INQ00001181 - Transcript (25/07/2024): Post Office Horizon IT Inquiry - The Rt. Hon. Sir Vince Cable [WITN1083] and The Rt. Hon. Greg Clark [WITN1090]

Evidence on official site

The Post Office Horizon IT Inquiry 25 July 2024

ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

Thursday 25 July 2024 1 A. Yes, they are true to the best of my knowledge and
(9.45 am) 2 belief.
MR BEER: Good morning, sir. Can you see and hear us? 3  Q. Thank you very much. You can put that to one side now.
SIR BRIAN LANGSTAFF: Yes, thank you very much. 4 All of the other documents I will show you will come up
MR BEER: May I call Sir Vince Cable, please. 5 on the screen.
THE RIGHT HONOURABLE SIRJOHN VINCENT CABLE (sworn) 6 I think by training and background you are
Questioned by MR BEER 7 an economist; is that right?
MR BEER: Good morning, Sir Vince. My name is Jason Beer 8 Yes, that's right, yes.
and I ask questions on behalf of the Inquiry. Can you 9 After university and the like, you entered the Civil
give us your full name, please? 10 Service; is that correct?
John Vincent Cable. "1 For a couple of years, yes, and then I was later
Thank you. For those listening and watching, if I'm 12 a Special Adviser within the Department of Trade and
speaking in more than usually loud voice today and if 13 Industry but mostly not in the Civil Service, but I had
I'm getting closer to the microphones than is usual, 14 a stretch there.
there is a good reason for that, which Sir Vince 15 Then you worked in business before being elected to
understands? 16 Parliament in 1997; is that right?
Thank you very much. I appreciate it. 17 Correct, yes.
Can you look at a witness statement that you've kindly 18 So far as concerns this Inquiry, the most important
prepared for the Inquiry, please, it's in front of you. 19 office you held was as Secretary of State for Business,
So it should be 53 pages long and dated 27 June 2024. 20 Innovation and Skills, and was that between 12 May 2010
If you look at the last page, page 53, do you see your 21 and the 12 May 2015?
signature? 22 Yes, that was the full length of the Coalition
Yes, I do. 23 Government.
Are the contents of that witness statement true to the 24 So five years?
best of your knowledge and belief? 25 Five years, yes.
1 2
During that period, is it right that there was a junior 1 I wouldn't say abnormally so. I mean, I was unusual in
minister responsible for postal affairs? 2 having five years in my office. I think under the
Yes, I think there were six or seven junior ministers 3 government that has just passed, we had Cabinet
and one was responsible for postal affairs, amongst 4 Ministers who held jobs for a few months but I was
other things, most notably, I think, labour relations, 5 unusual. I think, in Jo Swinson's case, there was
consumer protection. 6 an interruption because of the maternity leave. That
You list them in paragraph 21 of your witness 7 was, I think, very understandable, that wasn't really
statement -- no need for it to be turned up -- but there 8 churn. But the others were changed because of
were a succession of junior ministers with 9 an overall mix in our ministerial portfolio: Ed Davey
responsibility for postal affairs in that five-year 10 became a Secretary of State, for example.
period; is that right? 11 Did you get any sense in your period of office that the
Yes, there were four. 12 brief held by the person responsible for postal affairs,
Was that a regular or normal number of junior ministers 13 the minister responsible for postal affairs, was too
holding down a post over that kind of period? 14 broad, ie there was too much to do?
Well, I think there was quite a high turnover generally. 15 Well, there was a vast amount within the Department,
The four ministers we've referred to were people from my, 16 I think we may come to this in more detail later, but in
party, the other junior ministers were Conservatives, 17 the briefing pack, the topical briefing pack, I noticed
but they had a turnover which was really directed by the 18 there was a list of 100 items which came within my
Prime Minister. My group of ministers were essentially 19 portfolio, roughly, and Post Office was one of them, and
appointed by Nick Clegg and worked with me. 20 the portfolio had to be divided up between ministers and
Did you get any sense that there was churn, as it's 21 civil servants. The Post Office was part of a junior
sometimes referred to, in that ministerial post that may 22 minister's portfolio and I think that was proportionate,
have made it difficult for the person occupying it to 23 given the wide range of things that we had to do.
grasp/fully understand/get to grips with post Office 24 Did any of the Junior Ministers in your time ever raise
issues? 25

with you a problem as to capacity, such that they
4

(1) Pages 1-4
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

couldn't give postal affairs sufficient attention?
No, I don't think so. I mean, in my judgement they were
highly conscientious and very intelligent ministers and
very capable and perfectly capable of handling the
responsibility. I met them regularly as party

colleagues and ministers, we talked formally and
informally and they kept me abreast of issues which they
found particularly important.

In paragraph 2 of your witness statement -- again, no
need to turn it up -- you say:

“lam informed that a large number of documents
which should have been retained cannot be located, such
as my official diary and minutes of meetings.”

Sir Ed Davey and Jo Swinson have said similar things
to the Inquiry. Do you know why such papers, including
your official diary, which is presumably an important
record of your activities, was not retained?
I have no idea why they weren't retained but there
were -- in my case, there were some what I call seminal
meetings which were never recorded. I had a first
courtesy call meeting with Paula Vennells and Alice
Perkins, for example. There doesn't seem to be any
record of that, though I registered with them some of my
concerns about the Post Office at that point. There was

a meeting where a Member of Parliament, Mr Bridgen,
5

which cast doubt on the safety of criminal convictions
obtained by the Post Office when acting as a private
prosecutor; the CCRC, the Criminal Cases Review
Commission, had commenced an investigation into the
safety of some convictions; second Sight, the forensic
accountants, had been instructed and had produced four
reports in that five-year period: it marked the
beginning, middle and end of the initial Complaint and
Mediation Scheme run by the Post Office; Deloitte,
forensic accountants, had completed reports on the
Horizon system.

I've given you a smattering of things that happened
in that five-year period where you say Horizon barely
came across your desk. Looking at it in the round, how
do you think it is that Horizon barely came across your
desk in that five-year period?

Well, I think the general reason is that the officials
who were briefing me and the ministers on the subject
hadn't seen it as a particular problem. I think, with
hindsight, I should have been told at the outset about
Horizon, what it was. It was just a word. I should
have been told that people were querying it -- you know,
good, competent people. Computer Weekly, for example,
I knew nothing of their work. We should have been told
that people were suggesting there was a risk factor and

7

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

brought the Federation to tell me about some of the
distressing cases of subpostmasters. There appears to
be no record of that either.

Have you asked why there is no record?

Yes, I was told that people had searched and couldn't
find it. I think probably it has to do with the

transition which was taking place from paper to digital.
When I first started the job, almost everything was done
‘on paper, letters came into the Department. I think, by
the end of it, it was email based and, for a variety of
reasons, complete records were not kept.

You tell us also in paragraph 2 of your witness
statement that, in your five years in office, problems
with Horizon barely came across your desk; is that
right?

That is correct and, when they did, it was usually in

a very uncontroversial way and it was not drawn to my
attention as an issue I should focus on.

That five-year period was a significant one in relation

to the unfolding events concerning Horizon, including,
within that five-year period, because campaigning work
was being undertaken by the Justice for Subpostmasters
Alliance; there was the threat of a class action being
brought against the Post Office in the courts; there had

been the discovery of evidence in that five-year period
6

I should have been told about Mr Bates and the Justice
group. I never heard his name until I'd been in the job
five years at the end, when the whole issue came to
ahead. But, certainly, I wasn't briefed on them and

I think probably this came down to civil servants making
a judgement that, because I had a vast area of
responsibility and because it was being well handled at
a minister level, that I didn't need to be told about

them.

Thank you. You tell us in paragraph 4 of your witness
statement that governments across the political spectrum
share some responsibility for the fact that the scandal
happened on their watches and that you accept your share
of responsibility.

Yes, I -- to be frank, I found it very difficult to

pinpoint particular events or decisions that I could

have done differently but, simply as a matter of formal
responsibility, this was a state enterprise that came
within the remit of my Department and I accept the fact
that it happened on our watch. I know that's a cliché
but it's something that ministers have to recognise.

I was about to ask you, when you say that you accept
your share of responsibility, what are you accepting
responsibility for?

Well, general oversight of the Department, and this was
8

(2) Pages 5-8
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

an area of the Department where clearly there was
a policy failure.

As far as I recall, there weren't any specific
interventions that I made or was asked to make that
would have changed any of those long list of things that
you described.

Can we get down to some specifics then and start with
the issue of your knowledge of key issues relating to
subpostmaster challenges concerning Horizon. If we just
turn up paragraph 33 of your witness statement, it'll
come up on the screen, please. It's on page 12,

page 33. You're here dealing with, as part of your
chronological account, the period of time when you took
up office, and you say in 33:

"I was not briefed by officials on, or otherwise
aware of, any issues to do with the Post Office's IT
system at this time."

If we go back to paragraph 13 of your witness
statement, which is on page 5, thank you. This is years
before you took up office.

Yes.

In this part of your witness statement, you're telling
us more generally about your knowledge of the Post
Office.

Yes.

involved in a separate issue, a closure issue, and that
had given you some insight into the way that POL middle
management the behaved; is that right?
That's correct. Just to elaborate a little bit, I had
raised a debate in Parliament, I think probably I was
one of the first, about the way postmasters were treated
by the Post Office, and there was a particular case,
which you haven't referred to, but there's a particular
case of a woman in my constituency who had invested,
I think, £75,000 in her post office. It was taken away
from her for reasons that were never clearly explained,
she lost all the money. Another post office opened up
nearby for reasons that were never explained.

I never got good answers for why this was happening,
so I called the debate and it basically chimed in with
other experiences I had of the Post Office. For
example, I'd been campaigning for months on Post Office
closures in my own constituency and others and I took
them to the Post Office and it was all sort of brushed
aside, I was an interfering politician, it was nothing
to do with me, operational matters were matters for the
Post Office and not for ministers or politicians. And
so I'd formed a very negative impression, in the case,
and it was reinforced in Government because, as I think

I mentioned a few minutes ago, that I think the one
1

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

You say:

"I became aware of allegations of fraud when
a constituent was charged and lost his post office.
[You] cannot recall exactly when this was -- probably
around 2001-2002. [You] approached the family and
offered help. They told me that the charges were
unjustified but they wanted to rely on ‘justice’ and not
involve me as MP. The family never mentioned IT."

Then, thirdly, in paragraph 92 of your witness
statement, which is on page 37, you say:

"Before I came into government, I think I had 8
closures in my constituency ... I organised and
collected numerous petitions against branch closures ...
Usually postmasters did not want to become involved,
because they were afraid of the consequences."

Then this:

"When we came into Government, Ed Davey and I agreed

based on our experience as constituency MPs that [Post
Office Limited] middle management were, as I described
[and you refer to a debate in Parliament in 1999]
‘authoritarian’. Mr Bates has, I believe, described

them as ‘thugs in suits’ and I recognise this

description. [Post Office] dealt with us in an arrogant
way when we campaigned against closures."

Drawing the threads together there, you had been
10

occasion when I was a minister where these distressing
cases were brought to me was by a deputation -- not
a deputation -- a single man, a man from the Federation,
I think, about 50 to 100 cases, he brought a scrapbook
of photographs to illustrate it. So I knew that these
expulsions, fraud cases, and so on, were taking place
but, throughout the whole of that, in none of these
cases did anybody, as far as I remember, ever say
anything about the computers.

It was seen as -- as I sawit -- I had a theory
which may have been proved to be wrong but, essentially,
the Post Office had what I would call a ‘one strike and
you're out' policy, that if a postmaster made a mistake
they would be punished severely -- not necessarily
anything to do with computing mistakes, that emerged
subsequently. And if I can just add one final point,
that when I was campaigning on behalf of postmasters at
that stage, and it was 10 years before I went into the
Government, I did get a lot of help from the Federation,
Mr Baker, who was in charge at that point, and they
helped me to obtain compensation for the postmistress
who had been evicted in my constituency. She was fully
compensated and it was with the help of the Federation.

So I, thereafter, tended to have a very positive

view about them and trusted their judgement.
12

(3) Pages 9 - 12
©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

You say here that POL middle management was

authoritarian and you recognised the description of them

applied by Sir Alan as "thugs in suits"; what about your

dealings with them led you to those views?

Well, it was the description of what happened when --

well, in the particular cases I brought to Parliament,

but I'd heard of others -- about what happened when

a postmaster made a mistake. I mean, in the case of my

constituent, the only thing that we had identified was

that Twickenham residents had gone into the post office

and found that the person behind the counter didn't know

that Santiago was the capital of Chile, and a complaint

had been made and, on the basis of this complaint, she

had been -- had her franchise taken away from her.
Certainly, when I raised that issue and closures

with the Post Office officials who I met around

closures, the attitude came across to me very much as it

was described here.

It was as a result of meeting them face-to-face?

It was indeed and through the attitude that was revealed

in correspondence at the time.

If we turn to the period when you took up office -- that

can come down from the screen, thank you -- when were

you first aware of individual subpostmasters challenging

the Post Office's enforcement action against them?
13

subpostmasters had been prosecuted on the basis of
Horizon data, which may not be reliable?

Well, I think it was then, very much at the end of the
Parliament when we had that coincidence of events, and
I was brought in to the picture.

If we turn up your witness statement, please, at page 14
and paragraph 40, you say:

“In the course of preparing this statement, my
attention has been drawn to an unsigned letter dated
‘August 2012' to David Miliband MP, apparently a draft
prepared by officials on my behalf ... I understand this
letter to have been held by UKGI, and it is therefore
reasonable to assume that it was drafted by officials in
the Shareholder Executive. The draft letter indicates
it is a response to a letter from Mr Miliband dated
23 July 2012, which apparently enclosed a letter from
his constituent, Kevin Carter. I have seen neither
David Miliband's nor Kevin Carter's letter."

You then quote from the letter, which I'll skip
over. If we go over the page, please, and look at
paragraph 41, you say:

"I have no recollection of this correspondence at
all. I've not seen a signed and dated version of this
letter, though it is fair to assume that someone in the

Department responded, and did so along the lines of this
15

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

I wasn't aware of that at all. I knew that there were
these fraud cases because, as I've mentioned, I had this
delegation brought to me by Mr Bridgen, and I had asked
the Post Minister what action we were taking, and it was
at that point that I was told about Second Sight, the
forensic accountant, and I think reasonably assumed that
there was now a process to deal with it. That was the
‘only occasion on which this came to my attention.

When did you first become aware that Post Office both
investigated and privately prosecuted its own
subpostmasters and mistresses?

Well, I wasn't aware specifically about that
differentiation. I think the kind of common way of
looking at it was if somebody was charged with fraud it
‘was all a matter to do with the police and the courts.

The distinction that you draw and subsequently emerged
was not something I was aware of.

Not aware of at any time in your period of office?

Well, I think right at the end, when we had this coming
together of Mr Arbuthnot's question in Parliament and
the report of the Select Committee, I started to ask

a lot of questions about what was going on and I think
that was one of the issues which emerged but, until
then, the question had never arisen.

When did you first become aware of concerns that
14

draft referred to above. As David Miliband was a Privy
Counsellor, normally I would have been asked to sign the
response as a matter of courtesy -- though ... this was

in the summer recess and [you] may not have been
available ..."

Can we look at the letter, please. UKGI00013690.
This was the draft letter to which you were referring in
those paragraphs and it begins, you'll see, by thanking
Mr Miliband for his letter of the 23rd, enclosing
a letter from Mr Carter, and continues:

"I have noted Mr Carter's experiences and concerns
as subpostmaster [but] note that Post Office remains
fully confident about the robustness and integrity of
its Horizon and related accounting processes.”

Next paragraph:

"... in the light of discussions with James
Arbuthnot and a number of other MPs with
ex-subpostmaster constituents [Post Office] recently
agreed to an external independent review of a small
number of individual cases that had been raised with
them by several MPs."

If we go down, please, we'll see it's got your name
at the bottom but, as you say, you've not seen a signed
version of this letter. For letters like this, would

you read the letters before signing them?
16

(4) Pages 13 - 16
©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

Yes, I would, but let me just explain a little bit of

the background. I think the clue to this particular

letter is in the date. It was August. I was rarely, if

ever, in the Department in August because that was the
month I was sent on overseas visits to China, India,
whatever, to negotiate trade and investment agreements.
It was also the month I took short holidays with my

wife. So I almost certainly never saw the letter or the
incoming letter but maybe it will help answer your
question, I think, if I describe the process by which
correspondence was dealt with in my office and

I personally related to. The situation --

Just before you do, we've got a very detailed account
from you in your witness statement as to how
correspondence was dealt with. I just wanted to ask you

a few questions about how the correspondence was managed

within the Department and your private office.
Yes, maybe I can help with that. The problem was that
I think there were about several hundred letters a day
and emails, would come addressed to me personally.

I never saw them they would be directed by the
Correspondence Unit to the relevant civil servants who
would prepare replies, either by other civil servants or
by the Post Minister and very, very occasionally to me,

if there was a special reason ~- as I say, Mr Miliband
17

and it would have been sent out by my office PP'd on my
behalf.

You see in the second paragraph it refers to Post Office
remaining fully confident about the robustness and
integrity of the Horizon system and related accounting

processes. What enquiries would you expect to have been

undertaken and by whom, whether in private office, ShEx,
or otherwise, in order to confirm or stand up what is
said there?
Well, I would have expected -- and I think I said this
to you earlier, that when I first came into office
I would have expected to have been told that there were
questions being raised about this system, both by
Computer Weekly and by the Justice group, but I wasn't
and all I was ever told was -- and it appeared in
letters and in annexes to briefs that I was given --
that this was an issue that wasn't controversial.

I mean, bear in mind, I think, that, like, I think,
most politicians and most officials, I wasn't computer
literate. If somebody had said to me there was
a problem of integrity in a computer system, I wouldn't

have understood what on earth they meant. So I was very

reliant, as we all were, on the competence and integrity
of the people who were giving advice.

My question was more what enquiries would you expect, if
19

ONOaARWN

©

1
12
13
14
15

17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

>

was a Privy Counsellor -- and a letter of this kind
would come to me probably in a folder and it would be
explained by the civil servants, and my private office,
that this was a standard letter, that it had been agreed
with the Post Minister's office, it was the Departmental
line, and all I needed to do was sign it because there
was nothing controversial or difficult in it.
Just stopping there, Sir Vince, when you say it would
have been explained by officials in your private office
to you --
Yes.
-- in a covering submission, covering document, or
explained orally to you?
Well, I think in a case like this there may not even
have been a covering document because it was seen as
a routine bit of correspondence, and I would sometimes
have put in front of me a pile of letters for signing on
totally different subjects, and I would be told "These
are standard letters, you don't need to study them in
the way that, you know, other controversial issues
needed to be studied".

I mean, if I'd had time and opportunity I would
almost certainly have spent as much time as I could
reading them and absorbing them but, as I say, in this

particular case, I almost certainly never saw the letter
18

any, officials to have carried out before recommending
the inclusion of a line like this in a letter to be

signed by you?

Well, I think the civil servants who dealt with it --

I find it difficult to put myself in their minds, these

were people who were working full time on computer
related issues, I would certainly have expected them to
consult somebody independent, to have validated this
claim and probably to have taken time to interrogate the
people who were offering criticisms, and it appears
there were, at that time. But, no, I wasn't in their

mind. It wasn't a subject I was remotely familiar with
and I had to accept and trust the advice I was given
because, I mean, that is ultimately how Government
works.

Yes.

You have to trust advice.

Would you have regarded it as sufficient if officials

had lines provided for them by Post Office and simply
incorporated those into letters that were to be sent out
in your name or junior ministers’ names, without the
kind of testing or challenge that you've just mentioned?
Well, there should have been a testing or challenge at
some point but, having established, as they seemed to

have done, that there wasn't a problem, it would have
20

(5) Pages 17 - 20

25 July 2024
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

2

prop

The Post Office Horizon IT Inquiry

been reasonable then to have accepted the Post Office
wording.

So you would have expected at some point a moment of
challenge or deep investigation to —-

Yes --

-- have occurred --

-- I think that's reasonable.

-- in order to start up the use of the lines provided by
Post Office about Horizon, even if, thereafter, the line
was perpetuated without further investigation?

Yes, I would have expected an interrogation of the
issue, of course.

In paragraph 31 of your witness statement, if we turn
that up, please -- it's on page 11 -- you say:

"Upon my appointment I set three objectives for the
Department and Ministers ..."

Then if we go over the page, please, and the third
of them -- it hasn't got a (c) next to it but I think it
is the third of them -- is:

"To address the imbalance in the relationship
between the Post Office and subpostmasters, giving
postmasters a greater say in the running of the network,
and to advance, in partnership with the Federation, the
idea of mutualisation."

What lay behind your understanding that there was
24

the post office.
It was an ambitious idea and, unlike the other two
objectives, this didn't come to fruition unfortunately
but that was where the idea came from.
Can we look, please, at POL00059303, and look at page 2,
please, and scroll down a little further. You'll see
this is a letter from Yasmin Qureshi, the then MP for
Bolton South East. Then if we go back to page 1,
please, you'll see it's dated 25 October 2012, and it's
addressed directly to you. It concerns Chirag Patel.
If we scroll down, please, if you just read to yourself
what is said in the first six paragraphs.
Yes.
You'll see in the seventh paragraph it says:
"The person who did the audit even said there was
a problem with the computer because all the money in the
post office was accounted for and it was not Mr Patel."
Scrolling on, he had to pay £12,500 and then, over
the page, if you just read what's on that page.
Yes. If we just go back to page 1, looking at the
letter, is this the kind of letter that you would have
seen yourself?
No. As I've explained --
In this instance, why would you not have seen this type

of letter?
23

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

an imbalance in the relationship between the Post Office
and subpostmasters?
Well, it was based on -- largely on my own personal
experience, which I've already described to you that
I had called a debate in Parliament 10 years earlier,
expressing my unhappiness with the way that postmasters
were dealt with. And there was actually a broader
policy issue which engaged me, in the sense that I was.
responsible, overall, for competition policy and there
are, in the country, a whole set of cases where you have
a what you might call a monopoly -- the technical word
is monopsony but, sorry, I don't want to get into
complex economics here -- but where you had a powerful
organisation with large numbers of suppliers, and we had
that situation with, say, farmers and supermarkets, we
brought in legislation to protect the farmers.

We did the same with publicans and pub-goers, which
took a great deal of time and Jo Swinson's time, and
I was aware there was a similar problem with the Post
Office, and I had thought, at the outset, we needed to
change this situation.

And the idea came up, I think it was Ed Davey in his
discussions with the Federation, that the best way to
deal with this problem was to create a mutual structure

which would effectively put the postmasters in charge of
22

Well, I never saw any of this kind of letter for the

reasons I described. Because of the way the
Correspondence Unit operated, there would be very large
numbers of incoming letters, they were immediately sent
to the relevant part of the Department to prepare

an answer and the answer would come back through either
a civil servant or through the Post Minister. In this

case, it was judged that I didn't need to be involved

and, certainly, I never saw the letter. But the content

of it is familiar, because of the case I was familiar

with in Twickenham, it sounded very similar to this,
except that the IT dimension wasn't in evidence there,
and it was the same kind of issue which was presented to
me by the Federation when the representative met me with
Mr Bridgen.

One of your objectives was addressing the imbalance in
the relationship between Post Office and its
subpostmasters and this kind of complaint speaks to that
very issue, doesn't it?

Yes, I thought a lot about how you dealt with this

question of imbalance but the proposal I had made to
Parliament 10 years earlier was that we did need to set
up an arbitration mediation mechanism. You may say it
was just serendipity but this is ultimately what

happened and, certainly, in my first meeting with Paula
24

(6) Pages 21 - 24
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24

The Post Office Horizon IT Inquiry

Vennells, I had suggested that this is what the Post
Office should do. But when I came into Government and
discussed this matter with Ed Davey, and I think
separately the Federation, we thought a more radical
solution was required and that's how the idea of
mutualisation came up.

In retrospect, probably we should have been more
modest and perhaps insisted that postmasters should be
‘on the Board of the Post Office. I believe this has now
happened but, at the time, they weren't directly
represented. But that would have achieved some of the
objectives of mutualisation, without the full process
which took an inordinately long time.

Given that one of your three key objectives for Post
Office was to address the imbalance in the relationship
between Post Office and subpostmasters, do you know why
correspondence of this kind, which speaks to that very
issue, was not flagged to you?

Well, I think the reason it wasn't flagged to me was the
reason I gave in my earlier answers: that I had a vast
portfolio, the civil servants in my private office and

in the Department knew that this was -- I don't know,

1 or 2 per cent of my workload, and clearly judged that
they didn't need to deal with me, if necessary, there

was a Post Minister who would deal with it on my behalf.
25

a lot of complaints that MPs weren't getting answers, so
I asked for more resources to beef up the Correspondence
Unit. So the fact that proper letters were going out
was, in itself, an advance on where we'd been before.
But, yes, I recognised the letter, and there are several
messages in it, which were, I think, fairly consistent
and consistent with what I'd heard.

For example when I'd held my debate in Parliament in
1999, the first thing that the Labour minister told me
was, "I can't deal with this because this is
an operational matter, and operational matters are the
responsibility of the Post Office"; and the second issue
which was pointed out to me is that, you know, there are
legal issues involved, there are court cases, ministers
cannot get involved in matters relating to the criminal
law. So, ministers replying to letters were probably,
at each stage, having to explain that.
You'll see that, as you say, in the second paragraph, it
says:

"The issues raised in your [Norman Lamb's] letter
are operational and contractual matters between Post
Office and [the postmistress] Mrs Henderson ... neither
I nor the Department can intervene in cases which are
sub judice or where court action had been determined.

The constituent was charged to appear at Norwich
27

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

So, you know, it was a judgement on their part, it was
perfectly fair, that I simply would not have been able

to cope with the volume of correspondence.

Can we look at some of the responses that junior
ministers sent out. UKGI00013863, please.

Thank you. If we go to the bottom of the second
page and the top of the third page. In fact, we can see
it from that first page. We can see this is a letter
sent out by Ed Davey MP. You can see it’s to Norman
Lamb who, ironically enough, was subsequently to be
a Postal Affairs Minister but here he is being written
to in his capacity as a backbench MP. Here, Ed Davey is
replying to a letter that had been sent to you by Norman
Lamb on behalf of his constituent, Allison Henderson,
setting out her concerns about Post Office audit
procedures and accusations levelled against
subpostmasters:

"I am replying as Minister for Postal Affairs.”

So there are number of these. Just looking at what
we have seen this so far, is this what you would have
expected to have happened, namely a letter coming in to
you from a backbench MP, being passed to the Postal
Affairs Minister to respond to?

Yes, I would have expected that that was the process.

I have to say when I first came into Government, I got
26

Crown Court. She pleaded guilty to false accounting.
Then it is said:

"... Lunderstand, at no time during the case were
any problems with ... Horizon IT system raised by
Mrs Henderson or separately identified.”

That line there, that no problems with the IT system
were raised by Mrs Henderson at any time, we know to be
false. She had raised in the course of the court
proceedings, on two occasions, including in formal
documents, her suggestion that the losses were caused by
the IT system.

For this kind of correspondence, what kind of
inquiry would you expect officials to make before
including in a letter information such as that?

Well, in a way this is your earlier question in

a different form --

Itis.

-- which is basically, at the outset, there did need to
have been an interrogation of the claim by the Post
Office that there wasn't a problem but that, having been
satisfied, as apparently the civil servants were, it was
perfectly reasonable to incorporate that kind of comment
in an outgoing letter.

This goes slightly further. It has a bit of a dig at

Mrs Henderson, saying it's all very well complaining
28

(7) Pages 25 - 28
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

>

prop,

The Post Office Horizon IT Inquiry

now, she didn't complain when she had the opportunity to
do so, namely in the court proceedings.

Yes.

What would you expect officials to do, if anything,
before including that kind of line in a letter?

Well, this is a level of detail I'd never got involved

in, drafting and preparing letters of this kind. So how
much detail -- I think there is a serious point, though,
which is that this issue about commenting on court
cases. Throughout --

Put that to one side for the moment. I am asking you,
as the Secretary of State, what you would expect
Officials to do before including this kind of content in
aletter? If you say you don't know, and are not in

a position to judge --

Well, this is in a level of detail that I really can't

make any useful comment on. As I said, I think it was
incumbent on the officials in the Department to have
established, in general terms, that the Post Office were
acting correctly but, having established that, it was
not unreasonable for them to reproduce versions of
events that they were given.

le given by Post Office?

Yes.

So you wouldn't see anything objectionable in, if they
29

first paragraph thanking her for her letter of
22 February 2011 to you on behalf of her constituent,
Bhavisha Parekh, whose father was prosecuted for cash
losses. It records that the constituent suggests that
the Horizon computer system caused these losses?

So, again, similar to what we see before in the
terms of the architecture of the thing: letter in to you
but letter out from Ed Davey.
Yes.
That would be the system operating as it should?
Yes. That was how it worked.
There are quite number of these letters but just to see
this is a repetition, in the second paragraph:

"The issues raised in your letter are ...
operational and contractual matters between Post
Office", et cetera.

Was that a line that you were familiar with, a line
to take?
Yes, I was very familiar with that because that was
exactly what I was told when I had raised cases in
Parliament on behalf of the postmaster, that they had --
I think I had a 15-minute reply from the then Labour
Minister and the first five minutes were explaining the
legislation under which the Post Office operated, '69

Act, which made it very clear that they had
31

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

were given that line by the Post Office, simply to cut
it into a letter?

Well, it is a little odd, now you mention it but I don't

really have anything add. I mean, this is a very high

level of detail and I wasn't involved in drafting

letters of this kind, so I can't really make any

intelligent comment on it.

No, I know you weren't involved; I'm just trying to

explore with you whether, before you or your ministers

put their names to letters, you had an understanding of
what had gone on in the back office. If somebody had
asked me to sign something, I'd either want to know if
what's in it is true from my own personal knowledge or

a little bit about the process which has gone into

finding out the information and testing it?

Yes, well, I'd imagine that what happened was that the

civil servants in BIS spoke to their opposite number

on -- in the Post Office, and said, you know, "Can you

give me the background to this case because I need to be
able to give a full reply, and will you please tell me

what happened in the case of Mrs Henderson?", and would,
I think, simply on matters of fact, have had to trust

the reply they were given.

Thank you. Can we look, please, at UKGI00014038, March

2011, a letter out from Ed Davey to Glenda Jackson. The
30

responsibility for operational matters.

And certainly when I, I think, first met Paula
Vennells, the first courtesy meeting, I'd explained my
history and I think she reminded me that this is exactly
the way in which the relationship between me as
a minister and her as a Chief Executive, must operate.
You mentioned the '69 Act there, are you referring to
the Post Office Act 1969?

Yes, yes.

What did you understand that to say, by the time of the
years 2010 to 2015, as to operational independence?
Well, my understanding, which framed the way I dealt
with issues, was that I had responsibility for the

general kind of strategic direction of the Post Office

and its financing, and that the Post Office were
responsible for their relationships with individual
postmasters and operational decisions about the opening
and closing of post offices. That was how I saw the
distinction.

We've got in our pack a series of letters -- I'm just

going to list them -- from MPs or constituents. I'll

list them, one in October 2013, POL00195964 at page 3;
one, December 2014, POL00218852, pages 1 to 4; and one
where the date isn't clear, POL003454283. So letters in

to you raising matters concerning the operation of the
32

(8) Pages 29 - 32
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

rPOoOPrP.D

The Post Office Horizon IT Inquiry

Horizon system and action taken against subpostmasters.
Would you expect anyone, in your office or

otherwise, to draw together correspondence which was of

the same or substantially the same nature, ie was

complaining about the same thing?

Well, I would have expected the operational civil

servants, not necessarily my private office, to have

been alert to a systemic problem if there was one. But

perhaps if I can just add another note, because the

letters you're drawing to my attention are letters from

MPs. I was very conscious from the outset that I didn't

want to be caught in what you might call a Sir Humphrey

situation, of being blindsided by officials who had,

say, a biased view. So I set up in Parliament, through

my so-called PPS, a system of surgeries so that MPs

could come and talk to me on a Monday evening with or

without officials present, if there were any problems

they had.

Just stopping you there, you explained some of this in

your witness statement.

Yes.

Can you explain to those watching and listening what you

mean by a "Sir Humphrey situation"?

Well, the fact that civil servants may have had a view

of the world which was different to mine and I needed to
33

I mean, they did on other issues.

Sorry, Sir Vince, are you saying it there that James
Arbuthnot was not concerned because he didn't raise the
matter with you?

No, I have read about his work and it was monumental,
and he did enormous amount of good work. But, for
whatever reason, the MPs who were concerned about this
issue never raised it with me in Parliament. They had
abundant opportunities to do so.

You're not being critical of them for failing to do so?

No, not at all --

You're simply saying they took a different route?

No, they took a different route and different MPs

operate in different ways. No, I'm not remotely

critical, particularly Lord Arbuthnot, as he is now, did

a heroic job. I wouldn't dare to criticise him.

Were you aware that, essentially, a boilerplate reply

was being sent out in response to each and every one of
these letters in from MPs that were being sent to you?
Well, I wasn't aware of the letters as coming in or

going out but, yeah, it clearly was a boilerplate

response. But that was actually how Government dealt
with most issues. Department/Government had to have
a line on issues and, having established it, reproduced

it and it would have caused chaos if there'd been
35

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

be aware of that, and that's why I set up this system

and people came to see me every week, MPs, on Post

Office issues, not related to postmasters, but on Post

Office issues. And I'm very surprised that, in the

whole of the five-year period, with the single exception

of Mr Bridgen, who brought the Federation, who didn't

raise the IT issue, why none of the MPs who were

concerned about this ever came to talk to me about it.
That was the way in which I could have challenged

the officials but I was never given the ammunition to do

so.

Did you know that groups of MPs, quite a large number of

MPs, were seeking to progress, during your period of

office, the complaints of their constituents, led

essentially by James Arbuthnot?

Well, I discovered this in March 2015. Before that,

I wasn't aware of it, no.

This may sound an awkward question: do you know why you

weren't aware of it?

Well, I -- optimistically, I would say it was because

they had complete trust that the Post Minister was

dealing with it properly. But the way Parliament worked

was that I walked past Mr Arbuthnot and the other MPs

several times a day and, if they were concerned, they

would surely have stopped and said something to me.
34

a different response to every individual.

The alternative view might be that having a boilerplate
response and sticking to it means that there's never any
real investigation of the issues?

Well, as I said several times already, I think, you

know, there should have been at some point a careful
interrogation of the issues but, having established

a clear line of argument, it was entirely appropriate to
be consistent in dealing with everybody who wrote in
about it.

Can I turn to the second issue, then: the Second Sight
investigations and the Mediation Scheme. Can we turn to
paragraph 46 of your witness statement, which is on
page 17. You say:

"lam told that on 8 July 2013 the Second Sight
Interim Report was published; I was not aware of this
report or its contents at the time...”

When did you first hear about the Second Sight
investigation and its Interim Report?

Well, I don't think I did, except I did meet, you know,
the ministers on a very regular basis. They may well
have said in the course of reporting to me on what they
were doing that this forensic investigation was taking
place and was proceeding normally. But I certainly was

never given a formal, detailed report on the work of
36

(9) Pages 33 - 36
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

Second Sight. I only heard about it when I had this
visit from Mr Bridgen and the Federation, and I wanted
to follow it up and ask the postmaster -- the Post
Minister what was going on, and they told me that the
Second Sight investigation was taking place.

I didn't realise, incidentally, that it was an IT
investigation. I thought it was just a general
investigation into why so many postmasters were being
charged with fraud and losing their post offices.
When were you first aware that Second Sight were
undertaking an investigation?
Well, when I told the Post Minister that I'd had this
delegation and I was very worried about it and the
numbers of people and the distress of some of the cases,
and I said, "What are we doing about this?" And she
said -- I think it was Jo Swinson at that time -- "We
have just launched this forensic audit and investigation
and I'm sure that all your cases will have been dealt
with properly".
Would that be in the course of her first period of
office, 6 September 2012 onwards?
Yes, I'm sure it was. It may not even have been Jo; it
may have been, I think, Norman Lamb, briefly. But no,
from memory, I think it was Jo's time.

If we look, please, at UKGI00013690, we can see the
37

To the private office of Jo Swinson and others within
ShEx. The subject is "Subpostmasters News Story", can
you see that?
Yes.
It says:

"Hi all

"Vince has seen this news article and thought it was
a good news story for the Post Office and good link to
the Trust and Transparency work. Any suggestions on
what we can do to take this forward?

"Thanks

"Anna."

Was she one of your private secretaries?
I don't remember -- there were a lot of private
secretaries. I don't remember an Anna but I'm sure it
was, yes.
We can see the second highlight is the attachment,
"Subpostmasters news story.pdf". Can we look at that,
please. UKGI00019390.

You may recognise the style and font and text. It's
an extract from Private Eye.
Yes.
It reads:

"At last some encouraging news for subpostmasters

who have been sacked, sued and even jailed over
39

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25 A.

prearearoe>

oP

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22 Q
23
24 A.
25 Q

25 July 2024

letter from you to David Miliband and, if we just look
in the third paragraph:

"Nevertheless, in the light of discussions with
James Arbuthnot and number of ... MPs [Post Office]
recently agreed to an external independent review of
a small number of individual cases that had been raised
by them ..."

That's, I think, a reference, would you agree, to
the Second Sight investigation.

Yes.

So you signing this letter off in August 20 --

12. As I said, I didn't sign it off.

No, so you simply would never have seen this?

Almost certainly.

Didn't see the letter in; didn't see the letter out?
Almost certainly not.

So we can't take this as knowledge by you of Second
Sight at this time?

No, absolutely not.

Can we look, please, then, at UKGI00019389, and look at
the bottom of the page, please, and over to the second
page. Can you see an email dated 22 July 2013 from
"Cable MPST"; is that your private office's email
address?

Yes, itis, yes.
38

shortfalls that hoe up on the Post Office's [Horizon
system].

"The Interim Report of a review of the IT system,
following a campaign by Tory MP James Arbuthnot, sets
out a raft of failings. These include the brutal way
the Post Office investigated financial errors;
unreliable hardware; the absence of training or support
for subpostmasters on a system said to be more complex
than that at a high street bank; and an unfair business
model which automatically makes subpostmasters
responsible for any discrepancy.

"These failings have led to false accounting
prosecutions as inexperienced individuals with
unexplained discrepancies have been faced with either
reporting false figures or losing their business, with
nowhere else to turn.

"Arbuthnot has applauded the Post Office on the open
way in which, through the review, it has allowed the
flaws to be exposed. But the next big test is whether
scores of people who have lost their livelihoods and
sometimes liberty will win any redress."

Now, it seems from the covering email that you had read
the article?
Well, I had seen it, yes.

What's the difference between seeing and reading?
40

(10) Pages 37 - 40
©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

Well, the difference is I was given every morning a pack
‘of 30 or 40 press cuttings, everything relating to the
Department, and I would normally judge from the gist of
it, the headlines, whether this was something we in the
Department needed to react to in some way. Part of my
was job to be conscious of the public impact of what we
were doing, and I just glanced and this one and it did
refer to the brutal way the Post Office investigate, and
I thought you know, "Well, this chimes with what
I know’, and I --
Do you recall now only glancing at it?
Yes, I'm sure I only glanced at it. I only glanced at
almost all of the press cuttings. It wasn't
an important part of the day's routine; it was just
picking up important issues. I just noticed that -- I'd
been lecturing businesses on how they needed to be much
more transparent about how they dealt with consumers and
workers, and so on, and here was somebody who had been
a critic of the Government saying that, actually,
a Government agency under our remit was doing a good
job. So I thought "Oh, yeah, why don't we make more of
this?"

And, as you see from the private office response,
they were at pains to dampen my enthusiasm because they

realised that this was a complex issue, so I think we
a

reply. So again, it's from Anna Bartholomew, a private
secretary in your office, so she's essentially replying
to her own email with the same distribution list. She
says:

"I have spoken to officials working on [Post Office]
and compiled the following advice for [you] -- this will
go in the box tonight with the article.

"Officials recommend not following up on the
article -- it presents a very skewed picture and does
not cover all the facts.

"The Interim Report clearly said that there was no
evidence of systemic failures or flaws, whereas the
report suggests [Post Office] has admitted to system
errors. There were 2 minor discrepancies which [Post
Office] identified and rectified independently of the
report. This affected a very small [proportion] of the
network ... no subpostmasters lost money

“Arbuthnot is closely involved in the investigation,
and provided a chance for the submission of individual
cases ... Although the article correctly refers to [him]
applauding the Post Office on the open way it responded
to allegations, there remain significant differences in
opinion. Following publication on the Interim Report
[he’s] tabled an Urgent Question requiring a Government

statement ... despite conversations with Jo Swinson to
43

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

2

25 July 2024

simply moved on and I didn't take it any further.
We'll come to all of those steps in a moment. You'll

see the article says that the Interim Report, which is

a reference to the 8 July 2013 Second Sight Report, sets
out a raft of failings: the brutal way Post Office
investigated errors; unreliable hardware; the absence of
training or support; an unfair business model leading to
false accounting prosecutions, leading to people losing
their business with nowhere else to tun. Why did you
think this was a good news story?

Well, I thought it was a good news story because I'd
simply picked up the fact that, I think it says

Mr Arbuthnot applauded the Post Office on the open way
in which it allows these flaws to be exposed. I mean,

as I say, I didn't read it carefully. It wasn't

a policy document: it was just one of 30 press cuttings
that I'd glanced at, but I'd picked up that somebody was
saying something positive about the Department and the
agencies we're responsible for.

Most of the press coverage was negative. I mean,
that's the way -- you know, the way of Government and
here, at a quick glance, was something positive. So
I suggested to the Press Office maybe they should take
this a bit further.

Looking back at the email, please, UKG100019389, see the
42

explain the operational nature of the issue.

"With regards to the possibility of redress, it must
be remembered that prosecutions were subject to the
judicial process. There is no automatic redress and
nothing the Government should or could intervene on.
Additionally, number of the subpostmasters pleaded
guilty.

"... this is only an interim report."

So, essentially, pouring cold water of a different
kind or a different variety in a number of ways on your
idea to take forwards what you had read?

Yes, it was. Obviously.

Are you able to recall whether that's what happened?
No, I don't recall this episode at all but it -- we'd

had this kind of discussion constantly about the kind of
public relations/communications issue, about how to deal
with them, and I had got the point fairly quickly that
this was something the Press Office and the officials
didn't want to make something of. So I'd deferred to
their judgement on public relations grounds.

I certainly didn't study the content of this minute in

any detail.

What about studying the reports, "Can I see the report,
there's obviously a difference of view here"?

Well, I could have done but I think it didn't ring
44

(11) Pages 41 - 44
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry 25 July 2024

a bell at the time that this was an issue. As I say, it

was just -- I was focusing on a different question,

which is the fact that the Government and Government
agencies were being more transparent, and I thought that
was the theme of the issue, rather than getting into

a debate about what the Government was actually doing in
relation to Second Sight. So I saw it entirely as

a rather simple one-line PR issue, and I was warned off

it and -- as I often was, and took no further action on

it.

Q. Would you expect to have been provided with a copy of
the report by your officials?

A. Not necessarily. Independently of this press issue, it
was proceeding under the overall oversight of the Post
Minister. I'd no reason to believe that it wasn't being
well handled by her and, indeed, it was being well
handled. So I didn't need to see the report and nobody
suggested that I read it.

Q. Would you expect to be provided with an impartial and
‘objective summary of the report?

A. Not necessarily, depending on whether it was potentially
controversial and might lead to difficult decisions but
this was -- I think it goes back to the earlier part of
our exchange, that this was a very small part of my
portfolio, I left it to the discretion of my private

45
(A short break)
(11.11 am)
MRBEER: Good morning, sir, can you continue to see and
hear us?

SIR WYN WILLIAMS: Yes, thank you.

MR BEER: Thank you.

Sir Vince in your witness statement you tell us in
paragraphs 61, 68, 69, 76 and 77 about some letters that
you received from James Arbuthnot MP and Adrian Bailey
MP --

A. Mm.

Q. -- on 11 and 17 March 2015. I'd like to just look at
those, please, and see what happened in relation to
them?

A. Sure, yeah.

Q. These are about the Second Sight investigations and the
Mediation Scheme and a report that they were publishing
or providing. Can we look, please, at the first letter
in, UKGI00003781. Can we see this is from James
Arbuthnot, it is dated 11 March 2015, to you. Scroll
down, please, he says:

“In [PMQs] today the Prime Minister told me that he
would ask you to write to me about the Post Office
Mediation Scheme. While there are many things that are

very worrying about it, what particularly concerns me is
47

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

A.
a
A

office and my ministerial colleagues to decide what was
sufficiently important to bring to me, and they clearly
judged that this wasn't necessary.

You had, it seems, seen or read the Private Eye article
and realised that it raised an issue of substance?

Well, I'd seen the Private Eye article. I didn't

realise that it had raised an issue of substance, no.

Why did you not realise that it raised an issue of
substance?

Well, because I'd probably glanced at it in two or three
seconds. That was the way we -- you know, I had to deal
with press cuttings. As I say, it was a very rapid
exercise, took ten minutes in the morning and I would
just pick up, usually from headlines, what were the
issues in the news that I needed to be abreast of.

Is that why you focused on it being a good news story,
rather than all of the parts of the article --

Yes, exactly right.

-- which point in the other direction?

Yes, exactly.

MR BEER: Sir, it's 11.00 now. I wonder if we might take

the first morning break until 11.10.

SIR WYN WILLIAMS: Yes, of course.
MR BEER: Thank you very much.
(11.00 am)

46

that the Post Office has recently been refusing to give
to Second Sight the documents and information that
Second Sight feel they need in order to determine
whether a miscarriage of justice has occurred.

I believe that the only legal folder, for example, that
Second Sight has seen is that relating to my constituent
Jo Hamilton -- but that folder did show that there was
no evidence (as the Post Office knew at the time) of
theft. Yet the Post Office charged her with theft. And
as a result she then pleaded guilty to false accounting,
having untruthfully been told that she was the only
person going through these difficulties.

"That suggests to me that there is more disclosure
of documents that needs to take place and that our
constituents will never believe that the truth has been
reached without that disclosure. Equally, that
disclosure needs to be made to Second Sight, who have
now built up the expertise to deal with it.”

If we look at the letter in from Mr Bailey,
POL00176637, page 3 and 4, please. If we just pan out,
17 March 2015, to you.

"Dear Secretary of State,

“As you will be aware, on 3 February the [BIS]
Committee heard evidence on the Post Office Mediation

Scheme. During this session, we were concerned to hear
48

(12) Pages 45 - 48
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

that the Mediation Scheme was not operating in the
matter envisaged when it was established.

“I was pleased to hear that since our evidence
session Post Office has agreed to take most cases
forward to mediation. However, I have a number of
specific concerns regarding Post Office's approach to
the mediation process, which I expect the Government to
be actively involved in addressing in order to ensure
they do not cause further issues in the future.”

Then Mr Bailey lists them. I'm not going to go
through them.

You tell us in your witness statement that you
replied to both letters, indicating that you had read
both letters, and that your response is in detail, and
that you did not accept your private office's advice
that you should approve the revised draft of the letters
out without reading them. Correct?

Yes, that's correct. I only became aware of these when
I was asked to sign an outgoing letter and, of course,
they are different sources -- one is Mr Arbuthnot and
the other is the Select Committee -- but, in my mind,
they were dealing essentially with the same set of
issues. And I got a draft letter from officials, and

I wasn't happy with it. It was partly, I think,

stylistic. I thought we should be a little bit more
49

happened here was that I realised that there's something
really rather important and bad going on because it

isn't just a campaigning MP, this is the Select
Committee, who were there to have oversight of what

I did, being very critical of the Department.

So I needed to really concentrate on the issue and
think about it, and I think it was only in March 2015
I realised there was some really -- something really
seriously bad going on. It was actually quite
difficult. I mean, I remember this period quite clearly
because I was in the middle of a crisis, the last big
crisis of my period in office, when I was having to
decide about the export of weapons to Saudi Arabia that
were being used to bomb civilians, and I was keeping
awake at night because either I'd have blood on my hands
or I'd make a decision that would put large numbers of
British workers out of work, so I was totally
preoccupied with that problem.

And in the middle of it, I was being asked to sign
letters about this Mediation Scheme. So I needed time
to think about it and I refused to sign the first draft,
for the reasons I've just given you.

Can we look at the draft you did sign, UKGI00003910.
This the letter back to James Arbuthnot, dated 17 March:

"Iam writing to you further to your question to the
51

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

deferential, respectful, to the senior gentleman, but
I think more a substance that I'd read the letter and

I realised that it entirely hinged on accepting the view

of the Post Office.

And I said "Well, are the postmasters happy with
this? I mean, that whole Mediation Scheme was for their
benefit, so do they accept it?" And so I said "I want
you to go" -- I asked the officials, who clearly wanted
me to sign this in a hurry, because we were almost at
the end of the Parliament, I said, "Look, I want to be
satisfied that the postmasters share the view of the
Post Office about this question".

So I declined to sign the letter until I had been
given evidence on that point.

Just on that point, you said that the reason for you not
following your advice was that the draft that had been
supplied to you depended on the accuracy entirely of
that which the Post Office was saying.

Yes, and I --

A number of the earlier letters that had gone out also
depended entirely upon the accuracy of what the Post
Office was saying. What differentiated this occasion
for you to say, "Hold on, I'm not signing that draft"?
Well, the difference -- I'm not sure that I did commit

myself in quite the same way earlier but, anyway, what's,
50

Prime Minister regarding the Post Office Mediation
Scheme on Wednesday last week, and your subsequent
letter.

"I appreciate you raising your concerns about the
Mediation Scheme in general, but particularly regarding
your constituent Mrs Jo Hamilton, who I understand has
a case in the scheme. I must first of all reiterate
that the Mediation Scheme is independent of Government,
and decisions relating to the scheme or its operation
are matters for the parties involved and not for the
Government."

Then if we go over the page, please, if you look at
the penultimate paragraph at the foot of the page, you
conclude by saying:

"... [note, through Second Sight's Report and the
subsequent investigations, there is no evidence of
system-wide problems with Horizon and that conclusion
has stood firm through nearly two years of
investigation. As such, the priority must be to ensure
that those applicants remaining in the scheme can have
their cases considered swiftly and fairly, and I am
hopeful that all parties will continue to work
constructively to ensure this can happen."

That sentence, "there is no evidence of system-wide

problems with Horizon and that conclusion has stood term
52

(13) Pages 49 - 52
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24

2

The Post Office Horizon IT Inquiry

through nearly two years of investigation", was that
a suggestion put to you by officials?

Well, it was but because I was confronting the issue

really for the first time, I wanted reassurance from the
postmasters that that was indeed the case, and I had
asked the officials to check with the Federation whether
this was indeed their understanding, and I was told that

it was and that the General Secretary or the head of the
union had appeared before the Select Committee and has
said he was satisfied that there was no problem.

So I was now being told by the officials, the Post
Office and the union that there wasn't a problem, so it
seemed to me perfectly reasonable for me to accept that
collective view.

Was that, in your mind, the critical turning point: the
views expressed by, I think, the General Secretary of
the NFSP?

Yes, it was. I had dealt with them before --

Had you dealt with him?

Not with him. Well, he'd met me, I think, on a couple
of courtesy calls --

Sorry, just to make clear, who are you referring to?
Sorry, my first dealings with the Federation, 15 years
earlier, had been with Mr Baker.

Colin Baker, yes.
53

there was something going on here and had I -- had
Parliament continued or had I been returned to office,

I would have got all these people around the table --
the Select Committee, Mr Arbuthnot, the Post Office
people and, for the first time, Mr Bates, I'd not heard

of him until this point -- and I'd have got them all
around a table and asked "What the hell is going on
here?" But I didn't have time to do that and I had to
make a snap judgement about whether to send out this
letter.

Can we look at the reply to Mr Bailey please,
POL00039281. Can you see 26 March and, if we just go
over the page to page 2, signed by you. Then if we go
back, please, to page 1:

"Thank you for your letter ... I am grateful to the
Committee for considering this matter and am pleased to
provide a response ... attached to the letter.

“It is important to reiterate that the Mediation
Scheme is independent of Government. Given that the
cases in the scheme are disputes between independent
business people and the Post Office, and are of course
sensitive and confidential, it would not be appropriate
for Government to intervene or seek to influence the
outcome.”

Is that what you understood you were being asked to
55

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

My second interaction had been when a representative --
I'm not sure who it was, whether it was Mr Thomson or

a regional head -- had come to see me about individual
cases, and I had met Mr Thomson. I think on couple of
occasions he had come to talk about the progress of the

Transformation Programme and the progress we were making

‘on mutualisation. So that was my extent of my dealings
with the union --

That he, in your dealings with him, ever struck you as

a tool -- meaning a tool of the Post Office?

Absolutely not. All my dealings with the Federation and
him personally, they'd struck me as people of high
integrity, who believed in what they were doing, as

trade union officials do. I had no reason to doubt

their integrity whatever.

Do you not need to see Second Sight's Report in order to
include a sentence or sentences such as these in the
letter?

Well, I think, given time, I probably would have done

and should have done but I think the context was that
we, within a day or so of the end of Parliament, I was
being pressed by the officials to get this letter out,

I think even when I was given the reassurance about the
Federation's view, I declined still to sign it, because

I had the - I was beginning to smell a rat. I mean,
54

do, to influence outcomes?

No, I think that wasn't the part of the letter that

I was focusing on. It was the implication that the
Horizon scheme was or wasn't functioning properly.

I wasn't -- as explained to you before the break,

I hadn't been given any briefing about the Second Sight
and the mediation process. I was, I suppose, privately
pleased that the suggestion I'd made 15 years earlier,
about setting up a mediation process, was actually
happening. The fact that it had not gone in an ideal
way was not something I was aware of until that point.
Then there's the line:

"Since the issues were first raised over two years
ago, [the system] has been under considerable scrutiny,
and ... it remains the case there is no evidence of
systemic problems with Horizon. That conclusion has
stood firm through independent investigation by Second
Sight."

Then:

"The vast majority of subpostmasters continue to use
Horizon successfully every day in operating their
branches ... There are fewer than 150 cases in the
Mediation Scheme, while there have been around 500,000
users who have worked with Horizon since it was

introduced, [it] processes over 6 million transactions
56

(14) Pages 53 - 56
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

o>

prop

The Post Office Horizon IT Inquiry

every working day."
Is that a line, a comparison, of the said to be

small number of cases where individuals were raising

a problem versus the number of users and the number of

transactions that was put to you by officials as

an important point?

Yes, it almost certainly was. I mean, I - it's

an issue that troubles me, and I'm sure the Inquiry to

this day, about -- those of us who don't really

understand computers and computer system, is why it

works almost all the time, but in some cases not, with

disastrous consequences. I mean, it needed somebody,

I think, to explain why --

Did anyone ever explore that with you or --

No, I wish they had. I wish they had --

-- and suggest that it doesn't really matter if there's

a large number of okay transactions because if --

No, clearly

Hold on. If you let me finish, Sir Vince.

Sorry.

If you're the person that has been sent to prison whilst

pregnant, if you're the person who has committed

suicide, if you're the person who has been made

bankrupt, it doesn't matter that quite a few other

people have been getting on fine with the computer?
57

briefing note says, in the top paragraph, that:

"James Arbuthnot ... has been the most vocal of
a group of 140 MPs campaigning for redress ...

"Speaking to Computer Weekly this week, [he]
expressed disappointment that a written answer to his
question during Prime Minister's Questions on 11 March,
which subsequently came from [you], followed the Post
Office's line closely.

“In response to the written answer to his question,
written by [you], Arbuthnot told Computer Weekly: 'The
Secretary of State has chosen to listen carefully to his
advisers and the Post Office on this matter rather than
seeking to understand why over 140 of his fellow MPs
have outstanding cases and unresolved concerns about the
matter. This is a shame. I remain quietly confident
that the truth will be revealed in due course and
I intend to pursue this matter until that happens."

Do you agree that 140 outstanding cases or 140 MPs
having outstanding cases represented a significant
number?

Yes, it is. It's appalling.

Was Mr Arbuthnot's statement that you had listened to
the Post Office and had not sought to understand why 140
of fellow MPs have outstanding cases accurate?

No, I hadn't just listened to the Post Office. That's
59

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

Of course it matters, it matters immensely, and enormous
harm was done. I think the problem, as I was just
trying to explain, for policymakers, is who -- who don't
understand anything about computers and computer
systems, is how it is that they seem to work almost all
the time but not all the time.

It's a concept here that I still struggle to get my
head around, why this was the case.
We've received a lot of evidence on precisely that issue
and the Inquiry understand how that occurs, concerning
code regression and the combination of a set or a series
of circumstances which, when they interact with each
other, can lead to undesirable outcomes?
Well, indeed, and I've read about that. But it would
have been helpful, when I was in Government, for
somebody to have explained how that was possible.
I believe the Computer Weekly people had some insight
into it but I went aware of their existence. And
Mr Bates too, it was only then, March 2015, I was aware
of his existence and he may have been able to explain
that.
Can we turn, please, to POL00153177, and page 15,
please. It's the top two paragraphs. We don't actually
have the Computer Weekly article that's here quoted and

so I'm using this as a source of the information. This
58

the whole point of what I was telling you: I only agreed
to support the official line on this when I was
reassured that the people who represented the
postmasters were content. It wasn't based on

an acceptance of the Post Office view at all. I would
never have signed it if that was all I was asked to do.

And I would just add a point, which I think we did
discuss briefly before, that what is strange about this
whole episode is that none of these 140 MPs ever came to
talk to me about it. I had some of them coming to talk
to me in my -- the privacy of my House of Commons office
about Post Office issues, like the last bank in town,
where the Post Office were not being very proactive.
Nobody came to talk to me about the Post Office and, for
example, the Chairman of the Select Committee, who
I knew very well and respected, he was a very good
Parliamentarian, had actually come to see me a few weeks
before this episode and all he wanted to talk to me
about was about the pub legislation, and never raised
the issue about postmasters. So I think I could be
forgiven for not understanding the weight of this 140 MP
campaign because none of them ever talked to me about
it.

He wrote you a detailed letter setting out his and the

committee's concerns --
60

(15) Pages 57 - 60
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

2

2

The Post Office Horizon IT Inquiry

Yes, but I think --

Was that not enough?

It certainly wasn't, no. I think all MPs realised that
writing polite letters to departments isn't necessarily

the way to get through to people at the top of
Government. You have to talk to them face-to-face.

So you do blame them for failing to come and see you?
No, I'm not blaming them. As I say, different people
have different styles. Some people operated through the
formal processes of Parliament, others didn't. No, it's
not a question of blame. As I say I had a great --
having seen the mountain of work that they did, have
enormous respect for them but it was -- let's just say

it was unfortunate that I never had any personal contact
with the MPs about this matter.

Would the outcome have been different; is that what
you're saying, Sir Vince?

Yes, I think it probably would have been.

In what way?

Well, because I would have realised much earlier than
March 2015 that there were serious problems that were
not being properly addressed by the Post Office and the
Department, and I would have started to interrogate it
much more aggressively, as I did long quite a lot of

other issues where MPs came to see me.
61

Can we look at that exchange, please, UKGI00004225,
and go to page 4, please. Email, 15 April, Laura
Thompson to, amongst others, your private office. Can
you see that?

Yes. Yes, I can.
“Hannah, Ashley

"_. we expect the next development in the Post
Office Horizon issue to happen tomorrow ... or possibly
Friday.

"Second Sight ... have completed their final report
into the matter. This report will be issued to all
remaining applicants ... later today ...

"Post Office advise that the report is poor,
containing unsubstantiated allegations and
misrepresentations ... they are issuing their own
response to the report alongside it.

"The report is designed to inform those applicants
in the scheme awaiting mediation. It is not designed to
be published ... once it is received by applicants ...
it will be leaked. Post Office anticipate this will
happen and are prepared to release the report in full,
alongside [its] response, to journalists on request

"[Post Office] will send a copy of the report and
their response to BIS later today ... This is in line

with the commitment that [you] made in [your] letter to
63

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

2

25 July 2024

Don't you think you would have been provided with
exactly the same Post Office lines by officials, and

they would have been sent out in the same way as we've
seen?

I might well have been and it might well have led to the
same conclusion but I would have been more alert to the
challenge that was being made in Parliament.

