend the meeting, which is
a slightly different point, clearly. I understand the
importance of Board meetings. I don't know what the
exact timing clash was.
Let's just look at that, please, POL00388295.

And look at page 2 first, please. If we scroll

down, please:
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data at branch level could be amended by the insertion
of transactions into an account, without the
subpostmaster's knowledge, and that Second Sight, on the
basis of some whistleblower evidence, had discovered
some of this.

We know that, by this time, the Post Office knew
that its principal expert witness in criminal
prosecutions was said to have breached his duties to the
court and to have given misleading evidence to the
court, but the Post Office had decided not to reveal
that information either to Second Sight or to convicted
defendants.

Did you know any of those things?
I didn't know any of those things, no, but I'd also note
that Paula Vennells didn't come to the meeting.
I suppose if she knew -- and she's written this letter,
which, certainly, if that was known to her, is odd that
there's absolutely no suggestion of any hesitation or
concern on any of those points at that point in time.
She didn't come, she sent the -- Mr Davies who was
communications person.
And Mr Bourke, the Corporate Affairs Director?
And Mr Bourke. At that time, I remember that, I asked
who was this person, and I was told, well, he was the

person in charge of the Mediation Scheme but, actually,
54

"Please see attached that has just arrived."

That's your letter.

"I assume we should seek to respond quickly.

“It is still my view that Paula should not attend
but should perhaps speak to [Baroness Neville-Rolfe]
beforehand? I am very open to contrary views."

That's Tom Wechsler, Ms Vennells' then Chief of
Staff.

Then scroll up, please, to see what the
Communications Director said.

"I agree re Paula point and this was also her view
when we spoke this morning. And I also agree that she
should speak to her in advance."

I think that means "I agree that Paula Vennells
should speak to Baroness Neville-Rolfe in advance":

"I suggest we reply as warmly as possible,
especially as the letter is from [you].

Then scroll up, please.

"I share that view re Paula", says Patrick Bourke.

Then scrolling up, please, Tom Wechsler then agrees
re attendees and I think that's the end of it.

So, at the time, you wouldn't be aware, presumably,
that various Post Office PR and communications people
were providing advice behind the scenes to Paula

Vennells that she should not attend the meeting with
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you? You took at face value what was said in her
letter, that she had a diary clash.

A. I took it entirely at face value and, of course, it's
a Board meeting and you do try to respect ~- if you're
a Director, you do tie to make sure you do go to Board
meetings. So it was a perfectly valid excuse but I was
somewhat perturbed when I subsequently saw this, that
actually it was strategic rather than a diary clash.
Because I think, having her there would have been good,
because she would have had to listen to the MPs’
concerns and answer them herself.

MR BEER: Thank you.

Sir, that is an appropriate moment for the morning

back. Could we break until 11.25, please?

SIR WYN WILLIAMS: Yes, certainly.

MR BEER: Thank you, sir.

(11.11 am)
(A short break)
(14.25 am)
MRBEER: Good morning, sir. Can you continue to see and
hear us?

SIR WYN WILLIAMS: Yes, thank you.
MR BEER: Thank you.
Baroness Neville-Rolfe, can we turn briefly to what

happened at the meeting between Post Office and the MPs.

57

legal representatives. I believe they also raised
concerns about document destruction.

"63. I recall thinking that the concerns expressed
by Andrew Bridgen and Kevan Jones needed to be taken
extremely seriously.”

You say, skipping a paragraph:

"This meeting, which took place within 2 months of
my taking up the postal affairs role, was an important
step. Amongst other things, it brought home that the
processes in place -- including mediation and the CCRC
process -- were not working satisfactorily. More
generally I was from the start surprised that so many
people from normally reliable sections of the community
were being convicted of dishonesty. This was
troubling.”

On that last sentence there, can you explain more
generally what you meant, please?

A. As I got into the individual cases, which earlier on I'd
been discouraged from thinking about, it became apparent
that these were honest citizens who perhaps had, on
retirement, bought a -- I think if you buy a Post
Office -- I'm not quite sure what the arrangements
are -- people like Lord Arbuthnot's constituency,
I think is in Hampshire, you know, leafy, middle-class

people, who suddenly, out of the blue, with no even
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Is it right that you essentially chaired or facilitated
the meeting?

Yes, I chaired it, as would be normal with a ministerial
meeting.

Can we turn to page 17 of your witness statement,
please, and look at the foot of page 17. At

paragraph 62 you say:

"The meeting between MPs and [Post Office] was
attended by Andrew Bridgen, Kevan Jones [they're the
MPs] Mark Davies ... Patrick Bourke ... Laura Thompson
... and [you]. A note was drafted by Ms Thompson ..."

You give the reference to it, I was going to give
your witness statement instead to address what happens.
You say:

"The note records that Messrs Bridgen and Jones
outlined their concerns relating to some individuals.

The concerns focused on the length of time the issue had
been ongoing and the view of the MPs that [Post Office]
had acted with a lack of transparency in dealing with

the claims that there had been problems with Horizon;
the way in which [Post Office] had used its powers of
prosecution; the length of time it took for cases to
progress through the Mediation Scheme; concerns about
miscarriages of justice where individuals had been

advised to plead guilty to false accounting by their
58

suggestion that they had either themselves or any of
their friends and relations been involved in anything
dishonest, was suddenly ending up in court and being
convicted, mainly, I think, on grounds of false
accounting but in some cases of theft, and that just -
I'd got all this evidence that everything was fine, that
there was nothing wrong, that there'd been
an independent inquiry which actually told us that the
Post Office was right, and yet the people who were, as
it were, going down were terribly honest citizens.
I have to say this is the thing that worried me.
You know, I have come from business and I'd also come
from the Civil Service and, you know, it's not -- it's
not only keeping the business going, it's having
an element of common sense and thinking about your
Staff. So that -- so that was what worried me, but
I didn't actually have any information to support my
case until I had this meeting and Andrew Bridgen and
Kevan started to, you know, list some of these points.
That was my sort of road to Damascus, if you like,
beginning to realise that there were quite small
numbers -- we were talking about I think about three or
four MPs at that time -- who'd had these very
unsatisfactory experiences with what I call Middle

Britain.
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Thank you. Can I check with you whether a couple of
issues were addressed at the meeting, by firstly looking
at POL00027729, which is an email -- you wouldn't have
seen this at the time, it's internal to the Post
Office -- from Mark Davies on 15 July, at 8.17 in the
evening, to, amongst others, Jane MacLeod, Paula
Vennells, Angela van den Bogerd and he says, if we
scroll down:

"All

"Patrick and I met with Andrew Bridgen and Kevan
Jones today, at a meeting chaired by [you].

“The meeting was held up as Mr Jones was late.
Mr Bridgen then ran through his central points.

"This included no new allegations and was broadly
a repeat of his Adjournment Debate script. He raised
some new unnamed cases ...

"He accused the Post Office of:

“Abusing its prosecution powers and using plea
bargaining to 'cajole' people into accepting guilty
pleas.

“Curtailing Second Sight's work and the Mediation
Scheme.

"Reducing scope of [Second Sight's] work and forcing
[Second Sight] to moderate its reports.

"Not cooperating with [Second Sight]."

61

actually got given the keys to Horizon.
So did you know about the one-sided nature of the
contract at the time?
I think I knew after this meeting. It wasn't referred
to in any of the briefing that I'd had prior to that
from ShEx, that I've noticed. But I mean, obviously
it's difficult for me to remember 10 years hence when
I learnt what I learnt. But it was a sort of -- I was
gradually learning, from listening to these outsiders,
what their problems were, and one of the problems, it
seemed, was the contract arrangements. And, of course,
I know now because I have been given information about
what eventually happened that was that the contract was
a key issue in the Fraser judgment.
Lastly, Mr Bridgen accused the Post Office of:

"Using Bracknell and remote access to target and
implicate postmasters of wrongdoing."

Then:

"[Kevan] Jones endorsed the above and accused the
Post Office of:

"Using the Mediation Scheme as a smokescreen to pass
the Statute of Limitations.

"A deliberate and planned cover-up.
Leaning’ on [Second Sight].

‘Gagging’ Panorama.
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Then this:

"Having ‘Dickensian’ contract arrangements with
postmasters, ‘suspicious’ suspense account procedure and
an inadequate helpline.

Have you any recollection that the contract itself,
said to be Dickensian, which was rather prophetic
because that's how the Court of Appeal was subsequently
to describe it in similar terms many years later,
whether that was raised?

Well, I have no reason to believe that it wasn't. After

all, it's on a memo from POL saying what came up, which
disturbed them and, clearly -- I probably knew at the
time that the way it works is that a subpostmaster is
almost like -- is a kind of agent responsible for all
their -- you know, for everything that they do and that
was no doubt incorporated into the contract. It's
a very one-sided arrangement but then, I think, to be
fair, post offices entered into that knowing that it was
a one-sided arrangement and thinking that they would be
able to cope with that because, you know, often they had
a lot of experience of running small businesses and
things when they took over post offices.

You weren't -- didn't become a subpostmaster
overnight. You know, there was some sort of, I assume

there was some sort of vetting procedure before you
62

"He accused Patrick and I of lying to him and
Mr Bridgen in the meeting. We did not.

"The MPs asked the Minister:

"To call an independent inquiry.

"To meet with Second Sight.

"They asked us:

"To provide details of how much we paid out to
settle claims.

"We agreed:

"To write to both MPs reiterating our offer to meet

"It was a very unpleasant meeting at which Patrick
and I were robust but respectful in making our case in
[the] face of an approach which was volatile and at
times aggressive.”

Do you remember these two MPs being volatile and
aggressive?
To be honest, this isn't my note of the meeting and
I didn't see it at the time and, if I had, I think that
was probably a little bit unfair on them. They were
actually explaining clearly what their concerns were in
detail, which frankly was exactly what I wanted in
having the meeting.
Scrolling down under "COMMENT", Mr Davies says:

"This was a very difficult meeting. We now need to
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ensure that the Minister [that's you] understands the
position. While she was supportive, there is a risk
that the complexity of the issue, plus MP interpretation
of that complexity, causes the search for simple
‘solutions’ which we know do not exist."

Then, at the foot of the page, second paragraph up:

"The Minister did appear to agree that it would be
rather difficult to make progress if the MPs refused to
engage with the rest of the story."

Can you recall which commitments you made, if any,
at the conclusion of the meeting?
I'm sure I will have said that I would reflect further
because that would have been standard practice and
I think I encouraged the MPs to talk to the Post Office,
because there'd been the stand-off between them and it
looks from this as though there was some acceptance by
Mr Bridgen. There was also a point about documents.
There seemed to be concern that documents were being
shredded, which would be helpful to the unfortunate
people who'd been prosecuted, and I do recall -- I don't
know -- probably as a result of this meeting -- that
took some steps to do something about that, because
obviously, given my commercial background, I was very
aware of the importance of not shredding documents, even

very old documents, and of your legal duty, particularly
65

important and pivotal he was. So I was obviously keen
to talk to him, and I did later meet him, and, you know,
he's played a crusading role in all of this.

Can we see what ShEx's follow-up was to the meeting by
looking at UKGI00015226. This is 17 July, so two days
later. The "Purpose", says Ms Thompson, is the:

"Next steps following your meeting on Wednesday,
with MPs [with a recommendation] That you:

“Note that the Post Office will write to
[Messrs Bridgen and Jones] to reiterate the offer of
a meeting and provide information relating to some of
their concerns.

“Agree that you would like to meet James Arbuthnot,
as discussed in the meeting and confirm whether [or not]
you would like officials and/or Post Office to attend.

"Decide whether you would like to write to
Sir Anthony Hooper ...

“Agree that you should write to the Prime Minister
following your meeting with James Arbuthnot ..."

I just want to explore the last of those, please, by
looking at paragraph 9 of the note, which is over the
page. Ms Thompson says:

"Following your meeting with Mr Arbuthnot and, if
appropriate, Sir Anthony, we recommend that you should

write to the Prime Minister, to set out your assessment
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if you were an actual trained lawyer, you know,
a barrister or solicitor, not to shred documents.

So I think I recall that coming out of it and,
‘obviously, I went away and, you know, wanted further
meetings to discuss what might be done.

Thank you. That can come down.

You tell us in your witness statement that at about
this time - it's paragraph 65, no need to turn it up:

"All of the advice I was receiving regarding Horizon
was from ShEx. This was supposed to be impartial and
balanced. However, my faith in that advice was
beginning to wane. I now wanted to hear different views
and wanted to apply some more independent scrutiny to
the issue than had been offered to date by ShEx and, at
that meeting, I agreed with Andrew Bridgen that I should
meet with James Arbuthnot MP."

Because this meeting therefore one of the turning
points in the unfolding picture?

Definitely. I think the MPs played an important role,
you know, in articulating the issues and articulating

the problems in a way that perhaps the experts, Second
Sight and things, were not able to do, and I think James
Arbuthnot was probably -- may have been invited to the
original meeting and hadn't been able to come, I don't

know. But it became apparent from that meeting how
66

of the situation and the Government's position, having
‘got to the bottom of the matter’, to use his word:

I think they're the words that he used in PMQs.
Yes.

"We strongly recommend that the Government comes to

an agreed position, and ideally should communicate

whether it will take any action. We advise that the

priority should be to put this issue to bed -- continued

uncertainty and allegation does damage to Post Office's

business and prevents those individuals with cases from

reaching a resolution. We will provide further advice

‘on this [and] propose your office sends a short note of

the meeting ... to the Private Secretary at Number 10."
What did you think to this suggestion that you

should write to the Prime Minister to set out your

assessment of the situation, having got to the bottom of

the matter?

Well, I think I had two concerns about this. One was

I wasn't sure I'd yet got to the bottom of the matter,

and the second is, it's not really appropriate for

a Parliamentary Under-Secretary of State to write to the

Prime Minister. I'm not sure that's -- perhaps

Ms Thompson didn't really know that. That is something

that would go through the Secretary of State or the

Secretary of State's office.
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So, for those two reasons, did you ignore the
suggestion?
So I said -- I'm sure I didn't agree to it although it
comes back because they then produce draft and it goes,
takes days on end to go round through lots of different
people and then comes back to me to sign off, to look at
anyway, but it's not my note. So clearly the Prime
Minister had been involved at PMQs, so it's not
unreasonable that there should be feedback to Number 10
but certainly I wasn't in a position to write saying I'd
got to the bottom of it and, more important, it would
have been a first time that somebody, you know,
a Parliamentary Under-Secretary, had kind of written to
a Prime Minister on a business issue from their
Department because that seemed to me to be not what
normally happens.
So there a protocol or convention issue but then there
was an issue of substance as well?
There was substance and protocol which came together,
which means I, in your words, probably for that time
ignored paragraph 9.
Thank you.

I think it's right that the next step in the
chronology -- that can come down, thank you -- is

essentially the provision of the Second Sight Part Two
69

itself (ie 'Horizon’ and ... ‘Horizon Online’), and even
more narrowly on the software, rather than the entirety
of the platform used by its subpostmasters. It follows
that even if there had never been any systemic flaws in
either version of the system (that being a contention
with which we do not agree), that would not mean that
the operational platform as a whole was always fit for
purpose for all of the tens of thousands of users. As
we have stated in our Report, it was not.

"I have attached here a copy of our Briefing
Report -- Part Two."

Then scroll down:

“lam available at any time."

So he is attaching the Part Two Briefing Report, he
is drawing specific attention to some paragraphs within
it. If we go back to page 3, please, thank you. In the
middle of the page, we can see an email from Andrew
Bridgen MP to Andrew Smith, your private secretary; is
that right?
Yes.
"... please see that the email below reaches the
Minister as it contradicts statements [made] by the Post
Office."

Then if we scroll up, please. He, Mr Smith,

forwards the chain to Laura Thompson. You'll see that
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Report to you, towards the end of July. Can we look at
some material that relates to that.

UKGI00005133. Can we start by looking at page 3,
please. If we scroll down, please. Thank you. We'll
see Mr Warmington's email in his familiar font, of
22 July 2015, to George Freeman. You're not copied in
at this time. The subject is "Second Sight's Briefing
Report -- Part Two”, and he says, Mr Warmington:

"lam puzzled, and not a little distressed, by your
ssummarisation in your recent email to lan Warren [no
need to look at that], and more importantly to
Parliament [we're not going to look at that either], of
my firm's Interim and Part Two Reports (there were, in
fact, three reports). You have summarised our Reports
with the following words: 'Second Sight have produced
two independent reports, in 2013 and 2015, both of which
demonstrate that there is no evidence of systemic flaws
within the Horizon system which could cause the issues
reported’. That is NOT a correct statement.
I respectfully draw your attention to paragraphs [then
he lists some] of our Report, and to the following
additional paragraphs [then he lists some].

"You may have noted from reading our Reports, and
also from Post Office's Rebuttal Documents, that Post

Office has continually focused attention on the system
70

it CCs the same email address as he is sending it from.
Is there something that we are missing there, as to why
that would be done?

No. I think it might be to do with, if you've got

an attachment, if you copy it, does it --is it

retained, or something. That's still the private office
address. It's not an address I've got access to.

No. Then scroll up, please. We can see that

Ms Thompson replies to Mr Smith:

"1. Ron Warmington ... has emailed George Freeman
regarding Second Sight's Reports ... Mr Warmington
states that he disagrees with the summary that Second
Sight's reports demonstrates no evidence of systemic
flaws within the Horizon system which could cause the
issues reported by applicants to [the] Mediation Scheme.
[He] directs the Minister to several paragraphs in the
final report which he feels demonstrates that Horizon,
in the totality of the user experience, is flawed."

Then if we scroll down:

"3. ... Iwould emphasise that our position is not
arbitrate in this matter -- it is a commercial matter
for the Post Office. As shareholder, we expect the Post
Office to operate commercially and to handle operational
and legal matters such as this one without Government

intervention ...
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"4. Following [the] email, we have looked again at
the paragraphs he has highlighted ... The statement that
‘there is no evidence of systemic flaws within the

Horizon system’ remains correct."

That does appear to be arbitrating:

"This is a position we have stated repeatedly,
including in Parliament, so it is unclear why Second
Sight are choosing to raise this now. We are happy to
provide further detail on the ... points raised if
Ministers require."

So how would you have read this kind of commentary
from Laura Thompson on the Second Sight Report that was
being sent through to you?

Well, I'm not sure whether I saw it at that time

although I certainly saw if it later in the month and

had a look at those paragraph numbers. I'd got
concerned by that time, which is why I wanted to have
a policy meeting to discuss what we should do about all
of this and that's what happened on 4 August. I'm not
sure I've got a lot to add. I mean, we can talk about
the Second Sight Report if you want, here or later.

I mean, they refer to all these paragraphs. If you
go through those particular paragraphs, it doesn't bring
out nearly as clearly as the session I had with MPs what

the issues were, particularly if you're not technical,
73

is the key points need to be in the covering memo. So
Warmington's covering memo was helpful because a couple
of the key points came out but I don't think I actually
read the full report until later in the month, and you
will recall that I then -- Mr McInnes sent me a memo
saying "Well, there's nothing new here", and I asked for
further advice, hoping that I would get further advice
on the detailed allegations in the Second Sight Report,
which at the time I didn't get. I got another note from
the Post Office.
So just dealing with the extent of your reading of the
second Second Sight Report, can we look, please, at
UKGI00005504. We are skipping ahead in the chronology
a little here but it is because of what is said in the
body of the email. If we scroll down to the second
email down, there's an email from your office to
Mr Warmington of 14 August. You say in the second line,
last two words:

"I have read with interest your ‘Part Two Briefing
Report’ as well as the response from Post Office
Limited."

Was that correct: that, by this time, 14 August, you
had read the Second Sight Report and Post Office's
83-page rebuttal?

I had certainly looked through it and, later on, I think
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you read through and you look at all those different
paragraphs and then you look at the POL response, which
is even longer --

The 83-page rebuttal?

-- and comes back on it and, to be honest, for somebody
who is not expert and not meant to be expert, it's
actually quite confusing. And it was that -- you know,

so I've got this milling about. Obviously, you've got
somebody writing in saying that what Freeman had been
advised to say looked -- I think they're actually saying
was misleading, which is obviously a serious matter.

So, for me, I wanted to try and find a way through but
obviously the advice that I'm getting here is "Stay at
arm's length, you know, we haven't got any reason to
think that our advice is wrong, that the Second Sight
Report demonstrated no evidence of systemic flaws within
the Horizon system".

When did you receive the second Second Sight Report?
I'm not convinced I saw it before that meeting of the

4th -- I mean, I may have been aware of it. What
normally happens with a box is you read the top papers
and, if you've got time or reason, you might read some
of the annexes. It's one of the things that you that to
explain to civil servants, actually, I've found, because

I've had these different jobs, both inside and outside,
74

I say I've kind of looked through it. It's convention

that if somebody writes to you as a Minister and they
send you a report -- it happens all the time, they send
you a report on accidents, statistics or procurement --
then you write back saying, "I've read with interest" --
this is a standard reply "I've read with interest your
report" and, in this case, I have mentioned the two
reports. That will have been drafted for me by

Officials of some kind and I have no reason not to quote
it in a conventional way.

So it's not that I wasn't aware of the Second Sight
Report and was aware that it had got important things in
it but the idea -- it's perhaps slightly misleading, the
idea that I would have been on top of all of it, but
what I have said is they've committed to addressing them
and making improvements, on training, which of course
I think they had done but, obviously, I've stuck to the
line of the parties involved.

But behind the scenes, you will know that I'd asked
Tim Parker to, you know, do some sort of independent
investigation of all of this, of which Second Sight
would be at the heart.

So just focusing at the moment then on the extent to
which you read Second Sight's Part Two Briefing Report.

In your witness statement, you tell us that you would
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have read the report or at least the passages which
Mr Warmington had listed?

Yeah, yeah.

I don't suppose you can remember which is the case?
Well, I certainly read the passages which were listed

and those were the ones I was commenting on: that, if
you go through them, you don't get quite the same
tonality as if you read the whole report from beginning
to.end. And then, of course, you turn to the POL
response, and you're actually confused as to what you
know, what you need. So, I mean, to some extent,

I think you have to understand, I was concerned about
this. There wasn't that much I could personally do, in
terms of getting on top of this. I therefore wanted to
make sure that a proper piece of work was done on this,
which is what eventually became the Swift Report.

The Second Sight Part Two Briefing Report in summary
finds that some form of unauthorised remote access may
have occurred; that amounts in excess of £100,000 had
been taken into Post Office's profit and loss accounts;
that the Post Office operated contracts to the detriment
of subpostmasters; and provided them with no automatic
entitlement to data upon which properly to judge whether
or not they were liable for the losses alleged against

them; and that some prosecutions appear to have been
7

I think -- unfortunately I haven't got it with me but

I think there is a reference somewhere, because what was
done by POL, and perhaps by ShEx, was to pick up from
the work that Second Sight had done this sort of magic
sentence that there wasn't a systemic flaw. But,

actually, there were lots of other things in the report,

like the fact that obviously they'd had a really crummy
foreign currency scheme, which ended up losing money,
either for the unfortunate postmaster or indeed for the
Post Office itself, it's not too clear.

So there were these various different points in
those reports, which I didn't have the time or expertise
to really look at properly. And what they seemed to be
just doing was repeating this mantra that Second Sight
was fine and they'd gone native, and we should just
ignore that report. And I was -- I didn't really like
that approach to things. But I have to say, I think
perhaps Second Sight -- you know, they weren't
experienced, they weren't lobbyists, they hadn't brought
‘out into the front of the report, in a way that might
have helped them a bit more, you know, the key things
that you have now summarised so beautifully and -- you
know, as Counsel to the Inquiry. They didn't do that.

But the MPs had talked to them and they did bring

out strongly exactly these points that you're -- that
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focused more on debt recovery than in the interests of
justice.

That comes out very well from the Swift Report, which
summarises -- which I only saw when I was preparing for
this hearing, summarises it very well. But, at that

time, I had asked ShEx for advice on this, you may
recall. So I'd said, "I'd like some advice, please",

and I had then been sent a memo by Mr Mcinnes which
repeated the usual mantra and didn't go into the

details. I never actually got proper briefing on that
report, and I don't think it's unreasonable for

a Minister to ask officials to look at and summarise
something of that importance, particularly as it turns

out they'd had it for about a year, so presumably they
could and should have read it in great detail, and when

I asked for an analysis of it, I actually should have

had an analysis of it. But I didn't get that, and so

I then moved on, and accelerated the work being done by
the new Chair of Post Office.

Do I take it from that, Baroness Neville-Rolfe, that

your reading of either the report or the identified
paragraphs in the report didn't highlight to you that

what you had been consistently told by Laura Thompson
and others, that that second report had revealed no

systemic problems with Horizon, was untrue?
78

were actually quite well summarised in the note from POL
of the meeting that I had, which obviously wasn't

an official note.

You tell us in your witness statement -- it's

paragraph 88 -- that you received a briefing note from
Laura Thompson. Can we look at that, please.
UKGI00001067. Going back a little bit to 31 July, but

it's a passage that I want to pick up, and if we scroll
down, please -- and again -- yes, (6).

"Individuals who have a criminal conviction already
have a suitable independent route of appeal through the
courts or the [CCRC]. That is the appropriate course of
action for those individuals to take if they feel their
convictions are unsafe.”

Then over the page. Yes, nothing else on that. The
briefing note appears to be advising you not to
interfere in cases where there had been criminal
convictions because that was a matter for the CCRC and
the courts. What was your view on that aspect of the
advice that you were receiving?

Well, obviously the line that I should respect the CCRC,
who, at that -- you know, were well -- I think were well
viewed at that time, seemed to me to be a reasonable
‘one, especially as I'd been told by -- with -- including

a letter from their General Counsel, that they weren't
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holding any papers, which actually turned out to be
untrue. When you eventually read the Swift Report, you
find there were sort of Deloitte papers and things,
which I was completely unaware of, which other people
hadn't had, and so the CCRC should be allowed to get on
with it seemed to be not an unreasonable point.

Having said that, I was -- and obviously, they were
the particular population I was worried about, but,
equally, there were these points by Second Sight that
had been raised about how -- I mean, what seems to have
been happening was the Post Office had an awful lot of
lines for a poor subpostmaster in a small rural post
office and so it was really, really important that
Horizon worked properly when they, you know, had to deal
with all of these things. And the Second Sight Report
is quite good, and it takes you through all these
different lines and explains the difficulties.

Now, if you've got a really good IT system and
really good IT support, you can bring online new
products and people who are selling them, you know, can
be ushered in to making it work. But the Second Sight
Report suggested that there were some wider problems,
and we kept being told there weren't systemic problems
but there were obviously, you know, bugs and the odd

problems, as you can see from what the MPs were telling
81

recall feeling the pressure of the consistent advice
from ShEx that these were not matters for Government and
to hold that official line, but based on what I now

knew, that was no longer a tenable position."

Had this happened in either your Civil Service or
political career to date, ie by mid-August 2015, the
officials that were advising you were fighting you, they
had lost objectivity, they seemed closed minded?
I mean, the answer is no. I mean, I did deal with the
Green Investment Bank -- and, funnily enough, that was
ShEx as well, although a different cast list -- where we
had a problem of trying to reassure people that green
credentials would not be sort of completely lost, and
the advice there was it was privatisation, so that was
tough, eventually, we found a solution, which was to
been trustees who were slightly outside the structure,
and, you know, could be turned to, in the event of,
I think, an onward sale or whatever.

But to start with, I'd found ShEx quite difficult on
that subject, although we did get a resolution to that
in the end. But, on the whole, you know, if you're
clear you want something --

I mean, the other thing the officials do is go to
the Permanent Secretary or go to the Secretary of State

and, to some extent, obviously, there was this
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me and, indeed, from the Second Sight Report. If you
could find the right bits.
Can we turn back to your witness statement --
I'm sorry, does that answer your question?
Yes, it does. Can we turn back to your witness
statement, please, and page 34. In fact, if we start at
page 30, and paragraph 110, you say:

"I did feel at this stage [that's mid-August 2015]
that I was fighting ShEx."

Then if we go forwards, please, to page 34, you say:

"By this time I had lost confidence in the quality
of ShEx's advice. We were going round in circles, and
they were unwilling to engage with the issues in the way
I felt they needed to. In my view ShEx had lost
objectivity, and its officials were unable or unwilling
to scrutinise [Post Office] properly -- even though that
was an essential part of their role. The advice they
gave seemed close minded, deaf to the issues and
constantly repeating the same mantra. As time went by
I felt as though they were trying to obstruct, or shut
down, my efforts to get to grips with the issues. This
may have been connected in some way to a dogmatic belief
that [arm's-length bodies] should be entirely free of
Government interference; and certainly I was repeatedly

advised that [Post Office] should be left alone. I do
82

understanding that there was operational separation, and
that certainly had the endorsement of the Secretary of
State, but I probably would have mentioned by
frustrations, but the way I dealt with the frustration

rightly or wrongly, I wanted to do something, was

I moved forward and I got the new Chairman to take

a look at this, I explained that it was, you know,
reputationally and organisationally important for the

Post Office, and I encouraged him.

My recollection is I encouraged him actually to use
lawyer, a QC, because that's what -- the sort of thing
that I had experience of in the private sector. Where
you've got a really big problem, if you bring
an independent leading member of your profession, they
provide clarity, they make sure you know what the facts
are, and then that enables you to move forward and do
the right thing.

But if what you're asking me about was had I lost
confidence in ShEx advice, the honest truth I had,
I tried at an earlier junction to get some Business
Department officials to come along to a meeting and they
sent along a lawyer. So I had a lawyer and I had two
Special Advisers at the meeting but I didn't have, you
know, a senior Business Department Official who I felt

might be a little bit more understanding of the fact
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that you've got MPs -- I mean, MPs are really important
in our democracy because they sometimes bring, you
know -- they bring unwelcome bits of information to you.

I wasn't an MP, but I was at a major retailer. We had

the same system. You've got these letters coming in to
the CEO, which were an excellent source of stones in the
shoe, and that's what we were getting from these MPs,

and I didn't feel that ShEx really wanted to listen to

that.

They wanted to make sure that the line that they
took prevailed, and they worked with POL to try and make
sure that that's, you know, what I was being told. And
then I bought in Oliver Letwin -- see paragraph 125 --
which was obviously helpful.

Yes. If we skip forwards to paragraph 239 on page 61,
please, you say:

"My relationship was mainly with Laura Thompson who
was, for the most part hardworking, helpful and
effective. However, she followed party lines decided
above her by Richard Callard, the [Post Office] Board
member, and others. In retrospect, ShEx was too close
to [Post Office] for effective scrutiny and I was at
times frustrated by their unwillingness to question the
status quo."

Who within ShEx did you have concerns about, by
85

copies of all the exchanges I was having with Laura
Thompson, who knew of my concerns. I mean, one
difficulty we've got -- and I now know why -- is that we
haven't got any notes of my meetings by my private
secretaries, except where they ended up somewhere else
and one of the documents you've just flashed up says

it's not the responsibility of a private office to keep

any copies; it's the responsible of the divisions.

So that's the problem we've got. Sorry, I'm not
really answering the question, but those were the
concerns I had. I think I had one meeting with
Mr Russell, who was the top honcho, and that was later
on -- I think he came to I see me to ask about how I'd
found ShEx.

Given the concerns that you have mentioned in the
passages of your witness statement that I've shown to
you, in particular that ShEx was being obstructive, that
you had lost confidence in it, that it lacked

objectivity, what steps did you take to address those
issues?

Well, the main step I took was to ask the new Chairman

of Post Office to bring an independent person to have

a good look at the whole thing and provide us with

advice and then I pushed back on ShEx in the normal way,

where they gave me advice that I didn't like. But, you
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reference to the words "and others"?

Well, I had -- I didn't see much of Richard Callard but,
to the extent, I did have a little bit concern about

him, and clearly we've got -- we've had evidence
separately that he was working very closely to POL,
which I mean is understandable, he was on their Board.
And then I had this exchange with Mr Mclnnes, who

I think was -- I don't know where he slotted in but

maybe above Callard, and I'd asked him specifically for
a proper submission on Second Sight, and I ended up not
getting a reply from him at all, but getting a reply

from Laura Thompson, saying the same thing and
forwarding a piece of paper from POL, annexe B, which
was missing when I saw all these papers initially.

What was the nature of your interactions with

Mr Callard?

I think he came to the meeting at the beginning of
August. I met him when I went on the away day in June,
because he was the Board member.

Did you communicate your concerns directly to

Mr Callard?

Well, certainly on 4 August I communicated my concerns,
and he saw -- the thing about the Civil Service is

there's a lot of reading of paper, and civil servants

are very good at reading paper, and he was receiving
86

know, they were the officials. I had a go, at the
beginning of August, at bringing in officials from
elsewhere, but I was told that -- and remember, I was
a relatively junior minister, I was told that that
wasn't appropriate.

I mean, I did have updates with -- quite short
updates, always -- with the Secretary of State and I'm
sure I will have -- I know I explained to him that I was
planning this review by Parker, obviously, who he was
partly responsible for bringing in, which my
recollection was he supported.
Was that Sajid Javid?
Yeah.
Did you ever consider -- escalating might not be the
right word -- but raising the problems that you were
encountering with the Permanent Secretary?
The honest truth is I can't remember but if I had had
a meeting with the Permanent Secretary, which I did
occasionally have at that time, I'm sure I would have
said "Well, it's all very frustrating but what we're
going to do is get -- we've got these two or three
avenues, we're going to add the extra avenue of having
an independent look at it by Parker, and he would have
probably agreed that was a good idea".

You have to remember that I tried to be
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constructive. I tried to actually do something, which
was why I got this extra piece of work done, which

I think, if it had become public, would have been
extremely transformational.

Given your concern that the party line was being decided
by individuals, including Mr Callard, did you consider

it was appropriate for Mr Callard to have been the
Government's representative on the Board?

I mean, that was not a decision for me. My
understanding of the structure was that I was
responsible for postal affairs, but who -- you know, how
the Shareholder Executive worked -- and, you know, the
Permanent Secretary sat -- the permanent secretaries,

I think, sit on the TopCo in the Shareholder Executive
and it is for them to decide who the individuals are.

It is important who the individuals are but it is not

part of the constitution that we, as ministers, you

know, decide which civil servants have which jobs. And
when that works well, that's fine.

Which Permanent Secretary had functional responsible for
ShEx?

Well, that will have been the Business Permanent
Secretary, who I think -- it was first Martin Donnelly,

and then it became Alex Chisholm, but I think that

was -~- Alex came in with the climate change and energy
89

minutes over the phone tomorrow if there is time --
I appreciate it's her first day back but ... if we could
find a slot, it's worth her being aware of [Lady
Neville-Rolfe's] mood and position (not that there is
too much to worry about)."

Can we look, please, at your witness statement at
paragraph 102, which is on page 27. At the foot of the
page, you say, "I have also been shown a copy of a chain
of emails", that's the one I've just shown you. Then
fourth line:

"Of course I did not see these emails at the time."

Then you start quoting from the email and, if we go
cover the page, please. You say:

"I find this troubling. This seems to me to be
clear evidence that ShEx -- whose role it was to provide
me and other ministers with objective and impartial
advice, to scrutinise POL's actions and to hold it to
account -- was taking steps to provide advance warning
to [Post Office] about my concerns and intended
direction of travel. I cannot see any good reason for
them to have done so. I am sadly driven to the
conclusion that ShEx and [Post Office], perhaps
inadvertently, were in effect working together to try to
deflect me, and that ShEx were not giving me the

independent and impartial advice that I needed."
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work, which was the time I was moved, so I think Martin
Donnelly would have been the Perm Sec at that time.
Thank you.
I did have meetings with him on European issues quite
a lot because one of the points I haven't made is
obviously, although the Post Office was very important
to me, I was quite heavily occupied on other matters,
notably going to Brussels, probably once or twice
a month. I think I was in Asia in this summer period on
intellectual property and, you know, that was the most
important -- those were the -- those, plus the Bills,
were the most important part of my portfolio, important
though this obviously is.
You've referred to having a meeting at the beginning of
August with Paula Vennells. Can we look, please, at
UKGI00005261. If we scroll to the foot of the page,
please. This is an email exchange not including you,
and is in the run-up to the meeting. The subject
heading is "Sparrow catch-up", it's dated 4 August 2015,
from Mr Callard to Avene O'Farrell, who is or was Paula
Vennells', essentially, personal assistant:

"... we had a catch up with Lady Neville-Rolfe today
about Sparrow. Paula is seeing her on Thursday morning
[that will be the 6th] first thing(ish) and I thought it

might be worthwhile me having a chat with Paula for five
90

What was it about the communication between Richard
Callard and Paula Vennells' office that led you to that
conclusion?
I think he and Laura knew that, by that time, I was
getting frustrated and wanted more done than the classic
Post Office line and so he seems to be ringing them up,
to say "Well, there's a meeting coming up", and, as it
were, telling them in advance where I was going to come
from so that they could prepare for that. That took the
element of kind of surprise away from my meeting with
Vennells, so instead of being able to take on Vennells,
they would obviously pre-brief Vennells, the
Communications Director, who was an ex-special Adviser,
who will have obviously explained everything that she
should do and I didn't really think, given there was
a difference between us at the Post Office at that time,
that that was a very sensible or wise thing to do.
I mean, it is true, sort of Prime Minister's have
Sherpas that talk to each other before meetings but, you
know, that's where things are, you know, more -- there's
more agreement coming along, whereas, actually, you
know, this was a slightly rocky patch, and I think that
showed a lack of judgement and a wish to be perhaps more
aligned with the Post Office than was appropriate. But

obviously, Mr Callard had these two conflicting -- he
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was trying to be a good NED to the Post Office, and he
was also trying to advise me. So I, you know, well,

I can perhaps understand it from that point of view.

But I think it was misjudged and it made me feel

slightly that those who were advising me have had a foot
in the Post Office camp, and it was one of the reasons
why, as I alluded to earlier, I wondered if we shouldn't
have some more classic Civil Service officials because
you remember that ShEx is very much made up of
commercial people -- Richard came from Deloitte. You
know, they're all a series of people who have come in
from the private sector, which of course I do

understand, but it does mean that they're not so au fait
with these political difficulties which were obviously
facing at this time.

Why did you consider that ShEx and the Post Office
working together to try to deflect you was perhaps
inadvertent?

Well, I was trying to -- obviously, I don't have --

I don't have evidence except the evidence that you have
given me in those pieces of paper and, you know, they're
civil servants, they try to act with objectivity.

That's why I put "perhaps inadvertently". As itis,

I think, during the course to your inquiry, this thing

that I wrote some weeks ago has become a little more
93,

Then under 1:

"Since we spoke to you earlier this week, we have
been exploring options to address the concerns you
raised."

Then this:

"We have also been engaging with Post Office at
a senior level to ensure [that] they are aware of your
views."

Reading that sentence, "engaging at a senior level
to ensure they are aware of your views", would you
understand that that's a reference to the forewarning of
Paula Vennells of your mood and position in the way that
we saw in the email that we looked at before the break?
Well, I think it's a completely fair point, that they
did say that. I don't recall that at the time and it
says "aware of your views", so I suppose that's fair
enough. It doesn't resolve -- obviously it depends what
the exchanges were. It doesn't quite resolve the
problem that I was looking for independent advice, and
they knew that because my private office had been on to
them, saying that I wanted somebody outside ShEx to come
to the meeting.

But the point that we take from this, would this be
right, is at least ShEx were being open with you --

Yeah.
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believable.

MR BEER: Sir, thank you we're about to move to a separate
topic. Can we break until 12.35, please.

SIR WYN WILLIAMS: Yes.

MR BEER: Thank you.

(12.23 pm)

(A short break)

(12.35 pm)

MR BEER: Good afternoon, Baroness Neville-Rolfe. Can we
just go back --

Assuming, sir, you can see and hear us?

SIR WYN WILLIAMS: That is a correct assumption.
MR BEER: Thank you very much.

Can we go back, please, to the tipping off or
priming of Paula Vennells and her staff about your
concerns, your mood and your position in advance of the
meeting. We looked at that email before the break and
you expressed your concerns about it. Can we look,
please, at UKGI00001067. We have looked at this note
before but I want to ask you a couple of questions about
a different issue. It's from Laura Thompson to you of
31 July, and you'll see that it refers, under “Purpose”
to "ahead of our discussion with you and Nick King on
Tuesday (4 August)", and "Timing: To see ahead of our

meeting on Tuesday, 4 August”.
94

Q. -- about the fact of communication over "your views"
with Post Office at senior level; it wasn't
surreptitious?
A. That's true. From that note, yeah.
But do I detect that you retain a residual concern,
having read the email exchange between Richard Callard
and Paula Vennells' --

2

I retain --

-- staff?

I retain a residual concern, yes.

Can we turn to the separate issue -- that can come down,
thank you -- you've mentioned it a number of times
already: the wish to have separate or independent
advice, ie separate from ShEx. Can we turn to your
witness statement, please. It's paragraph 99, which is
on page 26. Page 26, 99 is at the foot of the page.

You say:

"... [had agreed to a meeting with Paula Vennells
and Jane MacLeod on 6 August. As explained ... by this
stage I was dissatisfied with the advice I was receiving
from ShEx, and I wanted a senior official outside ShEx
to provide support. On 3 August, my private secretary
communicated to Laura Thompson my request for support
from a senior official from outside [of] ShEx at this
meeting."

prop

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So here you appear to be saying that the request was
for a senior official outside of ShEx to provide you
with support at the meeting with Paula Vennells and Jane
MacLeod on 6 August, correct?
My recollection was the main occasion on which I wanted
someone from outside was on the 4 August meeting because
we were looking -- we were trying to look forward at
options, but I think the private office, perhaps
rightly -- it was a long time ago -- took that as
meaning that it would be good to have somebody there on
the 6 August meeting. I mean, I think that might be the
conflation of the two meetings. I'm not sure that that
detail matters. It was more that I was hoping to have
a different pair of eyes on the issues.
Can I just persist with the detail modestly for
a moment, by looking at the email, because I think you
may be right in what you're saying, that the independent
assistance was for the purposes of the meeting on the
th, not the 6th. UKGI00005195. This is the
correspondence that you cited in paragraph 99 of your
witness statement and if we look at page 2 first, please
and scroll down, an email from Laura Thompson to your
private office:

"Please see attached a short note to the Minister

ahead of our meeting with her on Tuesday.”
97

"Just spoke to Harriet. She thinks [Baroness
Neville-Rolfe] still wants a senior official outside of
ShEx and not including whoever we get from Legal but is.
going to go back with the proposal of just three plus
Legal and see what the Minister says. I asked Harriet
to emphasis that we are taking the policy view not just
the shareholder view."

So it would appear from your private secretary's
email that the request from you was to have somebody
from outside of ShEx present at the meeting on the 4th,
ie the internal meeting on the 4th; is that right?

That's right but --

Rather than the meeting with Post Office on the 6th?
But I only got half a loaf. I got a Legal Department
person and I got a more senior person from ShEx, and
I got Special Adviser.

So leaving aside the detail point and getting back to

the point of substance, why did you request the support
of a senior official outside of ShEx for your meeting on
4 August?

Because, as I explained in my statement, by then, I was
beginning to worry about the advice that I was getting
from ShEx, which is very much a single track "everything
is fine", and I was seriously concerned about the sort

of points that the MPs who I met had been making, and
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So Tuesday would have been 4 August.

Then if we scroll up, please, revised note sent
through.

First page, please, at the foot of the page. And
scroll a bit more, please. Thank you. Your private
secretary replies to Laura Thompson:

"Thank you for the note, which [you had] seen. [You
were] looking forward to the discussion at Tuesday's
meeting. To ensure this meeting was as valuable as
possible, she commented that:

"It was very helpful [to have] Nick King ...

“A lawyer would need to be involved ...
keen to have a list of the senior officials
that would attend.

"Grateful if you could advise on who should be
invited from legal. On point (c) ... I understand that
Richard Callard and Anthony Odgers will attend. The
Minister is still keen that a senior official outside of
ShEx be involved given that part of this discussion is
a policy one that may go beyond BIS's shareholder role.
I would be grateful for your steer on how we can address
this. I would like to go back to the Minister on this
point this afternoon ...”

Then at the top of the page, an email from Laura to
Richard:

98

I felt that something extra needed to be done so that

the line that the things we got, which were the CCRC,
the mediation, the SS report, were not enough and that
we needed to do something extra. And I thought that
somebody from outside ShEx would be more open to that.
Do you know why your request was denied?

I suspect it might be partly to do with the fact that it

was August and probably nobody was around, you know, the
cock-up theory of history, but also they obviously felt
strongly they were going to do the policy view as well

as the shareholder view and, you know, when you're

a Government Minister, you know, you have to fight the
battles you have to fight and we were nearly at the time
of the meeting, and it was important that the meeting
should go ahead, rather than wait to -- you know, sort

of going round the office politics was not what I wanted
to do. What I wanted to do was to actually get
something done.

So you attended the meeting in the end without the —
Yeah, I had --

-- independent advice --

I had called the meeting. I wanted that meeting to
happen before the August break. I wanted to get on with
it and make sure that something was done.