Can we go towards the end of this episode and look at
paragraph 79 of your witness statement on page 33.
Page 33, paragraph 79:

"On 15 April 2015, my Private Office was copied into
an email from Laura Thompson [a ShEx official] to the
BIS Communications Team concerning the imminent
publication of the Second Sight second report ... It
essentially said that the report was about to be
published, [Post Office] considered it to be of poor
quality and had prepared a response, that the report
would be provided to BIS in line with my response to the
BIS Select Committee and that there may be some media
interest. My Private Office responded to say that [you]
had noted the [concerns] of the email and was grateful
for the update. By this time, Parliament had dissolved
and preparations were under way for the general
election. [You] were unable to take non-urgent

decisions."
62

the BIS Select Committee last month.

"I understand from [Post Office] that, while the
report does not make any particularly new accusations,
it still contains criticism of [Post Office] and these
could be picked up by interested parties (probably Nick
Wallis from the One Show). However, it is important to
note that the report maintains the conclusion that there
are no systemic flaws in Horizon capable of causing the
issues that have been claimed."

Your office, I think, was told to direct all calls
to Post Office and seek Post Office lines; is that
right?

It appears so, yes.

Would you have seen this email chain?

I doubt it. It's possible. There was a great flurry of
activity, in the last few days of Parliament. I think

the judgement would have been that my sending those
letters to Mr Arbuthnot and the Select Committee was the
end of my involvement but it's possible I was shown.

So this being the last days of Parliament, or

a Parliament, it affected the extent of your

involvement?

Yes, and, indeed, the issue I referred to earlier around
Saudi Arabia was absorbing more and more of my time and

I think my officials understood I had to focus on that.
64

(16) Pages 61 - 64
©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

Would anything be done in those circumstances to alert
the new Secretary of State, if there was going to be
anew Secretary of State, as to the issues that weren't
being addressed because of the ending of this
Parliament?
Well, I guess I was hoping I would be the new Secretary
of State and I would have an opportunity to deal with
this issue properly. I mean, I'd realised, as I'd just
said to you, that there was something bad happening.
I tried to respond to it as best I could. I think the
rational approach of an incoming Secretary of State who
I hoped would be me would be to get the various parties
together, including Mr Bates, who I'd heard of for the
first time, the critics of the Post Office in
Parliament, in order to thrash out why these
discrepancies in interpreting the work of the computer
and the mediation system had arisen.

I mean, it would -- part of my role as Secretary was
convening, and I think what I should have done and would
have done, had there been time, would have been to have
dealt with the matter in that way.
Thank you, that can come down.

You tell us in your witness statement, it's
paragraph 140, that the Post Office Board was, in

retrospect, clearly a failure:
65

though it's fair to ask whether it's really for
a Secretary of State to be surfacing these issues or for
the officials in ShEx, whose focus was the Post Office."

Firstly, can you tell us what the something wrong
might be about two individuals, one the Chairman and the
second a CEO, attending a meeting at the same time?
Well, I suppose it's observations that have come from
later years and now, since I've left politics, I'm
involved in a Non-Executive Director role in companies
and I'm directly confronted with this whole issue of
Cadbury principles in business and the separation of
roles of Chairs and Chief Executives. I probably hadn't
appreciated at the time why that was important.

The Chair and the Chief Executive, when they came to
see me -- and I think it was only on two or three
occasions on courtesy calls -- were a double act and,
you know, in one sense, it's, you know, understandable
that the Chair would want to give encouragement to the
Chief Executive in delivering our big programme of
transformation. That's understandable, but I think
I now appreciated, having had personal responsibility
for corporate governance, that there is a separation of
roles and it might have been better in hindsight if they
had separated the roles themselves.

Did you ever have concerns about the competency of the
67

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

"I wish I had spent more time thinking about the
role and constitution of the Board and whether it was
doing its job properly.”

Can you tell us in greater detail, please, what you
think you should have spent more time doing, concerning
the role and constitution of the Post Office Board?

Well, in retrospect we know that bad things were
happening in the Post Office and that the Board were the
people who would have surfaced any disquiet and reported
it back to ministers and, if necessary, me, and so there
was a failure at that level. As to what I could have

done about it, I think, as I said earlier, I was wanting

to change the institutional arrangement so that the
postmasters had a bigger voice and an easy way of doing
it would have been to have insisted that postmasters and
their representatives were put on the Board.

At the time, it hadn't occurred to me to do that but
I know it's now been done.

You tell us in paragraphs 141 and 142 of your witness
statement that:

"I should have also noticed that there was something
wrong about Paula Vennells and Alice Perkins attending
meetings together, where Alice Perkins was supposed to
be supervising and independently scrutinising the Post

Office's Executive Team's performance. On these issues,
66

Post Office's senior management?

No, I didn't. I -- as I think I mentioned earlier,

I think at my first ever meeting with Paula Vennells,

I'd told her I didn't think much about Post Office
Management. I'd had very negative views about them and
I'd recommended, I think, that she should read my
Hansard report and think about it. But she had nothing
to do with that, she came much later and I certainly had
no reason to believe that she and her senior colleagues
were a problem.

Was it ever escalated to you that members of the Board,
individuals within ShEx, and some ministers, had
concerns about her competence and abilities?

No, it was never communicated to me.

Did the consistent complaints from subpostmasters that
were addressed to your Department not cause you to have
concerns about Post Office's management?

Well, I didn't know about the volume of them. As I say,
the one occasion I -- when an MP brought the Federation
to me, concerned, I think, 100 postmasters, which was

1 per cent of the total, I think, something of that

‘order of magnitude. Indeed, I asked the question at the
time, of my officials would they do some research, as to
into whether a 1 per cent prosecution rate was abnormal

in franchise networks. I said go to Londis and Spa, and
68

(17) Pages 65 - 68
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25 A.

10 Q

11. SIRWYN WILLIAMS: Before we go on, Mr Beer, can I just ask

22
23 = AL

The Post Office Horizon IT Inquiry

so on, and ask if this is normal. And the message came
back to me that it was normal and there was nothing
worrisome about it.

So the fact is that my limited knowledge of
complaints didn't suggest to me that at that point, that
there was a failing at the top management.

Can we turn, lastly, to some reflections you make at the
ending of your witness statement it's page 51 and
paragraph 144. You say:

"[You] have naturally reflected on what lessons can
be learnt from the Post Office scandal. A few
thoughts", and you set out five of them:

"[First] The relationship between the Post Office
and postmasters was, and is, highly unequal. In
comparable situations [you] promoted legislation
establishing independent regulators to protect the
weaker [parties].”

You've mentioned that already:

"In the case of the Post Office, a different
approach was tried ... but for a variety of reasons it
did not work. In future an independent
regulator/arbitrator should be appointed."

Can you expand, please, on what you mean by
an independent regulator and arbitrator?

Well, I can't expand a great deal because it was a sort
69

you: that I'd -- one of the things I'd done as

a minister was to set up these regulatory bodies for
industries where this was a common problem, which was
agriculture and supermarkets, and pubs and pubcos. In
introducing the legislation, it proved to be a lot more
complicated than I'd realised when I was putting the

idea out in general terms. But I think we should be
looking at those models and applying -- drawing on those
lessons to apply it in the case of the Post Office.

Over the page, please.

‘one question about the first subparagraph, just to clear
my mind.

Sir Vince, as you probably are aware, the Mediation
Scheme in 2013 to 2015 was just that, in the sense that
the parties, in effect, were free to choose whether to
accept what the mediator was trying to achieve. Does
your phrase "independent regulator/arbitrator” convey to
me that you think that there should be some kind of
scheme which, in effect, imposes a solution on the
postmasters and the Post Office, whether they like it or
not?

No, that's exactly what I envisaged.

24 SIRWYN WILLIAMS: Fine. All right. Thank you. Yes.
25 MRBEER: Thank you, sir.

ral

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

of concept and we actually, as we now know, the Second
Sight project led to a form of arbitration or dispute
settlement, which didn't work, once -- because the
details were wrong. So the concept was tried and didn't
work brilliantly well. But I think in the other cases
I had taken action, in respect of pubs and supermarkets,
a set-up had worked. The difference being that we were
dealing here with a state agency, and to have introduced
that kind of arrangement, I would have been asking to
set up an arrangement where the Government would have to
investigate complaints into Government, which would have
been a rather circular process. But I think the concept
of having an entirely independent arbitration process is
right, though, of course, the details also need to be
right.
You say, secondly:

"A related point is that UK competition law is
forced on distortion of competition resulting in
detrimental impacts on consumers. It does not address
market imbalances between large corporations and smaller
subcontractors or [franchises]. Consideration should be
given to addressing this.”

Can you expand, please, on what you have in mind
there?

Well, I think the answer is the one I've just given to
70

Over the page to 3, please. You say:

"The experience of Horizon has been that Post Office
Management, government officials and ministers did not
understand the workings and limitations of complex,
advanced computer systems. There have been many other
failures (as in the NHS). There is a case for
Government Departments and entities like the Post Office
to have a Board-level Technology Officer who is legally
responsible for validating the integrity of technology
systems in the same way that the Permanent Secretary is
Accounting Officer and company Chief Finance Officers
are responsible for accounts."

"Legally responsible", do you mean through
legislation?

Yes. Not that the individual would be subject to
prosecution, no; indeed, through legislation. I mean,

I was just attracted to this idea because of the
experience I had with the Permanent Secretary, who was
the Accounting Officer for BIS, and, if there was
something wrong in the accounts of the Department, he
would be hauled up before the Parliamentary Public
Accounts Committee. So there was a real accountability
here. There is analogous behaviour in the private
sector, obviously, with due diligence, and I thought,

since very few people in public life have any
72

(18) Pages 69 - 72
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

understanding of computers and systems, there needed to
be somebody who was properly qualified/knowledgeable,

who would take that level of responsibility, because,

I mean, some companies and Government departments, stand
or fall by whether their technology is working, and so

having a specific line of accountability would, in my

view, be useful.

Thank you. Fourthly:

"There appears to have been a failure of governance
in as much as the Board failed to identify a serious
failure and alert ministers to it ... When government
appoints members of supervisory boards of this kind it
is important that members are aware that their primary
duty is to protect the wider public interest. This may
involve creating a bespoke corporate structure with
specific legislative underpinning."

A couple of questions on that: you say that when the
government appoints members to a board it is important
that that member is aware that their primary duty is to
protect the wider public interest?

Yes.

Do you say that that is established already, that that
was the members’ duty?

I think it is implicit. But I think it was obvious --

Implicit how? I'm so sorry.
73

Well, because he was there to represent the Government
and the Government represents the public interest. As
I say, we can debate the different components of public
interest but he was the Government -- the Government was
the shareholder, he was there to represent the
Government and the Government, if it -- in a democracy,
is there to represent the wider public interest.
Do you think that was obvious at the time?
No, it wasn't, probably obvious and maybe, as I've said
in this note, we should have been, and should be
thinking a little bit more about the composition of the
board.
You say, secondly, that this would:
involve creating a bespoke corporate structure,
with specific legislative underpinning.”

Do you have this idea in mind in relation to the
whole range of public corporations in which the
Government is a shareholder?

Well, I don't want to redesign Government but we know
from the private sector, sometimes you have two-tier
boards, which is necessary to capture the variety of
stakeholder interest. I mean, when we talk about public
corporations, we're talking about some very
controversial bodies, like the BBC, and so the word

"bespoke" is to take account of the fact that these are
75

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

> oO

25 July 2024

In this case, of course, the -- there was a Government
representative on the Board --

Yes.

- but he or she was, I think, probably looking in terms
of the public interest, in terms of spending £2 billion
of taxpayer's money and making sure it was properly and
effectively spent, but there were other public
obligations, the welfare of postmasters being one of
them, and it was quite difficult for, you know, one
shareholder representative to carry out different,
possibly on occasions conflicting, aspects of public
interest.

So I think we probably hadn't thought through how
these different aspects of public interest were best
captured in the composition of the Board.

So the first question, your answer to the first question

is you think it was established that Mr Callard's

primary duty was to protect the wider public interest?
Yes, I think so. We can debate, you know, academically
about what public interest was but, yes, I think that

was clearly the case.

Why do you think that was clearly established, that his
duty was to protect the wider public interest, rather

than to be -- to hold and discharge the duties that any

other Board member held?
74

very different animals and require different treatment.
Fifth, lastly:

"There will need to be a review of the precise role
of Government in relation to [ALBs] as in the status of
Public Corporation under the 1969 Act. There is no
appetite at any level for politicians to be micro
managing organisations, like the Post Office (or
hospitals, colleges and government laboratories). But
an explicit mandate to deal with failing organisations
(as with schools, NHS Trusts and police forces) might be
helpful."

Can you explain what you mean by an “explicit
mandate"?
Well, the question I'm addressing here is one that runs,
I think, through the heart of this Inquiry: which is
this whole question of the distinction between
operational questions and strategic questions and where
you draw the line. And I think, in general, it is
sensible policy that agencies of Government should not
be micromanaged from the centre, whether they're schools
‘or public corporations.

But that does require some mechanism to ensure that,
when they go very badly wrong, there is an opportunity
for Government, the Minister sitting behind them, to

interfere, and I think this has been thought through in
76

(19) Pages 73 - 76
The Post Office Horizon IT Inquiry 25 July 2024

1 the case of schools and hospitals. It is clear that in 1 first. It'll only take a couple of minutes.

2 this case there wasn't a kind of emergency mechanism, 2  SIRWYN WILLIAMS: Certainly.

3 where probably my successors would have been able to 3  MRBEER: Thank you, sir. Can we turn up paragraph 90 of
4 move in very quickly and take over the organisation, 4 your witness statement, please. It's on page 36. About
5 appoint new management and start from scratch. 5 five lines from the bottom, you say:

6 Q._Incolloquial language, special measures -- 6 "It was clear that in my period in office the

7 A. Special measures. 7 operational failures were sufficiently widespread and

8 Q. --type enterprises? 8 serious as to justify Government intervention. But

9 A. Yes. 9 these were not identified or recognised within the

10 MRBEER: Sir Vince, those are my questions. Thank you for 10 Government. The reason, so far as I can tell, was that
1 answering them. 1 officials in ShEx were misinformed or lied to by their

12 A. Thank you. 12 counterparts in the Post Office.”

13 MRBEER: There will be some questions from Core 13 Then similarly page 41, at the foot of the page,

14 Participants. May I suggest we have our second break 14 paragraph 110, two lines from the bottom:

15 now until 12.10. There are about 45 minutes' of 15 "It is clear that in my period in office the

16 questions, sir, which will take us to the lunch break. 16 operational failures were not identified or recognised

17 SIRWYN WILLIAMS: All right. Thank you very much. 12.10. 17 as systemic, or engaging strategy. The reason, so far
18 MRBEER: Thank you very much. 18 as I can tell, was that officials in ShEx were

19 THE WITNESS: Thank you. 19 misinformed or lied to by their counterparts in the Post
20 (11.57 am) 20 Office."
21 (A short break) 21 Firstly, would you agree that there is a distinction
22 (12.10 pm) 22 between ShEx misinforming, on the one hand, or lying to,
23 MRBEER: Sir, before the Core Participants ask their 23 on the other, their counterparts in the Post Office?

24 questions, there's one matter that I'd omitted to ask on 24 Yes, indeed. There is an important distinction, yes.

25 behalf of a Core Participant, so I ought to do that 25 Are you able to assist the Inquiry as to the basis for

77 78

1 the assertion that any officials in ShEx were lied to by 1 Questioned by MS PATRICK

2 their counterparts in the Post Office? 2  MSPATRICK: Sir Vince, good afternoon. My name is Angela
3 A. No, nothing specific. I've been trying to follow the 3 Patrick and I represent, together with Mr Moloney KC and
4 Inquiry at some distance and that is the kind of 4 Hudgells Solicitors, a number of subpostmasters who were
5 language and interpretation that I've heard, and you've 5 convicted and have since had their convictions quashed,
6 given -- you've taken evidence from Ed Davey, who. 6 including Mrs Hamilton, who I'm sure you can see sitting
7 certainly felt very strongly that he had been very 7 to my right.

8 seriously misinformed or lied to, he wasn't clear which, 8 Yes.

9 and that matters might have been addressed if that 9 You'll be glad to hear I've got one issue I want to

10 information had been given to him. 10 cover with you in questions and it's looking back at

11 Q. Are you able to assist the Inquiry from your own 11 your witness statement. At paragraphs 117 to 118 you
12 knowledge, rather than having watched the Inquiry 12 deal with your knowledge and experience on the

13 proceedings, as to the identity of any individual within 13 backbenches before you came to Government, and you've
14 ShEx who was lied to by their counterpart -- 14 dealt win that a little with Mr Beer this morning.

15 A. No, I certainly can't do that. ShEx were one of many 15 I just want to look again at paragraph 118, if we could,
16 departments within the BIS. As far as I was concerned, 16 and if that could be brought up for you, I'd be

17 they were just part of the BIS Civil Service. We had, 17 grateful. It's WITN10830100, and it's page 44 at the

18 I think, 3,000 to 4,000 civil servants and I had no 18 top.

19 particular reason to reflect on who ShEx were in this 19 Can you see that, Sir Vince?

20 context and who the individual civil servants were or, 20 (No audible answer)

21 indeed, their relationships with the Post Office. 21 It says:

22 MRBEER: Thank you very much. 22 "From 1999 until 2003, I was the Liberal Democrat
23 Sir, those are the supplemental questions. I think 23 Trade and Industry spokesman ..."

24 it's Ms Patrick first and then Ms Page and then 24 You make clear you've never been the Shadow

25 Mr Jacobs. 25 Secretary of State and you say you are extensively

79

80

(20) Pages 77 - 80
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

involved in issues related to Post Office closures and
you remembered Alan Johnson introducing Horizon as
asystem. You've dealt with that a little this morning
with Mr Beer.

It's the second part I want to look at particularly
and if you see that there:

"When I was a backbencher, there were continuing
debates about government IT systems (the NHS and Inland
Revenue systems were complete disasters) so there was
acertain amount of scepticism about this new IT system
[Horizon], but we had no information indicating that
this one didn't or wouldn't work."

I just want to ask you a few questions about that.

So before you took up your ministerial role, you were

aware of continuing debates about Government IT systems
being problematic?

Mm.

Those debates were about IT failures in multiple public

IT projects?

Mm.

You're nodding, Sir Vince. For the transcript,
unfortunately, you have to either say "yes" or "no"?
Sorry, I was -- I didn't quite hear your question.
Sorry. You were aware, looking at your evidence, that

there had been IT failures in multiple different --
81

expected that kind of scepticism that you held about
public IT systems, and Horizon itself, to have been
adopted by others, including in the Post Office, in the
Civil Service and in other public agencies, contracting
for IT or managing IT systems?

Yes, I would have expected people to be in inherently
sceptical. I think, in the case of the Post Office,

I remember this was this flurry of concern when Alan
Johnson was the Minister, and quite a lot questions were
asked, including by me, but, by the time I had been in
Government, that was 10 years later and they'd had

10 years to get their system organised and iron out any
problems and as I -- I had no reason to assume that it
wasn't the working properly.

Putting Horizon to one side just for a minute, you were
aware of continuing reporting of problems in these kind
of IT projects, including in the public sector, at the

time you became Secretary of State?

Yes, that's fair.

I mean, just to be really obvious, from 2010 on, the
historic risk about IT, public or private, didn't go

away with the forming of the Coalition, did it?

No, I'm sure.

No. So if I take just one example, to see if I can

spark your memory a little. If I mention Libra,
83,

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

o>

p>po>

25 July 2024

Yes.

- public projects?

The answer is, yes, yes.

You give examples of the NHS and the Inland Revenue but
there had been others, hadn't there?

Yes, indeed.

This had informed the public narrative that Government
and other public bodies, when it came to IT, came with

a particular known susceptibility to a degree of risk;

is that fair?

I'm not sure this was necessarily just public bodies.

I think probably private companies had the same problem.
Okay. But there had been disasters which had been
particularly costly to the public purse, hadn't there?

Yes, there had. In fact, I -- shortly before I went

into Government, I remember taking Gordon Brown to task
because of the problems with the Inland Revenue and
large amounts of loss of money.

Yes, and there had been projects that were just, as you
put it, simply complete disasters in the sense that they
just simply didn't do what they were intended to do; is

that fair?

Yes, I think it is fair, yes.

You refer there in your witness statement to a certain

amount of scepticism about Horizon. Would you have
82

a system that was running in the Magistrates Court and
another system that had been developed by ICL Fujitsu
and it having been criticised in the mainstream media,
following what if it is work by the NAO in 2011, would
that have been something you'd have been aware of?
Not that specific case, I don't think so.

Again, stepping away from Horizon for a second, if there
were allegations and concerns about a third-party
contractor who was contracting across Government and
different public IT platforms, were there systems in
place for information sharing across Government
departments or public agencies where there were
different commercial contracts with different
departments or different public bodies?

I certainly knew nothing about that. The only -- trying

to help answer your question, that I think in the middle
of my period of Secretary of State, the computer systems
actually broke down in my Department and I tried to find
out why that was, and it was being blamed on me because
I had given instructions that contracts should be
awarded to small companies, rather than big
multinationals, where there was a choice. And it turned
out that the small guys hadn't been able to operate the
system properly. And unfortunately, the decision had to

be reversed. So I was aware that there had been systems
84

(21) Pages 81 - 84
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

failures, yes.
I think we are at slight cross purposes, Sir Vince. I'm
suggesting -- I'm just asking if you can help the

Inquiry understand, where you have different commercial
contracts with a third-party contractor, in different
Government departments or different public agencies, is
there a system across Government for sharing
intelligence about concerns that might arise in respect

of one contractor, albeit that there are different

contracts with different bodies or different public
departments?

Well, the answer is I don't know but I think that the
Cabinet Office were the people in Government whose job
it was to ensure that that kind of coordination took

place.

Okay. I think you've told Mr Beer this morning that
Horizon wasn't on your radar until fairly late in your
ministerial appointment. Whether in 2013, at the time

of the Private Eye article being circulated to you, or

later in March 2015, when you were dealing with the
correspondence around the Select Committee and James
Arbuthnot, if you had been aware either of difficulties

in the early development of Horizon and, separately, if
there were other difficulties arising in projects

developed or managed by ICL Fujitsu, would either of
85

Indeed, and the Inquiry has heard evidence about the
development and the management of Horizon throughout the
years and I'm not asking you questions about that
evidence.

But one final question: we've talked about issues
arising, can you recall whether there was any discussion
about the performance of Fujitsu as a repeat Government
contractor across departmental lines at any time when
you were Secretary of State?

No, I can't recall them. My dealings with Fujitsu were

in a totally different context because we had

an industrial strategy designed to develop manufacturing
industry and I think they were partners or part of the
ICT arm of the industrial strategy, and they contributed
to thinking about Government training, and so on. But

I certainly was never involved, to my recollection, in

any discussions about Fujitsu as a contractor.

Just to raise you having said that, and their role in

the wider industrial strategy, we know that the campaign
run by subpostmasters, including Mrs Hamilton, was
running well before you became Secretary of State in
2010. At any time when you were talking to civil
servants or other officials around the strategy and any
role played by Fujitsu, did anyone mention that they

were involved in these concerns around Horizon issues?
87

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

those matters have increased or decreased your
scepticism?

A. Well, as I explained to Mr Beer, I think the 2013 case,
I just saw as a public relations issue. I didn't
realise it was anything to do with policy. Perhaps
I should have read it more carefully but I didn't
realise at the time. And the 2015 case, yes indeed, all
of these issues came together, and I did realise there
was a systemic problem here because a lot of serious
people were questioning it. I don't remember the name
of the contractor to ever have been mentioned in this
context, but I'm -- as your question suggests, there was
an issue with them.

Q. Separately, would you have expected, if anyone in the
Post Office or in ShEx, or in any role responsible for
representing the interests of the shareholder, if they'd
had information about difficulties in the early
development of Horizon or difficulties arising in other
projects run by the contractor, would you have expected
them to have similarly increased scepticism?

A. Yes, I would but I think your phrase about the early
stages -- I mean, I think it was introduced in, was it
1999? So I think 10 years later, I would have expected
that, if there were any problems, they'd been dealt

with.
86

A. Not that I recall, no.

Q. Would you have expected that ought to have been
something that was raised with you?

A. Well, as I said, and in response to Mr Beer's question,
I did expect to have been briefed at the beginning of my
term of office, that questions were being raised about
the computer system by serious people, which they were.
But I was not briefed about it, no.

MS PATRICK: Thank you very much, Sir Vince. Those are all
the questions that we have.

THE WITNESS: = Thank you.

Questioned by MS PAGE

MS PAGE: Over to me now, I think, Sir Vince.

I'd like to ask you about your strategic objectives.

A. Yes.

Q. No need to bring it up but in paragraph 31 of your
witness statement you set out three strategic
objectives. The first was to secure funding for the
network and Network Transformation specifically, with
a view to stopping closures, yes?

A. Yes.

Q. Then your second was to separate the Post Office from
Royal Mail Group with a view to then privatising Royal
Mail Group?

A. Correct.
88

(22) Pages 85 - 88
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

>

The Post Office Horizon IT Inquiry

Then, finally, you hoped to mutualised the Post Office?
Correct.

How did you come up with those three strategic
objectives?

Well, it was -- I was responsible for the Department,

I'd had a background in Post Office issues, to a limited
extent. I think the overriding one of those three was
getting of funding for Network Transformation. It was
difficult because this was a time of austerity, most
Government services were being cut. I could see from my
having dealt with the Post Office Network that it was in

a state of collapse, it had fallen from, I think, 17,000

to 11,000 branches in the decade since I first raised it
and, unless something dramatic was done, there wasn't
going to be a network, although it mattered enormously

to millions of people.

So it needed an injection of cash and commitment to
turn it round and, certainly, whenever I met Post Office
Officials -- I didn't very often but, when I did, the
issue that was at the top of my mind was were they doing
this effectively, was it working? And it was, actually,
because I think, to my recollection, there haven't been
any more post office closures net since that time.

So that objective was your pre-eminent one. Your second

strategic objective, was that interlinked to it?
89

it, in at least this sense: that when all shares were

sold in Royal Mail Group, that brought in 3.3 billion

for the Treasury, didn't it?

Yes, there was a big dispute as to whether we could have
got more but, in retrospect, actually, the Royal Mail is
worth less now than when we sold it. So yes, I think
that was considered a success. I mean, the issue was
not actually simply a question of raising money; the
main reason we did it was to enable the Royal Mail to
survive. Its business was dying because --

To bring in private injections?

Yes, so the Treasury would not allow the Post Office to
raise -- would not allow it to borrow when it was under
public ownership. So if it was to finance its -- you
know, modernise, it could only happen in the private
sector.

But I asked you whether the two were interlinked and you
have suggested not. Are you saying that George
Osborne's Treasury would have given out £2 billion for
the network if there hadn't have been the promise of
£3.3 billion coming in from the sale of --

No, I think they were completely separate issues. We
had no idea at the time that the sale was launched how
much would be realised, and there was no connection.

Even though, as you said yourself, this was a time of
1

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

I don't think they were necessarily linked. The issues
around the separation of the Post Office and the Royal
Mail were essentially sort of technical and legal, and

I think they were handled very effectively by Ed Davey,
who did a lot of the preparations for that and the
legislation around it. I didn't get involved in that.

The third one, which I did care about, goes back to
when I was campaigning for the postmasters. You know,
we felt as a matter of principle that this was a very
unequal and unfair relationship, it needed to be
addressed and it needed radical change and we had
support for that idea from the Federation. So that was
how that originated. It wasn't -- it was quite
disconnected from the others.

Well, the second one, of course, was pre-existing in the
sense that the previous Labour administration had made
moves in the direction of separation and privatisation;
that's right, isn't it?

Yes, that's correct, yes.

Obviously, your first objective of securing the

£2 billion funding for the network, that did happen and
there was then a period of time over which that funding
was released.

Yes.

Your second objective was also a success though, wasn't
90

cutting back, a time of the launch of austerity, and the
Treasury was very reluctant to give out money?

Yes. No, actually, the big cost to the Treasury was the
cost of the pension fund. It swamped all the other
financial consideration.

That's certainly another factor, isn't it, because there
was some --

If I could just finish my answer. The reason we pressed
for it was for political reasons. It was -- certainly

I believed and my party colleagues believed, that the
Post Office Network was a major national priority and it
needed funding, and we, in the negotiations with the
Treasury, identified certain key issues -- and that was
‘one, and Catapult Network was another, I could list half
a dozen -- where we wanted more money, even at a time
frame when cuts were having to be made.

But you couldn't sell Royal Mail Group with the problems
that it had with the pension pot, could you? There was
a £28 billion pension pot there that needed to cover
£37.5 million of liabilities, didn't it?

Yes. It had to be dealt with before a sale could take
place. No shareholders would have taken it on
otherwise.

Although that was a problem in the sense that the

liabilities were greater than the sum of money there, in
92

(23) Pages 89 - 92
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

the short-term, for the Treasury, that was £28 billion
straight in the door, wasn't it?

Yes, indeed.

Albeit that there was then, for future administrations,

a long-term problem of £37.5 billion that needed to be
paid out in the future?

Yes, well, as you know, there has been a big argument
about the measurement of the liabilities of pension
funds, depending on the interest rate and the discount
rate. So, I mean, we could have a long debate about the
privatisation of Royal Mail but I'm trying to see the
connection with the Post Office --

Well, the simple point is this: those issues were
interrelated, weren't they? There was no way there was
going to be funding for the Post Office unless the
Treasury was going to get in both the £28 billion
pension pot and what was ultimately, although not known
at the time, £3.3 billion in shares?

I didn't see them as interlinked. I saw them as
separate problems.

How did the people within Post Office and Royal Mail
Group know about your three strategic objectives?
Almost certainly because I told them. I had a courtesy
meeting with the Chief Executive and the Chair, shortly

after the Post Office was separated and I spelt out what
93

[that's his intended statement about the Second Sight
Interim Report] should be considered in the context of
the Royal Mail privatisation ...

"Vince Cable and Michael Fallon are making
a statement to Parliament on Wednesday, 10 July [that’s
one day after Ms Swinson's statement], setting out the
steps towards a Royal Mail transaction. In the eyes of
many MPs, the media and the public at large, Royal Mail
and the Post Office are the same entity. Although not
related, the adverse coverage that Arbuthnot is seeking
to attract is likely to have a significant and
diversionary impact on the messaging of the Royal Mail
statement."

So those can come down. So here's the point, isn't
it, Sir Vince: that it was seen as essential not to let
problems with the Second Sight Interim Report get in the
way of a statement that you were about to make that
related to privatisation?

Well, that's your assertion, but I -- I don't think

that's correct, actually. I mean, I became involved in
the Royal Mail privatisation because it was highly
controversial and I had to lead from the front. It was
being led by a Minister of State but I got sufficiently
involved to be aware of some of the risk factors,

I don't recall this ever being mentioned. The big risk
95

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

I wanted them to do and the Post Ministers were aware
that those were our priorities and very aware of them
and carried them out.

Can I just then turn to some of the specifics about how
they may have related to what happened within Post
Office. In July 2013, you were making an announcement
in Parliament about privatisation and, shortly before
that, Jo Swinson had to give a short reaction in
Parliament to the Second Sight Interim Report. What I'd
like to be brought up, first of all, is her statement.

It's POLO0141558. If we just zoom in to the middle of
the second paragraph, there is just a one-liner and it
says this -- sorry, this is the second paragraph as we
see it on the page:

"It is important to note that the issues in the
report [that's the Second Sight Interim Report] have no
impact on Royal Mail, which is an entirely separate
business."

If we also go to a Whip's briefing that lies behind
that statement from Ms Swinson, if we could go, please,
to UKGI00001679, and we go to page 2, please, and under
a heading of "Wider impacts". As I say, this is the
Whip's briefing that sits behind the statement that Jo
Swinson made on 9 July:

“The timing of Arbuthnot's intended statement
94

factor was around the trade union, the CWU, who were
threatening to go on strike. That was a big risk factor
for the investors, and that was the one -- the only one
that I recall being discussed with any seriousness.

So this going on in the background, we can take it that
it wasn't something that was coming directly from you
but, nevertheless, this was, because you had
communicated your three strategic objectives, something
which people knew you needed to have happen. Right?
Yes, that's correct.

So whilst you may not have become involved in what
people at Post Office and, indeed, in Government
supporting Ms Swinson were getting up to, they were
helping, because they thought it was necessary, to get
the privatisation over the line?

Yes, well getting the privatisation over the line
depended on managing a group of risk factors. I don't
recall this being one of them. As I say, the risk

factors overwhelmingly centred on industrial relations
issues. It may be, as you say, that there were people

in the -- who were involved in the Post Office who were
worried that they might be creating a problem. The
people who had identified risk factors were the brokers
and the investment managers, and they would have said,

"This is worrying us". I don't recall they ever did.
96

(24) Pages 93 - 96
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

You may not have seen some of the evidence in the
Inquiry about Ms Vennells' work on the prospectus?
Okay.

She, in fact, managed to get a section in the prospectus
taken out that was going to be about the Horizon
problems.

Mm.

She told her Chair, Ms Perkins, that she had earned her
keep on that one. So that may have been an example, may
it not, Sir Vince, where you didn't know but the people
acting within the Post Office knew that there was a risk
factor that they wanted to take out of the picture in
order to help your strategic direction?

Yes, what you say seems to be perfectly fair. All I can
say is that I didn't -- I wasn't aware of it as a risk

factor, and I was involved in the privatisation, so

I would have, I think, known.

Yes. Well, let me just give you another example,
perhaps, of what may have been going on behind the
scenes. If I could bring up POL00296944, please. This
is an email between the Chief Executive and the Chair,
and it's about finessing the Second Sight Interim
Report. In that second paragraph, she's referring to
conversations that she had with her General Counsel,

Susan Crichton. She said:
97

that make sense to you?

Yes, it does make sense.

Yes. So this appears to be an attempt to have the
Interim Report's findings managed in a way so as not to
disrupt your strategic plans. Are you confident that
there was no one in Government putting any pressure on
Post Office to do that sort of thing?

Well, I simply I don't know. The ShEx, who were the
unit responsible for Post Office, were also the people
who were managing the privatisation from the BIS point
of view, so it was the same group of people. Whether
they acted the way you describe, I have absolutely no
way of knowing but I can see that, if you're looking

for -- no, conspiracy is too hard a word but, if you're
looking for attempts to manage the issue then what you
say makes sense.

MS PAGE: Thank you. Those are my questions.

Questioned by MR STEIN

MR STEIN: Sir Vince, my name is Sam Stein, I appear on

behalf of a very large group of subpostmasters and staff
that worked in branches.

I work with Mr Jacobs, who appears on my left, and
we are instructed by a firm of solicitors who have long
been a thorn in the side of the Post Office, called

Howe+Co.
99

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

"I caught up with Susan this evening after we
finished. She had finished her meeting with [Second
Sight] ..."

She says "wade" but I think we can take it that she

‘was
"... of the view that they do now understand the

risk of being caught up in something bigger and more

sensitive. She is hoping their report should be more

balanced, should say they have found no evidence of

systemic Horizon (computer) issues but will confirm

shortcomings in support processes and systems, and that

Post Office has already identified and corrected

a number of these."

Then she talks about James Arbuthnot:

"I hope when they speak to James tomorrow that they
will confirm all this. They will also want to say their
work is not finished and therefore still not
conclusive.”

Now, something bigger and more sensitive, this email
is on 1 July 2013. Ms Swinson was to make the statement
about the Interim Report in Parliament on 9 July, and
your statement about privatisation was on 10 July. This
again, rather looks as if this is people within the Post
Office worrying about Second Sight tying into something

bigger and more sensitive, ie the privatisation; does
98

Now, you've been asked a number of questions by
Mr Beer about the correspondence that either was or
wasn't sent through to your office, when you were
Secretary of State for BIS, and what happened to that.
I am just going to quote from paragraph 37 of your
statement. We don't need it on the screen. Sir Vince,
you say there this:

“Whilst Horizon was on a few occasions raised in
correspondence addressed to me, with very few
exceptions, my correspondence were dealt with by
Officials at the level of the responsible junior
minister, none of whom flagged these issues to me as
needing my engagement.”

That's what you've been said in your statement.
You've been asked a large number of questions about that
by Mr Beer. Okay.

Mm.

I'm not going to repeat those questions. I'm going to

go to a different type of information that BIS was aware

of.

Mm.

Can we go, please, to a document which is POL00141382.
The date of this document is May 2012. If you'll take

that from me, I'll be very grateful. Helpfully, for me,

you started as Secretary of State for BIS in May 2010,
100

(25) Pages 97 - 100
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

so this is pretty much two years into your time as
Secretary of State dealing with these matters.

You've just been asked a few questions that touched
upon Post Office Network Transformation. You're
familiar with the discussions about that and you'll
recall, I hope, that there was a BIS Select Committee
that was set up to consider issues that related to
Network Transformation at around the same time in 2012?
No, I don't actually recall that but I appeared before
the Select Committee every year and they interrogated me
about the things that they thought I should know.

Right. Now, this is the written evidence, as you'll

see, submitted by Shoosmiths solicitors, and you can see
there that, if we go to just a few of these paragraphs,
paragraph 2:

“Access Legal from Shoosmiths, a national law firm,
have been contacted by almost 100 SPMs [subpostmasters]
who have suffered losses they cannot explain and have
been subject to disciplinary measures by POL. All are
adamant that they or their staff have not stolen any
money. They claim that the Horizon system ...
an Electronic Point of Sale and accounting system POL
require them to use, has caused the errors or not
enabled them to work out why the errors have appeared in

the first place.”
101

The reasons they do this vary, but are typically related
to an inability to pay (often due to have made various
repayments previously) and a desire to keep the post
office open for their community. When doing the above
an SPM is committing false accounting, albeit not to
enrich themselves, or to deny POL what is rightfully
theirs."

So by the time we get to paragraph 8 we've got
a description, by a national law firm, representing 100
subpostmasters in May 2012, setting out real fundamental
difficulties with the Horizon system, people being made
to do things within their branches that they shouldn't
have to. So these are complicated, cogent submissions
being made by this law firm, Shoosmiths; do you agree?
Absolutely. Yes.
Now, did this information, this submission, get through
to you?
No.
Right. Help the rest of us understand why not. This is
a public consultation by a Select Committee in
Parliament, where these issues, which are serious, are
being raised in relation to Network Transformation,
which is meant to be informative for the Post Office,
"Get this thing up and running, get it back on its

feet", but the Shoosmiths solicitors are saying, "Hang
103

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24

25 July 2024

They go on to say there:

"They claim there has been no real investigation by
POL as to the cause of the losses that have appeared --
SPMs are expected to pay it back regardless of how it
was caused."

Go to paragraph 3:

"POL are adamant that the Horizon system has no
faults."

Go down to paragraph 7, please. What is being said
here is about:

"If the SPM ever faced with a loss when balancing,
the SPM is presented with two options on the Horizon
system: ‘Settle Centrally’ or ‘Make Good Loss’. Settle
centrally means that, according to POL, the loss can be
investigated. However the description of this from SPMs
means that it just means the loss will be taken from the
SPM's remuneration either as a lump payment or in
stages. If 'make good loss’ is selected the SPM must
make good the loss there and then out of their own
pocket. One of these options must be selected otherwise
an SPM will not be able to trade the following day.”

I'm just then going to touch on paragraph -- I think
itis 8. Yes:

"Some of the SPMs have told Horizon that they have

made good the losses when in actual fact they haven't.
102

‘on, there's a real problem here"; how come that didn't
get through to you as the Secretary of State for BIS?

I don't know why it didn't get through to me. My own
perceptions, as I tried to describe earlier, were based
‘on the contacts I had with individual postmasters, and

I was aware, as I've described, that there were some
terrible things happening, and the one that I cared most
about was in my constituency, and I'd contacted the
family and I said, you know, "What's happened? We've
lost our post office, you're being charged with fraud.
What happened?" And the explanation from the family -
I didn't speak directly to the postmaster -- was "We
think that we made a mistake, and we're being punished
in a ridiculously excessive way".

So that's how I started thinking about this problem
and, as I also said, I think around about 2012/13, I was
visited by the Federation -- a regional head or
a national figure, I don't know -- but I was visited by
the Federation, who had this scrap book full of
photographs of some of these postmasters who were in
terrible situations -- I mean, you know all about them,
they've been in the Inquiry -- and clearly very
emotional about it, and we sat in a meeting trying to
understand why this had happened.

And the theory they had, and I agreed with, was that
104

(26) Pages 101 - 104
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

what was happening was that mistakes were being made,
you know, obvious mistakes but, you know, postmasters
are handling vast sums of money and large numbers of
transactions, you know, perfectly honest, understandable
mistakes we all make in every aspect of live, and they
were being brutally punished for it. And that was my
understanding, it was this kind of ‘one strike and
you're out' policy which -- the way I interpreted it,
and the Federation, when they came to see me, confirmed
that view.

I don't ever recall this being discussed in terms of
Horizon problems. I mean, it may have been mentioned,
but it didn't register with me because other people were
giving a very clear explanation about why this was
happening. It reflected very badly on the Post Office
but it wasn't about computers.
Well, let's have a look at what is being said in a very
clear explanation a little bit further. Paragraph 8,
the description there of what is happening by SPMs that
are having to make good the losses, when they haven't,
and related to an inability to pay, desire to keep the
Post Office open for their community. When doing that,
the Shoosmiths submissions say this:

"When doing the above an SPM is committing false

accounting, albeit not to enrich themselves or deny POL
105

that right?
That's correct.
Well, let's deal with the NFSP, paragraph 17:

“National Federation of SubPostmasters -- the NFSP.
are the trade association for SPMs. They negotiate with
POL on behalf of SPMs and provide representation at
disciplinary meetings. They state publicly that there
are no issues with Horizon. Many SPMs report that they
receive no useful assistance from the NFSP when they
have accounting difficulties."

Then it goes on to reference to the Communications
Workers Union, the CWU:

"... the relevant union for POL employees, have
recently set up a branch to assist and represent SPMs."

So there the Government, BIS, is being told that
there is a problem with the NFSP and, if that had been
looked into, it would have been discovered that the NFSP_
was being paid off by the Post Office. To so all of
these issues were being set out lucidly, cogently, in
simple submissions, that 14 years later, we've been
examining through the Post Office Inquiry; all of these
points now we know to be true. But BIS did what, as far
as you know, with these submissions?
I have no idea what they did with them. On this

particular point about the Federation, I think I've
107

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

what is rightfully theirs.”

Paragraph 9, last sentence, losses that have been
discussed by Shoosmiths Solicitors, losses between
£6,000 and £150,000.

Paragraph 10:

"The SPM then has, according to POL, an opportunity
to explain the losses [and so on]. Typically the SPM's
contract will be terminated and POL will request any
losses that are repaid under the contract.”

Paragraph 12 we'll touch on and then I'll move on to
something that may assist in relation to the NFSP:

“If the loss is not repaid POL will prosecute the
SPM for false accounting. SPMs are typically advised by
their legal advisers to plead guilty to false
accounting, as in the above circumstances they will have
committed it. Many will be charged with theft or fraud
but these charges are typically dropped in these
circumstances. SPMs have been imprisoned as a result of
convictions for false accounting."

So, Sir Vince, my point, on behalf of the group of
people I represent, the subpostmasters, people working
in branches, is that these were all matters that could
have been investigated, that could have been looked into
by BIS, essentially the Department in control over the

Post Office, but this was never taken to your level; is
106

explained, in answers to Mr Beer, my dealings with them
were very limited but positive. I first brought to
Parliament the case of a postmistress who had lost her
post office, lost upwards of £100,000, and I asked for
help from the Federation to advise me, and they
succeeded in getting full compensation. So why would

I not think of this as an effective trade union?

And, similarly, in the other cases that were brought
to me, which I've already described, it was clear that
they cared passionately about the hardship that
postmasters were experiencing. I had no reason whatever
to doubt their integrity or their competence.

Let's move on through the chronology. This is 2012, two
years into your time as Secretary of State for BIS,

‘okay? Now, you've said this in your evidence: that by
the time we get to 2015, you'd realised something bad
was happening --

Mm.

-- and you say, and you've said to this Inquiry that

what happened at that stage was that that was the end of
your term as Secretary of State and you wish,
essentially, that you'd been able to stay on so that you
could do something about this. So your words were you
realised something bad was happening. Well, you're

right. Jacqueline Falcon was prosecuted in 2015 by the
108

(27) Pages 105 - 108
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

CPS for fraud. She was prosecuted for her work at the
Hadston post office, she'd worked there for eight and
a half years, in total she had worked in branches for
15 years, from the year 2000, Hadston branch for eight
and a half years, and losses below £1,000, a shortfall,
was discovered in that particular branch. The end of
2014, that was discovered. In 2015, early 2015, she by
that point, based upon advice, pleaded guilty to fraud,
into a suspended sentence for three months.

In 2015, Jacqueline Falcon was pregnant, going
through all of that, she was prescribed antidepressants.
So you're right, Sir Vince: something bad was happening.

Now when we try and understand what happened at that

point, when you hand over to the next person to take on
the job of ignoring the problems with the Post Office,
at that particular point, what did you do to say to the
next person, "Hang on, there's a real problem here.
Something bad is happening"?

A. Well, the answer is I was unemployed after the election
for two years, until I got my job back. But it appears
to be the case, and I was frankly shocked by this,
nothing to do with the Post Office but that when a new
Government comes in, they start with a completely blank
sheet of paper. I was never -- when I became Secretary

of State, the Civil Service would not tell me what my
109

SIR WYN WILLIAMS: Didn't we have evidence from the
Conservative minister who succeeded the Conservative
minister, I forget the precise dates, that that's
exactly what happened?

MR STEIN: Yes, well, I think we're establishing that, sir.
The question is whether it relates to --

‘SIR WYN WILLIAMS: I think Ms James said she didn't have
a briefing from Baroness Neville-Rolfe.

MR STEIN: My question related to whether, even if it's the
same minister, whether, essentially, they're not allowed
background to their own papers, if they carry on.

SIR WYN WILLIAMS: Sorry, that's a variation on it. Sorry,
Mr Stein.

MR STEIN: Now, we're going through time. As you say, you
spent two years outside of Parliament, then you come
back into Parliament. Yes?

A. Yes.

Q. So the timing we're now getting to, 2017/2018, you're
aware by that point that there are then, in 2019, the
judgments in the High Court.

A. No, I wasn't aware. No.

Q. Well, when were you first aware of the judgments by
Mr Justice Fraser, now Lord Justice Fraser, in the High
Court?

A. Well, I wasn't aware, I think, until this whole Inquiry
111

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

Pppropr

25 July 2024

predecessors had been advised on a whole range of
issues. It was thought to be improper, that we start

again with a new Parliament and we have to reinvent the
wheel. That unfortunately is the way government
operates.

But, certainly, if I'd met Sajid Javid, who was my
successor, and this issue had come up, I would have
certainly passed on that advice. But the way Government
works, there isn't a transition, there is no carryover.

It's entirely reliant on the Civil Service to maintain
continuity.

Sir Vince, we understand that that happens certainly
between the transition of one government from one party
to another, so recently, as we understand it, the
position is that the Labour Government will not have
access to Conservative Government papers. Does that
also happen, to your knowledge, in relation to the next
administration, even though it may be the same
individuals involved?

Well, it wasn't the same individuals.

No. It could be, though?

It could be.

Yes. Does that happen in the same way?

I don't know but I -- it's common sense to suggest that

it should.
110

process started and journalists started asking me about
it and what I knew, and following the evidence.

I certainly had lost all contact with this issue after

2015.

Okay. So when you came back into Parliament, and we
know that there were issues that were in relation to the
Post Office going through the High Court, you're saying
you were aware of that later, and you know that there

are issues being raised in relation to the criminal
appeals, did you look into any aspect of those matters?
No, I would have looked into aspects of those matters if
any of my constituents had become involved. I'd
reverted to being a backbencher -- I happened to be
leader of the party but that was a separate matter --

but in relation to Parliamentary business, I would only
have encountered them if postmasters in Twickenham had
been in this situation. I don't think there were any.

You see that represented an opportunity for you to do
what you've criticised other MPs for. So if you had
engaged with these issues, if you had read the judgments
from the High Court, had paid attention to what was
going on, you would have been able to say to the
Government at that time, in 2019, “Hang on, there's been
a problem here. When I was looking at matters such as

this, nobody brought this to my attention".
112

(28) Pages 109 - 112
©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

Well, had I known about it, I could possibly have
intervened in the way you describe but, when I came back
into Parliament in 2017, Government and opposition were
completely overwhelmed by the big new issue, which is
called Brexit and, as the leader of my party at the
time, I was having to devote 100 per cent of my time to
focusing on that, apart from the time I spent on the
constituency issues, and I raised issues for
constituents in Parliament in debate and questions.

I didn't range outside that -- well, there were many
‘outstanding issues. One of the things which followed me
was this Saudi arms deal, for example, and there were
half a dozen issues like that, that I dealt with in
Parliament, and I realised were still hanging around two
years later and I was being asked about them, and -- but
for the reasons I have given, I wasn't then in the
business of dealing with Post Office issues.
Last question. Let's turn it round the other way. Did
anyone in Government go to you and say, "Sir Vince I've
got these issues at the High Court. You may not or may
not know about them but let me tell you about them.
They've raised serious, deep rooted problem within the
Post Office about the Horizon system. It's a mess.
Total debacle. People being sent to prison under

horrendous circumstances, lives being ruined".
113

Questioned by MR BLAKE

MR BLAKE: Thank you very much. Can you give your full

oP

o>

p>po>

prop

name, please?
My name is Gregory David Clark.
Thank you. You should have in front of you a witness
statement.
Indeed.
Is that dated 28 June this year?
Itis.
Could I can you to turn to the final substantive page,
that's page 47.
Yes.
Can you confirm that that is your signature?
Itis.
Is that statement true to the best of your knowledge and
belief?
Itis.
Thank you very much, that has a Unique Reference Number
of WITN10900100 and that will be uploaded onto the
Inquiry's website.

Mr Clark, you were a Member of Parliament between
2005 and this year; is that correct?
That's correct.
You've held a number of different ministerial posts, you

served as Minister of State in the Department for
115

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

Did anybody come to you and say, "Sir Vince, what
were you told about this during your time at BIS"?

A. Nobody came to me and asked that question. I wish they
had --

MR STEIN: Yes, thank you Sir Vince.

A. ~ but they didn't.

SIR WYN WILLIAMS: = Thanks, Mr Stein.

Is that it, Mr Beer?

MR BEER: Yes, itis, sir.

SIR WYN WILLIAMS: Well, thank you very much, Sir Vince, for
making your witness statement and for coming to the
Inquiry this morning and answering questions from number
of people. I'm very grateful to you.

THE WITNESS: Thank you very much, Sir Wyn.

MR BEER: Sir, could we reconvene at 2.00 pm, please?

SIR WYN WILLIAMS: Yes.

MRBEER: Thank you very much.

(1.03 pm)

(The Short Adjournment)

(2.00 pm)

MR BLAKE: Good afternoon, sir. Can you see and hear me?

‘SIR WYN WILLIAMS: I can, thank you.

MR BLAKE: Thank you, sir. This afternoon we're going to
hear from Mr Clark.

THE RIGHT HONOURABLE GREGORY DAVID CLARK (sworn)

114

Communities and Local Government; is that right?
That's right.

You were Financial Secretary to the Treasury?

I was.

Minister in the Cabinet Office?

Yes.

Minister for Universities and Science?

Correct.

Secretary of State for Communities and Local Government?
That's right.

And, relevant to today, you were Secretary of State for
Business, Energy and Industrial Strategy, and that was.
between 14 July 2016 and 24 July 2019.

That's correct.

That was during the premiership of Theresa May?
That's right.

I'm just going to begin with a little bit of background
before your time as Secretary of State and if I can ask
to be brought up on screen POL00097393, please. I'm
going to take you to some correspondence relating to
a constituent of yours, and this is a letter from

yourself to the Right Honourable James Arbuthnot, and
you're in conduct with him regarding your constituent,
Mrs Pauline Thomson, who the Inquiry has heard from in

an earlier phase, who wished you to refer her case
116

pPrPorororop

prop

(29) Pages 113 - 116
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

2

prop,

The Post Office Horizon IT Inquiry

against the Post Office on to Second Sight.

"Mrs Thomson has now stated that she is happy for
Second Sight to proceed with an investigation of her
case and she has confirmed that she understand her
details will be seen by the Post Office."

Did you have a number of different cases around this
period from subpostmasters, as a constituency MP?
This was the only one in my constituency that I was
aware of at the time.
Thank you very much. You were corresponding with Lord
Arbuthnot in relation to --
Correct.
-- the Second Sight investigation into her case?
That's right.
Could we please turn to POL00232847. We're now moving
‘on from January 2013 to March 2015, so quite
a considerable time has elapsed and it relates again to
the same constituent, Mrs Thomson. In this letter,
you're corresponding with Paula Vennells about a letter
that Mrs Thomson received only a couple of days after
being told that her case would proceed to mediation?
Correct.
If we turn over the page, we can see the letter that you
have enclosed. The letter is marked as "Confidential --

Not to be disclosed outside of the Scheme and
117

particular case for the reasons I set out below.
"Responsibility for Losses
"Post Office considers that the question of
responsibility for the losses suffered in your branch
was appropriately addressed at the time of the
suspension of your contract with Post Office on
12 September 2008 and your subsequent prosecution and
conviction. It remains Post Office's view that the
conclusions drawn at the time were correct and nothing
in our own reinvestigation, nor in the review of your
case by Second Sight, represents a challenge to that
position.”
So a refusal to mediate the case on behalf of the
Post Office.
That's right.
Did you meet with this particular constituent at the
time?
I can't remember. I certainly met with her on several
‘occasions during the long period in which I've been
trying to help her resolve the case.
We'll come on to talk about the particular case in
a moment but, before I do, I will just take you to
a response that was received to your correspondence,
that can be found at POL00117339. Thank you very much.

So this is a response from Ms Angela van den Bogerd to
119

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

mediation", dated 5 February 2015, so it's during
a period where we know that the Working Group is being
shut down.

Yes.

I'll just read to you a couple of passages from the

letter that was sent to Mrs Thomson. It says:

“You will be aware that your case has been looked at
afresh and thoroughly reinvestigated by Post Office.

Your case has also has been considered by the Scheme's
independent forensic accountants, Second Sight Support
Services Limited. The reports of both of these
investigations have been shared with you.

"As you will know, Second Sight recommended that the
question of responsibility for losses incurred in your
branch should be mediated. In the event, the Scheme's
Working Group considered that the issue was suitable for
mediation on a deferred basis."

So it seems as though Second Sight and the Working
Group both considered that Mrs Thomson's case was
suitable for mediation.

Indeed.
Then the letter continues:

"I regret to inform you that, after careful
consideration, Post Office takes a different view and

has decided against proceeding to mediation in your
118

you and, if we scroll down, she says:

"There is, in fact, no inconsistency in the two
communications she received.

"The first communication she received enclosed
Second Sight's final independent review of her case,
including Post Office's investigation into the matters
it raised. In these reviews, Second Sight offer their
view as to whether a case might be suitable for
mediation. However, while this is their view, all
mediations are entirely voluntary. The final decision
on whether or not to mediate a case ultimately rests
with the parties involved. It follows that either party
can decline to take part.

"Mrs Thomson's case has been thoroughly
reinvestigated through the Scheme and, after careful
consideration of all relevant facts (including Second
Sight's final report), the Post Office has concluded
that mediation does not offer any realistic prospect of
resolving your constituent's complaint for the reasons
set out in our letter to her."

Prior to becoming Secretary of State, so in this
period, what was your understanding of the issues
relating to Horizon and Second Sight?

My principal understanding, I think, in fact all of my

understanding, came from dealing with Mrs Thomson, and
120

(30) Pages 117 - 120
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

it conditioned my view of certainly the management of
Post Office Limited. I mean, on the documents that
you've just put up -- I don't know whether we can have
that second one again -- that reply from Angela van den
Bogerd, I think she was called, I thought was
an impudent reply. She didn't answer the question as to
why Mrs Thomson was being refused the ability to
arbitrate.

Indeed, if we look at it, I think they even get her
name wrong. I've just noticed that --
That's going to be brought up on to the screen.
-- now. "Mrs Paula Thomson"; she's called Pauline
Thomson. It doesn't say why, it merely asserts that,
despite the fact that Second Sight and this panel had
recommended it, they say that "We simply decided that we
don't want to"; either party can decline to take part
and so they've done so. I thought it was an impudent
letter to receive in reply to mine to the Chief
Executive and it conditioned, as I say, my view of the
management of Post Office Limited.
Thank you very much. That can come down now. You took
office in July 2016.
Yeah.
I'd like to take you to the introductory brief that was

provided to you. That can be found at WITN10900103. At
121

Thank you. If we scroll down, we can see it begins by
outlining some key facts about the Post Office. It then
addresses the Department's role, and I'd just like to
read to you the first paragraph from the next page. It
says:

"The BEIS Secretary of State is the sole shareholder
of [Post Office], and UKGI manage that shareholding for
BEIS, representing Government as [the Post Office's]
shareholder and with a position on the Board. UKGI also
acts as a voice/guide for [the Post Office] within
Government and it maintains relationships with key
Department's such as HMT, Cabinet Office and DWP."

So it seems as though UKGI represent Government as
POL's shareholder but, at the same time, act as
a voice/guide for the Post Office within Government.
How does that work?

Well, how it worked then, before there was a team in
BEIS, was that regular meetings and briefings and
communications to do with the Post Office would come
from UKGI, principally, actually, to the Post Office
Minister at the time, rather than me directly as
Secretary of State. But, as I say in my witness
statement, one of the things that I instituted right at
the beginning of my tenure was to require each of the

Directors General, which is to say the layer below the
123

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

paragraph 33 of your witness statement, you have said
that you received introductory briefs from each of the

40 or so directorates in your Department; is that right?
Correct, as a standard, yes.

So is this kind of a brief that we're going to see, is

this typical of the kinds of briefs you would receive in
relation to the areas for which you had responsibility?
Fairly typical. I mean, some were more substantial than
others, for example at the time that I took office, one

of the first decisions I had to make was whether to
approve the -- Hinkley Point, the nuclear power station,
which was and is the biggest construction project in
Europe, I think, at the time. So, obviously, the

briefing for that was necessarily more substantial but

this was not untypical of many briefs that I received.

Are you able to assist us with who might have been
responsible for drafting this?

\ infer from knowing, I think, with the benefit of

hindsight, the structure of things now, that this would
have been from UKGI -- someone in UKGI, perhaps Mark
Russell, who was the CEO, who we may come on to discuss,
regularly briefed me, because I think I'm right in

saying that there was not a Post Office team within the
Department at that point, and so I assume that came from

them.
122

Permanent Secretary, to give me a weekly report, just to
me, of anything on their mind, and one of them came from
Mark Russell, who was the Chief Executive and,
therefore, the equivalent of the DG of UKGI.

And so, each week, I would get what was on his mind
through that directly, but most of the detailed
submissions and contact would have been with the Post
Office Minister.

Irrespective of individual personalities, is there

a tension between representing Government at the Post
Office and also acting as a voice/guide for the Post
Office within Government?

I think there is a tension in many respects that we may
come on to talk about in more detail. I actually think
there is a structural tension and, arguably, at least in

the view of the Department, something of a legal
tension, in that, in a fiduciary board, the

responsibility of a director, and the UKGI director was,
as it were, a fully fledged the director of the
organisation, there is a kind of unitary responsibility

to the company and, in particular, my understanding, and
certainly it's consistent with advice during this

period, was that, in terms of the Department, and indeed
the Government, directing or influencing the Board

through that director, that that was a perilous thing to
124

(31) Pages 121 - 124
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

do, that it was something known as the shadow director
risk, in which if you -- if, from the outside, whether
collectively or through an individual, you directed the
Board's decision, then you could be counted as

a director yourself.

In my view -- I'm sure we'll come on to talk about
this -- rather than seek to dance around that I think it
would have been better for it to be perfectly legitimate
for ministers and officials in the Department to input
directly without any of these -- this kind of tiptoeing
around, to the decision making of the Board. But no, it
was constituted that way, and that's how it was at the
time.

Moving down to policy areas, it says:

"Government's policy on the Post Office is to set
the parameters within which we expect it to operate
(reach of network, types of services it should seek to
offer) and then allow the business to operate
commercially, at arm's length from Government. [Post
Office] is a public corporation with a fiduciary Board
... Operational decisions are made by the CEO, Paula
Vennells, and her ... team, supported by the Board. CFO
Al Cameron, who are meeting, is the other Executive on
the Board."

That's another thing that we've heard quite a bit
125

Thank you. It seems there that you were going to be
meeting with the CFO, Al Cameron; do you recall

a meeting with Mr Cameron?

I do recall meeting with Mr Cameron and, indeed, other
executives throughout my period in office. What has
been a bit frustrating, and I think other witnesses --
including Sir Vince this morning -- have said, is that,

for reasons I don't understand, the Department don't
have access to -- whether they don't have at all --
ministerial diaries and minutes of meetings. That is --
that surprises me and disappoints me. So, in

a three-year tenure, meeting literally thousands of
people a year, I'm unable to say how often and when, but
certainly I met Mr Cameron and I probably, from this,

I met him shortly after this note was sent.

If we scroll down, we can see various headings, we have
"Ownership", "Services and Long-Term strategy”,
“Network" -- if we keep on scrolling -- at the bottom of
the next page, "Pensions", "Cash supply chain",
"Industrial relations", then we come to "Other issues".

Yes.
Under "Other issues", it says as follows:

"Following complaints from a small number of
subpostmasters regarding the [Post Office's] Horizon IT

(point of sale) system, an investigation was undertaken
127

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

2

25 July 2024

about: operational decisions.
Yes.

Was that something that could be easily separated out,
when it came to, for example, matters relating to
subpostmasters?

Well, I think -- as other witnesses have said, I think

there is no bright line, certainly there is no

definition that sets this out. The view of the

Department -- the inherited view across different
administrations of different parties -- was that

certainly what counted as operational included matters
like IT systems and the relationship with the
subpostmasters and, therefore, that was definitely in

that category. Things that were strategic, or obviously
was Government requirement on how many post offices were
to be there. But, clearly, and no doubt we'll come on

to talk about this, within the middle, there are

questions as to when operational matters become
strategic or certainly kind of proper for ministers, and

my view, as set out in my witness statement, is that

I think in certain government-owned organisations, of
which Post Office Limited is one, I think there is

a greater likelihood of that to happen than in some
others, for example Lloyds Bank, when it was owned by --

at least in part by the taxpayer.
126

by an independent firm, Second Sight, over two years.
Whilst this received relatively high profile press
attention no systemic issue with Horizon has been found.
However, affected subpostmasters continue to put
pressure on [the Post Office], the Criminal Cases Review
Commission are considering some cases where individuals
have received criminal convictions, and group civil
litigation is being launched against [the Post Office]
in the High Court."

It seems as though that is the only mention of
Horizon related issues within this brief; is that right?
Itis, yes.
Do you consider that brief to be sufficient?
Well, it contains, in my view, the crucial information
which is in that last sentence, I think it is, that the
Criminal Cases Review Commission are considering some
cases, by implication the safety of the convictions, and
that litigation is about to begin in the High Court.
That was -- that communicated what I thought was the
essential information on that.
Did it give you, for example, an idea of the scale of
the Group Litigation?
No, it didn't, clearly.
It begins by saying that there were complaints from

a small number of subpostmasters --
128

(32) Pages 125 - 128
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

o>

pPrororp

The Post Office Horizon IT Inquiry

Yes.

- regarding Horizon IT systems. Now, looking at it, do
you consider this summary to be an accurate and fair
summary?

Well, certainly it wasn't a small number. I think, if

I were to be fair to the authors, I think the number of
subpostmasters that were part of the group civil
litigation increased. I think it started off not small

but, you know, smaller than it ended up and that grew
over time. But, in some ways, the number was not the
most important point. It is an important point,
certainly, but I didn't think it was the most important
point because the most important point is that people
are talking about criminal convictions that are in front
of the CCRC.

My view is, and bearing in mind that I was working
with a constituent who was absolutely sort of an example
of this, if she'd been the only one, that would be
enough.

It refers there to Second Sight investigation and no
systemic issue with Horizon has been found. Were you
aware, for example, that Second Sight had produced

a report which identified two bugs that they went into
detail on, and a further bug?

I wasn't aware of that.
129

determination, the discovery of the truth about this,
was taking place through that process.

So, in that sense, I think it was proper that the
court was, you know, sitting, in some cases daily, to.
examine that, and so the updates, when it came to
Horizon, were on the progress of the litigation.

So the courts had charge of the matter?

Yes --

You were being updated about --

-- and the CCRC.

-- and you were being updated about their progress.

Yes.

But looking at this, this one paragraph, plus the weekly
briefings you've looked at, do you think that was

sufficient in relation to the overall picture of

problems with the Horizon system?

Well, I describe in my witness statement as "this

period" being a period, I think as I described it,

between two times and what I mean by that is that up
until, I think, 2015 prosecutions were being made of
subpostmasters. They had come to an end. The legal
processes had commenced -- both the CCRC, I think, had
commenced the year before, and the Group Litigation had
started -- I think I was appointed in July, in the

April. But they clearly neither had been resolved.
131

p>

©

1A
12
13
14 Qa
15
16
17 A.
18
19
20
21
22
23
24
25

©NOORON

©
2

"1
12
13
14
15
16
17
18
19
20
21
22
23
24 A.
25 Q

25 July 2024

Were you aware at this stage of any concerns about
an expert witness who had appeared in a criminal case or
criminal cases?

I certainly was not.

You, in your witness statement -- it's paragraph 36, you
say that you've re-read all 150 or so weekly updates --
Yes.

-- that were provided to you while you were Secretary of
State and there's minimal reference in there to issues
relating to Horizon.

Referring to the lit -- to Horizon, yes, and it was

through the lens of the litigation, essentially, it was

an update on that.

We'll come to examples and to detail but do you think
you were sufficiently briefed in relation to matters

relating to Horizon?

Well, were it not for the fact that these cases were

before the courts, what I say in my witness statement is
that view of the Department, and you may ask me about,
as it were, my own view of this, the view of the deposit
were that these matters were, essentially, sub judice

and were perhaps not technically so, but they were being
tested in two judicial forums, if I can put it that way:

‘one with the Criminal Cases Review Commission and the

other in the High Court and, therefore, the
130

So this was a time of limbo, in some sense, between
the entered of the Post Office making -- taking forward
prosecutions but before the opinion of the courts, High
Court, and the Court of Appeal had been issued.

So the role of the Government, I would say, in
resolving those problems, was -- and certainly sort of
mounting prosecutions -- was not the same as it was
before or after.

Could we please turn to POL00117715, please. On
becoming Secretary of State you received a letter from
Paula Vennells. That's 25 July 2016. If we scroll

down, she congratulates you on your appointment. If we
scroll down, we can see the significant strides in
modernising the network that she refers to and, if we go
cover the page, please, it says:

"We are therefore developing a new strategy to
2020/21 designed to strengthen our market position,
improve our digital capabilities and radically reduce
our operating costs. While this will require investment
to execute, it provides an historic opportunity to
complete the commercial turnaround of the Post Office
and put the network on a self-sustaining footing.”

Do you recall receiving this letter?
I don't recall it but I'm sure I did.

There's no mention in this letter of Horizon issues?
132

(33) Pages 129 - 132
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

Indeed.

Do you recall, in your early time as Secretary of State,
or even thereafter, discussing Horizon issues with Paula
Vennells?

I don't have any recollection of that.

How about Al Cameron, who you met perhaps more
regularly?

I can't remember that but, again, I would say that the
litigation and the Court of Appeal, the CCRC, they were
the most important parts of that. And as I say, the

view was that these were effectively being determined in
court, rather than between ministers and the Post Office
at that stage.

You say the view, that was of those who advised you; was.
that your view as well?

Well, so, going back to your first questions to me,

Mr Blake, I had an insight into this through one
particular constituent and it led me, I think, that
correspondence -- and there's others we might have
looked at -- that I didn't trust the management of the
Post Office, to be frank. So take that unilateral

refusal of -- to Mrs Thomson to have her case
arbitrated, despite the fact that the panel, whatever it
was, recommended it -- that led me to suspect that the

current management of the Post Office were not to be
133

a person of sort of blameless character, had been
treated in this way, not just charged and convicted, but
subsequently been treated in this predatory way by the
Post Office. There are letters about demanding
repayment of funds even after she was sentenced.

I was very keen that the courts would determine the
truth here, rather than relying on the Post Office.
Moving on in time now to 2018, can we please turn to
UKGI00007712. There seems to have been a letter to you
from Ms Eleanor Shaikh in respect of a subpostmaster.
This is a response from your minister, Margot James.
This particular version is unsigned, we have two
different versions, one from Margot James and we also
have a later one from UKGI as well. I don't think
whether we can say this particular one was sent or
wasn't sent. I think the assumption is that this did
go.

She writes as follows, you had been written to in
relation to the suspension of Farncombe village's
subpostmaster, following a sub post office audit in
2017. She sets out there that the Government recognises
the importance the Post Office plays, and then this
paragraph, she says:

"I should explain that the Government sets the

parameters in which the Post Office operates --
135

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

trusted to resolve some of these questions.

So the view of the Department, as I say, the
inherited view that Horizon IT systems, contracts with
subpostmasters, et cetera, were kind of operational, and
therefore, litigation around it was for the Post Office
itself. My view was to welcome the fact that court was
going to look at this, the High Court in particular.
I thought the authority of a High Court judge, and the
requirements of disclosure and all the rest of the
things, was a better way of resolving this than, as it
were, a process that involved the Post Office -- any
kind of arbitration with the management of the Post
Office.

So pausing there at, say, 2016, who, if anybody, did you
think should have been providing you with more
information about the Horizon system, or is it your
evidence that, in fact, you are satisfied with the level

of information you were being given at that time?

I would say that what I was -- I was relieved that the
High Court and the CCRC were, with the powers available
to them, going to determine the truth about what went
on. I had no evidence to think that the -- or to know
that the Post Office were behaving improperly but,
certainly, the experience of a constituent, who I should

say was a well-respected person in the community, was
134

including its geographic reach and the key services it
offers -- and then allows the Post Office to operate as
an independent commercial organisation within those
parameters. As such, we do not play a direct role in
the day-to-day responsibilities of the company, and this
will include matters concerning the investigation and
suspension of subpostmasters.”

Just pausing there, is there a difficulty with this
clear distinction when it comes to, for example,
prosecutions of subpostmasters? Do you consider
prosecutions of subpostmasters to be purely operational
matters or might there be more to it?

First of all, I didn't know that the Post Office itself
prosecuted at that stage subpostmasters. In the case of
my constituent, I'd known that the police arrested her
and so I kind of inferred from that that it was a normal
process. So I was not aware of that.

Irrespective of what happened in that particular case,

as a principle, do you see the prosecution of
subpostmasters to be a purely operational matter for the
Post Office or are they something else?

Well, I think that would -- I think it depends. Every
organisation will, from time to time, have instances in
which they have to take disciplinary action against

either an employee or, in this case, someone that it has
136

(34) Pages 133 - 136
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

rPOoOPrPSD

po

The Post Office Horizon IT Inquiry

a contractual relationship with, whether that's, you
know, a retail group, whether it's a corporation. So
leaving aside whether they should have the power to
prosecute themselves, the fact of people being
prosecuted, I don't think is necessarily a strategic

thing.

Whether -- I mean, what clearly does make it
strategic is whether those prosecutions were mounted in
a way that was, I'm afraid, corrupt and we now know,
from what has been disclosed, that the Post Office was
in receipt of information that at least one of its
witnesses, during those trials, was unreliable and,
certainly, I'm not sure of the timing, whether people,
once they knew it, were continuing to be prosecuted,
despite the knowledge of that. But, certainly, the case
that people that had been prosecuted had to live their
lives as convicted people because of it.

Now, that not only raises it to the level of
strategic, it raises it to the level of being totally
unconscionable. So from the spectrum of, you know, one
or two people in a large organisation being prosecuted
for misdemeanours from time to time, to what seems to be
the case, that at least in some parts of the management
of the Post Office, people were prosecuted, in some

cases jailed, in some cases people lost their lives, on
137

response to Ms Shaikh, this time February 2018. It
says:

"Thank you for your email of 13 January 2018 to Greg
Clark MP about Farncombe Post Office."

If we scroll down, very similar terms towards the
bottom."
Yes.
Again, same number referred to there, it's used over
11,600 branches, et cetera, and this one was sent by
Stephen Clarke of UKGI. Was he somebody that you worked
with?
I can't remember, I mostly dealt with Mark Russell who
was the head of the organisation but he may well have
been in meetings accompanying Mr Russell.
I want to turn now to the Common Issues judgment.
Can I just make a comment on that --
Absolutely.
-- since you put it up? I think, looking back -- does
it say what date of the letter --
If we scroll up, 13 January was the letter to you?
2018. Beginning of 2018. I think, if I look back, what
it would have been better to have said is what I've just
said to you: that actually these matters are being
tested by the High Court and we -- and will be

determined shortly.
139

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

the basis of information that we now know, and was known
to them, to be wrong, is of a whole different order.
If we look at the final paragraph there, it says:

"The Post Office have also assured me that they are
confident that their Horizon system is robust and
reliable. It is used by over 11,600 branches for
numerous services every day and has been for a number of
years. Itis right that the Post Office should
investigate these sorts of instances thoroughly given it
is charged with overseeing substantial amounts of public
and third party funds.”

Were you aware of these kinds of stock lines being
sent out to people who wrote to either yourself or to
your ministers?
I can't remember but it wouldn't surprise me. They
were, as you say, standard lines that had, I think,
prevailed for many years under different
administrations.

I -- if I saw this, I would have regard it as, in
effect, a holding line. It says, "The Post Office have
also assured me". It comes from Margot James but it
says "The Post Office have assured me". I wanted to see
the Post Office's assurances tested rigorously in court,
and that's what was going on during this time.

Can we turn, please, to UKGI00007733. This another
138

Thank you. I'm going to move to the Common Issues
judgment, the judgment itself was 5 March 2019.

It seems, certainly from the paperwork that we have,
that Horizon didn't really feature very much in your
briefings between 2016 and March 2019; is that a fair
summary?

Well, only to the extent that it was before the High

Court, it was obviously until the judgment was issued.
That was where, as it were, the action was, and there
were updates on that. The Post Office Minister at the
time, I think, got a regular update. I say in my

witness statement that there was some reluctance even to
give those factual updates of what was going on, but
that's not to say that I didn't regard that court

process, as I hope is evident, as being very important,
and the respective judgment as being important, because,
before we get to that judgment, you will see from my
witness statement that I took steps to, as it were, to
prepare for the receipt of that judgment, even to the

point of asking whether the Government Business
Department could have early sight of that judgment.

I was advised that this was not possible because we
weren't a party to the litigation.

I asked the Permanent Secretary, outside the UKGI

process, to advise me and the then Post Office Minister
140

(35) Pages 137 - 140
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

in anticipation of the judgment as to what his
assessment of how we should handle it was. So this -
throughout it I'd regarded this court process as being
extremely important and, therefore, the judgment I had
no idea what it was going to say, but I was looking
forward to it, shall we say.
Can we turn to the advice in relation to the draft
judgment. That can be found at UKGI00009076. This is
a ministerial submission to you of 1 March 2019, and we
see there you are noted there "To Note".
Yes.
Do you know who drafted this? There are a number of
names there?
I assume from deciphering the norms on these things,
that Tom Aldred, who was marked as the Lead Official,
I assume that he would have drafted it, but that it
would have been approved by Mark Russell. In fact
I required that Directors General approve statements
like this.
Thank you. It is headed "Judgment in Post Office Common
Issues Trial", and it says:

“A judgment in the Common Issues trial will be sent
to the parties next week ..."

If we scroll down, there's some advice. It says on

paragraph 5:
141

relationship with its subpostmasters and the management
of its IT systems are operational matters for Post
Office Limited."

So again, reference to operational matters:

"The legal defence and the costs involved are being
handled by them."

If we scroll down and over to page 3, please.
Paragraph 14 says:

"[Your Department's] Legal and UKGI legal advisers
have consulted relevant [Government Legal Department]
litigation advisers and advise that such an application
is highly unlikely to be successful."

So it’s unlikely to be successful if you did apply
to see the judgment in advance.

Then at paragraph 15:

"As well as being unlikely to receive permission,
the application for permission and the judge's response
will be made public. An application would run counter
to the position the Department has taken thus far
regarding this litigation (including in Parliamentary
Questions), namely that it is an operational matter for
[the Post Office."

Reference here to a position that the Department has
taken. Can the distinction between operational matters

and other matters, can that sometimes be used to advance
143

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

"You have asked for advice on whether we should seek
permission from the judge for ministers to have advanced
sight of the judgment."

Yeah.
If we scroll down and over the page to page 2, please.
We can see at paragraph 10, it says:

"Regardless of the legal findings, Post Office
expect the judge to continue to be critical of some
aspects of Post Office's handling of the case and its
treatment of claimants. We expect these largely to
relate to historic behaviour and do not believe that
[the Post Office] currently has problems with its
operational culture.”

Did you have at this stage any views as to the
current operational culture at the Post Office?

Yes, I -- my views of the -- well, whether it's current,

I don't know. Drawing from my experience with my
constituent, I am minded to think, inclined to think

that the management of the Post Office was insensitive
to and dismissive to the point of abject rudeness to
subpostmasters.

Paragraph 11:

"While [Post Office Limited] is 100 per cent owned
by [Her Majesty's Government], it operates as

an independent, commercial business. As such, the
142

a particular position?

Well, it was the longstanding position of the Department
‘over many years, over different administrations, that it
was the case that the contract between the Post Office
and subpostmasters and IT systems were operational and,
therefore, litigation around it was also operational.

My view was that that was entirely dependent on the
judgment of the court and, were the court to find, as it
did, that the Post Office had behaved as disreputably as
it had, then that marked it very firmly as strategic.

So he is reporting -- or repeating the inherited line.
In my own mind, I was very clear that the -- this
judgment was going to determine whether this was
operational or strategic.

Then at paragraph 16:

"Therefore, we advise that the Minister does not
seek permission to have early sight of the judgment.
UKGI will work with BEIS communications and with POL to
ensure that appropriate responses are made as soon as.
the judgment is out."

Can we please turn to UKGI00009137, please. And
this is a further submission a few days later, 5 March,
now. This is a submission from Alex Chisholm, the
Permanent Secretary, to you.

Yeah.
144

(36) Pages 141 - 144
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

9
10
"1
12
13
14
15
16
17
18
19
20
21
22
23
24

The Post Office Horizon IT Inquiry

He says:
"You asked me yesterday to look into some issues
relating to the Post Office and to advise both you and
Kelly on the way ahead."
Do you recall the conversation that you had with
Mr Chisholm at --
Not in detail but I recall enough about it to be able to
make some observations, if I may?
Yes, please.
So the timings you say, I think it was shortly after
that submission that we've just looked at. My view was
that the result of this court case, which I regard as
important, was about to come out. I had a notion that
this would be significant, and I didn't entirely --
trust is the wrong word. I wanted a different view to
the UKGI view, which we saw in the last submission. So
in the weekly meeting -- I had a meeting one to one with
the Permanent Secretary every week, normally every
Monday morning, and I said, "You give me, Alex, your own
view of this, write to me separately", and it's why
I think he describes it as a kind of personal minute or
something like that.
It's not a submission, which tend to be kind of
agreed across the Department by sort of multiple people.

This was direct from the Permanent Secretary to me and
145

that was directly for the Department. It may be that he
took that view, it may not be. So I think it would be
unfair for me to read into his mind on that.

Thank you. It then says:

"This is only the first of four trials scheduled to
continue until at least March 2020, and the final
‘outcome will not be clear until they have all completed.
Ministers will want to keep an appropriate distance from
the trial and not comment directly while it is sub
judice", which is the point that you made.

Indeed.

"([The Post Office] may wish to appeal if the judgment
goes against them). Personally I would not be surprised
if the proceedings uncovered some faults on both sides
of the litigation. Hence it would be especially

advisable to stay above the fray for now, leaving you
free to speak and act as necessary and in the public
interest once the matter is decided."

He then addresses the position of the interim CEO,
and is satisfied that Al Cameron is the right person for
that particular job.

Yeah.
Moving now to the judgment, so the judgment was
15 March --

25 A. So perhaps to just kind of comment on that, Certainly,

147

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

Kelly Tolhurst, who was then the Post Office Minister.
It says:

“The two most pressing issues relate to the court
case and the appointment of an interim Chief Executive

Then in relation to litigation, he says:

"I agree with the legal and policy advice that we
should not seek permission to see the judgment in
advance of it being made public, and not comment when it
is published. To obtain an advance copy we would need
to satisfy the judge that there was a clear public
interest in such. This is difficult in any case but
especially in one such as this where there are no
immediate consequences, and we have presented the trial
as being an operational matter for the Post Office."

That comes up back to the same point I was making
before as to the use of the word “operational” to
perhaps distance the Department from it.

Yeah.

Is that something you would agree with, that it was, to
some extent used, for purposes?

Well, it's hard to know what was in the Permanent
Secretary's mind when he wrote that. My own view was
that the court case and the judgment would determine

whether this was an arm's-length matter or something
146

paragraph 1 about the early sight of the judgment and
suchlike, that was a kind of second opinion that I'd

sought on the UKGI advice. That's just in summary.

That was broadly consistent --

He was effectively supporting the advice of UKGI on

that.

Where he says, "I would not be surprised if the
proceedings uncovered some faults on both sides" --
Well, I had more in mind -- I think it did echo that but

also that we shouldn't seek -- the key issue to hand was
whether the Department, rather than UKGI, who were
getting it anyway, should try to obtain the judgment in
advance, and UKGI said you shouldn't because there's no
precedent for this ever happening for a shareholder, and
the Permanent Secretary agreed. So, on that basis,

I think we didn't apply.

At this point, was there a difference in view that you

could sense between the Permanent Secretary and UKGI in
relation to where the fault may lie?

I don't -- I'm not aware of -- I can't recall any

difference at that stage, not to say that there wasn't

any, but I don't recall it. Although I think the fact

that I went to the Permanent Secretary and asked him to
give advice, as it were, on UKGI's advice, I'm sure, in

my mind, was that the Permanent Secretary was not, as it
148

(37) Pages 145 - 148
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

were, wholly on the same page in general as UKGI.
If I'd known him to have the identical view, there'd
have been no point going to him in the first place but
I didn't, and it was direct and personal to him.
Thank you. That can come down.
The judgment was 15 March, paragraph 51 of your
witness statement, you described it as seminal.
Yes.
Can you briefly assist us with why you considered it to
be seminal?
Well, it was seminal, as I set out in my witness
statement for -- in a number of respects. I mean, first
is that this was a long-awaited verdict, after a long
period of litigation, perhaps too long, and the parties
to it, the subpostmasters and mistresses, wanted to see
it. So -- but that's probably the most trivial sense in
which it was seminal.
It was seminal in another sense, in which it is the
first time, in my recollection or in my view, that
a court, a court of the land, had opined on this
question of justice for subpostmasters and mistresses
since the individual court that had handed down criminal
convictions. There'd been, you know, arbitrations that
had gone nowhere, there'd been, by now discovered but

didn't know at the time, a review by the Post Office
149

and, that evening I had an important commitment,
an irrevocable commitment in my constituency, but
I wanted to have a meeting to discuss the judgment, so
we did, at the first opportunity, which in this minutes,
this readout, is 9.45 in the morning, so I assume it
would have been 8.30 or something like that on the
Saturday morning.
Thank you. If we scroll down, can you assist us to with
who these participants are?
Yes, SoS, obviously me, Secretary of State; Kelly
Tolhurst was Post Office Minister at the time; Will
Holloway and Jacob Willmer were my inter-department
Special Advisers; Gavin Lambert was, by then, the
Director General, that's to say one below the Permanent
Secretary with responsibility for this area of policy;
Tom Cooper was the UKGI representative on the Board of
the Post Office; Tom Cartlidge was one of my private
secretaries, the duty private secretary -- it wasn't, as.
I recall, his specialism but it was Saturday morning,
and he obviously had drawn the short straw to be on duty
that weekend; and Hibaq Said, I assume -- it says "PS"
on there, it must be Kelly Tolhurst's private secretary.
If we scroll down to the detail, it says as follows:

"Kelly brought [the Secretary of State] up to date

‘on the judgment against [the Post Office], indicating
151

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24

2

25 July 2024

Chairman, commissioned by a silk and his assistant on
that. There'd been all sorts of things done internally
but this was the first time, since those convictions
were made, that a court had opined on it.

It was -- so that was, as it were, it was seminal in
anticipation. It was seminal in terms of its content,
because the judge was very clear the subpostmasters and
mistresses were right, and that the Post Office had
behaved disreputably, as I think I describe it, and to
the considerable detriment of the claimants.

Can we please turn to UKGI00009213. There was a meeting
on 16 March. If we could scroll down on this page,

please, at the bottom of the page we can see --is this

is an email from your private office?

Yes, "Clark MPST" is my private office.

"All,

“Thanks for joining the call this morning. A quick
readout below with actions."

So it seems as though there was a call with a number
of participants, if we scroll down we can see who
attended.

Can I just describe the context of that?
Absolutely, please do.
So the judgment was handed down on a Friday afternoon at

a time when I was in my constituency with engagements,
150

that the judgment was close to the worst-case scenario."

There's some detail there from Tom Cooper.

It then says:

"[Secretary of State] asked about the prospect of
an appeal by [the Post Office]. Tom Cooper discussed
the legal advice received by the Post Office. This
advice will require careful consideration. Tom
indicated that there are both legal and tactical reasons
for the Post Office to appeal and that it is most likely
they will do so. Appealing may be [unhelpful] in
reaching a settlement."

"May be helpful".

I was going to say, just pausing there, can you assist

us with the discussion regarding legal and tactical
reasons?

So I was incensed by that remark. It seemed to me that
this was a very important judgment that was strongly
critical of the postmaster -- of the post office, and
supportive of the subpostmasters, and it was instantly
evident that that needed to be accepted and acted upon.
And what really stung me was the use of the word
“tactical” in this:

".. there are ... tactical reasons ... to appeal
and that it is most likely that they will do so."

That suggested to me that this wasn't because there
152

(38) Pages 149 - 152
ONOaARWN

1A
12
13
14
15
16
17
18
19
20
21
22
23
24
2 a

©NOORON

"1
12
13
14
15
16
17
18
19
20
21 A.
22
23
24 Q.
25 A.

The Post Office Horizon IT Inquiry

was something unclear in the judgment. It wasn't that
there was some kind of area of law that needed to be
clarified or some material fact that was wrong. But
that it was, I could -- well, at least I inferred that
this was, in effect, to disadvantage to the
subpostmasters and their litigation, which should not
have been in anyone's mind.
There aren't speech marks around the word "tactical", is
that something you actually remember from this meeting
being mentioned?
Well, tactical, I assume, was mentioned because it's
a very specific word, and it's -- I mean, the fact that
it says -- I mean the private secretary is -- was a very
experienced private secretary. He captures two aspects,
both legal and tactical. So it was clearly pointing to
something other than the legal. And -- I mean, I say in
my witness statement that my reaction may have been
unfair, it might have done an injustice and perhaps it
wasn't intended in the way that I interpreted it.

But all I can tell you, and what I recall, is that
I took that as meaning that they -- there was
an intention to play -- it was a pretty appalling
thought -- a kind of legal game with this rather than to
respect the judgment.

Itthen says:
153

angry about it and, in terms of making clear, I don't
think I would have said, you know, "Let me tell you my
primary objective is to see justice done”. I think

I would have said -- did say, "my only objective” and
that's how it should be read.

It then continues:

"Where postmasters and mistresses have been treated
improperly they should be treated justly. It will be
necessary to consider the legal advice carefully to
ensure no activity by [your Department] will prejudice
any appeal.

"[The Secretary of State] and Kelly discussed the
possibility of making a statement. [Secretary of State]
resolved not to make a proactive statement. He asked
that an [Urgent Question] rebuttal be prepared for
Monday morning. He also asked that the Department put
at a statement making the point that we are aligned with
the interests of the postmasters but that we are still
going through the legal process.”

Do you recall if that statement went out or not?
Yes, it was a -- I think in the evidence that was
disclosed, there was a written ministerial statement
that I think was issued on the Monday morning.

So that's a written ministerial statement --

Yes.
155

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

po

2

rPOoOPrPSD

25 July 2024

"[The Secretary of State] made clear his primary
objective is to see justice done.”

I think in your witness statement you've said that
that is a diplomatic way of putting it.
So, for those that are not -- have the good fortune not
to be connoisseurs of kind of ministerial minutes and
readouts, there is a general understatement to what is
kind of recorded in this. But there is a kind of code
that I think people understand if they read it, and
whenever it says something like "Secretary of State made
clear", that means that I intervened with some force on
the issue. It's not "Secretary of State said" or
"Secretary of State observed" or "Secretary of State
suggested". "SOS made clear" is, if you take evidence
from other civil servants, I'm sure they will confirm,
that means something. That means that this was a pretty
emphatic.
Is that one level below "full and frank"?
I think it's probably a level above. I think it
probably implies that I was pretty direct about it.
It then continues:

“Where postmasters" --
Before you go on, can I have a quibble with this?
Yes.

I think I recall my demeanour on that call. I was quite
154

-- when it refers to a statement?

Correct.

Yes. "We should also" --

It was probably a press statement as well. Actually

I think -- I suspect it was both.

"We should also do a Dear Colleague letter promising to
revert to the House when the legal matters are
completed. It should be robust in tone and making clear
that the litigation is ongoing and that [Her Majesty's
Government] will keep the House updated.

"(The Secretary of State] made clear that where [the
Post Office] can fix problems internally before the
conclusion of the legal process, it should do so."

It then says:

"He agreed with Tom Cooper's assertion that caution
would be required to ensure that justice is done for
legitimate claimants, but that restitution may not be
appropriate in all circumstances."

Now, I think you've said in your witness statement
that the reference to "your agreement" is, again, the
Civil Service speak of --

So I think both of these are a little opaque. The first
sentence of that paragraph, "[Secretary of State] made
clear that where POL can fix problems internally before

the conclusion of the legal process", my recollection is
156

(39) Pages 153 - 156
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

I told them to get on with giving restitution to
postmasters and mistresses. There was enough in the
Common Issues judgment to -- for that to be any
initiated.

They'd waited long enough and they shouldn't, as it
were, wait for the conclusion of the process. They
should get on with it.

To this last point, so Tom Cooper -- so -- and
I think -- I infer from the last sentence that, in the
sentence before, that they should give restitution to
the postmasters and mistresses, I think I said
comprehensive restitution. They should all be put in --
financially, at least, in the kind of position that they
should have been in, had this not taken place, to which
Tom Cooper clearly made an observation that I think has
been familiar from other evidence that the Inquiry has
taken, that, well, you know, there may be some people
that actually were convicted and were genuinely guilty
of criminal deeds, and it would be an abuse of public
money if they were compensated when they shouldn't be.

To be frank, I didn't have much patience with that.
I didn't think that was the import of the judgment.
I don't recall Mr Justice Fraser as having made a kind
of great play of that. But, you know, it's hard to

dissent from noting that, yes, of course, if someone
157

If we scroll up, Mr Cooper responds:

"Really?"

Then Mr Watson said:

“Are you free to speak?"

There is a further correspondence on the same point,
if we turn -- the last document before the break -- to
UKGI00009308. Perhaps if we could start with the bottom
of page 3. We have, if we scroll up, Mr Chisholm's
view, as expressed to Mr Cooper, regarding recusal. He
says:

"I have now read all this legal advice.

"Personally I find Justice Fraser in this case (as
in the Magnox case) to be opinionated, exacting, and
rather inclined to personalise matters. But not (to my
layman's mind) obviously wrong or biased.

"I also share the concern that a recusal attempt
risks further antagonising him (if unsuccessful) and
also positioning [the Post Office] in public as
aggressive and in denial about its shortcomings (which
impression would be consistent with the judge's findings
to date).

"However my personal view of the case -- formed from
a rapid perusal of the judgment and all the legal
commentary you've kindly provided -- does not matter as.

(a) I am not a lawyer and, anyway (b) the Department is
159

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

clearly isn't entitled to it, they shouldn't get it.
But I -- there's not much emphasis I would have placed
on that aspect.
Thank you. I'm going to turn to two related documents.
Can we please turn to UKGI00009296, please. This is
internal UKGI correspondence. If we scroll down, we can
see an email there from Richard Watson to Tom Cooper,
and he says:

"Tom, I spoke again to BEIS Legal. While they agree
it is a Board decision we think that if [the Post
Office] decides to make the application it should leave
open the possibility that the Minister, after her
discussion with Tim tomorrow, would want to say the
shareholder disagrees."

This is talking now about the recusal application.
Itis.
“Legally the shareholder cannot force the Board not to
make the application and our advice to the Minister is
not to get involved but if she is adamant she does not
want it made that may be a matter the Board will want to
consider.”

So this is 19 March and it's a discussion about
whether or not the Minister should have a say in the
decision to recuse.

That's right.
158

not controlling the case -- that is properly a matter
for the Post Office and their advisers."

If we just scroll down, I will just read a few
passages from the bottom of that email, it goes on to
say:

"Proceeding with the appeal and recusal attempt,
risks identifying the organisation's leadership today
with the negative historic behaviours of which [the Post
Office] stands accused. But it is not obviously
mistaken or otherwise inappropriate.

"The Board will want to reflect carefully on all
these matters. For my part I am satisfied that [the
Post Office] Board is the right body to do this; and
that it has been properly advised.

"The Department should maintain its clearly distinct
and detached position, so that it is free and credible
for dealing with the consequences as they unfold.
Ministers may want to show appropriate concern about the
criticisms and may express a desire for [the Post
Office] to act appropriately but should not comment
substantively in ongoing litigation in which the
department has a clear interest but no direct
involvement."

If we scroll up, we can see that Mr Watson, Richard

Watson, says:
160

(40) Pages 157 - 160
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

"Thanks. Alex sums up my view perfectly.”

If we scroll up, we have a further email, from
Mr Watson, that says:

"All

"Are we agreed that we should not try to engineer
a position today whereby if the Board decides to proceed
with recusal the Minister is given a chance to object,
ie some sort of conditional Board approval. As
shareholder, I don't consider she has the legal power to
prevent this even if it was an appropriate thing for her
to express a view on, which I think we agree it isn't
but instead is properly a matter for the Board.

"It is of course proper for the Minister to
understand [the Post Office's] decision and why their
position might have changed since her call with the
chair on the weekend. I understand that might be
subject of a call with the Minister later today."

Then Tom Cooper responds and he says:

"I have no intention of engineering such an outcome
of the Board meeting.”

Finally, if we scroll on to the first page,
Mr Evans, who was Deputy Director, in BEIS Legal
Advisers, he says:

"Clearly the Minister should be given an opportunity

to understand [the Post Office's] decision but it is for
161

the same as that. They were going to do it I think the
next morning.

From memory, I think I was either out of Parliament
or the Department, I suspect it was an evening, I was
probably speaking at some industry dinner somewhere. So
I don't have access to these things, unfortunately, from
my private office but I think that I called the
Permanent Secretary and asked him to get to the bottom
of this and to advise Kelly and the Board as to what we
could do about it, and I think that is why his advice --
I note this email is 9.23 on the Tuesday evening, so it
to suggests that it's late at night.

If I may make a couple of observations on the
handling of this.

So the first is to say that I thought it was
outrageous that UKGI contrived to keep the unambiguous
view of ministers from the Post Office Board in making
the consideration of this. It was my view, it was Kelly
Tolhurst's view, even to the point - and you had it in
the email that was up -- about looking for
an opportunity even for the Minister, once they'd made
their decision, and the strong legal advice from two
sets of legal advisers was that it had to be made by the
Board but, even after they'd made it, should it be for

recusal, we were minded to want to disassociate
163

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

the Board to decide whether to apply for a recusal (or
the variant described by Tom) guided by their officials

and counsel and there should not be a situation where

the Board takes a decision subject to endorsement or
otherwise by the Minister. This should be a decision

that is taken by the Board, on the merits of the

litigation advice."

Can you assist us with what your view was on the
recusal application at that point in time?

Yes. I think it's a very important episode because it
indicates that, notwithstanding the strength, and

I would say unambiguous nature of the view that I and
Kelly Tolhurst -- I should say, throughout this, the

Post Office Minister's view, from whom you heard earlier
this week, was identical to mine in this -- in every
conceivable respect, that the Post Office needed now to
accept the judgment, give restitution to subpostmasters,
and change their whole approach.

And yet, we discovered -- I only discovered, I think
it was on the Tuesday evening -- so that call was on the
Saturday morning on the Tuesday evening, I got a message
from Kelly Tolhurst asking to speak to me to say,

"You'll never guess what, they're now tying to recuse
the judge and I'm completely against it, as being

incompatible with what we said”. My view, again, was
162

ourselves from it at the time. And that exchange about,
you know, I'm not going to -- I can't remember what the
words were -- "I'm not going to engineer a situation
that was possible" --

"I have no intention of engineering such an outcome at
the Board meeting."

I thought that was wrong and appalling.

In terms of the discussion at the Board, I haven't
seen -- perhaps the Inquiry has seen -- any kind of
verbatim account of what was discussed at the Board, but
the advice that Alex Chisholm as Permanent Secretary
gave on my request, it went to Tom Cooper, as to what he
could do and what he could say. Even though it was, to
my taste, a bit to on the one hand and on the other,
I would have preferred a more robust piece of advice,
saying ministers are strongly opposed.

Actually what he does say -- and you highlighted it
when you called up the document:

"Proceeding with the appeal and recusal attempt,
risks identifying the organisation's leadership today
with the negative historic behaviours of which POL.
stands accused."

Then he says:

"The Board will want to reflect carefully on these

matters."
164

(41) Pages 161 - 164
©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24

The Post Office Horizon IT Inquiry

Now, in my view, that aspect of the Permanent
Secretary's advice should have been put to the Board so
that they could consider that not only were ministers
strongly opposed to this, even accepting that it was
a decision for the Board but that the Permanent
Secretary had some apposite things to say on what they
should have in mind.

I'm not certain but it was -- the impression that
I've formed, is that there was a discussion in which --
forgive me, it's not clear to me whether Tom Cooper said
anything. He recused himself from the vote but whether
he did what was advised by the Permanent Secretary and
set these concerns out, in my view, he should have done.

MR BLAKE: Thank you.

Sir, that might be an appropriate moment to take our
mid-afternoon break.

SIR WYN WILLIAMS: Yes, certainly.

MS PRICE: Can we come back at 3.30, please?

SIR WYN WILLIAMS: By all means, fine.

(3.17 pm)

(A short break)

(3.30 pm)

MR BLAKE: Thank you, sir. Can you see and hear me?

SIR WYN WILLIAMS: Yes, thank you.

MR BLAKE: Can we turn to BEISO000070. Sticking with the
165

Tolhurst called me on the Tuesday evening, I think it
was. But I note -- I think, this thing into which I was
copied would be the first I knew.

Q. We--

A. The confirmation of it. That wasn't the first I knew
but this was the first kind of official submission.

Q. Thank you. If we scroll down, we can see it says:

"On 20 March, [the Post Office's] Board met to hear
legal opinion on the recusal application, and to take
a decision on whether to proceed. Tom Cooper attended
as the shareholder's representative to the Board, but
following advice from UKGI Legal, he took no part in the
decision making.”
Your Department ultimately would have been funding

this application; is that fair?

A. No, I don't think that's strictly right. So the Post
Office were funding the application. Now, of course,
the Government stood behind the Post Office and there's
a perfectly legitimate question you might go on to, is
again, how arm's length can that be? But, certainly,
throughout it, the Post Office, were -- and I think
the -- there's some evidence that the Permanent
Secretary reiterated that this had to come from the Post
Office's own resources.

So this wasn't, as it were, sort of coming to the
167

ONOaARWN

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

recusal application, this is a submission of 21 March
2019. The summary is that:

“Following independent legal advice, [the Post
Office] Board has approved an application to recuse the
judge. We expect this to be tabled today."

If we scroll down, please, it says:

"[Over] the weekend you spoke to the Secretary of
State and separately with the [Post Office Limited's]
Chair Tim Parker”, so this isn't a ministerial
submission to yourself, although you are --

It was to the Post Office Minister, I assume, is it?
Yes.

and interim CEO-designate Al Cameron. [The
Post Office] informed you that they were taking
independent advice on whether to seek an application for
the judge to recuse himself from hearing the rest of the
litigation. At that stage, Tim thought if it unlikely

that an application would be taken forward. Following
these calls, on Monday, 18 March, you sent a Dear
Colleague letter to update MPs on events.”

Were you aware that it was originally Tim Parker's
understanding that it was unlikely that there was going
to be an application for recusal?

Only from this, I didn't know that there was any thought

given whatsoever to a recusal application until Kelly
166

Department to fund that, not that it makes it any more
acceptable, in my view.

\s it right for the UKGI member of the Board not to
vote, not to be part of that decision-making process, in
light of the reasons you've already set out about the
relationship between Government and the Post Office?
Well, I've discovered quite a bit about this through

this Inquiry and its disclosures. At the time, it was

an evening call from the Post Office Minister and then
a later night call to the Permanent Secretary. But what
I understood and I recollect -- I'm sure accurately from
my conversation with Kelly -- was that she was being
essentially told, given strong legal advice, which is to
say that, you know, you can't intervene in this, you
can't make this decision yourself, and I discovered ex
post that it applied to Tom Cooper as well.

Now, there is a very interesting thing here in the
evidence that's been disclosed. Some of that advice, it
seems to me from reading the to and fro, was advice from
UKGI Legal, that's to say from lawyers, but it was
essentially presentational advice, not a requirement of
the law, shall we say, and, since that was summarised,
I think possibly -- well, certainly in other
correspondence, that legal advice was that the Minister

shouldn't intervene and Tom Cooper shouldn't intervene.
168

(42) Pages 165 - 168
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

You know, I'm not sure that it’s the right thing for
presentational advice -- which, in any case, frankly,
should be a matter for others and the ministers -- for
that to be passed off as legal advice. And if there
were no legal bar on Mr Cooper taking part in that
decision, I was clearly -- I was certainly of the view
that he should have participated and should have spoken
against it.

As it happens, I could understand a genuine sort of
legal objection to, as it were, the Executive being
involved in a criticism of the judiciary, but that would
more apply, it seemed to me, if the Department, UKGI and
Mr Cooper were wanting the judge to be recused, which --
whereas certainly the ministerial view, and I think
consistent with the reading between the lines of the
Permanent Secretary's view is: we didn't want that. We
wanted the opposite.
Thank you. Could we please turn to UKGI00009464.

So the submission I just took you to was 21 March.
A few days later now, 25 March, and you have received
correspondence from another member of the Department,
Anne-Marie Trevelyan, writing on behalf of
a constituent, Peter Holloway, and she discloses, if we
scroll over to page 3, please, an email from her

constituent. He says:
169

Joint Action and many have been forced into bankruptcy,
some sent to prison, all severely ... disadvantaged.

AND the Post Office has been, and is still, spending
millions of pounds of public money to defend its
entrenched position and the reputations of

an incompetent Executive and a Board that either doesn't
care or doesn't understand what is going on.

“Over the last ten years there have been three
enquiries all of which the Post Office refused to accept
their findings, an attempt at mediation, at which the
Post Office refused to mediate. It's time for the Post
Office to accept the true position and agree to settle
with us who have been so badly treated.”

Is this correspondence you recall receiving; was it
sent directly to you?

It isn't and I don't expect I would have seen it for
reasons that Vince Cable, I think, set out today.

I think it would have been directed by the Department
straight to the Post Office Minister.

Were they sentiments that you were aware of more
broadly?

Well, I'm not sure I was aware of them more broadly but
I couldn't have written it better myself. It basically
reflects my views on the judgment.

Were they your views at the time?
171

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

"lam sure you're aware that judgment in the first
part of the trial came down very strongly for the
subpostmasters, with strong criticism of the management
of Post Office. We are currently in the second phase of
the trial looking at the Horizon system operated by the
Post Office. We are confident often a similar outcome.

"The Post Office are fighting the case vigorously
and are already considering appealing the first
judgment. However, two of their Senior Managers have
been found lying understanding oath in the court whilst
giving their evidence with the severe adverse comments
by the judge.

"I respectively request that you raise questions
with the Minister responsible for Post Office, as to
whether they have seen the judgment of the court and
what is the Minister proposing to do about it. The
Government is the single shareholder of the Post Office
and that Government, in its own words ‘has an arm's
length’ approach to managing the Post Office, and it is
this very ‘arm's length’ approach that has created this
position whereby Post Office is in the middle of a train
crash and refuses to see it. Meanwhile people like me
have been fighting for ‘justice’ for over ten years
having lost many hundreds of thousands of pounds at the

hands of the Post Office. There are 550 of us in this
170

Certainly. From might Saturday -- from the Friday night
when I first saw the judgment in my box to the
conversation on the Saturday morning when I, in effect,
directed that it needed to be respected and, to the
point here about the financial detriment that had been
longstanding, my clear instruction was that needed to
end and there needed to be a restitution.

Could we turn, please, to BEISO000071. This is

a ministerial submission of 12 April. If we could

scroll down, it updates you on developments, since the
submission of the recusal application. It says in the
first paragraph:

"The judge dismissed the application on 9 April and
refused permission to appeal, but [Post Office] will now
seek the Court of Appeal's permission directly. In
parallel, [the Post Office] is preparing an appeal of
the Common Issues judgment."

The "Recommendation" is:

"To note the contents of this advice and indicate if
you wish [the Post Office] to give you an oral briefing
to supplement this, as well as to outline its appeal
strategy once the Board has decided.”

If we scroll down, please, over the page to
paragraph 8, we can see a section entitled "Legal Team",

and it says as follows:
172

(43) Pages 169 - 172
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

"[The Post Office] has decided to boost the Legal
Team and has provisionally appointed Herbert Smith
Freehills to oversee the litigation with a direct

mandate from the Board rather than ... through the
company legal counsel. Their mandate will be to revisit
the approach to the litigation (both substance and

tone), which in the short-term means looking at the

appeal relating to the Common Issues trial, the

currently adjourned Horizon Issues trial, and the

strategy for reaching resolution."

What did you understand by the reference to
substance and tone?

Well, I think the Common Issues judgment -- I described
it as seminal and it was. It was finding, it was in

effect directing that the Post Office needed to accept
the unfairness of its treatment of subpostmasters and
mistresses, and that it needed to -- the tone thing is

to conduct itself in a more respectful way.

It continues:

"[The Post Office] is open to making other changes
depending on the advice received from the new firm.
Given the unexpected outcome of the Common Issues trial
we have been pressing [the Post Office] to ensure that
their litigation strategy is considered with a fresh set

of eyes, so this is a good outcome and we expect it to
173

Were you aware by this stage of any changes to the
substance and tone as proposed at earlier submissions --
That first submission that you put up did indicate that
they were taking the direction that had been given by me
and Kelly Tolhurst immediately after the Common Issues
judgment. I don't know whether you can put it back up,
the end of that first -- of the two that you have just
shown. They were appointing this new team to review the
strategy, to report direct to the Board and to change
the substance and the tone. So that was encouraging.
What was very disappointing in this, I should just
say for completeness, I've seen this in what was
disclosed to me but I don't think this submission was
sent to me, it was to the Permanent Secretary and to the
Post Office Minister.
That's correct.
But through conversations, I would be aware -- would
have become aware of it, you know, I was, I suppose,
looking forward, you know, with some anticipation to
seeing the outcome of this review by a fresh pair of
eyes, and then to find that it, in effect, is taking the
same approach, was bitterly disappointing.
Could we please turn to BEISO000075. This is the final
significant ministerial submission that I'm going to

take you to today, and it's from 11 June. So this is
175

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

have a significant bearing on the way the litigation is
conducted."

We then have a further ministerial submission in
May. That's at BEIS0000073, 10 May. By this stage,
Herbert Smith Freehills has reviewed the legal strategy.
If we scroll down we can see paragraph 5:

“Following the appointment of [Herbert Smith
Freehills] to oversee the litigation with a direct
mandate from the Board, [they have] reviewed [the Post
Office's] legal strategy. [They] presented their advice
‘on the proposed approach to the Common Issues [trial].
This approach was endorsed by the Board's Group
Litigation Subcommittee ... In broad summary [they] will
be appealing ..."

Then it sets out (a), (b), (c) and (d), the points
they will be appealing. Then it says below, in relation
to recusal application:

"[The Post Office] applied on 11 April directly to
the Court of Appeal for permission to appeal the judge's
decision and for the second ‘Horizon Issues' trial to be
stayed in the meantime."

It doesn't seem at this stage as though the
litigation strategy has actually changed very much, does
it?

No, to coin a phase, nothing has changed.
174

a ministerial submission to you, to approve and it says,
as follows:

"At the industry meeting on 4 June, you [Secretary
of State] asked for advice on how the ongoing Post
Office Limited litigation could be brought to a swift
and satisfactory conclusion, ensuring subpostmasters who
had been treated unfairly were appropriately
compensated."

So starting at the beginning there, what was the
industry meeting of 4 June, do you recall?

So I describe in my witness statement that my pattern,
as well as having every Director General give to me
their thoughts every week, direct to me, I had a series
of what I regard as important internal meetings in which
we would discuss with the relevant minister present, in
this case the Post Office Minister, usually the
Permanent Secretary and senior officials, things that
were on my mind, or a decision that one of the junior
ministers was going to take, that they wanted or I felt
that they should have some collective discussion. So
this was a weekly meeting of these things, and senior
officials were present.

I would observe that it says at the industry meeting
on 4 June, and we will certainly have had a discussion

resulting in this commission.
176

(44) Pages 173 - 176
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

pero>

The Post Office Horizon IT Inquiry

My recollection is that there were discussions
before that as well, from around the time of the two
submissions that you put up, in other words the weeks
ahead. They quite probably were or quite possibly were
at one of the other industry meetings. Unfortunately,
the Department doesn't have minutes of those meetings
and, certainly, I would have, in my weekly discussions
with the Permanent Secretary and with the Post Office
Minister, have been, essentially, kind of preparing the
ground for a major intervention in the Post Office to
cause them to do what manifestly I'd hope that they
would do, from that Saturday after the Common Issues
judgment, in other words to settle, to set up
a restitution scheme, to change their whole legal
approach. I hoped that they would do that, as it were
voluntarily.

By this stage, I had essentially given up on them
and concluded that they needed to be forced to do it.
There's reference there to appropriate compensation. At
that point in time, what did you have in mind?

Oh, the full detriment. I mean, the detriment can never
be overcome. I mean, the -- the loss of reputation, you
know, the disruption of people's lives can never be
properly compensated. But certainly financial

compensation, and something that was, you know,
177

judgments and is taking action ..

"5, Put UKGI lead legal counsel (or other legal
adviser) on {the Post Office] Litigation Subcommittee as
director or observer

"6. Invite Nigel Boardman, Chair of the BEIS Audit
and Risk Committee, to carry out some independent due
diligence on [their] litigation strategy

"7. Put in place clear information-sharing
arrangements via the proposed Framework Agreement for
[the Post Office]."

Then it says:

"More radical steps are presented in options 8-10:
we recommend these are not pursued at this stage."

I think, did you ask for --

\ did.

-- what was called "nuclear options"?

\ did.

-- or what you called “nuclear options"?

My purpose in requesting and requiring this package of
advice, which I think took some time to put together, so
that -- the interval between the industry meeting and
this submission, I think, is slightly misleading,

I think this was in train before that -- was essentially
that I wanted the direction that I'd in effect given on

that Saturday morning to be put into effect, up to and
179

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

an attempt to deal with that.

There are various references, you'll probably see
later in this submission, to, you know, kind of worrying
about the costs of this. If there's one thing I would
communicate very clearly, is that there was no way that
I was going to see the compensation, the entitlement to
the subpostmasters, see them sort of bilked to protect
the -- for the convenience of the Post Office or even
the Treasury and the Government. They needed to get
what were their desserts.

There are a number of recommendations. The
“Recommendations” are:

"That you note the advice and our recommendation
that you choose from the following options (which are
not mutually exclusive):

"1. Challenge [the Post Office] Chair and Board to
review their litigation strategy ...

"2. Commission [the Post Office] to carry out
a project on how to structure and operate a settlement

"3. BEIS Ministers to state publicly that they want
to see justice resulting from litigation for claimants
with valid claims.

"4, Challenge Post Office to announce that it is

taking on board some of the legitimate criticisms of the
178

including dismissing the Board, taking over the
litigation by the Department.

Thank you. If we scroll down over the page on to
paragraph 6, it says there:

"The current status of the litigation is that at
a hearing on 23 May the judge denied [the Post Office]
permission to appeal his judgment in the first ‘Common
Issues' trial and awarded the claimants their costs of
the Common Issues trial rather than reserving this
judgment until later in the litigation. Setting out his
reasons in a written judgment of 4 June, the judge
criticised [the Post Office's] conduct again, namely
[the Post Office's] ‘veiled or implied threat that
mirrors the approach adopted by Post Office on the
recusal application, namely that in adopting a course of
action in the face of opposition by the Post Office ...
runs the risk that the Post Office will say that the
overall outcome of the litigation ... has already been
decided’. The Judge also expressed concern about the
escalating costs of the litigation ..."

In your witness statement at paragraph 96, you have
said that the Post Office had not accepted the
significance of the previous judgment --

Well, it's to my remark that nothing can change.

Clearly, you know, even at this stage on 4 June, so
180

(45) Pages 177 - 180
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24

2

The Post Office Horizon IT Inquiry

I had commissioned this advice, probably better more
accurately described as a kind of set of actions to

force them into line. I'd commissioned it before this
judgment, suspecting that they were not doing what I had
directed them to do and, lo and behold, the judgment of
Mr Justice Fraser, who seems to have been very alert to
the Post Office's conduct, says that, even now, they're
engaged in the kind of behaviour that he deprecated in

the first Common Issues judgment -- almost unbelievable.

If we scroll down, please, to paragraph 14 there's
a section there regarding the role of Government as sole
shareholder. It says at the bottom:

"This does not include explicit powers to direct the
Board to take a specific course of action ..."

Although, over the page, it says:

"_. though ultimately ministers have the right to
appoint or remove any member of the Board ..."

We will get to it but I think those were one of the
nuclear options that were proposed?
Indeed. There is throughout this a continuing anxiety
‘on the part of the Department that, you know, it's
an arm's-length Limited company, in which the power of
ministers is confined to approving the strategy and to
appointing or firing individuals, not to direct them,

and there was -- I think it's here, there's a kind of --
181

collectively.

If we briefly turn to BEISO000076. We can see the
annexe to the submission, which sets out the options and
the advantages and the risks. If we scroll down, we can
see at page 4 the additional options that were
potentially available:

"Go public with a stronger [Secretary of State]
statement ...

"Change Chair/[change the] Board."

Scrolling down:

"Change management team."

Further down:

"BEIS to take shared responsibility for the
litigation ..

So those were options 8 to 11.
Correct.

Very briefly, why did you discount those options?
Well, so, as you said Mr Blake, these were options that
I'd asked to be included and I didn't so much discount
them as start with the -- so I think what I said is

I want all of the above in terms of the top seven, and
to keep on the table these to see whether they could
be -- obviously whether they would act in the
appropriate way.

I think the top one of these additional ones, to
183

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24

25 July 2024

in fact, there it is in paragraph 16 -- there's
a warning that, you know:

"... care needs to be taken that Ministers do not
risk being regarded as shadow directors. A shadow
director is someone in accordance with whose directions
or Customs the board are accustomed to act."

Now, it was very much my intention that the Board
should act in accordance with my instructions, they were
alive to that, they were drawing my attention to it, so
we were skating on somewhat sort of thin legal ice, as
it was described to me, which is one of the reasons in
my recommendations that I don't think we needed to
tiptoe around it in quite that way for -- God forbid
that there should ever be a future case but, in future,
that sort of advice should not need to be given.

Was there a point at which you actually considered, in
effect, becoming a shadow director?

Well, it was in my mind from the Saturday morning that
I had a clear view as to what the Post Office Board
should do and that I was going to do everything I could
to make sure they implemented it, within the law, hence
the -- this discussion. But I was -- I was prepared to
push the envelope, shall we say.

If we scroll down, at 19 the recommendation was you

choose from options 1 to 7, either individually or
182

make a strong statement, actually I don't think that
very different from what I did direct, which was to say
we were on the side of the subpostmasters and the
litigation had to change.

But, in terms of -- so the others essentially amount
to, one way or another, dismissing the Board, either
explicitly, in terms or through perhaps the option 11,
taking responsibility for it. They, I think, might be
likely, probably would have been likely, to quit on the
basis that, you know, it's a lack of faith in our
competence.

So, essentially, they boiled down to a question of,
at that point, should you -- should I fire the Board?
Now, that's something that I certainly wouldn't shy
about doing. I have used my powers in other
organisations to remove people that I thought were not
competent or performing or had certain problems
associated with them.

But it's a step that one has to take advisedly, it
seems to me, as a kind of Secretary of State. This was
an organisation without a Chief Executive, at this point
in time. The interviews, I think, were being conducted
that week for the new Chief Executive. Nick Read was
someone that was appointed a few weeks after that.

So it's an organisation, you know -- running the
184

(46) Pages 181 - 184
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

Post Office is, it's a complex organisation, it's
absolutely essential for national infrastructure of
paying benefits and applying for passports, and all the
rest of the things. So to -- I would have had in my
mind that, in order to instantly summarily, as it were,
dismiss the Board, you'd have to have an alternative
arrangement in place. To have an organisation as
important without any leadership would be quite a big
step. In addition to that, I would certainly have had
to consult the Prime Minister and others, were I to do
that.

So my view -- it was certainly not taken off the
table. Quite the opposite, I just --

Q. Shall we turn to your confirmation of the options that
you did choose?

A. Yes.

Q. That can be found at UKGI00010205.

So this is 18th June 2019, I think you were only in
post for about a month after this.

A. Yes.

Q. Itsays:

"[Secretary of State] has reviewed this advice and
has expressed a preference for the first 7 options to
pursue. Content for you to proceed on this basis and we

can discuss further at industry meeting when next
185

and I don't know whether we got the date. There was

an important appearance that Kelly Tolhurst was going to
make at the Post Office Board to tell them what to do.
One of the other aspects was that the new Chief
Executive was about to be appointed and, no doubt, he
would be -- he or she, turned out to be a he -- would be
the conduit of that.

But, in general terms, I think it would be fair to
reflect that, given how dilatory the Post Office were,
that actually to have been more directive a few weeks
earlier might have saved a few weeks in this. I think
that would be a reasonable reflection to make.

SIR WYN WILLIAMS: Can I just get one thing straight in my
head though. Unless I've got this fact wrong, there
would seem to me to be quite some difficulty in actually
doing very much at all in June 2019 because was it not
in June 2019 that the Horizon issues trial started? So
it's very difficult to imagine doing anything while
you're actually conducting that litigation.

A. Thank you, Sir Wyn. I was aware that the Horizon Issues
trial was going on, but I, for example, in the drawing
up of a scheme of compensation --

SIR WYN WILLIAMS: Sorry, perhaps I put it too broadly, so
I'l stop you. In terms of generally the litigation

strategy, as opposed to the broader issues --
187

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

scheduled."

Can we turn back to the submission, so that is
BEISO000075. Thank you. If we could scroll down and
look at the recommendations. How many of those
recommendations are you aware were actually fulfilled?

A. Ican't say. There were various actions that were
implementing the recommendations, much of which was
about the Minister appearing at a POL Board meeting,
which I think was in a few weeks’ time.

Q. In respect of public statements, for example, were they
carried out during your period in office?

A. I can't remember. I think we did, in terms of -- well,
for -- I mean, some of these we've already done. For
example (3), I think in the communication after the
Common Issues judgment, we said that we were aligned
with the postmasters and mistresses and we wanted to see
restitution. So, actually, I think that was already in
train.

Q. Could we please turn to POL00285354. The suggestion
might be made that you should have done more of those
more quickly.

A. Mm-hm.

What do you say about that?

A. Well, I -- when one takes a decision like that, it --

2

there are different ways of implementing it. One was ~
186

A. Yes.

SIR WYN WILLIAMS: -- of compensating the postmasters, I've
just been musing to myself about how anything meaningful
could be done while the Post Office lawyers are on their
feet busily fighting the postmasters' lawyers before
Mr Justice Fraser again.