Can we turn to the meeting on 6 August with Paula
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Vennells, by looking at your witness statement, please,
page 27, paragraph 100. You tell us that, in advance of
the meeting, ShEx provided you with a briefing note and
lines to take, which they drafted and which didn't

reflect your concerns at the time nor your intended
direction of travel. You say:

"I did not want to be told yet again about [Post
Office's] side of the story; what I wanted to ensure was
that there would be a fresh and independent review to
see if issues with Horizon had been missed."

101, you say:

“Regrettably, I understand that DBT has been unable
to locate any minutes or other record of the meeting of
6 August."

Skipping a few lines, you say:

"Whilst I cannot recall whether I said [in the
meeting] that I thought a QC-led (or similar)
independent review should be commissioned, [you] might
not have done as [you] had not yet spoken to Tim Parker

Referring to a letter four lines from the bottom,
you say:

"... this does seem to suggest that I highlighted at
the meeting the concerns by MPs previously, including

that postmasters felt insulted by [Post Office's]
104

I mean, they sent me a big -- there was a big PowerPoint
pack of stuff, some of which was extremely helpful, you
know, like the detail on mediation, and things. So it
wasn't all negative. But there was just this memory and
I was encouraged to put this in, that I'd kind of felt
slightly threatened at the meeting.
From the Post Office side, what is your recollection as
to who led for them: was it Ms Vennells or somebody
else?
Well, Ms Vennells led but she kept -- she got
interrupted by other people when questions were asked.
You know often, if you're the leader at a meeting, you
make the points, you have a speaking note, and then you
bring your people in as and when you feel that that
would be helpful. It didn't feel like that. It felt
the other way round.
Thank you. Can we turn to paragraph 103 of your witness
statement, please, which is just over the page. You say
you recall speaking to Tim Parker, probably later on
that same day, 6 August, and you impressed on him that
he needed to ensure that the Horizon issues were looked
at again and taken seriously:

"I just wanted this sorted out properly and believed
that he would realise that he and the other Board

members had a duty to just that. I recall asking him to
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approach to mediation. I do recall finding one of the
[Post Office] attendees to be particularly overbearing
and dismissive of my concerns.”

Who was that?
I think it was either Mr Davies or Mr Bourke.
I don't -- I haven't got photos of them but what I found
was that when I made points and made them to Paula
Vennells, there was quite a lot of interrupting by them,
giving their view of things and, obviously, I was trying
to have a meeting with Paula Vennells to hear her views,
and not have the sort of insistent line of these people
who were kind of supporting her in this matter. You
know, I don't know whether it was -- whether it was the
General Counsel, she was obviously there as well.
I mean, she might have intervened.

Just my memory of that meeting was that it was, you
know, sort of almost -- there was a sort of threatening
feel that I was trying to do the wrong thing and, you
know, I should watch out. It was just, as I said,
‘overbearing and dismissive of my concerns. I was
passing on concerns that had been registered by people,
you know, the democratic representatives, and I didn't
feel - I felt that they wanted to tell me what they
thought the thing was, rather than, you know, explain

why the detail of some of these points wasn't right.
102

bring in an independent QC or equivalent to head
a review when he took up office, and he moved to do so
soon after he took office."

You understand that the Department doesn't hold
a record of that call.

So, by this time, you knew, ie early August, that
Mr Parker was to take up the chairmanship of the Post
Office.
Yes.
You spoke to him and impressed on him the things that
you set out there. Why did you think that Mr Parker was
the solution or a solution to the outstanding issue or
issues?
Because he was the new Chairman of the Post Office, he
had a background which combined business experience,
I think Clarks, Samsonite, various things. I mean, he
was a strong candidate for this job -- and National
Trust, which is more public sector kind of thing, and
I think he was a Treasury official when he started in
this life because I had briefly interviewed him early on
in my time as a minister because when new appointments
were being made to Boards it's classic that the people
who come through the system, through the panel, then
sort of have a cup of tea with the Minister, before the

final appointment is made. And I was quite -- I have to
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say I was quite impressed by him. I thought he had
a sort of strength and dynamism and he seemed, when

I spoke to him, to very much want to get to the heart of

all of this.

And I knew from my experience of running Boards that
if you have a running sore like this, bring in somebody
from outside, like a QC, or it can be a senior civil
servant or I think somebody had suggested a captain of
industry, which I think probably would work less well,
then that was the thing to do. It was also a route to
actually getting something done.

Can we look, please, at POL00102551. This is your
letter to Mr Parker of 10 September 2015, so about month
later. You say:

"Lam writing to you ahead of your taking up the
role of Post Office Chairman to confirm our conversation
last month regarding [Horizon]. The issues surrounding
the Horizon IT system have not been resolved. Indeed,
some of the MPs concerned have written to me again
following the Panorama programme pressing the case for
an independent investigation.

“The Government takes seriously the concerns raised
by individuals and MPs regarding the ... Horizon system
and the suggestions there may have been miscarriages of

justice [and] also recognises the commitment that Post
105

the issues, whether it was to be conducted by him or
somebody else and, if by somebody else, the nature or
qualifications of that person?
I agree that it leaves it open. The letter was, of
course, drafted by ShEx for me.
Yes.
And I do recall the circumstances. A whole package came
up. I think they'd all been cleared through the
Secretary of State by the time they got to me, or anyway
certainly by the time I was signing this. I think the
letter could have added in something about deadlines,
something about publicity, one or two other things,
but -- and it's very much written from a ShEx
perspective, respecting the ALB character. And I think
that, actually, that balance is probably quite sensible,
because, you know, if they were concerned, which they
always were, about the commercial, you know, operation
being separate.

But I had a lot of faith in a new chair coming in,
who I thought, you know, would take a really good and
strong look at this, talk to those concerned, do the
sort of forensic work that wasn't appropriate for
a minister to do and I wouldn't even have had time for
it and the letter, you know, confirmed that that is what

I'd asked him to through.
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Office have demonstrated to resolving those issues,
including through creating a mediation scheme and
appointing independent investigators to scrutinise the
system.

"As you will be aware, there have been some three
years of scrutiny of Horizon and the [CCRC] is
considering a number of cases which have been brought to
it by individuals, and the Government cannot intervene
in that independent process.

"As the sole shareholder ... the Government wants to
make sure that the Post Office Network is successful and
sustainable across the country. We recognise [it] is
a commercial business and we allow it to operate as such
but, of course, we expect it to behave fairly and
responsibly in doing so. I am therefore requesting
that, on assuming your role as Chair, you give this
matter your earliest attention and if you determine that
any further action is necessary, will take steps to
ensure that happens."

Over the page:

"I look forward to hearing your conclusions and to
working with you to secure the future of the Post Office
Network."

Would you agree this letter did not specify how Tim

Parker should carry out any review or investigation into
106

Can we look, please, at POL00233179. This is an email
exchange that you weren't party to, if we scroll down,
that's the email from Rodric Williams, a lawyer in Post
Office, to Patrick Bourke and Mark Underwood in Post
Office, and he says:

e ... my Starter for ten on Jane's speaking
notes for her meeting with [Tim Parker]."

So this is ahead of a proposed meeting between Jane
MacLeod, then General Counsel for Post Office, and Tim
Parker, who would by then be Post Office Chairman. If
you just look at number 3:

"The review will however be creditable if it is:

“Undertaken independently from the existing Post
Office team;

"logical in its approach; AND

"delivered against stated objective/s."

What would you say to the suggestion that the idea
of independence, namely a review undertaken by Queen's
Counsel or similar, came from Post Office and not you?
I mean, I think, when I suggested the thing, I was most
keen on having some independence. I don't think I laid
down specifically that it should be a QC because there
were other options, such as a senior civil servant or,
as I say, a captain of industry. But the key thing was

to bring somebody in so that there was, you know,
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an independence from existing PO teams. So I agree, to
be honest, that seems to me a very fair point, and
without, you know, sparing your brushes, if you bring

a QC you know they will do a thorough job and that it

will be objective and that the facts will be correct,

and that they're quite good at marshalling lots of

different pieces of paper and summarising things in

a way that's understandable and, actually, I would say
that the Swift Review, when I eventually saw it, did

a lot of those things.

So I was entirely in agreement with Tim Parker, and
delighted when he wrote to me very soon after his start
date, saying that was what he was going to do. And Sir
Jonathan Swift, who is now, I think, a High Court judge,
seemed up and coming and a very talented person to do
exactly what I felt needed to be done, and could be
done, you know, at reasonable speed and then we could
get on and do something which wouldn't take many years.
If we just look over the page, please, at paragraph 6.

"Given the volume of material, [Tim Parker] is
likely to need ‘independent professional assistance’ ...

"Subject to any procedural requirements, this could
be:

"a solicitor:

“with good document management and summarising
109

of 10 September. UKGI00006138:

"Dear Lucy

"Thank you for your letter of 10 September.

"Having had my first ... days of induction ... just
last week, I am considering how to fulfil the commitment
I gave you to take a fresh look at the Post Office's
handling of the complaints raised ... in connection with
Horizon ...

"To this end, and to promote the independence of the
exercise, I propose to instruct a QC to advise me as to
the appropriate scope of my investigation, how I might
best conduct the necessary enquiries, and to assist me
in considering how to present and, as necessary, act on
my findings."

That refers to a slightly different role of the QC,
doesn't it? The QC is going to advise on scope, the
conduct and presentation of his, Mr Parker's, findings,
rather than conducting the investigation him or herself?
Well, that might be so but, equally, when we eventually
had the summary letter later on, explaining what he'd
covered, it seemed to me to cover the right area. You
have to put a certain amount of trust in a highly paid
chairman to a Government ALB and, you know, bringing in
a QC to advise seemed a good idea, and there's no

suggestion that he's sort of just - just leaving it to
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skills

“from a firm which has not been instructed by the
Post Office ...

"which is on the Government Services Panel if we
want preferential rates ...

"or completely off panel if we want total
independence ...

"a barrister:

“likely to have a high level of independence

"BUT tend to be focused on forensics and outcomes
rather than process ...

"a management consultant:

“likely to be good at understanding the process ...

"BUT may not be able to opine on the suitability of
the process, or may focus on whether there is a ‘better’
one

“a former civil servant ..."

Again, did the idea of independent professional
assistance come from you to Tim Parker way back on that
conversation in early August?

That was very much my recollection, that was exactly

what I wanted, as I say, and I reference that because of
my commercial experience at knowing how helpful that can
be to a Board.

Can we look, then, at Tim Parker's reply to your letter
110

the QC, actually he's to assist me in considering both
how to present and as necessary react on my findings.
I mean, actually, I require -- I think that's

a positive, rather than a negative, if I'm honest.

I didn't have a concern at the time. I felt a certain
weight off my shoulders that we were going to actually
bring in somebody different.

And, of course, you have to remember that we're
now -- we have an inquiry with hindsight. We did not
know at the time that there had been these unsafe
prosecutions. Everybody was telling me that Horizon was
fine, that it was all fine. I was having to tell
Officials, who didn't like the idea that we were opening
up, you know, possible criticisms of them -- they didn't
like the idea that the things might have gone wrong.
I had to remind them that we, as Government, you know,
had to try to make sure the right thing was done.

So looking at the episode as a whole, you thought that
this was positive, in that he wasn't simply outsourcing

this, farming it out to a silk. The references to his
involvement in it were a good thing?

They were. It's a balance. You've got the independent
QC coming along and doing a proper forensic job and then
you've got the Chairman following through and actually,

you know, doing what was necessary. That seemed to me
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what that letter said.

MR BEER: Thank you.

Sir, that will be an appropriate moment for the
lunch break.

SIR WYN WILLIAMS: Yes.

MR BEER: We will turn next to Baroness Neville-Rolfe's
meeting with Second Sight on 19 October 2015. Could we
do that at 1.55, please?

SIR WYN WILLIAMS: = Sure.

MR BEER: Thank you very much.

(1.06 pm)

(The Short Adjournment)

(1.55 pm)

MR BEER: Good afternoon, sir, can you see and hear us.

SIR WYN WILLIAMS: Yes, thank you very much.

MR BEER: Good afternoon, Baroness Neville-Rolfe.

Can we turn then to the meeting of 19 October 2015
with Second Sight and start with a bit of a run into it
by looking at some correspondence beforehand, beginning
with UKGI00005300. If we turn to the bottom of page 2
and on to page 3 -- thank you -- we can see there the
Ron Warmington email of 22 July to George Freeman that
we looked at earlier, the one that says, "Please look at
the following paragraphs of our second report, and the

statement that Second Sight in 2015 found no evidence of
113

another one for response ... we should aim to
send a short response on Friday on the back of the
response to Ron Warmington."

Do you think you got personally to see this

exchange?

A. I can't be sure. I mean, clearly I must have known
during that August period that Warmington was disputing
what Freeman had said.

Q. Can you recall what your reach was to Mr Warmington
saying that Second Sight's Report had been
misrepresented in Parliament?

A. I think I probably sought advice, that's what I normally
did if I got something from outside like that. But
I think it also came in from the MP, it did, from Andrew
Bridgen, who obviously I had a lot of respect for. And
so, you know, that meant there was more work to do. It

confirmed my view that we should have somebody else look

at this.

Q. Had you by this time read the Second Sight second report
to see for yourself whether what had been represented on
the basis of briefings to Parliament was correct or
incorrect?

A. I mean, at or around this time I will have got that.
I don't recall exactly when the full report was put in

my box, if I'm honest. And, remember, this was
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systemic flaws with Horizon is incorrect".

If we scroll up, please, we can see that he,

Mr Warmington, sends that on to David Cameron, on
28 July. Then scroll up, please. Then on 4 August, he
sends it to you.

"Dear Baroness,

“Further to the article written by Tim Ross in this
weekend's Sunday Telegraph [and he provides the
hyperlink], I have as yet received no acknowledgement
from Westminster in regard to my 22 and 28 July emails

"The possibility seems to exist that Mr Freeman was
inaccurately briefed on the results of our firm's
investigation. As stated below, we have concluded that
there were, and probably still are, systemic flaws in
Horizon."

Then if we go to page 1 and stop there, thank you.
Andrew Bridgen says, in an email to your private office,
of 5 August:

"Dear Lucy,

“I have been forwarding this email ... perhaps you
could advise given the seriousness of this allegation
that Parliament may have been misled by the Post
Office."

Your private office send that to ShEx:
114

a holiday period, we were travelling about, et cetera,

et cetera, but I had taken on board the seriousness of

it and we had spoken earlier about how, actually, quite
difficult it is. You look at the individual paragraphs

and it is quite confusing as to exactly what, but

there's certainly a problem there and that I was well
aware of.

Did that problem being raised by Second Sight constitute
a separate and independent reason for an independent
investigation being a priority?

I think it certainly helped to stiffen my resolve. But,

as I've said, I thought the key things were well
articulated by the MPs that I'd seen and, indeed, by the
debate, which we haven't looked at in the House, there
was an Adjournment Debate a few weeks earlier, bringing
all of these things together. And then you've got the
Second Sight Report as well.

Thank you. That can come down.

Although the Second Sight Report had been around for
a very long time and, as yet, I've still not had

a summary of it from the system.

Can you recall what the system's attitude was to your
proposal to meet with Second Sight?

Well, basically, they always advised me not to meet with

Second Sight on the basis they were unreliable, they
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didn't abide by confidentiality and their report that --
they seemed to cling on to this key thing that they had
found that there was no systematic fault with the

system, but they then said that other things that they

were doing, you know, that they were not straight with,
which was a bit confusing, to me. And, as I said,

a little bit earlier, I actually really -- I found it

difficult to know what the key points in the Second

Sight Report were, particularly when I'd seen the

counter stuff from POL.

But what I would say is I think Second Sight were
amazing in the way that they kept going. You know, year
after year, they produced these reports, they thought
that they were on to something. They got, you know, not
much sympathy from the powers that be and yet they kept
on trying and, obviously, they did engage MPs, which was
the right thing to do.

Can we move to closer to the October meeting by looking
at UKGI00006142. At the foot of the page or the bottom
half of the page, an email from Laura Thompson to Andrew
Smith of your private office of 9 October 2015, and she
says:

"Andrew

"I noted down for the team here the non-Horizon

points from the meeting with the Minister, which I have
117

objections to your meeting with Second Sight, on the
basis that meeting with Second Sight would risk
undermining your independence and distance from the
situation?

I didn't really think that that was the case. I thought

it was quite possible to have a meeting to hear what
they'd got to say and encourage them to help Tim Parker
with his review. So, you know, I'd said I'd see Second
Sight as early as July. I'd reiterated that, I think,

to James Arbuthnot when I saw him. They all felt Second
Sight was very important and I didn't think that they
should stop me -- that Post Office should stop me seeing
them and, in fact, I think even ShEx agreed, perhaps
warn down by my assistance, that I should see Second
Sight, so I had a meeting with them.

We are going to look at ShEx's note in a moment where
they, to an extent, in fact, echo the position taken by
Post Office, at least initially.

Did it occur to you that Post Office's resistance
might be motivated by a desire to avoid scrutiny from
Government?

Well, certainly they were always trying to defend their
line. That seemed to be their approach externally, and
they seemed very paranoid about external matters.

Indeed, I remember them being very paranoid about
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attached ...

"On the Horizon discussion, the main points I took
away were [as follows].

So it seemed like you had a meeting at which Horizon
and non-Horizon issues were discussed and this is
Ms Thompson noting down, in the body of the email, the
main Horizon points that she took away. Bullet point 1:

[Post Office] wanted to flag their concerns around
the Minister meeting Second Sight. They felt that doing
so would risk undermining her independence and distance
from the situation, and were also concerned that if news
of the meeting were to leak to the media, it could risk
individuals withdrawing from the mediation process
(after considerable efforts by [Post Office] to get
these in the diary). Paula was also concerned that the
Minister's meeting might conflict with any meeting Tim
Parker decided to have with [Second Sight].

"[You] noted Paula Vennells' views but felt it
important to make the offer of a meeting to Second Sight
and inform [James Arbuthnot] that [you] were doing so.
[You also] suggested that the offer should be of
a private meeting, and should happen quite soon, so that
it would take place before Tim Parker invites them to
meet."

Can you recall what you thought of Post Office's,
118

Panorama. Obviously, I'd worked in the private sector,
I worked for Tesco, which was a company that, at that
time, was very high profile and successful and we'd had
Panoramas about ourselves, and all the rest of it, about
you had to engage and, you know, the fact -- I mean
actually, I agree that it should be a private meeting,
probably, you know, to try and assuage Paula Vennelis’
concerns, but I did think the right thing was for me to
see Second Sight, since they'd been, you know, making
a lot of these points over a prolonged period and

I couldn't really see why I shouldn't do that.

You said there that that step might assuage Paula
Vennells' concerns. Do I take it that you understood
that Post Office's approach in this regard was being led
by or taken with the approval of Paula Vennells?

Yeah, I think -- didn't I have a conversation with her
about it?

Yes --

Yeah, sorry. So she felt strongly about it herself ~
enough about it herself, not just her PR people, to
actually want to talk to me about it. So she obviously
felt strongly, presumably on the advice of lawyers, you
know, that this could somehow get in the way of some
legal arrangements, mediation, et cetera, to talk to me

about it and explain her concerns. I listened to those
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concerns, I was careful, obviously, when I saw them, not
to say anything about -- trying to think -- you know,
sort of something that was going to lead to a lot of
public rows, because they were obviously worried about
that, but I was absolutely determined to see Second
Sight, and that I did --
Can we look --
- and it was helpful.
Can we look, please, at ShEx's position, BEIS0000013.
Anote of 1 October 2015 from Laura Thompson to you:
"Advice following your meeting with James Arbuthnot
... covering [his] ask that you meet Second Sight and
Sir Anthony Hooper.”
"Recommendation" is:
"That you:
"Decide whether you would like to meet Second Sight

If we go down to paragraph 3:

"Mr Arbuthnot argued that, since you had received
a briefing from Post Office on this matter, it was only
fair that you should meet Second Sight and hear their
side of the story. He invited you to judge for yourself
as to whether Second Sight were as ‘biased and
unprofessional’ as he felt they had been depicted by the

Post Office.
121

Second Sight?

I did. I suspect I had already decided before this memo
came up. It's one of the things in Government that
quite often submissions sort of come along to formalise
a view, you know, on the one hand, on the other, and
they've given me a reasonable, you know, run down and
accepting that I should see Second Sight. So I'm seeing
them -- I'm not saying I saw them -- the sort of
implication is we're just seeing them to show it was

a good thing. I was actually interested in seeing them
to hear from them what their view of Horizon was.

You tell us in your witness statement that when Post
Office's objections came in, you “did not allow Post
Office's objections to deflect me"?

Exactly.

Is that how you saw the Post Office's intervention,
namely an occasion on which they were seeking to deflect
you?

I think that's fair, yes.

Can we turn to what happened at the meeting itself and
the sources for that are unfortunately quite sparse.

Look at your witness statement, please, page 39,
paragraph 143. Page 39, paragraph 143. It's at the
foot of the page. You say:

"I met [Messrs Warmington and Henderson] on
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"4. The advantages of agreeing to meet Second Sight
would be", and then they're set out: demonstrate the
Government is listening; agreeing to maintain a positive
relationship with James Arbuthnot; assuaging a concern
that Second Sight believed that their findings are being
misrepresented; and the position that no Government
action is necessary since the CCRC is considering cases,
mediation is ongoing and Tim Parker is considering the
matter with a fresh pair of eyes would be stronger if
you can say you have met Mr Bridgen, Mr Arbuthnot and
Second Sight.

But then there are significant risks, it was said:
the operational matter point in (a); more stakeholders
in (b) "might have a reasonable expectation that
Government will opine on the merits"; (c) a risk of
briefing it out.

Over the page, 6, clearly a difficult judgement:

“Our view is that on balance you should offer
a meeting to Second Sight. The risks of doing so are
significant, but we believe they can be handled if we
are careful and robust in our messaging ...

"8. If you do decide to meet Second Sight we
suggest a low-key approach with an email from your
office to Mr Warmington ..."

Did you decide, therefore, that you should meet with
122

19 October 2015. I understand that, regrettably, [the
Department] has been unable to locate any minutes or
other record of the meeting. I recall listening
sympathetically to the issues raised, but I do not
remember much of the substance of the meeting: the
meeting was certainly not a ‘lightbulb moment’. I am
confident I would have informed them of the Parker
Review and that I had asked Tim Parker to meet them and
that I encouraged them to raise these issues with Mr Tim
Parker as part of that review."

Is that the limit of your recollection of the
meeting of 19 October?
Yes, the specific memory of that meeting, I can kind of
remember the room I was in, and so on, but unfortunately
there is no note of the meeting which makes it
difficult. But what I do remember was, you know, they
went through some of their points. Obviously, those
were becoming to become familiar to me because there was
a point about contracts, wasn't there, there was a point
of Bracknell remote being able to fiddle about without
a footprint, the thing that Mr McInnes had told me
wasn't possible. You know, there were various things
which they repeatedly said but their communication was
not of a kind -- very decent people, quite right to keep

going, but the communication was not of a kind that
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created a lightbulb moment and that's my recollection.
However, by then, I felt that we were moving towards
a solution and I encouraged them to talk to Tim Parker
and to Sir Jonathan Swift about, you know, what their
views were. I felt that this was the right way to get
those concerns looked at and in play and understand
whether the Post Office's long defence was correct or
whether the Second Sight Report was correct.
We gleaned something from what happened at that meeting
from paragraph 145 of the statement.
Yeah.
Because you cross-refer to a letter that you later wrote
to Oliver Letwin MP?
Yes.
You say of the meeting of 19 October:
"It was a helpful meeting and they raised a number
of important points. I suggested they contact Tim
Parker ... to follow [them] up. [He's] currently
conducting a review ... and has appointed a QC to advise
him. He is currently setting up meetings with the key
parties and [you are] expecting him to update [you] with
findings in the New Year."
I think that's all we know about the meeting of
19 October. Did you receive any periodic updates from

Mr Parker about the conduct of his review?
125

Obviously, I'd had that from him, which I noted.
I mean, the meeting in January, we had quite a lot of
issues to discuss, is my recollection. They probably
crowded out any discussion of Horizon.
If we turn then to Mr Parker's letter to you of 4 March,
POL00024913. We can see this is Mr Parker's letter to
you of 4 March 2016. He cross-refers to your meeting on
26 January and says he had provided you with an update
on the work he had undertaken with the assistance of
Messrs Swift and Knight, to review the Post Office's
handling of complaints made by subpostmasters about the
‘operation of the Horizon software system, and sets out
in the letter further information about the approach to
the review, scope of work undertaken so far, and his
initial findings, and outlines his plans to bring the
work to a conclusion?

This is a long letter and we haven't got the space
to go through it in detail, but on pages 1 and 2, under
the heading of "Scope of the Review", you'll see that he
sets out his objections to review the Post Office's
handling of complaints made by subpostmasters regarding
the alleged flaws in Horizon, and to determine whether
the processes designed and implemented by Post Office to
understand, investigate and resolve those complaints,

were reasonable and appropriate. Do those terms of
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I think during the next three or four months I had
meetings with him. I don't recall any letters or

anything from him but, from time to time, when I was
having a meeting on the Post Office, then Laura Thompson
would send me a background brief as to what was
happening and I think I asked for a meeting in January
because I think somewhere -- at some stage or other

I was told that he was hoping to have some findings in
the New Year, so I had sort of pencilled that into my
mind as the time to take up the story again.

We can see that from paragraph 150, if we go over the
page.

Yeah, there we are, 26th January. Yeah.

You had a meeting with Mr Parker, you cross-refer to
your own offices or ShEx's note. There were some
unrelated Horizon issues discussed, or issues unrelated
to Horizon, and he told you on Horizon that Jonathan
‘Swift "was about to report. He had found no systemic
problem".

Was the first communication in writing that you
received from Mr Parker about the Swift Report, or his,
Mr Parker's, review, a letter of 4 March 2016?

As far as I know, that was the first that I had anything
of substance, other than this it's all slightly --

“about to report”, and he found no systemic problem.
126

reference, or does that stated objective, accord with
your intention?
I think broadly. I mean, understand, investigate and
resolve -- the "resolve" is important too, and then if
you go down the letter, there are four areas which seem
quite reasonable ones to me. I mean, if you're
a minister you're not General Counsel for the
Department, you're not kind of fiddling about at the
margins -- what you want is to make sure that somebody
sensible is taking things forward. I thought the scope
looked all right to me, rightly or wrongly.
Over the page, he says that he decided that the
particular focus should be on four matters: criminal
prosecutions; the Horizon system, ie the software;
support provided through training and helplines; and
investigations in the circumstances of specific cases.
Can you assist as to whether or not that looked
broadly satisfactory to you?
That looked like the right headings to me.
He says, skipping a paragraph:
"... that [his] advisers requested and were given
unrestricted access to documentation."
I'll skip over whether that's accurate or not:
"Numerous meetings were held between them and

a range of Post Office staff and employees of Fujitsu",
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and he sets out the meetings that he had.

Then he sets out, for the rest of this page and on
to page 3, the principal findings and recommendations.
Did you understand that there existed separately from
this document a written report.

Certainly not a final report. I mean, I think they

might even talk about a draft at some point. The way

I read this was that they were -- they'd made quite

a lot of progress and that they'd found these areas
where they needed further investigation, which actually,
to my mind, matched some of the things I was concerned
about and so were the MPs. So I thought it was work in
progress, and I was -- I think I asked for advice from
Officials and they sort of said "You don't have to do
anything at this moment in time", so I was glad that
those various areas of further work were being carried
out.

Obviously, what I didn't know but you're probably
going to come on to ask me about, was this was.

a slightly rosy summary of the Swift Report --
Yeah, I --

- in my view.

Yes, I may choose words differently than "slightly
rosy". Can we go to page 4, please. "Next steps":

“I have commissioned independent persons to
129

kind of work in progress, that they'd got these extra
pieces of work to do, and that I would get a report from
the Chairman once that work was complete. He'd
mentioned May -- there was a Board meeting in May,

I think somebody told me, and clearly it's the sort of
thing that I would have expected the Post Office Board
to have a look at. But I was also aware that there were
some threads to follow up.

We know that, by this time, Jonathan Swift had provided
Mr Parker with a copy of his final report. Do you know
why Mr Parker did not state so in his letter?

I've no idea.

Did you discuss -- did he mention that there was a final
review report when you spoke with him?

I spoke to him in April, I think. I asked for advice

from officials, the officials said do nothing. I was
having a meeting with him anyway in April, one of my
quarterly meetings with him, and I don't recall him
saying that "I've got a final report’, or anything of

the sort that I might have asked for. I recall him

saying that the work was ongoing in these two or three
important areas, some of which turned out to be actually
quite relevant to the court cases that eventually came
through.

Do you know why he did not, without request, provide you
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undertake the necessary work ...

"I... share your aim that matters should be drawn
to a conclusion as soon as possible ... I anticipate
I will be in a position to report back on the outcome of
the further work during May.

"I firmly believe that the focus and scope of my
review to date, together with further work which I have
now commissioned, will allow me to confirm that the
processes designing and implemented by Post Office to
understand, investigate and resolve those complaints
were reasonable and appropriate, and that there are no
further enquiries ... to be undertaken ..."

Two other matters:

"... as I have noted ... a number of subpostmasters
have made applications to the [CCRC]. That work is
‘ongoing ... Second the Justice for Subpostmasters
Alliance is reported to have received funding [and] no
claim has [yet] been issued.”

Lastly, the last sentence:

"If you would like to discuss the review report with
me, I would be happy to do so."

Given the context of the letter as a whole and that
last sentence, did you understand there to exist some
freestanding review report?

No, to be honest, I didn't. I assumed that this was
130

with a copy of the report?
I've no idea but I think he's separately said it was
something to do with legal privilege.

Was that the discussion -- was that a discussion that
you had at the time, ie whether he could or could not
provide you with a report --

No, not that --

-- and, if not, why not?

Not that I recall. The letter is after all -- at the
beginning it says "This is legal privilege", and he sent
to me under its legal privilege. So what's the

difference between a letter which is legally privileged
and a document that is legally privileged? I'm not

sure. But, obviously, the fact that the two didn't

match was an issue that I don't know if Tim Parker
himself was aware of. He may not have been but, you
know, you have to read the longer report to see whether
the summary is -- it's not that the summary is wrong

it's more sins of omission.

Did you actively seek a copy of the report?

No, because I didn't have anything to do with the matter
after I'd had the advice from Laura Thompson not to do
anything until April, and then we had a meeting in

April. Is there a note of the meeting in April?

Um --
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I don't think there is.

I don't think there is, no.

No, sadly. But what I will have wanted, you know, I'd
asked him to do a review. I would have wanted the
conclusions of that review. I don't think it's
appropriate for ministers to suddenly see drafts of --

I mean, I'm thinking about other things that I've done
as a minister since, you know, you ask for a report and
you get the report in due course. You don't sort of
have iterations. That sort of undermines the
independence of the report almost, if it's being sent to
the minister in between.

If can we see a little of what was going on internally
POL00110382, and start with page 2, please. There's
an email of 19 February from Jane MacLeod to Tim Parker,
under the heading "Chairman's Enquiry":

“As discussed last week, we have considered the best
way for you to brief the Minister on the outcome of your
enquiry ... I expressed concerns that were we to provide
the Minister with a copy of the legal advice you
received from Jonathan Swift, there was a risk that
privilege could be lost and that the report could become
disclosable by BIS through FOI requests or similar. We
have also received a call from the Minister's office in

which they sought to understand how the reporting would
133

The rest of the chain deals with the drafting of the
letter, which eventually became the 4 March 2016 letter.
Were you ever made aware, prior to Mr Parker sending the
letter on 4 March 2016 that Post Office had discussed
either with ShEx or your office their intended approach
of sending a letter that was claimed to be a summary of
the reviews findings?
No.
Were you ever made aware that the full review report was
not to be provided, it was said, in order to preserve
privilege over it?
Well, certainly not at that stage. I think probably
never. I mean when I stopped doing it -- we'll come on
to this no doubt -- I thought the sort of follow-up work
was continuing because there was one or two quite
important bits of work by Deloitte and others, but then
it all got muddled up with the general court case by the
subpostmasters group but, you know, at this stage
I would have assumed that I would have -- would get the
full report in due course with recommendations as to
what to do, and recommendations on how we communicated
that to Arbuthnot and others and how we communicated it
to the world at large.

After all, you know, my concern came from the points

that they'd raised with me a few months earlier, which
135

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be undertaken. During that call it became apparent that
BIS officials are also concerned as to the legal status
and positioning of any report received from you."

Those last two sentences suggest that people in your
private office were seeking to understand how the report
or reporting of the outcome of the review would be
undertaken and they said that BIS officials were
concermed about the status and positioning of the
report. Was that something in which you had any
involvement?

Well, (a) I had no involvement and (b) having --
obviously I was very concerned to read this at the time,
when the Inquiry sent me all these papers because it was
suggested that my private office were working behind my
back and not giving me full information. But I don't

think that the Minister's office reference is correct.

I think in the Minister's office, they mean --

ShEx --

-- Ms Thompson. They were thinking she -- they're
getting muddled up between my private secretaries and
Ms Thompson, who didn't work for me; she worked for
ShEx, and they may -- you'd have to ask them, you know,
what they felt about all of that. This is just the time

when we got the referendum starting, isn't it so a busy

time for ministers.
134

I'd -- was -- I was -- you know, I'd obviously continued

to be worried about.

In his witness statement -- I'm not going to display it

now and that document can come down from the screen --
the cross-reference is WITN00690100, and it's

paragraph 93 -- Tim Parker says:

"Baroness Neville-Rolfe and her office was made
aware of the approach being taken to the distribution of
the Swift Review to seek to maintain legal privilege."
Do you know what date that was?

He doesn't cross-reference it. He simply says you and
your office were made aware of the approach being taken
to the distribution of the Swift Review to seek to
maintain legal privilege; is that correct?

Well, as I said when I looked at this earlier, I wasn't
convinced it was my office and I don't recall my office
coming in to say to me "You can't have this document".
So either that's a mistake in the email, which refers to
your office and it's meant to mean ShEx --

Yeah.

- or your office had kept something from you?

Correct. Why I said when was it, it was -- obviously by
the time you get to sort of July, it's then unclear

who's going to be Minister because we'd had a big

change, change of Secretary of State, and I lost the
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Post Office brief in that carve-up, and they seemed to
think, even before I lost it, that I might lose it, if

you read the paperwork.

Okay. You tell us in your witness statement that the

first time you saw the Swift Report was earlier this

year as a result of the --

Yes, it was during the Inquiry when the documents came
through and, obviously, I was very interested to see it.
Obviously the letter I'd seen but not the Swift Report.

Did you compare the report with the letter?

In preparing for this Inquiry I did.

What view did you take in comparing --

Well, I took the view that it was a bit, you know, it

put a positive gloss --

I think it's paragraph 166?

I think I've dealt with it in my inquiry -- so there was

two -- there was a generality that it seemed to be

saying there wasn't too much of a problem in spite of

the fact that there was all these extra areas to be
explored, and then there was stuff that particularly
concerned me about how prosecutors had tried to do deals
with people who were being prosecuted by getting them to
accept false accounting, you know, as a quid pro quo for
dropping theft charges, and that came out -- I think

that's 100 to 109 of the Swift Review.
137

charging theft and false accounting, it did not refer to
the important and strongly critical findings in
paragraphs 100-109 ...

"These specific findings should have been brought to
my attention.

"I was surprised and disappointed to discover, years
later, that Mr Swift's findings were not disclosed as
part of any criminal or civil proceedings. I do think
this is nothing short of scandalous."

What action would you have taken if you had been
provided with the raw material, ie the Swift Report
itself?
Well, I would have read the report, I would have seen
those paragraphs and other paragraphs, and I would have
wanted to take steps to make sure that this duty of
disclosure was implemented. I mean, when I came in,
I asked about documents. I was told by the MPs that
people were destroying files. I tried to make sure that
that didn't happen, and yet here we've got an instance
where things are not being disclosed. And I think
you've found, Mr Beer, as part of your other hearings
with Fujitsu and others, that there was material. In
fact, the -- some of the Deloitte stuff was referred to
in Mr Swift's report, but not in the covering letter, as

far as I can recall.
139

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If you look at -- if we display it on the screen,
because there's a quite neat summary -- your witness
statement at page 45, paragraph 166.

Yeah.

Page 45, paragraph 166. You say:

"Even more importantly I now see having had access
to the Swift Report, that Mr Parker's reassuring summary
of the report was materially misleading. Specifically,
it failed to make any reference to the important points
made [by Mr Swift (sic)] in paragraphs 145-147 ... which
concern remote access and directly undermine the
information provided to ministers and, in turn,

Parliament, and indicate serious historic and ongoing
concerns as to [Post Office's] compliance with its
disclosure obligations in relation to criminal

prosecutions and convictions. This contradicts the
assurances given in the second paragraph of the Criminal
Prosecutions section of Mr Parker's letter, 'l am

satisfied that Post Office has adopted a proper approach
to disclosure such that it satisfies its duty of

disclosure as [a] prosecutor’. Alll this touches on my

key concern which was that postmasters should be able to
secure justice through the CCRC process.

"Similarly, whilst it refers to further work

commissioned in relation to [Post Office's] tactic of
138

So what you've got is some really quite explosive
material in that detailed report which should have been
referred to in the letter to me, in my opinion.

Well, in particular, would you agree, since the relevant
Deloitte report was then two years old in the tooth, and
that report had itself been provided to a number of
senior executives and a summary of it had been provided
to the Board?

Absolutely, and there was almost a suggestion that that
was new material, I think, that Swift had got hold of.
Sorry, we hadn't got up the Swift Report but, for those
involved in the Inquiry, I think it makes extremely good
reading because it summarises a lot of the background
very well and, frankly, it would have been good, you
know, for everybody to have had that summary made
available much more broadly, including, I would suggest,
to the Board of the Post Office.

To what extent did you have any dealings with Jane
MacLeod?

Well, I think she came to the meeting on 6 August with
Paula Vennells. I think that's my only dealing with her
that I'm aware of.

Therefore, would that be an insufficient basis to form

a view or impression of her?

It would and I know she hasn't given you evidence, which
140

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The Post Office Horizon IT Inquiry

is a pity because obviously a lot of the work she did
touched on these issues that are so important to the
subpostmasters --
Exactly ~
-- who are in the firing line on all of this.
-- and Mr Parker said it was Jane MacLeod who told him
that he couldn't disclose the Swift Report to you.
Well, there you are.
Can we move forwards, please, to a draft letter, as
I think it rightly is called, of 21 June 2016, and turn
up paragraphs 180 to 181 of your witness statement,
which are on page 48. You tell us that you have had
sight of an unsigned draft letter of 21 June from Tim
Parker to you. In it, Mr Parker says that Post Office:
"has received very strong advice from Leading
Counsel that the work being undertaken under the aegis
of my review should come to an immediate end, and
instead address the issues through equivalent work taken
forward in the litigation ... I have therefore
instructed that the work being undertaken pursuant to my
review should now be stopped’.”
You say the first time you saw this draft letter was
in preparation for the Inquiry. A FOIA request said
that they couldn't locate any information that the

letter was in fact sent to the Department. You are told
141

So I was -- I mean, I thought -- I described it as
scandalous but I also think it's very surprising and
I don't know -- obviously you'd have to ask the counsel
that was involved in that litigation, you know, why it
wasn't made available to anybody.

Thank you. That can come down.

You make a number of observations in your statement
by way of reflections. You say that Government cannot
function if ministers are unable to trust the
information that they are provided with by officials.

You say that you were, by mid-August, fighting ShEx,
that you had lost confidence in the quality of ShEx
advice, that they were trying to obstruct or shut down
your efforts to get to grips with the issues, that you
had lost the confidence in your civil servants on
matters relating to Post Office and Horizon.

Did you ever escalate any of those matters to the
Secretary of State?
I think I told the Secretary of State in August that
I was unhappy and that, therefore, I was calling for
a review by Tim Parker, and that my recollection is that
he supported that, that it could get to the bottom of
things, you know, in a reasonable way. You know, so --
sorry, So -- and then -- I mean, I think, at updates,

which are unrecorded because of the problem of lack of
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by the Department that it has no record of receiving it
and you're confident you didn't see it at the time: is

that right?

That's right. I was amazed when I saw it, to be honest.
How, therefore, in the absence of that letter, was the
work that was outstanding from the Swift Review, that
was summarised in the 4 March letter, rounded off for
you?

Well, it wasn't really rounded off. There was, in the
briefing that I got in July, they said well, they were
looking at how the Swift Review stuff fitted in with the
civil litigation, which I think was perfectly reasonable

to look at the two alongside each other. But obviously,

I never had any advice on what then happened as a result
of that. What I discovered, you know, a couple of years
ago or whenever -- partly when looking, I think, for the
Inquiry, and partly I discovered that, you know, the
Swift Review had basically been buried, which I was
quite surprised by, because when you have legal cases,
there's huge processes of discovery -- I mean, I know
this from my background at Tesco -- there are huge
processes of discovery for documents, and you have to,
as a -- your lawyers have to make sure that things are
made available that may help, you know, the people

bringing the case.
142

records, I might well have mentioned my concerns and,
you know, getting stuff done on this issue. And I think

I had an update with Mr Russell at some point, who was
the CEO, and I think you showed me a piece of paper just
before I came in this afternoon which actually is quite
helpful because, for the first time, I can see I did

raise it with the Permanent Secretary, as an issue.
Perhaps you're going to show me that.

In fact, somebody else is going to show you that and
they ask that you be shown the piece of paper, so --
Oh, thank you. Let them ask me.

-- I'll let them do it.

Were they the alternative possibilities, of raising
your concerns with the Permanent Secretary, Martin
Donnelly; the Chief Executive of ShEx, Mark Russell; or
the Chair of the ShEx Advisory Board, Robert Swannell?
Well, if you look at a lot of the papers, they're copied
to the Permanent Secretary, they're copied to the
Minister's office, they're copied to Mr Russell. And in
the Civil Service, that's, you know, I was -- used to be
a civil servant -- that's the way senior civil servants
like Permanent Secretaries get an eye on things. They
get a lot of paper that they sift through and, as it
happens, I did recall having a bit of a moan to Martin

Donnelly and, actually, he did something about it, as
144

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The Post Office Horizon IT Inquiry

this document we're going to come on to discuss shows.
Obviously I felt happier once Tim Parker had taken
‘on the mantle of bringing in an independent adviser to
look at the complications, and, you know, although we've
focused on the negative from ShEx, you have to bear in
mind that, in my Post Office brief, I was looking at
lots of different things, transformation, the accounts,
visiting post offices, you know, how -- what was their
strategy going to be go forwards? So they didn't have
to have so much of the taxpayers’ money but kept the
network which was so vital to local communities going.
So, you know, it wasn't all negative but, clearly,
‘on this Horizon thing, they seemed to be particularly
narrow and, as I've said several times when I asked for
detailed advice on the Second Sight Report towards the
end of August, I didn't get a submission as I should
have done outlining the various accusations and what we
as the Department thought about those. I got a defence
document from the Post Office.
MR BEER: Baroness Neville-Rolfe, thank you very much for
answering my questions. That's all of the questions
that I propose to ask.
There are, I think, a number of Core Participants
that wish to ask questions. I know that Mr Henry has

15 minutes or so, maybe if we start with those, that
145

appears to be endemic within the UKGI on this subject?
Do you regard this as something which has hampered you?

A. I certainly do. I think it's very unfortunate and, if

you look at one or two of the documents, it says at the
bottom: "It isn't the private office's responsibility to
keep documents; it's your responsibility as the advising
division", which I found quite surprising.

I mean, latterly, I've been a Cabinet Office
Minister and I asked my staff what they did about
records and they explained that, every three months,
they send off a pile of papers to the archives.

Q. Right. So this appears to be unusual?
A. So it may be that it's unusual. I mean, it's not

something that I can really comment on. It's more for
the civil servants in charge of records. But it has
certainly been very unhelpful for me and, I think, for
other Ministers, that they haven't been able to see the
contemporaneous notes. You know, has one forgotten
important things? We've all tried our hardest, I'm
sure, but it's quite difficult.

Q. Right. I now want to go to a document which is

UKGI00019859. While it's being put up on the screens,
one of the themes that has dominated the Inquiry has
been the constant refrain, "We had every reason to

believe Horizon was robust. We were told this by the
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will take us to the break at 3.00.
Questioned by MR HENRY

MR HENRY: Good afternoon, Baroness Neville-Rolfe.

Itis often said that openness is the first casualty
of a project that is in serious trouble, and you
wouldn't disagree with that observation, would you,
given your experience with the Post Office?

A. No, and generally -- obviously, I come from a background
in business where your working assumption has to be
that, you know, that things do become public and it's
better to --

Q. Exactly. One paragraph among many, but early on in your
statement, was striking, and it was your paragraph 5,
which reads:

"I would like to emphasise that a large number of
documents which would have been helpful in preparing
this statement, such as the minutes of several meetings
in my Ministerial Diary, have not been made available to
me. This is perhaps because, in 2016, the Shareholder
Executive and its staff and records were transferred out
of BIS to become part of the newly formed UKGI and, in
the same year, BIS was merged into a new department."

This is a refrain at paragraphs 31, 42, 101, 143 and
177 of your witness statement. Given your experience in

Government, how disturbing is this loss of data which
146

Post Office. We were told this by ShEx".