A. Sir Wyn, I would say that my hope and intention was that
the approach that was taken to that Horizon trial would
be different from the approach that had been taken
throughout the common issues period, that they would be
looking to acknowledge the --

SIR WYN WILLIAMS: I might be trespassing well beyond my
terms of reference but it seems to me that, once the
Horizon Issues trial started, of course there could be
a difference in tone and the way you approached
people -- I don't mean you personally, I mean the Post
Office and the Government -- but, effectively, the
choice was either to fight the case properly and
legitimately, or to give up. That's what it boils down
to.

What I mean by "give up", start making real
overtures about settlement. I mean, those were the only
two practical options in those days, weren't they?

A. Well, I would agree with you that, in terms of

settlement, that was going back to the readout of that
188

(47) Pages 185 - 188
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

Saturday morning conversation. I can't remember the
exact words, but it was something to the effect of that

we shouldn't wait for the end of the legal processes to
settle, in effect.

So that was part of it. Part of these points that
we've just been talking about were to begin setting up
the structure of a compensation scheme but I am not
a legal -- not a lawyer, let alone a legal expert, so to
what extent the -- my hopes that the conduct of the ~
of that -- of the Post Office's participation in that
trial could have been changed, I had hoped and intended
that it -- that was possible, that it should happen.

SIR WYN WILLIAMS: All right. Thank you. Okay.
MR BLAKE: Can we please turn to POL00285354. This is the

>

final document I'll take you to before we move on to
recommendations.

This is an email of 30 September 2019, so it's after
your time in office. It's an email from Alisdair
Cameron to Nick Read and it relates to potential
changes, structural changes. It says:

"In the conversation there are multiple stakeholders
with varying needs which I have tried to set down in the
attached (which should not be forwarded please).
I don't think a [I think that's some sort of

responsibility assignment matrix] is the answer because
189

I thought this whole document was pretty cynical.
It's looking, as we go on, to -- looking at ways in
which the stakeholders can be, as it were, sort of
managed, it seems to me. I was --

There's a section there on Alex Chisholm --
(Unclear)
and it says:

"Alex doesn't want us to do anything that might
damage his career prospects.

"Alex meets us very rarely to date. His views have
been developed, starting with the last funding round,
when he and Greg Clark concluded that UKGI had gone
native and they were anxious about Government investing,
via us, commercially (not their skillset) and how did
they stop us throwing ‘good money after bad"?”

It's that, in particular, I want to ask you about,
where it says that you “concluded that UKGI had gone
native"; is that a fair reflection of your view at the
time and, if so, why?
I don't think I would have put it in necessarily those
terms but certainly, during the funding round, as it's
referred to, it was my responsibility, as Secretary of
State, along with the Permanent Secretary, to ensure
that public funds were not wasted and I felt, and

I think the Permanent Secretary felt, that there were
191

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

they won't abide by it.”
It seems to be relating to UKGI --

Yes.

-- and how to manage that relationship.

The document that's attached to that can be found at
POL00285355, and there are various comments from
Mr Cameron. I'd just like to get your view on these
because I think you did meet Mr Cameron on a number of
occasions.

\ did.

So BEIS Secretary of State -- that may be a reference at
that stage to Andrea Leadsom rather than yourself, or to
the post, it's not entirely clear. But it says:

"Usually the [Secretary of State] has no strong
feelings except not being embarrassed by us. The [Group
Litigation Order] is important because we are being sued
by Postmasters -- politicians have mixed feelings about
us but LOVE constituency postmasters and will always
side with them versus us if they can. When we make that
difficult it is stressful.”

Were you aware of those views, as expressed there?
Well, when I first saw this document I assumed, wrongly,
that it was referring to me, and I don't believe anyone
can think I didn't have strong feelings on the matter,

but I think it's my successor.
190

proposals that were being made to invest in quite large
sums of money in different ventures that seemed to be
dubious, in terms of their likely value for money.

And I think there's a structural problem here, in
that UKGI -- we may come on to talk about this a bit
more -- UKGI is a sort of deal-making -- it's a kind of,
you know, it's a private equity-type organisation who
I think the people in it, structurally, are kind of keen
to do deals and to do the things that you do in
corporate finance. And so, in our scrutiny of UKGI,
I think we were pretty wary about their views and they
were more aligned with encouraging the Post Office to do
things that we didn't necessarily think were judicious.

It says:

"[Mr Chisholm] has been infuriated by the GLO which
he thinks we should have settled ages ago -- and said so
last year."

Do you recall Mr Chisholm having said that the GLO
should have been settled considerably earlier?
I don't. I don't recall him having said that. For the
reasons that I gave, I think, earlier in our discussion
this afternoon, I thought it was important that that
litigation concluded, that it were not -- I can see from
a sort of Department -- from a Permanent Secretary's

point of view, to have it sort of dealt with might have
192

(48) Pages 189 - 192
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

had its attractions, but I think a lot of what was in

the very comprehensive judgment would not have been in
the public domain. And if you take the view that I do,

and did, that the criminal convictions, the unsafety of

the -- the lack of safety of the criminal convictions

was, as it were, the keystone of the edifice, I think
pursuing that litigation, I think, was important for

that.

My concern, having seen partly what happened, going
right back to the beginning of my evidence of the
supposed settlement mediation through Second Sight, that
was not satisfactory, and so I think it needed that
resolution. But that's a long digression. I did not
know that Alex Chisholm took that view.

If we scroll down, finally, on this document, there's.
a reference to UKGI, and it says:

"UKGI has the role of overseeing Government's
commercial interests. They're generally ineffective and
pleasant."

Very briefly, what was your view of UKGI?

Well, I've got great respect for the people who, often
after distinguished commercial careers, give up their
time to be on the Board of UKGI and to serve in the

public interest, and I don't want to say anything

critical about them. But I think there is -- I have
193

with the Treasury, or with the Communities Department,
they wanted to work together. So I think there was

a kind of cod corporate finance arrangement to this
that, actually, I don't think was appropriate and
necessary.

If I could bring on to screen the memorandum of
understanding that was in place during your period in
office. That's UKGI00017461. It explains, under
"Background":

"UKGI is a limited company wholly owned by HM
Treasury ..."

Then it says, at 2.2:

"To facilitate UKGI in managing its work and
resources, and to enable the constructive engagement of
UKGI with the department it advises, memorandums of
understanding are expected to be put in place for the
benefit of UKGI and the departments it works with.”

"UKGI Service

"UKGI will provide independent advice to BIS and its
ministers to deliver BIS objectives. Any direct
engagement with Assets or Projects will formally be as
an agent of BIS.

"UKGI will provide its advice in a manner consistent
with the Civil Service's core values of integrity,

honesty, objectivity and impartiality."
195

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

reflected on this over the weeks and months ahead --
I think there's something of a kind of Emperor's New
Clothes quality to UKGI, as an organisation, that, with
hindsight, I think I and perhaps others should have
pointed out.

I mean, let me give you some examples, some of them
perhaps trivial. It talks about its "assets", the whole
time, "We are managing the asset", "We are dealing with"
-- "These are our assets". It's a peculiar way of
talking. These are, you know, the Post Office, the
Nuclear Decommissioning Authority, Ordnance Survey.
They're not assets. It denotes
would talk about the "assets". They are organisations,
they are public bodies; why not call them public bodies?

I think the fact that it's a limited company is
abit peculiar. You know, why do you have a limited
company with all of the downsides, in terms of being
able to direct, and that we've discussed, when it
doesn't charge for its advice? I don't see why it
should be a limited company.

And to have a limited company giving advice on
another limited company, I think, is a bit peculiar.
And this whole thing of having memorandums of
understanding with departments, you know, the Business

Department didn't have a memorandum of understanding
194

no one in Government

It then has a section on accountabilities and
responsibilities, and it says:

"The accountability to Parliament for the Activities
UKGI is involved in will be ..."

Then it says:

"Ministerial level: BIS Ministers."

Then, if we scroll over to the fourth page, it sets
out there what it defines as the activities as at
1 April 2016, and one of the assets, as you say, defined
under "Assets" is the Post Office.

If we scroll back to the first page, it says on the
first page, paragraph 4:

"The accountability to Parliament for the Activities
[ie the Post Office]:

"[At] Ministerial level: BIS Ministers."

Irrespective of the legal interpretation of this
memorandum of understanding, do you understand there to
be a clear link of accountability of UKGI?

No, and I think it's obscured somewhat by its
organisation as a limited company. I mean, in other --
I think I say in my witness statement that it describes
itself as being, you know, owned by the Treasury, and
accountability is to Treasury Ministers.

I think it obscures. It seems to me that sort of

simplicity is the best way to proceed. I never had any
196

(49) Pages 193 - 196
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

difficulty in understanding the role of civil servants.
Again, they're not part of the Civil Service, I don't

know why not. There are norms in the Civil Service as

to how to proceed. I don't think it needs that.

I understand that one reason -- I suspect, I don't
know, but I suspect one reason for creating this limited
company, arm’s-length body is to be able to pay people
more than the Civil Service pay scales allow.

But that's a good example, it seems to me, of, you
know, setting up something to get round a problem rather
than to address it. If you need, you know, senior
corporate finance people in Government to advise
Ministers and Permanent Secretaries, then, rather than
sort of set up a limited company to employ them, why not
have an exception and be direct about it, it seems to
me?

How would you improve, very briefly, the line of
accountability?

Well, I would certainly have UKGI reporting -- well,

I would prefer the advice to be within the Department,
in essence to be from officials within the Department.

There's another example of this, and I -- in
preparing for this hearing, a number of the other public
bodies, the Nuclear Decommissioning Authority, an asset

in the terms of UKGI, had obviously not a similar but
197

seems evident, I think from our conversation this
afternoon, that there is a combination of public
interest and commercial interest.

In other spheres -- in charities, for example -- we
have a corporate form. The Charity Law states -- I'm
the trustee of a charity -- how that should be because
it's a particular way of organising things. There are
things like community interest companies that have their
separate governance. So, just for simplicity, to
recognise that there are some organisations in which
there is, pretty much sort of jointly and severally,

a public interest, as well as a commercial interest, and
to make it very clear that ministers and officials are
absolutely at liberty to have information to direct, as

it were, proceedings there, it seems to me, would make
life a whole lot easier.

Some people have blamed individual actions as well as
structures. How would you guard against that?

Well, there will always be individuals who don't
discharge their duties as well as they should. When
we're talking about UKGI, I have been very struck -- and
I'm the latest in a series of witnesses who have been
members of the Government -- that many of my
predecessors have been critical about individuals who

have been employed by UKGI: I think Jo Swinson was,
199

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

25 July 2024

a kind of related problem in which it got into
a contractual tangle. UKGI were not very effective in
spotting it and bringing it to the attention of the
Department and ministers.

As Secretary of State, I commissioned a review by
aman called Steve Holliday into that and it reported,
I think a couple of years ago. And, interestingly, one
of its recommendations is that the complexity of this
sort of governance is excessive and it should be --
there should be BEIS civil servants directly on the
Board, and that's, it seems to me, a preferable way of
operating.
One of the things that you've referred to in your
proposed recommendations is something called a public
interest company. Very briefly, how do you envisage
that would work?
Well, it's a thought, rather than a blueprint, but the
thought is this: that some of what we've been talking
about has been, you know, advice about, you know,
whether you're going to be a shadow director; is this
the responsibility of the Board; do you have standing,
as a minister, to direct it or not? And a lot of this
comes from using the kind of vehicle of an ordinary
Companies Act company to contain

businesses/organisations like the Post Office, and it
198

Baroness Neville-Rolfe, Margot James, Kelly Tolhurst and
others.

I think that actually points to a kind of structural
problem that they are in a dilemma, or at least are --
perhaps because of the requirement to be a member of
a unitary board, are drawn into a certain way of
proceeding at the expense of another, and this is not
a kind of trivial observation.

I mean, you know, one of the purposes of UKGI is to
be good at governance, to improve the Government's
capacity at governance. But I have to say, on the
evidence of this, and I think on the NDA, the evidence
is that they have not been very good at that, in
important instances.

For example, the failure of UKGI to bring to the
attention of the Post Office Board, let alone ministers,
the Parker Review/the Swift Review, which was highly
consequential, that seems to me to be a failure of
corporate governance, in which UKGI was part. I might
also add -- which was news to me until the evidence of
this Inquiry was disclosed and reported -- I had no
information given to me that the Board had a lack of
confidence in Paula Vennells, for example. UKGI did.

You've had conversations, I know, about, you know,

ministers from successive administrations being aware of
200

(50) Pages 197 - 200
ONOaARWN

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

The Post Office Horizon IT Inquiry

what happened in the previous one. I think that would
have been very material, to know that the Board had
expressed, in the past at least, a lack of confidence
there.

So even as corporate governance specialists, I don't
think the record of UKGI is all that robust, shall we
say.

Q. Thank you. Very finally, you've clearly watched a lot
or heard a lot of the evidence from this Inquiry. Are
there any recommendations that didn't make its way into
your statement that you can think of now, briefly?

A. I tried to reflect on all of these. I do say something
about the pattern of evidence. I mean, it seems to me
kind of standing back, and I think it -- you know, in
public policy and public life generally, one of the
things that I've become -- been interested in, in recent
years -- I was chairing the Science and Technology
Committee at the House of Commons -- is the development
of artificial intelligence.

Artificial intelligence -- I'll explain the
relevance in a second -- spots patterns that, actually,
as it were, the naked eye may not spot. I think if the
pattern of prosecutions/convictions had been spotted
better and earlier then certainly a lot of the time to

resolve these matters might have been shortened and, in
201

to think about in terms of how I make recommendations
for the future.

THE WITNESS: Thank you, Sir Wyn, and if I'm put in the
position of my colleagues, to thank you and the Inquiry
for the meticulous approach that you're taking to it.
Thank you.

‘SIR WYN WILLIAMS: Right, Mr Blake, tomorrow we resume at
9.45?

MR BLAKE: That's correct, sir, yes.

SIR WYN WILLIAMS: We have a part-heard witness, do we not,
and then Mr Edwards, is it? Yes, itis.

MR BLAKE: That's correct, yes.

SIR WYN WILLIAMS: Fine. All right, then. 9.45 tomorrow.

MR BLAKE: Thank you very much.

(4.28 pm)

(The hearing adjourned until 9.45 am the following day)

203

25 July 2024

many cases, by getting to a recognition of injustice
earlier, some people might have been saved the appalling
effects that they had. And so some of the
recommendations I make in my witness statement is to
give responsibility, whether it's to the CPS or other
bodies, to actively monitor unusual patterns, so that
they can be brought forward earlier.

But here am I, as it were, sort of freelancing into
an area that is judicial, in which I am not really
qualified. So I mention that because you asked me
whether there was anything else I included in my witness
statement, and that was a reflection that I made.

MR BLAKE: Thank you very much.

Sir, I don't think there are any questions from Core
Participants, unless you sir, have any questions?

‘SIR WYN WILLIAMS: No, I asked the few that I needed to as
we went along.

So thank you very much, Mr Clark, for your witness
statement, for your oral evidence and also for your
reflections. A number of your fellow current or past
politicians have addressed their minds to reflections,
so I think I'm right in saying that, currently at least,
you are the last politician who is going to give
evidence in this phase and so I would thank all of you,

and you've used the vehicle for providing me with plenty
202

INDEX
THE RIGHT HONOURABLE SIR JOHN VINCENT ....
CABLE (sworn)

Questioned by MR BEER ...

Questioned by MS PATRICK ..... 80
Questioned by MS PAGE ... 88
Questioned by MR STEIN ... 99

THE RIGHT HONOURABLE GREGORY DAVID... 114
CLARK (sworn)

Questioned by MR BLAKE .. 115

204

(51) Pages 201 - 204
1

MR BEER: [17] 1/3
1/5 118 46/21 46/24
47/3 4716 71/25 77/10
77/13 77/18 77/23
78/3 79/22 114/9
114/15 114/17

MR BLAKE: [11]
114/21 114/23 115/2
165/14 165/23 165/25I
189/14 202/13 203/9
203/12 203/14

MR STEIN: [5] 99/19
1114/5 1114/9 111/14
114/5

MS PAGE: [2] 88/13
99/17

MS PATRICK: [2]
80/2 88/9

MS PRICE: [1]
165/18

SIR BRIAN
LANGSTAFF: [1] 1/4I
SIR WYN WILLIAMS:
[25] 46/23 47/5
TAIN4 71124 7717
78/2 114/1 1141/7
111/12 114/7 114/40
114/16 114/22 165/17
165/19 165/24 187/13}
187/23 188/2 188/12
189/13 202/16 203/7
203/10 203/13

THE WITNESS: [4]
77/19 88/11 114/14
203/3

42 [1] 38/12

"69 [2] 31/24 32/7
‘arm's [1] 170/20
"August [1] 15/10
‘August 2012' [1]
15/10
‘authoritarian’ [1]
10/21

"Common [1] 180/7
"good [1] 191/15
‘has [1] 170/18
"Horizon [1] 174/20
‘justice’ [2] 10/7
170/23

"Make [2] 102/13
102/18

"one [2] 12/12 105/7
"Settle [1] 102/13
‘The [4] 59/10
“thugs [1] 10/22
‘veiled [1] 180/13

-- have [1] 21/6
- or [1] 179/18

1 April [1] 196/9

4 July [1] 98/20

4 March [1] 141/9
1 or [1] 25/23

1 per cent [1] 68/21
1,000 [1] 109/5
1.03 [1] 114/18

10 [4] 98/22 106/5
142/6 179/12

10 July [1] 95/5

10 May [4] 174/4
10 years [6] 12/18
22/5 24/22 83/11
83/12 86/23

100 [7] 4/18 12/4
68/20 101/17 103/9
113/6 142/23
100,000 [1] 108/4
44 [6] 21/14 47/12
142/22 174/18 183/15)
184/7

11 June [1] 175/25
11 March [2] 47/20
59/6

11,000 [4] 89/13
11,600 [2] 138/6
139/9

11.00 [2] 46/21 46/25
11.10 [4] 46/22
11.11 [1] 47/2
11.57 [1] 77/20

110 [1] 78/14

117 [1] 80/11

118 [2] 80/11 80/15
12 [2] 9/11 106/10
12 April [1] 172/9
12 May [2] 2/20 2/21
12 September [1]
119/7

12,500 [1] 23/18
12.10 [3] 77/15 77/17
77/22

13 [2] 9/18 104/16
13 January [2] 139/3
139/20

14 [3] 15/6 143/8
181/10

14 July [1] 116/13
14 years [1] 107/20
140 [8] 59/3 59/13
59/18 59/18 59/23
60/9 60/21 65/24
141 [1] 66/19

142 [1] 66/19

144 [1] 69/9

15 [3] 58/22 62/11
143/15

15 April [1] 63/2

15 March [2] 147/24
149/6

15 years [3] 53/23
56/8 109/4

150 [2] 56/22 130/6
150,000 [1] 106/4
16 [2] 144/15 182/1
46 March [1] 150/12
17 [2] 36/14 107/3
17 March [3] 47/12
48/21 51/24

17,000 [1] 89/12

18 [1] 166/19

48th June 2019 [1]
185/18

19 [1] 182/24

19 March [1] 158/22
1969 [2] 32/8 76/5
1997 [1] 2/16

1999 [4] 10/20 27/9
80/22 86/23

2
2 billion [3] 74/5
90/21 91/19

2.00 [1] 114/20

2.00 pm [1] 114/15
2.2 [4] 195/12

20 [1] 38/11

20 March [1] 167/8
2000 [1] 109/4
2001-2002 [1] 10/5
2002 [1] 10/5

2003 [1] 80/22

2005 [1] 115/22
2008 [1] 119/7

2010 [5] 2/20 32/11
83/20 87/22 100/25
2011 [3] 30/25 31/2
84/4

2012 [7] 15/16 23/9
37/21 100/23 101/8
103/10 108/13

2012' [4] 15/10
2012/13 [1] 104/16
2013 [10] 32/22
36/15 38/22 42/4
71/15 85/18 86/3 94/6
98/20 117/16

2014 [2] 32/23 109/7
2015 [22] 2/21 32/11
34/16 47/12 47/20
48/21 51/7 58/19
61/21 62/11 71/15
85/20 86/7 108/16
108/25 109/7 109/7
109/10 112/4 117/16
118/1 131/20

2016 [6] 116/13
121/22 132/11 134/14]
140/5 196/9

2017 [2] 113/3
135/21

2017/2018 [1] 111/18
2018 [6] 111/18
135/8 139/1 139/3
139/21 139/21

2019 [11] 111/19

112/23 116/13 140/2
140/5 141/9 166/2
185/18 187/16 187/17)
189/17

2020 [1] 147/6
2020/21 [1] 132/17
2024 [2] 1/1 1/20

21 [2] 3/7 132/17
21 March [2] 166/1
169/19

22 February [1] 31/2
22 July [1] 38/22
23 July [1] 15/16
23 May [1] 180/6
23rd [1] 16/9

24 July [1] 116/13
25 July [4] 132/11
25 July 2024 [1] 1/1
25 March [1] 169/20
25 October [1] 23/9
26 March [1] 55/12
27 June [1] 1/20

28 billion [3] 92/19
93/1 93/16

28 June [1] 115/8

3

3 February [1] 48/23
3,000 [1] 79/18

3.17 [4] 165/20

3.3 billion [3] 91/2
91/21 93/18

3.30 [2] 165/18
165/22

30 [2] 41/2 42/16

30 September [1]
189/17

31 [2] 21/13 88/16
33 [6] 9/10 9/12 9/14
62/9 62/10 122/1

36 [2] 78/4 130/5

37 [2] 10/10 100/5
37.5 billion [1] 93/5
37.5 million [1] 92/20

40
4 June [4] 176/3
176/10 180/11 180/25}
4,000 [1] 79/18

4.28 [1] 203/15

40 [3] 15/7 41/2
122/3

41 [2] 15/21 78/13
44 [1] 80/17

45 [1] 77/15

46 [1] 36/13

47 [1] 115/11

5

5 February [1] 118/1
5 March [2] 140/2
144/22

50 [4] 12/4

500,000 [1] 56/23

51 [2] 69/8 149/6
53 [1] 1/21

53 pages [1] 1/20
550 [1] 170/25

6

o

ion [1] 56/25
6 September [1]
37/21

6,000 [1] 106/4
61 [1] 47/8

68 [1] 47/8

69 [4] 47/8

7

75,000 [4] 11/10
76 [1] 47/8
77 [1] 47/8
79 [2] 62/9 62/10

8

8 July [2] 36/15 42/4
8-10 [1] 179/12
8.30 [1] 151/6

9

9 April [1] 172/13
9 July [2] 94/24
98/21

9.23 [1] 163/11
9.45 [4] 1/2 1541/5
203/8 203/13
9.45 am [1] 203/16
90 [1] 78/3

92 [1] 10/9

96 [1] 180/21

abide [1] 190/1
abilities [1] 68/13
ability [1] 121/7
abject [1] 142/20
able [15] 26/2 30/20
44/13 58/20 77/3
78/25 79/11 84/23
102/21 108/22 112/22)
122/16 145/7 194/18
197/7

abnormal [1] 68/24
abnormally [1] 4/1
about [213]

above [7] 16/1 103/4
105/24 106/15 147/16)
154/19 183/21
abreast [2] 5/7 46/15
absence [2] 40/7
42/6

absolutely [9] 38/19
54/11 99/12 103/15
129/17 139/17 150/23}
185/2 199/14
absorbing [2] 18/24
64/24

abundant [1] 35/9

(62) MR BEER: - abundant
A

abuse [1] 157/19
academically [1]
74/19
accept [12] 8/13 8/19
8/22 20/13 49/15 50/7,
53/13 71/17 162/17
171/9 171/12 173/15
acceptable [1] 168/2
acceptance [1] 60/5
accepted [3] 21/1
152/20 180/22
accepting [3] 8/23
50/3 165/4
access [4] 101/16
110/16 127/9 163/6
accompanying [1]
139/14
accordance [2]
182/5 182/8
according [2] 102/14
106/6
account [4] 9/13
17/13 75/25 164/10
accountabilities [1]
196/1
accountability [7]
72/22 73/6 196/3
196/13 196/18 196/23
197/18
accountant [1] 14/6
accountants [3] 7/6
7/10 118/10
accounted [1] 23/17
accounting [15]
16/14 19/5 28/1 40/12)
42/8 48/10 72/11
72/19 101/22 103/5
105/25 106/13 106/15}
106/19 107/10
accounts [3] 72/12
72/20 72/22
accuracy [2] 50/17
50/21
accurate [2] 59/24
129/3
accurately [2] 168/11
181/2
accusations [2]
26/16 64/3
accused [2] 160/9
164/22
accustomed [1]
182/6
achieve [1] 71/17
achieved [1] 25/11
acknowledge [1]
188/11
across [11] 6/14 7/14
7/15 8/11 13/17 84/9
84/11 85/7 87/8 126/9
145/24
act [12] 31/25 32/7

32/8 67/16 76/5
123/14 147/17 160/20)
182/6 182/8 183/23
198/24

acted [2] 99/12
152/20

acting [4] 7/2 29/20
97/11 124/11

action [13] 6/23
13/25 14/4 27/24 33/1
45/9 70/6 136/24
140/9 171/1 179/1
180/16 181/14
actions [4] 150/18
181/2 186/6 199/17
actively [2] 49/8
202/6

activities [4] 5/17
196/3 196/8 196/13
activity [2] 64/16
155/10
acts [1] 123/10
actual [1] 102/25
actually [34] 22/7
35/22 41/19 45/6 51/9)
56/9 58/23 60/17 70/1
84/18 89/21 91/5 91/8
92/3 95/20 101/9
123/20 124/14 139/23)
153/9 156/4 157/18
164/17 174/23 182/16)
184/1 186/5 186/17
187/10 187/15 187/19)
195/4 200/3 201/21
adamant [3] 101/20
102/7 158/19
add [5] 12/16 30/4
33/9 60/7 200/20
addition [1] 185/9
additional [2] 183/5
183/25
Additionally [1] 44/6
address [5] 21/20
25/15 38/24 70/19
197/11
addressed [10]
17/20 23/10 61/22
65/4 68/16 79/9 90/11
100/9 119/5 202/21
addresses [2] 123/3
147/19
addressing [4] 24/16
49/8 70/22 76/14
adjourned [2] 173/9
203/16
Adjournment [1]
114/19
administration [2]
90/16 110/18
administrations [5]
93/4 126/10 138/18
144/3 200/25
admitted [1] 43/13
adopted [2] 83/3

180/14
adopting [1] 180/15
Adrian [1] 47/9
Adrian Bailey [1]
47/9
advance [7] 21/23
27/4 143/14 143/25
146/9 146/10 148/13
advanced [2] 72/5
142/2
advantages [1] 183/4I
adverse [2] 95/10
170/11
advice [53] 19/24
20/13 20/17 43/6
49/15 50/16 109/8
110/8 124/22 141/7
141/24 142/1 146/7
148/3 148/5 148/24
148/24 152/6 152/7
155/9 158/18 159/11
162/7 163/10 163/22
164/11 164/15 165/2
166/3 166/15 167/12
168/13 168/18 168/19!
168/21 168/24 169/2
169/4 172/19 173/21
174/10 176/4 178/13
179/20 181/1 182/15
185/22 194/19 194/21
195/19 195/23 197/20}
198/19
advisable [1] 147/16
advise [8] 63/13
108/5 140/25 143/11
144/16 145/3 163/9
197/12
advised [6] 106/13
110/1 133/14 140/22
160/14 165/12
advisedly [1] 184/19
adviser [2] 2/12
179/3
advisers [8] 59/12
106/14 143/9 143/11
151/13 160/2 161/23
163/23
advises [1] 195/15
affairs [9] 3/2 3/4
3/10 4/12 4/13 5/1
26/11 26/18 26/23
affected [3] 43/16
64/21 128/4
afraid [2] 10/15 137/9I
afresh [1] 118/8
after [24] 2/9 93/25
95/6 98/1 109/19
112/3 117/20 118/23
120/15 127/15 132/8
135/5 145/10 149/13
158/12 163/24 175/5
177/12 184/24 185/19!
186/14 189/17 191/15}
193/22

afternoon [7] 80/2
114/21 114/23 150/24}
165/16 192/22 199/2
again [19] 5/9 31/6
43/1 80/15 84/7 98/23)
110/3 117/17 121/4
133/8 139/8 143/4
156/20 158/9 162/25
167/20 180/12 188/6
197/2

against [15] 6/24
10/13 10/24 13/25
26/16 33/1 117/1
118/25 128/8 136/24
147/13 151/25 162/24}
169/8 199/18
agencies [6] 42/19
45/4 76/19 83/4 84/12)
85/6

agency [2] 41/20
70/8

agent [1] 195/22
ages [1] 192/16
aggressive [1]
159/19
aggressively [1]
61/24

ago [4] 11/25 56/14
192/16 198/7

agree [10] 38/8 59/18)
78/21 103/14 146/7
146/20 158/9 161/11
171/12 188/24
agreed [11] 10/17
16/19 18/4 38/5 49/4
60/1 104/25 145/24
148/15 156/15 161/5
agreement [2]
156/20 179/9
agreements [1] 17/6
agriculture [1] 71/4
ahead [3] 145/4
177/4 194/1

Al [5] 125/23 127/2
133/6 147/20 166/13
Al Cameron [3]
125/23 127/2 133/6
Alan [3] 13/3 81/2
83/8

albeit [4] 85/9 93/4
103/5 105/25

ALBs [1] 76/4
Aldred [1] 141/15
alert [5] 33/8 62/6
65/1 73/11 181/6
Alex [8] 144/23
145/19 161/1 164/11
191/5 191/8 191/10
193/14

Alice [3] 5/21 66/22
66/23

aligned [3] 155/17
186/15 192/12
Alisdair [1] 189/18

alive [1] 182/9
all [79] 2/4 11/12
11/19 14/1 14/15
15/23 18/6 19/15
19/23 23/16 28/25
35/11 37/18 39/6
41/13 42/2 43/10
44/14 46/17 52/7
52/22 54/11 55/3 55/6
57/11 58/5 58/6 60/5
60/6 60/18 61/3 63/11
64/10 71/24 77/17
86/7 88/9 91/1 92/4
94/10 97/14 98/16
101/19 104/21 105/5
106/22 107/18 107/21
109/11 112/3 120/9
120/16 120/24 127/9
130/6 134/9 136/13
1447/7 150/2 150/16
153/20 156/18 157/12)
159/11 159/23 160/11
161/4 165/19 171/2
171/9 183/21 185/3
187/16 189/13 194/17)
201/6 201/12 202/24
203/13
allegations [4] 10/2
43/22 63/14 84/8
Alliance [1] 6/23
Allison [1] 26/14
allow [4] 91/12 91/13
125/18 197/8
allowed [2] 40/18
111/10
allows [2] 42/14
136/2
almost [14] 6/8 17/8
18/23 18/25 38/14
38/16 41/13 50/9 57/7
57/11 58/5 93/23
101/17 181/9
alone [2] 189/8
200/16
along [3] 15/25
191/23 202/17
alongside [2] 63/16
63/22
already [11] 22/4
36/5 69/18 73/22
98/12 108/9 168/5
170/8 180/18 186/13
186/17
also [27] 6/12 17/7
50/20 66/21 70/14
90/25 94/19 98/16
99/9 104/16 110/17
118/9 123/9 124/11
135/13 138/4 138/21
144/6 148/10 155/16
156/3 156/6 159/16
159/18 180/19 200/20)
202/19
alternative [2] 36/2

(53) abuse - alternative
A

alternative... [1]
185/6

although [8] 43/20
89/15 92/24 93/17
95/9 148/22 166/10
181/15

always [2] 190/18
199/19

am [21] 1/2 5/11
26/18 29/11 36/15
46/25 47/2 51/25
52/21 55/15 55/16
77/20 100/5 142/18
159/25 160/12 170/1
189/7 202/8 202/9
203/16

ambitious [1] 23/2
ammunition [1]
34/10

amongst [2] 3/4 63/3
amount [5] 4/15 35/6
81/10 82/25 184/5
amounts [2] 82/18
138/10

analogous [1] 72/23
Andrea [1] 190/12
Angela [3] 80/2
119/25 121/4

angry [1] 155/1
animals [1] 76/1
Anna [3] 39/12 39/15
43/1

Anne [1] 169/22
Anne-Marie [1]
169/22

annexe [1] 183/3
annexes [1] 19/16
announce [1] 178/24
announcement [1]
94/6

another [15] 11/12
33/9 84/2 92/6 92/14
97/18 110/14 125/25
138/25 149/18 169/21
184/6 194/22 197/22
200/7

answer [15] 17/9
24/6 24/6 59/5 59/9
70/25 74/16 80/20
82/3 84/16 85/12 92/8
109/19 121/6 189/25
answering [2] 77/11
114/12

answers [4] 11/14
25/20 27/1 108/1
antagonising [1]
159/17

anticipate [1] 63/20
anticipation [3]
141/1 150/6 175/19
antidepressants [1]
109/11

anxiety [1] 181/20
anxious [1] 191/13
any [69] 3/21 4/11
4/24 5/22 9/3 9/5 9/16
14/18 20/1 24/1 28/4
28/7 29/17 30/6 33/17
36/3 39/9 40/11 40/21
42/1 44/22 56/6 61/14
64/3 66/9 72/25 74/24
76/6 79/1 79/13 83/12
86/15 86/24 87/6 87/8)
87/17 87/22 87/23
89/23 96/4 99/6
101/20 106/8 112/10
112/12 112/17 120/18)
125/10 130/1 133/5
134/11 142/14 146/12)
148/20 148/22 155/11
157/3 164/9 166/24
168/1 169/2 175/1
181/17 185/8 195/20
196/25 201/10 202/14)
202/15
anybody [3] 12/8
114/1 134/14
anyone [6] 33/2
57/14 86/14 87/24
113/19 190/23
anyone's [1] 153/7
anything [15] 12/9
12/15 29/4 29/25 30/4
58/4 65/1 86/5 124/2
165/11 187/18 188/3
191/8 193/24 202/11
anyway [3] 50/25
148/12 159/25
apart [1] 113/7
appalling [4] 59/21
153/22 164/7 202/2
apparently [3] 15/10
15/16 28/21
appeal [16] 132/4
133/9 147/12 152/5
152/9 152/23 155/11
160/6 164/19 172/14
172/16 172/21 173/8
174/19 174/19 180/7
Appeal's [1] 172/15
appealing [4] 152/10
170/8 174/14 174/16
appeals [1] 112/10
appear [2] 27/25
99/19
appearance [1]
187/2
appeared [6] 19/15
53/9 101/9 101/24
102/3 130/2
appearing [1] 186/8
appears [7] 6/2 20/10
64/13 73/9 99/3 99/22
109/20
appetite [1] 76/6
applauded [2] 40/17

42/13

applauding [1] 43/21
applicants [4] 52/20
63/12 63/17 63/19
application [20]
143/11 143/17 143/18}
158/11 158/15 158/18!
162/9 166/1 166/4
166/15 166/18 166/23}
166/25 167/9 167/15
167/17 172/11 172/13
174/17 180/15
applied [3] 13/3
168/16 174/18

apply [5] 71/9 143/13
148/16 162/1 169/12
applying [2] 71/8
185/3

appoint [2] 77/5
181/17

appointed [6] 3/20
69/22 131/24 173/2
184/24 187/5
appointing [2] 175/8
181/24

appointment [5]
21/15 85/18 132/12
146/4 174/7
appoints [2] 73/12
73/18

apposite [1] 165/6
appreciate [2] 1/17
52/4

appreciated [2]

67/13 67/21
approach [15] 49/6
65/11 69/20 162/18
170/19 170/20 173/6
174/11 174/12 175/22
177/15 180/14 188/8
188/9 203/5
approached [2] 10/5
188/15

appropriate [11] 36/8)
55/22 144/19 147/8
156/18 160/18 161/10}
165/15 177/19 183/24
195/4

appropriately [3]
119/5 160/20 176/7
approval [1] 161/8
approve [4] 49/16
122/11 141/18 176/1
approved [2] 141/17
166/4

approving [1] 181/23
April [7] 62/11 63/2
131/25 172/9 172/13
174/18 196/9

April 2015 [4] 62/11
Arabia [2] 51/13
64/24

arbitrate [1] 121/8
arbitrated [1] 133/23

arbitration [4] 24/23

70/2 70/13 134/12
arbitrations [1]

149/23
arbitrator [3] 69/22
69/24 71/18
Arbuthnot [23] 16/17
34/15 34/23 35/3
35/15 38/4 40/4 40/17
42/13 43/18 47/9
47/20 49/20 51/24
55/4 59/2 59/10 64/18
85/22 95/10 98/14

116/22 117/11
Arbuthnot's [3]

14/20 59/22 94/25
architecture [1] 31/7
are [139] 1/24 2/1 2/6
8/23 18/19 22/10
26/19 27/5 27/11
27/13 27/14 27/21
27/23 29/14 31/12
31/14 32/7 33/10 35/2)
37/15 44/13 47/16
47/24 47/24 49/20
50/5 52/10 53/22
55/20 55/21 56/22
63/15 63/21 64/8
71/14 72/12 73/13
75/25 77/10 77/15
78/25 79/11 79/23
80/25 85/2 85/9 88/9
91/18 95/4 95/9 99/5
99/17 99/23 101/19
102/4 102/7 103/1
103/13 103/21 103/21
103/25 105/3 105/20
106/9 106/13 106/17
107/5 107/8 111/19
112/9 120/10 122/16
125/21 125/23 126/17]
128/6 128/16 129/14
129/14 132/16 134/17I
135/4 136/21 138/4
139/23 141/10 141/12)
143/2 143/5 144/19
146/13 151/9 152/8
152/23 154/5 155/17
155/18 156/7 156/22
159/4 161/5 164/16
166/10 170/4 170/6
170/7 170/8 170/25
178/2 178/11 178/12
178/14 179/12 179/13}
182/6 186/5 186/25
188/4 189/21 190/6
190/16 192/8 194/8
194/8 194/9 194/10
194/13 194/14 195/16)
197/3 199/7 199/10
199/13 200/4 200/4
200/6 201/9 202/14
202/23
area [5] 8/6 9/1

151/15 153/2 202/9
areas [2] 122/7
125/14
aren't [1] 153/8
arguably [1] 124/15
argument [2] 36/8
93/7
arise [1] 85/8
arisen [2] 14/24
65/17
arising [3] 85/24
86/18 87/6
arm [1] 87/14
arm's [6] 125/19
146/25 167/20 170/18)
181/22 197/7
arm's-length [1]
197/7
arms [1] 113/12
around [24] 10/5
13/16 55/3 55/7 56/23
58/8 64/23 85/21
87/23 87/25 90/2 90/6)
96/1 101/8 104/16
113/14 117/6 125/7
125/11 134/5 144/6
153/8 177/2 182/13
arrangement [5]
66/13 70/9 70/10
185/7 195/3
arrangements [1]
179/9
arrested [1] 136/15
arrogant [1] 10/23
article [11] 39/7
40/23 42/3 43/7 43/9
43/20 46/4 46/6 46/17
58/24 85/19
artificial [2] 201/19
201/20
as [303]
Ashley [1] 63/6
aside [2] 11/20 137/3
ask [17] 1/9 8/22
14/21 17/15 37/3
47/23 67/1 69/1 71/11
77123 77124 81/13
88/14 116/18 130/19
179/14 191/16
asked [34] 6/4 9/4
14/3 16/2 27/2 30/12
49/19 50/8 51/19 53/6)
55/7 55/25 60/6 68/22
83/10 91/17 100/1
100/15 101/3 108/4
113/15 114/3 140/24
142/1 145/2 148/23
152/4 155/14 155/16
163/8 176/4 183/19
202/10 202/16
asking [7] 29/11 70/9
85/3 87/3 112/1
140/20 162/22
aspect [4] 105/5

(64) alternative... - aspect
A

aspect... [3] 112/10
158/3 165/1
aspects [6] 74/11
74/14 112/11 142/9
153/14 187/4
assertion [3] 79/1
95/19 156/15
asserts [1] 121/13
assessment [1]
141/2
asset [2] 194/8
197/24
assets [7] 194/7
194/9 194/12 194/13
195/21 196/9 196/10
assignment [1]
189/25
assist [9] 78/25
79/11 106/11 107/14
122/16 149/9 151/8
152/13 162/8
assistance [1] 107/9
assistant [1] 150/1
associated [1]
184/18
association [1] 107/5I
assume [10] 15/13
15/24 83/13 122/24
141/14 141/16 151/5
151/21 153/11 166/11
assumed [2] 14/6
190/22
assumption [1]
135/16
assurances [1]
138/23
assured [3] 138/4
138/21 138/22
at [235]
attached [3] 55/17
189/23 190/5
attachment [1] 39/17
attempt [6] 99/3
159/16 160/6 164/19
171/10 178/1
attempts [1] 99/15
attended [2] 150/21
167/10
attending [2] 66/22
67/6
attention [11] 5/1
6/18 14/8 15/9 33/10
112/21 112/25 128/3
182/9 198/3 200/16
attitude [2] 13/17
13/20
attract [1] 95/11
attracted [1] 72/17
attractions [1] 193/1
audible [1] 80/20
audit [5] 23/15 26/15
37/17 135/20 179/5

August [3] 17/3 17/4
38/11

August 20 [1] 38/11
austerity [2] 89/9
92/1

authoritarian [1] 13/2!
authority [3] 134/38
194/11 197/24
authors [1] 129/6
automatic [1] 44/4
automatically [1]
40/10

available [3] 16/5
134/20 183/6
awaited [1] 149/13
awaiting [1] 63/18
awake [1] 51/15
awarded [2] 84/21
180/8

aware [61] 9/16 10/2
13/24 14/1 14/9 14/12
14/17 14/18 14/25
22/19 34/1 34/17
34/19 35/17 35/20
36/16 37/10 48/23
49/18 56/11 58/18
58/19 71/14 73/13
73/19 81/15 81/24
83/16 84/5 84/25
85/22 94/1 94/2 95/24)
97/15 100/19 104/6
111/19 111/21 111/22)
111/25 112/8 117/9
118/7 129/22 129/25
130/1 136/17 138/12
148/20 166/21 170/1
171/20 171/22 175/1
175/17 175/18 186/5
187/20 190/21 200/25)
away [4] 11/10 13/14
83/22 84/7

awkward [1] 34/18

back [31] 9/18 23/8
23/20 24/6 30/11
42/25 45/23 51/24
55/14 66/10 69/2
80/10 90/7 92/1 102/4
103/24 109/20 111/16)
112/5 113/2 133/16
139/18 139/21 146/16)
165/18 175/6 186/2
188/25 193/10 196/11
201/14

backbench [2] 26/12
26/22

backbencher [2]

81/7 112/13
backbenches [1]
80/13

background [8] 2/6
17/2 30/19 89/6 96/5
111/11 116/17 195/9

bad [8] 51/2 51/9
65/9 66/7 108/16
108/24 109/12 109/18
bad’ [1] 191/15
badly [3] 76/23
105/15 171/13
Bailey [4] 47/9 48/19
49/10 55/11
Baker [3] 12/20
53/24 53/25
balanced [1] 98/9
balancing [1] 102/11
bank [3] 40/9 60/12
126/24
bankrupt [1] 57/24
bankruptcy [1] 171/1
bar [1] 169/5
barely [3] 6/14 7/13
75
Baroness [2] 111/8
200/1
Bartholomew [1]
43/1
based [6] 6/10 10/18
22/3 60/4 104/4 109/8
basically [3] 11/15
28/18 171/23
basis [9] 13/13 15/1
36/21 78/25 118/17
138/1 148/15 184/10
185/24
Bates [5] 8/1 10/21
55/5 58/19 65/13
BBC [1] 75/24
be [262]
bear [1] 19/18
bearing [2] 129/16
174/1
became [7] 4/10 10/2
49/18 83/18 87/21
95/20 109/24
because [69] 4/6 4/8
6/21 8/6 8/7 10/15
11/24 14/2 17/4 18/6
18/15 20/14 23/16
24/2 24/10 27/10
30/19 31/19 33/9
34/20 35/3 41/24
42/11 46/10 50/9 51/2
51/11 51/15 53/3
54/24 57/17 60/22
61/20 65/4 69/25 70/3
72/17 73/3 75/1 82/17
84/19 86/9 87/11 89/9
89/22 91/10 92/6
93/23 95/21 96/7
96/14 105/13 122/22
129/13 137/17 140/16
140/22 148/13 150/7
152/25 153/11 162/10}
187/16 189/25 190/8
190/16 199/6 200/5
202/10
become [8] 10/14

14/9 14/25 96/11
112/12 126/18 175/18}
201/16

becoming [3] 120/21
132/10 182/17

beef [1] 27/2

been [211]

BEER [12] 1/7 1/8
71/11 80/14 81/4
85/16 86/3 100/2
100/16 108/1 114/8
204/5

Beer's [1] 88/4
before [49] 2/15 9/20
10/11 12/18 16/25
17/13 20/1 27/4 28/13}
29/5 29/13 30/9 31/6
34/16 53/9 53/18 56/5)
60/8 60/18 71/11
72/21 77/23 80/13
81/14 82/15 87/21
92/21 94/7 101/9
116/18 119/22 123/17]
130/18 131/23 132/3
132/8 140/7 140/17
146/17 154/23 156/12)
156/24 157/10 159/6
177/2 179/23 181/3
188/5 189/15

begin [3] 116/17
128/18 189/6
beginning [7] 7/8
54/25 88/5 123/24
139/21 176/9 193/10
begins [3] 16/8 123/1
128/24

behalf [14] 1/9 12/17
15/11 19/2 25/25
26/14 31/2 31/21
77/25 99/20 106/20
107/6 119/13 169/22
behaved [3] 11/3
144/9 150/9
behaving [1] 134/23
behaviour [3] 72/23
142/11 181/8
behaviours [2] 160/8
164/21
behind [7] 13/11
21/25 76/24 94/19
94/23 97/19 167/18
behold [1] 181/5
being [92] 2/15 6/22
6/23 8/7 19/13 26/11
26/22 33/13 35/10
35/18 35/19 37/8 45/4
45/15 45/16 46/16
51/5 51/14 51/19
53/11 54/22 55/25
60/13 61/22 62/7
64/20 65/4 70/7 74/8
81/16 84/19 85/19
88/6 89/10 95/23
95/25 96/4 96/18 98/7

102/9 103/11 103/14
103/22 104/10 104/13)
105/1 105/6 105/11
105/17 107/15 107/18)
107/19 112/9 112/13
113/15 113/24 113/25)
117/21 118/2 121/7
128/8 130/22 131/9
131/11 131/18 131/20}
133/11 134/18 137/4
137/19 137/21 138/12)
139/23 140/15 140/16
141/3 143/5 143/16
146/9 146/15 153/10
162/24 168/12 169/10)
182/4 184/22 190/15
190/16 192/1 194/17
196/22 200/25
BEIS [11] 123/6
123/8 123/18 144/18
158/9 161/22 178/21
179/5 183/13 190/11
198/10
BEIS0000070 [1]
165/25
BEIS0000071 [1]
172/18
BEIS0000073 [1]
174/4
BEIS0000075 [2]
175/23 186/3
BEIS0000076 [1]
183/2
belief [3] 1/25 2/2
115/16
believe [9] 10/21
25/9 45/15 48/5 48/15)
58/17 68/9 142/11
190/23
believed [3] 54/13
92/10 92/10
bell [1] 45/1
below [7] 109/5
119/1 123/25 150/18
151/14 154/18 174/16)
benefit [3] 50/7
122/18 195/17
benefits [1] 185/3
bespoke [3] 73/15
75/14 75/25
best [7] 1/25 2/1
22/23 65/10 74/14
115/15 196/25
better [7] 67/23
125/8 134/10 139/22
171/23 181/1 201/24
between [31] 2/20
4/20 21/21 22/1 24/17
25/16 27/21 31/15
32/5 40/25 55/20
69/13 70/20 76/16
78/22 97/21 106/3
110/13 115/21 116/13)
124/10 131/19 132/1

(55) aspect... - between
B

between... [8] 133/12
140/5 143/24 144/4
148/18 168/6 169/15
179/21

beyond [1] 188/12
Bhavisha [1] 31/3
biased [2] 33/14
159/15

big [11] 40/19 51/11
67/19 84/21 91/4 92/3
93/7 95/25 96/2 113/4
185/8

bigger [4] 66/14 98/7
98/19 98/25

biggest [1] 122/12
bilked [1] 178/7
billion [10] 74/5
90/21 91/2 91/19
91/21 92/19 93/1 93/5)
93/16 93/18

BIS [26] 30/17 48/23
62/13 62/18 62/19
63/24 64/1 72/19
79/16 79/17 99/10
100/4 100/19 100/25
101/6 104/2 106/24
107/15 107/22 108/14}
114/2 195/19 195/20
195/22 196/6 196/15
bit [17] 11/417/4
18/16 28/24 30/14
42/24 49/25 75/11
105/18 116/17 125/25
127/6 164/14 168/7
192/5 194/16 194/22
bitterly [1] 175/22
BLAKE [5] 115/1
133/17 183/18 203/7
204/16

blame [2] 61/7 61/11
blamed [2] 84/19
199/17

blameless [1] 135/1
blaming [1] 61/8
blank [1] 109/23
blindsided [1] 33/13
blood [1] 51/15
blueprint [1] 198/17
board [73] 25/9
65/24 66/2 66/6 66/8
66/16 68/11 72/8
73/10 73/18 74/2
74/15 74/25 75/12
123/9 124/17 124/24
125/11 125/20 125/22
125/24 151/16 158/10}
158/17 158/20 160/11
160/13 161/6 161/8
161/12 161/20 162/1
162/4 162/6 163/9
163/17 163/24 164/6
164/8 164/10 164/24

165/2 165/5 166/4
167/8 167/11 168/3
171/6 172/22 173/4
174/9 175/9 178/16
178/25 180/1 181/14
181/17 182/6 182/7
182/19 183/9 184/6
184/13 185/6 186/8
187/3 193/23 198/11
198/21 200/6 200/16
200/22 201/2
Board's [2] 125/4
174/12
Boardman [1] 179/5
boards [2] 73/12
75/21
bodies [10] 71/2
75/24 82/8 82/11
84/14 85/10 194/14
194/14 197/24 202/6
body [2] 160/13
197/7
Bogerd [2] 119/25
121/15,
boiled [1] 184/12
boilerplate [3] 35/17
35/21 36/2
boils [1] 188/19
Bolton [1] 23/8
bomb [1] 51/14
book [1] 104/19
boost [1] 173/1
borrow [1] 91/13
both [16] 14/9 19/13
49/13 49/14 93/16
118/11 118/19 131/22)
145/3 147/14 148/8
152/8 153/15 156/5
156/22 173/6
bottom [12] 16/23
26/6 38/21 78/5 78/14
127/18 139/6 150/13
159/7 160/4 163/8
181/12
box [2] 43/7 172/2
branch [6] 10/13
107/14 109/4 109/6
118/15 119/4
branches [8] 56/22
89/13 99/21 103/12
106/22 109/3 138/6
139/9
break [9] 46/22 47/1
56/5 77/14 77/16
77/21 159/6 165/16
165/21
Brexit [1] 113/5
Bridgen [5] 5/25 14/3
24/15 34/6 37/2
brief [5] 4/12 121/24
122/5 128/11 128/13
briefed [6] 8/4 9/15
88/5 88/8 122/22
130/15

briefing [10] 4/17
4/17 7/18 56/6 59/1
94/19 94/23 111/8
122/14 172/20
briefings [3] 123/18
131/14 140/5
briefly [9] 37/23 60/8
149/9 183/2 183/17
193/20 197/17 198/15}
201/11
briefs [4] 19/16 122/2
122/6 122/15
bright [1] 126/7
brilliantly [4] 70/5
bring [6] 46/2 88/16
91/11 97/20 195/6
200/15
bringing [1] 198/3
British [1] 51/17
broad [2] 4/14
174/13
broader [2] 22/7
187/25
broadly [4] 148/4
171/21 171/22 187/23
broke [1] 84/18
brokers [1] 96/23
brought [21] 6/1 6/24
12/2 12/4 13/6 14/3
15/5 22/16 34/6 68/19}
80/16 91/2 94/10
108/2 108/8 112/25
116/19 121/11 151/24
176/5 202/7
Brown [1] 82/16
brushed [1] 11/19
brutal [3] 40/5 41/8
42/5
brutally [1] 105/6
bug [1] 129/24
bugs [1] 129/23
built [1] 48/18
busily [1] 188/5
business [17] 2/15
2/19 40/9 40/15 42/7
42/9 55/21 67/11
91/10 94/18 112/15
113/17 116/12 125/18
140/20 142/25 194/24)
businesses [2] 41/16
198/25
businesses/organisa
tions [1] 198/25
but [230]

Cc

Cabinet [4] 4/3 85/13
116/5 123/12

Cable [7] 1/5 1/6 1/11
38/23 95/4 171/17
204/3

Cadbury [1] 67/11
call [15] 1/5 5/19
5/21 12/12 22/11

33/12 150/17 150/19
154/25 161/15 161/17I
162/20 168/9 168/10
194/14

Callard's [1] 74/17
called [14] 11/15
22/5 33/15 99/24
113/5 121/5 121/12
163/7 164/18 167/1
179/16 179/18 198/6
198/14

calls [4] 53/21 64/10
67/16 166/19

came [41] 4/18 6/9
6/14 7/14 7/15 8/3 8/5
8/18 10/11 10/17
13/17 14/8 19/11
22/22 23/4 25/2 25/6
26/25 34/2 34/8 59/7
60/9 60/14 61/25
67/14 68/8 69/1 80/13)
82/8 82/8 86/8 105/9
112/5 113/2 114/3
120/25 122/24 124/2
126/4 131/5 170/2
Cameron [11] 125/23}
127/2 127/3 127/4
127/14 133/6 147/20
166/13 189/19 190/7
190/8

campaign [3] 40/4
60/22 87/19
campaigned [1]
10/24

campaigning [6]

6/21 11/17 12/17 51/3)
59/3 90/8

can [139] 1/3 1/9
1/18 2/3 9/7 12/16
13/23 16/6 17/18 23/5}
26/4 26/7 26/8 26/9
27/23 30/18 30/24
33/9 33/22 36/11
36/12 37/25 38/20
38/22 39/2 39/10
39/17 39/18 44/23
47/3 47/18 47/19
51/23 52/20 52/23
55/11 55/12 58/13
58/22 62/8 63/1 63/3
63/5 65/22 66/4 67/4
69/7 69/10 69/23
70/23 71/11 74/19
75/3 76/12 78/3 78/10)
78/18 80/6 80/19
83/24 85/3 87/6 94/4
95/14 96/5 97/14 98/4
99/13 100/22 101/13
102/14 114/21 114/22)
115/2 115/10 115/13
116/18 117/23 119/24}
120/13 121/3 121/16
121/21 121/25 123/1
127/16 130/23 132/13

135/8 135/15 138/25
139/16 141/7 141/8
142/6 143/24 143/25
144/21 149/5 149/9
150/11 150/13 150/20)
150/22 151/8 152/13
153/20 154/23 156/12)
156/24 158/5 158/6
160/24 162/8 165/18
165/23 165/25 167/7
167/20 172/24 174/6
175/6 177/21 177/23
180/24 183/2 183/4
185/17 185/25 186/2
187/13 189/14 190/5
190/19 190/24 191/3
192/23 201/11 202/7
can't [18] 27/10
29/16 30/6 38/17
69/25 79/15 87/10
119/18 133/8 138/15
139/12 148/20 164/2
168/14 168/15 186/6
186/12 189/1

cannot [5] 5/12 10/4
27/15 101/18 158/17
capabilities [1]
132/18

capable [3] 5/4 5/4
64/8

capacity [3] 4/25
26/12 200/11

capital [1] 13/12
capture [1] 75/21
captured [1] 74/15
captures [1] 153/14
care [3] 90/7 171/7
182/3

cared [2] 104/7
108/10

career [1] 191/9
careers [1] 193/22
careful [4] 36/6
118/23 120/15 152/7
carefully [6] 42/15
59/11 86/6 155/9
160/11 164/24
carried [3] 20/1 94/3
186/11

carry [4] 74/10
111/11 178/18 179/6
carryover [1] 110/9
Carter [2] 15/17
16/10

Carter's [2] 15/18
16/11

Cartlidge [1] 151/17
case [69] 4/5 5/19
11/7 11/9 11/23 13/8
18/14 18/25 24/8
24/10 28/3 30/19
30/21 52/7 53/5 56/15]
58/8 69/19 71/9 72/6
TAI 74/21 77/1 77/2

(56) between... - case
Cc

case... [45] 83/7 84/6
86/3 86/7 108/3
109/21 116/25 117/4
117/13 117/21 118/7
118/9 118/19 119/1
119/11 119/13 119/20}
119/21 120/5 120/8
120/11 120/14 130/2
133/22 136/14 136/18)
136/25 137/15 137/23
142/9 144/4 145/12
146/4 146/12 146/24
152/1 159/12 159/13
159/22 160/1 169/2
170/7 176/16 182/14
188/18

cases [43] 6/2 7/3
12/2 12/4 12/6 12/8
13/6 14/2 16/20 22/10}
27/14 27/23 29/10
31/20 37/14 37/18
38/6 43/20 49/4 52/21
54/4 55/20 56/22 57/3,
57/11 59/14 59/18
59/19 59/24 70/5
108/8 117/6 128/5
128/6 128/16 128/17
130/3 130/17 130/24
131/4 137/25 137/25
202/1

cash [3] 31/3 89/17
127/19

cast [1] 7/1

Catapult [1] 92/14
category [1] 126/14
caught [3] 33/12 98/1
98/7

cause [4] 49/9 68/16
102/3 177/11

caused [5] 28/10
31/5 35/25 101/23
102/5

causing [1] 64/8
caution [1] 156/15
CCRC [6] 7/3 129/15
131/10 131/22 133/9
134/20

cent [5] 25/23 68/21
68/24 113/6 142/23
centrally [1] 102/14
Centrally’ [1] 102/13
centre [1] 76/20
centred [1] 96/19
CEO [5] 67/6 122/21
125/21 147/19 166/13
CEO-designate [1]
166/13

certain [7] 81/10
82/24 92/13 126/21
165/8 184/17 200/6
certainly [60] 8/4
13/15 17/8 18/23

18/25 20/7 24/9 24/25
32/2 36/24 38/14
38/16 44/21 57/7 61/3
68/8 78/2 79/7 79/15
84/15 87/16 89/18
92/6 92/9 93/23 110/6'
110/8 110/12 112/3
119/18 121/1 124/22
126/7 126/11 126/19
127/14 129/5 129/12
130/4 132/6 134/24
137/13 137/15 140/3
147/25 165/17 167/20)
168/23 169/6 169/14
172/1 176/24 177/7
177/24 184/14 185/9
185/12 191/21 197/19)
201/24

cetera [3] 31/16
134/4 139/9

CFO [2] 125/22 127/2
chain [2] 64/14
127/119

chair [10] 67/14
67/18 93/24 97/8
97/21 161/16 166/9
178/16 179/5 183/9
chairing [1] 201/17
Chairman [3] 60/15
67/5 150/1

Chairs [1] 67/12
challenge [7] 20/22
20/23 21/4 62/7
119/11 178/16 178/24)
challenged [1] 34/9
challenges [1] 9/9
challenging [1] 13/24I
chance [2] 43/19
161/7

change [11] 22/21
66/13 90/11 162/18
175/9 177/14 180/24
183/9 183/9 183/11
184/4

changed [6] 4/8 9/5
161/15 174/23 174/25)
189/11

changes [4] 173/20
175/1 189/20 189/20
chaos [1] 35/25
character [1] 135/1
charge [4] 12/20
22/25 131/7 194/19
charged [9] 10/3
14/14 27/25 37/9 48/9)
104/10 106/16 135/2
138/10

charges [2] 10/6
106/17

charities [1] 199/4
charity [2] 199/5
199/6

check [1] 53/6

Chief [13] 32/6 67/12

67/14 67/19 72/11
93/24 97/21 121/18
124/3 146/4 184/21
184/23 187/4

Chile [1] 13/12
chimed [1] 11/15
chimes [1] 41/9
China [4] 17/5
Chirag [1] 23/10
Chisholm [7] 144/23
145/6 164/11 191/5
192/15 192/18 193/14
Chisholm's [1] 159/8
choice [2] 84/22
188/18

choose [4] 71/16
178/14 182/25 185/15}
chosen [1] 59/11
chronological [1]
9/13

chronology [1]
108/13

churn [2] 3/21 4/8
circular [1] 70/12
ulated [1] 85/19
circumstances [6]
58/12 65/1 106/15
106/18 113/25 156/18}
civil [31] 2/9 2/13
4/21 8/5 17/22 17/23
18/3 20/4 24/7 25/21
28/21 30/17 33/6
33/24 79/17 79/18
79/20 83/4 87/22
109/25 110/10 128/7
129/7 154/15 156/21
195/24 197/1 197/2
197/3 197/8 198/10
civilians [1] 51/14
claim [4] 20/9 28/19
101/21 102/2
claimants [5] 142/10
150/10 156/17 178/22
180/8

claimed [1] 64/9
claims [1] 178/23
clarified [1] 153/3
Clark [9] 114/24
114/25 115/4 115/21
139/4 150/15 191/12
202/18 204/14

Clarke [1] 139/10
class [1] 6/23

clear [33] 31/25
32/24 36/8 53/22
71/12 77/1 78/6 78/15)
79/8 80/24 105/14
105/18 108/9 136/9
144/12 146/11 147/7
150/7 154/1 154/11
154/14 155/1 156/8
156/11 156/24 160/22
165/10 172/6 179/8
182/19 190/13 196/18}

199/13

clearly [26] 9/1 11/11
25/23 35/21 43/11
46/2 50/8 51/10 57/18)
65/25 74/21 74/22
104/22 126/16 128/23}
131/25 137/7 153/15
157/15 158/1 160/15
161/24 169/6 178/5
180/25 201/8

Clegg [1] 3/20
cliché [1] 8/20

close [1] 152/1
closely [2] 43/18
59/8

closer [1] 1/14
closing [1] 32/18
closure [1] 11/1
closures [9] 10/12
10/13 10/24 11/18
13/15 13/17 81/1
88/20 89/23

Clothes [1] 194/3
clue [1] 17/2

Co [1] 99/25
Coalition [2] 2/22
83/22

cod [1] 195/3

code [2] 58/11 154/8
cogent [1] 103/13
cogently [1] 107/19
coin [1] 174/25
coincidence [1] 15/4
cold [1] 44/9

Colin [1] 53/25
collapse [1] 89/12
Colleague [2] 156/6
166/20

colleagues [5] 5/6
46/1 68/9 92/10 203/4;
collected [1] 10/13
collective [2] 53/14
176/20

collectively [2] 125/3
183/1

colleges [1] 76/8
colloquial [1] 77/6
combination [2]
58/11 199/2

come [37] 2/4 4/16
9/11 13/23 17/20 18/2
23/3 24/6 33/16 42/2
54/3 54/5 60/17 61/7
65/22 67/7 89/3 95/14)
104/1 110/7 111/15
114/1 119/21 121/21
122/21 123/19 124/14
125/6 126/16 127/20
130/14 131/21 145/13}
149/5 165/18 167/23
192/5

comes [5] 109/23
136/9 138/21 146/16
198/23

coming [8] 14/19
26/21 35/20 60/10
91/21 96/6 114/11
167/25
commenced [3] 7/4
131/22 131/23
comment [8] 28/22
29/17 30/7 139/16
146/9 147/9 147/25
160/20
commentary [1]
159/24
commenting [1] 29/9
comments [2]
170/11 190/6
commercial [9]
84/13 85/4 132/21
136/3 142/25 193/18
193/22 199/3 199/12
commercially [2]
125/19 191/14
commission [6] 7/4
128/6 128/16 130/24
176/25 178/18
commissioned [4]
150/1 181/1 181/3
198/5

commit [1] 50/24
commitment [4]
63/25 89/17 151/1
151/2

committed [2] 57/22
106/16

Committee [18]
14/21 48/24 49/21
51/4 53/9 55/4 55/16
60/15 62/19 64/1
64/18 72/22 85/21
101/6 101/10 103/20
179/6 201/18
committee's [1]
60/25

committing [2] 103/5
105/24

common [19] 14/13
71/3 110/24 139/15
140/1 141/20 141/22
157/3 172/17 173/8
173/13 173/22 174/11
175/5 177/12 180/9
181/9 186/15 188/10
Commons [2] 60/11
201/18
communicate [1]
178/5
communicated [3]
68/14 96/8 128/19
communication [2]
120/4 186/14
communications [6]
44/16 62/13 107/11
120/3 123/19 144/18
Communities [3]
116/1 116/9 195/1

(57) case... - Communities
Cc

community [4] 103/4
105/22 134/25 199/8
companies [6] 67/9
73/4 82/12 84/21
198/24 199/8
company [16] 72/11
124/21 136/5 173/5
181/22 194/15 194/17)
194/20 194/21 194/22)
195/10 196/20 197/7
197/14 198/15 198/24
comparable [1]
69/15
comparison [1] 57/2
compensated [4]
12/23 157/20 176/8
177/24
compensating [1]
188/2
compensation [7]
12/21 108/6 177/19
177/25 178/6 187/22
189/7
competence [4]
19/23 68/13 108/12
184/11
competency [1]
67/25
competent [2] 7/23
184/17
competition [3] 22/9
70/17 70/18
compiled [1] 43/6
complain [1] 29/1
complaining [2]
28/25 33/5
complaint [5] 7/8
13/12 13/13 24/18
120/19
complaints [7] 27/1
34/14 68/15 69/5
70/11 127/23 128/24
complete [5] 6/11
34/21 81/9 82/20
132/21
completed [4] 7/10
63/10 147/7 156/8
completely [4] 91/22
109/23 113/4 162/24
completeness [1]
175/12
complex [5] 22/13
40/8 41/25 72/4 185/1
complexity [1] 198/8
complicated [2] 71/6
103/13
components [1] 75/3
composition [2]
74/15 75/11
comprehensive [2]
157/12 193/2
computer [19] 7/23

19/14 19/19 19/21
20/6 23/16 31/5 57/10
57/25 58/4 58/17
58/24 59/4 59/10
65/16 72/5 84/17 88/7
98/10
computers [5] 12/9
57/10 58/4 73/1
105/16
computing [1] 12/15
conceivable [1]
162/16
concentrate [1] 51/6
concept [4] 58/7 70/1
70/4 70/12
concern [5] 83/8
159/16 160/18 180/19)
193/9
concerned [7] 34/8
34/24 35/3 35/7 48/25
68/20 79/16
concerning [7] 6/20
9/9 32/25 58/10 62/13
66/5 136/6
concerns [20] 2/18
5/24 14/25 16/11
23/10 26/15 47/25
49/6 52/4 59/14 60/25
62/21 67/25 68/13
68/17 84/8 85/8 87/25
130/1 165/13
conclude [1] 52/14
concluded [5] 120/17I
177/18 191/12 191/17)
192/23
conclusion [9] 52/17
52/25 56/16 62/6 64/7
156/13 156/25 157/6
176/6
conclusions [1]
119/9
conclusive [1] 98/18
conditional [1] 161/8
conditioned [2]
121/1 121/19
conduct [5] 116/23
173/18 180/12 181/7
189/9
conducted [2] 174/2
184/22
conducting [1]
187/19
conduit [1] 187/7
confidence [2]
200/23 201/3
confident [6] 16/13
19/4 59/15 99/5 138/5)
170/6
confidential [2]
55/22 117/24
confined [1] 181/23
confirm [5] 19/8
98/10 98/16 115/13
154/15

confirmation [2]
167/5 185/14
confirmed [2] 105/9
117/4
conflicting [1] 74/11
confronted [1] 67/10
confronting [1] 53/3
congratulates [1]
132/12
connection [2] 91/24
93/12
connoisseurs [1]
154/6
conscientious [1]
5/3
conscious [2] 33/11
41/6
consequences [4]
10/15 57/12 146/14
160/17
consequential [1]
200/18
Conservative [3]
110/16 111/2 111/2
Conservatives [1]
3/17
consider [8] 101/7
128/13 129/3 136/10
155/9 158/21 161/9
165/3
considerable [3]
56/14 117/17 150/10
considerably [1]
192/19
consideration [6]
70/21 92/5 118/24
120/16 152/7 163/18
considered [10]
52/21 62/16 91/7 95/2
118/9 118/16 118/19
149/9 173/24 182/16
considering [4]
55/16 128/6 128/16
170/8
considers [1] 119/3
consistent [9] 27/6
27/7 36/9 68/15
124/22 148/4 159/20
169/15 195/23
conspiracy [1] 99/14
constantly [1] 44/15
constituency [12]
10/12 10/18 11/9
11/18 12/22 104/8
113/8 117/7 117/8
150/25 151/2 190/18
constituent [20] 10/3
13/9 15/17 26/14
27/25 31/2 31/4 48/6
52/6 116/21 116/23
117/18 119/16 129/17]
133/18 134/24 136/15]
142/18 169/23 169/25}
constituent's [1]

120/19
constituents [6]
16/18 32/21 34/14
48/15 112/12 113/9
constituted [1]
125/12
constitution [2] 66/2
66/6
construction [1]
122/12
constructive [1]
195/14
constructively [1]
52/23
consult [2] 20/8
185/10
consultation [1]
103/20
consulted [1] 143/10
consumer [1] 3/6
consumers [2] 41/17
70/19
contact [3] 61/14
112/3 124/7
contacted [2] 101/17
104/8
contacts [1] 104/5
contain [1] 198/24
containing [1] 63/14
contains [2] 64/4
128/14
content [6] 24/9
29/13 44/21 60/4
150/6 185/24
contents [3] 1/24
36/17 172/19
context [6] 54/20
79/20 86/12 87/11
95/2 150/22
continue [6] 47/3
52/22 56/20 128/4
142/8 147/6
continued [1] 55/2
continues [5] 16/10
118/22 154/21 155/6
173/19
continuing [5] 81/7
81/15 83/16 137/14
181/20
continuity [1] 110/11
contract [4] 106/8
106/9 119/6 144/4
contracting [2] 83/4
84/9
contractor [7] 84/9
85/5 85/9 86/11 86/19
87/8 87/17
contracts [5] 84/13
84/20 85/5 85/10
134/3
contractual [4] 27/21
31/15 137/1 198/2
contributed [1] 87/14
contrived [1] 163/16

control [1] 106/24
controlling [1] 160/1
controversial [6]
18/7 18/20 19/17
45/22 75/24 95/22
convenience [1]
178/8
convening [1] 65/19
conversation [6]
145/5 168/12 172/3
189/1 189/21 199/1
conversations [4]
43/25 97/24 175/17
200/24
convey [1] 71/18
convicted [4] 80/5
135/2 137/17 157/18
conviction [1] 119/8
convictions [12] 7/1
7/5 80/5 106/19 128/7
128/17 129/14 149/23)
150/3 193/4 193/5
201/23
Cooper [16] 151/16
152/2 152/5 157/8
157/15 158/7 159/1
159/9 161/18 164/12
165/10 167/10 168/16)
168/25 169/5 169/13
Cooper's [1] 156/15
coordination [1]
85/14
cope [1] 26/3
copied [2] 62/11
167/3
copy [3] 45/11 63/23
146/10
core [5] 77/13 77/23
77/25 195/24 202/14
corporate [9] 67/22
73/15 75/14 192/10
195/3 197/12 199/5
200/19 201/5
corporation [3] 76/5
125/20 137/2
corporations [4]
70/20 75/17 75/23
76/21
correct [25] 2/10
2/17 6/16 11/4 49/17
49/18 88/25 89/2
90/19 95/20 96/10
107/2 115/22 115/23
116/8 116/14 117/12
117/22 119/9 122/4
156/2 175/16 183/16
203/9 203/12
corrected [1] 98/12
correctly [2] 29/20
43/20
correspondence [25]
13/21 15/22 17/11
17/15 17/16 17/22
18/16 24/3 25/17 26/3}

(68) community - correspondence
Cc

correspondence...
[15] 27/2 28/12 33/3
85/21 100/2 100/9
100/10 116/20 119/23
133/19 158/6 159/5
168/24 169/21 171/14}
corresponding [2]
117/10 117/19
corrupt [1] 137/9
cost [2] 92/3 92/4
costly [1] 82/14
costs [5] 132/19
143/5 178/4 180/8
180/20
could [57] 8/16 18/23
33/16 34/9 44/5 44/25)
60/20 64/5 65/10
66/11 80/15 80/16
89/10 91/4 91/15 92/8
92/14 92/18 92/21
93/10 94/20 97/20
106/22 106/23 108/23
110/21 110/22 113/1
114/15 115/10 117/15)
125/4 126/3 132/9
140/21 148/18 150/12
153/4 159/7 163/10
164/13 164/13 165/3
169/9 169/18 172/8
172/9 175/23 176/5
182/20 183/22 186/3
186/19 188/4 188/14
189/11 195/6
couldn't [4] 5/1 6/5
92/17 171/23
counsel [4] 97/24
162/3 173/5 179/2
Counsellor [2] 16/2
18/1
counted [2] 125/4
126/11
counter [2] 13/11
143/18
counterpart [1]
79/14
counterparts [4]
78/12 78/19 78/23
79/2
country [1] 22/10
couple [9] 2/11 53/20
54/4 73/17 78/1
117/20 118/5 163/13
198/7
course [19] 15/8
21/12 28/8 36/22
37/20 46/23 49/19
55/21 58/1 59/16
70/14 74/1 90/15
157/25 161/13 167/17
180/15 181/14 188/14}
court [42] 27/14
27/24 28/1 28/8 29/2

29/9 84/1 111/20
111/24 112/7 112/21
113/20 128/9 128/18
130/25 131/4 132/4
132/4 133/9 133/12
134/6 134/7 134/8
134/20 138/23 139/24)
140/8 140/14 141/3
144/8 144/8 145/12
146/3 146/24 149/20
149/20 149/22 150/4
170/10 170/15 172/15)
174/19
courtesy [6] 5/21
16/3 32/3 53/21 67/16
93/23
courts [6] 6/24 14/15
130/18 131/7 132/3
135/6
cover [3] 43/10 80/10
92/19
coverage [2] 42/20
95/10
covering [4] 18/12
18/12 18/15 40/22
CPS [2] 109/1 202/5
crash [1] 170/22
create [1] 22/24
created [1] 170/20
creating [4] 73/15
75/14 96/22 197/6
credible [1] 160/16
Crichton [1] 97/25
criminal [15] 7/1 7/3
27/15 112/9 128/5
128/7 128/16 129/14
130/2 130/3 130/24
149/22 157/19 193/4
193/5,
crisis [2] 51/11 51/12
critic [1] 41/19
critical [8] 35/10
35/15 51/5 53/15
142/8 152/18 193/25
199/24
criticise [1] 35/16
criticised [3] 84/3
112/19 180/12
criticism [3] 64/4
169/11 170/3
criticisms [3] 20/10
160/19 178/25
critics [1] 65/14
cross [1] 85/2
Crown [1] 28/1
crucial [1] 128/14
culture [2] 142/13
142/15
current [5] 133/25
142/15 142/16 180/5
202/20
currently [4] 142/12
170/4 173/9 202/22
Customs [1] 182/6

cut [2] 30/1 89/10
cuts [1] 92/16
cutting [1] 92/1
cuttings [4] 41/2
41/13 42/16 46/12
CWU [2] 96/1 107/12
cynical [1] 191/1

D

daily [1] 131/4
damage [1] 191/9
dampen [1] 41/24
dance [1] 125/7
dare [1] 35/16
data [1] 15/2
date [8] 17/3 32/24
100/23 139/19 151/24
159/21 187/1 191/10
dated [10] 1/20 15/9
15/15 15/23 23/9
38/22 47/20 51/24
115/8 118/1
dates [1] 111/3
Davey [11] 4/9 5/14
10/17 22/22 25/3 26/9
26/12 30/25 31/8 79/6
90/4
David [7] 15/10 15/18
16/1 38/1 114/25
115/4 204/13
day [12] 17/19 34/24
54/21 56/21 57/1 57/9
95/6 102/21 136/5
136/5 138/7 203/16
day's [4] 41/14
days [6] 64/16 64/20
117/20 144/22 169/20}
188/23
deal [17] 14/7 22/18
22/24 25/24 25/25
27/10 44/16 46/11
48/18 65/7 69/25 76/9
80/12 107/3 113/12
178/1 192/6
deal-making [1]
192/6
dealing [11] 9/12
34/22 36/9 49/22 70/8
85/20 101/2 113/17
120/25 160/17 194/8
dealings [7] 13/4
53/23 54/7 54/9 54/11
87/10 108/1
deals [1] 192/9
dealt [22] 10/23
17/11 17/15 20/4 22/7I
24/20 32/12 35/22
37/18 41/17 53/18
53/19 65/21 80/14
81/3 86/24 89/11
92/21 100/10 113/13
139/12 192/25
Dear [3] 48/22 156/6
166/19

debacle [1] 113/24
debate [10] 10/20
11/5 11/15 22/5 27/8
45/6 74/19 75/3 93/10)
113/9
debates [3] 81/8
81/15 81/18
decade [1] 89/13
December [1] 32/23
decide [3] 46/1 51/13
162/1
decided [5] 118/25
121/15 147/18 172/22}
173/1
decided’ [1] 180/19
decides [2] 158/11
161/6
deciphering [1]
141/14
decision [21] 51/16
84/24 120/10 125/4
125/11 158/10 158/24}
161/14 161/25 162/4
162/5 163/22 165/5
167/10 167/13 168/4
168/15 169/6 174/20
176/18 186/24
decision-making [1]
168/4
decisions [8] 8/16
32/17 45/22 52/9
62/25 122/10 125/21
126/1
decline [2] 120/13
121/16
declined [2] 50/13
54/24
Decommissioning [2]
194/11 197/24
decreased [1] 86/1
deeds [1] 157/19
deep [2] 21/4 113/22
defence [1] 143/5
defend [1] 171/4
deferential [1] 50/1
deferred [2] 44/19
118/17
defined [1] 196/9
defines [1] 196/8
definitely [1] 126/13
definition [1] 126/8
degree [1] 82/9
delegation [2] 14/3
37/13
deliver [1] 195/20
delivering [1] 67/19
Deloitte [1] 7/9
demanding [1] 135/4
demeanour [1]
154/25
democracy [1] 75/6
Democrat [1] 80/22
den [2] 119/25 121/4
denial [1] 159/19

denied [1] 180/6
denotes [1] 194/12
deny [2] 103/6
105/25
department [66] 2/12
4/15 6/9 8/19 8/25 9/1
15/25 17/4 17/17
21/16 24/5 25/22
27/23 29/18 35/23
41/3 41/5 42/18 51/5
61/23 68/16 72/20
84/18 89/5 106/24
115/25 122/3 122/24
124/16 124/23 125/9
126/9 127/8 130/19
134/2 140/21 143/10
143/19 143/23 144/2
145/24 146/18 147/1
148/11 151/12 155/10)
155/16 159/25 160/15}
160/22 163/4 167/14
168/1 169/12 169/21
171/18 177/6 180/2
181/21 192/24 194/25)
195/1 195/15 197/20
197/21 198/4
Department's [3]
123/3 123/12 143/9
Department/Govern
ment [1] 35/23
departmental [2]
18/5 87/8
departments [10]
61/4 72/7 73/4 79/16
84/12 84/14 85/6
85/11 194/24 195/17
depended [3] 50/17
50/21 96/17
dependent [1] 144/7
depending [3] 45/21
93/9 173/21
depends [1] 136/22
deposit [1] 130/20
deprecated [1] 181/8
deputation [2] 12/2
12/3
Deputy [1] 161/22
describe [8] 17/10
99/12 104/4 113/2
131/17 150/9 150/22
176/11
described [14] 9/6
10/19 10/21 13/18
22/4 24/2 104/6 108/9I
131/18 149/7 162/2
173/13 181/2 182/11
describes [2] 145/21
196/21
description [6] 10/23
13/2 13/5 102/15
103/9 105/19
designate [1] 166/13
designed [4] 63/17
63/18 87/12 132/17

(69) correspondence... - designed
D

desire [3] 103/3
105/21 160/19
desk [3] 6/14 7/14
7/16
despite [4] 43/25
121/14 133/23 137/15}
desserts [1] 178/10
detached [1] 160/16
detail [14] 4/16 29/6
29/8 29/16 30/5 44/22
49/14 66/4 124/14
129/24 130/14 145/7
151/23 152/2
detailed [4] 17/13
36/25 60/24 124/6
details [3] 70/4 70/14
117/5
determination [1]
131/1
determine [5] 48/3
134/21 135/6 144/13
146/24
determined [3] 27/24
133/11 139/25
detriment [4] 150/10
172/5 177/21 177/21
detrimental [1] 70/19
develop [1] 87/12
developed [3] 84/2
85/25 191/11
developing [1]
132/16
development [5]
63/7 85/23 86/18 87/2
201/18
developments [1]
172/10
devote [1] 113/6
DG [1] 124/4
diaries [1] 127/10
diary [2] 5/13 5/16
did [86] 3/21 4/11
4/24 6/16 10/14 12/8
12/19 14/9 14/25
15/25 22/17 23/15
24/22 28/18 32/10
34/12 35/1 35/6 35/15
36/18 36/20 36/20
41/7 42/9 46/8 48/7
49/15 50/24 51/5
51/23 57/14 60/7
61/12 61/24 67/25
68/15 69/21 72/3
83/22 86/8 87/24 88/5
89/3 89/19 90/5 90/7
90/21 91/9 93/21
96/25 103/16 107/22
107/24 109/16 112/10}
113/18 114/1 117/6
119/16 128/21 132/24}
134/14 135/16 142/14)
143/13 144/9 148/9

151/4 155/4 165/12
173/11 175/3 177/20
179/14 179/15 179/17)
183/17 184/2 185/15
186/12 190/8 190/10
191/14 193/4 193/13
200/23
didn't [69] 8/8 13/11
23/3 24/8 25/24 29/1
33/11 34/6 35/3 37/6
38/12 38/15 38/15
42/1 42/15 44/19
44/21 44/25 45/17
46/6 55/8 61/10 68/2
68/4 68/18 69/5 70/3
70/4 81/12 81/23
82/21 83/21 86/4 86/6)
89/19 90/6 91/3 92/20
93/19 97/10 97/15
104/1 104/3 104/12
105/13 111/1 111/7
113/10 114/6 121/6
128/23 129/12 133/20)
136/13 140/4 140/14
145/14 148/16 149/4
149/25 157/21 157/22)
166/24 169/16 183/19)
190/24 192/13 194/25)
201/10
difference [8] 40/25
41/1 44/24 50/24 70/7)
148/17 148/21 188/15)
differences [1] 43/22
different [48] 18/18
28/16 33/25 35/12
35/13 35/13 35/14
36/1 44/9 44/10 45/2
49/20 61/8 61/9 61/16
69/19 74/10 74/14
75/3 76/1 76/1 81/25
84/10 84/13 84/13
84/14 85/4 85/5 85/6
85/9 85/10 85/10
87/11 100/19 115/24
117/6 118/24 126/9
126/10 135/13 138/2
138/17 144/3 145/15
184/2 186/25 188/9
192/2
differentiated [1]
50/22
differentiation [1]
14/13
differently [1] 8/17
difficult [11] 3/23
8/15 18/7 20/5 45/22
51/10 74/9 89/9
146/12 187/18 190/20)
difficulties [7] 48/12
85/22 85/24 86/17
86/18 103/11 107/10
difficulty [3] 136/8
187/15 197/1
dig [1] 28/24

digital [2] 6/7 132/18
digression [1]
193/13
dilatory [1] 187/9
mma [1] 200/4
diligence [2] 72/24
179/7
dimension [1] 24/12
dinner [1] 163/5
diplomatic [1] 154/4
direct [18] 64/10
136/4 145/25 149/4
154/20 160/22 173/3
174/8 175/9 176/13
181/13 181/24 184/2
194/18 195/20 197/15}
198/22 199/14
directed [6] 3/18
17/21 125/3 171/18
172/4 181/5
directing [2] 124/24
173/15
direction [6] 32/14
46/19 90/17 97/13
175/4 179/24
directions [1] 182/5
ctive [1] 187/10
directly [14] 23/10
25/10 67/10 96/6
104/12 123/21 124/6
125/10 147/1 147/9
171/15 172/15 174/18}
198/10
director [14] 67/9
124/18 124/18 124/19)
124/25 125/1 125/5
151/14 161/22 176/12
179/4 182/5 182/17
198/20
directorates [1]
122/3
directors [3] 123/25
141/18 182/4
disadvantage [1]
153/5
disadvantaged [1]
171/2
disagrees [1] 158/14
disappointing [2]
175/11 175/22
disappointment [1]
59/5
disappoints [1]
127/11
disassociate [1]
163/25
disasters [3] 81/9
82/13 82/20
disastrous [1] 57/12
discharge [2] 74/24
199/20
disciplinary [3]
101/19 107/7 136/24
disclosed [6] 117/25

137/10 155/22 168/18
175/13 200/21
discloses [1] 169/23
disclosure [4] 48/13
48/16 48/17 134/9
disclosures [1]
168/8
disconnected [1]
90/14
discount [3] 93/9
183/17 183/19
discovered [9] 34/16
107/17 109/6 109/7
149/24 162/19 162/19}
168/7 168/15
discovery [2] 6/25
131/1
discrepancies [3]
40/14 43/14 65/16
discrepancy [1]
40/11
discretion [1] 45/25
discuss [5] 60/8
122/21 151/3 176/15
185/25
discussed [8] 25/3
96/4 105/11 106/3
152/5 155/12 164/10
194/18
discussing [1] 133/3
discussion [11]
44/15 87/6 152/14
158/13 158/22 164/8
165/9 176/20 176/24
182/22 192/21
discussions [7]
16/16 22/23 38/3
87/17 101/5 177/1
177/17
dismiss [1] 185/6
dismissed [1] 172/13
dismissing [2] 180/1
184/6
dismissive [1]
142/20
dispute [2] 70/2 91/4
disputes [1] 55/20
disquiet [1] 66/9
disreputably [2]
144/9 150/9
disrupt [1] 99/5
disruption [1] 177/23
dissent [1] 157/25
dissolved [1] 62/22
distance [3] 79/4
146/18 147/8
distinct [1] 160/15
distinction [7] 14/16
32/19 76/16 78/21
78/24 136/9 143/24
distinguished [1]
193/22
distortion [1] 70/18
distress [1] 37/14

distressing [2] 6/2
12/1
distribution [1] 43/3
diversionary [1]
95/12
divided [1] 4/20
do [109] 1/21 1/23
4/14 4/23 5/15 6/6
7/15 9/16 11/21 12/15
14/15 17/13 18/6 25/2)
25/16 29/2 29/4 29/13}
34/10 34/18 35/9
35/10 39/10 41/11
49/9 50/7 54/14 54/16)
55/8 56/1 59/18 60/6
61/7 66/17 68/8 68/23
72/13 73/22 74/22
75/8 75/16 77/25
79/15 82/21 82/21
86/5 94/1 98/6 99/7
103/1 103/12 103/14
108/23 109/16 109/22)
112/18 119/22 123/19)
125/1 127/2 127/4
128/13 129/2 130/14
131/14 132/23 133/2
136/4 136/10 136/19
141/12 142/11 145/5
150/23 152/10 152/24)
155/20 156/6 156/13
160/13 163/1 163/10
164/13 170/16 176/10)
177/11 177/12 177/15)
177/18 181/5 182/3
182/20 182/20 185/10}
186/23 187/3 191/8
192/9 192/9 192/9
192/12 192/18 193/3
194/16 196/17 198/15)
198/21 201/12 203/10)
document [12] 18/12
18/15 42/16 100/22
100/23 159/6 164/18
189/15 190/5 190/22
191/1 193/15
documents [7] 2/4
5/11 28/10 48/2 48/14I
121/2 158/4
does [19] 43/9 64/3
70/19 71/17 76/22
98/25 99/2 110/16
110/23 120/18 123/16)
137/7 139/18 144/16
158/19 159/24 164/17)
174/23 181/13
doesn't [11] 5/22
24/19 57/16 57/24
121/13 171/6 1741/7
174/22 177/6 191/8
194/19
doing [17] 36/23
37/15 41/7 41/20 45/6I
54/13 66/3 66/5 66/14
89/20 103/4 105/22

(60) desire - doing
D
doing... [5] 105/24
181/4 184/15 187/16
187/18
domain [1] 193/3
don't [70] 5/2 18/19
22/12 25/22 29/14
30/3 36/20 39/14
39/15 41/21 44/14
57/9 58/3 58/23 62/1
75/19 84/6 85/12
86/10 90/1 95/19
95/25 96/17 96/25
99/8 100/6 101/9
104/3 104/18 105/11
110/24 112/17 121/3
121/16 127/8 127/8
127/9 132/24 133/5
135/14 137/5 142/17
148/20 148/22 155/1
157/23 161/9 163/6
167/16 171/16 175/6
175/13 182/12 184/1
187/1 188/16 189/24
190/23 191/20 192/20)
192/20 193/24 194/19}
195/4 197/2 197/4
197/5 199/19 201/5
202/14
done [24] 6/8 8/17
20/25 44/25 54/19
54/20 58/2 65/1 65/19)
65/20 66/12 66/18
71/1 89/14 121/17
150/2 153/18 154/2
155/3 156/16 165/13
186/13 186/20 188/4
door [1] 93/2
double [4] 67/16
doubt [6] 7/1 54/14
64/15 108/12 126/16
187/5
down [50] 3/14 8/5
9/7 13/23 16/22 23/6
23/11 47/21 65/22
84/18 95/14 102/9
118/3 120/1 121/21
123/1 125/14 127/16
132/12 132/13 139/5
141/24 142/5 143/7
149/5 149/22 150/12
150/20 150/24 151/8
151/23 158/6 160/3
166/6 167/7 170/2
172/10 172/23 174/6
180/3 181/10 182/24
183/4 183/10 183/12
184/12 186/3 188/19
189/22 193/15
downsides [1]
194/17
dozen [2] 92/15
113/13

draft [11] 15/10
15/14 16/1 16/7 49/16
49/23 50/16 50/23
51/21 51/23 141/7
drafted [3] 15/13
141/12 141/16
drafting [3] 29/7 30/5
122/17

dramatic [1] 89/14
draw [3] 14/16 33/3
76/18

drawing [6] 10/25
33/10 71/8 142/17
182/9 187/21

drawn [5] 6/17 15/9
119/9 151/20 200/6
dropped [1] 106/17
dubious [1] 192/3
due [4] 59/16 72/24
103/2 179/6

during [15] 3/1 28/3
34/13 48/25 59/6
114/2 116/15 118/1
119/19 124/22 137/12)
138/24 186/11 191/21
195/7

duties [2] 74/24
199/20

duty [7] 73/14 73/19
73/23 74/18 74/23
151/18 151/20

DWP [1] 123/12
dying [1] 91/10

E

each [6] 27/17 35/18
58/12 122/2 123/24
124/15,

earlier [24] 19/11
22/5 24/22 25/20
28/15 45/23 50/20
50/25 53/24 56/8
61/20 64/23 66/12
68/2 104/4 116/25
162/14 175/2 187/11
192/19 192/21 201/24)
202/2 202/7

early [8] 85/23 86/17
86/21 109/7 133/2
140/21 144/17 148/1
earned [1] 97/8
earth [1] 19/22
easier [1] 199/16
easily [1] 126/3

East [1] 23/8

easy [1] 66/14

echo [1] 148/9
economics [1] 22/13
economist [1] 2/7
Ed [11] 4/9 5/14
10/17 22/22 25/3 26/9)
26/12 30/25 31/8 79/6
90/4

edifice [1] 193/6

Edwards [1] 203/11
effect [12] 71/16
71/20 138/20 153/5
172/3 173/15 175/21
179/24 179/25 182/17
189/2 189/4
effective [2] 108/7
198/2
effectively [7] 22/25
TAIT 89/21 90/4
133/11 148/5 188/17
effects [1] 202/3
eight [2] 109/2 109/4
either [20] 6/3 17/23
24/6 30/12 40/14
51/15 81/22 85/22
85/25 100/2 102/17
120/12 121/16 136/25}
138/13 163/3 171/6
182/25 184/6 188/18
elaborate [1] 11/4
elapsed [1] 117/17
Eleanor [1] 135/10
elected [1] 2/15
election [2] 62/24
109/19
Electronic [1] 101/22
else [4] 40/16 42/9
136/21 202/11
email [22] 6/10 38/22
38/23 40/22 42/25
43/3 62/12 62/21 63/2
64/14 97/21 98/19
139/3 150/14 158/7
160/4 161/2 163/11
163/20 169/24 189/17
189/18
emails [1] 17/20
embarrassed [1]
190/15
emerged [3] 12/15
14/16 14/23
emergency [1] 77/2
eminent [1] 89/24
emotional [1] 104/23
Emperor's [1] 194/2
emphasis [1] 158/2
emphatic [1] 154/17
employ [1] 197/14
employed [1] 199/25
employee [1] 136/25
employees [1]
107/13
enable [2] 91/9
195/14
enabled [1] 101/24
enclosed [3] 15/16
117/24 120/4
enclosing [1] 16/9
encountered [1]
112/16
encouragement [1]
67/18
encouraging [3]

39/24 175/10 192/12
end [15] 6/10 7/8 8/3
14/19 15/3 50/10
54/21 62/8 64/19
108/20 109/6 131/21
172I7 175/7 189/3
ended [1] 129/9
ending [2] 65/4 69/8
endorsed [1] 174/12
endorsement [1]
162/4
Energy [1] 116/12
enforcement [1]
13/25
engaged [3] 22/8
112/20 181/8
engagement [3]
100/13 195/14 195/21
engagements [1]
150/25
engaging [1] 78/17
engineer [2] 161/5
164/3
engineering [2]
161/19 164/5
enormous [3] 35/6
58/1 61/13
enormously [1]
89/15
enough [6] 26/10
61/2 129/19 145/7
157/2 157/5
enquiries [3] 19/6
19/25 171/9
enrich [2] 103/6
105/25
ensure [10] 49/8
52/19 52/23 76/22
85/14 144/19 155/10
156/16 173/23 191/23}
ensuring [1] 176/6
entered [2] 2/9 132/2
enterprise [1] 8/18
enterprises [1] 77/8
enthusiasm [1]
41/24
entirely [12] 36/8
45/7 50/3 50/17 50/21
70/13 94/17 110/10
120/10 144/7 145/14
190/13
entities [1] 72/7
entitled [2] 158/1
172/24
entitlement [1] 178/6
entity [1] 95/9
entrenched [1] 171/5
envelope [1] 182/23
envisage [1] 198/15
envisaged [2] 49/2
71/23
episode [5] 44/14
60/9 60/18 62/8
162/10

Equally [1] 48/16
ity [1] 192/7

equivalent [1] 124/4
errors [5] 40/6 42/6
43/14 101/23 101/24
escalated [1] 68/11
escalating [1] 180/20
especially [2] 146/13
147/15
essence [1] 197/21
essential [3] 95/15
128/20 185/2
essentially [21] 3/19
12/11 34/15 35/17
43/2 44/9 49/22 62/15)
90/3 106/24 108/22
111/10 130/12 130/21
168/13 168/21 177/9
ATTINT 179/23 184/5
184/12
established [9] 20/24
29/19 29/20 35/24
36/7 49/2 73/22 74/17
74/22
establishing [2]
69/16 111/5
et [3] 31/16 134/4
139/9
et cetera [2] 31/16
134/4
Europe [1] 122/13
Evans [1] 161/22
even [25] 18/14 21/9
23/15 37/22 39/25
54/23 91/25 92/15
110/18 111/9 121/9
133/3 135/5 140/12
140/19 161/10 163/19)
163/21 163/24 164/13)
165/4 178/8 180/25
181/7 201/5
evening [9] 33/16
98/1 151/1 162/20
162/21 163/4 163/11
167/1 168/9
event [1] 118/15
events [5] 6/20 8/16
15/4 29/22 166/20
ever [19] 4/24 12/8
17/4 19/15 34/8 54/9
57/14 60/9 60/22
67/25 68/3 68/11
86/11 95/25 96/25
102/11 105/11 148/14)
182/14
every [15] 34/2 35/18
36/1 41/1 56/21 57/1
101/10 105/5 136/22
138/7 145/18 145/18
162/15 176/12 176/13}
everybody [1] 36/9
everything [3] 6/8
41/2 182/20

(61) doing... - everything
E

evicted [1] 12/22
evidence [37] 6/25
24/12 43/12 48/8
48/24 49/3 50/14
52/16 52/24 56/15
58/9 79/6 81/24 87/1
87/4 97/1 98/9 101/12
108/15 111/1 112/2
134/17 134/22 154/14)
155/21 157/16 167/22)
168/18 170/11 193/10
200/12 200/12 200/20
201/9 201/13 202/19
202/24
evident [3] 140/15
152/20 199/1
ex [2] 16/18 168/15
ex-subpostmaster
[1] 16/18
exact [1] 189/2
exacting [1] 159/13
exactly [8] 10/4
31/20 32/4 46/18
46/20 62/2 71/23
111/4
examine [1] 131/5
examining [1] 107/21
example [26] 4/10
5/22 7/23 11/17 27/8
48/5 60/15 83/24 97/9
97/18 113/12 122/9
126/4 126/24 128/21
129/17 129/22 136/9
186/10 186/14 187/21
197/9 197/22 199/4
200/15 200/23
examples [3] 82/4
130/14 194/6
except [3] 24/12
36/20 190/15
exception [2] 34/5
197/15
exceptions [1]
100/10
excessive [2] 104/14
198/9
exchange [3] 45/24
63/1 164/1
exclusive [1] 178/15
execute [1] 132/20
Executive [17] 15/14
32/6 66/25 67/9 67/14,
67/19 93/24 97/21
121/19 124/3 125/23
146/4 169/10 171/6
184/21 184/23 187/5
executives [2] 67/12
127/5
exercise [1] 46/13
existence [2] 58/18
58/20
existing [1] 90/15

expand [3] 69/23
69/25 70/23
expect [17] 19/6
19/25 28/13 29/4
29/12 33/2 45/11
45/19 49/7 63/7 88/5
125/16 142/8 142/10
166/5 171/16 173/25
expected [16] 19/10
19/12 20/7 21/3 21/11
26/21 26/24 33/6 83/1
83/6 86/14 86/19
86/23 88/2 102/4
195/16
expense [1] 200/7
experience [7] 10/18
22/4 72/2 72/18 80/12
134/24 142/17
experienced [1]
153/14
experiences [2]
11/16 16/11
experiencing [1]
108/11
expert [2] 130/2
189/8
expertise [1] 48/18
explain [12] 17/1
27/17 33/22 44/1
57/13 58/3 58/20
76/12 101/18 106/7
135/24 201/20
explained [12] 11/11
11/13 18/3 18/9 18/13
23/23 32/3 33/19 56/5)
58/16 86/3 108/1
explaining [1] 31/23
explains [1] 195/8
explanation [3]
104/11 105/14 105/18)
explicit [3] 76/9
76/12 181/13
explicitly [1] 184/7
explore [2] 30/9
57/14
export [1] 51/13
exposed [2] 40/19
42/14
express [2] 160/19
161/11
expressed [7] 53/16
59/5 159/9 180/19
185/23 190/21 201/3
expressing [1] 22/6
expulsions [1] 12/6
extensively [1] 80/25
extent [6] 54/7 64/21
89/7 140/7 146/21
189/9
external [2] 16/19
38/5
extract [1] 39/21
extremely [1] 141/4
eye [5] 39/21 46/4

46/6 85/19 201/22
eyes [3] 95/7 173/25
175/21

F

face [5] 13/19 13/19
61/6 61/6 180/16
faced [2] 40/14
102/11
facilitate [1] 195/13
fact [29] 8/12 8/19
26/7 27/3 30/22 33/24
42/12 45/3 56/10 69/4
75/25 82/15 97/4
102/25 120/2 120/24
121/14 130/17 133/23
134/6 134/17 137/4
141/17 148/22 153/3
153/12 182/1 187/14
194/15
factor [6] 7/25 92/6
96/1 96/2 97/12 97/16
factors [4] 95/24
96/17 96/19 96/23
facts [3] 43/10
120/16 123/2
factual [1] 140/13
failed [1] 73/10
failing [4] 35/10 61/7
69/6 76/9
failings [3] 40/5
40/12 42/5
failure [7] 9/2 65/25
66/11 73/9 73/11
200/15 200/18
failures [7] 43/12
72/6 78/7 78/16 81/18
81/25 85/1
fair [14] 15/24 26/2
67/1 82/10 82/22
82/23 83/19 97/14
129/3 129/6 140/5
167/15 187/8 191/18
fairly [5] 27/6 44/17
52/21 85/17 122/8
faith [1] 184/10
Falcon [2] 108/25
109/10
fall [1] 73/5
fallen [4] 89/12
Fallon [1] 95/4
false [11] 28/1 28/8
40/12 40/15 42/8
48/10 103/5 105/24
106/13 106/14 106/19}
familiar [7] 20/12
24/10 24/10 31/17
31/19 101/5 157/16
family [4] 10/5 10/8
104/9 104/11
far [9] 2/18 9/3 12/8
26/20 78/10 78/17
79/16 107/22 143/19
farmers [2] 22/15

22/16
Farncombe [2]
135/19 139/4
father [1] 31/3
fault [1] 148/19
faults [3] 102/8
147/14 148/8
feature [1] 140/4
February [4] 31/2
48/23 118/1 139/1
Federation [21] 6/1
12/3 12/19 12/23
21/23 22/23 24/14
25/4 34/6 37/2 53/6
53/23 54/11 68/19
90/12 104/17 104/19
105/9 107/4 107/25
108/5
Federation's [1]
54/24
feel [1] 48/3
feelings [3] 190/15
190/17 190/24
feet [2] 103/25 188/5
fellow [3] 59/13
59/24 202/20
felt [5] 79/7 90/9
176/19 191/24 191/25}
few [21] 4/4 11/25
17/16 57/24 60/17
64/16 69/11 72/25
81/13 100/8 100/9
101/3 101/14 144/22
160/3 169/20 184/24
186/9 187/10 187/11
202/16
fewer [1] 56/22
fiduciary [2] 124/17
125/20
Fifth [1] 76/2
fight [1] 188/18
fighting [3] 170/7
170/23 188/5
figure [1] 104/18
figures [1] 40/15
final [11] 12/16 63/10
87/5 115/10 120/5
120/10 120/17 138/3
147/6 175/23 189/15
finally [4] 89/1
161/21 193/15 201/8
finance [5] 72/11
91/14 192/10 195/3
197/12
financial [5] 40/6
92/5 116/3 172/5
177/24
financially [1] 157/13
financing [1] 32/15
find [6] 6/6 20/5
84/18 144/8 159/12
175/21
finding [2] 30/15
173/14

findings [4] 99/4
142/7 159/20 171/10
fine [4] 57/25 71/24
165/19 203/13
finessing [1] 97/22
finish [2] 57/19 92/8
finished [3] 98/2 98/2!
98/17
fire [1] 184/13
firing [1] 181/24
firm [8] 52/18 56/17
99/23 101/16 103/9
103/14 128/1 173/21
firmly [4] 144/10
first [71] 5/20 6/8
11/6 13/24 14/9 14/25}
19/11 23/12 24/25
26/8 26/25 27/9 31/1
31/23 32/2 32/3 36/18
37/10 37/20 46/22
47/18 51/21 52/7 53/4
53/23 55/5 56/13
65/14 68/3 69/13
71/12 74/16 74/16
78/1 79/24 88/18
89/13 90/20 94/10
101/25 108/2 111/22
120/4 122/10 123/4
133/16 136/13 147/5
149/3 149/12 149/19
150/3 151/4 156/22
161/21 163/15 167/3
167/5 167/6 170/1
170/8 172/2 172/12
175/3 175/7 180/7
181/9 185/23 190/22
196/11 196/12
Firstly [2] 67/4 78/21
five [16] 2/24 2/25
3/10 4/2 6/13 6/19
6/21 6/25 7/7 7/13
7/16 8/3 31/23 34/5
69/12 78/5
five-year [8] 3/10
6/19 6/21 6/25 7/7
7/13 7/16 34/5
fix [2] 156/12 156/24
flagged [3] 25/18
25/19 100/12
flaws [4] 40/19 42/14
43/12 64/8
fledged [1] 124/19
flurry [2] 64/15 83/8
focus [3] 6/18 64/25
67/3
focused [1] 46/16
focusing [3] 45/2
56/3 113/7
folder [3] 18/2 48/5
48/7
follow [2] 37/3 79/3
followed [2] 59/7
113/11
following [16] 40/4

(62) evicted - following
F

following... [15] 43/6
43/8 43/23 50/16 84/4)
102/21 112/2 127/23
135/20 166/3 166/18
167/12 174/7 178/14
203/16
follows [6] 120/12
127/22 135/18 151/23}
172/25 176/2
font [1] 39/20
foot [2] 52/13 78/13
footing [1] 132/22
forbid [1] 182/13
force [3] 154/11
158/17 181/3
forced [3] 70/18
171/1 177/18
forces [1] 76/10
forensic [6] 7/5 7/10
14/6 36/23 37/17
118/10
forget [1] 111/3
forgive [1] 165/10
forgiven [1] 60/21
form [3] 28/16 70/2
199/5
formal [4] 8/17 28/9
36/25 61/10
formally [2] 5/6
195/21
formed [3] 11/23
159/22 165/9
forming [1] 83/22
fortune [1] 154/5
forums [1] 130/23
forward [7] 39/10
49/5 132/2 141/6
166/18 175/19 202/7
forwarded [1] 189/23
forwards [1] 44/11
found [12] 5/8 8/15
13/11 98/9 119/24
121/25 128/3 129/21
141/8 170/10 185/17
190/5
four [4] 3/12 3/16 7/6
147/5
fourth [1] 196/7
Fourthly [1] 73/8
frame [1] 92/16
framed [1] 32/12
Framework [1] 179/9
franchise [2] 13/14
68/25
franchises [1] 70/21
frank [4] 8/15 133/21
154/18 157/21
frankly [2] 109/21
169/2
Fraser [6] 111/23
111/23 157/23 159/12)
181/6 188/6

fraud [9] 10/2 12/6
14/2 14/14 37/9
104/10 106/16 109/1
109/8

fray [1] 147/16

free [4] 71/16 147/17
159/4 160/16

Freehills [3] 173/3
174/5 174/8

freelancing [1] 202/8

fresh [2] 173/24
175/20

Friday [3] 63/9
150/24 172/1

fro [1] 168/19

front [5] 1/19 18/17
95/22 115/5 129/14

fruition [1] 23/3

frustrating [1] 127/6

87/7 87/10 87/17
87/24

fulfilled [4] 186/5
full [11] 1/10 2/22
20/6 25/12 30/20
63/21 104/19 108/6
115/2 154/18 177/21
fully [5] 3/24 12/22
16/13 19/4 124/19
functioning [1] 56/4
fund [2] 92/4 168/1
fundamental [1]
103/10

funding [10] 88/18
89/8 90/21 90/22
92/12 93/15 167/14
167/17 191/11 191/21
funds [4] 93/9 135/5
138/11 191/24
further [17] 21/10
23/6 28/24 42/1 42/24
45/9 49/9 51/25
105/18 129/24 144/22)
159/5 159/17 161/2
174/3 183/12 185/25
future [7] 49/9 69/21
93/4 93/6 182/14
182/14 203/2

G

game [1] 153/23
gave [3] 25/20
164/12 192/21

Gavin [1] 151/13
general [19] 7/17
8/25 29/19 32/14 37/7
52/5 53/8 53/16 62/23)
71/7 76/18 97/24
123/25 141/18 149/1
151/14 154/7 176/12
187/8

generally [5] 3/15
9/23 187/24 193/18
201/15

Fujitsu [6] 84/2 85/25

gentleman [1] 50/1
genuine [1] 169/9
genuinely [1] 157/18
geographic [1] 136/1
George [1] 91/18
get [37] 3/21 3/24
4/11 9/7 12/19 22/12
27/15 54/22 58/7 61/5
65/12 83/12 90/6
93/16 95/16 96/14
97/4 103/8 103/16
103/24 103/24 104/2
104/3 108/16 121/9
124/5 140/17 157/1
157/7 158/1 158/19
163/8 178/9 181/18
187/13 190/7 197/10
getting [11] 1/14 27/1
45/5 57/25 89/8 96/13
96/16 108/6 111/18
148/12 202/1
gist [1] 41/3
give [26] 1/10 5/1
30/19 30/20 48/1
67/18 82/4 92/2 94/8
97/18 115/2 124/1
128/21 140/13 145/19}
148/24 157/10 162/17]
172/20 176/12 188/19!
188/21 193/22 194/6
202/5 202/23
given [39] 4/23 7/12
11/2 19/16 20/13
25/14 29/22 29/23
30/1 30/23 34/10
36/25 41/1 50/14
51/22 54/19 54/23
55/19 56/6 70/22
70/25 79/6 79/10
84/20 91/19 113/16
134/18 138/9 161/7
161/24 166/25 168/13}
173/22 175/4 177/17
179/24 182/15 187/9
200/22
giving [6] 19/24
21/21 105/14 157/1
170/11 194/21
glad [1] 80/9
glance [1] 42/22
glanced [5] 41/7
41/12 41/12 42/17
46/10
glancing [1] 41/11
Glenda [1] 30/25
GLO [2] 192/15
192/18
go [36] 9/18 15/20
16/22 21/17 23/8
23/20 26/6 43/7 49/10
50/8 52/12 55/12
55/13 62/8 63/2 68/25)
71/11 76/23 83/21
94/19 94/20 94/21

96/2 100/19 100/22
101/14 102/1 102/6
102/9 113/19 132/14

183/7 191/2
God [1] 182/13
goers [1] 22/17
goes [6] 28/24 45/23
90/7 107/11 147/13
160/4
going [59] 14/22 27/3
32/21 35/21 37/4
48/12 49/10 51/2 51/9
55/1 55/7 65/2 89/15
93/15 93/16 96/5 97/5
97/19 100/5 100/18
100/18 102/22 109/10}
111/14 112/7 112/22
114/23 116/17 116/20}
121/11 122/5 127/1
133/16 134/7 134/21
138/24 140/1 140/13
141/5 144/13 149/3
152/13 155/19 158/4
163/1 164/2 164/3
166/22 171/7 175/24
176/19 178/6 182/20
187/2 187/21 188/25
193/9 198/20 202/23
gone [8] 13/10 30/11
30/14 50/20 56/10
149/24 191/12 191/17]
good [26] 1/3 1/8
1/15 7/23 11/14 35/6
39/8 39/8 41/20 42/10
42/11 46/16 47/3
60/16 80/2 102/13
102/18 102/19 102/25)
105/20 114/21 154/5
173/25 197/9 200/10
200/13
Gordon [1] 82/16
got [23] 11/14 16/22
17/13 21/18 26/25
29/6 32/20 44/17
49/23 55/3 55/6 80/9
91/5 95/23 103/8
109/20 113/20 140/11
162/21 187/1 187/14
193/21 198/1
governance [8]
67/22 73/9 198/9
199/9 200/10 200/11
200/19 201/5
government [104]
2/23 4/3 10/11 10/17
11/24 12/19 20/14
25/2 26/25 35/22
35/23 41/19 41/20
42/21 43/24 44/5 45/3)
45/3 45/6 49/7 52/8
52/11 55/19 55/23
58/15 61/6 70/10
70/11 72/3 72/7 73/4

135/17 154/23 167/19}

73/11 73/18 74/1 75/1
75/2 75/4 75/4 75/6
75/6 75/18 75/19 76/4I
76/8 76/19 76/24 78/8)
78/10 80/13 81/8
81/15 82/7 82/16
83/11 84/9 84/11 85/6I
85/7 85/13 87/7 87/15)
89/10 96/12 99/6
107/15 109/23 110/4
110/8 110/13 110/15
110/16 112/23 113/3
113/19 116/1 116/9
123/8 123/11 123/13
123/15 124/10 124/12)
124/24 125/19 126/15}
126/21 132/5 135/21
135/24 140/20 142/24)
143/10 156/10 167/18
168/6 170/17 170/18
178/9 181/11 188/17
191/13 194/12 197/12)
199/23
Government's [3]
125/15 193/17 200/10)
government-owned
[4] 126/21
governments [1]
8/11
grasp [1] 3/24
grasp/fully [1] 3/24
grateful [5] 55/15
62/21 80/17 100/24
114/13
great [6] 22/18 61/11
64/15 69/25 157/24
193/21
greater [4] 21/22
66/4 92/25 126/23
Greg [2] 139/3
191/12
GREGORY [3]
114/25 115/4 204/13
grew [1] 129/9
grips [1] 3/24
ground [1] 177/10
grounds [1] 44/20
group [23] 3/19 8/2
19/14 59/3 88/23
88/24 91/2 92/17
93/22 96/17 99/11
99/20 106/20 118/2
118/16 118/19 128/7
128/22 129/7 131/23
137/2 174/12 190/15
groups [1] 34/12
guard [1] 199/18
guess [2] 65/6
162/23
guide [3] 123/10
123/15 124/11
guided [1] 162/2
guilty [6] 28/1 44/7
48/10 106/14 109/8

(63) following... - guilty
G

guilty... [1] 157/18
guys [1] 84/23

H

had [246]
hadn't [10] 7/19 56/6
59/25 66/17 67/12
74/13 82/5 82/14
84/23 91/20
Hadston [2] 109/2
109/4
half [4] 92/14 109/3
109/5 113/13
Hamilton [4] 48/7
52/6 80/6 87/20
hand [4] 78/22
109/14 148/10 164/14
handed [2] 149/22
150/24
handle [1] 141/2
handled [5] 8/7 45/16
45/17 90/4 143/6
handling [4] 5/4
105/3 142/9 163/14
hands [2] 51/15
170/25
Hang [3] 103/25
109/17 112/23
hanging [1] 113/14
Hannah [1] 63/6
Hansard [1] 68/7
happen [10] 52/23
63/8 63/21 90/21
91/15 96/9 110/17
110/23 126/23 189/12
happened [25] 7/12
8/13 8/20 13/5 13/7
24/25 25/10 26/21
30/16 30/21 44/13
47/13 51/1 94/5 100/4
104/9 104/11 104/24
108/20 109/13 111/4
112/13 136/18 193/9
201/1
happening [13]
11/14 56/10 65/9 66/8
104/7 105/1 105/15
105/19 108/17 108/24}
109/12 109/18 148/14}
happens [3] 59/17
110/12 169/9
happy [3] 49/24 50/5
4117/2
hard [3] 99/14 146/22
157/24
hardship [1] 108/10
hardware [2] 40/7
42/6
harm [1] 58/2
has [80] 4/3 6/6
10/21 15/9 25/9 28/24
30/14 39/7 40/17

40/18 43/13 48/1 48/4
48/6 48/15 49/4 52/6
52/18 52/25 53/9
56/14 56/16 57/21
57/22 57/23 59/2
59/11 72/2 76/25 87/1
93/7 98/12 101/23
102/2 102/7 106/6
115/18 116/24 117/2
117/4 117/17 118/7
118/9 118/9 118/25
120/14 120/17 127/5
128/3 129/21 136/25
137/10 138/7 142/12
143/19 143/23 157/15)
157/16 160/14 160/22)
161/9 164/9 166/4
170/20 171/3 172/22
173/1 173/2 174/5
174/23 174/25 180/18)
184/19 185/22 185/23)
190/14 192/15 193/17)
196/1 198/19
hasn't [1] 21/18
hauled [1] 72/21
have [361]
haven't [5] 11/8
89/22 102/25 105/20
164/8
having [29] 4/2 20/24
27/17 28/20 29/20
35/24 36/2 36/7 48/11
51/12 59/19 61/12
67/21 70/13 73/6
79/12 84/3 87/18
89/11 92/16 105/20
113/6 157/23 170/24
176/12 192/18 192/20)
193/9 194/23
he [60] 12/4 23/18
26/11 35/3 35/6 35/15
47/21 47/22 53/10
54/5 54/9 58/20 59/4
60/16 60/18 60/24
72/20 74/4 75/1 75/4
75/5 79/7 79/8 139/10
139/13 141/16 144/11
145/1 145/21 146/6
146/23 147/1 147/19
148/5 148/7 151/20
153/14 155/14 155/16)
156/15 158/8 159/9
161/18 161/23 164/12)
164/13 164/17 164/23)
165/11 165/12 165/13)
167/12 169/7 169/25
181/8 187/5 187/6
187/6 191/12 192/16
he'd [1] 53/20
he's [1] 43/24
head [7] 8/4 53/8
54/3 58/8 104/17
139/13 187/14
headed [1] 141/20

heading [1] 94/22
headings [1] 127/16
headlines [2] 41/4
46/14
hear [11] 1/3 36/18
47/4 48/25 49/3 80/9
81/23 114/21 114/24
165/23 167/8
heard [14] 8/2 13/7
27/7 37/1 48/24 55/5
65/13 79/5 87/1
116/24 125/25 162/14
201/9 203/10
hearing [4] 166/16
180/6 197/23 203/16
heart [1] 76/15
held [8] 2/19 4/4 4/12
15/12 27/8 74/25 83/1
115/24
hell [1] 55/7
help [11] 10/6 12/19
12/23 17/9 17/18
84/16 85/3 97/13
103/19 108/5 119/20
helped [1] 12/21
helpful [3] 58/15
76/11 152/12
Helpfully [1] 100/24
helping [1] 96/14
hence [2] 147/15
182/21
Henderson [6] 26/14
27/22 28/5 28/7 28/25)
30/21
her [43] 11/10 11/11
13/14 13/14 26/15
28/10 31/1 31/1 31/2
32/6 37/20 43/3 45/16
48/9 68/4 68/9 68/13
94/10 97/8 97/8 97/24
98/2 108/3 109/1
116/25 117/3 117/4
117/13 117/21 119/18}
119/20 120/5 120/20
121/9 125/22 133/22
136/15 142/24 156/9
158/12 161/10 161/15}
169/24
Herbert [3] 173/2
174/5 174/7
here [29] 9/12 13/1
13/18 22/13 26/11
26/12 41/18 42/22
44/24 51/1 55/1 55/8
58/7 58/24 70/8 72/23,
76/14 86/9 102/10
104/1 109/17 112/24
135/7 143/23 168/17
172/5 181/25 192/4
202/8
here's [1] 95/14
heroic [1] 35/16
Hi [4] 39/6
Hibag [1] 151/21

high [19] 3/15 30/4
40/9 54/12 111/20
111/23 112/7 112/21
113/20 128/2 128/9
128/18 130/25 132/3
134/7 134/8 134/20
139/24 140/7
highlight [1] 39/17
highlighted [1]
164/17
highly [5] 5/3 69/14
95/21 143/12 200/17
him [17] 35/16 43/20
53/19 53/20 54/9
54/12 55/6 79/10
116/23 127/15 148/23
149/2 149/3 149/4
159/17 163/8 192/20
himself [2] 165/11
166/16
hindsight [4] 7/20
67/23 122/19 194/4
hinged [1] 50/3
Hinkley [1] 122/11
his [27] 8/2 10/3
15/17 16/9 22/22
26/12 26/14 35/5
58/20 59/5 59/9 59/11
59/13 60/24 74/22
95/1 124/5 141/1
147/3 150/1 151/19
154/1 163/10 180/7
180/10 191/9 191/10
historic [5] 83/21
132/20 142/11 160/8
164/21
history [1] 32/4
hm [2] 186/22 195/10
HMT [1] 123/12
hoe [1] 40/1
hold [3] 50/23 57/19
74124
holding [2] 3/14
138/20
holidays [1] 17/7
Holliday [1] 198/6
Holloway [2] 151/12
169/23
honest [1] 105/4
honesty [1] 195/25
HONOURABLE [5]
1/6 114/25 116/22
204/2 204/13
hope [5] 98/15 101/6
140/15 177/11 188/7
hoped [4] 65/12 89/1
177/15 189/11
hopeful [1] 52/22
hopes [1] 189/9
hoping [2] 65/6 98/8
Horizon [69] 6/14
6/20 7/11 7/13 7/15
7/21 9/9 15/2 16/14
19/5 21/9 28/4 31/5