You, however, did not believe that, did you,
Baroness Neville-Rolfe, because in this document you
expressed the view that it was probably one of HM
Government's IT debacles, and we can scroll down. We
have Richard Callard at the top, but then it's from Tim
McInnes. Do you see the second bullet point:

“As she's [that's you, Baroness Neville-Rolfe]
mentioned before, she thought Horizon was another
example of a Government IT debacle and that innocent
subpostmasters were the victims."

Then Mr McInnes says, and this is 12 June 2015:

"Clearly this is wholly untrue in two respects,
probably untrue in a third.”

The general tone of this -- I don't want to distract
you -- is slightly derisory or slightly mocking but
I don't want to distract you with that. But what I want
to explore with you is why you thought that; why you
harboured the suspicion that Horizon was another
Government IT debacle. Would I be right in suspecting
that part of your scepticism no doubt came from your
personal experience in business?

A. I think so but also my experience of Government IT

systems. You know, there'd been police computers,

various different IT things, and Government do seem to
148

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find -- or did -- perhaps did seem to find -- you know,
getting IT systems right very difficult.

Very difficult.

And, you know, a key to having good systems -- it's been
my experience, partly as a non-exec in other companies,
but also a little bit when I was at Tesco -- is you've

got to have really good induction, training, helplines

and learn from mistakes as you go along, because it is
inherently difficult, bringing in IT systems and I have

to say that the Horizon system, if you look at the

Second Sight Report, had to do an awful lot of stuff.
Yes.

And I'm sure that the IT providers will have known that.
They were obviously experienced IT providers in lots of
areas. But, you know, I came -- I suppose it's fair to

say this was very early on and it probably irritated
Officials -- but I came in with a certain questioning --
questioning of IT and I would have wanted to hear why
there weren't the sort of problems that we'd seen in
some of these other areas, from my recollection of when
I worked in Government and --

Yes, and, of course, you'd served in Government in the
1990s and you'd served in Government --

Exactly.

-- from, I think it's right, 2015 onwards?
149

bugs and things to start with, and so you've got to have
really good support and training and helplines, and help
people.

And an openness and a commitment --

Exactly.

-- to get it right, as opposed to covering it up?
Absolutely.

I mean this, of course -- notoriously, Horizon grew out
of the problems that the DSS had had with it, had it
not?

I don't think I know the background to the -- the early
background to Horizon but that sounds quite likely
because, after all, they were -- you know, there was
this question of making payments to individual benefit
claimants, yes.

So to this refrain, where we were being told that it was
robust, you certainly weren't gulled by that, and the
wool wasn't pulled over your eyes by that, hence your
scepticism and the fact you were probing?

I tried to probe but I also tried to take advice because
the Civil Service has to work on the basis that

officials set things out in a cool and sensible way for
the attention of Ministers, offering them options, you
know, considering what needs to be done in the public

interest. I know that because obviously, to some
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Well, until I went to Tesco in '97, I worked in
Government latterly in the Cabinet Office, and in the
Business Department, and in Number 10. Then I had
15 and a half years in business. Then I joined the
Lords and I became a Minister in 2014. And then I was
a Minister for about three years and then, after the
referendum, I went on the backbenches, and then I've
been back being a minister.

So I'm quite unique in having had such a lot of
different experience: business, Civil Service and
several ministerial departments. So I suppose I thought
it was a fair comment to talk about IT debacles, even if
the Shareholder Executive obviously found that
exceptional.

So, therefore, it's within your direct knowledge that
Government had suffered notorious problems with IT
systems for decades?

Yeah.

You mentioned the police. There was also, I think it's
right, the Inland Revenue had difficulties with IT
problems?

They did, and especially moving to self-assessment,
although, actually, in time, they sorted them out. So
it was very bad to start with and then gradually it got

better. I think that's the problem. You get a lot of
150

extent, I had residual Civil Service values in my DNA.
Could I now move to the role of the Civil Service,
because you once said in the House of Lords:

"My Lords, having had previous responsibility for
the Post Office, I am very well aware that ministers are
advised to stand firm on seemingly solid grounds, only
for it to become clear in the long term that that is not
defensible."

Now, you may have heard the Right Honourable Pat
McFadden's suggestion regarding a new body to
investigate potentially rogue arm's-length businesses.
What would you suggest, however, be done about
potentially reckless advisers and officials who seemed
to have lost their objectivity and upon whom you relied?
Right, well, that's quite a big question. I mean, off
the cuff, a couple of points. One, I think it's
incredibly important to have the right people in jobs.

So you need good performance culture. You need to hire
the right people. You need to give them feedback when
they're not there. I think, as an ex-civil servant,

I mean, the role of the Permanent Secretary is also
important. So, if you think about financial matters, if
ministers ask civil servants to spend money that they
think is poor value for money, then the Perm Sec can

object and they send a memo that -- you know there has
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to be an instruction from the Permanent Secretary to
the -- from the Minister to the Permanent Secretary
saying, "I, the Minister, think it's right to do this,
even though you've expressed some reservations".

I mean, rather than setting up a whole new
department to do this sort of thing on the off-chance
that there might be -- I hope never -- repeats of this
sort of thing, my only thought is: is there some way
that you could, you know, bring that kind of thing into
play and people would then know that, if their work was
a problem -- I mean, obviously, you can always go to the
Secretary of State. That is the sum role of the
Permanent Secretary. I don't know exactly what Pat
McFadden said. I'm sure he was trying to be helpful.
So is there anyone you could have depended upon
independently, at the time, to validate the truth and
honesty of important ministerial statements before you
made them, to prevent the mischief that you were
speaking of in the House of Lords, that ultimately those
statements had become untenable?
I mean, the truth is that, as a politician, you are
extraordinarily aware that anything you say on the
public record in the House, whether it's the Lords or
the Commons, has to be accurate. And there are

well-established processes for correcting the record, if
153

Can I come to that because, of course, one such recruit
was Mr Callard, and the final document for you,
Baroness, is UKGI00017443. This is an email that

Mr Callard sent on 18 November 2015. Could we go to
Mr Callard's email, which is, I think, on page 2. It's

18 November 2015 at 18.25. Yes, thank you very much.

This is in response to you expressing some dismay
with the way you had been informed of matters, and this
is Mr Callard stating that he believed that you'd been
a bit harsh:

"The problem is we cannot deliver what she [that's
you, Baroness] wants (a green-locked GIB, and a Post
Office without a perceived but non-existent IT problem).
Bit harsh from my perspective, we've kept a lid on the
latter", he says.

So in other words, "We've kept a lid on the Post
Office".

Baroness, given everything that you instituted, did
you want Richard Callard to keep a lid on the
subpostmasters' dispute with the Post Office?

No, I wanted to get to the bottom of the matter and the
truth of the matter.

Exactly. So what he's done there is precisely the
opposite of what you wanted, isn't it?

It does seem to be. Obviously I hadn't seen this at the
155

23 July 2024

1 you have to do that. I mean, that arose during Covid,

2 of course, didn't it?

3 So, I mean, the answer is you have to try and find
4 a way of getting at the truth and, if you find out that

5 the truth hasn't been communicated, then you have to
6 correct the record. I think, if Sir Wyn is thinking

7 about what might be done for the future -- and I think

8 you've got a further sort of whole module on this -- you
9 need to just have a think about how this would work in
10 practice and whether there would be perverse effects to
"1 bringing in a whole new sort of tier.

12 I mean, the key thing, in organisations where you've
13 got people who aren't very good, what happens is you
14 move them. You move them on. In the Civil Service, the
15 Civil Service -- the appointments are rightly for the

16 Civil Service, rather than for the Ministers, to avoid,

17 you know, inappropriate -- or, you know, people having
18 their friends in the wrong places, and I think that is

19 valuable, that independence of the Civil Service.

20 So I think you need to look at this particularly in

21 the light of ShEx, where you were bringing in a lot of

22 people from outside the Civil Service, and it might be
23 that you could do more to help them, to induct them, to
24 make sure that their sort of -- their reports are

25 looking properly at what might go wrong.

154

1 time, and I had taken steps to say that I would like

2 more political handling, as you can see from the

3 subsequent memo in this area and in the Green Investment
4 Bank -- which also, as I said earlier, involves, you

5 know, people from outside who come in, and that's great
6 that they come in and bring their expertise, but it's

7 also important that you follow the values of --

8 Q. Government?

9 A. --of transparency, truth, and Government.

10 MRHENRY: Yes.

11 Thank you very much, Baroness.

12. SIRWYN WILLIAMS: Thank you, Mr Henry.

13 ‘So we'll have our break now, Mr Beer?

14 MRBEER: Sir, can I just check with the Core Participants
15 how long they will be?

16 SIRWYN WILLIAMS: Yes, of course.

17 MRBEER: If it's a short period of time, then it might be

18 that we can survive without a break.

19 SIRWYNWILLIAMS: Yes, sure.

20 MRBEER: One Core Participant, five minutes.

21  SIRWYN WILLIAMS: Then we will have our five minutes.
22 MRBEER: Thank you.
23 Questioned by MR JACOBS

24 MRJACOBS: Good afternoon.

25 A. Good afternoon.
156

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I don't know if you can hear me. I represent a large
number of Core Participants, subpostmasters and
subpostmistresses, who were affected by this scandal.
Mr Beer asked you about your reflections. Mr Henry took
you to some correspondence involving Mr Callard. I have
a couple of very brief further questions.

You've said in your evidence that you believed that
you were being misled. You've also said that you
believe that ShEx and Post Office were working together
to try to deflect you. We have that email where
Mr Callard was trying to arrange a meeting with Post
Office officials to talk about a forthcoming meeting
with you and the Chief Executive, and to gauge your mood
and what it is that you wanted to do. So they were
colluding and talking about you behind your back,
effectively.

It's right, isn't it, that your experience is that
ShEx were far too close to the Post Office?
I think they weren't taking in alternative sources of
information. I mean, clearly, they were going to have
to be close to the Post Office because the Post Office
had all the facts on individual cases.
But they lost their objectivity?
My worry was that they'd lost their objectivity in all

of that. That was at the heart of the problem, I think.
157

meeting just to say hello to people.

Because it's very different, and what you have to do
in the public sector is a bit different, I think it's
very, very important that they should understand that,
and that, obviously, was an understanding by Mr Callard.
He felt that it was important to keep the lid on but,
obviously, as a civil servant, it's not only keeping the
lid on; it's also making sure that you're doing the
right thing.
In terms of public duties and serving the public, did
you perceive there to be any ethical difference between
ShEx officials and the rest of the civil servants who
you worked with?
I don't think we discussed ethics but they obviously
took a very narrow, focused view, linked to their duties
in terms of the commercial and strategic vision for the
POL, and didn't seem to focus so much on classic
governance issues like, you know, the risk from these
prosecutions, which would be something that, as a civil
servant, you're always looking at the downside, as well
as the commercial opportunity.

I mean, having said that, they were trying to move
forward. Paula Vennells, to give her credit, reduced
the deficits in the Post Office. So the Post Office

must have been doing something right at that time.
159

1 QI just want to clarify a point, it may have already been
2 made, but it just seems to be quite an important point.

3 You made a distinction, at 12.20 this afternoon, that

4 ShEx was made up of commercial people and not classic
5 civil servants/Civil Service Officials. Do you think

6 things would have been different, from what you

7 experienced, had the body charged with oversight of the
8 Post Office been composed of classic Civil Service

9 Officials?

10 A. I'm not sure that they would have had the expertise to

1 hold shareholdings in things like the banks and the Post
12 Office, and things, without commercial expertise. I'm

13 not against commercial expertise. I think what I was

14 saying is that that's not necessarily sufficient.

15 I mean, having said that, there were some -- I mean,
16 Susannah Storey, who I think you're seeing later, whom
17 I know from DCMS, I mean she was a civil servant of the
18 classic kind. So there was a mixture. But they --

19 I think that -- I think -- I'm not sure the Civil

20 Service is as good -- I remember when I went to work in
21 the private sector, the whole of my first month was
22 induction, and I had three-hour meetings with all of the
23 key directors -- three-hour meetings, which I couldn't

24 understand. The difference, when you go to work in

25 Civil Service, is you're lucky to get a 15-minute

158

1 Q. Finally, Baroness, this narrow view, this lack of focus

2 on more public interest-type problems, such as

3 prosecution, is that, on your evidence, the fault in the

4 system which prevented you from being able to carry out
5 your ministerial duties in terms of receiving the right

6 information?

7 A. I think it was also to do with the particular

8 individuals because I gave them lots of openings,

9 saying, you know, "What's in the Second Sight Report?"
10 If I had been, my previous self, sitting in that seat,

11 I would have gone away and I would have read the whole
12 of the Second Sight Report and I would have gone through
13 all of the negative findings and I would have then

14 wanted to do my own job, understanding what was right
15 and what was wrong. That wasn't done.

16 What they did was take advice from the Post Office
17 because they felt the Post Office could give the answers
18 and that isn't what you do. As a good civil servant,

19 you bring -- you look at different -- you know, you look
20 at different sources.

21 MRJACOBS: I think that's answered my question. I haven't
22 ‘other questions for you. Thank you.
23 THE WITNESS: Thank you.

24 Questioned by SIR WYN WILLIAMS

25 SIRWYN WILLIAMS: Baroness, are you a supporter of

160

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arm's-length bodies?

A. As I think I said in my statement, I think they do have
value. If you think about Government owning things like
banks, the Post Office, it's not really possible for
ministers to be responsible on a day-to-day basis.
Therefore, the arm's-length system was set up. However,
as I said, I think, in my statement, it's extremely
important -- it's almost even more important that you
have really good people engaged, and I think people need
to understand that, when you are the board member on
an ALB representing the Government, you have a very
important duty and, actually, it's quite similar,
private equity, where they own a big stake in a company,
which I've had experience of, they put a director on the
board, and that director, I can tell you, is always
asking questions and thinking about, as it were, the
owners’ needs, both financial and non-financial. So
does that answer my question, Sir Wyn?

SIR WYN WILLIAMS: Well, it does. I'm just wondering how
easy it is, actually, to find this super-charged person
who is able to always distinguish between his or her
duties as a member of the Board, ie his or her duties to
the company, and, at the same time, represent
a shareholder who is not necessarily aligned with all

the objects of the company because the shareholder will
161

I'm very grateful to you for making a very detailed
witness statement and for answering a good many
questions during the course of most of today. So,
again, thank you very much for your witness statement,
and for appearing to give oral evidence.

THE WITNESS: = Thank you.

‘SIR WYN WILLIAMS: Right, Mr Beer. Is that it for the day?

MR BEER: tis, sir. We return tomorrow with Margot James.

SIR WYN WILLIAMS: Yes.

MR BEER: Tomorrow being a Wednesday, might I suggest that
we start at 10.05, so that we don't have the
interruption of the fire alarm?

‘SIR WYN WILLIAMS: I don't think I need much of a temptation
to start a little later, Mr Beer.

MRBEER: 10.05 itis. Thank you very much, sir.

‘SIR WYN WILLIAMS: Fine.

(3.12 pm)

(The hearing adjourned until 10.05 am the following day)

163

23 July 2024

1 have things like, for example, the social value of
2 keeping post offices open in their head.

3 So I'm just wondering how easy or not, as the case
4 may be, it is to find this person who is able to perform

5 these, as I would see it, extremely difficult tasks?

6 A. I think it is difficult but I think if you have clear

7 objectives that all understand and those are kind of

8 trained in at the beginning through induction, and my

9 experience, which is quite limited of private equity, is

10 that the people they put on boards to represent them,
"1 you know, have sort of central -- if you like, central

12 training, they're selected to be able both to sit on

13 boards and to take an independent view, and it may be
14 that the cadre of people that we have in ShEx, which is
15 now UKGI, you know, have to have that kind of support.
16 I have to say, you know, I'm obviously not up to

17 date on what they do do, but it is a very interesting,

18 important area because you've got to get the mixture of
19 these operations moving forward commercially, but

20 reflecting the public sector value, sometimes the social
21 value, sometimes obviously value for money, which
22 matters as well, and which the external people can

23 really help with. It's difficult. I don't envy them

24 their task, Sir Wyn.

25 SIRWYN WILLIAMS: All right. Thank you very much. Well,

162
INDEX

BARONESS LUCY NEVILLE-ROLFE (sworn)...... 1

Questioned by MR BEER .

Questioned by MR HENRY ... 146
Questioned by MR JACOBS ..... 157
Questioned by SIR WYN WILLIAMS .. 161

164

(41) Pages 161 - 164
MR BEER: [25] 1/3
1/5 1/10 35/8 57/12
57/16 57/20 57/23
94/2 94/5 94/9 94/13
113/2 113/6 113/10
113/14 113/16 145/20
156/14 156/17 156/20
156/22 163/8 163/10
163/15

MR HENRY: [2]
146/3 156/10

MR JACOBS: [2]
156/24 160/21

SIR WYN WILLIAMS:
[23] 1/4 1/7 34/14
34/25 35/7 57/15
57/22 94/4 94/12
113/5 113/9 113/15
156/12 156/16 156/19
156/21 160/25 161/19
162/25 163/7 163/9
163/13 163/16

THE WITNESS: [2]
160/23 163/6

"97 [1] 150/1
‘better’ [1] 110/15
‘biased [1] 121/23
‘cajole' [1] 61/19
"contempt' [2] 40/5
46/4

‘Dickensian’ [1] 62/2
"Gagging' [1] 63/25
“get [1] 48/7

"got [1] 68/2
"great [2] 38/25 39/6
‘has [1] 141/15
highly [4] 38/7
"Horizon [1] 71/1
‘Horizon’ [1] 71/1
I[1] 138/18

‘Lam [1] 138/18
‘independent [1]
109/21

‘is [1] 38/9
‘Leaning’ [1] 63/24
‘lightbulb [1] 124/6
‘lost [1] 39/15
"Part [1] 75/19
‘Post [1] 40/2
"Second [1] 70/15
‘solutions’ [1] 65/5
‘suspicious’ [1] 62/3
"the [2] 39/1 42/8
‘there [1] 73/3
“trying [1] 22/20

= who [4] 141/5

w! [2] 39/16 40/8

=

1 July [4] 40/21

1 October [1] 121/10
1.06 [1] 113/11

4.55 [2] 113/8 113/13
10 [4] 2/5 68/13 69/9
150/3

10 July [1] 50/16

10 September [3]
105/13 111/1 111/3
10 years [1] 63/7
10.05 [2] 163/11
163/15

10.05 am [1] 163/18
100 [2] 101/2 137/25
100,000 [1] 77/19
104 [2] 101/11
146/23

102 [4] 91/7

103 [1] 103/17

109 [2] 137/25 139/3
11 June [2] 35/20
35/24

11,700 [4] 18/18
11.14 [1] 57/17
11.25 [2] 57/14 57/19
110 [1] 82/7

12 [1] 37/21

142 June [1] 148/12
12 May [1] 2/22
12.20 [1] 158/3
12.23 [1] 94/6

12.35 [2] 94/3 94/8
125 [1] 85/13

13 [5] 13/4 13/5
14/16 23/12 24/20
13 July [1] 2/22
136 [2] 18/17 19/10
14 [3] 2/24 6/9 14/16
14 August [2] 75/17
75/22

14-month [1] 3/5
143 [3] 123/23
123/23 146/23

145 [4] 125/10

147 [1] 138/10

15 [1] 2/14

15 and [1] 150/4

15 July [1] 61/5

15 minutes [1]
145/25

150 [1] 126/11

16 [1] 47/18

166 [3] 137/15 138/3
138/5

17 [2] 58/5 58/6

17 August [1] 38/2
17 July [4] 67/5
177 [1] 146/24

18 May [1] 10/21

18 November [2]
155/4 155/6

18.25 [1] 155/6

180 [4] 141/11

181 [1] 141/11

19 [1] 133/15

19 October [6] 113/7
113/17 124/1 124/12
125/15 125/24

1973 [1] 1/25
1990s [1] 149/23
1997 [4] 1/25

2nd [1] 50/17

97/20

3

A

3 August [1] 96/22
3.00 [1] 146/1

3.12 [1] 163/17

30 [1] 82/7

31 [4] 146/23

31 July [2] 80/7
94/22

34 [2] 82/6 82/10

39 [2] 123/22 123/23

4

2 July [1] 48/13

2 June [5] 11/23
16/19 16/22 35/10
36/25

2-3 [4] 36/5

2012 [2] 15/1 19/8
2013 [5] 2/17 15/6
18/9 19/8 70/16
2014 [2] 2/17 150/5
2015 [29] 2/22 3/16
3/17 4/18 11/23 15/6
16/19 19/9 20/25
35/10 35/20 36/25
37/24 70/6 70/16 82/8
83/6 90/19 105/13
113/7 113/17 113/25
117/21 121/10 124/1
148/12 149/25 155/4
155/6

2016 [7] 2/22 126/22
127/7 135/2 135/4
141/10 146/19

2017 [1] 2/17

2024 [2] 1/1 1/15
21 June [2] 141/10
141/13

22 [1] 114/10

22 July [2] 70/6
113/22

22 June [1] 13/4

23 July 2024 [4] 1/1
239 [1] 85/15

24 June 2015 [1]
37/24

24 years [1] 1/25
26 [2] 96/16 96/16
26 January [1] 127/8
26 June [3] 1/15 1/21
38/23

26th January [1]
126/13

27 [2] 91/7 101/2
28 [1] 114/10

28 July [1] 114/4
28 pages [1] 12/13
29 June [1] 38/2

29 May [2] 11/25
16/21

290 [1] 31/12

29th [1] 39/12

4 August [7] 73/19
86/22 90/19 97/6 98/1
99/20 114/4

4 March [6] 126/22
127/5 127/7 135/2
135/4 142/7

42 [1] 146/23

45 [2] 138/3 138/5
46 [2] 37/22 37/23
47 [4] 38/11

48 [1] 141/12

4th [4] 74/20 97/19
99/10 99/11

5
5 August [1] 114/19
50 [1] 38/20
51 [1] 39/11
52 [1] 39/23
58 [1] 47/18

6

6 August [7] 96/19
97/4 97/11 100/25

101/14 103/20 140/20)

61 [1] 85/15
62 [1] 58/7

63 [1] 59/3

65 [1] 66/8

68,000 [1] 18/17
6th [3] 90/24 97/19
99/13

7

72 [1] 1/17
72 pages [1] 1/15

Bo
8.17 [1] 61/5
83-page [2] 74/4
75/24

88 [4] 80/5

9

9 June [2] 35/21
35/22

9 October [1] 117/21
9.45 [1] 1/2

93 [1] 136/6

99 [3] 96/15 96/16

abide [2] 29/2 117/1
able [14] 10/19 55/11
62/20 66/22 66/24
92/11 110/14 124/20
138/22 147/17 160/4
161/21 162/4 162/12
about [122] 4/3 5/5
7/9 7/13 7/14 7/25
9/11 9/21 10/14 11/22!
12/22 15/1 16/20 21/3)
25/15 28/21 28/22
29/3 29/11 29/14 30/2
30/10 30/18 34/16
34/16 42/23 43/9
43/10 43/11 43/25
44/7 45/20 46/17 47/1
51/17 58/23 59/2
59/19 60/15 60/22
60/22 63/2 63/12
65/17 65/22 66/7
68/18 73/18 73/20
74/8 77/12 78/14 81/8)
81/10 84/18 85/25
86/3 86/23 87/13
90/23 91/5 91/19 92/1
94/2 94/15 94/18
94/20 96/1 99/22
99/24 101/7 105/13
107/11 107/12 107/17)
116/1 116/3 119/24
119/25 120/4 120/4
120/17 120/19 120/20)
120/21 120/25 121/2
121/4 124/19 124/20
125/4 125/23 125/25
126/18 126/21 126/25)
127/11 127/13 128/8
129/7 129/12 129/19
133/7 134/8 134/23
136/2 137/21 139/17
144/25 145/18 147/9
150/6 150/12 152/12
152/22 154/7 154/9
157/4 157/12 157/15
161/3 161/16

above [3] 63/19
85/20 86/9

absence [1] 142/5
absolutely [4] 54/18
121/5 140/9 151/7
Abusing [1] 61/18
accelerated [1] 78/18}
accept [3] 46/5 50/22
137/23

acceptance [1] 65/16)
accepted [2] 35/11
40/6

accepting [2] 61/19
123/7

access [9] 8/14
53/24 53/25 63/16

(42) MR BEER: - accessO
A

77/18 128/22 138/6
138/11

accidents [1] 76/4
accord [1] 128/1
accordingly [2] 4/7
27/18

account [5] 32/15

accounting [7] 15/4
18/8 20/8 58/25 60/5
137/23 139/1

accounts [2] 77/20
145/7

accredited [1] 17/23

accurate [2] 128/23
153/24

accusations [2] 49/9
145/17

accused [4] 61/17
63/15 63/19 64/1

acknowledgement

[1] 114/9

acknowledges [2]
49/2 52/8

across [4] 3/5 8/25
26/8 106/12

act [2] 93/22 111/13

acted [1] 58/19

acting [1] 4/5

action [6] 50/5 68/7
80/13 106/18 122/7
139/10

actions [1] 91/17

actively [1] 132/20

actual [1] 66/1

actually [49] 5/15
5/25 11/2 24/6 25/12
33/7 33/13 45/5 47/2

74/10 74/24 75/3
77/10 78/10 78/16
79/6 80/1 81/1 84/10
89/1 92/21 100/17
105/11 107/15 109/8
112/1 112/3 112/6
112/24 116/3 117/7
120/6 120/21 123/10
129/10 131/22 144/5
144/25 150/23 161/12)
161/20

acute [1] 19/4

adapt [1] 25/2

add [2] 73/20 88/22
added [1] 107/11
additional [2] 50/5
70/22

additionally [1] 35/24I
address [19] 3/1 8/9
8/11 8/13 18/13 22/25

access... [5] 72/7

41/24 54/2 62/3 91/18)
accountants [1] 18/6

54/25 55/18 57/8 60/8
60/17 63/1 64/21 74/7

53/9 58/13 72/1 72/7
72/7 87/19 95/3 98/21
141/18
addressed [2] 33/13
61/2
addressing [1] 76/15
adds [1] 45/19
adjourned [1] 163/18
Adjournment [11]
37/18 38/3 38/24

49/3 61/15 113/12
116/15
adopted [1] 138/19
advance [8] 38/23
51/2 56/13 56/15
91/18 92/8 94/16
101/2
advantages [1] 122/1
advice [59] 4/18 4/23
4/25 5/11 6/19 7/3
21/2 21/10 21/16
21/24 22/2 23/7 24/15
25/21 25/25 26/1
35/12 38/14 40/17
42/8 55/18 56/24 66/9
66/11 68/11 74/13
74/15 75/7 75/7 78/6
78/7 80/20 82/12
82/17 83/1 83/14
84/19 87/24 87/25
91/17 91/25 95/19
96/14 96/20 99/22
100/21 115/12 120/22)
121/11 129/13 131/15)
132/22 133/20 141/15)
142/14 143/13 145/15)
151/20 160/16
advise [8] 68/7 93/2
98/15 111/10 111/16
111/24 114/22 125/19)
advised [9] 6/22
17/21 26/12 38/8
58/25 74/10 82/25
116/24 152/6
adviser [3] 92/13
99/16 145/3
advisers [3] 84/23
128/21 152/13
advising [4] 80/16
83/7 93/5 147/6
Advisory [1] 144/16
aegis [1] 141/16
affairs [8] 2/21 7/8
7/25 50/23 54/22 55/2
59/8 89/11
affected [1] 157/3
after [13] 31/20 47/16)
62/10 63/4 104/3
109/12 117/13 118/14}
132/9 132/22 135/24
150/6 151/13
afternoon [9] 94/9

41/22 49/8 51/8 51/15

39/12 41/5 42/4 48/17

98/23 113/14 113/16
144/5 146/3 156/24
156/25 158/3
afterwards [2] 23/24
45/15

38/8 44/16 73/1 80/9
101/7 103/22 105/19
110/18 126/10 163/4
against [9] 5/8 18/24
20/7 33/10 46/7 49/9
77/24 108/16 158/13
agent [1] 62/14
ages [1] 33/11
aggressive [2] 64/15
64/17
ago [5] 10/18 31/12
93/25 97/9 142/16
agree [18] 17/2 17/4
17/8 17/11 40/12
56/11 56/12 56/14

71/6 106/24 107/4
109/1 120/6 140/4
agreed [10] 17/25
27/17 40/18 43/15
64/9 66/15 68/6 88/24
96/18 119/13
agreeing [3] 37/13
122/1 122/3
agreement [2] 92/21
109/11
agrees [2] 42/13
56/20
ahead [10] 11/22
12/5 12/8 75/13 94/23
94/24 97/25 100/15
105/15 108/8
aim [2] 115/1 130/2
air [1] 38/2
Al [1] 35/25
Alan [3] 17/10 25/12
35/11
alarm [1] 163/12
ALB [3] 107/14
111/23 161/11
albeit [1] 6/16
Alex [2] 89/24 89/25
align [1] 6/12
aligned [2] 92/24
161/24
all [72] 3/4 5/14 5/25
8/13 10/3 11/5 11/15
12/12 21/17 21/24
23/1 24/1 24/12 25/11
28/24 29/4 29/12
31/10 32/19 39/7
39/15 51/22 51/23
60/6 61/9 62/11 62/14
66/9 67/3 71/8 73/18
73/22 74/1 76/3 76/14
76/21 81/15 81/16
86/11 86/14 87/1
88/20 93/11 103/4

again [12] 12/5 35/23

65/7 67/13 67/18 69/3

105/4 107/8 112/12
116/16 119/10 120/4

132/9 134/13 134/23

138/21 141/5 145/12

160/13 161/24 162/7
162/25

allegation [2] 68/9
114/22

allegations [2] 61/14
75/8

alleged [2] 77/24
127/22

Alliance [2] 23/5
130/17

allocated [1] 11/5
allow [5] 26/24 49/8
106/13 123/13 130/8
allowed [1] 81/5
allowing [2] 14/9
31/13

alluded [1] 93/7

102/17 133/11 140/9
161/8
alone [1] 82/25

92/21 112/23 123/4
149/8

alongside [1] 142/13
already [7] 11/6 12/1
13/18 80/10 96/13
123/2 158/1

also [47] 2/14 4/1
4/23 5/12 9/7 18/14
19/9 19/22 24/18
29/20 30/8 36/1 36/9
48/1 48/3 51/11 54/14
56/11 56/12 59/1
60/12 65/17 70/24
91/8 93/2 95/6 100/9
105/10 105/25 115/14)
118/11 118/15 118/21
1314/7 133/24 134/2
143/2 148/23 149/6
150/19 151/20 152/21
156/4 156/7 157/8
159/8 160/7
alternative [2]

144/13 157/19
although [16] 7/18
21/9 28/18 38/21
43/15 45/16 47/12
55/15 69/3 73/15
83/11 83/20 90/6
116/19 145/4 150/23
always [14] 11/14
21/24 33/2 39/2 47/5
71/7 88/7 107/17
116/24 119/22 153/11
159/20 161/15 161/21

125/23 126/24 128/11
135/17 135/24 137/19)

145/21 147/19 151/13}
157/22 157/24 158/22}

almost [6] 27/6 62/14)

along [6] 84/21 84/22

am [19] 1/2 4/17 16/4
43/10 43/10 48/16
56/6 57/17 57/19 70/9I
71/13 91/21 105/15
106/15 111/5 124/6
138/18 152/5 163/18
amazed [1] 142/4
amazing [1] 117/12
amended [1] 54/1
among [1] 146/12
amongst [5] 2/3 4/12
40/22 59/9 61/6
amount [1] 111/22
amounts [2] 19/21
77N9
analysis [2] 78/16
78/17
Andrew [19] 9/6 38/4
39/12 40/24 41/13
41/21 42/16 48/13
58/9 59/4 60/18 61/10)
66/15 71/17 71/18
114/18 115/14 117/20)
117/23
Angela [1] 61/7
annexe [5] 11/8 25/1
30/22 35/9 86/13
annexe C [1] 25/1
annexes [1] 74/23
anonymity [1] 23/3
another [8] 46/15
47/5 47/6 49/24 75/9
115/1 148/9 148/19
answer [8] 10/16
11/14 25/8 57/11 82/4I
83/9 154/3 161/18
answered [1] 160/21
answering [4] 11/12
87/10 145/21 163/2
answers [1] 160/17
antennae [1] 43/4
Anthony [4] 67/17
67/24 98/17 121/13
anticipate [1] 130/3
anticipating [1]
28/22
any [56] 7/18 8/15
9/22 19/23 20/6 20/9
20/12 21/7 21/8 25/15
28/15 29/11 34/9 37/2I
38/18 39/5 40/5 46/4
50/4 52/2 53/4 54/13
54/14 54/18 54/19
60/1 60/17 62/5 63/5
65/10 68/7 71/4 71/13)
74/14 81/1 87/4 87/8
91/20 101/13 106/18
106/25 109/22 118/16)
124/2 125/24 126/2
127/4 134/3 134/9
138/9 139/8 140/18
141/24 142/14 143/17)
159/11
anybody [2] 24/1

(43) access... - anybodyO
A

anybody... [1] 143/5
anyone [1] 153/15
anything [13] 24/17
37/6 45/1 52/25 60/2
121/2 126/3 126/23
129/15 131/19 132/21
132/23 153/22
anyway [4] 43/19
69/7 107/9 131/17
apologies [1] 50/22
apologise [1] 33/14
apparent [7] 6/11
34/2 40/5 46/4 59/19
66/25 134/1
appeal [2] 62/7 80/11
appear [6] 3/13 65/7
73/5 77/25 97/1 99/8
appeared [1] 26/7
appearing [1] 163/5
appears [3] 80/16
147/1 147/12
applicants [7] 18/17
51/24 52/18 52/23
53/2 53/15 72/15
applications [3]
20/16 48/25 130/15
applied [1] 15/21
apply [1] 66/13
appointed [1] 125/19
appointing [1] 106/3
appointment [4] 3/16
7/6 16/11 104/25
appointments [2]
104/21 154/15
appreciate [1] 91/2
approach [29] 3/22
6/11 17/12 17/16 23/9
23/15 23/17 23/19
23/22 26/3 26/19
26/23 36/23 40/4
40/19 45/10 46/3
64/14 79/17 102/1
108/15 119/23 120/14
122/23 127/13 135/5
136/8 136/12 138/19
appropriate [15]
52/19 53/16 57/13
67/24 68/20 80/12
88/5 89/7 92/24
107/22 111/11 113/3
127/25 130/11 133/6
appropriately [1]
38/17
approval [1] 120/15
April [7] 15/6 19/9
131/15 131/17 132/23}
132/24 132/24
arbitrate [1] 72/21
arbitrating [1] 73/5
Arbuthnot [13] 38/5
66/16 66/23 67/13
67/19 67/23 118/20

119/10 121/11 121/19)

122/4 122/10 135/22
Arbuthnot's [1]
59/23
archives [1] 147/11
are [94] 1/19 1/21 9/1
10/14 11/7 15/10
15/25 16/14 18/19
20/8 20/16 21/13
22/21 22/21 23/8
23/19 24/22 25/4
25/24 26/1 27/21 29/6
31/5 36/15 36/22
36/22 37/2 40/3 40/7
40/7 41/12 42/4 42/8
42/25 44/3 44/10
45/20 46/2 46/6 46/6
46/10 46/11 46/12
50/11 52/3 52/6 59/23
72/2 73/8 73/8 75/13
80/14 81/20 84/16
85/1 86/25 89/15
89/16 92/20 95/7
95/10 99/6 114/15
119/16 122/5 122/12
122/19 122/21 123/21
125/21 126/13 128/5
130/11 134/2 139/20
141/2 141/5 141/8
141/12 141/25 142/21
142/23 143/9 143/10
143/25 145/23 152/5
153/21 153/24 154/15)
154/24 160/25 161/10)
162/7
area [5] 16/11 30/24
111/21 156/3 162/18
areas [10] 6/21 9/1
11/18 128/5 129/9
129/16 131/22 137/19)
149/15 149/20
aren't [3] 22/10 50/12
154/13
arguably [1] 30/17
argued [1] 121/19
arguments [2] 5/24
22/18
arise [1] 3/5
arm's [9] 3/22 13/19
14/12 26/18 74/14
82/23 152/11 161/1
161/6
arm's-length [5]
26/18 82/23 152/11
161/1 161/6
arose [2] 52/7 154/1
around [6] 38/13
45/22 100/8 115/23
116/19 118/8
arrange [1] 157/11
arrangement [2]
62/17 62/19
arrangements [5]
31/13 59/22 62/2

63/11 120/24
arrived [1] 56/1
article [1] 114/7
articulated [1]

116/13

articulating [2] 66/20
66/20

artificial [1] 3/10

as [200]

ASAP [1] 42/5

Asia [1] 90/9

aside [1] 99/17

ask [16] 1/10 21/13
78/12 87/13 87/21
94/20 121/12 129/19
133/8 134/22 143/3
144/10 144/11 145/22
145/24 152/23
asked [27] 5/12 16/5
17/16 26/11 35/13
52/24 54/23 64/3 64/6
75/6 76/19 78/6 78/16
86/9 99/5 103/11
107/25 124/8 126/6
129/13 131/15 131/20
133/4 139/17 145/14
147/9 157/4

asking [5] 13/23 29/9
84/18 103/25 161/16
aspect [1] 80/19
assessment [3]
67/25 68/16 150/22
assist [3] 111/12
112/1 128/17

assistance [4] 97/18
110/19 119/14 127/9

assistance’ [1]
109/21

assistant [1] 90/21

associated [1] 16/24

association [1] 17/24I

association/state [1]
17/24

assuage [2] 120/7
120/12

assuaging [1] 122/4

assume [2] 56/3
62/24

assumed [2] 130/25
135/19

assuming [2] 94/11
106/16

assumption [3] 26/4

94/12 146/9

assurances [1]

138/17

at [270]

at page 2 [1] 12/17

attached [8] 9/1 12/7

41/4 42/3 56/1 71/10

97/24 118/1

attaching [2] 41/20

71/14

attachment [2] 12/11

72/5
attacks [2] 40/8 46/7
attempt [1] 44/14
attempts [1] 19/19
attend [16] 36/1
42/19 43/7 47/25
48/19 49/17 50/18
51/1 53/13 55/11
55/19 56/4 56/25
67/15 98/14 98/17
attend’ [1] 42/13
attendance [1] 49/23
attended [3] 30/7
58/9 100/19
attendees [3] 35/24
56/21 102/2
attention [7] 23/5
70/20 70/25 71/15
106/17 139/5 151/23
attitude [1] 116/22
au [1] 93/13
audit [5] 29/11 29/21
30/3 30/3 30/5
August [37] 5/10
5/15 21/14 38/2 73/19)
75/17 75/22 82/8 83/6
86/18 86/22 88/2
90/15 90/19 94/24
94/25 96/19 96/22
97/4 97/6 97/11 98/1
99/20 100/8 100/23
100/25 101/14 103/20}
104/6 110/20 114/4
114/19 115/7 140/20
143/11 143/19 145/16
author [1] 26/6
automatic [1] 77/22
available [6] 10/2
71/13 140/16 142/24
143/5 146/18
Avene [1] 90/20
avenue [1] 88/22
avenues [1] 88/22
avoid [3] 48/4 119/20
154/16
aware [30] 4/11 7/7
7/21 20/18 25/18
27/18 27/20 28/1
34/12 47/23 56/22
65/24 74/20 76/11
76/12 91/3 95/7 95/10)
95/16 106/5 116/7
131/7 132/16 135/3
135/9 136/8 136/12
140/22 152/5 153/22
away [11] 10/3 31/9
33/13 36/9 43/18 66/4
86/18 92/10 118/3
118/7 160/11
awful [3] 33/4 81/11
149/11

B
back [29] 16/9 21/22

33/10 34/23 35/5
43/24 46/11 57/14
69/4 69/6 71/16 74/5
76/5 80/7 82/3 82/5
87/24 91/2 94/10
94/14 98/22 99/4
99/17 110/19 115/2
130/4 134/15 150/8
157/15
backbenches [1]
150/7
background [15]
1/24 11/24 12/7 20/18)
24/11 25/11 36/2
65/23 104/15 126/5
140/13 142/21 146/8
151/11 151/12
backwards [1] 47/10
bad [2] 44/3 150/24
balance [4] 18/24
107/15 112/22 122/18)
balanced [1] 66/11
Bank [2] 83/10 156/4
banking [1] 36/13
banks [2] 158/11
161/4
bargaining [1] 61/19
Baroness [28] 1/5
1/8 1/13 12/5 22/14
34/17 41/7 56/5 56/15
57/24 78/20 94/9 99/1
113/6 113/16 114/6
136/7 145/20 146/3
148/3 148/8 155/3
155/12 155/18 156/11
160/1 160/25 164/2
barrister [2] 66/2
110/8
based [4] 33/21
45/12 52/17 83/3
basically [2] 116/24
142/18
basis [9] 24/22 26/1
54/4 115/21 116/25
119/2 140/23 151/21
161/5
Bates [5] 17/10 25/5
25/11 26/23 35/11
battles [1] 100/13
BBC [4] 24/17 36/17
37/18 37/25
BBC's [2] 13/3 23/6
be [205]
bear [1] 145/5
beautifully [1] 79/22
became [9] 34/2 36/4
59/19 66/25 77/16
89/24 134/1 135/2
150/5
because [81] 3/3 5/1
5/24 6/3 6/15 6/17 8/5I
9/23 10/6 11/14 13/20I
19/3 25/12 27/4 27/21
33/7 34/23 43/18 44/9

(44) anybody... - becauseO
B

because... [62] 45/6

46/11 52/20 57/9
57/10 62/7 62/20
63/12 65/13 65/15
65/22 66/17 69/4
69/15 74/24 75/2
75/14 79/2 80/18

84/11 85/2 86/19 90/5
93/8 95/20 97/6 97/16

99/21 104/14 104/20

104/21 107/16 108/22)

110/22 121/4 124/18
125/12 126/7 132/21

134/13 135/15 136/24)

138/2 140/13 141/1
142/19 143/25 144/6
146/19 148/3 149/8

151/13 151/20 151/25)

152/3 155/1 157/21
159/2 160/8 160/17
161/25 162/18
become [9] 62/23
89/3 93/25 124/18
133/22 146/10 146/21
152/7 153/20
becoming [3] 40/8
46/7 124/18

bed [1] 68/8

been [133] 3/13 3/23
3/24 4/22 6/6 6/7 7/8
7/10 7/11 7/12 9/17
9/23 14/20 14/22
19/11 19/13 19/24
21/2 21/21 22/7 22/11

23/4 23/5 23/21 23/24

24/8 25/11 25/14
27/20 29/14 30/19
31/14 31/24 32/10
35/13 38/22 39/3
42/17 46/24 49/9
50/20 51/4 51/15
51/22 51/24 52/1
53/12 55/4 57/9 58/18
58/20 58/24 59/19
60/2 60/7 63/12 65/13
65/15 65/20 66/14
66/23 66/24 69/8
69/12 71/4 74/9 74/20
76/8 76/14 77/20
77/25 78/8 78/23
80/17 80/24 81/10
81/11 82/22 83/16
89/3 89/7 89/22 90/2
91/8 95/3 95/6 95/20
98/1 99/25 101/10
101/12 102/21 105/18)
105/24 106/5 106/7
107/8 110/2 112/10
114/21 114/23 115/10)
115/20 116/19 120/9
121/24 124/2 130/18
132/16 139/4 139/10

140/2 140/6 140/7
146/18 147/8 147/16

149/4 150/8 154/5
155/8 155/9 158/1
158/6 158/8 159/25
160/10

BEER [9] 1/9 1/10
34/14 139/21 156/13
157/4 163/7 163/14
164/4

before [21] 7/7 13/5

47/17 62/25 74/19
92/19 94/17 94/20
95/13 100/23 104/24
118/23 123/2 137/2
144/5 148/9 153/17
beforehand [3] 35/21
56/6 113/19

began [1] 19/7
beginning [11] 4/19
60/21 66/12 77/8
86/17 88/2 90/14
99/22 113/19 132/10
162/8

behalf [1] 1/11
behave [3] 13/20
29/3 106/14

behind [5] 46/10
56/24 76/19 134/14
157/15
being [49] 3/19 5/24
8/16 11/5 11/16 23/11
26/10 29/18 39/9
42/14 50/11 50/12
55/11 59/14 60/3
64/16 65/18 71/5
73/13 78/18 81/23
85/12 87/17 89/5 91/3
92/11 95/24 104/22
107/18 116/8 116/10
119/25 120/14 122/5
124/20 129/16 133/11
136/8 136/12 137/22
139/20 141/16 141/20)
147/22 150/8 151/16
157/8 160/4 163/10
BEIS0000013 [1]
121/9
belief [2] 1/20 82/22
believable [1] 94/1
believe [12] 6/4 37/2
43/6 45/1 45/17 59/1
62/10 122/20 130/6
147/25 148/2 157/9
believed [6] 15/17
22/12 103/23 122/5
155/9 157/7
below [2] 71/21
114/14
benefit [3] 28/19
32/12 151/14

140/14 142/18 146/16)

147/17 147/24 148/24)

27/21 28/1 34/5 34/14

best [3] 1/20 111/12
133/17

better [3] 49/12
146/11 150/25
between [25] 1/25

37/19 39/21 40/12

57/25 58/8 65/15 92/1
92/16 96/6 108/8

beyond [2] 53/8
98/20

big [7] 33/1 84/13
103/1 103/1 136/24
152/15 161/13
Bills [2] 11/7 90/11
BIS [6] 8/25 133/23
134/2 134/7 146/21
146/22