33/1 40/1 52/17 52/25
56/4 56/16 56/21
56/24 63/8 64/8 72/2
81/2 81/11 82/25 83/2I
83/15 84/7 85/17
85/23 86/18 87/2
87/25 97/5 98/10
100/8 101/21 102/7
102/12 102/24 103/11
105/12 107/8 113/23
120/23 127/24 128/3
128/11 129/2 129/21
130/10 130/11 130/16)
131/6 131/16 132/25
133/3 134/3 134/16
138/5 140/4 170/5
173/9 187/17 187/20
188/8 188/14
horrendous [1]
113/25

hospitals [2] 76/8
77M

House [4] 60/11
156/7 156/10 201/18
how [48] 7/14 17/14
17/16 20/14 24/20
25/5 29/7 31/11 32/18
35/22 41/16 41/17
44/16 58/5 58/10
58/16 73/25 74/13
89/3 90/13 91/23
93/21 94/4 102/4
104/1 104/15 123/16
123/17 125/12 126/15)
127/13 133/6 141/2
155/5 167/20 176/4
178/19 186/4 187/9
188/3 190/4 191/14
197/4 197/17 198/15
199/6 199/18 203/1
Howe [1] 99/25
However [7] 49/5
64/6 102/15 120/9
128/4 159/22 170/9
Hudgells [1] 80/4
Humphrey [2] 33/12
33/23

hundred [1] 17/19
hundreds [1] 170/24
hurry [1] 50/9

l accept [1] 8/19

l actually [1] 124/14
lagree [1] 146/7

l agreed [2] 10/17
104/25

l almost [2] 17/8
18/25

lalso [2] 104/16
159/16

lam [13] 5/11 29/44
36/15 51/25 52/21
55/15 100/5 142/18

(64) guilty... -Tam
lam... [5] 159/25
160/12 170/1 189/7
202/9

land [2] 162/12
194/4

l appear [1] 99/19

l appeared [1] 101/9
l appreciate [2] 1/17
52/4

lask [1] 1/9

l asked [7] 27/2 50/8
68/22 91/17 108/4
140/24 202/16
lassume [7] 122/24
141/14 141/16 151/5
151/21 153/11 166/11
l assumed [1] 190/22
I became [3] 10/2
95/20 109/24

I been [1] 55/2

I believe [4] 10/21
25/9 48/5 58/17

I believed [1] 92/10
I brought [1] 13/6

I call [2] 1/5 5/19

I called [2] 11/15
163/7

I came [3] 10/11 25/2
113/2

lean [15] 12/16
17/18 33/9 63/5 78/10)
78/18 83/24 97/14
99/13 114/22 115/10
116/18 130/23 153/20}
192/23

Ican't [12] 27/10
30/6 69/25 87/10
119/18 133/8 138/15
148/20 164/2 186/6
186/12 189/1

lI cared [1] 104/7

I caught [1] 98/1

I certainly [10] 36/24
44/21 68/8 79/15
84/15 87/16 112/3
119/18 130/4 184/14

I commissioned [1]
198/5

I could [16] 8/16
18/23 34/9 44/25
60/20 65/10 66/11
89/10 92/8 92/14
97/20 113/1 153/4
169/9 182/20 195/6

I couldn't [1] 171/23

I dealt [2] 32/12
113/13

I declined [2] 50/13
54/24

I describe [4] 17/10
131/17 150/9 176/11

I described [4] 10/19

24/2 131/18 173/13

I did [15] 12/19 36/20
36/20 50/24 51/5
61/24 86/8 88/5 89/19
90/7 132/24 179/15
184/2 190/10 193/13
I didn't [33] 8/8 24/8
33/11 37/6 38/12 42/1
42/15 45/17 46/6 55/8)
68/2 68/4 68/18 81/23
86/4 86/6 89/19 90/6
93/19 97/15 104/12
113/10 129/12 133/20)
136/13 140/14 145/14)
149/4 157/21 157/22
166/24 183/19 190/24)
I discovered [2]
34/16 168/15

Ido [5] 1/23 119/22
127/4 193/3 201/12

I don't [57] 5/2 22/12
25/22 30/3 36/20
39/14 39/15 44/14
75/19 84/6 85/12
86/10 90/1 95/19
95/25 96/17 96/25
99/8 101/9 104/3
104/18 105/11 110/24}
112/17 121/3 127/8
132/24 133/5 135/14
137/5 142/17 148/20
155/1 157/23 161/9
163/6 167/16 171/16
175/6 175/13 182/12
184/1 187/1 188/16
189/24 190/23 191/20)
192/20 192/20 193/24)
194/19 195/4 197/2
197/4 197/5 201/5
202/14
I doubt [4] 64/15
lenvisaged [1] 71/23
lexpect [1] 49/7
l explained [1] 86/3
I felt [2] 176/19
191/24
I find [2] 20/5 159/12
I fire [1] 184/13
I first [7] 6/8 19/11
26/25 89/13 108/2
172/2 190/22
I forget [1] 111/3
I found [1] 8/15
I gave [2] 25/20
192/21
I got [5] 26/25 49/23
95/23 109/20 162/21
I guess [1] 65/6
I had [58] 2/13 5/20
8/6 10/11 11/4 11/16
12/10 14/2 14/3 20/13
22/5 22/20 24/21 25/1
25/20 31/20 31/22
32/13 37/1 40/24

44/17 46/11 50/13
53/5 53/18 54/4 54/14
54/25 55/8 60/10
61/11 64/25 66/1 70/6
72/18 79/18 83/10
83/13 84/20 93/23
95/22 104/5 108/11
122/10 133/17 134/22
141/4 145/13 145/17
148/9 151/1 176/13
177/17 181/1 181/4
182/19 189/11 200/21
I hadn't [2] 56/6
59/25

I happened [1]
112/13

Ihave [19] 5/18
15/17 16/11 26/25
35/5 43/5 49/5 99/12
107/24 113/16 154/23}
159/11 161/19 164/5
184/15 189/22 193/25]
199/21 200/11
Ihaven't [1] 164/8

I hope [3] 98/15
101/6 140/15

I hoped [2] 65/12
177/15

l included [1] 202/11
linfer [2] 122/18
157/9

linferred [1] 153/4

l instituted [1]

123/23

lintend [1] 59/17

l interpreted [2]

105/8 153/19

l intervened [1]
154/11

I just [13] 17/15 41/7
41/15 71/11 80/15
81/13 86/4 94/4
139/16 150/22 169/19}
185/13 187/13
Ikind [1] 136/16
I knew [7] 7/24 12/5
14/1 60/16 112/2
167/3 167/5
I know [5] 8/20 30/8
41/10 66/18 200/24
I known [1] 113/1
Ileft [1] 45/25
Hook [1] 139/21
I made [2] 9/4 202/12
I make [2] 202/4
203/1
I may [2] 145/8
163/13
I mean [43] 4/1 5/2
13/8 18/22 19/18
20/14 30/4 35/1 42/14
42/20 51/10 54/25
57/7 57/12 65/8 65/18
72/16 73/4 75/22

83/20 86/22 91/7
93/10 95/20 104/21
105/12 121/2 122/8
131/19 137/7 149/12
153/12 153/13 153/16
177/21 177/22 186/13}
188/16 188/21 194/6
196/20 200/9 201/13
I mention [2] 83/25
202/10

I mentioned [2]
11/25 68/2

I met [5] 5/5 13/16
89/18 127/14 127/15
I might [3] 62/5
188/12 200/19

I mostly [1] 139/12

I must [1] 52/7

I need [1] 30/19

I needed [6] 18/6
33/25 46/15 51/6
51/20 202/16
Inever [7] 8/2 11/14
17/21 24/1 24/9 61/14}
196/25

Inor [1] 27/23

I not [1] 108/7

I note [3] 52/15
163/11 167/2

I noticed [1] 4/17

I now [1] 67/21

l often [1] 45/9

I only [6] 37/1 41/12
41/12 49/18 60/1
162/19

l organised [1] 10/12
l ought [4] 77/25

I personally [1] 17/12
I probably [3] 54/19
67/12 127/14

I put [1] 187/23

I raised [2] 13/15
113/8

Iread [4] 45/18

I realised [4] 50/3
51/1 51/8 113/14
really [1] 29/16

I recall [7] 9/3 88/1
96/4 145/7 151/19
153/20 154/25

l received [1] 122/15
I recognise [1] 10/22
I recognised [1] 27/5
I recollect [1] 168/11
referred [1] 64/23

I refused [1] 51/21

Iregard [2] 145/12
176/14

I registered [1] 5/23

regret [1] 118/23

Iremain [1] 59/15

I remember [4] 12/8
51/10 82/16 83/8

lI represent [2] 80/3

106/21
I required [1] 141/18
l respectively [1]
170/13
I said [15] 19/10
29/17 36/5 37/15
38/12 50/5 50/7 50/10)
66/12 68/25 88/4
104/9 145/19 157/11
183/20
I saw [5] 12/10 32/18
45/7 93/19 138/19
I say [19] 17/25 18/24
42/15 45/1 46/12 61/8)
61/11 68/18 75/3
94/22 96/18 121/19
123/22 130/18 133/10)
134/2 140/11 153/16
196/21
I see [1] 44/23
I set [5] 21/15 33/14
34/1 119/1 149/11
I should [12] 6/18
7/20 7/21 8/1 65/19
66/21 86/6 101/11
134/24 135/24 162/13)
175/11
I simply [2] 26/2 99/8
I spelt [1] 93/25
I spent [1] 113/7
I spoke [1] 158/9
I started [2] 14/21
104/15
I suggest [1] 77/14
I suggested [1] 42/23
I suppose [3] 56/7
67/7 175/18
I suspect [4] 156/5
163/4 197/5 197/6
I take [1] 83/24
I think [232]
I thought [16] 24/20
37/7 41/9 41/21 42/11
45/4 72/24 121/5
121/17 128/19 134/8
163/15 164/7 184/16
191/1 192/22
Ito [1] 185/10
I told [3] 37/12 93/23
157/1
I took [5] 11/18 17/7
122/9 140/18 153/21
I tried [4] 65/10 84/18)
104/4 201/12
Iturn [1] 36/11
l understand [6]
15/11 28/3 52/6 64/2
161/16 197/5
l understood [1]
168/11
I walked [1] 34/23
I want [6] 50/7 50/10
81/5 139/15 183/21
191/16

(65) lam... -T want
I wanted [7] 37/2
53/4 94/1 138/22
145/15 151/3 179/24
I was [107] 2/11 4/1
4/4 6/5 8/22 9/15 11/5)
11/20 12/1 12/17 14/5)
14/17 15/5 17/3 17/5
19/15 19/16 19/22
20/12 20/13 22/8
22/19 24/10 31/19
31/20 33/11 34/10
36/16 37/13 41/1 45/2
45/8 49/3 49/19 51/11
51/12 51/14 51/17
51/19 53/3 53/7 53/11
54/21 54/23 54/25
56/3 56/7 56/11 58/2
58/15 58/19 60/1 60/2
60/6 64/19 65/6 66/12
71/6 72/17 79/16
80/22 81/7 81/23
84/25 88/8 89/5 90/8
97/16 104/6 104/16
104/18 109/19 109/21
109/24 112/24 113/6
113/15 116/4 117/8
129/16 131/24 134/19}
134/19 135/6 136/17
140/22 141/5 144/12
146/16 150/25 152/13}
152/16 154/20 154/25)
163/3 163/4 167/2
169/6 169/6 171/22
175/18 178/6 182/20
182/22 182/22 187/20)
191/4
I wasn't [16] 8/4 14/1
14/12 19/14 19/19
20/11 30/5 34/17
35/20 49/24 56/5
97/15 111/21 111/25
113/16 129/25
I went [4] 12/18
58/18 82/15 148/23
I were [1] 129/6
I will [3] 2/4 119/22
160/3
I wish [2] 66/1 114/3
I wonder [1] 46/21
I work [1] 99/22
I would [56] 12/12
16/2 17/1 18/16 18/18}
18/22 19/10 19/12
20/7 21/11 26/24 33/6)
34/20 41/3 46/13 55/3
60/5 60/7 61/20 61/23,
62/6 65/6 65/7 70/9
83/6 86/21 86/23
97/17 110/7 112/11
112/15 124/5 132/5
133/8 134/19 138/19
147/13 148/7 155/2

155/4 158/2 162/12
164/15 171/16 175/17)
176/23 177/7 178/4
185/4 185/9 188/7
188/24 191/20 197/19)
197/20 202/24
I wouldn't [3] 4/1
19/21 35/16
I'd [55] 8/2 11/17
11/23 13/7 18/22 27/7)
27/8 29/6 30/12 30/16
32/3 37/12 41/15
42/11 42/17 42/17
44/19 45/15 46/6
46/10 47/12 50/2
51/15 51/16 55/5 55/6
56/8 65/8 65/8 65/13
68/4 68/5 68/6 71/1
71/1 71/6 77/24 80/16)
88/14 89/6 94/9 104/8
110/6 112/12 121/24
123/3 136/15 141/3
148/2 149/2 177/11
179/24 181/3 183/19
190/7
Til [8] 15/19 32/21
100/24 106/10 118/5
187/24 189/15 201/20)
I'm [58] 1/12 1/14
30/8 32/20 34/4 35/14
37/18 37/22 39/15
41/12 49/10 50/23
50/24 54/2 57/8 58/25
61/8 67/8 67/10 73/25)
76/14 80/6 82/11
83/23 85/2 85/3 86/12
87/3 93/11 100/18
100/18 102/22 114/13}
116/17 116/19 122/22)
125/6 127/13 132/24
137/9 137/13 140/1
148/20 148/24 154/15)
158/4 162/24 164/2
164/3 165/8 168/11
169/1 171/22 175/24
199/5 199/22 202/22
203/3
I've [27] 7/12 14/2
15/23 22/4 23/23
51/22 58/14 67/8
70/25 75/9 79/3 79/5
80/9 104/6 107/25
108/9 113/19 119/19
121/10 139/22 165/9
168/7 175/12 187/14
188/2 193/21 201/16
ice [1] 182/10
ICL [2] 84/2 85/25
ICT [1] 87/14
idea [15] 5/18 21/24
22/22 23/2 23/4 25/5
44/11 71/7 72/17
75/16 90/12 91/23
107/24 128/21 141/5

ideal [1] 56/10
identical [2] 149/2
162/15

identified [9] 13/9
28/5 43/15 78/9 78/16
92/13 96/23 98/12
129/23

identify [1] 73/10
identifying [2] 160/7
164/20

identity [1] 79/13

ie [6] 4/14 29/23 33/4
98/25 161/8 196/14
le given [1] 29/23

ie some [1] 161/8

ie the [2] 98/25
196/14

ie there [1] 4/14

ie was [1] 33/4

if [180] 1/12 1/13
1/21 9/9 9/18 12/13
12/16 13/22 14/14
15/6 15/20 16/22 17/3
17/10 17/25 18/22
19/20 19/25 20/18
21/9 21/13 21/17 23/8
23/11 23/11 23/19
23/20 25/24 26/6 29/4
29/14 29/25 30/11
30/12 33/8 33/9 33/17
34/24 35/25 37/25
38/1 46/21 48/19
48/20 52/12 52/12
55/12 55/13 57/16
57/17 57/19 57/21
57/22 57/23 60/6 65/2
66/10 67/23 69/1
72/19 75/6 79/9 80/15
80/16 81/6 83/24
83/24 83/25 84/4 84/7
85/3 85/22 85/23
86/14 86/16 86/24
91/14 91/20 92/8
94/11 94/19 94/20
97/20 98/23 99/13
99/14 100/23 101/14
102/11 102/18 106/12
107/16 110/6 111/9
111/11 112/11 112/16}
112/19 112/20 116/18}
117/23 120/1 121/9
123/1 125/2 125/2
127/16 127/18 129/5
129/18 130/23 132/11
132/12 132/14 134/14
138/3 138/19 139/5
139/20 139/21 141/24]
142/5 143/7 143/13
145/8 147/12 147/14
148/7 149/2 150/12
150/20 151/8 151/23
154/9 154/14 155/20
157/20 157/25 158/6
158/10 158/19 159/1

159/6 159/7 159/8
159/17 160/3 160/24
161/2 161/6 161/10
161/21 163/13 166/6
166/17 167/7 169/4
169/12 169/23 172/9
172/19 172/23 174/6
178/4 180/3 181/10
182/24 183/2 183/4
186/3 190/19 191/19
193/3 193/15 195/6
196/7 196/11 197/11
201/22 203/3
ignoring [1] 109/15
illustrate [1] 12/5
imagine [2] 30/16
187/18
imbalance [5] 21/20
22/1 24/16 24/21
25/15
imbalances [1] 70/20)
immediate [1] 146/14)
immediately [2] 24/4
175/5
immensely [1] 58/1
imminent [1] 62/13
impact [3] 41/6 94/17,
95/12
impacts [2] 70/19
94/22
impartial [1] 45/19
impartiality [1]
195/25
implemented [1]
182/21
implementing [2]
186/7 186/25
implication [2] 56/3
128/17
implicit [2] 73/24
73/25
implied [1] 180/13
implies [1] 154/20
import [1] 157/22
importance [1]
135/22
important [34] 2/18
5/8 5/16 41/14 41/15
46/2 51/2 55/18 57/6
64/6 67/13 73/13
73/18 78/24 94/15
129/11 129/11 129/12}
129/13 133/10 140/15)
140/16 141/4 145/13
151/1 152/17 162/10
176/14 185/8 187/2
190/16 192/22 193/7
200/14
imposes [1] 71/20
impression [3] 11/23
159/20 165/8
imprisoned [1]
106/18
improper [1] 110/2

improperly [2]
134/23 155/8
improve [3] 132/18
197/17 200/10
impudent [2] 121/6
121/17
inability [2] 103/2
105/21
inappropriate [1]
160/10
incensed [1] 152/16
incidentally [1] 37/6
inclined [2] 142/18
159/14
include [4] 40/5
54/17 136/6 181/13
included [3] 126/11
183/19 202/11
including [18] 5/15
6/20 28/9 28/14 29/5
29/13 65/13 80/6 83/3}
83/10 83/17 87/20
120/6 120/16 127/7
136/1 143/20 180/1
inclusion [1] 20/2
incoming [3] 17/9
24/4 65/11
incompatible [1]
162/25
incompetent [1]
17116
inconsistency [1]
120/2
incorporate [1] 28/22
incorporated [1]
20/20
increased [3] 86/1
86/20 129/8
incumbent [1] 29/18
incurred [1] 118/14
indeed [23] 13/20
45/16 53/5 53/7 58/14
64/23 68/22 72/16
78/24 79/21 82/6 86/7I
87/1 93/3 96/12 115/7
118/21 121/9 124/23
127/4 133/1 147/11
181/20
independence [1]
32/11
independent [21]
16/19 20/8 38/5 52/8
55/19 55/20 56/17
69/16 69/21 69/24
70/13 71/18 118/10
120/5 128/1 136/3
142/25 166/3 166/15
179/6 195/19
independently [3]
43/15 45/13 66/24
India [1] 17/5
indicate [2] 172/19
175/3
indicated [1] 152/8

(66) I wanted - indicated
indicates [2] 15/14
162/11
indicating [3] 49/13
81/11 151/25
individual [15] 13/24
16/20 32/16 36/1 38/6
43/19 54/3 72/15
79/13 79/20 104/5
124/9 125/3 149/22
199/17
individually [1]
182/25
individuals [10]
40/13 57/3 67/5 68/12)
110/19 110/20 128/6
181/24 199/19 199/24}
industrial [6] 87/12
87/14 87/19 96/19
116/12 127/20
industries [1] 71/3
industry [10] 2/13
80/23 87/13 163/5
176/3 176/10 176/23
177/5 179/21 185/25
ineffective [1] 193/18
inexperienced [1]
40/13
infer [2] 122/18 157/9
inferred [2] 136/16
153/4
influence [2] 55/23
56/1
influencing [1]
124/24
inform [2] 63/17
118/23
informally [1] 5/7
information [19]
28/14 30/15 48/2
58/25 79/10 81/11
84/11 86/17 100/19
103/16 128/14 128/20)
134/16 134/18 137/11
138/1 179/8 199/14
200/22
information-sharing
[1] 179/8
informative [1]
103/23
informed [3] 5/11
82/7 166/14
infrastructure [1]
185/2
infuriated [1] 192/15
inherently [1] 83/6
inherited [3] 126/9
134/3 144/11
initial [1] 7/8
initiated [1] 157/4
injection [1] 89/17
injections [1] 91/11
injustice [2] 153/18

202/1
Inland [3] 81/8 82/4
82/17
Innovation [1] 2/20
inordinately [1]
25/13
input [1] 125/9
inquiry [27] 1/9 1/19
2/18 5/15 28/13 57/8
58/10 76/15 78/25
79/4 79/11 79/12 85/4
87/1 97/2 104/22
107/21 108/19 111/25)
114/12 116/24 157/16)
164/9 168/8 200/21
201/9 203/4
Inquiry's [1] 115/20
insensitive [1]
142/19
insight [3] 11/2 58/17
133/17
insisted [2] 25/8
66/15
instance [1] 23/24
instances [3] 136/23
138/9 200/14
instantly [2] 152/19
185/5
instead [1] 161/12
instituted [1] 123/23
institutional [1]
66/13
instructed [2] 7/6
99/23
instruction [1] 172/6
instructions [2]
84/20 182/8
integrity [9] 16/13
19/5 19/21 19/23
54/13 54/15 72/9
108/12 195/24
intelligence [3] 85/8
201/19 201/20
intelligent [2] 5/3
30/7
intend [1] 59/17
intended [5] 82/21
94/25 95/1 153/19
189/11
intention [5] 153/22
161/19 164/5 182/7
188/7
inter [1] 151/12
inter-department [1]
151/12
interact [1] 58/12
interaction [1] 54/1
interest [24] 62/20
73/14 73/20 74/5
74/12 74/14 74/18
74/20 74/23 75/2 75/4
75/7 75/22 93/9
146/12 147/18 160/22)
193/24 198/15 199/3

199/3 199/8 199/12
199/12
interested [2] 64/5
201/16
interesting [1]
168/17
interestingly [1]
198/7
interests [3] 86/16
155/18 193/18
interfere [1] 76/25
interfering [1] 11/20
interim [17] 36/16
36/19 40/3 42/3 43/11
43/23 44/8 94/9 94/16
95/2 95/16 97/22
98/21 99/4 146/4
147/19 166/13
interlinked [3] 89/25
91/17 93/19
internal [2] 158/6
176/14
internally [3] 150/2
156/12 156/24
interpretation [2]
79/5 196/16
interpreted [2] 105/8
153/19
interpreting [1] 65/16I
interrelated [1] 93/14
interrogate [2] 20/9
61/23
interrogated [1]
101/10
interrogation [3]
21/11 28/19 36/7
interruption [1] 4/6
interval [1] 179/21
intervene [6] 27/23
44/5 55/23 168/14
168/25 168/25
intervened [2] 113/2
154/11
intervention [2] 78/8
177/10
interventions [1] 9/4
interviews [1] 184/22
into [48] 6/9 7/4
10/11 10/17 11/2
12/18 13/10 19/11
20/20 22/12 25/2
26/25 30/2 30/14 37/8
45/5 58/18 62/11
63/11 68/24 70/11
82/16 98/24 101/1
106/23 107/17 108/14
109/9 111/16 112/5
112/10 112/11 113/3
117/13 120/6 129/23
133/17 145/2 147/3
167/2 171/1 179/25
181/3 198/1 198/6
200/6 201/10 202/8
introduced [3] 56/25

70/8 86/22
introducing [2] 71/5
81/2
introductory [2]
121/24 122/2
invest [1] 192/1
invested [1] 11/9
investigate [3] 41/8
70/11 138/9
investigated [5]
14/10 40/6 42/6
102/15 106/23
investigation [23]
7/4 21/4 21/10 36/4
36/19 36/23 37/5 37/7
37/8 37/11 37/17 38/9
43/18 52/19 53/1
56/17 102/2 117/3
117/13 120/6 127/25
129/20 136/6
investigations [4]
36/12 47/16 52/16
118/12
investing [1] 191/13
investment [3] 17/6
96/24 132/19
investors [1] 96/3
Invite [1] 179/5
involve [3] 10/8
73/15 75/14
involved [29] 10/14
11/1 24/8 27/14 27/15}
29/6 30/5 30/8 43/18
49/8 52/10 67/9 81/1
87/16 87/25 90/6
95/20 95/24 96/11
96/21 97/16 110/19
112/12 120/12 134/11
143/5 158/19 169/11
196/4
involvement [3]
64/19 64/22 160/23
iron [1] 83/12
ironically [1] 26/10
Irrespective [3]
124/9 136/18 196/16
irrevocable [1] 151/2
is [396]
isn't [11] 32/24 51/3
61/4 90/18 92/6 95/14)
110/9 158/1 161/11
166/9 171/16
issue [50] 6/18 8/3
9/8 11/1 11/1 13/15
19/17 21/12 22/8
24/13 24/19 25/18
27/12 29/9 34/7 35/8
36/11 41/25 44/1
44/16 45/1 45/5 45/8
45/13 46/5 46/7 46/8
51/6 53/3 57/8 58/9
60/20 63/8 64/23 65/8)
67/10 80/9 86/4 86/13
89/20 91/7 99/15

1410/7 112/3 113/4
118/16 128/3 129/21
148/10 154/12
issued [4] 63/11
132/4 140/8 155/23
issues [86] 3/25 5/7
9/8 9/16 14/23 18/20
20/7 27/14 27/20
31/14 32/13 34/3 34/4
35/1 35/23 35/24 36/4I
36/7 41/15 46/15 49/9I
49/23 56/13 60/12
61/25 64/9 65/3 66/25]
67/2 81/1 86/8 87/5
87/25 89/6 90/1 91/22
92/13 93/13 94/15
96/20 98/10 100/12
101/7 103/21 107/8
107/19 110/2 112/6
1412/9 112/20 113/8
113/8 113/11 113/13
113/17 113/20 120/22)
127/20 127/22 128/11
130/9 132/25 133/3
139/15 140/1 141/21
141/22 145/2 146/3
157/3 172/17 173/8
173/9 173/13 173/22
174/11 175/5 177/12
180/9 181/9 186/15
187/17 187/20 187/25]
188/10 188/14
Issues’ [2] 174/20
180/8
issuing [1] 63/15
it [770]
it'll [2] 9/10 78/1
it's [85] 1/19 3/21
8/21 9/11 16/22 21/14I
23/9 23/9 26/9 28/25
39/20 43/1 46/21 57/7
58/7 58/23 59/21
61/10 64/15 64/19
65/23 66/18 67/1 67/1
67/7 67/17 69/8 78/4
79/24 80/10 80/17
80/17 81/5 94/11
97/22 110/10 110/24
111/9 113/23 118/1
124/22 130/5 137/2
139/8 142/16 143/13
145/20 145/23 146/22)
153/11 153/12 154/12!
154/19 157/24 158/22)
162/10 163/12 165/10)
169/1 171/11 175/25
180/24 181/21 181/25]
184/10 184/19 184/25)
185/1 185/1 187/18
189/17 189/18 190/13}
190/25 191/2 191/16
191/21 192/6 192/7
194/9 194/15 196/19
198/17 199/7 202/5

(67) indicates - it's
I
items [1] 4/18

its [35] 14/10 16/14
24/17 32/15 36/17
36/19 52/9 63/22 66/3
91/10 91/14 103/24
136/1 137/11 142/9
142/12 143/1 143/2
150/6 159/19 160/15
168/8 170/18 171/4
172/21 173/16 193/1
194/7 194/19 195/13
195/19 195/23 196/19}
198/8 201/10
itself [7] 27/4 83/2
134/6 136/13 140/2
173/18 196/22

J

Jackson [1] 30/25
Jacob [1] 151/12
Jacobs [2] 79/25
99/22
Jacqueline [2]
108/25 109/10
jailed [2] 39/25
137/25
James [18] 16/16
34/15 35/2 38/4 40/4
47/9 47/19 51/24 59/2
85/21 98/14 98/15
111/7 116/22 135/11
135/13 138/21 200/1
January [3] 117/16
139/3 139/20
January 2013 [1]
117/16
Jason [1] 1/8
Javid [1] 110/6
Jo [12] 4/5 5/14
22/18 37/16 37/22
39/1 43/25 48/7 52/6
94/8 94/23 199/25
Jo's [1] 37/24
job [10] 6/8 8/2 35/16
41/6 41/21 66/3 85/13)
109/15 109/20 147/21
jobs [1] 4/4
JOHN [3] 1/6 1/11
204/2
Johnson [2] 81/2
83/9
joining [1] 150/17
Joint [1] 171/1
jointly [1] 199/11
journalists [2] 63/22
112/1
judge [16] 29/15 41/3
134/8 142/2 142/8
146/11 150/7 162/24
166/5 166/16 169/13
170/12 172/13 180/6
180/11 180/19

judge's [3] 143/17
159/20 174/19
judged [3] 24/8 25/23
46/3
judgement [7] 5/2
8/6 12/25 26/1 44/20
55/9 64/17
judgment [56]
139/15 140/2 140/2
140/8 140/16 140/17
140/19 140/21 141/1
141/4 141/8 141/20
141/22 142/3 143/14
144/8 144/13 144/17
144/20 146/8 146/24
147/12 147/23 147/23}
148/1 148/12 149/6
150/24 151/3 151/25
152/1 152/17 153/1
153/24 157/3 157/22
159/23 162/17 170/1
170/9 170/15 171/24
172/2 172/17 173/13
175/16 177/13 180/7
180/10 180/11 180/23)
181/4 181/5 181/9
186/15 193/2
judgments [4]
111/20 111/22 112/20)
179/1
judice [3] 27/24
130/21 147/10
judicial [3] 44/4
130/23 202/9
judiciary [1] 169/11
judicious [1] 192/13
July [16] 1/1 15/16
36/15 38/22 42/4 94/6
94/24 95/5 98/20
98/21 98/22 116/13
116/13 121/22 131/24)
132/11
June [41] 1/20 115/8
175/25 176/3 176/10
176/24 180/11 180/25)
185/18 187/16 187/17,
junior [11] 3/1 3/3 3/9)
3/13 3/17 4/21 4/24
20/21 26/4 100/11
176/18
just [95] 4/3 7/21 9/9
11/4 12/16 17/1 17/13
17/15 18/8 20/22
23/11 23/19 23/20
24/24 26/19 30/8
31/12 32/20 33/9
33/19 37/7 37/17 38/1
41/7 41/14 41/15
42/16 45/2 46/14
47/12 48/20 50/15
51/3 51/22 53/22
55/12 58/2 59/25 60/7
61/13 65/8 70/25
71/11 71/12 71/15

72/17 79/17 80/15
81/13 82/11 82/19
82/21 83/15 83/20
83/24 85/3 86/4 87/18}
92/8 94/4 94/11 94/12
97/18 100/5 101/3
101/14 102/16 102/22
116/17 118/5 119/22
121/3 121/10 123/3
124/1 135/2 136/8
139/16 139/22 145/11
147/25 148/3 150/22
152/13 160/3 160/3
169/19 175/7 175/11
185/13 187/13 188/3
189/6 190/7 199/9
justice [15] 6/22 8/1
19/14 48/4 111/23
111/23 149/21 154/2
155/3 156/16 157/23
159/12 178/22 181/6
188/6

Justice for [1] 6/22
Justice Fraser [1]
159/12

justify [1] 78/8
justly [1] 155/8

K

KC [1] 80/3

keen [2] 135/6 192/8
keep [8] 97/9 103/3
105/21 127/18 147/8
156/10 163/16 183/22
keeping [1] 51/14
Kelly [15] 145/4
146/1 151/10 151/22
151/24 155/12 162/13
162/22 163/9 163/18
166/25 168/12 175/5
187/2 200/1

kept [2] 5/7 6/11
Kevin [2] 15/17 15/18
key [7] 9/8 25/14
92/13 123/2 123/11
136/1 148/10
keystone [1] 193/6
kind [64] 3/14 14/13
18/1 20/22 23/21 24/1
24/13 24/18 25/17
28/12 28/12 28/22
29/5 29/7 29/13 30/6
32/14 44/10 44/15
44/15 70/9 71/19
73/12 77/2 79/4 83/1
83/16 85/14 105/7
122/5 124/20 125/10
126/19 134/4 134/12
136/16 145/21 145/23}
147/25 148/2 153/2
153/23 154/6 154/8
154/8 157/13 157/23
164/9 167/6 177/9
178/3 181/2 181/8

181/25 184/20 192/6
192/8 194/2 195/3
198/1 198/23 200/3
200/8 201/14
kindly [2] 1/18
159/24
kinds [2] 122/6
138/12
knew [13] 7/24 12/5
14/1 25/22 48/8 60/16}
84/15 96/9 97/11
112/2 137/14 167/3
167/5
know [105] 5/15 7/22
8/20 13/11 18/20
25/16 25/22 26/1
27/13 28/7 29/14 30/8)
30/12 30/18 34/12
34/18 36/6 36/20 41/9
41/10 42/21 46/11
66/7 66/18 67/17
67/17 68/18 70/1 74/9)
74/19 75/19 85/12
87/19 90/8 91/15 93/7,
93/22 97/10 99/8
101/11 104/3 104/9
104/18 104/21 105/2
105/2 105/4 107/22
107/23 110/24 112/6
112/8 113/21 118/2
118/13 121/3 129/9
131/4 134/22 136/13
137/2 137/9 137/20
138/1 141/12 142/17
146/22 149/23 149/25
155/2 157/17 157/24
164/2 166/24 168/14
169/1 175/6 175/18
175/19 177/23 177/25}
178/3 180/25 181/21
182/2 184/10 184/25
187/1 192/7 193/14
194/10 194/16 194/24}
196/22 197/3 197/6
197/10 197/11 198/19}
198/19 200/9 200/24
200/24 201/2 201/14
knowing [2] 99/13
122/18
knowledge [12] 1/25
2/1 9/8 9/23 30/13
38/17 69/4 79/12
80/12 110/17 115/15
137/15
knowledgeable [1]
73/2
known [8] 82/9 93/17
97/17 113/14 125/1
136/15 138/1 149/2

L

laboratories [1] 76/8
labour [5] 3/5 27/9
31/22 90/16 110/15

lack [4] 184/10 193/5
200/22 201/3

Lamb [3] 26/10 26/14)
37/23

Lamb's [1] 27/20
Lambert [1] 151/13
land [1] 149/20
language [2] 77/6
79/5

large [14] 5/11 22/14
24/3 34/12 51/16
57/17 70/20 82/18
95/8 99/20 100/15
105/3 137/21 192/1
largely [2] 22/3
142/10

last [19] 1/21 39/24
51/11 52/2 60/12 64/1
64/16 64/20 106/2
113/18 128/15 145/16
157/8 157/9 159/6
171/8 191/11 192/17
202/23

lastly [2] 69/7 76/2
late [2] 85/17 163/12
later [19] 2/11 4/16
63/12 63/24 67/8 68/8
83/11 85/20 86/23
107/20 112/8 113/15
135/14 144/22 161/17)
168/10 169/20 178/3
180/10

latest [1] 199/22
launch [1] 92/1
launched [3] 37/17
91/23 128/8

Laura [2] 62/12 63/2
law [9] 27/16 70/17
101/16 103/9 103/14
153/2 168/22 182/21
199/5

lawyer [2] 159/25
189/8

lawyers [3] 168/20
188/4 188/5

lay [1] 21/25

layer [1] 123/25
layman's [1] 159/15
lead [5] 45/22 58/13
95/22 141/15 179/2
leader [2] 112/14
113/5

leadership [3] 160/7
164/20 185/8

leading [2] 42/7 42/8
Leadsom [1] 190/12
leaked [1] 63/20
learnt [1] 69/11
least [11] 91/1
124/15 126/25 137/11
137/23 147/6 153/4
157/13 200/4 201/3
202/22

leave [2] 4/6 158/11

(68) items - leave
L

leaving [2] 137/3
147/16

lecturing [1] 41/16
led [8] 13/4 34/14
40/12 62/5 70/2 95/23)
133/18 133/24

left [3] 45/25 67/8
99/22

legal [53] 27/14 48/5
90/3 101/16 106/14
124/16 131/21 142/7
143/5 143/9 143/9
143/10 146/7 152/6
152/8 152/14 153/15
153/16 153/23 155/9
155/19 156/7 156/13
156/25 158/9 159/11
159/23 161/9 161/22
163/22 163/23 166/3
167/9 167/12 168/13
168/20 168/24 169/4
169/5 169/10 172/24
173/1 173/5 174/5
174/10 177/14 179/2
179/2 182/10 189/3
189/8 189/8 196/16
legally [3] 72/8 72/13
158/17

legislation [8] 22/16
31/24 60/19 69/15
71/5 72/14 72/16 90/6
legislative [2] 73/16
75/15

legitimate [4] 125/8
156/17 167/19 178/25)
legitimately [1]
188/19

length [6] 2/22
125/19 146/25 167/20)
181/22 197/7

length' [2] 170/19
170/20

lens [1] 130/12

less [1] 91/6
lessons [2] 69/10
71/9

let [9] 17/1 57/19
95/15 97/18 113/21
155/2 189/8 194/6
200/16

let's [5] 61/13 105/17
107/3 108/13 113/18
letter [78] 15/9 15/12
15/14 15/15 15/16
15/18 15/19 15/24
16/6 16/7 16/9 16/10
16/24 17/3 17/8 17/9
18/1 18/4 18/25 20/2
23/7 23/21 23/21
23/25 24/1 24/9 26/8
26/13 26/21 27/5
27/20 28/14 28/23

29/5 29/14 30/2 30/25)
31/1 31/7 31/8 31/14
38/1 38/11 38/15
38/15 47/18 48/19
49/19 49/23 50/2
50/13 51/24 52/3
54/18 54/22 55/10
55/15 55/17 56/2
60/24 63/25 116/21
117/18 117/19 117/23)
117/24 118/6 118/22
120/20 121/18 132/10)
132/23 132/25 135/9
139/19 139/20 156/6
166/20
letters [30] 6/9 16/24
16/25 17/19 18/17
18/19 19/16 20/20
24/4 27/3 27/16 29/7
30/6 30/10 31/12
32/20 32/24 33/10
33/10 35/19 35/20
47/8 49/13 49/14
49/16 50/20 51/20
61/4 64/18 135/4
level [17] 8/8 29/6
29/16 30/5 66/11 72/8)
73/3 76/6 100/11
106/25 134/17 137/18)
137/19 154/18 154/19)
196/6 196/15
levelled [1] 26/16
liabilities [3] 92/20
92/25 93/8
Liberal [1] 80/22
liberty [2] 40/21
199/14
Libra [1] 83/25
lie [1] 148/19
lied [5] 78/11 78/19
79/1 79/8 79/14
lies [1] 94/19
life [3] 72/25 199/16
201/15
light [3] 16/16 38/3
168/5
like [26] 2/9 16/24
18/14 19/18 20/2
47/12 60/12 71/21
72/7 75/24 76/7 88/14
94/10 113/13 121/24
123/3 126/12 141/19
145/22 151/6 154/10
170/22 186/24 190/7
198/25 199/8
likelihood [1] 126/23
likely [6] 95/11 152/9
152/24 184/9 184/9
192/3
limbo [1] 132/41
limitations [1] 72/4
limited [21] 10/19
69/4 89/6 108/2
118/11 121/2 121/20

126/22 142/23 143/3
176/5 181/22 194/15
194/16 194/20 194/21
194/22 195/10 196/20
197/6 197/14
Limited's [1] 166/8
line [26] 18/6 20/2
21/9 28/6 29/5 30/1
31/17 31/17 35/24
36/8 45/8 56/12 57/2
59/8 60/2 62/18 63/24
73/6 76/18 96/15
96/16 126/7 138/20
144/11 181/3 197/17
liner [4] 94/12
lines [11] 15/25
20/19 21/8 62/2 64/11
78/5 78/14 87/8
138/12 138/16 169/15}
link [2] 39/8 196/18
linked [1] 90/1
list [7] 3/7 4/18 9/5
32/21 32/22 43/3
92/14
listen [1] 59/11
listened [2] 59/22
59/25
listening [2] 1/12
33/22
lists [1] 49/10
lit [1] 130/41
literally [1] 127/12
literate [1] 19/20
litigation [45] 128/8
128/18 128/22 129/8
130/12 131/6 131/23
133/9 134/5 140/23
143/11 143/20 144/6
146/6 147/15 149/14
153/6 156/9 160/21
162/7 166/17 173/3
173/6 173/24 174/1
174/8 174/13 174/23
176/5 178/17 178/22
179/3 179/7 180/2
180/5 180/10 180/18
180/20 183/14 184/4
187/19 187/24 190/16
192/23 193/7
little [13] 11/4 17/1
23/6 30/3 30/14 49/25)
75/11 80/14 81/3
83/25 105/18 116/17
156/22
live [2] 105/5 137/16
livelihoods [1] 40/20
lives [4] 113/25
137/17 137/25 177/23
Lloyds [1] 126/24
lo [1] 181/5
Local [2] 116/1 116/9
located [1] 5/12
Londis [1] 68/25
long [14] 1/20 9/5

25/13 61/24 93/5
93/10 99/23 119/19
127/17 149/13 149/13}
149/14 157/5 193/13
Long-Term [1]
127/17
longstanding [2]
144/2 172/6
look [32] 1/18 1/21
15/20 16/6 23/5 23/5
26/4 30/24 37/25 38/1
38/20 38/20 39/18
47/12 47/18 48/19
50/10 51/23 52/12
55/11 62/8 63/1 80/15
81/5 105/17 112/10
121/9 134/7 138/3
139/21 145/2 186/4
looked [7] 106/23
107/17 112/11 118/7
131/14 133/20 145/11
looking [23] 7/14
14/14 23/20 26/19
42/25 71/8 74/4 80/10
81/24 99/13 99/15
112/24 129/2 131/13
139/18 141/5 163/20
170/5 173/7 175/19
188/11 191/2 191/2
looks [1] 98/23
Lord [3] 35/15
111/23 117/10
Lord Arbuthnot [1]
35/15
Lord Justice Fraser
[4] 111/23
losing [3] 37/9 40/15
42/8
loss [7] 82/18 102/11
102/14 102/16 102/19}
106/12 177/22
loss' [2] 102/13
102/18
losses [15] 28/10
31/4 31/5 101/18
102/3 102/25 105/20
106/2 106/3 106/7
106/9 109/5 118/14
119/2 119/4
lost [10] 10/3 11/12
40/20 43/17 104/10
108/3 108/4 112/3
137/25 170/24
lot [17] 12/19 14/22
24/20 27/1 39/14 58/9)
61/24 71/5 83/9 86/9
90/5 193/1 198/22
199/16 201/8 201/9
201/24
loud [1] 1/13
LOVE [1] 190/18
lucidly [1] 107/19
lump [1] 102/17
lunch [1] 77/16

lying [2] 78/22
170/10

made [42] 3/23 9/4
12/13 13/8 13/13
24/21 31/25 48/17
56/8 57/23 62/7 63/25
90/16 92/16 94/24
102/25 103/2 103/11
103/14 104/13 105/1
125/21 131/20 143/18)
144/19 146/9 147/10
150/4 154/1 154/10
154/14 156/11 156/23}
157/15 157/23 158/20)
163/21 163/23 163/24I
186/20 192/1 202/12
Magistrates [1] 84/1
magnitude [1] 68/22
Magnox [1] 159/13
Mail [15] 88/23 88/24
90/3 91/2 91/5 91/9
92/17 93/11 93/21
94/17 95/3 95/7 95/8
95/12 95/21
main [1] 91/9
mainstream [1] 84/3
maintain [2] 110/10
160/15
maintains [2] 64/7
123/11
Majesty's [2] 142/24
156/9
major [2] 92/11
177/10
majority [1] 56/20
make [38] 9/4 28/13
29/17 30/6 41/21
44/19 51/16 53/22
55/9 64/3 69/7 80/24
95/17 98/20 99/1 99/2I
102/19 105/5 105/20
122/10 137/7 139/16
145/8 155/14 158/11
158/18 163/13 168/15)
182/21 184/1 187/3
187/12 190/19 199/13}
199/15 201/10 202/4
203/1
makes [3] 40/10
99/16 168/1
making [19] 8/5 54/6
74/6 94/6 95/4 114/11
125/11 132/2 146/16
155/1 155/13 155/17
156/8 163/17 167/13
168/4 173/20 188/21
192/6
man [3] 12/3 12/3
198/6
manage [3] 99/15
123/7 190/4
managed [5] 17/16

(69) leaving - managed
managed... [4] 85/25
97/4 99/4 191/4
management [20]
10/19 11/3 13/1 68/1
68/5 68/17 69/6 72/3
77/5 87/2 121/1
121/20 133/20 133/25
134/12 137/23 142/19}
143/1 170/3 183/11
managers [2] 96/24
170/9

managing [7] 76/7
83/5 96/17 99/10
170/19 194/8 195/13
mandate [5] 76/9
76/13 173/4 173/5
174/9

manifestly [1] 177/11
manner [1] 195/23
manufacturing [1]
87/12

many [18] 37/8 47/24
72/5 79/15 95/8
106/16 107/8 113/10
122/15 124/13 126/15}
138/17 144/3 170/24
171/1 186/4 199/23
202/1

March [27] 30/24
34/16 47/12 47/20
48/21 51/7 51/24
55/12 58/19 59/6
61/21 85/20 117/16
140/2 140/5 141/9
144/22 147/6 147/24
149/6 150/12 158/22
166/1 166/19 167/8
169/19 169/20

March 2015 [1]
117/16

March 2019 [1] 140/5
Margot [4] 135/11
135/13 138/21 200/1
Marie [1] 169/22
Mark [4] 122/20
124/3 139/12 141/17
marked [4] 7/7
117/24 141/15 144/10
market [2] 70/20
132/17

marks [1] 153/8
material [2] 153/3
201/2

maternity [1] 4/6
matrix [1] 189/25
matter [31] 8/17
14/15 16/3 25/3 27/11
35/4 49/2 55/16 57/16
57/24 59/12 59/15
59/17 61/15 63/11
65/21 77/24 90/9
112/14 131/7 136/20

143/21 146/15 146/25)
147/18 158/20 159/24}
160/1 161/12 169/3
190/24

mattered [1] 89/15
matters [37] 11/21
11/21 27/11 27/15
27/21 30/22 31/15
32/1 32/25 52/10 58/1
58/1 79/9 86/1 101/2
106/22 112/10 112/11
112/24 120/6 126/4
126/11 126/18 130/15)
130/21 136/6 136/12
139/23 143/2 143/4
143/24 143/25 156/7
159/14 160/12 164/25)
201/25

may [60] 1/5 2/20
2/21 3/22 4/16 12/11
15/2 16/4 18/14 24/23
33/24 34/18 36/21
37/22 37/23 39/20
58/20 62/19 73/14
77/14 94/5 96/11
96/20 97/1 97/9 97/9
97/19 100/23 100/25
103/10 105/12 106/11
110/18 113/20 113/20)
116/15 122/21 124/13)
130/19 139/13 145/8
147/1 147/2 147/12
148/19 152/10 152/12)
153/17 156/17 157/17)
158/20 160/18 160/19)
163/13 174/4 174/4
180/6 190/11 192/5
201/22

maybe [4] 17/9 17/18
42/23 75/9

me [141] 3/20 5/7 6/1
7/18 10/6 10/8 11/21
12/2 12/21 13/17 14/3
17/1 17/20 17/24 18/2
18/17 19/20 22/8
24/14 24/14 25/19
25/24 27/9 27/13
30/12 30/19 30/20
32/4 32/5 33/16 34/2
34/8 34/25 35/8 36/22
37/4 46/2 47/22 47/23
47/25 48/13 50/9
53/13 53/13 53/20
54/3 54/12 57/8 57/19)
60/10 60/11 60/14
60/17 60/18 60/22
61/25 65/12 66/10
66/17 67/15 68/14
68/20 69/2 69/5 71/19
83/10 84/19 88/13
97/18 100/9 100/12
100/24 100/24 101/10)
104/3 105/9 105/13
108/5 108/9 109/25

112/1 113/11 113/21
114/3 114/21 122/22
123/21 124/1 124/2
127/11 127/11 130/19}
133/16 133/18 133/24]
138/4 138/15 138/21
138/22 140/25 145/2
145/19 145/20 145/25)
147/3 151/10 152/16
152/21 152/25 155/2
162/22 165/10 165/10
165/23 167/1 168/19
169/12 170/22 175/4
175/13 175/14 176/12
176/13 182/11 184/20
187/15 188/13 190/23}
191/4 194/6 196/24
197/9 197/16 198/11
199/15 200/18 200/20}
200/22 201/13 202/10
202/25

mean [50] 4/1 5/2
13/8 18/22 19/18
20/14 30/4 33/23 35/1
42/14 42/20 50/6
51/10 54/25 57/7
57/12 65/8 65/18
69/23 72/13 72/16
73/4 75/22 76/12
83/20 86/22 91/7
93/10 95/20 104/21
105/12 121/2 122/8
131/19 137/7 149/12
153/12 153/13 153/16}
177/21 177/22 186/13}
188/16 188/16 188/21
188/22 194/6 196/20
200/9 201/13
meaning [2] 54/10
153/21

meaningful [1] 188/3
means [9] 36/3
102/14 102/16 102/16
154/11 154/16 154/16
165/19 173/7

meant [2] 19/22
103/23

meantime [1] 174/21
Meanwhile [1]

170/22
measurement [1]
93/8

measures [3] 77/6
77/7 101/19
mechanism [3] 24/23
76/22 77/2

media [3] 62/19 84/3
95/8

mediate [3] 119/13
120/11 171/11
mediated [1] 118/15
mediation [30] 7/9
24/23 36/12 47/17
47/24 48/24 49/1 49/5

49/7 50/6 51/20 52/1
52/5 52/8 55/18 56/7
56/9 56/23 63/18
65/17 71/14 117/21
118/1 118/17 118/20
118/25 120/9 120/18
171/10 193/11
mediations [1]
120/10

mediator [1] 71/17
meet [3] 36/20
119/16 190/8
meeting [29] 5/21
5/25 13/19 24/25 32/3)
67/6 68/3 93/24 98/2
104/23 125/23 127/2
127/3 127/4 127/12
145/17 145/17 150/11
151/3 153/9 161/20
164/6 176/3 176/10
176/21 176/23 179/21
185/25 186/38
meetings [10] 5/13
5/20 66/23 107/7
123/18 127/10 139/14}
176/14 177/5 177/6
meets [1] 191/10
member [8] 5/25
73/19 74/25 115/21
168/3 169/21 181/17
200/5

members [5] 68/11
73/12 73/13 73/18
199/23

members' [1] 73/23
memorandum [3]
194/25 195/6 196/17
memorandums [2]
194/23 195/15
memory [3] 37/24
83/25 163/3

mention [6] 30/3
83/25 87/24 128/10
132/25 202/10
mentioned [12] 10/8
11/25 14/2 20/22 32/7
68/2 69/18 86/11
95/25 105/12 153/10
153/11

merely [1] 121/13
merits [1] 162/6
mess [1] 113/23
message [2] 69/1
162/21

messages [1] 27/6
messaging [1] 95/12
met [13] 5/5 13/16
24/14 32/2 53/20 54/4I
89/18 110/6 119/18
127/14 127/15 133/6
167/8

meticulous [1] 203/5
Michael [1] 95/4
micro [1] 76/6

micromanaged [1]
76/20

microphones [1]

1/14

mid [1] 165/16
mid-afternoon [1]
165/16

middle [10] 7/8 10/19
11/2 13/1 51/11 51/19}
84/16 94/11 126/17
170/21

might [32] 22/14
33/12 36/2 45/22
46/21 62/5 62/5 67/5
67/23 76/10 79/9 85/8
96/22 120/8 122/16
133/19 136/12 153/18)
161/15 161/16 165/15)
167/19 172/1 184/8
186/20 187/11 188/12!
191/8 192/25 200/19
201/25 202/2
Miliband [6] 15/10
15/15 16/1 16/9 17/25)
38/1

Miliband's [1] 15/18
million [2] 56/25
92/20

millions [2] 89/16
1711/4

mind [23] 19/18
20/12 49/21 53/15
70/23 71/13 75/16
89/20 124/2 124/5
129/16 144/12 146/23}
147/3 148/9 148/25
153/7 159/15 165/7
176/18 177/20 182/18}
185/5

minded [2] 142/18
163/25

minds [2] 20/5
202/21

mine [3] 33/25
121/18 162/15
minimal [1] 130/9
minister [62] 3/2
3/19 4/13 8/8 12/1
14/4 17/24 24/7 25/25}
26/11 26/18 26/23
27/9 31/23 32/6 34/21
37/4 37/12 45/15
47/22 52/1 71/2 76/24
83/9 95/23 100/12
111/2 111/3 111/10
115/25 116/5 116/7
123/21 124/8 135/11
140/10 140/25 144/16)
146/1 151/11 158/12
158/18 158/23 161/7
161/13 161/17 161/24}
162/5 163/21 166/11
168/9 168/24 170/14
170/16 171/19 175/15}

(70) managed... - minister
minister... [6] 176/15
176/16 177/9 185/10
186/8 198/22
minister's [4] 4/22
18/5 59/6 162/14
ministerial [19] 3/22
4/9 46/1 81/14 85/18
115/24 127/10 141/9
154/6 155/22 155/24
166/9 169/14 172/9
174/3 175/24 176/1
196/6 196/15
ministers [50] 3/3
3/9 3/13 3/16 3/17
3/19 4/4 4/20 4/24 5/3
5/6 7/18 8/21 11/22
21/16 26/5 27/14
27/16 30/9 36/21
66/10 68/12 72/3
73/11 94/1 125/9
126/19 133/12 138/14)
142/2 147/8 160/18
163/17 164/16 165/3
169/3 176/19 178/21
181/16 181/23 182/3
195/20 196/6 196/15
196/23 197/13 198/4
199/13 200/16 200/25
ministers’ [1] 20/21
minor [1] 43/14
minute [4] 31/22
44/21 83/15 145/21
minutes [9] 5/13
11/25 31/23 46/13
78/1 127/10 151/4
154/6 177/6
minutes’ [1] 77/15
mirrors [1] 180/14
miscarriage [1] 48/4
misdemeanours [1]
137/22

misinformed [3]
78/11 78/19 79/8
misinforming [1]
78/22

misleading [1]
179/22
misrepresentations
[1] 63/15

mistake [3] 12/13
13/8 104/13
mistaken [1] 160/10
mistakes [4] 12/15
105/1 105/2 105/5
mistresses [9] 14/11
149/15 149/21 150/8
155/7 157/2 157/11
173/17 186/16

mix [1] 4/9

mixed [1] 190/17
Mm [8] 47/11 81/17
81/20 97/7 100/17

100/21 108/18 186/22)
Mm-hm [4] 186/22
model [2] 40/10 42/7
models [1] 71/8
modernise [1] 91/15
modernising [1]
132/14

modest [1] 25/8
Moloney [1] 80/3
moment [5] 21/3
29/11 42/2 119/22
165/15

Monday [5] 33/16
145/19 155/16 155/23)
166/19

money [16] 11/12
23/16 43/17 74/6
82/18 91/8 92/2 92/15
92/25 101/21 105/3
157/20 171/4 191/15
192/2 192/3

monitor [1] 202/6
monopoly [1] 22/11
monopsony [1]

22/12

month [4] 17/5 17/7
64/1 185/19

months [4] 4/4 11/17
109/9 194/1
monumental [1] 35/5
more [51] 1/13 4/16
9/23 19/25 25/4 25/7
27/2 40/8 41/17 41/21
45/4 48/13 49/25 50/2
61/24 62/6 64/24
64/24 66/1 66/5 71/5
75/11 86/6 89/23 91/5
92/15 98/7 98/8 98/19
98/25 122/8 122/14
124/14 133/6 134/15
136/12 148/9 164/15
168/1 169/12 171/20
171/22 173/18 179/12)
181/1 186/20 186/21
187/10 192/6 192/12
197/8

morning [24] 1/3 1/8
41/1 46/13 46/22 47/3
80/14 81/3 85/16
114/12 127/7 145/19
150/17 151/5 151/7
151/19 155/16 155/23
162/21 163/2 172/3
179/25 182/18 189/1
most [19] 2/18 3/5
19/19 19/19 35/23
42/20 49/4 59/2 89/9
104/7 124/6 129/11
129/12 129/13 133/10)
146/3 149/16 152/9
152/24
mostly [2] 2/13
139/12
mountain [1] 61/12

mounted [1] 137/8
mounting [1] 132/7
move [5] 77/4 106/10
108/13 140/1 189/15
moved [1] 42/1
moves [1] 90/17
moving [4] 117/15
125/14 135/8 147/23
MP [14] 10/8 15/10
23/7 26/9 26/12 26/22
40/4 47/9 47/10 51/3
60/21 68/19 117/7
139/4
MPs [27] 10/18 16/17
16/21 27/1 32/21
33/11 33/15 34/2 34/7
34/12 34/13 34/23
35/7 35/13 35/19 38/4
59/3 59/13 59/18
59/24 60/9 61/3 61/15
61/25 95/8 112/19
166/20
MPST [2] 38/23
150/15
MR [81] 1/7 5/25 8/1
10/21 12/20 14/3
14/20 15/15 16/9
16/10 16/11 17/25
23/17 24/15 34/6
34/23 37/2 42/13
48/19 49/10 49/20
53/24 54/2 54/4 55/4
55/5 55/11 58/19
59/22 64/18 65/13
71/11 74/17 79/25
80/3 80/14 81/4 85/16
86/3 88/4 99/18 99/22
100/2 100/16 108/1
111/13 111/23 114/7
114/8 114/24 115/1
115/21 127/3 127/4
127/14 133/17 139/14]
145/6 157/23 159/1
159/3 159/8 159/9
160/24 161/3 161/22
169/5 169/13 181/6
183/18 188/6 190/7
190/8 192/15 192/18
202/18 203/7 203/11
204/5 204/11 204/16
Mr Arbuthnot [5]
34/23 42/13 49/20
55/4 64/18
Mr Arbuthnot's [2]
14/20 59/22
Mr Bailey [3] 48/19
49/10 55/11
Mr Baker [2] 12/20
53/24
Mr Bates [5] 8/1
10/21 55/5 58/19
65/13
MR BEER [11] 1/7
71/11 80/14 81/4

85/16 86/3 100/2
100/16 108/1 114/8
204/5

Mr Beer's [1] 88/4
MR BLAKE [5] 115/1
133/17 183/18 203/7
204/16

Mr Bridgen [5] 5/25
14/3 24/15 34/6 37/2
Mr Callard's [1]
TANT

Mr Cameron [5]
127/3 127/4 127/14
190/7 190/8

Mr Carter [1] 16/10
Mr Carter's [1] 16/11
Mr Chisholm [3]
145/6 192/15 192/18
Mr Chisholm's [1]
159/8

Mr Clark [3] 114/24
115/21 202/18

Mr Cooper [4] 159/1
159/9 169/5 169/13
Mr Edwards [1]
203/11

Mr Evans [1] 161/22
Mr Jacobs [2] 79/25
99/22

Mr Justice [4] 111/23)
157/23 181/6 188/6
Mr Miliband [3]

15/15 16/9 17/25

Mr Moloney [1] 80/3
Mr Russell [1]
139/14

MR STEIN [4] 99/18
111/13 114/7 204/11
Mr Thomson [2] 54/2)
54/4

Mr Watson [3] 159/3
160/24 161/3

Mrs [19] 27/22 28/5
28/7 28/25 30/21 52/6)
80/6 87/20 116/24
1417/2 117/18 117/20
118/6 118/19 120/14
120/25 121/7 121/12
133/22

Mrs Hamilton [2]
80/6 87/20

Mrs Henderson [5]
27/22 28/5 28/7 28/25
30/21
Mrs Jo [1] 52/6
Mrs Paula [1] 121/12
Mrs Pauline [1]
116/24
Mrs Thomson [7]
117/2 117/18 117/20
118/6 120/25 121/7
133/22
Mrs Thomson's [2]
118/19 120/14

Ms [16] 79/24 79/24
80/1 88/12 94/20 95/6I
96/13 97/2 97/8 98/20)
111/7 119/25 135/10
139/1 204/7 204/9
Ms Angela [1] 119/25
Ms Eleanor [1]
135/10
Ms James [1] 111/7
Ms Page [1] 79/24
Ms Patrick [3] 79/24
80/1 204/7
Ms Perkins [1] 97/8
Ms Shaikh [1] 139/1
Ms Swinson [2]
94/20 98/20
Ms Swinson's [1]
95/6
Ms Vennells' [1] 97/2
much [41] 1/4 1/17
2/3 4/14 13/17 15/3
18/23 29/8 41/16
46/24 61/20 61/24
68/4 68/8 73/10 77/17
77/18 79/22 88/9
91/24 101/1 114/10
114/14 114/17 115/2
115/18 117/10 119/24}
121/21 140/4 157/21
158/2 174/23 182/7
183/19 186/7 187/16
199/11 202/13 202/18)
203/14
multinationals [1]
84/22
multiple [4] 81/18
81/25 145/24 189/21
musing [1] 188/3
must [7] 32/6 44/2
52/7 52/19 102/18
102/20 151/22
mutual [1] 22/24
mutualisation [4]
21/24 25/6 25/12 54/7
mutualised [1] 89/1
mutually [1] 178/15
my [194] 1/8 2/1 3/16
3/19 4/2 4/18 5/2 5/13)
5/19 5/23 6/17 8/19
10/12 11/9 11/18
12/22 13/8 14/8 15/8
15/11 17/7 17/11 18/3)
19/1 19/1 19/25 21/15
22/3 22/6 24/25 25/20)
25/21 25/23 25/25
27/8 30/13 32/3 32/12
33/7 33/10 33/15 41/5
41/24 45/24 45/25
46/1 48/6 49/21 51/12)
51/15 53/23 54/1 54/7
54/7 54/11 58/7 60/11
60/11 62/11 62/18
62/20 64/17 64/19
64/24 64/25 65/18

(71) minister... - my
my... [128] 68/3 68/6
68/23 69/4 71/13 73/6
77/3 77/10 78/6 78/15
80/2 80/7 84/17 84/18
87/10 87/16 88/5
89/10 89/20 89/22
92/8 92/10 99/17
99/19 99/22 100/10
100/13 104/3 104/8
105/6 106/20 108/1
109/20 109/25 110/6
111/9 112/12 112/25
113/5 113/6 115/4
117/8 120/24 120/24
121/1 121/19 123/22
123/24 124/21 125/6
126/20 126/20 127/5
128/14 129/16 130/18
130/20 131/17 134/6
136/15 140/11 140/17)
142/16 142/17 142/17)
144/7 144/12 145/11
146/23 148/25 149/11
149/19 149/19 150/15)
150/25 151/2 151/12
151/17 153/17 153/17
154/25 155/2 155/4
156/25 159/14 159/22
160/12 161/1 162/25
163/7 163/18 164/12
164/14 165/1 165/13
168/2 168/12 171/24
172/2 172/6 176/11
176/11 176/18 177/1
177/7 179/19 180/24
182/7 182/8 182/9
182/12 182/18 184/15
185/4 185/12 187/13
188/7 188/12 189/9
190/25 191/22 193/9
193/10 196/21 199/23}
202/4 202/11 203/4
myself [4] 20/5 50/25
171/23 188/3

N

naked [1] 201/22
name [11] 1/8 1/10
8/2 16/22 20/21 80/2
86/10 99/19 115/3
115/4 121/10
namely [5] 26/21
29/2 143/21 180/12
180/15

names [3] 20/21
30/10 141/13

NAO [1] 84/4
narrative [1] 82/7
national [6] 92/11
101/16 103/9 104/18
107/4 185/2

native [2] 191/13

191/18
naturally [1] 69/10
nature [3] 33/4 44/1
162/12
NDA [1] 200/12
nearby [1] 11/13
nearly [2] 52/18 53/1
necessarily [11]
12/14 33/7 45/13
45/21 61/4 82/11 90/1
122/14 137/5 191/20
192/13
necessary [8] 25/24
46/3 66/10 75/21
96/14 147/17 155/9
195/5
need [19] 3/8 5/10
8/8 18/19 24/8 24/22
25/24 28/18 30/19
45/17 48/3 54/16
70/14 76/3 88/16
100/6 146/10 182/15
197/11
needed [31] 18/6
18/21 22/20 33/25
41/5 41/16 46/15 51/6
51/20 57/12 73/1
89/17 90/10 90/11
92/12 92/19 93/5 96/9)
152/20 153/2 162/16
172/4 172/6 172/7
173/15 173/17 177/18)
178/9 182/12 193/12
202/16
needing [1] 100/13
needs [5] 48/14
48/17 182/3 189/22
197/4
negative [5] 11/23
42/20 68/5 160/8
164/21
negotiate [2] 17/6
107/5
negotiations [1]
92/12
neither [3] 15/17
27/22 131/25
net [1] 89/23
network [18] 21/22
43/17 88/19 88/19
89/8 89/11 89/15
90/21 91/20 92/11
92/14 101/4 101/8
103/22 125/17 127/18)
132/14 132/22
networks [1] 68/25
never [31] 5/20 8/2
10/8 11/11 11/13
11/14 14/24 17/8
17/21 18/25 24/1 24/9)
29/6 34/10 35/8 36/3
36/25 38/13 48/15
60/6 60/19 61/14
68/14 80/24 87/16

106/25 109/24 162/23}
177/21 177/23 196/25)
nevertheless [2]

38/3 96/7

Neville [2] 111/8
200/1

Neville-Rolfe [2]
111/8 200/1

new [15] 64/3 65/2
65/3 65/6 77/5 81/10
109/22 110/3 113/4
132/16 173/21 175/8
184/23 187/4 194/2
news [10] 39/2 39/7
39/8 39/18 39/24
42/10 42/11 46/15
46/16 200/20

next [12] 16/15 21/18
40/19 63/7 109/14
109/17 110/17 123/4
127/19 141/23 163/2
185/25

NFSP [7] 53/17
106/11 107/3 107/4
107/9 107/16 107/17
NHS [4] 72/6 76/10
81/8 82/4

Nick [4] 3/20 64/5
184/23 189/19

Nigel [1] 179/5

night [4] 51/15
163/12 168/10 172/1
no [114] 3/8 5/2 5/9
5/18 6/3 6/4 15/22
20/11 23/23 28/3 28/6
30/8 34/17 35/5 35/11
35/13 35/14 37/23
38/13 38/19 43/11
43/17 44/4 44/14 45/9
45/15 46/7 48/8 52/16
52/24 53/10 54/14
56/2 56/15 57/15
57/18 59/25 61/3 61/8
61/10 64/8 68/2 68/9
68/14 71/23 72/16
75/9 76/5 79/3 79/15
79/18 80/20 81/11
81/22 83/13 83/23
83/24 87/10 88/1 88/8
88/16 91/22 91/23
91/24 92/3 92/22
93/14 94/16 98/9 99/6
99/12 99/14 101/9
102/2 102/7 103/18
107/8 107/9 107/24
108/11 110/9 110/21
111/21 111/21 112/11
120/2 125/11 126/7
126/7 126/16 128/3
128/23 129/20 132/25}
134/22 141/5 146/13
148/13 149/3 155/10
160/22 161/19 164/5
167/12 167/16 169/5

174/25 178/5 187/5
190/14 194/12 196/19}
200/21 202/16
nobody [4] 45/17
60/14 112/25 114/3
nodding [1] 81/21
non [2] 62/24 67/9
non-urgent [1] 62/24
none [5] 12/7 34/7
60/9 60/22 100/12
nor [3] 15/18 27/23
119/10

normal [4] 3/13 69/1
69/2 136/16

normally [4] 16/2
36/24 41/3 145/18
Norman [4] 26/9
26/13 27/20 37/23
norms [2] 141/14
197/3

Norwich [1] 27/25
not [206]

notably [1] 3/5

note [13] 16/12 33/9
52/15 59/1 64/7 75/10)
94/15 127/15 141/10
163/11 167/2 172/19
178/13

noted [3] 16/11 62/21
141/10

nothing [12] 7/24
11/20 18/7 44/5 68/7
69/2 79/3 84/15
109/22 119/9 174/25
180/24

noticed [4] 4/17
41/15 66/21 121/10
noting [1] 157/25
notion [1] 145/13
notwithstanding [1]
162/11

now [58] 2/3 14/7
25/9 29/1 30/3 35/15
40/22 41/11 46/21
48/18 53/11 66/18
67/8 67/21 70/1 77/15
88/13 91/6 98/6 98/19)
100/1 101/12 103/16
107/22 108/15 109/13
111/14 111/18 111/23}
117/2 117/15 121/12
121/21 122/19 129/2
135/8 137/9 137/18
138/1 139/15 144/23
147/16 147/23 149/24}
156/19 158/15 159/11
162/16 162/23 165/1
167/17 168/17 169/20}
172/14 181/7 182/7
184/14 201/11
nowhere [3] 40/16
42/9 149/24

nuclear [6] 122/11
179/16 179/18 181/19

194/11 197/24
number [41] 3/13
5/11 16/17 16/20
26/19 30/17 31/12
34/12 38/4 38/6 44/6
44/10 49/5 50/20 57/3
57/4 57/4 57/17 59/20I
80/4 98/13 100/1
100/15 114/12 115/18}
115/24 117/6 127/23
128/25 129/5 129/6
129/10 138/7 139/8
141/12 149/12 150/19)
178/11 190/8 197/23
202/20

numbers [5] 22/14
24/4 37/14 51/16
105/3

numerous [2] 10/13
138/7

[e)

oath [1] 170/10
object [1] 161/7
objection [1] 169/10
objectionable [1]
29/25
objective [8] 45/20
89/24 89/25 90/20
90/25 154/2 155/3
155/4
objectives [11] 21/15
23/3 24/16 25/12
25/14 88/14 88/18
89/4 93/22 96/8
195/20
objectivity [1] 195/25
obligations [1] 74/8
obscured [1] 196/19
obscures [1] 196/24
observation [2]
157/15 200/8
observations [3]
67/7 145/8 163/13
observe [1] 176/23
observed [1] 154/13
observer [1] 179/4
obtain [3] 12/21
146/10 148/12
obtained [1] 7/2
obvious [5] 73/24
75/8 75/9 83/20 105/2
obviously [13] 44/12
44/24 72/24 90/20
122/13 126/14 140/8
151/10 151/20 159/15}
160/9 183/23 197/25
occasion [4] 12/1
14/8 50/22 68/19
occasionally [1]
17/24
occasions [7] 28/9
54/5 67/16 74/11
100/8 119/19 190/9

(72) my... - occasions
[e)

occupying [1] 3/23
occurred [3] 21/6
48/4 66/17

occurs [1] 58/10
October [2] 23/9
32/22

October 2013 [1]
32/22

odd [1] 30/3

off [7] 38/11 38/12
45/8 107/18 129/8
169/4 185/12

offer [3] 120/7
120/18 125/18
offered [1] 10/6
offering [1] 20/10
offers [1] 136/2
office [352]

office's [25] 9/16
13/25 38/23 40/1 49/6)
49/15 59/8 66/25 68/1
68/17 119/8 120/6
123/8 127/24 138/23
142/9 161/14 161/25
167/8 167/24 174/10
180/12 180/13 181/7
189/10

Officer [3] 72/8 72/11
72/19

Officers [1] 72/11
offices [3] 32/18 37/9
126/15

official [6] 5/13 5/16
60/2 62/12 141/15
167/6

officials [45] 7/17
9/15 13/16 15/11
15/13 18/9 19/19 20/1
20/18 28/13 29/4
29/13 29/18 33/13
33/17 34/10 43/5 43/8
44/18 45/12 49/23
50/8 53/2 53/6 53/11
54/14 54/22 57/5 62/2
64/25 67/3 68/23 72/3
78/11 78/18 79/1
87/23 89/19 100/11
125/9 162/2 176/17
176/22 197/21 199/13}
often [6] 45/9 89/19
103/2 127/13 170/6
193/21

Oh [2] 41/21 177/21
okay [8] 57/17 82/13
85/16 97/3 100/16
108/15 112/5 189/13

omitted [1] 77/24

on [333]

once [7] 63/19 70/3
137/14 147/18 163/21
172/22 188/13

one [101] 2/3 3/4

4/19 6/19 11/6 11/25
12/16 14/23 24/16
25/14 29/11 32/22
32/23 32/23 33/8
35/18 39/13 41/7
42/16 45/8 49/20 64/6
67/5 67/17 68/19
70/25 71/1 71/12 74/8)
TAI9 76/14 77/24
78/22 79/15 80/9
81/12 83/15 83/24
85/9 87/5 89/7 89/24
90/7 90/15 92/14
94/12 95/6 96/3 96/3
96/18 97/9 99/6
102/20 104/7 110/13
110/13 113/11 117/8
121/4 122/9 123/23
124/2 126/22 129/18
130/24 131/13 133/17,
135/13 135/14 135/15)
137/11 137/20 139/9
145/17 145/17 146/13)
151/14 151/17 154/18)
164/14 176/18 177/5
178/4 181/18 182/11
183/25 184/6 184/19
186/24 186/25 187/4
187/13 194/12 196/9
197/5 197/6 198/7
198/13 200/9 201/1
201/15
one-line [1] 45/8
ones [1] 183/25
ongoing [3] 156/9
160/21 176/4
only [32] 13/9 14/8
37/1 41/11 41/12
41/12 44/8 48/5 48/11
49/18 51/7 58/19 60/1
67/15 78/1 84/15
91/15 96/3 112/15
117/8 117/20 128/10
129/18 137/18 140/7
147/5 155/4 162/19
165/3 166/24 185/18
188/22
onto [1] 115/19
onwards [1] 37/21
opaque [1] 156/22
open [7] 40/17 42/13
43/21 103/4 105/22
158/12 173/20
opened [1] 11/12
opening [1] 32/17
operate [7] 32/6
35/14 84/23 125/16
125/18 136/2 178/19
operated [4] 24/3
31/24 61/9 170/5
operates [3] 110/5
135/25 142/24
operating [5] 31/10
49/1 56/21 132/19

198/12
operation [2] 32/25
52/9
operational [31]
11/21 27/11 27/11
27/21 31/15 32/1
32/11 32/17 33/6 44/1
76/17 78/7 78/16
125/21 126/1 126/11
126/18 134/4 136/11
136/20 142/13 142/15}
143/2 143/4 143/21
143/24 144/5 144/6
144/14 146/15 146/17
opined [2] 149/20
150/4
opinion [4] 43/23
132/3 148/2 167/9
opinionated [1]
159/13
opportunities [1]
35/9
opportunity [10]
18/22 29/1 65/7 76/23
106/6 112/18 132/20
151/4 161/24 163/21
opposed [3] 164/16
165/4 187/25
opposite [3] 30/17
169/17 185/13
opposition [2] 113/3
180/16
optimistically [1]
34/20
option [1] 184/7
options [16] 102/12
102/20 178/14 179/12
179/16 179/18 181/19}
182/25 183/3 183/5
183/15 183/17 183/18I
185/14 185/23 188/23}
or [157] 3/3 3/13 8/16
9/4 9/15 11/22 17/8
17/23 18/7 18/12 19/8
19/8 20/21 20/22
20/23 21/4 24/7 25/23
27/24 28/5 30/9 30/13)
32/21 33/2 33/4 33/16
35/20 36/17 40/7
40/15 41/2 42/7 43/12
44/5 44/10 46/4 46/10
47/18 51/16 52/9 53/8
54/2 54/17 54/21 55/2
55/23 56/4 57/14
58/11 59/18 63/8
64/20 67/2 67/15 70/2
70/21 71/21 73/5 74/4
76/7 76/21 78/9 78/11
78/16 78/17 78/19
78/22 79/8 79/20
81/12 81/22 83/5
83/21 84/12 84/14
85/6 85/10 85/19
85/25 86/1 86/15

86/15 86/18 87/13
87/23 100/2 101/20
101/23 102/13 102/17}
103/6 104/17 105/25
106/16 108/12 113/20
120/11 122/3 124/24
125/3 126/14 126/19
130/2 130/6 132/8
133/3 134/16 134/22
135/15 136/12 136/21
136/25 137/21 138/13}
144/11 144/14 145/21
146/25 149/19 151/6
153/3 154/12 154/13
155/20 158/23 159/15)
160/10 162/1 162/4
163/4 171/7 176/18
176/19 177/4 178/8
179/2 179/4 179/18
180/13 181/17 181/24,
182/6 182/25 184/6
184/7 184/17 184/17
187/6 188/19 190/12
195/1 195/21 198/22
200/4 201/9 202/5
202/20
oral [2] 172/20
202/19
orally [1] 18/13
order [11] 19/8 21/8
48/3 49/8 54/16 65/15)
68/22 97/13 138/2
185/5 190/16
ordinary [1] 198/23
Ordnance [1] 194/11
organisation [14]
22/14 77/4 124/20
136/3 136/23 137/21
139/13 184/21 184/25}
185/1 185/7 192/7
194/3 196/20
organisation's [2]
160/7 164/20
organisations [7]
76/7 76/9 126/21
184/16 194/13 198/25
199/10
organised [2] 10/12
83/12
organising [1] 199/7
originally [1] 166/21
originated [1] 90/13
Osborne's [1] 91/19
other [54] 2/4 3/5
3/17 11/16 16/17
17/23 18/20 23/2
34/23 35/1 46/19
49/21 57/24 58/13
61/25 70/5 72/5 74/7
74/25 78/23 82/8 83/4
85/24 86/18 87/23
92/4 105/13 108/8
112/19 113/18 125/23}
126/6 127/4 127/6

127/20 127/22 130/25]
143/25 153/16 154/15)
157/16 164/14 168/23)
173/20 177/3 177/5
177/13 179/2 184/15
187/4 196/20 197/23
199/4 202/5
others [17] 4/8 11/18
13/7 39/1 61/10 63/3
82/5 83/3 90/14 122/9I
126/24 133/19 169/3
184/5 185/10 194/4
200/2
otherwise [7] 9/15
19/8 33/3 92/23
102/20 160/10 162/5
ought [2] 77/25 88/2
our [25] 4/9 8/20
10/18 32/20 41/20
45/24 48/14 49/3
67/19 77/14 94/2
104/10 119/10 120/20)
132/17 132/18 132/19)
158/18 165/15 178/13)
184/10 192/10 192/21
194/9 199/1
ourselves [1] 164/1
out [68] 19/1 20/1
20/20 26/5 26/9 26/15]
27/3 27/13 30/15
30/25 31/8 35/18
35/21 38/15 40/5 42/5I
48/20 49/17 50/20
51/17 54/22 55/9
60/24 62/3 65/15
69/12 71/7 74/10
83/12 84/19 84/23
88/17 91/19 92/2 93/6
93/25 94/3 95/6 97/5
97/12 101/24 102/19
103/10 107/19 119/1
120/20 126/3 126/8
126/20 135/21 138/13)
144/20 145/13 149/11
155/20 163/3 165/13
168/5 171/17 174/15
178/18 179/6 180/10
183/3 186/11 187/6
194/5 196/8
out! [2] 12/13 105/8
outcome [10] 55/24
61/16 147/7 161/19
164/5 170/6 173/22
173/25 175/20 180/18)
outcomes [2] 56/1
58/13
outgoing [2] 28/23
49/19
outline [1] 172/21
outlining [1] 123/2
outrageous [1]
163/16
outset [4] 7/20 22/20
28/18 33/11

(73) occupying - outset
[e)

outside [5] 111/15
113/10 117/25 125/2
140/24

outstanding [5]
59/14 59/18 59/19
59/24 113/11

over [41] 3/14 15/20
15/20 21/17 23/18
38/21 39/25 52/12
55/13 56/13 56/25
59/13 71/10 72/1 77/4
88/13 90/22 96/15
96/16 106/24 109/14
117/23 128/1 129/10
132/15 138/6 139/8
142/5 143/7 144/3
144/13 166/7 169/24
170/23 171/8 172/23
180/1 180/3 181/15
194/1 196/7

overall [5] 4/9 22/9
45/14 131/15 180/18

overcome [1] 177/22

overriding [1] 89/7

overseas [1] 17/5

oversee [2] 173/3
174/18

overseeing [2]
138/10 193/17

oversight [3] 8/25
45/14 51/4

overtures [1] 188/22

overwhelmed [1]
113/4

overwhelmingly [1]
96/19

own [17] 11/18 14/10
22/3 30/13 43/3 63/15)
79/11 102/19 104/3
111/11 119/10 130/20
144/12 145/19 146/23}
167/24 170/18

owned [5] 126/21
126/24 142/23 195/10
196/22

ownership [2] 91/14
127/17

P

pack [4] 4/17 4/17
32/20 41/1

package [1] 179/19
page [66] 1/21 1/21
9/11 9/12 9/19 10/10
15/6 15/20 21/14
21/17 23/5 23/8 23/19)
23/19 23/20 26/7 26/7
26/8 32/22 36/14
38/21 38/22 48/20
52/12 52/13 55/13
55/13 55/14 58/22
62/9 62/10 63/2 69/8

71/10 72/1 78/4 78/13
78/13 79/24 80/17
88/12 94/14 94/21
115/10 115/11 117/23)
123/4 127/19 132/15
142/5 142/5 143/7
149/1 150/12 150/13
159/8 161/21 169/24
172/23 180/3 181/15
183/5 196/7 196/11
196/12 204/9
page 1 [3] 23/8 23/20
55/14
page 11 [1] 21/14
page 12 [1] 9/11
page 14 [1] 15/6
page 15 [1] 58/22
page 17 [1] 36/14
page 2 [4] 23/5 55/13
94/21 142/5
page 3 [5] 32/22
48/20 143/7 159/8
169/24
page 33 [3] 9/12 62/9
62/10
page 36 [1] 78/4
page 37 [1] 10/10
page 4 [2] 63/2 183/5
page 41 [1] 78/13
page 44 [1] 80/17
page 47 [1] 115/11
page 5 [1] 9/19
page 51 [1] 69/8
page 53 [1] 1/21
pages [2] 1/20 32/23
pages 1 [1] 32/23
paid [3] 93/6 107/18
112/21
pains [1] 41/24
pair [1] 175/20
pan [1] 48/20
panel [2] 121/14
133/23
paper [3] 6/7 6/9
109/24
papers [3] 5/15
110/16 111/11
paperwork [1] 140/3
paragraph [65] 3/7
5/9 6/12 8/10 9/10
9/18 10/9 15/7 15/21
16/15 19/3 21/13
23/14 27/18 31/1
31/13 36/13 38/2
52/13 59/1 62/9 62/10
65/24 69/9 78/3 78/14
80/15 88/16 94/12
94/13 97/23 100/5
101/15 102/6 102/9
102/22 103/8 105/18
106/2 106/5 106/10
107/3 122/1 123/4
130/5 131/13 135/23
138/3 141/25 142/6

142/22 143/8 143/15
144/15 148/1 149/6
156/23 172/12 172/24
174/6 180/4 180/21
181/10 182/1 196/12
paragraph 1 [1]
148/1

paragraph 10 [2]
106/5 142/6
Paragraph 11 [1]
142/22

paragraph 110 [1]
78/14

paragraph 118 [1]
80/15

Paragraph 12 [1]
106/10

paragraph 13 [1]
9/18

paragraph 14 [2]
143/8 181/10
paragraph 140 [1]
65/24

paragraph 144 [1]
69/9

paragraph 15 [1]
143/15

paragraph 16 [2]
144/15 182/1
paragraph 17 [1]
107/3

paragraph 2 [3] 5/9
6/12 101/15

paragraph 21 [1] 3/7

paragraph 3 [1]
102/6

paragraph 31 [2]
21/13 88/16

paragraph 33 [2]
9/10 122/1

paragraph 36 [1]
130/5

paragraph 37 [1]
100/5

paragraph 4 [2] 8/10
196/12

paragraph 40 [1]
15/7

paragraph 41 [1]
15/21

paragraph 46 [1]
36/13

paragraph 5 [2]
141/25 174/6

paragraph 51 [1]
149/6

paragraph 6 [1]
180/4

paragraph 7 [1]
102/9

paragraph 79 [2]
62/9 62/10

paragraph 8 [3]
103/8 105/18 172/24

Paragraph 9 [1]
106/2
paragraph 90 [1]
78/3
paragraph 92 [1]
10/9
paragraph 96 [1]
180/21
paragraphs [7] 16/8
23/12 47/8 58/23
66/19 80/11 101/14
paragraphs 117 [1]
80/11
paragraphs 141 [1]
66/19
paragraphs 64 [1]
47/8
parallel [1] 172/16
parameters [3]
125/16 135/25 136/4
Parekh [1] 31/3
Parker [2] 166/9
200/17
Parker's [1] 166/21
Parliament [42] 2/16
5/25 10/20 11/5 13/6
14/20 15/4 22/5 24/22,
27/8 31/21 33/14
34/22 35/8 50/10
54/21 55/2 61/10 62/7,
62/22 64/16 64/20
64/21 65/5 65/15 94/7,
94/9 95/5 98/21
103/21 108/3 110/3
111/15 111/16 112/5
113/3 113/9 113/14
115/21 163/3 196/3
196/13
Parliamentarian [1]
60/17
Parliamentary [3]
72/21 112/15 143/20
part [29] 4/21 9/12
9/22 24/5 26/1 41/5
41/14 45/23 45/24
56/2 65/18 79/17 81/5
87/13 120/13 121/16
126/25 129/7 160/12
167/12 168/4 169/5
170/2 181/21 189/5
189/5 197/2 200/19
203/10
Participant [1] 77/25
participants [5]
77/14 77/23 150/20
151/9 202/15
participated [1]
169/7
participation [1]
189/10
particular [25] 7/19
8/16 11/7 11/8 13/6
17/2 18/25 79/19 82/9)
107/25 109/6 109/16

119/1 119/16 119/21
124/21 133/18 134/7
135/12 135/15 136/18)
144/1 147/21 191/16
199/7
particularly [7] 5/8
35/15 47/25 52/5 64/3I
81/5 82/14
parties [10] 52/10
52/22 64/5 65/12
69/17 71/16 120/12
126/10 141/23 149/14)
partly [2] 49/24 193/9]
partners [1] 87/13
partnership [1] 21/23
parts [3] 46/17
133/10 137/23
party [12] 3/17 5/5
84/8 85/5 92/10
110/13 112/14 113/5
120/12 121/16 138/11
140/23
passages [2] 118/5
160/4
passed [4] 4/3 26/22
110/8 169/4
passionately [1]
108/10
passports [1] 185/3
past [3] 34/23 201/3
202/20
Patel [2] 23/10 23/17
patience [1] 157/21
Patrick [4] 79/24
80/1 80/3 204/7
pattern [3] 176/11
201/13 201/23
patterns [2] 201/21
202/6
Paula [11] 5/21 24/25)
32/2 66/22 68/3
417/19 121/12 125/21
132/11 133/3 200/23
Pauline [2] 116/24
121/12
pausing [3] 134/14
136/8 152/13
pay [6] 23/18 102/4
103/2 105/21 197/7
197/18
paying [1] 185/3
payment [1] 102/17
peculiar [3] 194/9
194/16 194/22
pension [5] 92/4
92/18 92/19 93/8
93/17
Pensions [1] 127/19
penultimate [1]
52/13
people [66] 3/16 6/5
7/22 7/23 7/25 19/24
20/6 20/10 34/2 37/14
40/20 42/8 54/12 55/3)

(74) outside - people
Pp

people... [52] 55/5
55/21 57/25 58/17
60/3 61/5 61/8 61/9
66/9 72/25 83/6 85/13,
86/10 88/7 89/16
93/21 96/9 96/12
96/20 96/23 97/10
98/23 99/9 99/11
103/11 105/13 106/21
106/21 113/24 114/13}
127/13 129/13 137/4
137/13 137/16 137/17)
137/21 137/24 137/25)
138/13 145/24 154/9
157/17 170/22 184/16}
188/16 192/8 193/21
197/7 197/12 199/17
202/2

people's [1] 177/23
per [5] 25/23 68/21
68/24 113/6 142/23
per cent [1] 25/23
perceptions [1]

104/4

perfectly [9] 5/4 26/2
28/22 53/13 97/14
105/4 125/8 161/1
167/19

performance [2]
66/25 87/7
performing [1]
184/17

perhaps [18] 25/8
33/9 86/5 97/19
122/20 130/22 133/6
146/18 147/25 149/14}
153/18 159/7 164/9
184/7 187/23 194/4
194/7 200/5

perilous [1] 124/25
period [34] 3/1 3/11
3/14 4/11 6/19 6/21
6/25 7/7 7/13 7/16
9/13 13/22 14/18 34/5
34/13 37/20 51/10
51/12 78/6 78/15
84/17 90/22 117/7
118/2 119/19 120/22
124/23 127/5 131/18
131/18 149/14 186/11
188/10 195/7

Perkins [4] 5/22
66/22 66/23 97/8
Permanent [28]

72/10 72/18 124/1
140/24 144/24 145/18)
145/25 146/22 148/15)
148/18 148/23 148/25)
151/14 163/8 164/11
165/1 165/5 165/12
167/22 168/10 169/16)
175/14 176/17 177/8

191/23 191/25 192/24)
197/13
permission [9] 142/2
143/16 143/17 144/17)
146/8 172/14 172/15
174/19 180/7
perpetuated [1]
21/10
person [13] 3/23
4/12 13/11 23/15
48/12 57/21 57/22
57/23 109/14 109/17
134/25 135/1 147/20
personal [7] 22/3
30/13 61/14 67/21
145/21 149/4 159/22
personalise [1]
159/14
personalities [1]
124/9
personally [6] 17/12
17/20 54/12 147/13
159/12 188/16
perusal [1] 159/23
Peter [1] 169/23
petitions [1] 10/13
phase [4] 116/25
170/4 174/25 202/24
photographs [2] 12/5]
104/20
phrase [2] 71/18
86/21
pick [1] 46/14
picked [3] 42/12
42/17 64/5
picking [1] 41/15
picture [4] 15/5 43/9
97/12 131/15
piece [1] 164/15
pile [1] 18/17
pinpoint [1] 8/16
place [16] 6/7 12/6
36/24 37/5 48/14
84/11 85/15 92/22
101/25 131/2 149/3
157/14 179/8 185/7
195/7 195/16
placed [1] 158/2
plans [1] 99/5
platforms [1] 84/10
play [3] 136/4 153/22
157/24
played [1] 87/24
plays [1] 135/22
plead [1] 106/14
pleaded [4] 28/1 44/6
48/10 109/8
pleasant [1] 193/19
please [74] 1/5 1/10
1/19 9/11 15/6 15/20
16/6 16/22 21/14
21/17 23/5 23/6 23/9
23/11 26/5 30/20
30/24 37/25 38/20

38/21 39/19 42/25
47/13 47/18 47/21
48/20 52/12 55/11
55/14 58/22 58/23
63/1 63/2 66/4 69/23
70/23 71/10 72/1 78/4
94/20 94/21 97/20
100/22 102/9 114/15
115/3 116/19 117/15
132/9 132/9 132/15
135/8 138/25 142/5
143/7 144/21 144/21
145/9 150/11 150/13
150/23 158/5 158/5
165/18 166/6 169/18
169/24 172/8 172/23
175/23 181/10 186/19}
189/14 189/23
pleased [3] 49/3
55/16 56/8
plenty [1] 202/25
plus [1] 131/13
pm [7] 77/22 114/15
114/18 114/20 165/20
165/22 203/15
PMQs [1] 47/22
pocket [1] 102/20
point [54] 5/24 12/16
12/20 14/5 20/24 21/3
29/8 36/6 44/17 46/19
50/14 50/15 53/15
55/6 56/11 57/6 60/1
60/7 69/5 70/17 93/13)
95/14 99/10 101/22
106/20 107/25 109/8
109/14 109/16 111/19]
122/11 122/24 127/25
129/11 129/11 129/13}
129/13 140/20 142/20
146/16 147/10 148/17
149/3 155/17 157/8
159/5 162/9 163/19
172/5 177/20 182/16
184/13 184/21 192/25]
pointed [2] 27/13
194/5
pointing [1] 153/15
points [4] 107/22
174/15 189/5 200/3
POL [18] 11/2 13/1
101/19 101/22 102/3
102/7 102/14 103/6
105/25 106/6 106/8
106/12 107/6 107/13
144/18 156/24 164/21
186/8
POL's [1] 123/14
POL00039281 [1]
55/12
POL00059303 [1]
23/5
POL00097393 [1]
116/19
POL00117339 [1]

119/24
POL00117715 [1]
132/9
POL00141382 [1]
100/22
POL00141558 [1]
94/11
POL00153177 [1]
58/22
POL00176637 [1]
48/20
POL00195964 [1]
32/22
POL00218852 [1]
32/23
POL00232847 [1]
117/15
POL00285354 [2]
186/19 189/14
POL00285355 [1]
190/6
POL00296944 [1]
97/20
POL003454283 [1]
32/24

police [3] 14/15
76/10 136/15
policy [13] 9/2 12/13
22/8 22/9 42/16 76/19)
86/5 105/8 125/14
125/15 146/7 151/15
201/15
policymakers [1]
58/3

polite [1] 61/4

itical [2] 8/11 92/9)
politician [2] 11/20
202/23

politicians [5] 11/22
19/19 76/6 190/17
202/21

politics [1] 67/8
poor [2] 62/16 63/13
portfolio [6] 4/9 4/19
4/20 4/22 25/21 45/25
position [18] 29/15
110/15 119/12 123/9
132/17 143/19 143/23}
144/1 144/2 147/19
157/13 160/16 161/6
161/15 170/21 171/5
171/12 203/4
positioning [1]
159/18

positive [4] 12/24
42/18 42/22 108/2
possibility [3] 44/2
155/13 158/12
possible [6] 58/16
64/15 64/19 140/22
164/4 189/12
possibly [5] 63/8
74/11 113/1 168/23
177/4

E-]

post [342]
postal [9] 3/2 3/4
3/10 4/12 4/13 5/1
26/11 26/18 26/22
postmaster [6] 12/13
13/8 31/21 37/3
104/12 152/18
postmasters [36]
10/14 11/6 12/17
21/22 22/6 22/25 25/8I
32/17 34/3 37/8 50/5
50/11 53/5 60/4 60/20
66/14 66/15 68/20
69/14 71/21 74/8 90/8)
104/5 104/20 105/2
108/11 112/16 154/22!
155/7 155/18 157/2
157/11 186/16 188/2
190/17 190/18
postmasters' [1]
188/5
postmistress [3]
12/21 27/22 108/3
posts [1] 115/24
pot [3] 92/18 92/19
93/17
potential [1] 189/19
potentially [2] 45/21
183/6
pounds [2] 170/24
1711/4
pouring [1] 44/9
power [4] 122/11
137/3 161/9 181/22
powerful [1] 22/13
powers [3] 134/20
181/13 184/15
PP'd [1] 19/1
PPS [1] 33/15
PR [1] 45/8
practical [1] 188/23
pre [2] 89/24 90/15
pre-eminent [1]
89/24
pre-existing [1]
90/15
precedent [1] 148/14
precise [2] 76/3
1411/3
precisely [1] 58/9
predatory [1] 135/3
predecessors [2]
110/1 199/24
prefer [1] 197/20
preferable [1] 198/11
preference [1]
185/23
preferred [1] 164/15
pregnant [2] 57/22
109/10
prejudice [1] 155/10
premiership [1]
116/15
preoccupied [1]

(75) people... - preoccupied
Pp

preoccupied... [1]
51/18

preparations [2]
62/23 90/5

prepare [3] 17/23
24/5 140/19
prepared [6] 1/19
15/11 62/17 63/21
155/15 182/22
preparing [5] 15/8
29/7 172/16 177/9
197/23

prescribed [1]
109/11

present [3] 33/17
176/15 176/22
presentational [2]
168/21 169/2
presented [5] 24/13
102/12 146/14 174/10)
179/12

presents [1] 43/9
press [10] 41/2 41/13
42/16 42/20 42/23
44/18 45/13 46/12
128/2 156/4
pressed [2] 54/22
92/8

pressing [2] 146/3
173/23

pressure [2] 99/6
128/5

presumably [1] 5/16
pretty [7] 101/1
153/22 154/16 154/20)
191/1 192/11 199/11
prevailed [1] 138/17
prevent [1] 161/10
previous [3] 90/16
180/23 201/1
previously [1] 103/3
primary [5] 73/13
73/19 74/18 154/1
155/3

Prime [5] 3/19 47/22
52/1 59/6 185/10
principal [1] 120/24
principally [1] 123/20
principle [2] 90/9
136/19

principles [1] 67/11
Prior [1] 120/21
iorities [1] 94/2

prison [3] 57/21
113/24 171/2

privacy [1] 60/11
private [37] 7/2 17/17
18/3 18/9 19/7 25/21
33/7 38/23 39/1 39/13)
39/14 39/21 41/23

43/1 45/25 46/4 46/6
49/15 62/11 62/20
63/3 72/23 75/20
82/12 83/21 85/19
91/11 91/15 150/14
150/15 151/17 151/18)
151/22 153/13 153/14)
163/7 192/7
privately [2] 14/10
56/7
privatisation [12]
90/17 93/11 94/7 95/3
95/18 95/21 96/15
96/16 97/16 98/22
98/25 99/10
privatising [1] 88/23
Privy [2] 16/1 18/1
proactive [2] 60/13
155/14
probably [29] 6/6 8/5
10/4 11/5 18/2 20/9
25/7 27/16 46/10
54/19 61/18 64/5
67/12 71/14 74/4
74/13 75/9 77/3 82/12
127/14 149/16 154/19)
154/20 156/4 163/5
177/4 178/2 181/1
184/9
problem [32] 4/25
7/19 17/18 19/21
20/25 22/19 22/24
23/16 28/20 33/8
51/18 53/10 53/12
57/4 58/2 68/10 71/3
82/12 86/9 92/24 93/5)
96/22 104/1 104/15
107/16 109/17 112/24)
113/22 192/4 197/10
198/1 200/4
problematic [1]
81/16
problems [24] 6/13
28/4 28/6 33/17 52/17
52/25 56/16 61/21
82/17 83/13 83/16
86/24 92/17 93/20
95/16 97/6 105/12
109/15 131/16 132/6
142/12 156/12 156/24)
184/17
procedures [1] 26/16
proceed [7] 117/3
117/21 161/6 167/10
185/24 196/25 197/4
proceeding [6] 36/24
45/14 118/25 160/6
164/19 200/7
proceedings [6] 28/9
29/2 79/13 147/14
148/8 199/15
process [23] 14/7
17/10 25/12 26/24
30/14 44/4 49/7 56/7

56/9 70/12 70/13
112/1 131/2 134/11
136/17 140/15 140/25]
141/3 155/19 156/13
156/25 157/6 168/4
processes [7] 16/14
19/6 56/25 61/10
98/11 131/22 189/3
produced [2] 7/6
129/22
profile [1] 128/2
programme [2] 54/6
67/19
progress [5] 34/13
54/5 54/6 131/6
131/11
project [3] 70/2
122/12 178/19
projects [7] 81/19
82/2 82/19 83/17
85/24 86/19 195/21
promise [1] 91/20
promising [1] 156/6
promoted [1] 69/15
proper [4] 27/3
126/19 131/3 161/13
properly [15] 34/22
37/19 56/4 61/22 65/8
66/3 73/2 74/6 83/14
84/24 160/1 160/14
161/12 177/24 188/18}
proportion [1] 43/16
proportionate [1]
4/22
proposal [1] 24/21
proposals [1] 192/1
proposed [5] 174/11
175/2 179/9 181/19
198/14
proposing [1] 170/16
prosecute [2] 106/12
137/4
prosecuted [11]
14/10 15/1 31/3
108/25 109/1 136/14
137/5 137/14 137/16
137/21 137/24
prosecution [4]
68/24 72/16 119/7
136/19
prosecutions [10]
40/13 42/8 44/3
131/20 132/3 132/7
136/10 136/11 137/8
201/23
prosecutions/convictI
ions [1] 201/23
prosecutor [1] 7/3
prospect [2] 120/18
152/4
prospects [1] 191/9
prospectus [2] 97/2
97/4
protect [7] 22/16

69/16 73/14 73/20
74/18 74/23 178/7
protection [1] 3/6
proved [2] 12/11 71/5)
provide [4] 55/17
107/6 195/19 195/23
provided [10] 20/19
21/8 43/19 45/11
45/19 62/1 62/18
121/25 130/8 159/24
provides [1] 132/20
providing [3] 47/18
134/15 202/25
provisionally [1]
173/2

PS [1] 151/21

pub [2] 22/17 60/19
pub-goers [1] 22/17
pubcos [1] 71/4
public [62] 41/6
44/16 44/20 72/21
72/25 73/14 73/20
74IS TAIT 74/11 74/14)
74/18 74/20 74/23
75/2 75/3 75/7 75/17
75/22 76/5 76/21
81/18 82/2 82/7 82/8
82/11 82/14 83/2 83/4
83/17 83/21 84/10
84/12 84/14 85/6
85/10 86/4 91/14 95/8
103/20 125/20 138/10}
143/18 146/9 146/11
147/17 157/19 159/18}
171/4 183/7 186/10
191/24 193/3 193/24
194/14 194/14 197/23}
198/14 199/2 199/12
201/15 201/15
publicans [1] 22/17
publication [2] 43/23
62/14

publicly [2] 107/7
178/21

published [4] 36/16
62/16 63/19 146/10
publishing [1] 47/17
pubs [2] 70/6 71/4
punished [3] 12/14
104/13 105/6

purely [2] 136/11
136/20

purpose [1] 179/19
purposes [3] 85/2
146/21 200/9
purse [1] 82/14
pursue [2] 59/17
185/24
pursued [1] 179/13
pursuing [1] 193/7
push [1] 182/23
put [30] 2/3 18/17
20/5 22/25 29/11
30/10 51/16 53/2 57/5

66/16 82/20 121/3
128/4 130/23 132/22
139/18 155/16 157/12)
165/2 175/3 175/6
177/3 179/2 179/8
179/20 179/25 187/23)
191/20 195/16 203/3
putting [4] 71/6
83/15 99/6 154/4

Qo
qualified [2] 73/2
202/10
qualified/knowledge
able [1] 73/2
quality [2] 62/17
194/3
quashed [1] 80/5
querying [1] 7/22
question [37] 14/20
14/24 17/10 19/25
24/21 28/15 34/18
43/24 45/2 50/12
51/25 59/6 59/9 61/11
68/22 71/12 74/16
74/16 76/14 76/16
81/23 84/16 86/12
87/5 88/4 91/8 111/6
111/9 113/18 114/3
118/14 119/3 121/6
149/21 155/15 167/19)
184/12
Questioned [10] 1/7
80/1 88/12 99/18
115/1 204/5 204/7
204/9 204/11 204/16
questioning [1]
86/10
questions [33] 1/9
14/22 17/16 19/13
59/6 73/17 76/17
76/17 77/10 77/13
77/16 77/24 79/23
80/10 81/13 83/9 87/3
88/6 88/10 99/17
100/1 100/15 100/18
101/3 113/9 114/12
126/18 133/16 134/1
143/21 170/13 202/14}
202/15
quibble [1] 154/23
quick [2] 42/22
150/17
quickly [3] 44/17
77/4 186/21
quietly [1] 59/15
quit [1] 184/9
quite [23] 3/15 31/12
34/12 50/25 51/9
51/10 57/24 61/24
74/9 81/23 83/9 90/13}
117/16 125/25 154/25)
168/7 177/4 177/4
182/13 185/8 185/13

(76) preoccupied... - quite
Qo
quite... [2] 187/15
192/1

quote [2] 15/19 100/5]
quoted [1] 58/24
Qureshi [1] 23/7

R

radar [1] 85/17
radical [3] 25/4 90/11
179/12

radically [1] 132/18
raft [2] 40/5 42/5
raise [6] 4/24 34/7
35/3 87/18 91/13
170/13

raised [26] 11/5
13/15 16/20 19/13
27/20 28/4 28/7 28/8
31/14 31/20 35/8 38/6
46/5 46/7 46/8 56/13
60/19 88/3 88/6 89/13
100/8 103/22 112/9
113/8 113/22 120/7
raises [2] 137/18
137/19

raising [4] 32/25 52/4I
57/3 91/8

range [4] 4/23 75/17
110/1 113/10

rapid [2] 46/12
159/23

rarely [2] 17/3 191/10
rat [4] 54/25

rate [3] 68/24 93/9
93/10

rather [23] 45/5 45/8
46/17 51/2 59/12
70/12 74/23 79/12
84/21 98/23 123/21
125/7 133/12 135/7
148/11 153/23 159/14}
173/4 180/9 190/12
197/10 197/13 198/17
rational [1] 65/11

re [1] 130/6

re-read [1] 130/6
reach [2] 125/17
136/1

reached [1] 48/16
reaching [2] 152/11
173/10

react [1] 41/5
reaction [2] 94/8
153/17

read [25] 16/25 23/11
23/19 35/5 40/22
42/15 44/11 45/18
46/4 49/13 50/2 58/14)
68/6 86/6 112/20
118/5 123/4 130/6
147/3 154/9 155/5
159/11 160/3 184/23

189/19
reading [5] 18/24
40/25 49/17 168/19
169/15
readout [3] 150/18
151/5 188/25
readouts [1] 154/7
reads [1] 39/23
real [7] 36/4 72/22
102/2 103/10 104/1
109/17 188/21
realise [6] 37/6 46/7
46/8 86/5 86/7 86/8
realised [13] 41/25
46/5 50/3 51/1 51/8
61/3 61/20 65/8 71/6
91/24 108/16 108/24
113/14
realistic [1] 120/18
really [18] 3/18 4/7
29/16 30/4 30/6 51/2
51/6 51/8 51/8 53/4
57/9 57/16 67/1 83/20
140/4 152/21 159/2
202/9
reason [19] 1/15 7/17I
17/25 25/19 25/20
35/7 45/15 50/15
54/14 68/9 78/10
78/17 79/19 83/13
91/9 92/8 108/11
197/5 197/6
reasonable [6] 15/13
21/1 21/7 28/22 53/13
187/12
reasonably [1] 14/6
reasons [20] 6/11
11/11 11/13 24/2
51/22 69/20 92/9
103/1 113/16 119/1
120/19 127/8 152/8
152/15 152/23 168/5
171/17 180/11 182/11
192/21
reassurance [2] 53/4
54/23
reassured [1] 60/3
rebuttal [1] 155/15
recall [33] 9/3 10/4
41/11 44/13 44/14
87/6 87/10 88/1 95/25)
96/4 96/18 96/25
101/6 101/9 105/11
127/2 127/4 132/23
132/24 133/2 145/5
145/7 148/20 148/22
151/19 153/20 154/25)
155/20 157/23 171/14)
176/10 192/18 192/20)
receipt [2] 137/11
140/19
receive [4] 107/9
121/18 122/6 143/16
received [15] 47/9

58/9 63/19 117/20
119/23 120/3 120/4
122/2 122/15 128/2
128/7 132/10 152/6
169/20 173/21
receiving [2] 132/23
171/14

recent [1] 201/16
recently [5] 16/18
38/5 48/1 107/14
110/14

recess [1] 16/4
recognise [4] 8/21
10/22 39/20 199/10
recognised [4] 13/2
27/5 78/9 78/16
recognises [1]
135/21

recognition [1] 202/1
recollect [1] 168/11
recollection [7]
15/22 87/16 89/22
133/5 149/19 156/25
177/1

recommend [2] 43/8
179/13
recommendation [3]
172/18 178/13 182/24
recommendations
[12] 178/11 178/12
182/12 186/4 186/5
186/7 189/16 198/8
198/14 201/10 202/4
203/1
recommended [4]
68/6 118/13 121/15
133/24
recommending [1]
20/1

reconvene [1]
114/15

record [5] 5/17 5/23
6/3 6/4 201/6
recorded [2] 5/20
154/8

records [2] 6/11 31/4
rectified [1] 43/15
recusal [16] 158/15
159/9 159/16 160/6
161/7 162/1 162/9
163/25 164/19 166/1
166/23 166/25 167/9
172/11 174/17 180/15}
recuse [4] 158/24
162/23 166/4 166/16
recused [2] 165/11
169/13

redesign [1] 75/19
redress [4] 40/21
44/2 44/4 59/3
reduce [1] 132/18
refer [4] 10/20 41/8
82/24 116/25
reference [13] 38/8

42/4 107/11 115/18
130/9 143/4 143/23
156/20 173/11 177/19}
188/13 190/11 193/16
references [1] 178/2
referred [8] 3/16 3/22
11/8 16/1 64/23 139/8}
191/22 198/13
referring [6] 16/7
32/7 53/22 97/23
130/11 190/23
refers [5] 19/3 43/20
129/20 132/14 156/1
reflect [5] 79/19
160/11 164/24 187/9
201/12

reflected [3] 69/10
105/15 194/1
reflection [3] 187/12
191/18 202/12
reflections [3] 69/7
202/20 202/21
reflects [1] 171/24
refusal [2] 119/13
133/22

refused [5] 51/21
121/7 171/9 171/11
172/14

refuses [1] 170/22
refusing [1] 48/1
regard [4] 138/19
140/14 145/12 176/14}
regarded [3] 20/18
141/3 182/4
regarding [10] 49/6
52/1 52/5 116/23
127/24 129/2 143/20
152/14 159/9 181/11
regardless [2] 102/4
142/7

regards [1] 44/2
regional [2] 54/3
104/17

register [1] 105/13
registered [1] 5/23
regression [1] 58/11
regret [1] 118/23
regular [4] 3/13
36/21 123/18 140/11
regularly [3] 5/5
122/22 133/7
regulator [3] 69/22
69/24 71/18
regulator/arbitrator
[2] 69/22 71/18
regulators [1] 69/16
regulatory [1] 71/2
reinforced [1] 11/24
reinvent [1] 110/3
reinvestigated [2]
118/8 120/15
reinvestigation [1]
119/10

reiterate [2] 52/7

55/18
reiterated [1] 167/23
relate [2] 142/11
146/3
related [17] 16/14
17/12 19/5 20/7 34/3
70/17 81/1 94/5 95/10)
95/18 101/7 103/1
105/21 111/9 128/11
158/4 198/1
relates [3] 111/6
117/17 189/19
relating [13] 9/8
27/15 41/2 48/6 52/9
116/20 120/23 126/4
130/10 130/16 145/3
173/8 190/2
relation [20] 6/19
45/7 47/13 75/16 76/4
103/22 106/11 110/17
112/6 112/9 112/15
117/11 122/7 130/15
131/15 135/19 141/7
146/6 148/19 174/16
relations [6] 3/5
44/16 44/20 86/4
96/19 127/20
relations/communicaI
tions [1] 44/16
relationship [12]
21/20 22/1 24/17
25/15 32/5 69/13
90/10 126/12 137/1
143/1 168/6 190/4
relationships [3]
32/16 79/21 123/11
relatively [1] 128/2
release [1] 63/21
released [1] 90/23
relevance [1] 201/21
relevant [7] 17/22
24/5 107/13 116/11
120/16 143/10 176/15)
reliable [2] 15/2
138/6
reliant [2] 19/23
110/10
relieved [1] 134/19
reluctance [1]
140/12
reluctant [1] 92/2
rely [1] 10/7
relying [1] 135/7
remain [2] 43/22
59/15
remaining [3] 19/4
52/20 63/12
remains [3] 16/12
56/15 119/8
remark [2] 152/16
180/24
remember [15] 12/8
39/14 39/15 51/10
82/16 83/8 86/10

(77) quite... - remember
R

remember... [8]
119/18 133/8 138/15
139/12 153/9 164/2
186/12 189/1
remembered [2] 44/3
81/2
reminded [1] 32/4
remit [2] 8/19 41/20
remotely [2] 20/12
35/14
remove [2] 181/17
184/16
remuneration [1]
102/17
repaid [2] 106/9
106/12
repayment [1] 135/5
repayments [1]
103/3
repeat [2] 87/7
100/18
repeating [1] 144/11
repetition [1] 31/13
replied [1] 49/13
replies [1] 17/23
reply [9] 30/20 30/23
31/22 35/17 43/1
55/11 121/4 121/6
121/18
replying [4] 26/13
26/18 27/16 43/2
report [46] 14/21
36/16 36/17 36/19
36/25 40/3 42/3 42/4
43/11 43/13 43/16
43/23 44/8 44/23
45/12 45/17 45/20
A7IN7 52/15 54/16
62/14 62/15 62/17
63/10 63/11 63/13
63/16 63/17 63/21
63/23 64/3 64/7 68/7
94/9 94/16 94/16 95/2
95/16 97/23 98/8
98/21 107/8 120/17
124/1 129/23 175/9
Report's [1] 99/4
reported [3] 66/9
198/6 200/21
reporting [5] 36/22
40/15 83/16 144/11
197/19
reports [4] 7/7 7/10
44/23 118/11
represent [7] 75/1
75/5 75/7 80/3 106/21
107/14 123/13
representation [1]
107/6
representative [6]
24/14 54/1 74/2 74/10
151/16 167/11

representatives [1]
66/16
represented [4]
25/11 59/19 60/3
112/18
representing [4]
86/16 103/9 123/8
124/10
represents [2] 75/2
119/11
reproduce [1] 29/21
reproduced [1] 35/24)
reputation [1] 177/22
reputations [1] 171/5
request [4] 63/22
106/8 164/12 170/13
requesting [1]
179/19
require [6] 76/1
76/22 101/23 123/24
132/19 152/7
required [3] 25/5
141/18 156/16
requirement [3]
126/15 168/21 200/5
requirements [1]
134/9
requiring [2] 43/24
179/19
research [1] 68/23
reserving [1] 180/9
residents [1] 13/10
resolution [2] 173/10
193/13
resolve [3] 119/20
134/1 201/25
resolved [2] 131/25
155/14
resolving [3] 120/19
132/6 134/10
resources [3] 27/2
167/24 195/14
respect [8] 61/13
70/6 85/8 135/10
153/24 162/16 186/10)
193/21
respected [3] 60/16
134/25 172/4
respectful [2] 50/1
173/18
respective [1] 140/16)
respectively [1]
170/13
respects [2] 124/13
149/12
respond [2] 26/23
65/10
responded [3] 15/25
43/21 62/20
responds [2] 159/1
161/18
response [21] 15/15
16/3 35/18 35/22 36/1
36/3 41/23 49/14

55/17 59/9 62/17
62/18 63/16 63/22
63/24 88/4 119/23
119/25 135/11 139/1
143/17
responses [2] 26/4
144/19
responsibilities [2]
136/5 196/2
responsibility [26]
3/10 5/5 8/7 8/12 8/14,
8/18 8/23 8/24 27/12
32/1 32/13 67/21 73/3
118/14 119/2 119/4
122/7 124/18 124/20
151/15 183/13 184/8
189/25 191/22 198/21
202/5
responsible [17] 3/2
3/4 4/12 4/13 22/9
32/16 40/11 42/19
72/9 72/12 72/13
86/15 89/5 99/9
100/11 122/17 170/14
rest [4] 103/19 134/9
166/16 185/4
restitution [8] 156/17
157/1 157/10 157/12
162/17 172/7 177/14
186/17
rests [1] 120/11
result [4] 13/19 48/10
106/18 145/12
resulting [3] 70/18
176/25 178/22
resume [1] 203/7
retail [1] 137/2
retained [3] 5/12
5/17 5/18
retrospect [4] 25/7
65/25 66/7 91/5
returned [1] 55/2
revealed [2] 13/20
59/16
Revenue [3] 81/9
82/4 82/17
reversed [1] 84/25
revert [1] 156/7
reverted [1] 112/13
review [18] 7/3 16/19
38/5 40/3 40/18 76/3
119/10 120/5 128/5
128/16 130/24 149/25}
175/8 175/20 178/17
198/5 200/17 200/17
Review/the [1]
200/17
reviewed [3] 174/5
174/9 185/22
reviews [1] 120/7
revised [1] 49/16
revisit [1] 173/5
Richard [2] 158/7
160/24

ridiculously [1]
104/14
right [51] 1/6 2/7 2/8
2/16 3/1 3/11 6/15
11/3 14/19 46/18
64/12 70/14 70/15
71/24 77/17 80/7
90/18 96/9 101/12
103/19 107/1 108/25
109/12 114/25 116/1
116/2 116/10 116/16
116/22 117/14 119/15}
122/3 122/22 123/23
128/11 138/8 147/20
150/8 158/25 160/13
167/16 168/3 169/1
181/16 189/13 193/10}
202/22 203/7 203/13
204/2 204/13
rightfully [2] 103/6
106/1
rigorously [1] 138/23)
ring [1] 44/25
risk [16] 7/25 82/9
83/21 95/24 95/25
96/2 96/17 96/18
96/23 97/11 97/15
98/7 125/2 179/6
180/17 182/4
risks [4] 159/17
160/7 164/20 183/4
robust [4] 138/5
156/8 164/15 201/6
robustness [2] 16/13
19/4
role [15] 65/18 66/2
66/6 67/9 76/3 81/14
86/15 87/18 87/24
123/3 132/5 136/4
181/11 193/17 197/1
roles [3] 67/12 67/23
67/24
Rolfe [2] 111/8 200/1
rooted [1] 113/22
roughly [1] 4/19
round [6] 7/14 89/18
113/18 191/11 191/21
197/10
route [2] 35/12 35/13
routine [2] 18/16
41/14
Royal [15] 88/23
88/23 90/2 91/2 91/5
91/9 92/17 93/11
93/21 94/17 95/3 95/7,
95/8 95/12 95/21
rudeness [1] 142/20
ruined [1] 113/25
run [4] 7/9 86/19
87/20 143/18
running [5] 21/22
84/1 87/21 103/24
184/25
runs [2] 76/14 180/17

Russell [5] 122/21
124/3 139/12 139/14
141/17

Ss

sacked [1] 39/25
safety [4] 7/1 7/5
128/17 193/5
said [65] 5/14 19/9
19/10 19/20 23/12
23/15 28/2 29/17
30/18 34/25 36/5
36/22 37/15 37/16
38/12 40/8 43/11 50/5
50/7 50/10 50/15
53/10 57/2 62/15 65/9I
66/12 68/25 75/9
87/18 88/4 91/25
96/24 97/25 100/14
102/9 104/9 104/16
105/17 108/15 108/19)
111/7 122/1 126/6
127/7 139/22 139/23
145/19 148/13 151/21
154/3 154/12 155/2
155/4 156/19 157/11
159/3 162/25 165/10
180/22 183/18 183/20)
186/15 192/16 192/18}
192/20
Sajid [1] 110/6
sale [5] 91/21 91/23
92/21 101/22 127/25
Sam [1] 99/19
same [30] 22/17
24/13 33/4 33/4 33/5
43/3 49/22 50/25 62/2)
62/3 62/6 67/6 72/10
82/12 95/9 99/11
101/8 110/18 110/20
110/23 111/10 117/18}
123/14 132/7 139/8
146/16 149/1 159/5
163/1 175/22
Santiago [1] 13/12
sat [1] 104/23
satisfactory [2]
176/6 193/12
satisfied [6] 28/21
50/11 53/10 134/17
147/20 160/12
satisfy [1] 146/11
Saturday [9] 151/7
151/19 162/21 172/1
172/3 177/12 179/25
182/18 189/1
Saudi [3] 51/13 64/24)
113/12
saved [2] 187/11
202/2
saw [14] 12/10 17/8
17/21 18/25 24/1 24/9)
32/18 45/7 86/4 93/19
138/19 145/16 172/2

(78) remember... - saw
Ss

saw... [1] 190/22
say [117] 4/1 5/10
7/13 8/22 9/14 10/1
10/10 12/8 13/1 15/7
15/21 16/23 17/25
18/8 18/24 21/14
21/22 22/15 24/23
26/25 27/18 29/14
32/10 33/14 34/20
36/14 42/15 45/1
46/12 50/23 61/8
61/11 61/13 62/20
68/18 69/9 70/16 72/1
73/17 73/22 75/3
75/13 78/5 80/25
81/22 94/22 96/18
96/20 97/14 97/15
98/9 98/16 99/16
100/7 102/1 105/23
108/19 109/16 111/14}
112/22 113/19 114/1
121/13 121/15 121/19
123/22 123/25 127/13}
130/6 130/18 132/5
133/8 133/10 133/14
134/2 134/14 134/19
134/25 135/15 138/16)
139/19 140/11 140/14}
141/5 141/6 145/10
148/21 151/14 152/13}
153/16 155/4 158/13
158/23 160/5 162/12
162/13 162/22 163/15
164/13 164/17 165/6
168/14 168/20 168/22)
175/12 180/17 182/23}
184/2 186/6 186/23
188/7 193/24 196/9
196/21 200/11 201/7
201/12
saying [16] 28/25
35/2 35/12 41/19
42/18 50/18 50/22
52/14 61/17 91/18
103/25 112/7 122/23
128/24 164/16 202/22)
says [69] 23/14
27/19 39/5 42/3 42/12
43/4 47/21 59/1 80/21
94/13 98/4 118/6
120/1 123/5 125/14
127/22 132/15 135/23}
138/3 138/20 138/22
139/2 141/21 141/24
142/6 143/8 145/1
146/2 146/6 147/4
148/7 151/21 151/23
152/3 153/13 153/25
154/10 156/14 158/8
159/10 160/25 161/3
161/18 161/23 164/23)
166/6 167/7 169/25