BIS's [1] 98/20

bit [22] 5/9 16/16
24/14 25/15 31/9
48/14 50/14 64/20

98/5 113/18 117/6
117/7 137/13 144/24
149/6 155/10 155/14
159/3

bits [4] 27/21 82/2
85/3 135/16

black [2] 22/2 22/4
blue [1] 59/25
board [22] 2/10
30/23 34/5 50/21
55/21 57/4 57/5 85/20
86/6 86/19 89/8
103/24 110/24 116/2
131/4 131/6 140/8
140/17 144/16 161/10
161/15 161/22
boards [4] 104/22
105/5 162/10 162/13
bodies [3] 32/10
82/23 161/1

body [9] 14/12 14/23
26/18 27/25 32/2
75/15 118/6 152/10
158/7

Bogerd [1] 61/7
bold [4] 13/7

Bonds [1] 37/12
borne [1] 20/1

both [16] 5/24 14/15
15/6 26/7 27/1 37/25
38/5 49/10 49/21
52/13 64/10 70/16
74/25 112/1 161/17
162/12

bottom [14] 13/6
32/14 41/15 48/7 68/2
68/16 68/19 69/11
101/21 113/20 117/19}

2/22 11/1 31/25 32/10

45/7 47/23 48/6 53/14

128/24 132/12 133/12
134/20 159/11 161/21

79/21 80/7 84/25 86/3

143/22 147/5 155/21
bought [2] 59/21
85/13

Bourke [7] 50/24
54/22 54/23 56/19
58/10 102/5 108/4
box [2] 74/21 115/25
Bracknell [2] 63/16
124/20

branch [2] 52/6 54/1
branches [1] 18/18
brand [1] 19/20
breach [1] 21/6
breached [1] 54/8
break [12] 47/16

94/17 95/13 100/23
113/4 146/1 156/13
156/18

Bridgen [24] 38/4
38/5 39/12 39/14
41/13 42/16 48/13
51/6 51/9 58/9 58/15
59/4 60/18 61/10
61/13 63/15 64/2
65/17 66/15 67/10
71/18 114/18 115/15
122/10

brief [10] 6/10 7/8
9/13 10/12 92/12
126/5 133/18 137/1
145/6 157/6

briefed [1] 114/13
briefing [32] 7/6

12/15 16/5 16/20
16/23 17/1 17/7 18/3
27/12 35/10 35/16

70/7 71/10 71/14
75/19 76/24 77/17
78/10 80/5 80/16
101/3 121/20 122/16
142/10

briefings [1] 115/21
briefly [3] 35/9 57/24
104/20

bring [19] 32/5 40/13
73/23 79/24 81/19

103/14 104/1 105/6
108/25 109/3 112/7
127/15 153/9 156/6
160/19

bringing [10] 46/21
88/2 88/10 111/23
116/15 142/25 145/3
149/9 154/11 154/21
Britain [1] 60/25
British [4] 20/20
broad [1] 5/10
broadcast [2] 13/3
38/1

broadly [6] 5/12 9/10

57/14 57/18 94/3 94/7,

11/24 12/4 12/7 12/10)

35/21 36/24 37/3 63/5)

84/13 85/2 85/3 87/22,

61/14 128/3 128/18
140/16

brought [5] 51/16
59/9 79/19 106/7
139/4

brushes [1] 109/3
Brussels [1] 90/8
bugs [4] 53/21 53/22
81/24 151/1

bullet [4] 20/5 22/13
118/7 148/7

bundle [1] 7/13
buried [1] 142/18
business [17] 2/18
10/25 45/21 60/12
60/14 68/10 69/14
84/20 84/24 89/22
104/15 106/13 146/9
148/22 150/3 150/4
150/10

businesses [4] 12/24)
22/22 62/21 152/11
busy [3] 11/6 47/9
134/24

but [182]

buy [1] 59/21

c

Cabinet [3] 1/22
147/8 150/2

cadre [1] 162/14
call [8] 1/5 4/17
42/24 60/24 64/4
104/5 133/24 134/1
Callard [20] 85/20
86/2 86/9 86/16 86/21
89/6 89/7 90/20 92/2
92/25 96/6 98/17
148/6 155/2 155/4
155/9 155/19 157/5
157/11 159/5
Callard's [1] 155/5
called [12] 6/17 9/6
38/4 39/12 39/13
39/17 41/13 42/16
44/2 44/2 100/22
141/10

calling [2] 44/15
143/20

calls [3] 17/3 19/15
19/23

came [26] 5/9 6/15
9/23 9/25 62/11 69/19)
75/3 86/17 87/13
89/25 93/10 107/7
108/19 115/14 123/3
123/13 131/23 135/24}
137/7 137/24 139/16
140/20 144/5 148/21
149/15 149/17
Cameron [4] 10/19
35/25 46/25 114/3
camp [1] 93/6
campaign [1] 24/25

(45) because... - campaignO
Go
campaigning [1]
13/2

can [124] 1/3 1/11
1/15 1/16 3/6 7/5 8/3
8/4 8/8 8/9 9/3 11/24
12/10 12/17 13/13
13/13 14/8 14/16 18/3
21/15 23/18 25/2 25/3
25/22 26/25 27/22
28/23 29/4 30/12
34/15 35/21 37/17
37/20 40/18 40/20
40/22 41/16 43/9
43/20 46/8 47/17
48/12 49/18 50/15
52/21 53/10 57/20
57/24 58/5 59/16 61/1
65/10 66/6 67/4 69/24
70/1 70/3 71/17 72/8
73/20 75/12 77/4 80/6
81/19 81/20 81/25
82/3 82/5 90/15 91/6
93/3 94/3 94/9 94/11
94/14 94/18 96/11
96/11 96/14 97/15
98/21 100/25 103/17
105/7 105/12 108/1
110/23 110/25 113/14}
113/17 113/21 114/2
115/9 116/18 116/22
117/18 118/25 121/7
121/9 122/10 122/20
123/20 124/13 126/11
127/6 128/17 129/24
133/13 136/4 139/25
141/9 143/6 144/6
147/14 148/5 152/24
153/11 155/1 156/2
156/14 156/18 157/1
161/15 162/22

can't [7] 12/12 22/9
50/7 55/17 88/17
115/6 136/17
candidate [1] 104/17

cannot [7] 45/16
52/17 91/20 101/16
106/8 143/8 155/11

capable [1] 52/19

capacity [1] 30/7

captain [2] 105/8
108/24

care’ [1] 39/6

career [2] 2/8 83/6

careful [2] 121/1
122/21

carefully [1] 8/24

carried [2] 5/16
129/16

carry [3] 5/6 106/25
160/4

carve [1] 137/1

carve-up [1] 137/1

case [17] 4/14 26/6
30/17 33/3 33/10
36/18 45/25 53/3

105/20 119/5 135/17
142/25 162/3

cases [47] 4/2 4/2
4/13 7/1 13/2 18/11
19/4 19/11 20/15
21/12 21/20 23/11
27/14 28/24 29/13

36/21 44/24 48/5
49/13 51/22 51/25
52/2 52/5 52/7 52/10
52/15 52/24 58/22
59/18 60/5 61/16
68/10 80/17 106/7
122/7 128/16 131/23
142/19 157/22
cast [1] 83/11
casualty [1] 146/4
catch [2] 90/19 90/22
catch-up [1] 90/19
cause [5] 15/4 18/7
18/10 70/18 72/14
caused [2] 12/23
52/1
causes [1] 65/4
CCRC [20] 27/14
27/16 39/8 40/11
44/13 44/19 45/22
48/24 49/13 52/24
59/10 80/12 80/18
80/21 81/5 100/2
106/6 122/7 130/15
138/23
CCs [1] 72/1
ceased [1] 31/15
central [3] 61/13
162/11 162/11
CEO [7] 35/14 35/18
41/14 47/13 49/19
85/6 144/4
certain [3] 111/22
112/5 149/17
certainly [25] 14/2
17/9 19/2 26/3 29/23
53/19 54/17 57/15
69/10 73/15 75/25
77/5 82/24 84/2 86/22
107/10 116/6 116/11
119/22 124/6 129/6
135/12 147/3 147/16
151/17
cetera [4] 30/25
116/1 116/2 120/24
chain [3] 71/25 91/8
135/1
chair [6] 5/13 30/10
78/19 106/16 107/19
144/16
chaired [4] 30/23

60/18 64/13 76/7 77/4

30/1 30/18 32/23 33/8
33/18 33/21 34/4 34/5)

58/1 58/3 61/11
chairman [8] 84/6
87/21 104/14 105/16

131/3
Chairman's [1]
133/16
chairmanship [1]
104/7
challenges [1] 11/16
chance [1] 153/6
change [3] 89/25
136/25 136/25
changed [2] 33/7
33/12
changes [1] 18/13
chapter [1] 55/18
character [1] 107/14
charge [3] 28/13
54/25 147/15
charged [2] 158/7
161/20
charges [1] 137/24
charging [1] 139/1
chat [1] 90/25
check [3] 32/20 61/1
156/14
Chief [3] 56/7 144/15
157/13
Chisholm [1] 89/24
choice [1] 53/2
choices [2] 53/6 53/8
choose [1] 129/23
choosing [1] 73/8
chose [1] 8/20
chronologically [1]
3/1
chronology [4] 37/17
37/21 69/24 75/13
circles [1] 82/12
circumstances [2]
107/7 128/16
cited [1] 97/20
zens [2] 59/20
60/10
civil [49] 1/25 7/3 7/4
22/6 22/7 22/8 22/9
26/4 46/18 53/4 60/13
74/24 83/5 86/23
86/24 89/18 93/8
93/22 105/7 108/23
110/17 139/8 142/12
143/15 144/20 144/21
144/21 147/15 150/10
151/21 152/1 152/2
152/20 152/23 154/14
154/15 154/16 154/19)
154/22 158/5 158/5
158/8 158/17 158/19
158/25 159/7 159/12
159/19 160/18
claim [3] 12/23 53/4
130/18
claimants [1] 151/15

108/10 111/23 112/24

claimed [1] 135/6
claims [2] 58/20 64/8
clarify [1] 158/1
clarity [1] 84/15
Clarks [1] 104/16
clash [4] 55/11 55/22
57/2 57/8
class [1] 59/24
classic [8] 6/22 92/5
93/8 104/22 158/4
158/8 158/18 159/17
clear [18] 12/15 15/7
15/15 17/11 23/9
34/16 34/18 41/25
46/8 51/7 52/5 53/6
53/7 79/10 83/22
91/15 152/7 162/6
cleared [1] 107/8
clearly [13] 44/25
55/20 62/12 64/21
69/7 73/24 86/4 115/6
122/17 131/5 145/12
148/13 157/20
climate [1] 89/25
cling [4] 117/2
close [5] 23/18 82/18
85/21 157/18 157/21
closed [2] 14/5 83/8
closely [2] 6/12 86/5
closer [2] 50/14
417/18
closing [1] 24/1
closures [2] 10/6
10/17
cock [1] 100/9
cock-up [1] 100/9
codes [1] 29/2
coincide [1] 38/3
coincides [1] 50/21
colleague [2] 42/17
43/14
colleagues [3] 11/15
39/15 50/22
colluding [1] 157/15
combination [1]
30/25
combined [1] 104/15
come [41] 8/3 8/6
18/15 18/23 21/15
25/3 30/2 30/12 31/2
34/23 35/5 43/18
43/22 47/12 47/16
54/15 54/20 60/12
60/12 66/6 66/24
69/24 84/21 92/8
93/11 95/21 96/11
104/23 110/19 116/18
123/4 129/19 135/13
136/4 141/17 143/6
145/1 146/8 155/1
156/5 156/6
comes [8] 20/9 20/19
21/18 68/5 69/4 69/6
74/5 78/3

comfort [1] 27/15
coming [12] 10/8
24/13 24/18 33/10
66/3 85/5 92/7 92/21
107/19 109/15 112/23}
136/17
comment [3] 64/24
147/14 150/12
commentary [1]
73/11
commented [3] 9/11
42/11 98/10
commenting [1] 77/6
comments [1] 42/7
commerce [1] 37/11
commercial [14]
16/13 32/11 32/24
65/23 72/21 93/10
106/13 107/17 110/23)
158/4 158/12 158/13
159/16 159/21
commercially [4]
13/20 27/2 72/23
162/19
Commission [4] 4/2
20/16 21/20 44/24
commissioned [6]
15/2 18/5 101/18
129/25 130/8 138/25
commitment [4]
41/10 105/25 111/5
151/4
commitments [1]
65/10
committed [4] 40/7
46/6 52/11 76/15
committee [9] 24/6
29/21 29/24 30/4 30/5
30/6 30/8 30/15 33/1
committees [3]
29/12 30/20 30/21
common [1] 60/15
commons [10] 7/17
10/17 11/1 11/2 11/12
24/6 24/19 41/6 42/17I
153/24
communicate [2]
68/6 86/20
communicated [6]
36/20 86/22 96/23
135/21 135/22 154/5
communication [5]
92/1 96/1 124/23
124/25 126/20
communications [5]
50/23 54/21 56/10
56/23 92/13
communities [1]
145/11
community [1] 59/13
companies [5] 2/11
29/16 29/20 30/22
149/5
company [9] 2/9 30/7

(46) campaigning - companyO
c

company... [7] 30/9
30/14 32/24 120/2
161/13 161/23 161/25
compare [1] 137/10
comparing [1]
137/12

comparison [2]
18/22 30/13
compensation [1]
33/16

competency [1]
14/14

competent [1] 26/7
complained [1] 52/2
complaining [1]
10/14

complaints [11]
14/25 19/15 19/25
22/21 39/14 51/16
4111/7 127/11 127/21
127/24 130/10
complete [2] 23/18
131/3

completely [5] 28/7
81/4 83/13 95/14
110/6

complexity [2] 65/3
65/4

compliance [5] 29/24
30/3 30/8 33/1 138/14,
complicated [1] 5/3
complications [1]
145/4

composed [1] 158/8
comprehensively [2]
19/24 51/22
computer [2] 51/19
52/1

computers [1]
148/24

concern [14] 24/14
32/17 48/1 54/19
65/18 86/3 89/5 96/5
96/10 112/5 122/4
135/24 138/11 138/22)
concerned [15] 6/11
45/22 73/17 77/12
99/24 105/19 107/16
107/21 118/11 118/15}
129/11 134/2 134/8
134/12 137/21
concerning [3] 14/17
16/6 39/19

concerns [50] 7/8
12/22 16/2 20/14
21/13 22/25 28/15
28/17 44/7 45/12 47/1
49/2 49/6 51/8 53/9
57/11 58/16 58/17
58/23 59/2 59/3 64/21
67/12 68/18 85/25
86/20 86/22 87/2

87/11 87/15 91/19
94/16 94/18 95/3
101/5 101/24 102/3
102/20 102/21 105/22)
118/8 120/8 120/13
120/25 121/1 125/6
133/19 138/14 144/1
144/14

concluded [1] 114/14!
conclusion [6] 21/5
65/11 91/22 92/3
127/16 130/3
conclusions [3]
40/11 106/21 133/5
conduct [4] 45/13
1114/12 111/17 125/25)
conducted [2] 27/19
107/1

conducting [2]
111/18 125/19
confidence [7] 39/2
39/25 82/11 84/19
87/18 143/12 143/15
confident [2] 124/7
142/2
confidentiality [6]
23/1 45/14 46/11
48/22 49/12 117/1
confirm [4] 45/16
67/14 105/16 130/8
confirmed [2] 107/24
115/17

conflation [1] 97/12
conflict [2] 32/17
118/16

conflicting [1] 92/25
confused [1] 77/10
confusing [3] 74/7
116/5 117/6
conglomerate [1]
28/10

connected [1] 82/22
connection [2] 36/16
1114/7

consent [1] 51/13
consider [9] 13/1
23/14 45/24 46/14
50/4 53/15 88/14 89/6
93/16

considerable [1]
118/14

considered [4] 8/24
15/24 42/8 133/17
considering [8]
27/16 106/7 111/5
111/13 112/1 122/7
122/8 151/24
considers [1] 22/20
consistent [3] 26/20
38/14 83/1
consistently [1]
78/23

constant [1] 147/24
constantly [3] 40/4

46/3 82/19
constituency [1]
59/23

constituent [1] 51/11
constituents’ [1]
39/13

constitute [1] 116/8
constitution [1]
89/17

constructive [3] 45/9
50/13 89/1
consultant [1]
110/12

contact [2] 12/2
125/17

contained [1] 9/1
contains [1] 22/2
contemporaneous
[1] 147/18

content [7] 7/19 9/10
23/19 23/21 25/5 25/8
42/9

contention [1] 71/5
contents [2] 1/19
1/21

context [6] 13/13
17/13 19/2 19/5 43/1
130/22

continually [1] 70/25
continue [3] 26/11
37/15 57/20
continued [5] 15/18
24/23 28/4 68/8 136/1
continues [2] 45/11
51/3

continuing [3] 34/4
39/7 135/15
contract [6] 62/2
62/5 62/16 63/3 63/11
63/13

contracts [2] 77/21
124/19

contradicts [2] 71/22
138/16

contrary [1] 56/6
convene [2] 39/20
41/11

convention [3] 7/15
69/17 76/1
conventional [1]
76/10

conversation [4]
50/13 105/16 110/20
120/16

convicted [3] 54/11
59/14 60/4
conviction [4] 39/5
52/15 52/21 80/10
convictions [6] 27/16
52/3 52/17 80/14
80/18 138/16
convinced [2] 74/19
136/16

cool [1] 151/22

cooperating [1]
61/25

cooperation [1] 39/8
coordinated [1] 6/23
cope [2] 22/9 62/20
copied [4] 70/6
144/17 144/18 144/19}
copies [2] 87/1 87/8
copy [8] 15/9 71/10
72/5 91/8 131/10
132/1 132/20 133/20
Core [4] 145/23
156/14 156/20 157/2
corporate [3] 20/18
50/23 54/22

correct [28] 2/13
2/20 2/23 2/25 5/22
8/2 8/18 12/16 22/6
26/21 27/11 31/21
31/23 42/20 42/21
70/19 73/4 75/22
94/12 97/4 109/5
115/21 125/7 125/8
134/16 136/14 136/22}
154/6

correcting [1] 153/25)
correspondence [8]
7/12 17/6 17/14 18/1
24/21 97/20 113/19
157/5

cost [1] 19/20

could [51] 5/22 15/4
18/7 18/9 18/11 20/10}
20/23 24/2 26/18 32/5)
32/6 32/18 33/13 34/9
35/5 38/13 39/22
45/23 47/5 53/7 54/1
55/5 57/14 70/18
72/14 77/13 78/15
82/2 83/17 91/2 92/9
98/15 107/11 109/16
109/17 109/22 113/7
114/22 118/12 120/23}
132/5 132/5 133/22
133/22 143/22 152/2
153/9 153/15 154/23
155/4 160/17
couldn't [6] 6/4 28/25]
120/11 141/7 141/24
158/23

counsel [9] 28/13
79/23 80/25 102/14
108/9 108/19 128/7
141/16 143/3
counter [1] 117/10
country [1] 106/12
couple [7] 11/4 61/1
75/2 94/20 142/15
152/16 157/6

course [29] 1/7 5/24
11/13 19/3 21/15
22/11 27/12 35/7
39/10 50/18 57/3
63/11 76/16 77/9

80/12 91/11 93/12
93/24 106/14 107/5
112/8 133/9 135/20
149/22 151/8 154/2
155/1 156/16 163/3
court [8] 21/7 54/9
54/10 60/3 62/7
109/14 131/23 135/17)
courtesy [1] 7/20
courts [4] 52/21 53/4
80/12 80/19

cover [2] 63/23
111/21

cover-up [1] 63/23
covered [1] 111/21
covering [7] 11/25
52/12 75/1 75/2
121/12 139/24 151/6
Covid [4] 154/1

CPS [6] 28/22 28/23
32/6 32/22 34/21 35/4I
created [1] 125/1
creating [1] 106/2
credentials [1] 83/13
credit [1] 159/23
creditable [1] 108/12
criminal [15] 4/2
20/15 21/20 34/5
44/24 46/18 52/11
52/15 54/7 80/10
80/17 128/13 138/15
138/17 139/8

critical [1] 139/2
critical’ [1] 38/7
criticised [1] 39/17
criticisms [1] 112/14
cross [5] 125/12
126/14 127/7 136/5
136/11

cross-refer [2]
125/12 126/14
cross-reference [2]
136/5 136/11
cross-refers [1]
127/7

crowded [1] 127/4
crummy [1] 79/7
crusading [1] 67/3
cuff [1] 152/16
culture [2] 2/18
152/18

cup [1] 104/24
currency [1] 79/8
current [1] 18/15
currently [2] 125/18
125/20

cursory [1] 5/2
Curtailing [1] 61/21
customers [1] 33/19
cut [1] 9/17

D

damage [3] 19/19
22/21 68/9

(47) company... - damageO
D

Damascus [1] 60/20
data [4] 34/11 54/1
77/23 146/25
date [9] 4/22 22/24
45/13 66/14 83/6
109/13 130/7 136/10
162/17
dated [6] 1/15 16/9
16/19 16/21 38/22
90/19
David [3] 10/19 46/25)
114/3
Davies [7] 35/25
50/23 54/20 58/10
61/5 64/24 102/5
day [19] 13/9 13/9
13/22 13/22 14/3 14/3}
18/20 19/1 36/9 42/24
47/9 49/19 86/18 91/2
103/20 161/5 161/5
163/7 163/18
days [5] 10/21 35/21
67/5 69/5 111/4
DBT [4] 101/12
DCMS [1] 158/17
deadlines [1] 107/11
deaf [1] 82/18
deal [5] 25/10 40/2
46/1 81/14 83/9
dealing [5] 38/16
50/25 58/19 75/11
140/21
dealings [2] 26/4
140/18
deals [2] 135/1
137/21
dealt [4] 10/6 10/17
84/4 137/16
Dear [3] 111/2 114/6
114/20
debacle [2] 148/10
148/20
debacles [2] 148/5
150/12
debate [18] 7/11
11/12 24/18 37/18
38/4 38/24 39/12
39/20 41/5 41/7 41/13
42/4 42/16 48/17 49/3
61/15 116/14 116/15
debt [1] 78/1
decades [1] 150/17
decent [1] 124/24
decide [7] 24/17
67/16 89/15 89/18
121/16 122/22 122/25}
decided [7] 8/25
54/10 85/19 89/5
118/17 123/2 128/12
decision [1] 89/9
decisions [1] 31/16
decline [1] 35/12

declining [2] 25/4
35/11
deeper [1] 11/3
defective [1] 14/13
defects [1] 53/21
defence [5] 20/10
20/24 21/1 125/7
145/18
defend [1] 119/22
defendants [1] 54/12
defensible [1] 152/8
deficits [1] 159/24
Definitely [1] 66/19
definitive [1] 19/5
definitively [1] 24/17
deflect [5] 91/24
93/17 123/14 123/17
157/10
degree [1] 39/19
deliberate [1] 63/23
delighted [1] 109/12
deliver [1] 155/11
delivered [1] 108/16
Deloitte [5] 81/3
93/10 135/16 139/23
140/5
democracy [1] 85/2
democratic [1]
102/22
demonstrate [4] 40/6
46/5 70/17 122/2
demonstrated [2]
74/16 106/1
demonstrates [2]
72/13 72/17
den [1] 61/7
denied [1] 100/6
denounced [2] 40/4
46/3
department [19] 5/12
17/18 28/9 32/5 32/9
48/19 69/15 84/21
84/24 99/14 104/4
124/2 128/8 141/25
142/1 145/18 146/22
150/3 153/6
departmental [1]
6/16
departments [2] 2/19
150/11
depended [1] 153/15
depends [2] 14/13
95/17
depicted [1] 121/24
derail [1] 23/10
Deregulation [1] 2/5
derisory [1] 148/16
descending [1] 48/4
describe [1] 62/8
described [2] 55/1
143/1
describing [1] 55/1
designed [1] 127/23
designing [1] 130/9

desire [2] 4/19
119/20
despite [4] 19/15
27/8 38/18 51/18
destroying [1]
139/18
destruction [1] 59/2
detached [1] 23/16
detail [13] 21/9 21/12
26/8 35/1 64/22 73/9
78/15 97/13 97/15
99/17 102/25 103/3
127/18
detailed [4] 75/8
140/2 145/15 163/1
details [2] 64/7 78/10
detect [1] 96/5
determine [2] 106/17
127/22
determined [2] 5/19
121/5
detriment [1] 77/21
develop [1] 43/17
developing [1] 3/13
diary [5] 55/11 57/2
57/8 118/15 146/18
Dickensian [1] 62/6
did [93] 9/4 14/4 15/9
15/13 15/14 17/11
18/10 21/7 21/13
27/23 28/3 28/5 28/15
29/10 29/22 31/1
32/19 33/24 33/25
35/1 38/2 44/20 48/10
49/24 51/19 54/13
63/2 64/2 65/7 67/2
68/14 69/1 74/18
79/24 82/8 83/9 83/20
85/25 86/3 86/20
87/19 88/6 88/14
88/18 89/6 90/4 91/11
93/16 95/15 99/18
101/7 104/11 106/24
109/9 110/18 112/9
115/13 115/14 116/8
117/16 119/19 120/8
121/6 122/25 123/2
123/13 125/24 129/4
130/23 131/11 131/13}
131/13 131/25 132/20
137/10 137/11 137/12
139/1 140/18 141/1
143/17 144/6 144/24
144/25 147/9 148/2
148/2 149/1 149/1
150/22 155/18 159/10}
160/16
didn't [52] 6/23 13/23
21/8 24/16 27/10 30/5
35/13 37/3 38/21 47/3
47/13 54/14 54/15
54/20 60/17 62/23
64/19 68/23 69/3 75/9
78/9 78/17 78/22

79/12 79/16 79/23
84/23 85/8 86/2 87/25)
92/15 101/4 102/22
103/15 112/5 112/13
112/14 117/1 119/5
119/11 120/16 129/18}
130/25 132/14 132/21
134/21 139/19 142/2
145/9 145/16 154/2
159/17

difference [4] 92/16
132/12 158/24 159/11
different [26] 4/20
16/13 28/7 29/7 33/4
55/20 66/12 69/5 74/1
74/25 79/11 81/17
83/11 94/21 97/14
109/7 111/15 112/7
145/7 148/25 150/10
158/6 159/2 159/3
160/19 160/20
ifferently [1] 129/23
difficult [17] 30/17
30/18 63/7 64/25 65/8)
83/19 116/4 117/8
122/17 124/16 147/20}
149/2 149/3 149/9
162/5 162/6 162/23
difficulties [3] 81/17
93/14 150/20
difficulty [3] 5/4
11/10 87/3

direct [2] 24/23
150/15

direction [2] 91/20
101/6

directions [1] 5/25
directly [4] 8/16 49/6
86/20 138/11
director [14] 2/5 2/11
2/13 29/15 29/15 31/2
50/24 54/22 55/2
56/10 57/5 92/13
161/14 161/15
directors [2] 30/6
158/23
directs [1] 72/16
disagree [1] 146/6
disagreed [2] 43/14
43/15
disagrees [1] 72/12
disappointed [1]
139/6
disappointment [1]
47/14
disclosable [1]
133/23
disclose [3] 20/9
20/19 141/7
disclosed [2] 139/7
139/20
disclosure [6] 29/4
39/7 138/15 138/20
138/21 139/16

discouraged [1]
59/19
discover [1] 139/6
discovered [7] 24/5
28/12 33/8 53/22 54/4
142/15 142/17
discovery [2] 142/20
142/22
discrepancies [2]
15/4 18/8
discuss [12] 4/16
36/9 36/11 48/19
50/19 51/12 66/5
73/18 127/3 130/20
131/13 145/1
discussed [7] 39/22
67/14 118/5 126/16
133/17 135/4 159/14
discussion [11] 37/5
40/15 48/4 48/6 94/23
98/8 98/19 118/2
127/4 132/4 132/4
dishonest [1] 60/3
dishonestly [1] 52/12)
dishonesty [1] 59/14
dismay [1] 155/7
dismissive [2] 102/3
102/20
display [2] 136/3
138/1
dispute [1] 155/20
disputes [1] 53/14
disputing [1] 115/7
dissatisfied [1] 96/20)
distance [4] 17/3
19/18 118/10 119/3
distinction [1] 158/3
distinguish [1]
161/21
distinguished [1]
52/17
distract [2] 148/15
148/17
distressed [1] 70/9
distribution [2] 136/8)
136/13
disturbed [1] 62/12
disturbing [1] 146/25
dividing [1] 3/11
division [1] 147/7
divisions [1] 87/8
DNA [1] 152/1
do [111] 11/7 11/17
12/12 13/6 13/25 17/7)
19/19 25/25 26/11
26/22 31/24 32/6
32/22 34/6 34/18
34/19 35/17 44/20
45/18 46/8 47/17
52/25 53/11 53/15
57/4 57/5 57/5 62/15
64/16 65/5 65/20
65/22 66/22 71/6 72/4I
73/18 76/20 77/13

(48) Damascus - doO
D

do... [73] 78/20 79/23
82/25 83/23 84/5
84/16 88/21 89/1
92/15 92/17 93/12
96/5 100/4 100/6
100/7 100/10 100/17
100/17 102/1 102/18
104/2 105/10 107/7
107/21 107/23 109/4
109/13 109/15 109/18
113/8 115/4 115/16
117/17 120/11 120/13}
122/22 124/4 124/16
127/25 129/14 130/21
131/2 131/10 131/16
131/25 132/3 132/21
132/22 133/4 135/21
136/10 137/21 139/8
144/12 146/10 147/2
147/3 148/7 148/25
149/11 153/3 153/6
154/1 154/23 157/14
158/5 159/2 160/7
160/14 160/18 161/2
162/17 162/17
document [19] 9/20
12/12 13/24 16/20
16/22 17/22 26/6
30/12 59/2 109/25
129/5 132/13 136/4
136/17 145/1 145/19
147/21 148/3 155/2
documentation [1]
128/22

documents [16] 23/4
27/17 47/15 65/17
65/18 65/24 65/25
66/2 70/24 87/6 137/7
139/17 142/22 146/16)
147/4 147/16

does [16] 9/16 9/19
13/8 14/15 22/18 68/9)
72/5 73/5 82/4 82/5
93/13 101/23 128/1
155/25 161/18 161/19}
doesn't [12] 7/18
50/8 50/9 50/11 50/12
53/19 73/23 95/17
95/18 104/4 111/16
136/11

dogmatic [1] 82/22
doing [16] 11/6 22/21
28/8 35/4 45/1 79/14
106/15 112/23 112/25}
117/5 118/9 118/20
122/19 135/13 159/8
159/25

dominated [1]

147/23

don't [41] 9/24 11/7
15/12 28/17 32/21
44/22 55/21 65/20

66/24 75/3 77/4 77/7
78/11 86/8 93/19
93/20 95/15 102/6
102/13 108/21 115/24)
126/2 129/14 131/18
132/15 133/1 133/2
133/5 133/9 134/15
136/16 143/3 148/15
148/17 151/11 153/13}
157/1 159/14 162/23
163/11 163/13
done [36] 3/2 5/23
6/3 27/22 29/1 29/4
29/18 33/2 51/7 52/8
66/5 72/3 76/17 77/15
78/18 79/3 79/4 89/2
91/21 92/5 100/1
100/18 100/24 101/19)
105/11 109/16 109/17;
112/17 133/7 144/2
145/17 151/24 152/12)
154/7 155/23 160/15
Donnelly [4] 89/23
90/2 144/15 144/25
doubt [7] 9/23 15/19
24/9 28/10 62/16
135/14 148/21
down [38] 8/8 9/3
9/12 24/1 30/12 38/20
48/13 49/20 50/2 53/3
55/25 60/10 61/8
64/24 66/6 69/24 70/4
71/12 72/19 75/15
75/16 80/9 82/21
96/11 97/22 108/2
108/22 116/18 117/24)
118/6 119/14 121/18
123/6 128/5 136/4
143/6 143/13 148/5
downside [1] 159/20
draft [11] 25/1 25/7
35/10 41/12 42/5
42/15 69/4 129/7
141/9 141/13 141/22
drafted [4] 58/11
76/8 101/4 107/5
drafting [1] 135/1
drafts [1] 133/6
draw [2] 31/24 70/20
drawing [1] 71/15
drawn [1] 130/2
driven [1] 91/21
dropping [1] 137/24
DSS [1] 151/9
DTI [1] 2/6
due [6] 11/13 13/3
21/15 38/1 133/9
135/20
during [11] 30/9
45/15 49/3 93/24
115/7 126/1 130/5
134/1 137/7 154/1
163/3
duties [7] 21/6 54/8

159/10 159/15 160/5
161/22 161/22

duty [9] 20/9 20/17
22/7 39/7 65/25
103/25 138/20 139/15}
161/12

DVLA [1] 27/24
dynamism [1] 105/2

E

each [4] 19/10 49/11
92/19 142/13
earlier [15] 5/9 22/14
41/1 59/18 84/20 93/7
95/2 113/23 116/3
116/15 117/7 135/25
136/15 137/5 156/4
earliest [1] 106/17
early [12] 4/7 7/25
9/14 10/13 35/19
104/6 104/20 110/20
119/9 146/12 149/16
151/11
easier [1] 47/25
easy [2] 161/20
162/3
echo [1] 119/17
effect [2] 5/6 91/23
effective [2] 85/19
85/22
effectively [4] 18/20
18/25 46/10 157/16
effects [1] 154/10
effort [2] 40/3 46/2
efforts [3] 82/21
118/14 143/14
either [17] 15/9 18/23}
20/7 32/18 32/21
45/14 52/11 54/11
60/1 70/12 71/5 78/21
79/9 83/5 102/5 135/5
136/18
element [3] 33/16
60/15 92/10
else [9] 46/18 46/19
80/15 87/5 103/9
107/2 107/2 115/17
144/9
elsewhere [4] 17/21
28/12 29/5 88/3
email [49] 8/9 8/9
8/10 8/11 8/15 8/16
9/17 10/24 11/25
40/20 41/16 41/22
41/23 41/24 44/1 44/5
44/16 61/3 70/5 70/10
71/17 71/21 72/1 73/1
75/15 75/16 75/16
90/17 91/12 94/17
95/13 96/6 97/16
97/22 98/24 99/9
108/1 108/3 113/22
114/18 114/21 117/20}
118/6 122/23 133/15

136/18 155/3 155/5
157/10
emailed [1] 72/10
emails [4] 8/19 91/9
91/11 114/10
embedded [2] 26/17
26/20
emerged [4] 20/11
20/23 20/25 31/19
emerging [1] 38/14
emphasis [1] 99/6
emphasise [2] 72/20
146/15
emphatic [1] 53/17
employees [1]
128/25
enables [1] 84/16
encountering [1]
88/16
encourage [2] 40/11
119/7
encouraged [6]
65/14 84/9 84/10
103/5 124/9 125/3
end [13] 11/19 11/19
28/4 43/15 56/21 69/5
70/1 77/9 83/21
100/19 111/9 141/17
145/16
ended [4] 31/14 79/8
86/10 87/5
endemic [1] 147/1
ending [2] 31/25 60/3
endorsed [1] 63/19
endorsement [1]
84/2
enduring [1] 20/14
energy [1] 89/25
engage [4] 65/9
82/13 117/16 120/5
engaged [2] 6/8
161/9
engagement [4]
24/24 40/11 45/14
51/7
engaging [2] 95/6
95/9
enough [6] 5/10 32/3
83/10 95/17 100/3
120/20
enquiries [2] 111/12
130/12
enquiry [2] 133/16
133/19
ensure [9] 23/17 49/5]
65/1 95/7 95/10 98/9
101/8 103/21 106/19
entered [1] 62/18
entirely [3] 57/3
82/23 109/11
entirety [2] 3/7 71/2
entitled [1] 25/25
entitlement [1] 77/23
entry [1] 13/7

envy [1] 162/23
episode [1] 112/18
equally [2] 81/9
111/19
equity [2] 161/13
162/9
equivalent [4] 17/23
49/21 104/1 141/18
errors [2] 52/6 53/21
escalate [1] 143/17
escalating [1] 88/14
especially [5] 4/12
32/11 56/17 80/24
150/22
essential [2] 13/17
82/17
essentially [9] 4/8
12/18 13/14 17/8
26/11 36/24 58/1
69/25 90/21
established [7] 3/21
18/14 26/12 26/14
51/20 53/5 153/25
estimated [1] 18/17
et [4] 30/25 116/1
116/2 120/24
et cetera [3] 116/1
116/2 120/24
ethical [1] 159/11
ethics [1] 159/14
European [1] 90/4
even [23] 7/7 21/18
22/1 23/2 27/20 27/25]
28/1 32/20 55/7 59/25)
65/24 71/1 71/4 74/3
82/16 107/23 119/13
129/7 137/2 138/6
150/12 153/4 161/8
evening [1] 61/6
event [3] 29/11 32/1
83/17
events [1] 31/22
eventually [10] 7/15
37/19 63/13 77/16
81/2 83/15 109/9
111/19 131/23 135/2
ever [4] 88/14 135/3
135/9 143/17
every [6] 18/20 19/1
27/6 51/11 147/10
147/24
everybody [2] 112/11
140/15
everything [5] 60/6
62/15 92/14 99/23
155/18
evidence [37] 14/21
15/8 15/16 18/7 18/9
19/13 20/4 20/6 21/5
21/18 22/5 22/5 22/5
24/8 29/3 36/18 38/17
40/5 46/4 52/2 52/6
54/4 54/9 60/6 70/17
72/13 73/3 74/16 86/4

(49) do... - evidenceO
E

evidence... [8] 91/15
93/20 93/20 113/25
140/25 157/7 160/3
163/5

evolving [1] 3/13

ex [2] 92/13 152/20
ex-civil [1] 152/20
exact [1] 55/22
exactly [15] 8/22
35/1 64/22 79/25
109/16 110/21 115/24
116/5 123/15 141/4
146/12 149/24 151/5
153/13 155/23
examine [2] 15/3
18/6

example [7] 4/11
11/12 33/6 33/17
46/19 148/10 162/1
excellent [1] 85/6
except [2] 87/5 93/20
exceptional [1]
150/14

excess [1] 77/19
exchange [7] 16/9
40/18 86/7 90/17 96/6)
108/2 115/5
exchanges [2] 87/1
95/18

exclude [3] 43/13
44/15 46/15
excluding [2] 43/11
44/8

excuse [1] 57/6
exec [1] 149/5
executive [17] 2/10
2/13 2/15 6/18 12/18
29/14 29/15 30/6 30/8
30/20 30/21 89/12
89/14 144/15 146/20
150/13 157/13
executives [3] 39/21
47/22 140/7
exercise [1] 111/10
exercising [1] 6/13
exist [3] 65/5 114/12
130/23

existed [1] 129/4
existent [1] 155/13
existing [2] 108/13
109/1

expect [2] 72/22
106/14

expectation [1]
122/14

expected [2] 38/7
131/6

expecting [1] 125/21
experience [15]
62/21 72/18 84/12
104/15 105/5 110/23
146/7 146/24 148/22

148/23 149/5 150/10
157/17 161/14 162/9
experienced [4]
51/17 79/19 149/14
158/7

experiences [1]
60/24

expert [5] 21/3 34/9
54/7 74/6 74/6
expertise [5] 79/12
156/6 158/10 158/12
158/13

experts [1] 66/21
explain [6] 21/13
41/16 59/16 74/24
102/24 120/25
explained [7] 13/18
84/7 88/8 92/14 96/19)
99/21 147/10
explaining [2] 64/21
111/20

explains [1] 81/17
explicitly [2] 50/8
50/9

explore [3] 3/4 67/20
148/18

explored [1] 137/20
exploring [1] 95/3
explosive [1] 140/1
expressed [7] 39/19
53/9 59/3 94/18
133/19 148/4 153/4
expressing [1] 155/7
extensively [1] 3/23
extent [10] 4/10 5/7
75/11 76/23 77/11
83/25 86/3 119/17
140/18 152/1
external [2] 119/24
162/22

externally [1] 119/23
extra [7] 5/23 88/22
89/2 100/1 100/4
131/1 137/19
extraordinarily [1]
153/22

extreme [1] 34/6
extremely [7] 45/20
59/5 89/4 103/2
140/12 161/7 162/5
eye [1] 144/22

eyes [3] 97/14 122/9
151/18

F

face [5] 48/1 55/12
57/1 57/3 64/14
facilitated [1] 58/1
facing [1] 93/15

fact [23] 6/18 7/24
27/15 29/9 38/2 47/13
48/24 49/22 70/14
79/7 82/6 84/25 96/1
100/7 119/13 119/17

120/5 132/14 137/19
139/23 141/25 144/9
151/19

facts [5] 6/25 52/16
84/15 109/5 157/22
failed [1] 138/9
failing [1] 5/6

fair [12] 4/1 4/22 4/23
32/3 62/18 95/14
95/16 109/2 121/21
123/19 149/15 150/12
fairly [1] 106/14

fait [1] 93/13

faith [4] 4/18 39/15
66/11 107/19

fallen [1] 38/12
false [8] 15/14 15/21
20/7 20/13 58/25 60/4
137/23 139/1
familiar [2] 70/5
124/18

far [6] 21/15 43/4
126/23 127/14 139/25)
157/18

farming [1] 112/20
fault [3] 36/19 117/3
160/3

faults [2] 3/24 12/25
favour [2] 23/8 44/8
features [2] 9/7 33/1
February [1] 133/15
Federation [1] 22/16
feedback [2] 69/9
152/19

feel [8] 80/13 82/8
85/8 93/4 102/18
102/23 103/14 103/15}
feeling [1] 83/1
feels [2] 42/9 72/17
fellow [2] 17/17 51/6
felt [26] 16/12 25/10
42/18 82/14 82/20
84/24 100/1 100/9
101/25 102/23 103/5
103/15 109/16 112/5
118/9 118/18 119/10
120/19 120/22 121/24
125/2 125/5 134/23
145/2 159/6 160/17
few [6] 4/12 10/17
19/4 101/15 116/15
135/25

fiddle [1] 124/20
fiddling [1] 128/8
fifth [1] 9/11

fight [2] 100/12
100/13

fighting [4] 46/10
82/9 83/7 143/11
files [1] 139/18
final [13] 15/6 15/10
15/15 15/22 19/9
23/11 72/17 104/25
129/6 131/10 131/13

131/19 155/2
Finally [2] 53/11
160/1

financial [6] 31/17
36/12 53/25 152/22
161/17 161/17

find [18] 6/2 6/25
12/7 18/10 33/25 34/9)
42/3 74/12 81/3 82/2
91/3 91/14 149/1
149/1 154/3 154/4
161/20 162/4
finding [3] 4/4 51/18
102/1

findings [13] 111/14
111/17 112/2 122/5
125/22 126/8 127/15
129/3 135/7 139/2
139/4 139/7 160/13
finds [1] 77/18

fine [7] 60/6 79/15
89/19 99/24 112/12
112/12 163/16

fire [1] 163/12

firing [1] 1441/5

firm [4] 15/2 18/5
110/2 152/6

firm's [2] 70/13
114/13

firmly [1] 130/6

first [26] 3/2 3/15 4/4
11/5 12/17 14/24
24/13 25/24 27/18
36/3 46/19 55/24
69/12 89/23 90/24
91/2 97/21 98/4 111/4I
126/20 126/23 137/5
141/22 144/6 146/4
158/21

firstly [5] 11/25 17/1
31/19 37/4 61/2

fit [3] 17/12 17/20
717

fitted [1] 142/11

five [4] 25/20 90/25
156/20 156/21

flag [1] 118/8
flashed [1] 87/6
flaw [1] 79/5

flawed [4] 72/18
flaws [13] 14/22 18/9
19/13 20/4 51/20
70/17 71/4 72/14 73/3
74/16 114/1 114/15
127/22

flowers [1] 33/15
focus [5] 110/15
128/13 130/6 159/17
160/1

focused [8] 42/11
44/9 58/17 70/25 78/1
110/10 145/5 159/15
focusing [1] 76/23
FOI [1] 133/23

FOIA [4] 141/23
follow [6] 48/18 67/4
125/18 131/8 135/14
156/7
follow-up [2] 67/4
135/14
followed [5] 4/7
13/21 40/16 44/4
85/19
following [13] 14/25
50/4 67/7 67/19 67/23}
70/15 70/21 73/1
105/20 112/24 113/24}
121/11 163/18
follows [4] 9/11 41/5
71/3 118/3
font [1] 70/5
foot [11] 33/9 37/23
58/6 65/6 90/16 91/7
93/5 96/16 98/4
117/19 123/24
footprint [1] 124/21
forcing [1] 61/23
foreign [1] 79/8
forensic [3] 18/6
107/22 112/23
forensics [1] 110/10
forewarning [1]
95/11
forgotten [1] 147/18
form [4] 5/20 53/25
77/18 140/23
formalise [1] 123/4
formed [2] 37/4
146/21
former [6] 7/3 12/21
15/1 18/15 51/16
110/17
forms [1] 53/23
forthcoming [2]
36/17 157/12
forum [1] 40/15
forward [12] 8/20
18/15 40/13 84/6
84/16 97/7 98/8
106/21 128/10 141/19}
159/23 162/19
forwarding [2] 86/13
114/21
forwards [10] 5/19
18/23 19/14 37/17
47/10 71/25 82/10
85/15 141/9 145/9
found [24] 3/24 12/14I
12/25 14/22 18/9
19/13 20/15 39/3 39/5]
51/1 74/24 83/15
83/19 87/14 102/6
113/25 117/3 117/7
126/18 126/25 129/9
139/21 147/7 150/13
four [8] 3/9 3/9 3/11
60/23 101/21 126/1
128/5 128/13

(50) evidence... - fourO
F

G

gloss [1] 137/14

fourth [1] 91/10
Fourthly [1] 26/17
frank [1] 40/15
frankly [2] 64/22
140/14

Fraser [1] 63/14
fraud [1] 32/3

free [2] 26/18 82/23
Freeman [17] 11/13
37/25 38/23 39/18

72/10 74/9 113/22
114/12 115/8
Freeman's [3] 40/19
40/22 42/7
freestanding [1]
130/24

fresh [4] 5/14 101/9
111/6 122/9

Friday [1] 115/2
friends [2] 60/2
154/18

front [2] 8/21 79/20
fruit [1] 20/1
frustrate [1] 46/7
frustrated [3] 40/8
85/23 92/5
frustrating [1] 88/20
frustration [1] 84/4
frustrations [1] 84/4
FTSE [1] 2/11
FTSE-listed [1] 2/11
Fujitsu [3] 53/24
128/25 139/22
fulfil [1] 111/5
full [7] 1/12 39/8 75/4
115/24 134/15 135/9
135/20

fuller [1] 16/20
fully [1] 30/14
function [7] 6/14
28/2 28/16 28/18 30/3
31/25 143/9
functional [1] 89/20
funding [2] 19/21
130/17
funnily [1] 83/10
further [32] 6/3 13/24
16/5 16/23 17/3 19/23)
38/20 43/25 48/14
48/15 48/17 49/8 50/2
50/5 51/10 65/12 66/4,
68/11 73/9 75/7 75/7
106/18 114/7 127/13
129/10 129/16 130/5
130/7 130/12 138/24
154/8 157/6
future [5] 16/25 17/6
49/25 106/22 154/7

40/13 41/8 42/18 43/4
43/10 44/8 48/18 70/6

Gareth [1] 21/3
gauge [1] 157/13
gave [5] 55/10 82/18
87/25 111/6 160/8
general [11] 17/12
17/15 22/19 28/13
37/12 80/25 102/14
108/9 128/7 135/17
148/15

generality [1] 137/17
generally [5] 16/21
22/24 59/12 59/17
146/8

George [15] 22/19
37/25 38/23 39/18

42/17 43/10 44/8
48/18 70/6 72/10
113/22

George Freeman [1]
41/8
get [45] 5/11 5/23 6/3
14/9 26/25 32/21

47/11 47/20 47/25
50/14 75/7 75/9 77/7
78/17 81/5 82/21
83/20 84/20 88/21
99/3 100/17 100/23
105/3 109/18 118/14
120/23 125/5 131/2
133/9 135/19 136/23

144/23 145/16 150/25)
151/6 155/21 158/25
162/18

getting [17] 5/10
21/23 33/19 74/13
77/14 85/7 86/11
86/11 92/5 99/17
99/22 105/11 134/20
137/22 144/2 149/2
154/4

GIB [1] 155/12
Gilliland [1] 35/25
give [10] 33/15 36/8
55/17 58/12 58/12
106/16 152/19 159/23}
160/17 163/5

given [27] 18/16 21/5
23/9 25/11 25/21
30/15 34/1 53/6 54/9
63/1 63/12 65/23
87/15 89/5 92/15
93/21 98/19 109/20
114/22 123/6 128/21
130/22 138/17 140/25)
146/7 146/24 155/18
giving [3] 91/24
102/9 134/15

glad [4] 129/15
gleaned [1] 125/9

40/13 41/8 42/7 42/10

37/14 43/19 45/5 47/4

143/14 143/22 144/22

go [48] 6/25 8/8 8/11
9/2 13/5 14/16 17/21
18/2 19/14 21/11
22/23 24/20 37/13
38/20 41/15 42/15
50/1 57/5 68/24 69/5,

82/10 83/23 83/24
88/1 91/12 94/10
94/14 98/20 98/22
99/4 100/15 114/17

128/5 129/24 145/9
147/21 149/8 153/11
154/25 155/4 158/24
goes [3] 26/15 32/14
69/4

going [45] 3/1 3/9

16/4 16/18 21/19
30/24 36/11 37/11

60/10 60/14 70/12
80/7 82/12 88/21
88/22 90/8 92/8 99/4

114/46 112/6 117/12
119/16 121/3 124/25
129/19 133/13 136/3
136/24 144/8 144/9
145/1 145/9 145/11
157/20

gone [7] 15/24 26/14
38/25 79/15 112/15
160/11 160/12

good [43] 1/3 1/10
10/15 11/11 28/14

57/20 81/16 81/18
81/19 86/25 87/23
88/24 91/20 93/1 94/9
97/10 107/20 109/6
109/25 110/13 111/24
112/21 113/14 113/16
123/10 140/12 140/14
146/3 149/4 149/7
151/2 152/18 154/13
156/24 156/25 158/20
160/18 161/9 163/2
got [80] 3/8 7/13 10/3I
11/23 13/10 17/13
20/8 20/12 24/13
24/17 25/22 27/5
29/11 32/8 32/8 34/4
43/4 45/4 59/18 60/6
63/1 68/16 68/19
69/11 72/4 72/7 73/16
73/20 74/8 74/8 74/14
74/22 75/9 76/12
78/10 79/1 81/18 84/6
84/13 85/1 85/5 86/4
87/3 87/4 87/9 88/21
89/2 99/14 99/14

71/16 73/23 77/7 78/9

121/18 126/11 127/18}

4/15 4/17 12/12 15/25

47/9 47/16 50/1 58/12

100/10 100/16 109/13

34/3 34/22 45/18 57/9

99/15 99/16 100/2
102/6 103/10 107/9
112/22 112/24 115/4

117/14 119/7 127/17
131/1 131/19 134/24
135/17 139/19 140/1
140/10 140/11 142/10}
145/18 149/7 150/24
151/1 154/8 154/13
162/18
governance [1]
159/18
Government [61]
1/22 2/18 3/21 3/21
4/9 5/17 13/8 14/12
17/2 19/17 19/18
19/23 22/9 23/16 26/5}
26/12 27/22 27/25
31/15 36/20 36/22
38/10 38/15 41/10
44/12 44/19 49/2 49/5)
AQ/T 55/2 68/5 72/24
82/24 83/2 100/12
105/22 106/8 106/10
110/4 111/23 112/16
119/21 122/3 122/6
122/15 123/3 143/8
146/25 148/10 148/20)
148/23 148/25 149/21
149/22 149/23 150/2
150/16 156/8 156/9
161/3 161/11
Government's [3]
68/1 89/8 148/5
governmental [1]
32/2
gradually [3] 6/15
63/9 150/24
grateful [3] 98/15
98/21 163/1
grave [1] 45/12
great [5] 33/8 40/2
46/1 78/15 156/5
green [4] 83/10 83/12)
155/12 156/3
grew [1] 151/8
grey [1] 22/2
grips [2] 82/21
143/14
grounds [2] 60/4
152/6
group [2] 52/9
135/18
guilty [2] 58/25 61/19
gulled [1] 151/17
guy [1] 9/6
H
had [221]
hadn't [6] 25/11
66/24 79/19 81/5
140/11 155/25
half [5] 2/14 42/23

115/13 115/23 116/16}

99/14 117/20 150/4
Hamilton [2] 4/13
4/14
hampered [1] 147/2
Hampshire [1] 59/24
hand [5] 13/6 14/18
21/11 46/10 123/5
handle [1] 72/23
handled [2] 24/22
122/20
handling [7] 16/25
23/9 36/15 111/7
127/11 127/21 156/2
Hannah [2] 8/23 9/9
happen [7] 26/13
43/19 45/24 48/9
100/23 118/22 139/19)
happened [11] 31/6
31/22 40/16 47/17
57/25 63/13 73/19
83/5 123/20 125/9
142/14
happening [3] 11/4
81/11 126/6
happens [7] 58/13
69/16 74/21 76/3
106/19 144/24 154/13)
happier [1] 145/2
happy [2] 73/8
130/21
harassment [1] 32/3
harboured [1] 148/19)
hardest [1] 147/19
hardworking [1]
85/18
harm [1] 45/18
Harriet [4] 9/4 9/18
99/1 99/5
harsh [2] 155/10
155/14
has [53] 8/24 8/25
9/10 9/17 9/23 12/23
12/25 14/20 14/22
19/11 19/13 19/24
20/8 20/11 20/17
20/23 22/19 23/5 36/5
39/3 42/16 44/2 48/24I
50/20 51/7 51/9 51/14
51/24 51/25 52/2
53/13 56/1 70/25
72/10 73/2 93/25
101/12 110/2 124/2
125/19 130/18 138/19}
142/1 145/24 146/9
147/2 147/15 147/18
147/23 147/23 151/21
152/25 153/24
hasn't [2] 140/25
154/5
have [299]
haven't [10] 21/11
74/14 79/1 87/4 90/5
102/6 116/14 127/17
147/17 160/21

(61) fourth - haven'tO
H

having [30] 29/14
33/8 33/18 47/2 57/9
60/14 62/2 64/23 68/1

90/14 90/25 96/6
108/21 111/4 112/12
126/4 131/17 134/11
138/6 144/24 149/4
150/9 152/4 154/17
158/15 159/22
he [99] 21/5 22/20
24/7 25/12 31/4 39/14
40/25 42/8 42/9 42/11
42/13 42/18 42/18
42/24 51/9 54/24 61/7)
61/15 61/17 64/1 67/1
68/3 70/8 70/21 70/22
71/14 71/14 71/24
72/1 72/12 72/16
72/I17 73/2 86/5 86/6
86/8 86/17 86/19
86/23 86/25 87/13
88/9 88/11 88/23 92/4
92/6 92/25 93/1
103/21 103/24 103/24)
104/2 104/2 104/3
104/14 104/14 104/16)
104/19 104/19 105/1
105/2 108/5 109/12
109/13 112/19 114/2
114/4 114/8 121/22
121/24 125/20 126/8
126/17 126/18 126/25
127/7 127/8 127/9
127/19 128/12 128/12)
128/20 129/1 129/1
129/2 131/13 131/25
132/5 132/10 132/16
136/11 136/11 141/7
143/22 144/25 153/14
155/9 155/15 159/6
he'd [2] 111/20 131/3
he's [7] 55/1 67/3
111/25 112/1 125/18
132/2 155/23
head [2] 104/1 162/2
heading [3] 90/19
127/19 133/16
headings [1] 128/19
healthy [4] 47/24
hear [14] 1/3 4/20
45/4 47/22 57/21
66/12 94/11 102/10
113/14 119/6 121/21
123/11 149/18 157/1
heard [1] 152/9
hearing [3] 78/5
106/21 163/18
hearings [1] 139/21
heart [3] 76/22 105/3
157/25
heavily [1] 90/7

68/16 81/7 87/1 88/22

held [4] 2/21 6/10
61/12 128/24

hello [1] 159/4
help [9] 8/9 10/20
30/12 31/9 119/7
142/24 151/2 154/23
162/23

helped [2] 79/21
116/11

helpful [17] 12/15

75/2 85/14 85/18
98/11 103/2 103/15
110/23 121/8 125/16
144/6 146/16 153/14
helpline [1] 62/4
helplines [3] 128/15
149/7 151/2

hence [2] 63/7
151/18

Henderson [2] 48/11
123/25

Henry [5] 145/24
146/2 156/12 157/4
164/6

her [26] 39/4 50/16
54/17 56/11 56/13
57/1 57/9 85/20 90/23)
91/2 91/3 94/15 97/25)
102/10 102/12 108/7
118/10 120/16 120/20)
120/25 136/7 140/21
140/24 159/23 161/21
161/22

here [21] 10/24 11/4
11/8 12/13 15/11
21/16 30/18 31/17
37/6 40/3 41/17 42/14
46/2 71/10 73/21
74/13 75/6 75/14 97/1
117/24 139/19
herself [5] 55/5 57/11
111/18 120/19 120/20)
hesitation [1] 54/18
high [4] 3/6 109/14
110/9 120/3
highlight [1] 78/22
highlighted [2] 73/2
101/23

highly [2] 52/25
111/22

him [38] 35/13 43/5
55/1 64/1 67/2 67/2
84/9 84/10 86/4 86/9
86/11 86/18 88/8 90/4
103/20 103/25 104/10)
104/10 104/20 105/41
105/3 107/1 107/25
111/18 119/10 125/20)
125/21 126/2 126/3
127/1 131/14 131/15
131/17 131/18 131/18)
131/20 133/4 141/6
himself [1] 132/16

25/14 40/3 46/2 65/19

hindsight [3] 21/22
28/19 112/9

hire [1] 152/18

his [26] 21/6 42/7
43/4 51/6 51/8 54/8

119/8 121/12 125/25

131/11 136/3 161/21
161/22

historic [1] 138/13
history [1] 100/9
HM [4] 148/4

hold [5] 83/3 91/17
104/4 140/10 158/11
holding [3] 2/3 2/9
81/1

holiday [1] 116/1
home [3] 31/9 33/14
59/9

honcho [1] 87/12
honest [14] 5/9 6/5
10/10 59/20 60/10
64/18 74/5 84/19
88/17 109/2 112/4
115/25 130/25 142/4
honestly [1] 22/10
honesty [2] 14/13
153/17

Hooper [2] 67/17
121/13

hope [3] 50/22 55/4
153/7

hoped [1] 45/8
hopefully [1] 3/3

126/8

Horizon [73] 3/23
4/21 5/21 6/2 7/9 8/1
9/14 10/13 12/23 13/1
14/17 15/8 15/16 16/6
16/11 16/23 18/20
19/13 20/4 32/19
33/22 34/10 36/13
37/4 37/7 38/8 38/17
39/1 39/3 41/6 42/3
53/21 58/20 63/1 66/9
70/18 72/14 72/17
73/4 74/17 78/25
81/14 101/10 103/21
105/17 105/18 105/23
106/6 111/8 112/11
114/1 114/16 117/24
118/2 118/4 118/5
118/7 123/11 126/16
126/17 126/17 127/4
127/12 127/22 128/14)
143/16 145/13 147/25)
148/9 148/19 149/10
151/8 151/12

hour [5] 42/23 43/9

61/13 61/15 68/2 70/5
109/12 111/17 112/20

126/21 127/14 127/15)
127/20 128/21 131/10

Honourable [1] 152/9}

hoping [3] 75/7 97/13}

44/1 158/22 158/23
House [9] 1/23 2/16
7/16 7/17 24/19
116/14 152/3 153/19
153/23

how [39] 5/22 6/23

62/7 64/7 66/25 73/11
81/10 87/13 89/11
98/21 106/24 110/23
4111/5 111/11 111/13
112/2 116/3 123/16
133/25 134/5 135/21
135/22 137/21 142/5
142/11 145/8 146/25
154/9 156/15 161/19
162/3

however [13] 3/6
24/16 35/13 42/9
44/10 53/8 66/11
85/19 108/12 125/2
148/2 152/12 161/6
huge [2] 142/20
142/21

hurting [1] 33/9
hyperlink [1] 114/9

I actually [3] 75/3
78/16 117/7

l agree [6] 40/12
56/11 56/14 107/4
109/1 120/6

l agreed [3] 17/25
43/15 66/15

l alluded [1] 93/7
lalso [6] 2/14 5/12
48/1 56/12 143/2
151/20

lam [13] 4/17 16/4
43/10 48/16 56/6 70/9
71/13 91/21 105/15
106/15 111/5 124/6
152/5

l anticipate [1] 130/3
l appreciate [1] 91/2
lask [1] 1/10

l asked [9] 54/23
75/6 78/16 99/5 126/6)
129/13 139/17 145/14}
147/9

lassume [2] 56/3
62/24

l assumed [1] 130/25

l attended [1] 30/7

Ibe [1] 148/20

I became [1] 150/5

I believe [1] 59/1

I believed [1] 15/17

I bought [1] 85/13

I call [2] 1/5 60/24

I came [5] 6/15

139/16 144/5 149/15

13/21 14/3 14/5 17/13}
17/14 18/1 37/11 41/9}

149/17

Ican [7] 21/15 93/3
124/13 139/25 144/6
147/14 161/15

I can't [4] 50/7 55/17
88/17 115/6

I cannot [2] 91/20
101/16

I certainly [3] 73/15
77/5 147/3

I chaired [1] 58/3

I check [1] 61/1

I come [2] 146/8
155/1

I communicated [1]
86/22

I could [3] 35/5 38/13)
7713

I couldn't [2] 120/11
158/23

I dealt [1] 84/4

I described [1] 143/1
I detect [1] 96/5

I did [17] 17/11 21/13
28/3 33/25 67/2 82/8
83/9 86/3 88/18 90/4
91/11 101/7 120/8
123/2 137/11 144/6
144/24

I didn't [24] 6/23 21/8
24/16 54/14 60/17
64/19 69/3 75/9 78/17
79/12 79/16 84/23
85/8 86/2 87/25 92/15
102/22 112/5 119/5
119/11 129/18 130/25)
132/21 145/16

I disagreed [1] 43/15

I discovered [3] 24/5
142/15 142/17

I do [8] 65/20 82/25
93/12 102/1 107/7
124/4 124/16 139/8

I don't [36] 9/24 11/7
15/12 28/17 44/22
55/21 65/20 66/24
75/3 77/4 78/11 86/8
93/19 93/20 95/15
102/6 102/13 108/21
115/24 126/2 131/18
132/15 133/1 133/2
133/5 134/15 136/16
143/3 148/15 148/17
151/11 153/13 157/1
159/14 162/23 163/13)

l encouraged [5]
65/14 84/9 84/10
124/9 125/3

lended [1] 86/10

leven [1] 32/20

l eventually [1] 109/9)

l explained [3] 84/7

88/8 99/21

l expressed [1]

(

52) having - I expressedO
l expressed... [1]
133/19

I felt [12] 16/12 25/10
82/14 82/20 84/24
100/1 102/23 109/16
112/5 125/2 125/5
145/2

I find [1] 91/14

I firmly [1] 130/6
first [1] 24/13

I found [4] 20/15
102/6 117/7 147/7

I gave [2] 111/6
160/8

I got [10] 59/18 75/9
84/6 89/2 99/14 99/15)
99/16 115/13 142/10
145/18

I had [45] 7/12 7/13
11/14 16/10 45/1
60/18 64/19 68/18
73/24 75/25 78/6 78/8
80/2 82/11 84/12
84/19 84/22 84/22
86/2 86/7 87/11 87/11
88/1 88/17 96/18
100/20 100/22 104/20}
107/19 112/16 115/15}
116/2 119/15 123/2
124/8 126/1 126/9
126/23 134/11 144/3
150/3 152/1 156/1
158/22 160/10

I hadn't [2] 25/11
155/25,

Ihave [24] 38/22
47/9 60/11 60/12
62/10 63/12 71/10
75/19 76/7 76/9 76/15)
79/17 91/8 104/25
114/9 114/21 117/25
120/16 129/25 130/7
141/19 149/9 157/5
162/16

I haven't [4] 79/1
90/5 102/6 160/21

I highlighted [1]
101/23

I hope [2] 50/22
153/7

joined [1] 150/4

Ijust [7] 6/3 34/15
67/20 97/15 103/23
156/14 158/1

I kind [1] 50/6

I knew [7] 7/3 11/9
20/14 28/8 29/10 63/4,
105/5

I know [11] 10/5 35/2
63/12 88/8 126/23
140/25 142/20 145/24)
151/11 151/25 158/17)

Haid [1] 108/21

63/8

Ilistened [1] 120/25
Hook [2] 40/18
106/21

I looked [1] 136/15

I lost [3] 84/18
136/25 137/2

I made [3] 10/4 14/2
102/7

I may [5] 3/1 23/23
32/20 74/20 129/23
I mean [74] 4/1 5/16
8/13 10/9 13/23 14/7
15/25 17/9 20/14
20/19 20/24 21/21
23/23 26/21 27/22
28/3 30/22 33/25
34/24 37/7 44/22 47/3
47/9 49/25 63/6 73/20
73/22 74/20 77/11
81/10 83/9 83/9 83/23
85/1 86/6 87/2 88/6
89/9 92/18 97/11
102/15 103/1 104/16
108/20 112/3 115/6
115/23 120/5 127/2
128/3 128/6 129/6
133/7 135/13 139/16
142/20 143/1 143/24
147/8 147/13 151/8
152/15 152/21 153/5
153/11 153/21 154/1
154/3 154/12 157/20
158/15 158/15 158/17)
159/22

I met [4] 61/10 86/18
99/25 123/25

I might [3] 114/14
131/20 144/1

I moved [1] 84/6

I must [1] 115/6
Ineed [1] 163/13
Ineeded [2] 11/11
91/25

I never [2] 78/10
142/14

I normally [1] 115/12

I note [1] 50/19

I noted [3] 29/10
117/24 127/1

I now [7] 28/19 66/12
83/3 87/3 138/6
147/21 152/2

l obviously [3] 5/3
25/18 29/14

lof [1] 64/1

lonly [2] 78/4 99/14

I probably [4] 13/18
62/12 84/3 115/12

I propose [2] 111/10
145/22

I pushed [1] 87/24

I learnt [3] 33/25 63/8}

I put [1] 93/23

I queried [1] 28/3
lread [1] 129/8

I recall [6] 59/3 66/3
103/25 124/3 131/20
132/9

lI reference [1]
110/22

I remember [5] 33/6
37/13 54/23 119/25
158/20

I represent [1] 157/1
I require [1] 112/3

I respectfully [1]
70/20

I retain [2] 96/8 96/10
I said [11] 10/4 32/9
69/3 101/16 102/19
117/6 136/15 136/22
156/4 161/2 161/7

I saw [7] 73/14 74/19
86/14 119/10 121/1
123/8 142/4

I say [3] 76/1 108/24
110/22

I see [1] 87/13

I share [1] 56/19

I should [10] 13/25
23/12 35/17 38/19
66/15 80/21 102/19
119/14 123/7 145/16
I shouldn't [1] 120/11
I spoke [2] 105/3
131/15

I start [1] 3/6

I stopped [1] 135/13
I strongly [1] 43/6

I subsequently [1]
57/7

I suggest [2] 56/16
163/10

I suggested [2]
108/20 125/17

I summarise [1]
25/22

I supported [1] 14/7

I suppose [5] 24/13
54/16 95/16 149/15
150/11

I suspect [2] 100/7
123/2

I take [4] 31/19 44/24
78/20 120/13

Ithen [1] 78/18

I therefore [1] 77/14

I think [173]

I thought [13] 44/22
90/24 100/4 101/17
105/1 107/20 116/12
119/5 128/10 129/12
135/14 143/1 150/11

I told [1] 143/19

I took [7] 27/21 46/23
55/12 57/3 87/21

118/2 137/13
I tried [5] 5/11 84/20
89/1 139/18 151/20
l understand [4] 44/7
55/20 98/16 101/12
I understood [1]
39/24
luse [1] 37/20
lused [1] 30/9
I want [4] 3/8 80/8
94/20 148/17
I wanted [16] 16/16
34/15 64/22 73/17
74/12 84/5 95/21
96/21 97/5 100/16
100/17 100/22 100/23}
101/8 110/22 155/21
Iwas [107] 1/22 2/13
4/10 4/11 4/15 4/15
4/23 4/25 5/1 5/9 5/24)
6/2 7/1 7/20 11/6
11/14 17/21 20/18
21/23 24/5 24/16 30/9)
30/10 32/25 37/8
37/10 39/9 40/10
43/19 43/20 45/8
46/25 47/22 54/24
57/6 58/12 59/12 63/8)
65/23 66/9 67/1 77/6
77/12 78/4 79/16 81/7,
81/8 82/9 82/24 85/4
85/12 85/22 87/1 88/3,
88/3 88/8 89/10 90/1
90/7 90/9 92/4 92/8
93/19 95/19 96/20
96/20 97/13 99/21
99/22 99/24 102/9
102/18 102/20 103/5
104/25 105/1 107/10
108/20 109/11 112/12)
116/6 121/1 121/5
123/10 124/14 126/3
126/8 129/11 129/13
129/15 131/7 131/16
134/12 136/1 137/8
139/6 139/17 142/4
142/18 143/1 143/20
143/20 144/20 145/6
149/6 150/5 158/13
I wasn't [7] 5/10
34/12 68/19 69/10
76/11 85/4 136/15
I went [5] 66/4 86/18
150/1 150/7 158/20
I were [1] 64/13
Iwill [6] 49/15 65/12
88/8 115/23 130/4
133/3
I won't [1] 8/5
I wondered [1] 93/7
I worked [3] 120/2
149/21 150/1
I would [36] 9/13
10/12 17/17 17/19

21/9 21/21 27/20
44/10 44/23 48/17
65/12 72/20 75/7
76/14 88/19 98/21
98/22 109/8 117/11
124/7 131/2 131/6
133/4 135/19 139/13
139/13 139/14 140/16
146/15 149/18 156/1
160/11 160/11 160/12)
160/13 162/5
I wouldn't [2] 34/23
107/23
I wrote [1] 10/1
I'd [34] 7/11 22/6
28/17 34/22 45/22
54/14 59/18 60/6
60/12 63/5 68/19
69/10 73/16 76/19
78/7 78/7 80/24 83/19
86/9 87/13 103/5
107/25 116/13 117/9
119/8 119/8 119/9
120/1 127/1 132/22
133/3 136/1 136/1
137/9
lil [2] 128/23 144/12
I'm [43] 1/22 3/1 3/9
7/14 11/5 26/21 28/21
33/25 34/18 36/11
44/23 59/22 65/12
68/22 69/3 73/14
73/19 74/13 74/19
82/4 87/9 88/7 88/19
97/12 112/4 115/25
123/7 123/8 132/13
133/7 136/3 140/22
147/19 149/13 150/9
153/14 158/10 158/12)
158/19 161/19 162/3
162/16 163/1
I've [33] 3/8 9/19
11/10 14/8 17/13
25/22 29/5 29/20
30/22 30/23 63/6 72/7
73/20 74/8 74/24
74/25 76/1 76/5 76/6
76/17 87/16 91/9
116/12 116/20 131/12!
131/19 132/2 133/7
137/16 145/14 147/8
150/7 161/14
lan [1] 70/10
idea [12] 28/14 44/3
76/13 76/14 88/24
108/17 110/18 111/24}
112/13 112/15 131/12!
132/2
ideally [1] 68/6
identified [1] 78/21
ie [10] 11/1 71/1 83/6
96/14 99/11 104/6
128/14 132/5 139/11
161/22

(53) I expressed... - ieO
I
ie by [1] 83/6

ie early [1] 104/6

ie his [1] 161/22

ie separate [1] 96/14
ie the [3] 99/11
128/14 139/11

ie whether [1] 132/5
ie who [1] 11/1

if [146] 3/1 7/16 8/8
8/19 9/2 9/3 11/12
12/19 13/5 13/13
13/23 14/23 15/23
17/16 17/17 17/18
19/14 21/18 22/9
22/23 24/9 24/20 25/1
29/1 30/16 32/2 32/3
32/6 33/15 35/5 38/20
41/15 42/22 43/23
44/12 44/23 45/24
47/6 47/25 49/20 50/1
50/2 54/16 54/17
55/24 57/4 59/21
60/20 61/7 64/19 65/8
65/10 66/1 67/23 70/4,
71/4 71/16 71/24 72/4
72/5 72/19 73/9 73/15
73/21 73/22 73/25

74/22 75/15 76/2 77/6).

77/8 80/8 80/13 81/18
82/1 82/6 82/10 83/21
84/13 84/18 85/15
88/17 89/3 90/16 91/1
91/2 91/12 93/7 97/21
98/2 98/15 101/10
103/12 105/6 106/17
107/2 107/16 108/2
108/10 108/12 109/3
109/19 110/4 110/6
112/4 113/20 114/2
114/17 115/13 115/25
118/11 121/18 122/9
122/20 122/22 126/11
127/5 128/4 128/6
130/20 132/8 132/15
133/11 133/13 137/2
138/1 138/1 139/10
143/9 144/17 145/25
147/3 149/10 150/12
152/22 152/22 153/10}
153/25 154/4 154/6
156/17 157/1 160/10
161/3 162/6 162/11
ignore [2] 69/1 79/16
ignored [1] 69/21
immediate [1] 141/17
immediately [1] 53/7
impartial [3] 66/10
91/16 91/25
impartially [1] 31/17
implemented [3]
127/23 130/9 139/16
implicate [1] 63/17

implication [1] 123/9
implicitly [1] 17/10
importance [4] 48/22
55/21 65/24 78/13
important [46] 19/5
20/20 22/16 24/19
27/6 28/20 32/21 43/6
45/25 48/3 51/5 59/8
66/19 67/1 69/11
76/12 81/13 84/8 85/1
89/16 90/6 90/11
90/12 90/12 100/14
118/19 119/11 125/17)
128/4 131/22 135/16
138/9 139/2 141/2
147/19 152/17 152/22)
153/17 156/7 158/2
159/4 159/6 161/8
161/8 161/12 162/18
importantly [2] 70/11
138/6
imprecise [1] 20/21
impressed [3]

103/20 104/10 105/1
impression [1]
140/24
improve [1] 26/25
improvement [1]
24/3

improvements [1]
76/16

inaccurately [1]
114/13

inadequate [1] 62/4
inadvertent [1] 93/18
inadvertently [2]
91/23 93/23
inappropriate [3]
38/10 52/25 154/17
incentives [2] 29/6
31/18

include [1] 7/25
included [5] 14/1
34/8 35/17 35/25
61/14

including [14] 2/11
10/19 39/7 42/15
53/25 59/10 73/7
80/24 89/6 90/17 99/3
101/24 106/2 140/16
incorporated [1]
62/16

incorrect [2] 114/1
115/22

increase [1] 19/18
increasingly [2] 40/8
46/7
incredibly [1] 152/17
indeed [9] 1/18 28/11
29/15 44/18 79/9 82/1
105/18 116/13 119/25)
independence [10]
108/18 108/21 109/1
110/7 110/9 111/9

118/10 119/3 133/11
154/19
independent [41]
4/20 5/14 5/20 6/14
7/2 12/25 14/20 15/2
17/4 18/5 19/12 36/22
38/15 38/18 60/8 64/4
66/13 70/16 76/20
80/11 84/14 87/22
88/23 91/25 95/19
96/13 97/17 100/21
101/9 101/18 104/1
105/21 106/3 106/9
110/18 112/22 116/9
116/9 129/25 145/3
162/13
independently [5]
3/23 31/16 51/23
108/13 153/16
indicate [1] 138/13
indicated [3] 23/20
25/6 38/5
individual [13] 7/1
13/2 21/12 35/1 48/5
49/13 51/15 51/24
52/9 59/18 116/4
151/14 157/22
individuals [15]
17/25 23/2 48/25
58/16 58/24 68/10
80/10 80/13 89/6
89/15 89/16 105/23
106/8 118/13 160/8
induct [1] 154/23
induction [4] 111/4
149/7 158/22 162/8
industry [2] 105/9
108/24
influence [2] 7/18
13/8
influencing [1] 13/22
inform [1] 118/20
information [20] 3/19
3/20 4/5 7/23 15/20
16/16 39/9 54/11
55/16 60/17 63/12
67/11 85/3 127/13
134/15 138/12 141/24
143/10 157/20 160/6
informed [3] 27/7
124/7 155/8
inherent [1] 32/17
inherently [2] 14/13
149/9
inherit [1] 26/16
inherited [2] 4/8
28/10
initial [5] 7/6 18/8
19/8 51/19 127/15
initially [2] 86/14
119/18
Inland [1] 150/20
innocent [1] 148/10
inquiry [17] 1/11 9/21

34/12 39/18 60/8 64/4
79/23 93/24 112/9
134/13 137/7 137/11
137/16 140/12 141/23}
142/17 147/23

ins [1] 5/4

insertion [1] 54/1
inside [1] 74/25
insistent [1] 102/11
insofar [1] 15/21
instance [1] 139/19
instead [4] 52/5
58/13 92/11 141/18
instigated [1] 34/21
instituted [1] 155/18
institutions [1] 28/20
instruct [1] 111/10
instructed [2] 110/2
141/20

instruction [1] 153/1
insufficient [1]
140/23

insulted [1] 101/25
integrity [1] 34/10
intellectual [1] 90/10
intended [3] 91/19
101/5 135/5
intention [1] 128/2
interactions [2]
25/13 86/15

interest [9] 13/2 20/2
32/17 45/2 75/19 76/5)
76/6 151/25 160/2
interest-type [1]
160/2

interested [4] 37/10
40/14 123/10 137/8
interesting [3] 30/13
46/22 162/17
interests [1] 78/1
interfere [3] 13/19
53/1 80/17
interference [2]
26/19 82/24
interfering [1] 38/19
Interim [3] 15/5
15/10 70/13

internal [2] 61/4
99/11

internally [1] 133/13
interpretation [1]
65/3

interrupted [1]
103/11

interrupting [1]
102/8

interruption [1]
163/12

intervene [1] 106/8
intervene’ [1] 38/10
intervened [1]
102/15

intervention [2]
72/25 123/16

interviewed [1]
104/20
into [26] 3/9 4/2 5/6
5/20 9/17 10/8 19/10
21/12 21/17 26/15
32/14 48/4 52/24 54/2I
59/18 61/19 62/16
62/18 77/20 78/9
79/20 106/25 113/18
126/9 146/22 153/9
introductory [3]
11/20 12/6 12/8
investigate [6] 38/25
39/16 127/24 128/3
130/10 152/11
investigated [2] 3/24
19/25
investigation [15]
5/20 12/25 17/4 19/16I
19/24 27/9 51/19
76/21 105/21 106/25
111/11 111/18 114/14)
116/10 129/10
investigations [4]
19/7 19/10 52/16
128/16
investigators [1]
106/3
Investment [2] 83/10
156/3
invite [1] 49/16
invited [12] 18/14
42/11 42/19 43/1 44/4)
44/11 47/12 50/11
50/12 66/23 98/16
121/22
invites [1] 118/23
inviting [3] 44/9
45/23 48/18
involved [8] 38/6
60/2 69/8 76/18 98/12
98/19 140/12 143/4
involvement [4]
53/15 112/21 134/10
134/11
involves [1] 156/4
involving [2] 52/15
157/5
irritated [1] 149/16
is [302]
ish [1] 90/24
isn't [11] 9/22 21/16
25/15 27/25 28/3
64/18 134/24 147/5
155/24 157/17 160/18)
issue [23] 6/1 7/9 7/9
10/15 11/3 24/10
39/16 42/5 49/22
58/17 63/14 65/3
66/14 68/8 69/14
69/17 69/18 94/21
96/11 104/12 132/15
144/2 144/7
issued [1] 130/18

(64) ie by - issuedO
5/21 16/14 18/10
36/10 36/15 37/12
39/22 45/22 61/2
66/20 70/18 72/15
73/25 82/13 82/18
82/21 87/20 90/4
97/14 101/10 103/21
104/13 105/17 106/1
4107/1 118/5 124/4
124/9 126/16 126/16
127/3 141/2 141/18
143/14 159/18

it [420]

it's [106] 1/15 1/16
3/7 7I7 7/17 7/20 9/3
12/11 13/14 17/11
19/4 20/3 21/10 22/2
26/23 27/12 28/20
32/3 32/20 33/17
34/15 34/22 35/23

50/12 57/3 60/13
60/13 60/14 61/4

72/7 74/6 74/23 76/1
76/11 76/13 78/11
79/10 80/4 80/8 87/7

91/3 94/21 95/14
96/15 104/22 107/13
112/22 123/3 123/23
126/24 131/5 132/18
132/19 133/5 133/11
136/5 136/19 136/23
137/15 143/2 146/10
147/3 147/6 147/13
147/13 147/14 147/20)
147/22 148/6 149/4
149/15 149/25 150/15}
150/19 152/16 153/3
153/23 155/5 156/6
156/17 157/17 159/2
159/3 159/7 159/8
161/4 161/7 161/8
161/12 162/23

italics [1] 13/7
iterations [1] 133/10
its [17] 23/18 27/13
27/19 38/6 39/6 53/1
54/7 58/21 61/18
61/24 71/3 82/15
108/15 132/11 138/14}
138/20 146/20

itself [8] 12/10 26/1
62/5 71/1 79/10
123/20 139/12 140/6

J

JACOBS [2] 156/23
164/8

issues [37] 3/13 4/21

41/25 43/5 44/3 49/20

62/11 62/16 63/7 66/8
68/20 69/7 69/8 69/23

87/8 88/20 90/19 91/2

James [10] 38/5
66/16 66/22 67/13
67/19 118/20 119/10
121/11 122/4 163/8
Jane [7] 61/6 96/19
97/3 108/8 133/15
140/18 141/6
Jane's [1] 108/6
January [4] 126/6
126/13 127/2 127/8
Jason [1] 1/10
david [1] 88/12
Jenkins [1] 21/3
JFSA [9] 17/6 18/23
20/1 22/20 23/9 23/9
24/21 42/13 45/17
JFSA's [3] 19/15
22/18 22/25
job [5] 7/4 104/17
109/4 112/23 160/14
jobs [3] 74/25 89/18
152/17
joined [1] 150/4
Jonathan [5] 109/14
125/4 126/17 131/9
133/21
Jones [7] 58/9 58/15
59/4 61/11 61/12
63/19 67/10
judge [3] 77/23
109/14 121/22
judgement [3] 47/11
92/23 122/17
judgment [1] 63/14
July [20] 1/1 2/22
3/17 4/18 15/5 40/21

70/1 70/6 80/7 94/22
113/22 114/4 114/10
119/9 136/23 142/10
junction [1] 84/20
June [22] 1/15 1/21
11/23 13/4 16/19
16/22 18/8 19/8 20/24
35/10 35/20 35/21
35/22 35/24 36/25
37/24 38/2 38/23
86/18 141/10 141/13
148/12

junior [2] 26/15 88/4
just [50] 6/3 9/3 9/16
11/16 13/5 13/13
30/12 34/15 34/18
42/24 48/14 49/20
51/13 55/23 56/1 60/5)
67/20 75/11 76/23
79/14 79/15 87/6 91/9
94/10 97/15 99/1 99/4
99/6 102/16 102/19
103/4 103/18 103/23
103/25 108/11 109/19)
111/4 111/25 111/25
120/20 123/9 134/23
144/4 154/9 156/14

48/13 50/16 61/5 67/5

158/1 158/2 159/1
161/19 162/3
justice [10] 12/12

58/24 78/2 105/25
130/16 138/23

98/13 98/18 108/21
keep [6] 50/1 87/7
124/24 147/6 155/19
159/6

keeping [3] 60/14
159/7 162/2

kept [8] 81/23 103/10
117/12 117/15 136/21

Kevan [5] 58/9 59/4
60/19 61/10 63/19
Kevan Jones [2]
58/9 59/4

Kevin [1] 35/25
key [17] 45/4 47/4
47/20 63/14 75/1 75/3
79/21 108/24 116/12
117/2 117/8 122/23
125/20 138/22 149/4
154/12 158/23

keys [1] 63/1

killer [1] 47/3

kind [21] 7/2 32/22
50/6 62/14 69/13
73/11 76/1 76/9 92/10
102/12 103/5 104/18
124/13 124/24 124/25)
128/8 131/1 153/9
158/18 162/7 162/15
kindly [1] 1/14

King [2] 94/23 98/11
knew [19] 7/3 11/9
13/18 20/14 28/8
29/10 29/14 53/20
53/23 54/6 54/16
62/12 63/4 83/4 87/2
92/4 95/20 104/6
105/5

Knight [4] 127/10
know [220]
knowing [3] 28/19
62/18 110/23
knowledge [4] 1/20
7/22 54/3 150/15
knowledgeable [1]
30/10

known [5] 16/10
25/14 54/17 115/6
149/13

L

lack [4] 58/19 92/23
143/25 160/1

17/22 20/20 23/4 53/5)

Justice for [1] 23/4

145/10 155/14 155/16

lacked [1] 87/18
Lady [2] 90/22 91/3
laid [1] 108/21
land [1] 27/6

146/15 157/1
largely [1] 4/6
last [16] 12/19 13/7

KO 3 v6 5178 51/10 51/14
keen [9] 40/10 42/5 _I 52/9 59/16 67/20
43/19 45/8 46/25 67/1] 75/18 105/17 111/5

134/4

lasted [1] 3/16
lastly [5] 5/19 23/12
27/7 63/15 130/19
late [1] 61/12

later [25] 5/16 6/23

62/8 67/2 67/6 73/15
73/21 75/4 75/25
87/12 103/19 105/14
111/20 125/12 139/7
158/16 163/14

latter [1] 155/15
latterly [2] 147/8
150/2

Laura [27] 6/18 12/1
26/7 35/23 37/24

58/10 71/25 73/12
78/23 80/6 85/17

96/23 97/22 98/6
98/24 117/20 121/10
126/4 132/22

laws [2] 15/3 18/7
lawyer [6] 66/1 84/11
84/22 84/22 98/12
108/3

lawyers [2] 120/22
142/23

lead [3] 39/20 41/7
121/3

lead-up [1] 39/20
leader [1] 103/12
leading [2] 84/14
141/15

leads [1] 50/24
leafy [1] 59/24

leak [1] 118/12
leaked [1] 23/4
leaking [1] 48/2
learn [1] 149/8
learning [4] 32/23
32/25 33/17 63/9
learnt [3] 33/25 63/8
63/8

least [5] 39/24 40/14
77/1 95/24 119/18
leave [1] 34/14
leaves [1] 107/4
leaving [2] 99/17

large [4] 28/9 135/23

130/19 130/23 133/17)

21/14 28/8 42/23 43/9)
44/1 47/14 48/10 55/1

40/21 43/24 44/1 44/6

86/12 87/1 92/4 94/21

111/25
led [9] 4/19 7/22
26/25 37/19 92/2
101/17 103/8 103/10
120/14
left [3] 13/6 14/18
82/25
left-hand [2] 13/6
14/18
legal [27] 23/7 28/9
29/13 30/21 30/24
32/4 32/9 33/10 44/11
44/18 45/22 59/1
65/25 72/24 98/16
99/3 99/5 99/14
120/24 132/3 132/10
132/11 133/20 134/2
136/9 136/14 142/19
legally [2] 132/12
132/13
length [11] 3/22
13/19 14/12 26/18
58/17 58/22 74/14
82/23 152/11 161/1
161/6
lengths' [1] 38/25
less [1] 105/9
let [2] 144/11 144/12
let's [4] 47/11 47/11
47/12 55/23
letter [53] 17/9 25/1
25/7 25/7 35/10 38/22I
39/4 48/13 49/18
49/21 50/17 53/12
54/16 56/2 56/17 57/2
80/25 101/21 105/13
106/24 107/4 107/11
107/24 110/25 111/3
111/20 113/1 125/12
126/22 127/5 127/6
127/13 127/17 128/5
130/22 131/11 132/9
132/12 135/2 135/2
135/4 135/6 137/9
137/10 138/18 139/24I
140/3 141/9 141/13
141/22 141/25 142/5
142/7
letters [8] 4/10 41/12
42/5 42/15 48/11
49/21 85/5 126/2
Letwin [2] 85/13
125/13
level [8] 3/6 24/22
30/14 54/1 95/7 95/9
96/2 110/9
liable [1] 77/24
lid [5] 155/14 155/16
155/19 159/6 159/8
life [1] 104/20
light [6] 20/9 20/19
23/20 25/6 31/22
154/21
lightbulb [2] 3/11

(65) issues - lightbulbO
L

lightbulb... [1] 125/1
like [48] 4/13 5/2
6/20 9/13 9/16 10/4
10/12 17/19 24/3 24/9
27/24 28/13 28/20
32/24 34/22 45/22
48/17 49/7 59/23
60/20 62/14 67/13
67/15 67/16 78/7 79/7
79/16 87/25 98/22
103/3 103/15 105/6
105/7 112/13 112/15
115/13 118/4 121/16
128/19 130/20 144/22)
146/15 156/1 158/11
159/18 161/3 162/1
162/11

likely [6] 9/19 48/8
109/21 110/9 110/13
151/12

limit [1] 124/14
Limitations [1] 63/22
limited [2] 75/21
162/9

line [20] 3/11 4/8
15/18 26/12 32/14
45/23 46/15 46/21
75/17 76/18 80/21
83/3 85/10 89/5 91/10
92/6 100/2 102/11
119/23 141/5

lines [7] 26/14 81/12
81/17 85/19 101/4
101/15 101/21

link [4] 31/25

ked [1] 159/15
links [1] 45/16

list [3] 60/19 83/11
98/13

listed [3] 2/11 77/2
77/5

listen [2] 57/10 85/8
listened [1] 120/25
listening [3] 63/9
122/3 124/3

lists [2] 70/21 70/22
litigate [1] 53/4
litigation [3] 141/19
142/12 143/4

little [18] 24/14 43/5
43/25 48/14 50/2
50/14 51/8 64/20 70/9
75/14 80/7 84/25 86/3
93/25 117/7 133/13
149/6 163/14

loaf [1] 99/14
lobbyists [1] 79/19
local [3] 10/18 23/6
145/11

locate [3] 101/13
124/2 141/24

locked [1] 155/12

logic [1] 44/21
logical [1] 108/15
long [11] 1/15 5/3
36/11 44/1 44/5 97/9
116/20 125/7 127/17
152/7 156/15
long-term [1] 36/11
longer [5] 16/17
16/19 74/3 83/4
132/17
look [75] 1/16 5/14
7/20 8/3 9/16 12/17
12/19 13/5 13/13
13/24 14/23 15/23
16/18 17/12 18/3
28/23 29/3 29/12
29/17 29/25 30/16
33/2 35/22 40/18
48/12 49/18 50/15
52/24 55/23 55/24
58/6 69/6 70/1 70/11
70/12 73/16 74/1 74/2
75/12 78/12 79/13
80/6 84/7 87/23 88/23)
90/15 91/6 94/18 97/7
97/21 105/12 106/21
107/21 108/1 108/11
109/19 110/25 111/6
113/23 115/17 116/4
119/16 121/7 121/9
123/22 131/7 138/1
142/13 144/17 145/4
147/4 149/10 154/20
160/19 160/19
looked [20] 5/2 16/10
16/14 21/17 30/19
73/1 74/10 75/25 76/1
94/17 94/19 95/13
103/21 113/23 116/14)
125/6 128/11 128/17
128/19 136/15
looking [24] 7/1
20/16 21/22 22/10
24/9 24/12 47/17 61/2
67/5 67/21 70/3 95/19)
97/7 97/16 98/8 101/1
112/18 113/19 117/18)
142/11 142/16 145/6
154/25 159/20
looks [5] 10/4 15/23
15/25 24/3 65/16
Lord [1] 59/23
Lord Arbuthnot's [1]
59/23
Lords [11] 1/23 2/17
7/18 11/1 11/15 11/16)
150/5 152/3 152/4
153/19 153/23
lose [1] 137/2
losing [2] 39/25 79/8
loss [2] 77/20 146/25
losses [5] 10/14
12/24 52/1 52/12
77124

lost [16] 33/3 39/25
82/11 82/14 83/8
83/13 84/18 87/18
133/22 136/25 137/2
143/12 143/15 152/14]
157/23 157/24

lot [25] 14/9 26/15
30/18 33/4 62/21
73/20 81/11 86/24
90/5 102/8 107/19
109/10 115/15 120/10
121/3 127/2 129/9
140/13 141/1 144/17
144/23 149/11 150/9
150/25 154/21

lots [7] 29/15 69/5
79/6 109/6 145/7
149/14 160/8

low [2] 29/23 122/23
luckily [1] 10/19
lucky [1] 158/25
LUCY [5] 1/8 1/13
111/2 114/20 164/2
lunch [1] 113/4
lying [1] 64/1

MacLeod [7] 61/6
96/19 97/4 108/9
133/15 140/19 141/6
made [43] 1/14 2/16
7/15 7/16 10/4 14/2
16/15 17/25 18/13
18/22 22/14 30/6
31/16 41/10 49/9 52/6
55/6 65/10 71/22 90/5
93/4 93/9 102/7 102/7
104/22 104/25 127/11
127/21 129/8 130/15
135/3 135/9 136/7
136/12 138/10 140/15}
142/24 143/5 146/18
153/18 158/2 158/3
158/4
magic [1] 79/4
Mail [1] 28/11
main [8] 6/19 9/6
36/10 46/17 87/21
97/5 118/2 118/7
mainly [2] 60/4 85/17
maintain [5] 17/2
19/17 122/3 136/9
136/14
maintained [2] 3/21
23/1
maintaining [2]
48/23 49/12
maintains [1] 36/21
major [1] 85/4
majority [2] 18/19
52/5
make [23] 13/20 15/7
26/25 29/17 32/23
57/5 65/8 77/15 84/15

85/10 85/11 100/24
103/13 106/11 112/17}
118/19 128/9 138/9
139/15 139/18 142/23
143/7 154/24
makes [3] 15/15
124/15 140/12
making [11] 7/13
22/1 38/6 64/13 76/16
81/21 99/25 120/9
151/14 159/8 163/1
manage [1] 55/8
management [3]
48/7 109/25 110/12
managers [1] 35/3
managing [2] 55/7
55/7
mantle [1] 145/3
mantra [3] 78/9
79/14 82/19
manuscript [1] 9/20
many [13] 6/6 13/23
17/13 33/8 33/18 35/2
35/2 53/9 59/12 62/8
109/18 146/12 163/2
March [6] 126/22
127/5 127/7 135/2
135/4 142/7
margins [1] 128/9
Margot [1] 163/8
Mark [6] 35/25 50/23
58/10 61/5 108/4
144/15
marked [2] 3/18 4/4
marshalling [1]
109/6
Martin [4] 89/23 90/1
144/14 144/24
match [1] 132/15
matched [1] 129/11
material [15] 15/20
20/9 20/12 20/19
20/22 20/22 20/25
21/14 21/18 70/2
109/20 139/11 139/22
140/2 140/10
materially [2] 21/6
138/8
matter [26] 14/6
16/25 17/3 19/18
19/19 19/19 19/24
23/6 25/24 38/9 41/12
48/20 68/17 68/19
72/21 72/21 74/11
80/18 102/12 106/17
121/20 122/9 122/13
132/21 155/21 155/22,
matter’ [2] 48/8 68/2
matters [19] 3/1
10/16 38/15 38/16
39/7 50/19 72/24 83/2,
90/7 97/13 119/24
128/13 130/2 130/13
143/16 143/17 152/22

155/8 162/22
may [38] 1/5 2/22 3/1
3/10 3/16 10/21 11/19I
11/25 16/21 22/11
23/23 30/13 32/20
36/14 66/23 70/23
74/20 77/18 78/6
82/22 97/17 98/20
105/24 110/14 110/15}
114/23 129/23 130/5
131/4 131/4 132/16
134/22 142/24 147/13)
152/9 158/1 162/4
162/13
maybe [6] 11/8 13/13
22/12 43/4 86/9
145/25
McFadden [1] 153/14
McFadden's [1]
152/10
McInnes [7] 36/1
75/5 78/8 86/7 124/21
148/7 148/12
me [89] 4/24 6/7 6/20
6/22 9/20 16/17 17/16I
24/3 24/12 29/9 35/3
37/25 40/2 41/18 45/3
47/3 47/14 55/17
60/11 60/16 63/7 69/6I
69/15 74/12 75/5 76/8
79/1 80/23 82/1 84/18
87/13 87/25 89/9 90/7
90/25 91/14 91/16
91/24 91/24 93/2 93/4I
93/5 93/21 102/23
103/1 105/19 107/5
107/9 109/2 109/12
411/10 111/12 111/21
112/1 112/11 112/25
116/24 117/6 119/12
119/12 120/8 120/21
120/24 123/6 123/14
124/18 124/21 126/5
128/6 128/11 128/19
129/19 130/8 130/21
131/5 132/11 134/13
134/15 134/21 135/25)
136/17 137/21 140/3
144/4 144/8 144/11
146/19 147/16 157/1
mean [80] 4/1 5/16
8/13 10/9 13/23 14/7
15/25 17/9 20/14
20/19 20/24 21/21
23/23 26/21 27/22
28/3 30/22 33/25
34/18 34/20 34/24
37/7 44/22 47/3 47/9
49/25 63/6 71/6 73/20
73/22 74/20 77/11
81/10 83/9 83/9 83/23}
85/1 86/6 87/2 88/6
89/9 92/18 93/13
97/11 102/15 103/1

(66) lightbulb... - meanO
mean... [34] 104/16
108/20 112/3 115/6
115/23 120/5 127/2
128/3 128/6 129/6
133/7 134/17 135/13
136/19 139/16 142/20
143/1 143/24 147/8
147/13 151/8 152/15
152/21 153/5 153/11
153/21 154/1 154/3
154/12 157/20 158/15
158/15 158/17 159/22)
meaning [1] 97/10
means [2] 56/14
69/20
meant [4] 59/17 74/6
115/16 136/19
media [2] 13/2
118/12
mediate [1] 53/3
mediated [1] 23/11
mediation [33] 7/14
13/1 14/18 16/2 16/24}
18/14 18/24 19/3
19/22 23/10 23/24
24/2 24/2 36/15 36/21
39/17 40/1 40/10
48/21 52/19 54/25
58/23 59/10 61/21
63/21 72/15 100/3
102/1 103/3 106/2
118/13 120/24 122/8
medicine [1] 52/3
meet [22] 35/13
35/14 36/5 41/9 47/1
48/10 53/18 64/5
64/10 66/16 67/2
67/13 116/23 116/24
118/24 121/12 121/16)
121/21 122/1 122/22
122/25 124/8
meeting [175]
meetings [17] 9/25
50/5 55/21 57/6 66/5
87/4 90/4 92/19 97/12
125/20 126/2 128/24
129/1 131/18 146/17
158/22 158/23
member [9] 1/23 2/4
2/10 2/16 84/14 85/21
86/19 161/10 161/22
members [4] 11/20
22/20 23/2 103/25
memo [8] 62/11 75/1
75/2 75/5 78/8 123/2
152/25 156/3
memory [3] 102/16
103/4 124/13
mention [3] 48/21
53/11 131/13
mentioned [16] 11/8
15/10 27/12 31/1

31/11 33/20 46/9

96/12 131/4 144/1
148/9 150/19
merged [1] 146/22
merit [1] 14/9
merits [2] 46/14
122/15
messaging [1]
122/21
Messrs [5] 48/11
58/15 67/10 123/25
127/10
Messrs Bridgen [1]
67/10
Messrs Swift [1]
127/10
Messrs Warmington
[2] 48/11 123/25
met [6] 51/5 61/10
86/18 99/25 122/10
123/25
mid [6] 3/16 3/17
4/18 82/8 83/6 143/11
mid-August [2] 82/8
143/11
mid-August 2015 [1]
83/6
mid-July [2] 3/17
4/18
mid-May [1] 3/16
middle [3] 59/24
60/24 71/17
middle-class [1]
59/24
might [34] 21/1 46/14
49/24 50/6 52/8 52/25
66/5 72/4 74/22 79/20
84/25 88/14 90/25
97/11 100/7 101/18
102/15 111/11 111/19)
112/15 118/16 119/20}
120/12 122/14 129/7
131/20 137/2 144/1
153/7 154/7 154/22
154/25 156/17 163/10)
milling [1] 74/8
mind [5] 7/5 46/13
126/10 129/11 145/6
minded [2] 82/18
83/8
minimise [1] 23/17
minister [53] 1/22
2/18 7/16 9/10 11/13
11/16 13/25 24/16
26/15 35/17 36/4
37/14 42/2 42/8 46/9
46/25 48/16 64/3 65/1
65/7 67/18 67/25
68/15 68/22 69/8
69/14 71/22 72/16
76/2 78/12 88/4 97/24
98/18 98/22 99/5
100/12 104/21 104/24)

55/17 76/7 84/3 87/15

107/23 117/25 118/9
128/7 133/8 133/12
133/18 133/20 136/24
147/9 150/5 150/6
150/8 153/2 153/3
Minister's [9] 2/4
41/11 44/7 92/18
118/16 133/24 134/16
134/17 144/19
ministerial [8] 2/21
6/10 43/14 58/3
146/18 150/11 153/17]
160/5
ministers [19] 17/5
24/24 25/13 25/24
36/5 55/8 73/10 89/17
91/16 133/6 134/25
138/12 143/9 147/17
151/23 152/5 152/23
154/16 161/5
minor [2] 33/16
34/15
minority [1] 52/10
minute [2] 37/1
158/25
minutes [7] 91/1
101/13 124/2 145/25
146/17 156/20 156/21
miscarriage [1] 53/5
miscarriages [2]
58/24 105/24
mischief [1] 153/18
misjudged [1] 93/4
mislead [1] 34/23
misleading [6] 21/6
39/10 54/9 74/11
76/13 138/8
misled [2] 114/23
157/8
misrepresented [2]
115/11 122/6
missed [1] 101/10
missing [2] 72/2
86/14
mistake [1] 136/18
mistakes [4] 32/24
32/25 33/17 149/8
mixture [2] 158/18
162/18
Mm [2] 16/3 33/23
moan [1] 144/24
mocking [1] 148/16
model [4] 13/21 14/6
14/6 14/11
moderate [1] 61/24
modestly [1] 97/15
module [1] 154/8
moment [9] 21/23
31/11 57/13 76/23
97/16 113/3 119/16
125/1 129/15
moment’ [1] 124/6
moments [1] 3/12
Monday's [1] 41/5

money [10] 19/21
20/2 32/13 32/14
52/12 79/8 145/10
152/23 152/24 162/21
month [8] 3/5 11/19
73/15 75/4 90/9
105/13 105/17 158/21
months [8] 2/24 6/9
15/18 31/6 59/7 126/1
135/25 147/10
mood [4] 91/4 94/16
95/12 157/13
more [52] 4/20 5/12
5/17 9/4 16/16 18/11
21/9 23/8 23/14 23/15)
24/18 25/15 28/6 31/9
33/19 34/2 34/2 37/9
37/11 45/18 46/8 52/8)
59/11 59/16 66/13
69/11 70/11 71/2 78/1
79/21 84/25 92/5
92/20 92/21 92/23
93/8 93/25 97/13 98/5
99/15 100/5 104/18
115/16 122/13 132/19}
138/6 140/16 147/14
154/23 156/2 160/2
161/8
morning [7] 1/3 1/10
51/2 56/12 57/13
57/20 90/23
most [9] 9/19 9/24
48/8 51/10 85/18
90/10 90/12 108/20
163/3
mostly [4] 12/21
14/25 23/6 51/16
motivated [1] 119/20
move [9] 37/17 84/16
94/2 117/18 141/9
152/2 154/14 154/14
159/22
moved [5] 28/5 78/18
84/6 90/1 104/2
moving [5] 39/11
39/23 125/2 150/22
162/19
MP [9] 17/17 38/4
51/11 65/3 66/16
71/18 85/4 115/14
125/13
MPs [56] 3/17 4/10
4/12 4/16 4/25 6/7 7/9)
10/18 17/16 37/19
39/13 39/21 40/5
42/11 44/9 45/4 45/7
46/4 47/1 47/21 48/6
49/2 49/5 49/11 51/5
51/6 51/13 53/9 53/17)
55/7 57/25 58/8 58/10
58/18 60/23 64/3
64/10 64/16 65/8
65/14 66/19 67/8
73/24 79/24 81/25

85/1 85/1 85/7 99/25
101/24 105/19 105/23)
116/13 117/16 129/12)
139/17

MPs' [1] 57/10
MPST [2] 8/10 8/16
MPST-OLD [1] 8/10
MR [95] 1/9 24/7 25/5)
25/11 26/23 34/14
38/5 39/14 40/19
40/22 42/23 43/4 51/6)
51/9 54/20 54/22
54/23 61/12 61/13
63/15 64/2 64/24
65/17 67/23 70/5 70/8
71/24 72/9 72/11 75/5
75/17 77/2 78/8 86/7
86/16 86/21 87/12
89/6 89/7 90/20 92/25
102/5 102/5 104/7
104/11 105/13 111/17)
114/3 114/12 115/9
121/19 122/10 122/10)
122/24 124/9 124/21
125/25 126/14 126/21
126/22 127/5 127/6
131/10 131/11 135/3
138/7 138/10 138/18
139/7 139/21 139/24
141/6 141/14 144/3
144/19 145/24 146/2
148/12 155/2 155/4
155/5 155/9 156/12
156/13 156/23 157/4
157/4 157/5 157/11
159/5 163/7 163/14
164/4 164/6 164/8
Mr Arbuthnot [2]
67/23 122/10

Mr Bates [3] 25/5
25/11 26/23

MR BEER [8] 1/9
34/14 139/21 156/13
157/4 163/7 163/14
164/4

Mr Bourke [3] 54/22
54/23 102/5

Mr Bridgen [9] 38/5
39/14 51/6 51/9 61/13
63/15 64/2 65/17
122/10

Mr Callard [12] 86/16
86/21 89/6 89/7 90/20
92/25 155/2 155/4
155/9 157/5 157/11
159/5

Mr Callard's [1]

155/5

Mr Davies [3] 54/20
64/24 102/5

Mr Freeman [2] 43/4
114/12

Mr Freeman's [2]
40/19 40/22

(57)

mean... - Mr Freeman'sO
146/2 156/12 157/4
164/6

Mr Jones [1] 61/12
Mr Mcinnes [5] 75/5
78/8 86/7 124/21
148/12

Mr Parker [11] 104/7

131/11 135/3 141/6
141/14
Mr Parker's [6]
111/17 126/22 127/5
127/16 138/7 138/18
Mr Ridkin [1] 24/7
Mr Russell [3] 87/12
144/3 144/19
Mr Smith [3] 42/23
71/24 72/9
Mr Swift [1] 138/10
Mr Swift's [2] 139/7
139/24
Mr Tim [1] 124/9
Mr Warmington [7]
70/8 72/11 75/17 77/2
114/3 115/9 122/24
Mr Warmington's [1]
70/5
Mrs [1] 4/13
Mrs Hamilton [1]
4/13
Ms [19] 4/14 38/8
39/4 40/23 45/11
47/25 51/3 53/17 56/7)
58/11 67/6 67/22
68/23 72/9 103/8
103/10 118/6 134/19
134/21
Ms Hamilton [1] 4/14
Ms Thompson [11]
38/8 40/23 45/11
58/11 67/6 67/22
68/23 72/9 118/6
134/19 134/21
Ms Vennells [5] 39/4
47/25 51/3 53/17
103/8
Ms Vennells' [1] 56/7
much [32] 1/4 10/4
17/14 20/25 33/19
46/20 47/19 64/7
77/13 86/2 91/5 93/9
94/13 99/23 105/3
107/13 110/21 113/10
113/15 117/15 124/5
137/18 140/16 145/10)
145/20 155/6 156/11
159/17 162/25 163/4
163/13 163/15
muddled [2] 134/20
135/17

Mr Henry [5] 145/24

104/11 105/13 125/25)
126/14 126/21 131/10)

murmurings [1] 4/12
must [4] 10/3 32/10
115/6 159/25
my [117] 1/10 3/7
6/19 7/13 9/25 11/5
11/15 14/8 17/12
17/15 20/18 20/21
26/3 26/3 26/3 26/23
28/3 30/7 32/17 37/7
38/12 41/18 41/24
45/2 45/10 47/20
50/22 50/22 55/4 56/4
59/8 60/17 60/20
64/18 65/23 66/11
69/7 70/13 82/14
82/21 84/10 85/17
86/22 87/2 87/4 87/4
88/10 89/9 90/12
91/19 92/10 95/20
96/22 96/23 97/5
99/21 102/3 102/16
102/20 104/21 105/5
108/6 110/21 110/23
111/4 111/114 111/14
112/2 112/6 114/10
115/17 115/25 116/11
119/14 125/1 126/9
127/3 129/11 129/22
130/6 131/17 134/14
134/14 134/20 135/24)
136/16 136/16 137/16)
138/21 139/5 140/3
140/21 141/17 141/20)
142/21 143/21 144/1
145/6 145/21 146/18
147/9 148/23 149/5
149/20 152/1 152/4
153/8 155/14 157/24
158/21 160/10 160/14)
160/21 161/2 161/7
161/18 162/8
My Lords [1] 152/4
myself [1] 41/18

nagged [1] 31/9
nagging [1] 43/18
name [3] 1/10 1/12
7TIN9

namely [2] 108/18
123/17

narrow [3] 145/14
159/15 160/1
narrowly [1] 71/2
National [1] 104/17
native [1] 79/15
nature [3] 63/2 86/15
107/2

nearly [2] 73/24
100/13

neat [2] 3/11 138/2
necessarily [2]
158/14 161/24
necessary [10] 33/15

47/7 53/16 106/18
111/12 111/13 112/2
112/25 122/7 130/1
NED [2] 2/10 93/1
need [14] 64/25 66/8
70/11 75/1 77/11
98/12 109/21 152/18
152/18 152/19 154/9
154/20 161/9 163/13
needed [10] 6/24
11/11 59/4 82/14
91/25 100/1 100/4
103/21 109/16 129/10
needs [2] 151/24
161/17
negative [6] 23/17
103/4 112/4 145/5
145/12 160/13
neighbourhood [1]
10/9
neither [1] 20/2
network [4] 36/12
106/11 106/23 145/11
never [6] 46/13 71/4
78/10 135/13 142/14
153/7
Neville [24] 1/5 1/8
1/13 8/10 8/15 12/5
22/15 41/7 56/5 56/15)
57/24 78/20 90/22
91/4 94/9 99/2 113/6
113/16 136/7 145/20
146/3 148/3 148/8
164/2
Neville-Rolfe [21] 1/5
1/8 1/13 8/10 8/15
12/5 22/15 56/5 56/15}
57/24 78/20 90/22
94/9 99/2 113/16
136/7 145/20 146/3
148/3 148/8 164/2
Neville-Rolfe's [3]
41/7 91/4 113/6
new [26] 5/13 13/25
14/6 19/15 20/9 24/16)
26/10 26/15 28/13
61/14 61/16 75/6
78/19 81/19 84/6
87/21 104/14 104/21
107/19 125/22 126/9
140/10 146/22 152/10
153/5 154/11
New Year [1] 125/22
newly [4] 146/21
news [3] 23/6 34/3
118/11
next [8] 12/9 42/4
48/21 67/7 69/23
113/6 126/1 129/24
NFSP [1] 42/10
Nick [2] 94/23 98/11
no [81] 3/11 3/11
3/24 6/1 9/23 12/25
14/21 15/7 15/15

15/19 15/20 15/23
18/9 19/12 20/1 20/4
20/6 20/14 20/22
20/22 21/17 22/2 22/5)
22/5 22/5 24/9 25/17
27/8 28/10 28/17
28/25 34/12 36/18
37/1 38/17 45/1 48/14
53/13 54/14 54/18
59/25 61/14 62/10
62/16 66/8 70/10
70/17 72/4 72/8 72/13)
73/3 74/16 76/9 77/22,
78/24 83/4 83/9
111/24 113/25 114/9
117/3 122/6 124/15
126/18 126/25 130/11
130/17 130/25 131/12)
132/2 132/7 132/21
133/2 133/3 134/11
135/8 135/14 142/1
146/8 148/21 155/21
nobody [1] 100/8
non [10] 2/10 2/15
29/14 30/6 30/20
117/24 118/5 149/5
155/13 161/17
non-executive [3]
2/15 30/6 30/20
non-existent [1]
155/13
non-financial [1]
161/17
non-Horizon [2]
117/24 118/5
none [5] 10/1 20/10
20/22 51/25 52/2
nor [2] 20/2 101/5
normal [2] 58/3
87/24
normally [4] 59/13
69/16 74/21 115/12
not [164] 7/14 11/17
13/8 13/19 14/12 19/5)
19/17 21/10 22/18
24/23 26/21 26/22
26/23 33/25 34/9 38/2,
38/19 40/16 41/25
42/12 42/13 42/25
43/8 43/11 44/11 45/1
45/2 45/13 46/8 46/12)
47/2 47124 47/25
50/10 51/20 52/19
52/19 53/6 53/11
53/15 53/18 54/10
55/10 56/4 56/25
59/11 59/22 60/13
60/14 61/25 64/2 65/5)
65/24 66/2 66/22
67/14 68/20 68/22
69/7 69/8 69/15 70/6
70/9 70/12 70/19 71/6
71/6 71/9 72/7 72/20
73/14 73/19 73/25

74/6 74/6 74/19 76/9
76/11 77/24 79/10
80/16 81/6 83/2 83/13)
86/10 87/7 87/9 88/14
89/9 89/16 90/17 91/4
91/11 91/24 93/13
97/12 97/19 99/3 99/6I
100/3 100/16 101/7
101/19 101/19 102/11
105/18 106/24 108/19)
110/2 110/14 112/9
116/20 116/24 117/5
117/14 120/20 121/1
123/8 123/13 124/4
124/6 124/24 124/25
128/7 128/8 128/17
128/23 129/6 131/11
131/25 132/5 132/7
132/8 132/8 132/9
132/13 132/16 132/18}
132/22 134/15 135/10)
135/12 136/3 137/9
139/1 139/7 139/20
139/24 146/18 147/13)
148/2 151/10 152/7
152/20 158/4 158/10
158/13 158/14 158/19}
159/7 161/4 161/24
162/3 162/16
notably [1] 90/8
note [30] 17/1 22/16
35/10 50/19 52/23
54/14 58/11 58/15
64/18 67/9 67/21
68/12 69/7 75/9 80/1
80/3 80/5 80/16 94/19]
96/4 97/24 98/2 98/7
101/3 103/13 119/16
121/10 124/15 126/15)
132/24
noted [6] 29/10 70/23
117/24 118/18 127/1
130/14
notes [4] 9/25 87/4
108/7 147/18
nothing [6] 39/5 60/7
75/6 80/15 131/16
139/9
noticed [1] 63/6
noting [2] 17/7 118/6
notorious [1] 150/16
notoriously [1] 151/8
November [2] 155/4
155/6
now [31] 1/23 8/5
16/18 16/21 20/24
21/2 23/8 25/12 28/19
28/25 37/1 39/10
63/12 64/25 66/12
73/8 79/22 81/18 83/3
87/3 109/14 112/9
130/8 136/4 138/6
141/21 147/21 152/2
152/9 156/13 162/15

(68) Mr Henry - now
N

number [23] 2/5 9/7
12/21 14/25 18/22
30/1 39/13 39/14
51/15 52/23 68/13
69/9 96/12 106/7
108/11 125/16 130/14
140/6 143/7 145/23
146/15 150/3 157/2
Number 10 [4] 2/5
68/13 69/9 150/3
number 2 [1] 9/7
number 3 [1] 108/11
numbers [5] 18/16
19/2 30/16 60/22
73/16

Numerous [1] 128/24!

[e)

O'Farrell [1] 90/20
object [1] 152/25
objections [4] 119/1
123/13 123/14 127/20}
objective [7] 7/2 22/8
26/2 91/16 108/16
109/5 128/1
objective/s [1]

108/16

objectives [1] 162/7
objectivity [7] 82/15
83/8 87/19 93/22
152/14 157/23 157/24}
objects [1] 161/25
obligations [1]
138/15

observation [1]

146/6

observations [1]
143/7

obstruct [2] 82/20
143/13

obstructive [1] 87/17
obviously [87] 4/11
5/3 5/16 6/16 6/24 7/2
7/19 10/5 11/7 15/17
17/7 20/18 21/8 21/22)
22/8 23/23 25/10
25/18 28/8 28/9 29/1
29/14 29/25 32/2 34/3
34/6 34/24 41/25
46/19 55/4 63/6 65/23)
66/4 67/1 74/8 74/11
74/13 76/17 79/7 80/2
80/21 81/7 81/24
83/25 85/14 88/9 90/6
90/13 92/12 92/14
92/25 93/14 93/19
95/17 100/9 102/9
102/14 115/15 117/16
120/1 120/21 121/1
121/4 124/17 127/1
129/18 132/14 134/12
136/1 136/22 137/8

137/9 141/1 142/13
143/3 145/2 146/8
149/14 150/13 151/25)
153/11 155/25 159/5
159/7 159/14 162/16
162/21
occasion [3] 47/6
97/5 123/17
occasionally [1]
88/19
occasions [1] 51/9
occupied [1] 90/7
occur [1] 119/19
occurred [2] 35/19
779
October [9] 113/7
113/17 117/18 117/21
121/10 124/1 124/12
125/15 125/24
odd [3] 16/20 54/17
81/24
Odgers [1] 98/17
off [13] 17/10 21/19
45/6 65/15 69/6 94/14
110/6 112/6 142/7
142/9 147/11 152/15
153/6
off-chance [1] 153/6
offences [1] 52/11
offer [10] 25/4 48/18
51/9 51/13 53/7 64/10
67/10 118/19 118/21
122/18
offered [4] 4/22
39/20 51/11 66/14
offering [1] 151/23
office [244]
office's [26] 12/23
13/9 19/20 20/6 21/4
28/2 39/16 68/9 70/24
75/23 77/20 101/8
101/25 111/6 118/25
119/19 120/14 123/13)
123/14 123/16 125/7
127/10 127/20 138/14)
138/25 147/5
Officer [1] 30/1
offices [12] 10/7 10/8
14/2 14/5 27/1 37/15
51/18 62/18 62/22
126/15 145/8 162/2
official [13] 6/19
17/10 24/22 80/3 83/3
84/24 96/21 96/24
97/2 98/18 99/2 99/19)
104/19
Officials [43] 5/11
6/12 6/16 6/20 17/5
18/2 18/21 24/9 25/5
25/9 25/10 25/25 40/1
42/4 42/25 43/1 43/12
44/25 67/15 76/9
78/12 82/15 83/7
83/23 84/21 88/1 88/2

93/8 98/13 112/13
129/14 131/16 131/16
134/2 134/7 143/10
149/17 151/22 152/13
157/12 158/5 158/9
159/12
often [5] 8/6 62/20
103/12 123/4 146/4
Oh [4] 144/11
Okay [2] 9/8 137/4
old [4] 8/10 14/6
65/25 140/5
Oliver [2] 85/13
125/13
Oliver Letwin [1]
85/13
omission [1] 132/19
on [276]
on pages 1 [1]
127/18
on' [1] 22/20
once [7] 28/5 29/5
32/7 90/8 131/3 145/2
152/3
one [53] 3/16 4/14
4/25 5/22 7/18 8/5 9/4
9/6 9/20 11/15 17/9
21/11 23/6 26/17 28/6
32/19 33/1 40/25
46/10 55/5 62/17
62/19 63/2 63/10
66/17 68/18 72/24
74/23 80/24 87/2 87/6
87/11 90/5 91/9 93/6
98/20 102/14 107/12
110/16 113/23 115/1
123/3 123/5 131/17
135/15 146/12 147/4
147/18 147/23 148/4
152/16 155/1 156/20
one's [1] 7/19
one-sided [2] 62/17
63/2
ones [3] 32/25 77/6
128/6
ongoing [5] 58/18
122/8 130/16 131/21
138/13
online [1] 81/19
Online’ [1] 71/1
only [11] 5/19 37/4
52/20 60/14 78/4
99/14 121/20 140/21
152/6 153/8 159/7
onward [1] 83/18
onwards [2] 5/5
149/25
open [7] 40/15 51/4
56/6 95/24 100/5
107/4 162/2
opening [1] 112/13
openings [1] 160/8
openness [2] 146/4
151/4

operate [3] 26/18
72/23 106/13
operated [1] 77/21
operating [4] 13/17
14/14 18/25 19/22
operation [5] 14/12
29/6 32/11 107/17
127/12

operational [4] 71/7
72/23 84/1 122/13
operations [4] 13/9
13/22 14/3 162/19
opine [2] 110/14
122/15

opinion [1] 140/3
opportunity [5] 49/6
49/8 49/10 51/12
159/21

opposed [1] 151/6
opposite [1] 155/24
opposition [1] 1/23
optimistic [1] 45/9
options [4] 95/3 97/8
108/23 151/23

or [130] 3/9 3/13 8/20
11/2 15/10 15/20
17/17 18/23 20/8 23/3
25/3 26/23 27/24 30/3I
30/23 31/4 31/6 31/6
31/8 32/3 32/4 32/5
32/15 32/22 33/3 34/8
34/10 34/19 39/25
44/2 44/20 45/14
45/15 46/18 49/24
50/5 50/10 52/12
52/13 53/4 53/16
54/11 54/18 58/1 60/1
60/22 66/2 67/14
67/15 68/24 69/17
72/6 73/21 74/22 76/4,
77/1 77/24 78/21 79/9)
79/12 80/12 82/15
82/20 83/5 83/18
83/24 84/5 88/21 90/8)
90/20 92/17 94/14
96/13 101/13 101/17
102/5 103/8 104/1
104/12 104/12 105/7
105/8 106/25 107/1
107/2 107/9 107/12
108/19 108/23 110/6
110/15 111/18 115/21
115/23 117/19 120/15)
124/2 125/7 126/1
126/2 126/7 126/15
126/16 126/21 128/1
128/11 128/17 128/23
131/19 131/21 132/5
133/23 134/6 135/5
135/15 136/21 139/8
140/24 142/16 143/13}
144/15 145/25 147/4
148/16 149/1 153/23
154/17 161/21 161/22

162/3
oral [1] 163/5
order [2] 11/11
135/10
orderly [1] 15/25
organisation [3]
22/17 24/23 28/6
organisationally [1]
84/8
organisations [2]
27/23 154/12
organised [2] 16/1
18/1
original [3] 16/9
35/16 66/24
originally [3] 7/13
23/25 28/11
orthodox [1] 4/8
orthodoxy [1] 13/16
other [36] 6/20 6/21
11/15 21/11 29/20
30/22 37/6 52/7 59/9
79/6 81/4 83/23 90/7
91/16 92/19 101/13
103/11 103/16 103/24)
107/12 108/23 117/4
123/5 124/3 126/7
126/24 130/13 133/7
139/14 139/21 142/13)
147/17 149/5 149/20
155/16 160/22
other's [1] 49/11
others [12] 2/3 37/8
40/22 43/11 46/12
61/6 78/24 85/21 86/1
135/16 135/22 139/22)
our [32] 10/9 19/16
19/18 25/1 50/23 51/7I
51/8 51/9 51/19 52/1
52/15 64/10 64/13
70/14 70/21 70/23
71/9 71/10 72/20
74/15 85/2 94/23
94/24 97/25 105/16
113/24 114/13 122/18)
122/21 147/19 156/13}
156/21
ourselves [2] 35/4
120/4
out [46] 6/25 7/19
10/25 11/13 13/23
25/7 34/1 34/19 37/6
39/4 42/15 47/6 48/12
59/25 64/7 66/3 67/25
68/15 73/24 75/3 78/3I
78/14 79/20 79/25
81/1 102/19 103/23
104/11 106/25 112/20)
122/2 122/16 127/4
127/12 127/20 129/1
129/2 129/17 131/22
137/24 146/20 150/23)
151/8 151/22 154/4
160/4

(69) number - outO
[e)

outcome [4] 52/20
130/4 133/18 134/6
outcomes [1] 110/10
outlined [1] 58/16
outlines [1] 127/15
outlining [2] 42/4
145/17
outs [1] 5/4
outside [16] 74/25
83/16 95/21 96/21
96/24 97/2 97/6 98/18
99/2 99/10 99/19
100/5 105/7 115/13
154/22 156/5
outsiders [1] 63/9
outsourcing [1]
112/19
outstanding [3] 34/4
104/12 142/6
over [38] 7/18 12/24
14/20 19/11 19/25
22/13 24/4 24/20
25/13 27/21 28/23
31/6 32/20 33/9 36/10)
36/13 38/11 45/9
49/14 50/1 51/14 52/4)
62/22 67/21 80/15
91/1 91/13 96/1
103/18 106/20 109/19
120/10 122/17 126/11
128/12 128/23 135/11
151/18
over-optimistic [1]
45/9
overall [1] 12/14
overbearing [2]
102/2 102/20
overnight [1] 62/24
overruling [1] 43/10
oversight [1] 158/7
overturn [1] 52/21
overview [2] 7/5 36/8
own [10] 21/4 23/3
27/13 27/19 27/23
31/14 45/2 126/15
160/14 161/13
owners’ [1] 161/17
owning [1] 161/3

Pp

pack [4] 15/23 16/15
36/25 103/2
package [1] 107/7
page [73] 1/17 8/8
9/2 12/11 12/11 12/17,
12/18 12/19 13/6
14/16 16/20 22/13
24/20 36/10 36/13
37/21 37/23 38/11
38/20 40/20 41/15
47/18 49/14 52/4
55/24 58/5 58/6 65/6

67/22 70/3 71/16
TANT 74/4 75/24
80/15 82/6 82/7 82/10
85/15 90/16 91/7 91/8
91/13 96/16 96/16
96/16 97/21 98/4 98/4
98/24 101/2 103/18
106/20 109/19 113/20
113/21 114/17 117/19}
117/20 122/17 123/22)
123/23 123/24 126/12)
128/12 129/2 129/3
129/24 133/14 138/3
138/5 141/12 155/5
page 1 [3] 9/2 12/11
114/17
page 12 [1] 37/21
page 14 [1] 14/16
page 16 [1] 47/18
page 17 [2] 58/5 58/6
page 2 [7] 8/8 41/15
55/24 97/21 113/20
133/14 155/5
page 26 [2] 96/16
96/16
page 27 [2] 91/7
101/2
page 3 [6] 13/6 40/20
70/3 71/16 113/21
129/3
page 30 [1] 82/7
page 34 [2] 82/6
82/10
page 39 [2] 123/22
123/23
page 4 [1] 129/24
page 45 [2] 138/3
138/5
page 48 [1] 141/12
page 61 [1] 85/15
page 72 [1] 1/17
pages [3] 1/15 12/13
127/18
paid [2] 64/7 111/22
pair [3] 41/4 97/14
122/9
panel [3] 104/23
110/4 110/6
Panorama [8] 13/3
24/18 36/17 37/18
38/1 63/25 105/20
120/1
Panoramas [1] 120/4
paper [9] 31/5 86/13
86/24 86/25 93/21
109/7 144/4 144/10
144/23
papers [7] 74/21 81/1
81/3 86/14 134/13
144/17 147/11
paperwork [3] 9/22
25/16 137/3
paragraph [56] 9/12
12/19 14/24 18/4

18/16 19/6 19/14
22/23 23/12 23/13
24/20 31/12 37/22
37/23 38/11 38/20
39/11 39/23 42/6
47/18 48/21 48/24
49/1 49/4 52/14 52/22
58/7 59/6 65/6 66/8
67/21 69/21 73/16
80/5 82/7 85/13 85/15
91/7 96/15 97/20
101/2 103/17 109/19
121/18 123/23 123/23
125/10 126/11 128/20
136/6 137/15 138/3
138/5 138/17 146/12
146/13
paragraph 100 [1]
101/2
paragraph 102 [1]
91/7

paragraph 103 [1]
103/17
paragraph 110 [1]
82/7

paragraph 125 [1]
85/13

paragraph 13 [2]
23/12 24/20
paragraph 143 [2]
123/23 123/23
paragraph 145 [1]
125/10
paragraph 150 [1]
126/11

paragraph 166 [3]
137/15 138/3 138/5
paragraph 2 [1] 18/4
paragraph 239 [1]
85/15

paragraph 290 [1]
31/12

paragraph 3 [2]
18/16 121/18
Paragraph 4 [1] 19/6
paragraph 46 [2]
37/22 37/23
paragraph 47 [1]
38/11

paragraph 5 [2] 49/4
146/13
paragraph 50 [1]
38/20

paragraph 51 [1]
39/11

paragraph 52 [1]
39/23

paragraph 58 [1]
47/18

paragraph 6 [1]
109/19

paragraph 62 [1]
58/7

paragraph 65 [1]

66/8
paragraph 7 [1]
19/14
paragraph 8 [1]
22/23
paragraph 88 [1]
80/5
paragraph 9 [3]
23/13 67/21 69/21
paragraph 93 [1]
136/6
Paragraph 99 [2]
96/15 97/20
paragraphs [17]
70/20 70/22 71/15
72/16 73/2 73/22
73/23 74/2 78/22
113/24 116/4 138/10
139/3 139/14 139/14
141/11 146/23
paragraphs 100-109
[1] 139/3
paragraphs 145-147
[4] 138/10
paragraphs 180 [1]
141/11
paragraphs 31 [1]
146/23
paranoid [2] 119/24
119/25
Parker [38] 5/13
76/20 88/9 88/23
101/19 103/19 104/7
104/11 105/13 106/25
108/7 108/10 109/11
109/20 110/19 118/17)
118/23 119/7 122/8
124/7 124/8 124/10
125/3 125/18 125/25
126/14 126/21 131/10}
131/11 132/15 133/15]
135/3 136/6 141/6
141/14 141/14 143/21
145/2
Parker's [7] 110/25
111/17 126/22 127/5
127/6 138/7 138/18
Parliament [7] 7/10
70/12 73/7 114/23
115/11 115/21 138/13}
Parliamentarians [1]
39/19
Parliamentary [5]
10/15 10/25 41/24
68/21 69/13
part [26] 3/2 4/8 10/7
10/24 23/25 31/15
37/4 37/21 48/7 69/25)
70/8 70/13 71/11
71/14 76/24 77/17
82/17 85/18 89/17
90/12 98/19 124/10
139/8 139/21 146/21
148/21

Participant [1]
156/20
Participants [3]
145/23 156/14 157/2
particular [12] 9/21
15/13 20/21 21/1
28/17 43/24 73/23
81/8 87/17 128/13
140/4 160/7
particularly [14] 4/13
7/1 17/18 26/22 36/16I
45/21 65/25 73/25
78/13 102/2 117/9
137/20 145/13 154/20)
parties [3] 40/14
76/18 125/21
partly [5] 88/10 100/7I
142/16 142/17 149/5
party [3] 85/19 89/5
108/2
pass [1] 63/21
passage [1] 80/8
passages [3] 77/1
77/5 87/16
passed [1] 24/4
passing [1] 102/21
past [2] 39/1 42/17
Pat [2] 152/9 153/13
patch [1] 92/22
Patrick [7] 50/24
56/19 58/10 61/10
64/1 64/12 108/4
pattern [1] 38/14
Paula [40] 35/14 36/3
36/5 36/14 37/8 38/23
41/13 42/15 47/21
49/19 50/15 54/15
55/4 55/10 56/4 56/11
56/14 56/19 56/24
61/6 90/15 90/20
90/23 90/25 92/2
94/15 95/12 96/7
96/18 97/3 100/25
102/7 102/10 118/15
118/18 120/7 120/12
120/15 140/21 159/23}
payments [1] 151/14
peer [1] 17/17
pencilled [1] 126/9
people [50] 4/3 6/4
6/5 10/14 14/9 14/14
14/15 18/23 33/9 44/8)
55/6 56/23 59/13
59/23 59/25 60/9
61/19 65/20 69/6 81/4I
81/20 83/12 93/10
93/11 102/11 102/21
103/11 103/14 104/22)
120/20 124/24 134/4
137/22 139/18 142/24I
151/3 152/17 152/19
153/10 154/13 154/17)
154/22 156/5 158/4
159/1 161/9 161/9

(60) outcome - peopleO
Pp

people... [3] 162/10

162/14 162/22

per [1] 36/5
perceive [1] 159/11
perceived [1] 155/13
perfectly [2] 57/6
142/12

perform [1] 162/4
performance [2]
36/12 152/18
perhaps [30] 11/8
24/10 24/18 25/14
28/7 28/21 33/9 35/3

35/4 43/20 45/9 46/19

56/5 59/20 66/21
68/22 76/13 79/3
79/18 91/22 92/23

93/3 93/17 93/23 97/8

114/21 119/13 144/8
146/19 149/1
period [14] 2/24 3/5
3/15 3/18 5/15 6/9
30/9 31/7 35/19 90/9
115/7 116/1 120/10
156/17
periodic [1] 125/24
periods [1] 3/9
Perm [2] 90/2 152/24
permanent [15]
83/24 88/16 88/18
89/13 89/13 89/20
89/22 144/7 144/14
144/18 144/22 152/21
153/1 153/2 153/13
permitted [1] 35/6
persist [1] 97/15
persists [1] 13/3
person [12] 33/14
41/1 54/21 54/24
54/25 87/22 99/15
99/15 107/3 109/15
161/20 162/4
personal [4] 41/23
41/24 90/21 148/22
personally [4] 8/17
25/2 77/13 115/4
persons [1] 129/25
perspective [3]
47/20 107/14 155/14
persuade [1] 43/12
perturbed [1] 57/7
perverse [1] 154/10
phone [1] 91/1
photos [1] 102/6
pick [2] 79/3 80/8
picks [1] 22/14
picture [1] 66/18
piece [8] 7/12 22/1
39/8 77/15 86/13 89/2
144/4 144/10
pieces [3] 93/21
109/7 131/2

pile [1] 147/11
pity [1] 141/1
pivotal [1] 67/1
place [4] 34/24 59/7
59/10 118/23
places [1] 154/18
planned [1] 63/23
planning [1] 88/9
plans [1] 127/15
platform [2] 71/3
71/7
play [2] 125/6 153/10
played [2] 66/19 67/3
plea [1] 61/18
plead [1] 58/25
pleas [1] 61/20
please [82] 1/6 1/12
1/16 1/17 8/3 8/8 9/2
11/24 12/7 12/17 13/6
14/16 22/13 22/23
23/12 24/20 35/22
36/10 37/21 38/11
39/23 40/19 40/20
41/4 41/15 42/3 42/22
43/23 43/25 47/18
48/12 55/23 55/24
55/25 56/1 56/9 56/18
56/20 57/14 58/6
59/17 67/20 70/4 70/4
71/16 71/21 71/24
72/18 75/12 78/7 80/6
80/9 82/6 82/10 85/16)
90/15 90/17 91/6
91/13 94/3 94/14
94/19 96/15 97/21
97/24 98/2 98/4 98/5
101/1 103/18 105/12
108/1 109/19 113/8
113/23 114/2 114/4
121/9 123/22 129/24
133/14 141/9
pleased [2] 4/15
50/25
plus [4] 28/11 65/3
90/11 99/4
pm [5] 94/6 94/8
113/11 113/13 163/17)
PMQs [2] 68/3 69/8
PO [1] 109/1
point [44] 10/3 10/5
11/14 15/20 20/5 22/1
22/13 22/14 28/7
30/13 34/15 35/5
43/12 44/5 44/14
44/16 45/19 46/13
46/17 47/3 47/4 48/5
54/19 55/20 56/11
65/17 81/6 93/3 95/14
95/23 98/16 98/23
99/17 99/18 109/2
118/7 122/13 124/19
124/19 129/7 144/3
148/7 158/1 158/2
points [27] 21/25

25/20 54/19 60/19
61/13 66/18 73/9 75/1
75/3 79/11 79/25 81/9
90/5 99/25 102/7
102/25 103/13 117/8
117/25 118/2 118/7
120/10 124/17 125/17
135/24 138/9 152/16
POL [13] 5/13 20/17
37/8 62/11 74/2 77/9
79/3 80/1 85/11 86/5
86/13 117/10 159/17
POL's [1] 91/17
POL00024913 [1]
127/16
POL00027164 [1]
49/18
POL00027729 [1]
61/3
POL00102551 [1]
105/12
POL00110382 [1]
133/14
POL00233179 [1]
108/1
POL00388295 [1]
55/23
police [4] 28/23
34/20 148/24 150/19
policy [11] 2/4 3/21
4/9 8/25 29/16 29/22
41/7 73/18 98/20 99/6
100/10
politely [1] 25/4
political [4] 26/19
83/6 93/14 156/2
ician [1] 153/21
politics [1] 100/16
poor [2] 81/12
152/24
population [1] 81/8
portfolio [4] 7/24
11/9 38/12 90/12
portfolios [3] 8/25
11/5 17/13
position [19] 6/12
13/17 19/17 26/20
44/21 65/2 68/1 68/6
69/10 72/20 73/6 83/4
91/4 94/16 95/12
119/17 121/9 122/6
130/4
positioning [2] 134/3
134/8
positions [2] 2/3 2/9
positive [5] 10/9
112/4 112/19 122/3
137/14
possibilities [1]
144/13
possibility [2] 50/1
114/12
possible [10] 22/25
23/19 53/24 56/16

E-]

98/10 112/14 119/6
124/22 130/3 161/4
post [230]
postal [6] 2/21 7/8
7/25 10/16 59/8 89/11
postmaster [1] 79/9
postmasters [5] 27/2
62/3 63/17 101/25
138/22
potentially [3] 44/12
152/11 152/13
PowerPoint [1] 103/1
powers [3] 58/21
61/18 117/15
PPS [1] 8/23
PR [2] 56/23 120/20
practice [2] 65/13
154/10
pre [1] 92/12
pre-brief [1] 92/12
precisely [1] 155/23
prefer [1] 25/2
preferably [1] 25/3
preferential [1] 110/5I
prejudices [2] 44/13
44/23
prejudicing [2] 44/19
46/17
Premium [1] 37/12
preparation [1]
141/23
prepare [2] 25/3 92/9
prepared [1] 12/15
preparing [4] 24/5
78/4 137/11 146/16
presence [1] 45/17
present [4] 47/2
99/10 111/13 112/2
presentation [1]
111/17
presented [1] 48/2
preserve [3] 27/17
40/10 135/10
preserved [1] 9/23
press [2] 23/3 23/17
pressing [1] 105/20
pressure [1] 83/1
presumably [5]
22/12 43/21 56/22
78/14 120/22
prevailed [1] 85/11
prevent [2] 23/10
153/18
prevented [1] 160/4
prevents [1] 68/10
previous [2] 152/4
160/10
previously [2] 51/6
101/24
Prime [10] 2/4 41/10
46/25 67/18 67/25
68/15 68/22 69/7
69/14 92/18
priming [1] 94/15

principal [5] 12/2
21/3 52/20 54/7 129/3I
principally [1] 3/19
principle [2] 20/20
25/24
print [1] 8/20
prior [3] 7/22 63/5
135/3
priority [2] 68/8
116/10
private [59] 2/3 2/9
5/17 8/13 8/14 8/20
9/3 9/4 9/8 9/17 9/22
12/4 27/22 28/2 28/6
28/16 28/18 29/6
29/10 30/14 34/19
40/21 40/22 40/25
41/18 41/21 41/22
42/7 43/8 43/23 44/15
49/15 51/16 68/13
71/18 72/6 84/12 87/4I
87/7 93/12 95/20
96/22 97/8 97/23 98/5
99/8 114/18 114/25
117/21 118/22 120/1
120/6 134/5 134/14
134/20 147/5 158/21
161/13 162/9
privatisation [3]
31/15 32/1 83/14
privatised [1] 32/7
privilege [7] 132/3
132/10 132/11 133/22)
135/11 136/9 136/14
privileged [2] 132/12
132/13
pro [1] 137/23
proactive [1] 23/14
probably [27] 8/4
13/18 16/9 27/20
41/24 47/10 62/12
64/20 65/21 66/23
69/20 84/3 88/24 90/8I
100/8 103/19 105/9
107/15 114/15 115/12)
120/7 127/3 129/18
135/12 148/4 148/14
149/16
probe [1] 151/20
probing [1] 151/19
problem [19] 6/1
16/11 21/17 38/18
83/12 84/13 87/9
95/19 116/6 116/8
126/19 126/25 137/18)
143/25 150/25 153/11
155/11 155/13 157/25}
problematic [1]
10/18
problems [25] 8/1
9/14 9/21 10/13 15/8
15/16 19/4 27/8 39/1
51/17 52/7 58/20
63/10 63/10 66/21

(

(61) people... - problemsO
Pp

problems... [10]
78/25 81/22 81/23
81/25 88/15 149/19
150/16 150/21 151/9
160/2
procedural [1]
109/22
procedure [2] 62/3
62/25
proceedings [1]
139/8
process [10] 23/1
48/7 51/5 59/11 106/9)
110/11 110/13 110/15}
118/13 138/23
processes [7] 53/6
59/10 127/23 130/9
142/20 142/22 153/25
procurement [1]
76/4
produce [1] 69/4
produced [3] 34/11
70/15 117/13
producing [2] 19/8
52/20
productive [1] 48/5
products [2] 37/16
81/20
profession [1] 84/14
professional [2]
109/21 110/18
profile [1] 120/3
profit [1] 77/20
programme [7] 13/4
13/25 36/17 37/18
38/1 38/7 105/20
programmes [1] 23/7
progress [7] 29/13
55/6 58/23 65/8 129/9
129/13 131/1
project [1] 146/5
prolong [2] 19/19
24/24
prolonged [1] 120/10
promise [1] 46/24
promised [1] 46/23
promote [1] 111/9
proper [8] 9/22 32/9
32/22 77/15 78/10
86/10 112/23 138/19
properly [8] 29/3
29/18 77/23 79/13
81/14 82/16 103/23
154/25
property [1] 90/10
prophetic [1] 62/6
proposal [2] 99/4
116/23
propose [4] 24/25
68/12 111/10 145/22
proposed [4] 35/24
42/19 43/13 108/8

prosecute [1] 32/21
prosecuted [6] 6/6
27/13 29/23 34/17
65/20 137/22
prosecuting [5]
31/18 32/18 32/19
33/21 34/8
prosecution [11]
28/16 28/18 29/16
29/22 30/15 31/16
31/25 34/21 58/22
61/18 160/3
prosecutions [21]
20/7 27/19 27/22
29/10 29/13 30/25
31/8 31/14 32/5 32/13
34/14 34/19 34/24
35/2 54/8 77/25
112/11 128/14 138/16)
138/18 159/19
prosecutor [1] 29/2
prosecutor’ [1]
138/21
prosecutorial [1]
28/2
prosecutors [1]
137/21
protocol [2] 69/17
69/19
provide [15] 40/14
49/10 64/7 67/11
68/11 73/9 84/15
87/23 91/15 91/18
96/22 97/2 131/25
132/6 133/19
provided [15] 3/19
18/11 38/22 39/9
77/22 101/3 127/8
128/15 131/9 135/10
138/12 139/11 140/6
140/7 143/10
providers [2] 149/13
149/14
provides [1] 114/8
providing [1] 56/24
provision [1] 69/25
public [14] 20/2 28/5
39/17 89/3 104/18
121/4 146/10 151/24
153/23 159/3 159/10
159/10 160/2 162/20
publicity [2] 30/19
107/12
publicly [1] 22/19
published [2] 15/5
15/6
pulled [1] 151/18
purpose [5] 10/24
16/22 67/6 71/8 94/22
purposes [1] 97/18
pursuant [1] 141/20
pursue [2] 31/13
53/4
pursued [1] 21/9

pushed [1] 87/24
put [17] 7/19 8/4 8/21
19/2 28/13 40/2 46/1
50/6 68/8 93/23 103/5
111/22 115/24 137/14]
147/22 161/14 162/10
puzzled [1] 70/9

Q

QC [13] 84/11 101/17
104/1 105/7 108/22
109/4 111/10 111/15
111/16 111/24 112/1
112/23 125/19
qualifications [1]
107/3
quality [2] 82/11
143/12
quarterly [1] 131/18
Queen's [1] 108/18
queried [1] 28/3
question [11] 5/22
20/21 28/4 34/22 82/4
85/23 87/10 151/14
152/15 160/21 161/18
Questioned [8] 1/9
146/2 156/23 160/24
164/4 164/6 164/8
164/10
questioning [2]
149/17 149/18
questions [11] 1/11
41/11 94/20 103/11
145/21 145/21 145/24
157/6 160/22 161/16
163/3
quickly [2] 33/19
56/3
quid [1] 137/23
quite [46] 6/20 11/6
24/8 28/5 29/23 30/18
59/22 60/21 74/7 77/7
80/1 81/16 83/19 88/6
90/4 90/7 95/18 102/8
104/25 105/1 107/15
109/6 116/3 116/5
118/22 119/6 123/4
123/21 124/24 127/2
128/6 129/8 131/23
135/15 138/2 140/1
142/19 144/5 147/7
147/20 150/9 151/12
152/15 158/2 161/12
162/9
quo [2] 85/24 137/23
quote [1] 76/9
quoting [1] 91/12

R

raise [5] 44/16 49/6
73/8 124/9 144/7
raised [18] 7/8 7/10
12/22 18/10 49/3
52/18 59/1 61/15 62/9

73/9 81/10 95/4
105/22 111/7 116/8
124/4 125/16 135/25
raising [3] 11/3 88/15)
144/13
ran [1] 61/13
range [2] 7/24 128/25
ranging [1] 37/10
rapidly [2] 14/5 24/4
rates [1] 110/5
rather [17] 3/3 6/13
17/5 35/4 55/6 57/8
62/6 65/8 71/2 99/13
100/15 102/24 110/11
111/18 112/4 153/5
154/16
raw [1] 139/11
re [3] 56/11 56/19
56/21
reach [2] 40/11 115/9
reaches [1] 71/21
reaching [1] 68/11
react [1] 112/2
read [27] 16/4 21/22
23/13 23/23 73/11
74/1 74/21 74/22 75/4
75/19 75/23 76/5 76/6
76/24 77/1 77/5 77/8
78/15 81/2 96/6
115/19 129/8 132/17
134/12 137/3 139/13
160/11
reading [7] 70/23
75/11 78/21 86/24
86/25 95/9 140/13
reads [1] 146/14
real [2] 40/5 46/4
realise [3] 6/23 60/21
103/24
really [29] 6/1 6/23
24/17 68/20 68/23
79/7 79/13 79/16
81/13 81/13 81/18
81/19 84/13 85/1 85/8)
87/10 92/15 107/20
4117/7 119/5 120/11
140/1 142/9 147/14
149/7 151/2 161/4
161/9 162/23
reason [13] 28/25
34/7 37/2 45/1 46/15
55/10 62/10 74/14
74/22 76/9 91/20
116/9 147/24
reasonable [9] 80/23
109/17 122/14 123/6
127/25 128/6 130/11
142/12 143/23
reasonableness [1]
25/20
reasons [5] 4/15 34/8
43/21 69/1 93/6
reassure [2] 36/14
83/12

reassuring [3] 4/5
20/15 138/7
rebuttal [3] 70/24
74/4 75/24
recall [25] 59/3 65/10
65/20 66/3 75/5 78/7
83/1 95/15 101/16
102/1 103/19 103/25
1407/7 115/9 115/24
116/22 118/25 124/3
126/2 131/18 131/20
132/9 136/16 139/25
144/24
receipt [3] 4/23 4/25
7/22
receive [2] 74/18
125/24
received [11] 35/20
48/25 80/5 114/9
121/19 126/21 130/17
133/21 133/24 134/3
141/15
receiving [7] 26/1
66/9 80/20 86/25
96/20 142/1 160/5
recent [2] 24/8 70/10
recently [2] 28/12
51/10
reckless [1] 152/13
recognise [1] 106/12
recognised [3] 22/17
24/23 27/9
recognises [1]
105/25
recognising [1] 5/23
recollection [12]
37/7 62/5 84/10 88/11
97/5 103/7 110/21
124/11 125/1 127/3
143/21 149/20
recommend [5]
19/22 42/25 44/10
67/24 68/5
recommendation [4]
17/1 19/16 67/8
121/14
recommendations
[4] 17/8 129/3
135/20 135/21
recommended [2]
17/18 24/21
recommending [1]
43/7
recommends [1]
41/9
record [7] 101/13
104/5 124/3 142/1
153/23 153/25 154/6
recorded [2] 11/10
16/22
records [6] 14/18
58/15 144/1 146/20
147/10 147/15
recovering [1] 32/14

(62) problems... - recoveringO
R

recovery [1] 78/1

recruit [1] 155/1
red [2] 45/23 46/15
reduced [1] 159/23
Reducing [1] 61/23
refer [4] 73/22
125/12 126/14 139/1
reference [10] 58/12
79/2 86/1 95/11
110/22 128/1 134/16
136/5 136/11 138/9
references [1]
112/20
referendum [2]
134/24 150/7
referred [6] 39/18
41/1 63/4 90/14
139/23 140/3
referring [3] 8/5
29/19 101/21
refers [5] 94/22
111/15 127/7 136/18
138/24
reflect [2] 65/12
101/5
reflecting [1] 162/20
reflections [2] 143/8
157/4
refrain [3] 146/23
147/24 151/16
refused [2] 51/9 65/8
regard [4] 14/6
114/10 120/14 147/2
regarding [8] 37/25
39/6 66/9 72/11
105/17 105/23 127/21
152/10
registered [1] 102/21
regrettable [1] 55/9
regrettably [4] 51/7
52/10 101/12 124/1
regularly [1] 18/22
reinvestigated [1]
51/23
Reinvestigation [1]
20/1
reiterate [1] 67/10
reiterated [1] 119/9
reiterating [2] 51/25
64/10
related [1] 32/19
relates [1] 70/2
relating [4] 36/15
58/16 67/11 143/16
relation [4] 6/8 8/11
138/15 138/25
relations [1] 60/2
relationship [3]
47/23 85/17 122/4
relatively [3] 6/9
35/19 88/4
relayed [1] 42/7

relevant [2] 131/23
140/4
reliability [1] 14/14
reliable [1] 59/13
reliance [1] 4/5
relied [2] 21/4 152/14
rely [4] 15/13 15/14
25/19 25/25
relying [1] 25/21
remains [2] 36/18
73/4
remedies [1] 33/12
remedy [1] 33/19
remember [21] 16/10
27/5 33/6 37/13 46/1
50/7 54/23 63/7 64/16
77/4 88/3 88/17 88/25)
93/9 112/8 115/25
119/25 124/5 124/14
124/16 158/20
remembering [1]
46/9
remind [1] 112/16
remote [6] 53/24
53/25 63/16 77/18
124/20 138/11
repeat [1] 61/15
repeated [5] 7/17
20/3 41/10 46/24 78/9)
repeatedly [3] 73/6
82/24 124/23
repeating [2] 79/14
82/19
repeats [1] 153/7
repetition [1] 36/24
replies [2] 72/9 98/6
reply [11] 9/2 25/2
43/8 43/24 50/15
50/16 56/16 76/6
86/11 86/11 110/25
report [103] 4/24 5/3
15/5 15/6 15/10 15/10
15/15 15/22 18/8
18/10 19/8 19/9 31/2
31/4 70/1 70/8 70/21
71/9 71/11 71/14
727 73/12 73/21
74/16 74/18 75/4 75/8)
75/12 75/23 76/3 76/4
76/7 76/12 76/24 77/1
77/8 77/16 77/17 78/3
78/11 78/21 78/22
78/24 79/6 79/16
79/20 81/2 81/15
81/22 82/1 100/3
113/24 115/10 115/19)
115/24 116/17 116/19)
117/1 117/9 125/8
126/18 126/21 126/25)
129/5 129/6 129/20
130/4 130/20 130/24
131/2 131/10 131/14
131/19 132/1 132/6
132/17 132/20 133/8

133/9 133/11 133/22
134/3 134/5 134/9
135/9 135/20 137/5
137/9 137/10 138/7
138/8 139/11 139/13
139/24 140/2 140/5
140/6 140/11 141/7
145/15 149/11 160/9
160/12
Report' [1] 75/20
reported [3] 34/20
72/15 130/17
reported’ [1] 70/19
reporting [2] 133/25
134/6
reports [12] 61/24
70/13 70/14 70/14
70/16 70/23 72/11
72/13 76/8 79/12
117/13 154/24
represent [3] 157/1
161/23 162/10
representative [2]
22/17 89/8
representatives [2]
59/1 102/22
represented [1]
115/20
representing [1]
161/11
reputationally [1]
84/8
request [8] 17/15
96/23 97/1 99/9 99/18
100/6 131/25 141/23
requested [1] 128/21
requesting [1]
106/15
requests [2] 17/14
133/23
require [2] 73/10
112/3
required [1] 50/5
requirements [1]
109/22
reservations [1]
153/4
residual [3] 96/5
96/10 152/1
resist [2] 17/3 19/23
resistance [1] 119/19]
resolution [2] 68/11
83/20
resolve [7] 95/17
95/18 116/11 127/24
128/4 128/4 130/10
resolved [1] 105/18
resolving [3] 40/7
46/6 106/1
respect [4] 45/13
57/4 80/21 115/15
respectable [1] 6/5
respectful [1] 64/13
respectfully [1]

70/20

respecting [3] 46/11
49/13 107/14
respects [1] 148/13
respond [4] 17/5
25/5 25/9 56/3
response [10] 24/25
25/2 25/4 74/2 75/20
77/10 115/14 115/2
115/3 155/7
responsibility [5]
2/21 87/7 147/5 147/6
152/4

responsible [9]
11/18 48/16 52/6
62/14 87/8 88/10
89/11 89/20 161/5
responsibly [1]
106/15

rest [8] 16/2 16/14
29/12 65/9 120/4
129/2 135/1 159/12
restating [1] 53/8
result [3] 65/21 137/6
142/14

results [1] 114/13
retail [1] 37/11
retailer [1] 85/4
retain [3] 96/5 96/8
96/10

retained [1] 72/6
retirement [1] 59/21
retrospect [1] 85/21
return [1] 163/8
reveal [2] 52/16
54/10

revealed [3] 31/24
34/7 78/24

Revenue [1] 150/20
review [42] 4/2 5/14
20/16 20/16 21/20
34/5 44/24 88/9 101/9
101/18 104/2 106/25
108/12 108/18 109/9
119/8 124/8 124/10
125/19 125/25 126/22,
127/10 127/14 127/19}
127/20 130/7 130/20
130/24 131/14 133/4
133/5 134/6 135/9
136/9 136/13 137/25
141/17 141/21 142/6
142/11 142/18 143/21
review's [1] 135/7
reviewed [1] 51/23
reviewing [2] 27/14
32/23

revised [1] 98/2
Richard [9] 85/20
86/2 92/1 93/10 96/6
98/17 98/25 148/6
155/19

Ridkin [4] 24/7

right [65] 2/1 2/12

2/22 3/8 3/15 3/18
6/10 7/7 7/10 7/11 8/1
8/19 10/22 10/23 12/2I
16/6 23/16 25/23 26/2)
33/3 35/15 41/2 41/23
43/20 58/1 60/9 69/23
71/19 82/2 84/17
88/15 95/24 97/17
99/11 99/12 102/25
111/21 112/17 117/17)
120/8 124/24 125/5
128/11 128/19 142/3
142/4 147/12 147/21
148/20 149/2 149/25
150/20 151/6 152/9
152/15 152/17 152/19}
153/3 157/17 159/9
159/25 160/5 160/14
162/25 163/7
rightly [5] 84/5 97/9
128/11 141/10 154/15)
rigorous [1] 38/18
ringing [1] 92/6
risk [14] 30/4 30/5
44/11 44/17 44/18
45/21 48/2 65/2
118/10 118/12 119/2
122/15 133/21 159/18)
risks [2] 122/12
122/19

road [1] 60/20
Robert [1] 144/16
robust [6] 23/8 23/14
64/13 122/21 147/25
151/17

rocky [1] 92/22
Rodric [1] 108/3
rogue [1] 152/11

role [13] 24/13 59/8
66/19 67/3 82/17
91/15 98/20 105/16
106/16 111/15 152/2
152/21 153/12

roles [1] 2/15

Rolfe [21] 1/5 1/8
1/13 8/10 8/15 12/5
22/15 56/5 56/15
57/24 78/20 90/22
94/9 99/2 113/16
136/7 145/20 146/3
148/3 148/8 164/2
Rolfe's [3] 41/7 91/4
113/6

Ron [3] 72/10 113/22
115/3

room [2] 47/21
124/14

Ross [1] 114/7

rosy [2] 129/20
129/24

round [5] 28/24 69/5
82/12 100/16 103/16
rounded [2] 142/7
142/19

(63) recovery - roundedO
R

route [2] 80/11
105/10

routinely [2] 7/17
29/17

rows [1] 121/4
Royal [1] 28/11
RSPCA [1] 27/24
rule [1] 13/23

run [5] 14/4 42/17
90/18 113/18 123/6
run-up [1] 90/18
running [4] 13/14
62/21 105/5 105/6
rural [1] 81/12
Russell [4] 87/12
144/3 144/15 144/19

Ss

sadly [2] 91/21 133/3
said [56] 10/4 12/1
14/8 15/13 18/25
22/19 24/15 29/5 32/9
34/17 42/18 44/17
48/2 54/8 56/10 57/1
62/6 65/12 69/3 75/14
76/15 78/7 81/7 88/20
101/16 102/19 113/1
115/8 116/12 117/4
117/6 119/8 120/12
122/12 124/23 129/14}
131/16 132/2 134/7
135/10 136/15 136/22
141/6 141/23 142/10
145/14 146/4 152/3
153/14 156/4 157/7
157/8 158/15 159/22
161/2 161/7
Sajid [1] 88/12
sale [1] 83/18
same [14] 21/24
27/24 42/24 44/5 49/7
49/19 72/1 77/7 82/19
85/5 86/12 103/20
146/22 161/23
Samsonite [1]
104/16
sat [3] 29/20 30/23
89/13
satisfactorily [1]
59/11
satisfactory [3] 6/21
42/12 128/18
satisfied [1] 138/19
satisfies [1] 138/20
saw [20] 24/13 34/13
35/9 36/24 57/7 73/14,
73/15 74/19 78/4
86/14 86/23 95/13
109/9 119/10 121/1
123/8 123/16 137/5
141/22 142/4
say [65] 3/12 10/11

12/13 14/11 24/10
28/24 31/1 37/23
38/21 39/23 40/9
44/23 45/5 47/9 47/19
47/22 49/1 49/24 50/8)
50/11 50/12 58/7
58/14 59/6 60/11
74/10 75/17 76/1
79/17 82/7 82/10
85/16 91/8 91/13 92/7,
95/15 96/17 101/6
101/11 101/15 101/22)
103/18 105/1 105/14
108/17 108/24 109/8
110/22 117/11 119/7
121/2 122/10 123/24
125/15 136/17 138/5
141/22 143/8 143/11
149/10 149/16 153/22)
156/1 159/1 162/16
saying [23] 42/24
43/5 44/3 45/2 62/11
69/10 74/9 74/10 75/6
76/5 86/12 95/21 97/1
97/17 109/13 115/10
123/8 131/19 131/21
137/18 153/3 158/14
160/9
says [30] 8/23 12/20
36/7 40/23 44/6 52/18
55/12 56/19 61/7
64/24 67/6 67/22 70/8
87/6 95/16 99/5 108/5)
113/23 114/18 117/22)
127/8 128/12 128/20
132/10 136/6 136/11
141/14 147/4 148/12
155/15
scale [1] 11/17
scandal [1] 157/3
scandalous [2] 139/9)
143/2
scenes [2] 56/24
76/19
scepticism [2]
148/21 151/19
scheme [32] 13/1
14/18 16/2 16/24
18/14 18/24 19/3
19/11 19/22 23/2
23/10 23/18 23/24
36/15 36/21 39/17
40/1 40/10 48/22
48/25 50/25 51/11
51/20 52/18 53/2
54/25 58/23 61/22
63/21 72/15 79/8
106/2
scope [7] 61/23
411/11 111/16 127/14)
127/19 128/10 130/6
screen [5] 8/4 8/6
30/13 136/4 138/1
screens [1] 147/22

script [1] 61/15
scroll [26] 8/8 9/3
42/22 43/23 43/25
49/20 50/2 55/24 56/9
56/18 61/8 70/4 71/12
71/24 72/8 72/19
75/15 80/8 90/16
97/22 98/2 98/5 108/2
114/2 114/4 148/5
scrolling [3] 48/13
56/20 64/24
scrutinise [3] 82/16
91/17 106/3
scrutiny [8] 4/21
14/21 19/12 30/14
66/13 85/22 106/6
119/20
search [1] 65/4
seat [1] 160/10
Sec [2] 90/2 152/24
second [122] 2/8
4/24 15/2 15/5 18/6
19/7 19/21 20/5 35/9
42/10 42/11 42/18
42/25 43/6 43/13
43/16 44/3 44/9 44/15)
44/20 45/3 45/13
45/19 45/23 46/16
47/2 47/5 47/24 48/2
48/9 49/22 50/10
50/11 50/12 53/12
53/13 53/18 53/19
53/22 54/3 54/11
61/21 61/23 61/24
61/25 63/24 64/5 65/6
66/21 68/20 69/25
70/7 72/11 72/12 73/7
73/12 73/21 74/15
74/18 74/18 75/8
75/12 75/12 75/15
75/17 75/23 76/11
76/21 76/24 77/17
78/24 79/4 79/14
79/18 81/9 81/15
81/21 82/1 86/10
113/7 113/18 113/24
113/25 115/10 115/19}
115/19 116/8 116/17
116/19 116/23 116/25
117/8 117/11 118/9
118/17 118/19 119/1
119/2 119/8 119/10
119/14 120/9 121/5
121/12 121/16 121/21
121/23 122/1 122/5
122/11 122/19 122/22
123/1 123/7 125/8
130/16 138/17 145/15}
148/7 149/11 160/9
160/12
secondly [5] 11/9
17/2 26/6 31/24 37/5
secretaries [5] 8/14
87/5 89/13 134/20

144/22
secretary [44] 2/4
2/10 7/23 8/23 8/24
9/5 9/8 9/18 9/24
22/19 30/7 30/9 41/18
41/21 43/23 68/13
68/21 68/24 68/25
69/13 71/18 83/24
83/24 84/2 88/7 88/16
88/18 89/13 89/20
89/23 96/22 98/6
107/9 136/25 143/18
143/19 144/7 144/14
144/18 152/21 153/1
153/2 153/12 153/13
secretary's [1] 99/8
section [1] 138/18
sections [1] 59/13
sector [11] 2/9 5/18
28/6 28/6 84/12 93/12
104/18 120/1 158/21
159/3 162/20
secure [3] 5/20
106/22 138/23
Security [2] 30/1
31/2
see [71] 1/3 8/19 9/3
13/4 13/6 13/13 17/16}
17/16 21/15 25/22
35/24 37/13 38/13
38/21 40/10 40/23
41/4 43/9 44/5 45/4
47/14 47/17 49/20
56/1 56/9 57/20 64/19
67/4 70/5 71/17 71/21
71/25 72/8 81/25
85/13 86/2 87/13
91/11 91/20 94/11
94/22 94/24 97/24
99/5 101/10 108/6
113/14 113/21 114/2
115/4 115/20 119/8
119/14 120/9 120/11
121/5 123/7 126/11
127/6 127/19 132/17
133/6 133/13 137/8
138/6 142/2 144/6
147/17 148/7 156/2
162/5
seeing [6] 90/23
119/12 123/7 123/9
123/10 158/16
seek [6] 7/25 13/8
56/3 132/20 136/9
136/13
seeking [3] 16/24
123/17 134/5
seem [7] 47/3 101/23
128/5 148/25 149/1
155/25 159/17
seemed [30] 5/1 5/7
6/19 24/14 32/11
35/18 45/3 45/6 48/8
63/11 65/18 69/15

79/13 80/23 81/6
82/18 83/8 105/2
109/15 111/21 111/24)
112/25 117/2 118/4
119/23 119/24 137/1
137/17 145/13 152/13}
seemingly [2] 6/5
152/6
seems [9] 10/1 33/4
53/17 81/10 91/14
92/6 109/2 114/12
158/2
seen [11] 25/7 55/10
55/16 61/4 98/7
116/13 117/9 137/9
139/13 149/19 155/25]
selected [1] 162/12
self [2] 150/22
160/10
self-assessment [1]
150/22
selling [2] 37/15
81/20
send [11] 24/25
33/15 41/12 47/13
76/3 76/3 114/25
1415/2 126/5 147/11
152/25
sending [4] 41/22
72/1 135/3 135/6
sends [4] 43/23
68/12 114/3 114/5
senior [17] 48/6
84/24 95/7 95/9 96/2
96/21 96/24 97/2
98/13 98/18 99/2
99/15 99/19 105/7
108/23 140/7 144/21
sense [3] 16/15
17/25 60/15
sensible [8] 28/24
34/6 35/18 40/15
92/17 107/15 128/10
151/22
sent [19] 4/24 7/20
8/10 9/20 16/17 37/24
41/4 54/20 73/13 75/5
78/8 84/22 98/2 103/1
132/10 133/11 134/13}
141/25 155/4
sentence [5] 59/16
79/5 95/9 130/19
130/23
sentences [1] 134/4
separate [10] 6/17
16/15 19/10 46/13
94/2 96/11 96/13
96/14 107/18 116/9
separately [3] 86/5
129/4 132/2
separation [1] 84/1
September [4] 5/5
105/13 111/1 111/3
series [2] 18/21

(64) route - seriesO
Ss

series... [1] 93/11
serious [4] 49/9
74/11 138/13 146/5
seriously [6] 39/10
44/25 59/5 99/24
103/22 105/22
seriousness [4] 40/6
46/5 114/22 116/2
servant [13] 1/25 7/3
22/7 22/8 105/8
108/23 110/17 144/21
152/20 158/17 159/7
159/20 160/18
servants [13] 7/4
22/6 22/10 74/24
86/24 89/18 93/22
143/15 144/21 147/15)
152/23 158/5 159/12
servants/Civil [1]
158/5
serve [1] 24/24
served [2] 149/22
149/23
Service [19] 26/4
60/13 83/5 86/23 93/8
144/20 150/10 151/21
152/1 152/2 154/14
154/15 154/16 154/19
154/22 158/5 158/8
158/20 158/25
Services [1] 110/4
serving [1] 159/10
session [2] 16/16
73/24
set [14] 19/3 32/8
32/22 36/16 37/6 39/4
50/13 50/20 67/25
68/15 104/11 122/2
151/22 161/6
sets [4] 127/12
127/20 129/1 129/2
setting [2] 125/20
153/5
settle [1] 64/8
seven [1] 38/13
several [5] 19/25
72/16 145/14 146/17
150/11
shades [1] 22/2
share [2] 56/19 130/2
shared [1] 51/24
shareholder [12]
6/18 72/22 89/12
89/14 98/20 99/7
100/11 106/10 146/19
150/13 161/24 161/25}
shareholdings [1]
158/11
she [39] 6/19 6/22
9/6 9/10 12/1 31/4
36/8 38/24 45/19
53/19 54/16 54/20

54/20 55/19 56/12
56/25 57/2 57/10 65/2
85/19 92/14 98/10
99/1 102/14 102/15
103/10 103/10 117/21
118/7 120/19 120/21
134/19 134/21 140/20)
140/25 141/1 148/9
155/11 158/17
she'd [1] 9/20
she's [3] 44/2 54/16
148/8
sheer [1] 11/17
Sherpas [1] 92/19
ShEx [81] 3/20 4/22
5/1 5/6 6/11 11/20
12/2 13/16 15/19
18/21 21/11 21/25
24/21 36/1 38/14 39/9
40/1 43/2 43/7 43/24
44/2 44/14 46/20 63/6
66/10 66/14 78/6 79/3
82/9 82/14 83/2 83/11
83/19 84/19 85/8
85/21 85/25 87/14
87/17 87/24 89/21
91/15 91/22 91/24
93/9 93/16 95/21
95/24 96/14 96/21
96/21 96/24 97/2
98/19 99/3 99/10
99/15 99/19 99/23
100/5 101/3 107/5
107/13 114/25 119/13)
134/18 134/22 135/5
136/19 143/11 143/12)
144/15 144/16 145/5
148/1 154/21 157/9
157/18 158/4 159/12
162/14
ShEx's [7] 4/18 40/16
67/4 82/12 119/16
121/9 126/15
shipped [1] 21/19
shoe [1] 85/7
shoplifters [2] 29/23
34/18
short [12] 6/9 25/3
53/2 57/18 68/12 88/6
94/7 97/24 113/12
115/2 139/9 156/17
should [68] 13/25
17/2 17/5 19/17 19/23
23/12 25/10 28/4
31/14 31/16 35/12
35/17 38/19 42/10
42/13 42/19 43/6
53/13 53/18 56/3 56/4
56/5 56/13 56/15
56/25 66/15 67/18
67/24 68/6 68/8 68/15
69/9 73/18 78/15
78/16 79/15 80/21
81/5 82/23 82/25

92/15 98/15 100/15

101/18 102/19 106/25

108/22 115/1 115/17
118/21 118/22 119/12
119/12 119/14 120/6
121/21 122/18 122/25)
123/7 128/13 130/2
138/22 139/4 140/2
141/17 141/21 145/16}
159/4
should’ [1] 39/3
shoulders [1] 112/6
shouldn't [5] 8/15
45/3 55/19 93/7
120/11
show [4] 23/6 123/9
144/8 144/9
showed [2] 92/23
144/4
shown [5] 52/1 87/16
91/8 91/9 144/10
shows [1] 145/1
shred [1] 66/2
shredded [1] 65/19
shredding [1] 65/24
shut [2] 82/20 143/13}
sic [2] 24/7 138/10
side [6] 8/5 13/6
14/18 101/8 103/7
121/22
sided [3] 62/17 62/19
63/2
sides [3] 5/24 14/15
50/14
sift [2] 23/25 144/23
sight [98] 4/24 15/3
18/6 19/7 19/21 42/10}
42/12 42/19 43/6
43/13 43/16 44/3 44/9
44/15 44/20 45/3
45/23 46/16 47/2 47/5
47/24 48/2 48/9 49/22
50/10 50/11 50/12
53/12 53/13 53/18
53/19 53/22 54/3
54/11 61/24 61/25
63/24 64/5 66/22
69/25 70/15 73/8
73/12 73/21 74/15
74/18 75/8 75/12
75/23 76/11 76/21
77/17 79/4 79/14
79/18 81/9 81/15
81/21 82/1 86/10
113/7 113/18 113/25
115/19 116/8 116/17
116/19 116/23 116/25}
117/9 117/11 118/9
118/17 118/19 119/1
119/2 119/9 119/11
119/15 120/9 121/6
121/12 121/16 121/21
121/23 122/1 122/5
122/11 122/19 122/22)

123/1 123/7 125/8
141/13 145/15 149/11
160/9 160/12

61/21 61/23 70/7
72/11 72/13 76/24
115/10
sign [1] 69/6
signature [1] 1/17
signed [1] 1/21
significant [5] 19/21
44/12 44/17 122/12
122/20
signing [1] 107/10
silent [2] 49/22 50/1
silk [1] 112/20
similar [7] 49/16
49/20 62/8 101/17
108/19 133/23 161/12
Similarly [1] 138/24
simple [1] 65/4
simply [3] 10/25
112/19 136/11
since [11] 18/13 36/4
38/22 51/8 55/16 95/2,
120/9 121/19 122/7
133/8 140/4
single [1] 99/23
sins [1] 132/19
sir [24] 1/3 17/10
25/12 34/22 57/13
57/16 57/20 67/17
67/24 94/2 94/11
109/13 113/3 113/14
121/13 125/4 154/6
156/14 160/24 161/18}
162/24 163/8 163/15
164/10
Sir Alan [2] 17/10
25/12
Sir Anthony [3]
67/17 67/24 121/13
Sir Jonathan [1]
125/4
Sir Wyn [4] 34/22
154/6 161/18 162/24
sit [4] 11/1 53/3
89/14 162/12
sitting [3] 24/12
32/15 160/10
situation [7] 40/7
46/6 46/14 68/1 68/16)
118/11 119/4
six [3] 10/21 16/20
31/6
skills [1] 110/1
skip [2] 85/15 128/23
skipping [7] 42/6
52/14 52/22 59/6
75/13 101/15 128/20
slide [6] 13/4 13/5
13/7 14/16 14/17 16/2)
slight [2] 32/16 32/16
slightly [16] 6/16

Sight's [9] 15/5 45/13}

16/12 20/21 29/6
55/20 76/13 83/16
92/22 93/5 103/6
111/15 126/24 129/20)
129/23 148/16 148/16
slipping [1] 33/9
slips [1] 33/6
slot [1] 91/3
slotted [1] 86/8
small [7] 12/21 14/25
37/4 51/15 60/21
62/21 81/12
Smith [7] 9/4 41/21
42/23 71/18 71/24
72/9 117/21
smokescreen [1]
63/21
snap [1] 47/11
so [177]
social [2] 162/1
162/20
society [1] 27/4
software [3] 71/2
127/12 128/14
sole [1] 106/10
solicitor [2] 66/2
109/24
solid [1] 152/6
solution [4] 83/15
104/12 104/12 125/3
some [84] 4/16 5/20
6/3 7/9 8/19 10/3 10/7I
10/8 11/5 12/7 15/18
18/11 18/16 21/18
23/5 24/10 27/14
27/16 32/12 33/15
37/12 37/16 39/24
48/11 51/1 51/6 52/7
53/22 54/4 54/5 55/6
58/16 60/5 60/19
61/16 62/24 62/25
65/16 65/22 66/13
67/11 70/2 70/21
70/22 71/15 74/22
76/9 76/20 77/11
77/18 77/25 78/7
81/22 82/22 83/25
84/20 93/8 93/25
102/25 103/2 105/19
106/5 108/21 113/19
120/23 124/17 126/7
126/8 126/15 129/7
129/11 130/23 131/8
131/22 139/23 140/1
144/3 149/20 151/25
153/4 153/8 155/7
157/5 158/15
somebody [22] 17/19}
44/2 55/17 69/12 74/5)
74/9 76/2 95/21 97/10
99/9 100/5 103/8
105/6 105/8 107/2
107/2 108/25 112/7
115/17 128/9 131/5

(65) series... - somebodyO
s
somebody... [1]
144/9
somehow [1] 120/23
someone [1] 97/6
something [34]
27/24 28/3 29/16
44/23 45/6 49/25
65/22 68/23 72/2 72/6
78/13 83/22 84/5 89/1
100/1 100/4 100/18
100/24 105/11 107/11
107/12 109/18 115/13}
117/14 121/3 125/9
132/3 134/9 136/21
144/25 147/2 147/14
159/19 159/25
sometimes [3] 85/2
162/20 162/21
somewhat [3] 3/10
42/9 57/7
somewhere [5] 46/18)
46/18 79/2 87/5 126/7)
soon [4] 104/3
109/12 118/22 130/3
sore [1] 105/6
sorry [7] 23/12 48/14
82/4 87/9 120/19
140/11 143/24
sort [55] 6/5 9/7
11/16 13/24 16/13
17/23 19/4 20/14
25/13 30/2 30/11
30/17 30/21 31/10
32/12 32/16 33/15
35/16 60/20 62/24
62/25 63/8 76/20 79/4
81/3 83/13 84/11
92/18 99/24 100/15
102/11 102/17 102/17)
104/24 105/2 107/22
111/25 121/3 123/4
123/8 126/9 129/14
131/5 131/20 133/9
133/10 135/14 136/23
149/19 153/6 153/8
154/8 154/11 154/24
162/11
sorted [2] 103/23
150/23
sought [5] 21/11
22/24 52/20 115/12
133/25
sounded [2] 6/21
28/13
sounds [1] 151/12
source [1] 85/6
sources [3] 123/21
157/19 160/20
space [1] 127/17
sparing [1] 109/3
Sparrow [2] 90/19
90/23

sparse [1] 123/21
speak [4] 51/1 56/5
56/13 56/15
speaking [5] 11/2
103/13 103/19 108/6
153/19
special [3] 84/23
92/13 99/16
specific [4] 71/15
124/13 128/16 139/4
specifically [5] 11/22
16/6 86/9 108/22
138/8
specify [1] 106/24
speed [2] 36/11
109/17
spend [1] 152/23
spirit [1] 18/1
spite [1] 137/18
split [2] 3/9 32/10
spoke [7] 56/12 95/2
99/1 104/10 105/3
131/14 131/15
spoken [3] 23/3
101/19 116/3
SS [1] 100/3
staff [7] 56/8 60/16
94/15 96/9 128/25
146/20 147/9
stage [14] 2/8 3/15
4/4 4/7 4/17 5/5 25/8
37/13 48/9 82/8 96/20)
126/7 135/12 135/18
stages [2] 3/9 3/11
stake [1] 161/13
stakeholders [1]
122/13
stance [1] 23/16
stand [4] 25/20 45/6
65/15 152/6
stand-off [1] 65/15
standard [2] 65/13
76/6
standing [1] 53/14
start [16] 3/6 7/5
40/20 59/12 70/3 82/6
83/19 91/12 109/12
113/18 133/14 145/25)
150/24 151/1 163/11
163/14
started [2] 60/19
104/19
starter [1] 108/6
starting [1] 134/24
state [15] 7/23 8/23
8/24 17/24 68/21
68/24 83/24 84/3 88/7
107/9 131/11 136/25
143/18 143/19 153/12)
State's [2] 9/24 68/25)
stated [8] 38/6 38/24
39/14 71/9 73/6
108/16 114/14 128/1
statement [52] 1/14

1/19 3/3 3/12 7/14
7/16 8/5 12/14 14/8
14/11 15/14 15/21
20/13 20/22 25/19
27/15 28/4 31/12
37/20 47/18 58/5
58/13 66/7 70/19 73/2
76/25 80/4 82/3 82/6
87/16 91/6 96/15
97/21 99/21 101/1
103/18 113/25 123/12
123/22 125/10 136/3
137/4 138/3 141/11
143/7 146/13 146/17
146/24 161/2 161/7
163/2 163/4
statements [4] 18/21
71/22 153/17 153/20
states [1] 72/12
stating [1] 155/9
statistics [1] 76/4
status [3] 85/24
134/2 134/8
Statute [1] 63/22
Stay [4] 74/13
stealing [1] 52/12
steer [1] 98/21
step [4] 59/9 69/23
87/21 120/12
steps [9] 42/4 65/22
67/7 87/19 91/18
106/18 129/24 139/15}
156/1
stiffen [1] 116/11
still [7] 44/10 56/4
72/6 98/18 99/2
114/15 116/20
stones [1] 85/6
stop [5] 32/18 32/19
114/17 119/12 119/12
stopped [6] 33/16
33/17 33/18 33/21
34/8 135/13
stopped’ [1] 141/21
stopping [1] 9/16
store [2] 33/13 35/2
stores [2] 10/9 33/7
Storey [1] 158/16
story [4] 65/9 101/8
121/22 126/10
straight [3] 21/19
33/13 117/5
strategic [2] 57/8
159/16
strategy [2] 36/12
145/9
strength [1] 105/2
striking [2] 39/18
146/13
strong [7] 19/16
21/10 21/16 24/15
104/17 107/21 141/15}
stronger [1] 122/9
strongly [14] 42/9

42/18 42/25 43/6 43/7)
44/10 45/17 46/20
68/5 79/25 100/10
120/19 120/22 139/2
structure [3] 26/17
83/16 89/10

stuck [1] 76/17

stuff [8] 31/10 103/2
117/10 137/20 139/23
142/11 144/2 149/11
subject [11] 12/4
16/13 23/7 23/25
26/24 51/12 70/7
83/20 90/18 109/22
147/1

submission [12]
16/17 16/19 25/21
37/24 38/4 41/4 41/9
41/20 42/3 42/14
86/10 145/16
submissions [2] 9/25}
123/4
subpostmaster [3]
62/13 62/23 81/12
subpostmaster's [4]
20/10 20/23 21/1 54/3
subpostmasters [28]
12/22 15/1 17/22
18/12 18/15 18/19
20/7 20/17 22/18 23/5
27/10 27/13 38/9
39/24 40/12 51/17
52/9 52/11 71/3 77/22,
127/11 127/21 130/14}
130/16 135/18 141/3
148/11 157/2
subpostmasters'’ [2]
22/22 155/20
subpostmistresses
[1] 157/3
subsequent [1]

156/3

subsequently [3]
48/10 57/7 62/7
substance [7] 18/3
27/7 69/18 69/19
99/18 124/5 126/24
substantive [1] 12/18}
success [1] 5/11
successful [3] 31/8
106/11 120/3
such [8] 72/24
106/13 108/23 138/20
146/17 150/9 155/1
160/2
suddenly [3] 59/25
60/3 133/6
suffer [1] 51/20
suffered [1] 150/16
sufficient [1] 158/14
suggest [9] 39/5 52/3}
56/16 101/23 122/23
134/4 140/16 152/12
163/10

suggested [9] 3/20
20/13 26/20 81/22
105/8 108/20 118/21
125/17 134/14

suggestion [8] 54/18
60/1 68/14 69/2
108/17 111/25 140/9
152/10

suggestions [2]
53/12 105/24

suggests [1] 35/3

suitability [1] 110/14

suitable [1] 80/11

sum [1] 153/12

summarisation [1]
70/10

summarise [2] 25/22
78/12

summarised [4]
70/14 79/22 80/1
142/7

summarises [3] 78/4
78/5 140/13

summarising [2]
109/7 109/25

summary [18] 3/6 3/7I

4/1 5/2 12/19 13/14
72/12 77/17 111/20
116/21 129/20 132/18)
132/18 135/6 138/2
138/7 140/7 140/15

summer [1] 90/9

Sunday [1] 114/38

super [1] 161/20

super-charged [1]
161/20

support [16] 18/12
20/10 20/23 21/1
22/18 27/10 52/9
60/17 81/19 96/22
96/23 97/3 99/18
128/15 151/2 162/15

supported [4] 14/7
27/9 88/11 143/22

supporter [1] 160/25

supporting [1]
102/12

supportive [2] 36/23
65/2

suppose [6] 24/13
54/16 77/4 95/16
149/15 150/11

supposed [1] 66/10

sure [40] 7/14 26/21
29/17 32/23 33/25
34/25 43/11 57/5
59/22 65/12 68/19
68/22 69/3 73/14
73/20 77/15 84/15
85/10 85/12 88/8
88/19 97/12 100/24
106/11 112/17 113/9
115/6 128/9 132/14
139/15 139/18 142/23}

(66) somebody... - sureO
Ss

sure... [8] 147/20
149/13 153/14 154/24)
156/19 158/10 158/19
159/8
surprise [1] 92/10
surprised [3] 59/12
139/6 142/19
surprising [2] 143/2
147/7
surreptitious [1] 96/3)
surrounding [1]
105/17
survive [1] 156/18
surviving [1] 37/1
Susannah [1] 158/16
suspect [2] 100/7
123/2
suspecting [1]
148/20
suspense [1] 62/3
suspicion [1] 148/19
sustainable [1]
106/12
Swannell [1] 144/16
Swift [26] 77/16 78/3
81/2 109/9 109/14
125/4 126/18 126/21
127/10 129/20 131/9
133/21 136/9 136/13
137/5 137/9 137/25
138/7 138/10 139/11
140/10 140/11 1441/7
142/6 142/11 142/18
Swift's [2] 139/7
139/24
swiftly [1] 23/18
sworn [2] 1/8 164/2
sympathetically [1]
124/4
sympathy [1] 117/15
system [43] 8/1 9/14
10/14 12/23 14/4
14/17 14/21 15/1 15/3}
15/8 15/16 16/24 18/7
18/25 27/8 32/22 33/7I
33/12 36/16 36/19
41/6 51/19 52/1 53/21
53/24 70/18 70/25
71/5 72/14 74/17
81/18 85/5 104/23
105/18 105/23 106/4
116/21 117/4 127/12
128/14 149/10 160/4
161/6
system' [1] 73/4
system's [1] 116/22
system-wide [2] 15/8)
15/16
systematic [1] 117/3
systemic [25] 3/24
6/1 12/25 14/21 15/3
18/7 18/9 19/13 20/4

27/8 36/19 38/18
51/20 70/17 71/4
72/13 73/3 74/16
78/25 79/5 81/23
114/1 114/15 126/18
126/25

systems [5] 148/24
149/2 149/4 149/9
150/17

T
table [1] 35/16
tactic [1] 138/25
take [32] 5/13 5/17
8/15 16/4 29/17 31/19
32/6 33/14 44/24 49/5)
68/7 78/20 80/13 84/6
87/19 92/11 95/23
101/4 104/7 106/18
107/20 109/18 111/6
118/23 120/13 126/10)
137/12 139/15 146/1
151/20 160/16 162/13)
taken [15] 15/18 41/8
51/13 59/4 77/20
103/22 116/2 119/17
120/15 136/8 136/12
139/10 141/18 145/2
156/1
takes [3] 69/5 81/16
105/22
taking [15] 10/21
11/9 23/7 23/8 33/10
34/24 44/5 46/13
46/20 59/8 91/18 99/6
105/15 128/10 157/19)
talented [1] 109/15
talk [14] 30/2 45/5
47/1 65/14 67/2 73/20
92/19 107/21 120/21
120/24 125/3 129/7
150/12 157/12
talked [1] 79/24
talking [4] 30/17
34/16 60/22 157/15
target [1] 63/16
task [1] 162/24
tasks [1] 162/5
taxpayers' [1] 145/10
tea [1] 104/24
team [4] 25/1 50/25
108/14 117/24
teams [1] 109/1
technical [1] 73/25
Telegraph [1] 114/8
tell [15] 1/11 27/14
31/11 39/11 48/10
66/7 76/25 80/4 101/2
102/23 112/12 123/12)
137/4 141/12 161/15
telling [5] 6/7 40/2
81/25 92/8 112/11
temptation [1]
163/13

ten [1] 108/6
tenable [1] 83/4
tend [2] 30/16 110/10
tended [1] 36/5
tends [1] 26/13
tens [1] 71/8
term [2] 36/11 152/7
terms [9] 45/14 49/16
49/21 62/8 77/14
127/25 159/10 159/16
160/5
terribly [1] 60/10
Tesco [11] 2/13
10/18 29/20 29/22
30/15 34/17 34/19
120/2 142/21 149/6
150/1
testify [1] 34/10
testing [1] 38/19
text [2] 9/17 14/23
than [27] 3/3 4/21
5/17 6/13 9/4 11/3
17/5 35/4 37/6 45/18
55/6 57/8 66/14 71/2
78/1 92/5 92/24 99/13)
100/15 102/24 110/11
111/18 112/4 126/24
129/23 153/5 154/16
thank [53] 1/4 1/5
1114 1/24 4/17 7/5
25/19 31/11 35/7 35/8
37/17 41/16 47/8
48/14 50/17 57/12
57/16 57/22 57/23
61/1 66/6 69/22 69/24
70/4 71/16 90/3 94/2
94/5 94/13 96/12 98/5
98/7 103/17 111/3
113/2 113/10 113/15
113/21 114/17 116/18}
143/6 144/11 145/20
155/6 156/11 156/12
156/22 160/22 160/23
162/25 163/4 163/6
163/15
thankfully [1] 52/10
thanks [1] 13/12
that [1066]
that I [5] 88/25 93/25
121/6 135/19 137/2
that's [69] 2/13 4/1
4/6 5/22 6/6 8/2 8/13
8/15 10/23 11/15
13/11 20/20 21/19
24/11 26/3 26/21
26/22 28/7 31/19
31/19 35/5 41/18
43/20 47/6 55/12
55/12 56/2 56/7 56/21
62/7 65/1 68/22 72/6
73/19 82/8 84/11 85/7
85/12 87/9 89/19 91/9
92/20 93/23 95/11
95/16 96/4 99/12

108/3 109/8 112/3
115/12 123/19 125/1
125/23 128/23 136/18}
137/25 140/21 142/4
144/20 144/21 145/21
148/8 150/25 152/15
155/11 156/5 158/14
160/21
theft [4] 20/8 60/5
137/24 139/1
their [67] 6/12 12/24
18/8 19/7 19/8 19/9
22/21 23/3 24/24
27/23 31/14 32/14
33/9 36/16 37/15
37/16 40/4 40/4 45/14)
45/17 45/21 46/3 46/3
46/11 47/1 49/6 51/18)
52/24 53/3 53/15
58/16 58/25 60/2
62/15 63/10 64/21
67/12 69/14 80/13
80/25 82/17 85/23
86/6 102/9 117/1
118/8 119/22 119/23
121/21 122/5 123/11
124/17 124/23 125/4
135/5 145/8 152/14
153/10 154/18 154/24}
154/24 156/6 157/23
157/24 159/15 162/2
162/24
them [77] 6/6 7/2
8/20 8/21 8/21 10/1
13/20 13/23 25/22
32/6 32/6 33/14 33/15)
33/15 34/20 42/13
44/9 45/5 45/24 46/8
47/1 49/17 53/11
57/11 62/12 64/20
65/15 76/15 77/7
77/22 77/25 79/21
79/24 81/20 89/15
91/21 92/6 92/8 95/21
102/6 102/7 102/8
103/8 112/14 112/16
118/23 119/7 119/13
119/15 119/25 121/1
123/8 123/8 123/9
123/10 123/11 124/7
124/8 124/9 125/3
125/18 128/24 134/22}
137/22 144/11 144/12)
150/23 151/23 152/19}
153/18 154/14 154/14}
154/23 154/23 160/8
162/10 162/23
thematically [1] 3/3
themes [2] 3/4
147/23
themselves [2] 29/1
60/1
then [132] 2/5 2/6 2/8
2/14 2/16 4/17 5/5

5/12 7/17 9/11 10/4
11/11 14/23 17/16
17/19 18/3 18/16
19/14 20/3 21/19
22/23 23/12 23/25
30/8 30/19 32/14
32/15 33/10 34/20
36/10 36/13 37/17
38/11 38/20 39/23
41/15 42/22 43/8
43/21 43/25 43/25
44/4 45/19 46/24
46/24 48/10 49/14
49/18 52/4 55/16 56/7)
56/9 56/18 56/20
56/20 61/13 62/1
62/17 63/18 65/6 69/4I
69/6 69/17 70/20
70/22 71/12 71/24
72/8 72/19 74/2 75/5
76/5 76/23 77/9 78/8
78/18 80/15 82/10
84/16 85/13 86/7
87/24 89/24 91/9
91/12 95/1 95/5 98/2
98/24 99/21 103/13
104/23 105/10 108/9
108/10 109/17 110/25)
112/23 113/17 114/4
114/4 114/17 116/16
1417/4 122/2 122/12
125/2 126/4 127/5
128/4 129/2 132/23
135/16 136/23 137/20}
140/5 142/14 143/24
148/6 148/12 150/3
150/4 150/5 150/6
150/7 150/24 152/24
153/10 154/5 156/17
156/21 160/13
theory [1] 100/9
there [152] 3/10 4/1
4/11 4/24 5/23 5/25
6/1 9/16 9/21 11/4
11/12 13/1 14/8 14/20
15/7 15/15 19/3 19/11
20/4 20/6 20/14 21/16I
21/17 21/18 22/21
23/5 23/23 24/8 24/10
27/7 27/121 31/17 32/3}
32/11 33/4 34/1 35/1
36/18 37/1 38/17
41/12 41/25 43/9 45/6)
48/1 53/12 53/20
55/18 57/9 58/20
59/16 60/7 60/21
62/24 62/25 65/2
65/16 65/17 65/18
69/9 69/17 69/17
69/19 70/13 70/17
71/4 72/2 72/2 77/13
79/2 79/5 79/6 79/11
80/17 81/3 81/9 81/22
81/23 81/24 83/14

(67) sure... - thereO
T

there... [72] 83/25
84/1 91/1 91/4 92/15
97/10 101/9 102/8
102/14 102/17 103/1
103/4 104/11 105/24
106/5 108/22 108/25
110/15 112/10 113/21
114/15 114/17 115/16}
116/6 116/14 117/3
120/12 122/12 124/15}
124/18 124/19 124/19
124/22 126/13 126/15}
128/5 129/4 130/11
130/23 131/4 131/7
131/13 132/24 133/1
133/2 133/21 135/15
137/16 137/17 137/18}
137/19 137/20 139/22
140/9 141/8 142/9
142/21 145/23 149/19)
150/19 151/13 152/20
152/25 153/7 153/8
153/15 153/24 154/10}
155/23 158/15 158/18)
159/11
there'd [5] 7/11 7/12
60/7 65/15 148/24
there's [22] 9/6 13/24)
18/16 21/16 24/25
28/25 32/16 40/20
42/14 44/17 49/25
54/18 75/6 75/16
86/24 92/7 92/20
111/24 116/6 133/14
138/2 142/20
therefore [21] 9/16
15/13 17/14 17/25
19/11 26/19 28/15
35/13 37/3 50/21
52/18 66/17 77/14
106/15 122/25 140/23}
141/19 142/5 143/20
150/15 161/6
these [55] 6/4 8/19
18/13 21/24 22/6
26/14 28/24 31/5 33/4,
34/4 36/11 38/15 45/7
50/19 52/23 53/6
59/20 60/19 60/23
63/9 64/16 73/22
74/25 79/11 79/25
81/9 81/15 81/16 83/2
85/5 85/7 86/14 88/21
91/11 92/25 93/14
102/11 102/25 112/10
116/16 117/13 118/15}
120/10 124/9 129/9
131/1 131/21 134/13
137/19 139/4 141/2
149/20 159/18 162/5
162/19
they [180]

they'd [15] 19/2
28/12 31/5 45/4 78/14
79/7 79/15 107/8
119/7 120/9 129/8
129/9 131/1 135/25
157/24

they're [17] 11/8 43/8)
44/16 58/9 68/3 74/10
93/11 93/13 93/21
109/6 122/2 134/19
144/17 144/18 144/19)
152/20 162/12

they've [4] 15/24
19/9 76/15 123/6
thing [40] 6/17 27/5
28/21 28/22 30/2
30/11 32/7 34/6 45/4
47/20 60/11 83/23
84/11 84/17 86/12
86/23 87/23 90/24
92/17 93/24 102/18
102/24 104/18 105/10)
108/20 108/24 112/17)
112/21 117/2 117/17
120/8 123/10 124/21
131/6 145/13 153/6
153/8 153/9 154/12
159/9
things [55] 5/17 11/4
13/25 14/4 15/24
22/10 27/1 31/5 33/5
35/16 54/13 54/14
59/9 62/22 66/22
74/23 76/12 79/6
79/17 79/21 81/3
81/15 92/20 100/2
102/9 103/3 104/10
104/16 107/12 109/7
109/10 112/15 116/12)
116/16 117/4 123/3
124/22 128/10 129/11
133/7 139/20 142/23
143/23 144/22 145/7
146/10 147/19 148/25)
151/1 151/22 158/6
158/11 158/12 161/3
162/1
think [208]
thinking [8] 59/3
59/19 60/15 62/19
133/7 134/19 154/6
161/16
thinks [4] 99/4
third [4] 17/9 20/3
48/24 148/14
thirdly [3] 2/16 17/4
26/10

this [278]

Thompson [36] 6/18
12/1 26/7 35/23 37/24
38/8 40/21 40/23
43/24 44/1 44/6 45/11
58/10 58/11 67/6
67/22 68/23 71/25

72/9 73/12 78/23 80/6
85/17 86/12 87/2
94/21 96/23 97/22
98/6 117/20 118/6
121/10 126/4 132/22
134/19 134/21
Thomson [3] 22/19
24/6 42/10
thorough [2] 26/2
109/4
those [43] 10/6 17/8
17/20 26/16 40/25
48/12 53/22 54/13
54/14 54/19 67/20
68/10 69/1 73/16
73/23 74/1 77/6 79/12
80/13 87/10 87/19
90/11 90/11 93/5
93/21 106/1 107/21
109/10 120/25 124/17
125/6 127/24 127/25
129/16 130/10 134/4
139/14 140/11 143/17)
145/18 145/25 153/19}
162/7
though [6] 38/2
65/16 82/16 82/20
90/13 153/4
thought [24] 24/7
44/22 47/24 48/3
90/24 100/4 101/17
102/24 105/1 107/20
112/18 116/12 117/13
118/25 119/5 128/10
129/12 135/14 143/1
145/18 148/9 148/18
150/11 153/8
thousands [1] 71/8
threads [1] 131/8
threatened [1] 103/6
threatening [1]
102/17
three [15] 5/5 39/1
51/13 51/14 60/22
70/14 88/21 99/4
106/5 126/1 131/21
147/10 150/6 158/22
158/23
three-hour [2]
158/22 158/23
through [41] 5/16 6/3
9/18 12/12 15/24
18/23 34/2 36/11
46/21 53/5 58/23
61/13 68/24 69/5
73/13 73/23 74/1
74/12 75/25 76/1 77/7
80/11 81/16 98/3
104/23 104/23 106/2
107/8 107/25 112/24
124/17 127/18 128/15}
131/24 133/23 137/8
138/23 141/18 144/23
160/12 162/8

throughout [2] 22/25
51/5
thrown [1] 10/3
Thursday [1] 90/23
tie [1] 57/5
tier [1] 154/11
Tim [28] 5/13 36/1
76/20 101/19 103/19
106/24 108/7 108/9
109/11 109/20 110/19}
110/25 114/7 118/16
118/23 119/7 122/8
124/8 124/9 125/3
125/17 132/15 133/15)
136/6 141/13 143/21
145/2 148/6
time [103] 3/7 3/15
5/17 6/9 15/9 19/12
20/3 20/12 20/24 21/7,
21/8 25/18 28/14 29/9
29/19 29/25 29/25
31/20 33/20 33/24
34/16 35/14 37/9
38/13 38/21 40/1
44/22 44/25 45/9 49/7)
51/1 53/20 53/23 54/6
54/19 54/23 56/22
58/17 58/22 60/23
61/4 62/13 63/3 64/19)
66/8 69/12 69/20 70/7
71/13 73/14 73/17
74/22 75/9 75/22 76/3,
78/6 79/12 80/23
82/11 82/19 88/19
90/1 90/2 91/1 91/11
92/4 92/16 93/15
95/15 97/9 100/13
101/5 104/6 104/21
107/9 107/10 107/23
112/5 112/10 115/19
115/23 116/20 120/3
126/3 126/3 126/10
129/15 131/9 132/5
134/12 134/23 134/25)
136/23 137/5 141/22
142/2 144/6 150/23
153/16 156/1 156/17
159/25 161/23
timed [1] 38/3
times [6] 2/15 36/5
64/15 85/23 96/12
145/14
timing [2] 55/22
94/24
tipping [1] 94/14
today [5] 24/5 41/11
61/11 90/22 163/3
together [10] 23/15
40/14 47/21 50/14
69/19 91/23 93/17
116/16 130/7 157/9
told [30] 5/25 13/16
23/21 24/6 37/2 37/5
37/8 42/14 44/23

47/19 54/24 60/8
78/23 80/24 81/23
85/12 88/3 88/4 101/7I
124/21 126/8 126/17
131/5 139/17 141/6
141/25 143/19 147/25)
148/1 151/16
Tom [2] 56/7 56/20
tomorrow [3] 91/1
163/8 163/10
tonality [1] 77/8
tone [1] 148/15
too [6] 79/10 85/21
91/5 128/4 137/18
157/18
took [30] 5/5 7/7
27/15 27/21 28/1
28/23 32/20 33/11
34/19 39/6 46/23 48/1
55/12 57/1 57/3 58/22
59/7 62/22 65/22
85/11 87/21 92/9 97/9I
104/2 104/3 118/2
118/7 137/13 157/4
159/15
tooth [1] 140/5
top [8] 22/13 43/9
74/21 76/14 77/14
87/12 98/24 148/6
TopCo [1] 89/14
topic [1] 94/3
total [1] 110/6
totality [4] 72/18
touched [1] 141/2
touches [1] 138/21
tough [1] 83/15
towards [3] 70/1
125/2 145/15
track [3] 37/3 37/20
99/23
trade [3] 17/19 17/23
17/24
trained [2] 66/1
162/8
training [6] 18/12
76/16 128/15 149/7
151/2 162/12
transactions [1] 54/2
transferred [1]
146/20
transformation [3]
36/12 37/10 145/7
transformational [2]
16/14 89/4
transformed [1] 14/5
transition [1] 10/8
transparency [2]
58/19 156/9
transparent [3] 40/3
46/2 51/4
travel [2] 91/20 101/6
travelling [1] 116/1
Treasury [4] 2/19
37/13 37/14 104/19

(68) there... - TreasuryO
T

tribunals [1] 30/25
tried [10] 5/11 13/19
84/20 88/25 89/1
137/21 139/18 147/19
151/20 151/20
trips [1] 33/6
trouble [1] 146/5
troubled [1] 5/1
troublesome [1] 4/13
troubling [4] 9/13
10/12 59/15 91/14
true [7] 1/19 1/21 4/6
26/9 26/13 92/18 96/4,
trust [5] 39/15 39/25
104/18 111/22 143/9
trustees [1] 83/16
truth [8] 84/19 88/17
153/16 153/21 154/4
154/5 155/22 156/9
truthful [1] 22/8
try [15] 17/17 17/19
26/24 50/13 53/8 57/4
74/12 85/11 91/23
93/17 93/22 112/17
120/7 154/3 157/10
trying [23] 6/2 13/20
24/4 24/8 43/12 44/16
50/13 51/15 82/20
83/12 93/1 93/2 93/19
97/7 102/9 102/18
117/16 119/22 121/2
143/13 153/14 157/11
159/22
Tuesday [7] 1/1 12/9
51/2 94/24 94/25
97/25 98/1
Tuesday's [1] 98/8
turn [20] 1/16 11/24
12/10 57/24 58/5 66/8)
77/9 82/3 82/5 96/11
96/14 100/25 103/17
113/6 113/17 113/20
123/20 127/5 138/12
141/10
turned [6] 11/13 47/6
55/5 81/1 83/17
131/22
turning [1] 66/17
turns [1] 78/13
twice [1] 90/8
twitching [1] 43/5
two [38] 4/17 12/24
14/20 17/8 19/11
32/10 35/21 50/14
64/16 67/5 68/18 69/1
69/25 70/8 70/13
70/16 71/11 71/14
75/18 75/19 76/7
76/24 77/17 84/22
88/21 92/25 97/12
107/12 130/13 131/21
132/14 134/4 135/15

137/17 140/5 142/13
147/4 148/13

tying [1] 55/8

type [1] 160/2

U

UKGI [3] 146/21
147/1 162/15
UKG1I00000026 [1]
50/16
UKGI00001067 [2]
80/7 94/19
UKGI00001074 [1]
35/22
UKGI00004415 [1]
11/25
UKGI00004416 [1]
12/10
UKGI00004453 [1]
16/18
UKGI00004820 [1]
48/12
UKGI00005133 [1]
70/3
UKGI00005195 [1]
97/19
UKGI00005261 [1]
90/16
UKGI00005300 [1]
113/20
UKGI00005504 [1]
75/13
UKGI00006138 [1]
111/1
UKGI00006142 [1]
117/19
UKGI00015226 [1]
67/5
UKGI00017443 [1]
155/3
UKGI00019859 [1]
147/22
ultimately [1] 153/19
Um [1] 132/25
unable [4] 82/15
101/12 124/2 143/9
unauthorised [1]
77/18
unaware [1] 81/4
uncertainty [2] 34/1
68/9
unclear [2] 73/7
136/23
under [10] 36/2
64/24 68/21 69/13
94/22 95/1 127/18
132/11 133/16 141/16)
Under-Secretary [2]
68/21 69/13
underlined [2] 15/7
39/2
undermine [1]
138/11
undermines [1]

133/10
undermining [2]
118/10 119/3
understand [25] 44/7
44/20 45/15 49/11
55/20 77/12 93/3
93/13 95/11 98/16
101/12 104/4 124/1
125/6 127/24 128/3
129/4 130/10 130/23
133/25 134/5 158/24
159/4 161/10 162/7
understandable [2]
86/6 109/8
understanding [8]
5/4 26/3 84/1 84/25
89/10 110/13 159/5
160/14
understands [1] 65/1
understood [3] 38/6
39/24 120/13
undertake [2] 5/14
130/1
undertaken [11] 4/21
19/10 108/13 108/18
127/9 127/14 130/12
134/1 134/7 141/16
141/20
Underwood [1] 108/4
uneasy [2] 43/10
43/20
unending [1] 21/23
unfair [1] 64/20
unfolding [1] 66/18
unfortunate [3] 65/19)
79/9 147/3
unfortunately [4]
50/20 79/1 123/21
124/14
unhappy [1] 143/20
unhelpful [1] 147/16
union [3] 17/19 17/24]
27/19
unique [1] 150/9
Unit [2] 2/4 2/6
unnamed [1] 61/16
unpleasant [1] 64/12
unprofessional’ [1]
121/24
unreasonable [3]
69/9 78/11 81/6
unrecorded [1]
143/25
unrelated [2] 126/16
126/16
unreliable [1] 116/25
unrestricted [1]
128/22
unsafe [5] 20/8 39/5
52/3 80/14 112/10
unsatisfactory [1]
60/24
unsigned [1] 141/13
unsuccessful [1]

31/8

unsuccessfully [1]
37/14

untenable [1] 153/20
until [12] 2/17 3/16
6/23 34/12 38/2 57/14)
60/18 75/4 94/3
132/23 150/1 163/18
untrue [4] 78/25 81/2
148/13 148/14
unusual [2] 147/12
147/13

unwelcome [1] 85/3
unwilling [2] 82/13
82/15

unwillingness [1]
85/23

up [80] 7/7 8/3 8/6
10/21 11/24 19/3
21/19 22/14 24/18
25/20 28/1 30/6 32/8
32/22 36/16 39/20
41/5 42/22 43/23
43/25 44/4 48/15
48/18 50/13 50/20
51/13 52/12 55/5 56/9
56/18 56/20 59/8 60/3
61/12 62/11 63/23
65/6 66/8 67/4 71/24
72/8 79/3 79/8 80/8
86/10 87/5 87/6 90/18
90/19 90/22 92/6 92/7,
93/9 98/2 100/9 104/2,
104/7 105/15 107/8
109/15 112/14 114/2
114/4 123/3 125/18
125/20 126/10 131/8
134/20 135/14 135/17,
137/1 140/11 141/11
147/22 151/6 153/5
158/4 161/6 162/16
update [3] 125/21
127/18 144/3

updates [4] 88/6 88/7I
125/24 143/24

upon [4] 7/22 77/23
152/14 153/15

us [28] 1/3 1/11 8/9
27/14 30/2 30/12
31/11 33/10 33/18
39/11 47/19 48/10
51/12 57/21 60/8 64/6
66/7 76/25 80/4 87/23
92/16 94/11 101/2
113/14 123/12 137/4
141/12 146/1
use [5] 9/18 37/15
37/20 68/2 84/10
used [6] 30/9 32/25
58/21 68/3 71/3
144/20
user [1] 72/18
users [3] 18/17 18/24
7118

ushered [1] 81/21
using [6] 18/19 35/4
41/21 61/18 63/16
63/21

usual [1] 78/9

Vv
valid [1] 57/6
validate [1] 153/16
valuable [2] 98/9
154/19
value [11] 20/2 48/1
55/13 57/1 57/3
152/24 161/3 162/1
162/20 162/21 162/21
values [2] 152/1
156/7
van [1] 61/7
various [13] 2/15
15/24 25/13 27/21
29/2 38/16 56/23
79/11 104/16 124/22
129/16 145/17 148/25)
variously [1] 2/18
vast [1] 18/19
Vennells [34] 35/14
36/3 38/23 39/4 41/14I
42/15 47/21 47/25
49/19 50/15 51/3
53/17 54/15 55/5
55/10 56/14 56/25
61/7 90/15 92/11
92/11 92/12 94/15
95/12 96/18 97/3
101/1 102/8 102/10
103/8 103/10 120/15
140/21 159/23
Vennells' [7] 56/7
90/21 92/2 96/7
118/18 120/7 120/13
verse [1] 55/18
version [1] 71/5
versus [1] 18/17
very [86] 1/4 4/15 5/2
5/2 6/12 6/21 8/6 10/4
10/18 20/20 21/10
21/16 22/2 22/4 24/14)
24/15 26/17 34/15
34/22 35/9 35/18
37/14 45/12 46/20
49/9 49/20 56/6 60/23)
62/17 64/12 64/25
65/23 65/25 78/3 78/5I
86/5 86/25 88/20 90/6I
92/17 93/9 94/13
98/11 99/23 105/3
107/13 109/2 109/12
109/15 110/21 113/10)
113/15 116/20 119/11
119/24 119/25 120/3
124/24 134/12 137/8
140/14 141/15 143/2
145/20 147/3 147/16
149/2 149/3 149/16

(69) tribunals - veryO
Vv

very... [17] 150/24
152/5 154/13 155/6
156/11 157/6 159/2
159/4 159/4 159/15
161/11 162/17 162/25)
163/1 163/1 163/4
163/15
vetting [1] 62/25
via [4] 34/21
victims [1] 148/11
view [28] 5/6 6/15
31/19 46/23 56/4
56/11 56/19 58/18
80/19 82/14 93/3 99/6
99/7 100/10 100/11
102/9 115/17 122/18
123/5 123/11 129/22
137/12 137/13 140/24
148/4 159/15 160/1
162/13
viewed [1] 80/23
views [11] 16/25
49/11 56/6 66/12 95/8
95/10 95/16 96/1
102/10 118/18 125/5
village [1] 27/6
visibility [1] 14/3
vision [1] 159/16
visiting [1] 145/8
visits [1] 14/2
vital [1] 145/11
vocal [1] 12/21
voices [1] 4/20
volatile [2] 64/14
64/16
volume [1] 109/20

Wo
wait [1] 100/15
waived [1] 23/3
wane [2] 4/19 66/12
want [23] 3/8 34/23
36/8 36/9 36/14 53/19
67/20 73/21 80/8
83/22 94/20 101/7
105/3 110/5 110/6
120/21 128/9 147/21
148/15 148/17 148/17)
155/19 158/1

wanted [36] 16/16
24/1 32/6 34/15 35/3
64/22 66/4 66/12
66/13 73/17 74/12
77/14 84/5 85/8 85/10
92/5 95/21 96/21 97/5)
100/16 100/17 100/22)
100/23 101/8 102/23
103/23 110/22 118/8
133/3 133/4 139/15
149/18 155/21 155/24}
157/14 160/14

wants [4] 49/5 99/2

106/10 155/12
Warmington [13]
48/11 70/8 72/10
72/11 75/17 77/2
113/22 114/3 115/3
115/7 115/9 122/24
123/25
Warmington's [2]
70/5 75/2
warmly [1] 56/16
warn [1] 119/14
warning [1] 91/18
Warren [1] 70/10
was [520]
wasn't [29] 5/10 5/25
11/10 25/18 34/12
62/10 63/4 68/19
69/10 76/11 77/13
79/5 80/2 85/4 88/5
96/2 102/25 103/4
107/22 112/19 124/19)
124/22 136/15 137/18)
142/9 143/5 145/12
151/18 160/15
watch [4] 102/19
way [36] 1/24 3/4
5/19 6/2 6/22 21/21
27/24 28/5 33/3 40/13
58/21 62/13 66/21
74/12 76/10 79/20
82/13 82/22 84/4
87/24 95/12 103/16
109/8 110/19 117/12
120/23 125/5 129/7
133/18 143/8 143/23
144/21 151/22 153/8
154/4 155/8
we [271]
we'd [7] 24/17 28/12
30/21 46/23 120/3
136/24 149/19
we'll [7] 21/15 43/16
43/21 44/5 70/4
135/13 156/13
we're [12] 16/18
16/21 21/22 30/17
47/16 70/12 88/20
88/22 94/2 112/8
123/9 145/1
we've [13] 31/7 31/8
43/4 86/4 86/4 87/3
87/9 88/21 139/19
145/4 147/19 155/14
155/16
Wechsler [2] 56/7
56/20
Wednesday [3] 50/20
67/7 163/10
week [5] 12/9 51/10
95/2 111/5 133/17
weekend's [1] 114/8
weeks [3] 38/13
93/25 116/15
weight [1] 112/6

well [64] 12/14 15/25
17/7 26/25 30/20 31/5
32/2 54/24 55/17
62/10 68/18 69/18
73/14 75/6 75/20 77/5
78/3 78/5 80/1 80/21
80/22 80/22 83/11
86/2 86/22 87/21
88/20 89/19 89/22
92/7 93/2 93/19 95/14
100/10 102/14 103/10
105/9 111/19 116/6
116/12 116/17 116/24
119/22 134/11 135/12
136/15 137/13 139/13}
140/4 140/14 140/20
141/8 142/9 142/10
144/1 144/17 150/1
152/5 152/15 153/25
159/20 161/19 162/22)
162/25
well-established [1]
153/25
went [12] 8/16 17/9
34/2 43/18 48/12 66/4
82/19 86/18 124/17
150/1 150/7 158/20
were [202]
weren't [14] 13/22
17/23 34/3 35/2 37/5
62/23 79/18 79/19
80/25 81/23 108/2
149/19 151/17 157/19!
Westminster [1]
114/10
what [144] 5/2 6/7
10/1 10/4 14/4 15/13
15/14 21/13 22/12
22/12 23/20 26/10
26/11 28/19 30/14
30/17 30/24 31/4 37/8
44/22 44/22 45/4
45/24 46/8 47/6 47/17
47/22 48/2 53/7 55/12,
55/12 55/21 56/9 57/1
57/24 58/13 59/17
59/22 60/16 60/24
62/11 63/8 63/10
63/13 64/21 64/22
66/5 67/4 68/14 69/15)
73/18 73/19 73/24
74/9 74/20 75/14
76/15 77/10 77/11
77/16 78/23 79/2
79/13 80/19 81/10
81/25 83/3 84/11
84/15 84/18 85/7
85/12 86/15 87/19
88/20 92/1 95/17
97/17 99/5 100/16
100/17 101/8 102/6
102/23 103/7 107/24
108/17 109/13 109/16}
110/22 111/20 112/25

113/1 115/8 115/9
115/12 115/20 116/5
116/22 117/8 117/11
118/25 119/6 123/11
123/20 124/16 125/4
125/9 126/5 128/9
129/18 133/3 133/13
134/23 135/21 136/10}
137/12 139/10 140/1
140/18 142/14 142/15}
145/8 145/17 147/9
148/17 151/24 152/12)
153/13 154/7 154/13
154/25 155/11 155/23}
155/24 157/14 158/6
158/13 159/2 160/14
160/15 160/16 160/18}
162/17

what's [2] 132/11
160/9

whatever [3] 31/7
32/4 83/18

when [60] 1/21 10/6
10/7 24/5 24/13 27/18}
28/22 31/15 33/25
34/4 34/16 46/12
56/12 57/7 62/22 63/7,
74/18 78/4 78/15 81/2
81/14 86/14 86/18
89/19 100/11 102/7
103/11 103/14 104/2
104/19 104/21 105/2
108/20 109/9 109/12
111/19 115/24 117/9
119/10 121/1 123/12
126/3 131/14 134/13
134/24 135/13 136/15}
136/22 137/7 139/16
142/4 142/16 142/19
145/14 149/6 149/20
152/19 158/20 158/24}
161/10

whenever [1] 142/16
where [25] 8/11
10/25 22/25 23/2 23/4}
29/20 32/11 58/24
80/17 83/11 84/12
86/8 87/5 87/25 92/8
92/20 119/16 129/10
139/20 146/9 151/16
154/12 154/21 157/10}
161/13

whereas [3] 31/17
55/4 92/21

whether [30] 3/8 7/15]
25/22 26/21 26/22
50/4 61/1 62/9 67/14
67/16 68/7 73/14
77/23 101/16 102/13
102/13 107/1 110/15
115/20 121/16 121/23}
125/7 125/8 127/22
128/17 128/23 132/5
132/17 153/23 154/10}

which [174]
while [4] 49/12 53/11
65/2 147/22
whilst [5] 6/9 40/1
51/17 101/16 138/24
whistleblower [1]
54/4
white [2] 22/3 22/4
who [73] 4/12 6/4
6/19 6/20 9/6 9/7
10/16 11/1 11/11
18/23 18/24 24/1
34/10 34/20 35/1
41/13 41/16 42/16
42/25 44/25 50/24
54/20 54/24 55/6
59/20 59/25 60/9 74/6I
80/10 80/22 81/20
83/16 84/24 85/17
85/25 86/7 87/2 87/12
88/9 89/11 89/15
89/16 89/23 90/20
92/13 92/14 93/5
93/11 98/15 99/25
102/4 102/12 103/8
104/23 107/20 108/10}
109/14 112/13 115/15}
134/21 137/22 141/5
141/6 144/3 152/13
154/13 156/5 157/3
158/16 159/12 161/21
161/24 162/4
who'd [2] 60/23
65/20
who's [1] 136/24
whoever [1] 99/3
whole [16] 26/23
32/7 33/7 33/12 71/7
77/8 83/21 87/23
107/7 112/18 130/22
153/5 154/8 154/11
158/21 160/11
wholly [1] 148/13
whom [3] 10/19
152/14 158/16
whose [1] 91/15
why [28] 16/8 28/25
31/24 33/3 40/6 45/7
46/5 72/2 73/7 73/17
87/3 89/2 93/7 93/16
93/23 99/18 100/6
102/25 104/11 120/11
131/11 131/25 132/8
136/22 143/4 148/18
148/18 149/18
wide [3] 15/8 15/16
37/10
wide-ranging [1]
37/10
wider [1] 81/22
will [52] 3/4 8/3 8/6
10/15 10/16 11/2
24/24 36/8 36/9 37/9
43/17 45/13 45/18

(70) very... - willO
Wo
will... [39] 49/10
49/15 49/15 50/4

50/10 50/10 50/22
50/25 53/8 65/12 67/9
68/7 68/11 75/5 76/8
76/19 88/8 89/22
90/24 92/14 98/17
106/5 106/18 108/12
109/4 109/5 109/5
113/3 113/6 115/23
122/15 130/4 130/8
133/3 146/1 149/13
156/15 156/21 161/25)
Williams [3] 108/3
160/24 164/10
willing [1] 50/18
willingness [1] 39/16
wise [1] 92/17
wish [4] 23/10 92/23
96/13 145/24
wishes [1] 5/7
Wiskin [1] 8/23
withdrawing [1]
118/13
within [17] 10/21
12/2 18/1 20/25 36/19
36/21 38/12 53/21
59/7 70/18 71/15
72/14 73/3 74/16
85/25 147/1 150/15
without [16] 5/11
11/10 40/5 42/12
43/16 46/4 48/9 54/2
72/24 100/19 109/3
124/20 131/25 155/13}
156/18 158/12
WITN00690100 [1]
136/5
WITN10200100 [1]
1/16
WITN10200101 [1]
8/7
WITN10200103 [1]
40/19
witness [37] 1/14
1/19 3/2 3/12 8/4
12/13 14/11 21/3
25/19 27/15 31/12
34/9 37/20 47/18 54/7
58/5 58/13 66/7 76/25)
80/4 82/3 82/5 87/16
91/6 96/15 97/21
101/1 103/17 123/12
123/22 136/3 137/4
138/2 141/11 146/24
163/2 163/4
won't [1] 8/5
wondered [1] 93/7
wondering [2]
161/19 162/3
wool [1] 151/18
word [2] 9/18 88/15

words [8] 68/2 68/3
69/20 70/15 75/18
86/1 129/23 155/16
work [54] 4/2 5/23
6/3 10/25 11/17 23/18)
26/15 39/3 44/13
44/19 44/24 46/18
46/18 49/13 51/24
53/1 61/21 61/23
77/15 78/18 79/4
81/21 89/2 90/1 105/9)
107/22 115/16 127/9
127/14 127/16 129/12)
129/16 130/1 130/5
130/7 130/15 131/1
1341/2 131/3 131/21
134/21 135/14 135/16)
138/24 141/1 141/16
141/18 141/20 142/6
151/21 153/10 154/9
158/20 158/24
worked [13] 2/8 6/20
13/21 40/25 81/14
85/11 89/12 120/1
120/2 134/21 149/21
150/1 159/13
working [10] 5/7
51/18 59/11 86/5
91/23 93/17 106/22
134/14 146/9 157/9
works [2] 62/13
89/19
world [1] 135/23
worried [8] 4/3 5/10
45/20 60/11 60/16
81/8 121/4 136/2
worry [6] 10/6 29/3
29/8 91/5 99/22
157/24
worth [3] 12/24 51/25)
91/3
worthwhile [1] 90/25
would [153] 3/18
3/18 6/4 6/10 7/24
8/11 8/19 9/13 10/12
10/15 11/1 11/41
17/11 17/17 17/19
20/1 21/9 21/21 21/21
23/16 23/21 25/1
25/14 27/20 29/7 29/7
29/17 29/24 29/25
29/25 30/1 30/16
30/19 30/23 30/24
31/2 31/4 32/4 32/17
33/2 33/14 34/10 36/1
37/7 38/10 40/16
42/12 43/2 44/10
44/23 45/8 45/24
45/24 47/24 48/8
48/17 49/7 52/24 55/4
55/5 57/9 57/10 58/3
62/19 65/7 65/12
65/13 65/19 67/13
67/15 67/16 68/24

69/11 71/6 72/3 72/20
73/11 75/7 76/14
76/22 76/25 83/13
84/3 88/19 88/23 89/3
90/2 92/12 95/10
95/23 97/10 98/1
98/12 98/14 98/21
98/22 99/8 100/5
101/9 103/15 103/24
105/9 106/24 107/20
108/10 108/17 109/8
117/11 118/10 118/23
119/2 121/16 122/2
122/9 124/7 126/5
130/20 130/21 131/2
131/6 133/4 133/25
134/6 135/19 135/19
135/19 139/10 139/13
139/13 139/14 140/4
140/14 140/16 140/23}
140/25 146/6 146/15
146/16 148/20 149/18
152/12 153/10 154/9
154/10 156/1 158/6
158/10 159/19 160/11
160/11 160/12 160/13
162/5
wouldn't [6] 34/23
56/22 61/3 107/23
109/18 146/6
write [11] 26/22 31/5
64/10 67/9 67/16
67/18 67/25 68/15
68/21 69/10 76/5
writes [1] 76/2
writing [7] 4/10 42/23}
48/16 49/16 74/9
105/15 126/20
written [8] 9/19 21/2
54/16 69/13 105/19
107/13 114/7 129/5
wrong [8] 60/7 74/15
102/18 112/15 132/18}
154/18 154/25 160/15}
wrongdoing [1]
63/17
wrongly [2] 84/5
128/11
wrote [4] 10/1 93/25
109/12 125/12
Wyn [6] 34/22 154/6
160/24 161/18 162/24
164/10

Y

yeah [24] 6/15 11/21
13/12 13/15 14/15
15/17 37/7 43/3 46/17
77/3 77/3 88/13 95/25
96/4 100/20 120/16
120/19 125/11 126/13
126/13 129/21 136/20
138/4 150/18

year [10] 31/6 34/3

36/6 78/14 117/12
117/13 125/22 126/9
137/6 146/22
years [19] 1/25 2/14
10/17 14/20 19/12
19/25 25/14 27/8 39/1
51/14 62/8 63/7 106/6)
109/18 139/6 140/5
142/15 150/4 150/6
years' [1] 12/24
yes [56] 1/4 1/18 1/24)
2/2 2/7 4/6 4/10 5/22
8/2 9/19 10/23 12/3
16/7 19/2 22/4 26/5
31/3 35/7 35/16 41/3
41/20 41/25 42/1 50/3)
53/18 55/3 55/14
57/15 57/22 58/3 68/4)
71/20 80/9 80/15 82/5
85/15 94/4 96/10
104/9 107/6 113/5
113/15 120/18 123/19}
124/13 125/14 129/23}
137/7 149/12 149/22
151/15 155/6 156/10
156/16 156/19 163/9
yet [11] 40/3 46/2
60/9 68/19 101/7
101/19 114/9 116/20
117/15 130/18 139/19
you [780]
you'd [6] 17/21
134/22 143/3 149/22
149/23 155/9
you'll [6] 35/24 47/14
49/20 71/25 94/22
127/19
you're [30] 11/18
22/1 29/2 29/5 29/9
29/19 32/2 32/23
42/14 55/1 57/4 70/6
73/25 77/10 79/25
83/21 84/18 97/17
100/11 103/12 128/6
128/7 128/8 129/18
142/2 144/8 158/16
158/25 159/8 159/20
you've [34] 1/14 3/2
11/23 12/1 25/7 27/5
28/5 32/7 32/8 32/8
34/4 72/4 74/8 74/22
81/18 84/13 85/1 85/5
87/6 90/14 96/12
112/22 112/24 116/16}
139/21 140/1 149/6
151/1 153/4 154/8
154/12 157/7 157/8
162/18
your [165]
yourself [2] 115/20
121/22

(71) will... - yourselfO