172/11 172/25 174/16)

176/1 176/23 179/11
180/4 181/7 181/12

181/15 185/21 189/20)

190/13 191/7 191/17

192/14 193/16 195/12,

196/2 196/5 196/11
scale [1] 128/21
scales [1] 197/8
scandal [2] 8/12
69/11
scenario [1] 152/1
scenes [1] 97/20
sceptical [1] 83/7
scepticism [5] 81/10
82/25 83/1 86/2 86/20
scheduled [2] 147/5
186/1
scheme [26] 7/9
36/12 47/17 47/24
48/25 49/1 50/6 51/20
52/2 52/5 52/7 52/8
52/9 52/20 55/19
55/20 56/4 56/23
63/18 71/15 71/20
117/25 120/15 177/14)
187/22 189/7
Scheme's [2] 118/9
118/15
schools [3] 76/10
76/20 77/1
Science [2] 116/7
201/17
scores [1] 40/20
scrap [1] 104/19
scrapbook [1] 12/4
scratch [1] 77/5
screen [7] 2/5 9/11
13/23 100/6 116/19
121/11 195/6
scroll [38] 23/6 23/11
47/20 120/1 123/1
127/16 132/11 132/13)
139/5 139/20 141/24
142/5 143/7 150/12
150/20 151/8 151/23
158/6 159/1 159/8
160/3 160/24 161/2
161/21 166/6 167/7
169/24 172/10 172/23)
174/6 180/3 181/10
182/24 183/4 186/3
193/15 196/7 196/11
scrolling [3] 23/18
127/18 183/10
scrutinising [1]
66/24
scrutiny [2] 56/14
192/10
searched [1] 6/5
second [73] 7/5 14/5
19/3 26/6 27/12 27/18)
31/13 36/11 36/11
36/15 36/18 37/1 37/5

37/10 38/9 38/17
38/21 39/17 42/4 45/7
47/16 48/2 48/3 48/6
48/17 52/15 54/1
54/16 56/6 56/17
62/14 62/14 63/10
67/6 70/1 77/14 81/5
84/7 88/22 89/24
90/15 90/25 94/9
94/12 94/13 94/16
95/1 95/16 97/22
97/23 98/2 98/24
117/14 117/3 117/13
118/10 118/13 118/18}
119/11 120/5 120/7
120/16 120/23 121/4
121/14 128/1 129/20
129/22 148/2 170/4
174/20 193/11 201/21
secondly [2] 70/16
75/13
seconds [1] 46/11
secretaries [4] 39/13
39/15 151/18 197/13
secretary [84] 2/19
4/10 29/12 43/2 48/22
53/8 53/16 59/11 65/2
65/3 65/6 65/11 65/18
67/2 72/10 72/18
80/25 83/18 84/17
87/9 87/21 100/4
100/25 101/2 104/2
108/14 108/21 109/24
116/3 116/9 116/11
116/18 120/21 123/6
123/22 124/1 130/8
132/10 133/2 140/24
144/24 145/18 145/25
148/15 148/18 148/23
148/25 151/10 151/15}
151/18 151/22 151/24
152/4 153/13 153/14
154/1 154/10 154/12
154/13 154/13 155/12
155/13 156/11 156/23}
163/8 164/11 165/6
165/12 166/7 167/23
168/10 175/14 176/3
176/17 177/8 183/7
184/20 185/22 190/11
190/14 191/22 191/23
191/25 198/5
Secretary's [4]
146/23 165/2 169/16
192/24
section [5] 97/4
172/24 181/11 191/5
196/1
sector [4] 72/24
75/20 83/17 91/16
secure [1] 88/18
securing [1] 90/20
see [86] 1/3 1/21
16/8 16/22 19/3 23/6

23/9 23/14 26/7 26/8
26/9 27/18 29/25 31/6
31/12 34/2 37/25
38/15 38/15 38/22
39/3 39/17 41/23 42/3
42/25 44/23 45/17
47/3 47/13 47/19 54/3)
54/16 55/12 60/17
61/7 61/25 63/4 67/15
80/6 80/19 81/6 83/24,
89/10 93/11 93/19
94/14 99/13 101/13
101/13 105/9 112/18
114/21 117/23 122/5
123/1 127/16 132/13
136/19 138/22 140/17
141/10 142/6 143/14
146/8 149/15 150/13
150/20 154/2 155/3
158/7 160/24 165/23
167/7 170/22 172/24
174/6 178/2 178/6
178/7 178/22 183/2
183/5 183/22 186/16
192/23 194/19
seeing [2] 40/25
175/20
seek [10] 55/23
64/11 125/7 125/17
142/1 144/17 146/8
148/10 166/15 172/15
seeking [3] 34/13
59/13 95/10
seem [4] 5/22 58/5
174/22 187/15
seemed [5] 20/24
53/13 152/16 169/12
192/2
seems [25] 40/22
46/4 97/14 118/18
123/13 127/1 128/10
135/9 137/22 140/3
150/19 168/19 181/6
184/20 188/13 190/2
191/4 196/24 197/9
197/15 198/11 199/1
199/15 200/18 201/13}
seen [27] 7/19 12/10
15/17 15/23 16/23
18/15 23/22 23/24
26/20 38/13 39/7
40/24 46/4 46/6 48/6
61/12 62/4 64/14
95/15 97/1 117/5
164/9 164/9 170/15
171/16 175/12 193/9
Select [13] 14/21
49/21 51/3 53/9 55/4
60/15 62/19 64/1
64/18 85/21 101/6
101/10 103/20
selected [2] 102/18
102/20
self [1] 132/22

sell [1] 92/17
seminal [9] 5/19
149/7 149/10 149/11
149/17 149/18 150/5
150/6 173/14
send [2] 55/9 63/23
sending [1] 64/17
senior [7] 50/1 68/1
68/9 170/9 176/17
176/21 197/11
sense [18] 3/21 4/11
22/8 67/17 71/15
82/20 90/16 91/1
92/24 99/1 99/2 99/16)
110/24 131/3 132/1
148/18 149/16 149/18)
sensible [1] 76/19
sensitive [4] 55/22
98/8 98/19 98/25
sent [24] 17/5 19/1
20/20 24/4 26/5 26/9
26/13 35/18 35/19
57/21 62/3 100/3
113/24 118/6 127/15
135/15 135/16 138/13)
139/9 141/22 166/19
1471/2 171/15 175/14
sentence [8] 52/24
54/17 106/2 109/9
128/15 156/23 157/9
157/10
sentenced [1] 135/5
sentences [1] 54/17
sentiments [1]
171/20
separate [7] 11/1
88/22 91/22 93/20
94/17 112/14 199/9
separated [3] 67/24
93/25 126/3
separately [6] 25/4
28/5 85/23 86/14
145/20 166/8
separation [4] 67/11
67/22 90/2 90/17
September [3] 37/21
119/7 189/17
serendipity [1] 24/24
series [4] 32/20
58/11 176/13 199/22
serious [8] 29/8
61/21 73/10 78/8 86/9
88/7 103/21 113/22
seriously [2] 51/9
79/8
seriousness [1] 96/4
servant [1] 24/7
servants [17] 4/21
8/5 17/22 17/23 18/3
20/4 25/21 28/21
30/17 33/7 33/24
79/18 79/20 87/23
154/15 197/1 198/10
serve [1] 193/23

(79) saw... - serve
Ss

served [1] 115/25
Service [11] 2/10
2/13 79/17 83/4
109/25 110/10 156/21
195/18 197/2 197/3
197/8
Service's [1] 195/24
services [6] 89/10
118/11 125/17 127/17)
136/1 138/7
session [2] 48/25
49/4
set [28] 21/15 22/10
24/22 33/14 34/1
49/22 58/11 69/12
70/7 70/10 71/2 88/17,
101/7 107/14 107/19
119/1 120/20 125/15
126/20 149/11 165/13}
168/5 171/17 173/24
177/13 181/2 189/22
197/14
sets [9] 40/4 42/4
126/8 135/21 135/24
163/23 174/15 183/3
196/7
setting [8] 26/15 56/9)
60/24 95/6 103/10
180/10 189/6 197/10
settle [4] 102/13
171/12 177/13 189/4
settled [2] 192/16
192/19
settlement [6] 70/3
152/11 178/19 188/22)
188/25 193/11
seven [2] 3/3 183/21
seventh [1] 23/14
several [6] 16/21
17/19 27/5 34/24 36/5
119/18
severally [1] 199/11
severe [1] 170/11
severely [2] 12/14
171/2
shadow [6] 80/24
125/1 182/4 182/4
182/17 198/20
Shaikh [2] 135/10
139/1
shall [5] 141/6
168/22 182/23 185/14}
201/6
shame [1] 59/15
share [5] 8/12 8/13
8/23 50/11 159/16
shared [2] 118/12
183/13
shareholder [14]
15/14 74/10 75/5
75/18 86/16 123/6
123/9 123/14 148/14

158/14 158/17 161/9
170/17 181/12
shareholder's [1]
167/11
shareholders [1]
92/22

shareholding [1]
123/7

sharing [3] 84/11
85/7 179/8

she [53] 11/12 12/22
13/13 28/1 28/8 29/1

68/7 68/8 68/9 74/4
97/4 97/8 97/8 97/24
97/25 98/2 98/4 98/4
98/8 98/14 109/1
109/3 109/7 109/11
1114/7 117/2 117/4
117/4 120/1 120/3
120/4 121/5 121/6
132/12 132/14 135/5

158/19 158/19 161/9
168/12 169/23 187/6
she'd [2] 109/2
129/18

she's [3] 43/2 97/23
121/12

sheet [1] 109/24
ShEx [14] 19/7 39/2
62/12 67/3 68/12
78/11 78/18 78/22
79/1 79/14 79/15
79/19 86/15 99/8
shocked [1] 109/21
Shoosmiths [6]

103/25 105/23 106/3
short [9] 17/7 47/1
77/21 93/1 94/8
114/19 151/20 165/21
173/7

short-term [2] 93/1
173/7

shortcomings [2]
98/11 159/19
shortened [1] 201/25
shortfall [1] 109/5
shortfalls [1] 40/4
shortly [6] 82/15
93/24 94/7 127/15
139/25 145/10
should [94] 1/20 5/12
6/18 7/20 7/21 7/24
8/1 20/23 25/2 25/7
25/8 31/10 36/6 42/23
44/5 49/16 49/25
54/20 65/19 66/5
66/21 68/6 69/22
70/21 71/7 71/19
75/10 75/10 76/19

shares [2] 91/1 93/18

29/1 32/4 37/15 39/13
43/3 48/10 48/11 68/6

135/18 135/21 135/23)

101/13 101/16 103/14)

84/20 86/6 95/2 98/8
98/9 101/11 110/25
115/5 118/15 125/17

137/3 138/8 141/2
142/1 146/8 148/12
153/6 155/5 155/8
156/3 156/6 156/8
156/13 157/7 157/10

161/5 161/24 162/3
162/5 162/13 163/24
165/2 165/7 165/13
169/3 169/7 169/7
175/11 176/20 182/8

192/19 194/4 194/20
198/9 198/10 199/6
199/20
shouldn't [9] 103/12
148/10 148/13 157/5
157/20 158/1 168/25
168/25 189/3
show [4] 2/4 48/7
64/6 160/18
shown [2] 64/19
175/8
shut [1] 118/3
shy [1] 184/14
side [6] 2/3 29/11
83/15 99/24 184/3
190/19
sides [2] 147/14
148/8
sight [47] 7/5 14/5
36/11 36/15 36/18
37/1 37/5 37/10 38/9
38/18 42/4 45/7 47/16
48/2 48/3 48/6 48/17
56/6 56/18 62/14
63/10 70/2 94/9 94/16)
95/1 95/16 97/22 98/3
98/24 117/14 117/3
117/13 118/10 118/13
118/18 119/11 120/7
120/23 121/14 128/1
129/20 129/22 140/21
142/3 144/17 148/1
193/11
Sight's [4] 52/15
54/16 120/5 120/17
sign [11] 16/2 18/6
30/12 38/12 49/19
50/9 50/13 51/19
51/21 51/23 54/24
signature [2] 1/22
115/13
signed [5] 15/23
16/23 20/3 55/13 60/6
significance [1]
180/23

134/15 134/24 135/24

157/12 157/14 158/11
158/23 160/15 160/20

182/14 182/15 182/20
184/13 184/13 186/20
189/12 189/23 192/16

significant [8] 6/19
43/22 59/19 95/11
132/13 145/14 174/1
175/24

signing [4] 16/25
18/17 38/11 50/23

silk [1] 150/1

similar [7] 5/14 22/19
24/11 31/6 139/5
170/6 197/25

similarly [3] 78/13
86/20 108/8

simple [3] 45/8 93/13
107/20

simplicity [2] 196/25
199/9

simply [14] 8/17
20/19 26/2 30/1 30/22,
35/12 38/13 42/1
42/12 82/20 82/21
91/8 99/8 121/15

since [14] 49/3 56/13
56/24 67/8 72/25 80/5
89/13 89/23 139/18
149/22 150/3 161/15
168/22 172/10

single [3] 12/3 34/5
170/17

sir [56] 1/3 1/5 1/6
1/8 1/15 5/14 13/3
18/8 33/12 33/23 35/2!
46/21 47/3 47/7 57/19
61/17 71/14 71/25
77/10 77/16 77/23
78/3 79/23 80/2 80/19
81/21 85/2 88/9 88/13)
95/15 97/10 99/19
100/6 106/20 109/12
110/12 111/5 113/19
114/1 114/5 114/9
114/10 114/14 114/15}
114/21 114/23 127/7
165/15 165/23 187/20}
188/7 202/14 202/15
203/3 203/9 204/2

Sir Alan [1] 13/3

Sir Ed [1] 5/14

Sir Vince [28] 1/5 1/8
1/15 18/8 35/2 47/7
57/19 61/17 71/14
77/10 80/2 80/19
81/21 85/2 88/9 88/13

95/15 97/10 99/19
100/6 106/20 109/12
110/12 113/19 114/1
114/5 114/10 127/7

Sir Wyn [4] 114/14

187/20 188/7 203/3

sits [1] 94/23

sitting [3] 76/24 80/6

131/4

situation [8] 17/12

22/15 22/21 33/13

33/23 112/17 162/3

164/3

situations [2] 69/15
104/21

six [2] 3/3 23/12
skating [1] 182/10
skewed [1] 43/9
Skills [1] 2/20
skillset [1] 191/14
skip [1] 15/19

slight [1] 85/2
slightly [2] 28/24
179/22

small [11] 16/19 38/6
43/16 45/24 57/3
84/21 84/23 127/23
128/25 129/5 129/8
smaller [2] 70/20
129/9

smattering [1] 7/12
smell [1] 54/25
Smith [3] 173/2
174/5 174/7

snap [1] 55/9

so [223]

so I think [1] 183/20
so-called [1] 33/15
sold [2] 91/2 91/6
sole [2] 123/6 181/11
solicitors [5] 80/4
99/23 101/13 103/25
106/3
solution [2] 25/5
71/20
some [86] 5/19 5/23
6/1 7/5 8/12 9/7 11/2
20/24 21/3 25/11 26/4I
33/19 36/6 37/14
39/24 41/5 47/8 51/8
57/11 58/17 60/10
61/9 62/19 68/12
68/23 69/7 71/19 73/4
75/23 76/22 77/13
79/4 92/7 94/4 95/24
97/1 102/24 104/6
104/20 116/20 122/8
123/2 126/23 128/6
128/16 129/10 131/4
132/1 134/1 137/23
137/24 137/25 140/12
141/24 142/8 145/2
145/8 146/21 147/14
148/8 152/2 153/2
153/3 154/11 157/17
161/8 163/5 165/6
167/22 168/18 171/2
175/19 176/20 178/25)
179/6 179/20 186/13
187/15 189/24 194/6
194/6 198/18 199/10
199/17 202/2 202/3
somebody [10] 14/14!
19/20 20/8 30/11
41/18 42/17 57/12
58/16 73/2 139/10

(80) served - somebody
Ss

182/5 184/24
something [52] 8/21
14/17 30/12 34/25
41/4 42/18 42/22

55/1 56/11 65/9 66/21

88/3 89/14 96/6 96/8
98/7 98/19 98/24

124/16 125/1 126/3

146/25 151/6 153/1
153/9 153/16 154/10

189/2 194/2 197/10
198/14 201/12
sometimes [5] 3/22
18/16 40/21 75/20
143/25

196/19

soon [1] 144/19
sorry [12] 22/12 35/2
53/22 53/23 57/20
73/25 81/23 81/24
94/13 111/12 111/12
187/23

sort [24] 11/19 69/25
90/3 99/7 129/17
132/6 135/1 145/24
161/8 167/25 169/9
178/7 182/10 182/15
189/24 191/3 192/6
192/24 192/25 196/24}
197/14 198/9 199/11
202/8

sorts [2] 138/9 150/2
SoS [2] 151/10
154/14

sought [2] 59/23
148/3

sound [1] 34/18
sounded [1] 24/11
source [1] 58/25
sources [1] 49/20
South [1] 23/8

Spa [1] 68/25

spark [1] 83/25
speak [6] 98/15
104/12 147/17 156/21
159/4 162/22
speaking [3] 1/13
59/4 163/5

speaks [2] 24/18
25/17

special [5] 2/12
17/25 77/6 77/7

someone [6] 15/24
122/20 136/25 157/25)

44/18 44/19 51/1 51/8
67/4 68/21 72/20 84/5
106/11 108/16 108/23)
108/24 109/12 109/18}

136/21 145/22 146/20)

154/16 177/25 184/14)

somewhat [2] 182/10

somewhere [1] 163/5}

151/13

specialism [1]
151/19

specialists [1] 201/5
specific [9] 9/3 49/6

84/6 153/12 181/14
specifically [2] 14/12
88/19

specifics [2] 9/7 94/4
spectrum [2] 8/11
137/20

speech [1] 153/8
spelt [1] 93/25
spending [2] 74/5
17113

spent [6] 18/23 66/1
66/5 74/7 111/15
113/7

spheres [1] 199/4
SPM [8] 102/11
102/12 102/18 102/21
103/5 105/24 106/6
106/13

SPM's [2] 102/17
106/7

SPMs [14] 101/17
102/4 102/15 102/24
105/19 106/13 106/18)
107/5 107/6 107/8
107/14

spoke [3] 30/17
158/9 166/7
spoken [2] 43/5
169/7

spot [1] 201/22
spots [1] 201/21
spotted [1] 201/23
spotting [1] 198/3
staff [2] 99/20 101/20
stage [16] 12/18
27/17 108/20 130/1
133/13 136/14 142/14)
148/21 166/17 174/4
174/22 175/1 177/17
179/13 180/25 190/12)
stages [2] 86/22
102/18

stakeholder [1]

75/22

stakeholders [2]
189/21 191/3

stand [2] 19/8 73/4
standard [4] 18/4
18/19 122/4 138/16
standing [2] 198/21
201/14

stands [2] 160/9
164/22

start [8] 9/7 21/8 77/5)
109/23 110/2 159/7
183/20 188/21
started [11] 6/8

73/6 73/16 75/15 79/3

spokesman [1] 80/23}

14/21 61/23 100/25
104/15 112/1 112/1
129/8 131/24 187/17
188/14
starting [2] 176/9
191/11
state [59] 2/19 4/10
8/18 29/12 48/22
59/11 65/2 65/3 65/7
65/11 67/2 70/8 80/25)
83/18 84/17 87/9
87/21 89/12 95/23
100/4 100/25 101/2
104/2 107/7 108/14

116/9 116/11 116/18
120/21 123/6 123/22
130/9 132/10 133/2
151/10 151/24 152/4
154/1 154/10 154/12
154/13 154/13 155/12
155/13 156/11 156/23
166/8 176/4 178/21
183/7 184/20 185/22
190/11 190/14 191/23
198/5
stated [1] 117/2
statement [74] 1/18
1/24 3/8 5/9 6/13 8/11
9/10 9/19 9/22 10/10
15/6 15/8 17/14 21/13}
33/20 36/13 43/25
A7IT 49/12 59/22 62/9
65/23 66/20 69/8 78/4
80/11 82/24 88/17
94/10 94/20 94/23
94/25 95/1 95/5 95/6
95/13 95/17 98/20
98/22 100/6 100/14
114/11 115/6 115/15
122/1 123/23 126/20
130/5 130/18 131/17
140/12 140/18 149/7
149/12 153/17 154/3
155/13 155/14 155/17I
155/20 155/22 155/24)
156/1 156/4 156/19
176/11 180/21 183/8
184/1 196/21 201/11
202/4 202/12 202/19
statements [2]
141/18 186/10
states [1] 199/5
station [1] 122/11
status [2] 76/4 180/5
stay [2] 108/22
147/16
stayed [1] 174/21
STEIN [5] 99/18
99/19 111/13 114/7
204/11
step [2] 184/19 185/9
Stephen [1] 139/10
stepping [1] 84/7

108/21 109/25 115/25

steps [4] 42/2 95/7
140/18 179/12
Steve [1] 198/6
sticking [2] 36/3
165/25

still [7] 54/24 58/7
64/4 98/17 113/14
155/18 171/3
stock [1] 138/12
stolen [1] 101/20

56/17 167/18
stop [2] 187/24
191/15
stopped [1] 34/25
stopping [3] 18/8
33/19 88/20
story [5] 39/2 39/8
42/10 42/11 46/16
story.pdf [1] 39/18
straight [3] 93/2
171/19 187/13
strange [1] 60/8
strategic [17] 32/14
76/17 88/14 88/17
89/3 89/25 93/22 96/8
97/13 99/5 126/14
126/19 137/5 137/8
137/19 144/10 144/14}
strategy [19] 78/17
87/12 87/14 87/19
87/23 116/12 127/17
132/16 172/22 173/10}
173/24 174/5 174/10
174/23 175/9 178/17
179/7 181/23 187/25
straw [1] 151/20
street [1] 40/9
strength [1] 162/11
strengthen [1]
132/17
stressful [1] 190/20
stretch [1] 2/14
strictly [1] 167/16
strides [1] 132/13
strike [3] 12/12 96/2
105/7
strong [6] 163/22
168/13 170/3 184/1
190/14 190/24
stronger [1] 183/7
strongly [5] 79/7
152/17 164/16 165/4
170/2
struck [3] 54/9 54/12
199/21
structural [4] 124/15
189/20 192/4 200/3
structurally [1] 192/8
structure [6] 22/24
73/15 75/14 122/19
178/19 189/7
structures [1] 199/18}
struggle [1] 58/7

stood [4] 52/18 52/25)

studied [1] 18/21
study [2] 18/19 44/21
studying [1] 44/23
stung [1] 152/21
style [1] 39/20
styles [1] 61/9
stylistic [1] 49/25
sub [4] 27/24 130/21
135/20 147/9
Subcommittee [2]
174/13 179/3
subcontractors [1]
70/21
subject [8] 7/18
20/12 39/2 44/3 72/15}
101/19 161/17 162/4
subjects [1] 18/18
submission [24]
18/12 43/19 103/16
141/9 144/22 144/23
145/11 145/16 145/23)
166/1 166/10 167/6
169/19 172/9 172/11
174/3 175/3 175/13
175/24 176/1 178/3
179/22 183/3 186/2
submissions [7]
103/13 105/23 107/20)
107/23 124/7 175/2
177/13,
submitted [1] 101/13
subparagraph [1]
7112
subpostmaster [5]
9/9 16/12 16/18
135/10 135/20
subpostmasters [55]
6/2 6/22 13/24 14/11
15/1 21/21 22/2 24/18)
25/16 26/17 33/1 39/2I
39/18 39/24 40/8
40/10 43/17 44/6
56/20 68/15 80/4
87/20 99/20 101/17
103/10 106/21 107/4
1417/7 126/5 126/13
127/24 128/4 128/25
129/7 131/21 134/4
136/7 136/10 136/11
136/14 136/20 142/21
143/1 144/5 149/15
149/21 150/7 152/19
153/6 162/17 170/3
173/16 176/6 178/7
184/3
subsequent [3] 52/2
52/16 119/7
subsequently [5]
12/16 14/16 26/10
59/7 135/3
substance [8] 46/5
46/7 46/9 50/2 173/6
173/12 175/2 175/10
substantial [3] 122/8

(81) someone - substantial
Ss

substantial... [2]
122/14 138/10
substantially [1] 33/4I
substantive [1]
115/10
substantively [1]
160/21
succeeded [2] 108/6
111/2
success [2] 90/25
91/7
successful [2]
143/12 143/13
successfully [1]
56/21
succession [1] 3/9
successive [1]
200/25
successor [2] 110/7
190/25
successors [1] 77/3
such [15] 4/25 5/12
5/15 28/14 52/19
54/17 112/24 123/12
136/4 142/25 143/11
146/12 146/13 161/19
164/5
suchlike [1] 148/2
sued [2] 39/25
190/16
suffered [2] 101/18
119/4
sufficient [4] 5/1
20/18 128/13 131/15
sufficiently [4] 46/2
78/7 95/23 130/15
suggest [4] 57/16
69/5 77/14 110/24
suggested [6] 25/1
42/23 45/18 91/18
152/25 154/14
suggesting [2] 7/25
85/3
suggestion [4] 28/10
53/2 56/8 186/19
suggestions [1] 39/9
suggests [5] 31/4
43/13 48/13 86/12
163/12
suicide [1] 57/23
suitable [3] 118/16
118/20 120/8
suits [1] 13/3
suits’ [1] 10/22
sum [1] 92/25
summarily [1] 185/5
summarised [1]
168/22
summary [7] 45/20
129/3 129/4 140/6
148/3 166/2 174/13
summer [1] 16/4

sums [3] 105/3 161/1
192/2
supermarkets [3]
22/15 70/6 71/4
supervising [1]
66/24
supervisory [1]
73/12
supplement [1]
172/21
supplemental [1]
79/23
supplied [1] 50/17
suppliers [1] 22/14
supply [1] 127/19
support [6] 40/7 42/7
60/2 90/12 98/11
118/10
supported [1] 125/22
supporting [2] 96/13
148/5,
supportive [1]
152/19
suppose [3] 56/7
67/7 175/18
supposed [2] 66/23
193/11
sure [22] 37/18 37/22
39/15 41/12 47/15
50/24 54/2 57/8 74/6
80/6 82/11 83/23
125/6 132/24 137/13
148/24 154/15 168/11
169/1 170/1 171/22
182/21
surely [1] 34/25
surfaced [1] 66/9
surfacing [1] 67/2
surgeries [1] 33/15
surprise [1] 138/15
surprised [3] 34/4
147/13 148/7
surprises [1] 127/11
Survey [1] 194/11
survive [1] 91/10
Susan [2] 97/25 98/1
susceptibility [1]
82/9
suspect [5] 133/24
156/5 163/4 197/5
197/6
suspecting [1] 181/4
suspended [1] 109/9
suspension [3] 119/6I
135/19 136/7
sustaining [1] 132/22)
swamped [1] 92/4
swift [2] 176/5
200/17
swiftly [1] 52/21
Swinson [10] 5/14
37/16 39/1 43/25 94/8)
94/20 94/24 96/13
98/20 199/25

Swinson's [3] 4/5
22/18 95/6
sworn [4] 1/6 114/25
204/3 204/14
system [41] 7/11
9/17 19/5 19/13 19/21
28/4 28/6 28/11 31/5
31/10 33/1 33/15 34/1
40/2 40/3 40/8 43/13
52/17 52/24 56/14
57/10 65/17 81/3
81/10 83/12 84/1 84/2
84/24 85/7 88/7
101/21 101/22 102/7
102/13 103/11 113/23
127/25 131/16 134/16}
138/5 170/5
system-wide [2]
52/17 52/24
systemic [9] 33/8
43/12 56/16 64/8
78/17 86/9 98/10
128/3 129/21
systems [18] 58/5
72/5 72/10 73/1 81/8
81/9 81/15 83/2 83/5
84/10 84/17 84/25
98/11 126/12 129/2
134/3 143/2 144/5

T

table [4] 55/3 55/7
183/22 185/13
tabled [2] 43/24
166/5
tactical [7] 152/8
152/14 152/22 152/23}
153/8 153/11 153/15
take [39] 31/18 38/17
39/10 42/1 42/23
44/11 46/21 48/14
49/4 62/24 73/3 75/25
77/4 77/16 78/1 83/24
92/21 96/5 97/12 98/4]
100/23 109/14 116/20}
119/22 120/13 121/16
121/24 133/21 136/24
154/14 165/15 167/9
175/25 176/19 181/14
183/13 184/19 189/15]
193/3
taken [20] 11/10
13/14 20/9 33/1 70/6
79/6 92/22 97/5
102/16 106/25 143/19]
143/24 157/14 157/17I
162/6 166/18 182/3
185/12 188/8 188/9
takes [3] 118/24
162/4 186/24
taking [17] 6/7 12/6
14/4 36/23 37/5 82/16
131/2 132/2 166/14
169/5 175/4 175/21

178/25 179/1 180/1
184/8 203/5
talk [15] 33/16 34/8
54/5 60/10 60/10
60/14 60/18 61/6
75/22 119/21 124/14
125/6 126/17 192/5
194/13
talked [3] 5/6 60/22
87/5
talking [8] 75/23
87/22 129/14 158/15
189/6 194/10 198/18
199/21
talks [2] 98/14 194/7
tangle [1] 198/2
task [1] 82/16
taste [1] 164/14
taxpayer [1] 126/25
taxpayer's [1] 74/6
team [8] 62/13
122/23 123/17 125/22)
172/24 173/2 175/8
183/11
Team's [1] 66/25
technical [2] 22/11
90/3
technically [1]
130/22
technology [4] 72/8
72/9 73/5 201/17
tell [17] 6/1 6/12 8/10
30/20 47/7 49/12
65/23 66/4 66/19 67/4
78/10 78/18 109/25
113/21 153/20 155/2
187/3
telling [2] 9/22 60/1
ten [3] 46/13 170/23
171/18
tend [1] 145/23
tended [1] 12/24
tension [4] 124/10
124/13 124/15 124/17)
tenure [2] 123/24
127/12
term [7] 52/25 88/6
93/1 93/5 108/21
127/17 173/7
terminated [1] 106/8
terms [24] 29/19 31/7I
71/7 74/4 74/5 105/11
124/23 139/5 150/6
155/1 164/8 183/21
184/5 184/7 186/12
187/8 187/24 188/13
188/24 191/21 192/3
194/17 197/25 203/1
terrible [2] 104/7
104/21
test [1] 40/19
tested [3] 130/23
138/23 139/24
testing [3] 20/22

20/23 30/15
text [1] 39/20
than [32] 1/13 1/14
40/9 45/5 46/17 56/22)
59/12 61/20 71/6
74/24 79/12 84/21
91/6 92/25 122/8
123/21 125/7 126/23
129/9 133/12 134/10
135/7 148/11 153/16
153/23 173/4 180/9
190/12 197/8 197/11
197/13 198/17
thank [65] 1/4 1/12
1/17 2/3 8/10 9/19
13/23 26/6 30/24
46/24 47/5 47/6 55/15I
65/22 71/24 71/25
73/8 77/10 77/12
7717 77/18 77/19
78/3 79/22 88/9 88/11
99/17 114/5 114/10
114/14 114/17 114/22)
114/23 115/2 115/5
115/18 117/10 119/24)
121/21 123/1 127/1
139/3 140/1 141/20
147/4 149/5 151/8
158/4 165/14 165/23
165/24 167/7 169/18
180/3 186/3 187/20
189/13 201/8 202/13
202/18 202/24 203/3
203/4 203/6 203/14
thanking [2] 16/8
31/1
Thanks [4] 39/11
1414/7 150/17 161/1
that [1204]
that I [1] 58/7
that's [65] 2/8 8/20
11/4 21/7 25/5 34/1
38/8 42/21 44/13
49/18 58/24 59/25
67/20 71/23 83/19
90/18 90/19 92/6
94/16 95/1 95/5 95/19I
95/20 96/10 100/14
104/15 107/2 111/3
111/12 115/11 115/23}
116/2 116/10 116/14
116/16 117/14 119/15)
121/11 125/12 125/25]
132/11 137/1 138/24
140/14 148/3 149/16
151/14 155/5 155/24
158/25 167/16 168/18}
168/20 174/4 175/16
184/14 188/19 189/24)
190/5 193/13 195/8
197/9 198/11 203/9
203/12
theft [3] 48/9 48/9
106/16

(62) substantial... - theft
T

their [82] 7/24 8/13
12/25 20/5 20/11 26/1
30/10 30/17 32/16
34/14 37/9 40/15
40/20 42/9 44/20 50/6)
52/21 53/7 54/15
56/21 58/18 63/10
63/15 63/24 66/16
73/5 73/13 73/19
77/23 78/11 78/19
78/23 79/2 79/14
79/21 80/5 83/12
87/18 98/8 98/16
101/20 102/19 103/4
103/12 105/22 106/14
108/12 108/12 111/11
120/7 120/9 124/2
131/11 137/16 137/25
138/5 153/6 160/2
161/14 162/2 162/18
163/22 170/9 170/11
171/10 173/5 173/24
174/10 176/13 177/14}
178/10 178/17 179/7
180/8 188/4 191/14
192/3 192/11 193/22
199/8 199/20 202/21

theirs [2] 103/7 106/1

them [88] 3/7 4/19
5/5 5/23 8/4 8/9 10/22
11/19 12/25 13/2 13/4)
13/19 13/25 16/21
16/25 17/21 18/19
18/24 18/24 20/7
20/19 21/18 21/19
29/21 32/21 32/22
35/10 38/7 44/17
47/14 49/10 49/11
49/17 53/18 55/6
60/10 60/22 61/6 61/7
61/8 61/13 68/5 68/18
69/12 74/9 76/24
77/11 86/13 86/20
87/10 93/19 93/19
93/23 94/1 94/2 94/3
96/18 101/23 101/24
104/21 107/24 108/1
112/16 113/15 113/21
113/21 122/25 124/2
134/21 138/2 143/6
147/13 157/1 171/22
177/11 177/17 178/7
181/3 181/5 181/24
183/20 184/18 187/3
190/19 193/25 194/6
194/14 197/14

theme [1] 45/5

themselves [4] 67/24
103/6 105/25 137/4

then [82] 2/11 2/15
9/7 10/9 10/16 14/24
15/3 15/19 21/1 21/17)

23/7 23/8 23/18 28/2
31/22 36/11 38/20
48/10 49/10 52/12
55/13 56/12 56/19
58/19 78/13 79/24
79/24 88/22 88/23
89/1 90/22 93/4 94/4
98/14 99/15 102/19
102/22 106/6 106/10
107/11 111/15 111/19)
113/16 118/22 123/2
123/17 125/4 125/18
127/20 135/22 136/2
140/25 143/15 144/10)
144/15 146/1 146/6
147/4 147/19 151/13
152/3 153/25 154/21
155/6 156/14 159/3
161/18 164/23 168/9
174/3 174/15 174/16
175/21 179/11 195/12)
196/1 196/5 196/7
197/13 201/24 203/11
203/13
theory [2] 12/10
104/25
there [275]
there'd [5] 35/25
149/2 149/23 149/24
150/2
there's [29] 11/8 36/3
44/24 51/1 56/12
57/16 77/24 104/1
109/17 112/23 130/9
132/25 133/19 141/24}
148/13 152/2 158/2
167/18 167/22 177/19)
178/4 181/10 181/25
182/1 191/5 192/4
193/15 194/2 197/22
thereafter [3] 12/24
21/9 133/3
therefore [10] 15/12
98/17 124/4 126/13
130/25 132/16 134/5
141/4 144/6 144/16
Theresa [1] 116/15
these [77] 12/1 12/5
12/7 14/2 18/18 20/5
26/19 31/5 31/12
35/19 40/5 40/12
42/14 47/16 48/12
49/18 54/17 55/3 60/9
64/4 65/15 66/25 67/2
71/2 74/14 75/25 78/9)
83/16 86/8 87/25
98/13 100/12 101/2
101/14 102/20 103/13)
103/21 104/20 106/17)
106/17 106/22 107/19)
107/21 107/23 112/20)
113/20 118/11 120/7
125/10 130/17 130/21
133/11 134/1 138/9

138/12 139/23 141/14]
142/10 151/9 156/22
160/12 163/6 164/24
165/13 166/19 176/21
179/13 183/18 183/22]
183/25 186/13 189/5
190/7 194/9 194/10
201/12 201/25

they [188] 2/1 3/18
4/25 5/2 57 5/7 5/18
6/16 10/6 10/7 10/15
12/14 12/20 17/21
19/22 20/24 24/4
25/10 25/24 29/22
29/25 30/23 31/21
31/25 33/18 34/21
34/24 34/24 35/1 35/8
35/12 35/13 36/21
36/22 37/4 41/16
41/17 41/24 41/24
42/23 46/2 47/17 48/3
49/9 49/20 49/22 50/7
54/13 57/15 57/15
58/5 58/12 61/12 62/3
63/15 67/14 67/23
68/23 71/21 76/23
79/17 82/20 82/21
87/13 87/14 87/24
88/7 89/20 90/1 90/4
91/22 93/14 94/5
96/13 96/14 96/22
96/24 96/25 97/12
98/6 98/9 98/15 98/15
98/16 99/12 101/10
101/114 101/18 101/20
101/21 102/1 102/2
102/24 102/25 103/1
103/12 104/25 105/5
105/9 105/20 106/15
107/5 107/7 107/8
107/9 107/24 108/5
108/10 109/23 111/11
114/3 114/6 121/9
124/15 127/9 129/23
130/22 131/21 131/25I
133/9 136/21 136/24
137/3 137/14 138/4
138/15 147/7 152/10
152/24 153/21 154/9
154/15 155/8 157/5
157/6 157/10 157/12
157/13 157/20 157/20
158/1 158/9 160/17
163/1 165/3 165/6
166/14 170/15 171/20
171/25 174/9 174/10
174/13 174/16 175/4
175/8 176/19 176/20
17/4 177/41 177/15
177/18 178/9 178/21
181/4 182/8 182/9
182/21 183/22 183/23
184/8 184/12 186/10
188/10 188/23 190/1

190/19 191/13 191/15}
192/11 194/13 194/14}
195/2 199/20 200/4
200/13 202/3 202/7
they'd [7] 54/12
83/11 86/16 86/24
157/5 163/21 163/24
they're [7] 76/20
111/10 162/23 181/7
193/18 194/12 197/2
they've [3] 104/22
113/22 121/17
thin [1] 182/10
thing [17] 13/9 27/9
31/7 33/5 99/7 103/24
124/25 125/25 137/6
161/10 167/2 168/17
169/1 173/17 178/4
187/13 194/23
things [29] 3/5 4/23
5/14 7/12 9/5 47/24
66/7 71/1 101/11
103/12 104/7 113/11
122/19 123/23 126/14}
134/10 141/14 150/2
163/6 165/6 176/17
176/21 185/4 192/9
192/13 198/13 199/7
199/8 201/16
think [286]
thinking [4] 66/1
75/11 87/15 104/15
thinks [1] 192/16
third [8] 21/17 21/19
26/7 38/2 84/8 85/5
90/7 138/11
thirdly [4] 10/9
this [425]
Thompson [2] 62/12
63/3
Thomson [12] 54/2
54/4 116/24 117/2
117/18 117/20 118/6
120/25 121/7 121/12
121/13 133/22
Thomson's [2]
118/19 120/14
thorn [1] 99/24
thoroughly [3] 118/8
120/14 138/9
those [47] 1/12 9/5
13/4 16/8 20/20 33/22,
42/2 47/13 52/20 57/9)
63/17 64/17 65/1 71/8
71/8 77/10 79/23
81/18 86/1 88/9 89/3
89/7 93/13 94/2 95/14
99/17 100/18 112/10
112/11 132/6 133/14
136/3 137/8 137/12
140/13 150/3 154/5
177/6 181/18 183/15
183/17 186/4 186/20
188/22 188/23 190/21

191/20
though [18] 5/23

15/24 16/3 29/8 67/1

70/14 90/25 91/25

110/18 110/21 118/18}

123/13 128/10 150/19)

164/13 174/22 181/16)

187/14
thought [30] 22/20

24/20 25/4 37/7 39/7
41/9 41/21 42/11 45/4)
49/25 72/24 74/13

76/25 96/14 101/11

110/2 121/5 121/17

128/19 134/8 153/23

163/15 164/7 166/17

166/24 184/16 191/1

192/22 198/17 198/18)
thoughts [2] 69/12

176/13
thousands [2]

127/12 170/24
thrash [1] 65/15
threads [1] 10/25
threat [2] 6/23

180/13
threatening [1] 96/2
three [12] 21/15
25/14 46/10 67/15
88/17 89/3 89/7 93/22
96/8 109/9 127/12

171/18
through [40] 13/20
24/6 24/7 33/14 40/18)
48/12 49/11 52/15
52/18 53/1 56/17 61/5I
61/9 72/13 72/16
74/13 76/15 76/25

100/3 103/16 104/2

104/3 107/21 108/13
109/11 111/14 112/7
120/15 124/6 124/25
125/3 130/12 131/2
133/17 155/19 168/7
173/4 175/17 184/7
193/11
throughout [9] 12/7
29/10 87/2 127/5
141/3 162/13 167/21
181/20 188/10
throwing [1] 191/15
thugs [1] 13/3
Thursday [1] 1/1
thus [1] 143/19
tier [1] 75/20
Tim [4] 158/13 166/9
166/17 166/21
time [110] 4/24 9/13
9/17 13/21 14/18
18/22 18/23 20/6 20/9}
20/11 22/18 22/18
25/10 25/13 28/3 28/7I
32/10 36/17 37/16
37/24 38/18 45/1 48/8

(83) their - time
T

time... [87] 51/20
53/4 54/19 55/5 55/8
57/11 58/6 58/6 62/22
64/24 65/14 65/20
66/1 66/5 66/17 67/6
67/13 68/23 75/8
83/10 83/18 85/18
86/7 87/8 87/22 89/9
89/23 90/22 91/23
91/25 92/1 92/15
93/18 101/1 101/8
103/8 108/14 108/16
111/14 112/23 113/6
113/6 113/7 114/2
116/18 117/9 117/17
119/5 119/9 119/17
122/9 122/13 123/14
123/21 125/13 129/10
132/1 133/2 134/18
135/8 136/23 136/23
137/22 137/22 138/24}
139/1 140/11 149/19
149/25 150/3 150/25
151/11 162/9 164/1
168/8 171/11 171/25
177/2 177/20 179/20
184/22 186/9 189/18
191/19 193/23 194/8
201/24

times [3] 34/24 36/5
131/19

timing [3] 94/25
111/18 137/13
timings [1] 145/10
‘oe [1] 182/13
tiptoeing [1] 125/10
today [12] 1/13 47/22
63/12 63/24 116/11
160/7 161/6 161/17
164/20 166/5 171/17
175/25

together [9] 10/25
14/20 33/3 65/13
66/23 80/3 86/8
179/20 195/2

told [32] 6/5 7/20
7/22 7/24 8/1 8/8 10/6
14/5 18/18 19/12
19/15 27/9 31/20
36/15 37/4 37/12
47/22 48/11 53/7
53/11 59/10 64/10
68/4 85/16 93/23 97/8
102/24 107/15 114/2
117/21 157/1 168/13
Tolhurst [8] 146/1
151/11 162/13 162/22)
167/1 175/5 187/2
200/1

Tolhurst's [2] 151/22
163/19

Tom [18] 141/15

151/16 151/17 152/2
152/5 152/7 156/15
157/8 157/15 158/7
158/9 161/18 162/2
164/12 165/10 167/10)
168/16 168/25
tomorrow [5] 63/8
98/15 158/13 203/7
203/13

tone [7] 156/8 173/7
173/12 173/17 175/2
175/10 188/15
tonight [1] 43/7
too [6] 4/13 4/14
58/19 99/14 149/14
187/23

took [22] 9/13 9/20
11/18 13/22 17/7
22/18 25/13 35/12
35/13 45/9 46/13
81/14 85/14 121/21
122/9 140/18 147/2
153/21 167/12 169/19)
179/20 193/14

tool [2] 54/10 54/10
top [9] 26/7 58/23
59/1 61/5 69/6 80/18
89/20 183/21 183/25
topical [1] 4/17
Tory [1] 40/4

total [3] 68/21 109/3
113/24

totally [4] 18/18
51/17 87/11 137/19
touch [2] 102/22
106/10

touched [1] 101/3
towards [3] 62/8 95/7,
139/5

town [1] 60/12
trade [8] 2/12 17/6
54/14 80/23 96/1
102/21 107/5 108/7
train [3] 170/21
179/23 186/18
training [4] 2/6 40/7
42/7 87/15
transaction [1] 95/7
transactions [4]
56/25 57/5 57/17
105/4

transcript [1] 81/21
transformation [7]
54/6 67/20 88/19 89/8)
101/4 101/8 103/22
transition [3] 6/7
110/9 110/13
Transparency [1]
39/9

transparent [2] 41/17
45/4

Treasury [14] 91/3
91/12 91/19 92/2 92/3)
92/13 93/1 93/16

116/3 178/9 195/1
195/11 196/22 196/23
treated [7] 11/6
135/2 135/3 155/7
155/8 171/13 176/7
treatment [3] 76/1
142/10 173/16
trespassing [1]
188/12

Trevelyan [1] 169/22
trial [18] 141/21
141/22 146/14 147/9
170/2 170/5 173/8
173/9 173/22 174/11
174/20 180/8 180/9
187/17 187/21 188/8
188/14 189/11

trials [2] 137/12
147/5

tried [7] 65/10 69/20
70/4 84/18 104/4
189/22 201/12
trivial [3] 149/16
194/7 200/8
troubles [1] 57/8
true [6] 1/24 2/1
30/13 107/22 115/15
171/12

trust [7] 20/13 20/17
30/22 34/21 39/9
133/20 145/15
trusted [2] 12/25
134/1

trustee [1] 199/6
Trusts [1] 76/10
truth [5] 48/15 59/16
131/1 134/21 135/7
try [3] 109/13 148/12
161/5

trying [8] 30/8 58/3
71/17 79/3 84/15
93/11 104/23 119/20
Tuesday [4] 162/20
162/21 163/11 167/1
turn [37] 5/10 9/10
13/22 15/6 21/13
36/11 36/12 40/16
42/9 58/22 69/7 78/3
89/18 94/4 113/18
115/10 117/15 117/23
132/9 135/8 138/25
139/15 141/7 144/21
150/11 158/4 158/5
159/6 165/25 169/18
172/8 175/23 183/2
185/14 186/2 186/19
189/14

turnaround [1]
132/21

turned [3] 3/8 84/22
187/6

turning [1] 53/15
turnover [2] 3/15
3/18

Twickenham [3]
13/10 24/11 112/16
two [33] 23/2 28/9
46/10 52/18 53/1
56/13 58/23 67/5
67/15 75/20 78/14
91/17 101/1 102/12
108/13 109/20 111/15]
113/14 120/2 128/1
129/23 130/23 131/19}
135/12 137/21 146/3
153/14 158/4 163/22
170/9 175/7 177/2
188/23

two-tier [1] 75/20
tying [2] 98/24
162/23

type [4] 23/24 77/8
100/19 192/7

types [1] 125/17
typical [2] 122/6
122/8

typically [4] 103/1
106/7 106/13 106/17

U

UK [1] 70/17

UKGI [59] 15/12
122/20 122/20 123/7
123/9 123/13 123/20
124/4 124/18 135/14
139/10 140/24 143/9
144/18 145/16 148/3
148/5 148/11 148/13
148/18 149/1 151/16
158/6 163/16 167/12
168/3 168/20 169/12
179/2 190/2 191/12
191/17 192/5 192/6
192/10 193/16 193/17
193/20 193/23 194/3
195/10 195/13 195/15
195/17 195/18 195/19
195/23 196/4 196/18
197/19 197/25 198/2
199/21 199/25 200/9
200/15 200/19 200/23
201/6

UKGI's [1] 148/24
UKGI00001679 [1]
94/21

UKG100003781 [1]
47/19
UKG100003910 [1]
51/23
UKG100004225 [1]
63/1

UKG100007712 [1]
135/9
UKG100007733 [1]
138/25
UKG100009076 [1]
141/8
UKG100009137 [1]

144/21
UKGI00009213 [1]
150/11
UKGI00009296 [1]
158/5
UKGI00009308 [1]
159/7
UKGI00009464 [1]
169/18
UKGI00010205 [1]
185/17
UKGI00013690 [2]
16/6 37/25
UKGI00013863 [1]
26/5
UKGI00014038 [1]
30/24
UKGI00017461 [1]
195/8
UKGI00019389 [2]
38/20 42/25
UKGI00019390 [1]
39/19

ultimately [6] 20/14
24/24 93/17 120/11
167/14 181/16
unable [2] 62/24
127/13
unambiguous [2]
162/12 163/16
unbelievable [1]
181/9

unclear [2] 153/1
191/6
unconscionable [1]
137/20
uncontroversial [1]
6/17

uncovered [2]
147/14 148/8

under [15] 4/2 31/24
41/20 45/14 56/14
62/23 76/5 91/13
94/21 106/9 113/24
127/22 138/17 195/8
196/10
underpinning [2]
73/16 75/15
understand [30] 3/24)
15/11 28/3 32/10 52/6)
57/10 58/4 58/10
59/13 59/23 64/2 72/4
85/4 98/6 103/19
104/24 109/13 110/12)
110/14 117/4 127/8
154/9 161/14 161/16
161/25 169/9 171/7
173/11 196/17 197/5
understand/get [1]
3/24
understandable [4]
4/7 67/17 67/20 105/4I
understanding [19]
21/25 30/10 32/12

(84) time... - understanding
U

understanding... [16]
53/7 60/21 73/1 105/7,
120/22 120/24 120/25}
124/21 166/22 170/10
194/24 194/25 195/7
195/16 196/17 197/1
understands [1] 1/16
understatement [1]
154/7
understood [4] 19/22
55/25 64/25 168/11
undertaken [3] 6/22
19/7 127/25
undertaking [1]
37/11
undesirable [1]
58/13
unemployed [1]
109/19
unequal [2] 69/14
90/10
unexpected [1]
173/22
unexplained [1]
40/14
unfair [5] 40/9 42/7
90/10 147/3 153/18
unfairly [1] 176/7
unfairness [1]
173/16
unfold [1] 160/17
unfolding [1] 6/20
unfortunate [1] 61/14]
unfortunately [6]
23/3 81/22 84/24
110/4 163/6 177/5
unhappiness [1]
22/6
unhelpful [1] 152/10
unilateral [1] 133/21
union [8] 53/9 53/12
54/8 54/14 96/1
107/12 107/13 108/7
Unique [1] 115/18
unit [4] 17/22 24/3
27/3 99/9
unitary [2] 124/20
200/6
Universities [1]
116/7
university [1] 2/9
unjustified [1] 10/7
unless [4] 89/14
93/15 187/14 202/15
unlike [1] 23/2
unlikely [5] 143/12
143/13 143/16 166/17)
166/22
unreasonable [1]
29/21
unreliable [3] 40/7
42/6 137/12

unresolved [1] 59/14
unsafety [1] 193/4
unsigned [2] 15/9
135/12
unsubstantiated [1]
63/14
unsuccessful [1]
159/17
until [20] 8/2 14/23
46/22 50/13 55/6
56/11 59/17 77/15
80/22 85/17 109/20
111/25 131/20 140/8
147/6 147/7 166/25
180/10 200/20 203/16
untruthfully [4] 48/11
untypical [1] 122/15
unusual [3] 4/1 4/5
202/6
up [77] 2/4 3/8 4/20
5/10 9/10 9/11 9/14
9/20 11/12 13/22 15/6
19/8 21/8 21/14 22/22
24/23 25/6 27/2 33/14
34/1 37/3 40/1 41/15
42/12 42/17 43/8
46/14 48/18 56/9 64/5)
70/7 70/10 71/2 72/21
78/3 80/16 81/14
88/16 89/3 94/10
96/13 97/20 98/1 98/7
101/7 103/24 107/14
110/7 116/19 121/3
121/11 129/9 131/19
139/18 139/20 146/16)
151/24 159/1 159/8
160/24 161/1 161/2
163/20 164/18 175/3
175/6 177/3 177/13
177/17 179/25 187/22)
188/19 188/21 189/6
193/22 197/10 197/14I
update [4] 62/22
130/13 140/11 166/20)
updated [3] 131/9
131/11 156/10
updates [5] 130/6
131/5 140/10 140/13
172/10
uploaded [1] 115/19
upon [5] 21/15 50/21
101/4 109/8 152/20
upwards [1] 108/4
urgent [3] 43/24
62/24 155/15
us [31] 1/3 1/10 6/12
8/10 9/23 10/23 47/4
A7IT 49/12 57/9 65/23
66/4 66/19 67/4 77/16
96/25 103/19 122/16
149/9 151/8 152/14
162/8 170/25 171/13
190/15 190/18 190/19
191/8 191/10 191/14

191/15

use [5] 21/8 56/20
101/23 146/17 152/21
used [7] 51/14 138/6
139/8 143/25 146/21
184/15 202/25
useful [3] 29/17 73/7
107/9

users [2] 56/24 57/4
using [2] 58/25
198/23

usual [1] 1/14
usually [6] 1/13 6/16
10/14 46/14 176/16
190/14

Vv
valid [1] 178/23
validated [1] 20/8
validating [1] 72/9
value [1] 192/3
values [1] 195/24
van [2] 119/25 121/4
variant [1] 162/2
variation [1] 111/12
variety [4] 6/10 44/10
69/20 75/21
various [6] 65/12
103/2 127/16 178/2
186/6 190/6
vary [1] 103/1
varying [1] 189/22
vast [5] 4/15 8/6
25/20 56/20 105/3
vehicle [2] 198/23
202/25
Vennells [10] 5/21
25/1 32/3 66/22 68/3
117/19 125/22 132/11
133/4 200/23
Vennells' [1] 97/2
ventures [1] 192/2
verbatim [1] 164/10
verdict [1] 149/13
version [3] 15/23
16/24 135/12
versions [2] 29/21
135/13
versus [2] 57/4
190/19
very [109] 1/4 1/17
2/3 4/7 5/3 5/4 6/17
8/15 11/23 12/24
13/17 15/3 17/13
17/24 17/24 19/22
24/3 24/11 24/19
25/17 28/25 30/4
31/19 31/25 33/11
34/4 36/21 37/13 43/9
43/16 45/24 46/12
46/24 47/25 51/5
60/13 60/16 60/16
68/5 72/25 75/23 76/1
76/23 77/4 77/17

77/18 79/7 79/7 79/22
88/9 89/19 90/4 90/9
92/2 94/2 99/20 100/9)
100/24 104/22 105/14}
105/15 105/17 108/2
114/10 114/13 114/14}
114/17 115/2 115/18
117/10 119/24 121/21
135/6 139/5 140/4
140/15 144/10 144/12)
150/7 152/17 153/12
153/13 162/10 168/17,
170/2 170/20 174/23
175/11 178/5 181/6
182/7 183/17 184/2
187/16 187/18 191/10
193/2 193/20 197/17
198/2 198/15 199/13
199/21 200/13 201/2
201/8 202/13 202/18
203/14
via [2] 179/9 191/14
view [73] 12/25 33/14]
33/24 36/2 44/24 50/3)
50/11 53/14 54/24
60/5 73/7 88/20 88/23
98/6 99/11 105/10
118/24 119/8 120/8
120/9 121/1 121/19
124/16 125/6 126/8
126/9 126/20 128/14
129/16 130/19 130/20}
130/20 133/11 133/14}
133/15 134/2 134/3
134/6 144/7 145/11
145/15 145/16 145/20)
146/23 147/2 148/17
149/2 149/19 159/9
159/22 161/1 161/11
162/8 162/12 162/14
162/25 163/17 163/18
163/19 165/1 165/13
168/2 169/6 169/14
169/16 182/19 185/12)
190/7 191/18 192/25
193/3 193/14 193/20
views [10] 13/4 53/16
68/5 142/14 142/16
171/24 171/25 190/21
191/10 192/11
vigorously [1] 170/7
village's [1] 135/19
Vince [31] 1/5 1/8
1/15 18/8 35/2 39/7
47/7 57/19 61/17
71/14 77/10 80/2
80/19 81/21 85/2 88/9
88/13 95/4 95/15
97/10 99/19 100/6
106/20 109/12 110/12
113/19 114/1 114/5
114/10 127/7 171/17
VINCENT [3] 1/6 1/11
204/2

visit [1] 37/2

visited [2] 104/17
104/18

visits [1] 17/5

vocal [1] 59/2

voice [5] 1/13 66/14
123/10 123/15 124/11
volume [2] 26/3
68/18

voluntarily [1]

177/16

voluntary [1] 120/10
vote [2] 165/11 168/4

Ww

wade [1] 98/4
wait [2] 157/6 189/3
waited [1] 157/5
walked [1] 34/23
Wallis [1] 64/6
want [30] 10/14
22/12 30/12 33/12
44/19 50/7 50/10
67/18 75/19 80/9
80/15 81/5 81/13
98/16 121/16 139/15
147/8 158/13 158/20
158/20 160/11 160/18)
163/25 164/24 169/16
178/21 183/21 191/8
191/16 193/24
wanted [18] 10/7
17/15 37/2 50/8 53/4
60/18 92/15 94/1
97/12 138/22 145/15
149/15 151/3 169/17
176/19 179/24 186/16
195/2
wanting [2] 66/12
169/13
warned [1] 45/8
warning [1] 182/2
wary [1] 192/11
was [780]
wasn't [54] 4/7 8/4
14/1 14/12 19/14
19/17 19/19 20/11
20/12 20/25 24/12
25/19 28/20 30/5
34/17 35/20 41/13
42/15 45/15 46/3
49/24 53/12 56/2 56/4)
56/5 60/4 61/3 75/9
77/2 79/8 83/14 85/17
89/14 90/13 90/25
93/2 96/6 97/15 100/3
105/16 110/20 111/21
111/25 113/16 129/5
129/25 135/16 148/21
151/18 152/25 153/1
153/19 167/5 167/25
wasted [1] 191/24
watch [1] 8/20
watched [2] 79/12

(85) ui

inderstanding... - watched
Ww

watched... [1] 201/8
watches [1] 8/13
watching [2] 1/12
33/22
water [1] 44/9
Watson [5] 158/7
159/3 160/24 160/25
161/3
way [67] 6/17 10/24
11/2 11/6 14/13 18/20}
22/6 22/23 24/2 28/15
32/5 32/12 34/9 34/22
40/5 40/18 41/5 41/8
42/5 42/13 42/21
42/21 43/21 46/11
50/25 56/11 61/5
61/19 62/3 62/23
65/21 66/14 72/10
93/14 95/17 99/4
99/12 99/13 104/14
105/8 110/4 110/8
110/23 113/2 113/18
125/12 130/23 134/10}
135/2 135/3 137/9
145/4 153/19 154/4
173/18 174/1 178/5
182/13 183/24 184/6
188/15 194/9 196/25
198/11 199/7 200/6
201/10
ways [5] 35/14 44/10
129/10 186/25 191/2
we [300]
we can [1] 98/4
we'd [2] 27/4 44/14
we'll [7] 16/22 42/2
106/10 119/21 125/6
126/16 130/14
we're [10] 42/19
75/23 104/13 111/5
111/14 111/18 114/23}
117/15 122/5 199/21
we've [15] 3/16 17/13)
32/20 58/9 62/3 87/5
103/8 104/9 107/20
125/25 145/11 186/13)
189/6 194/18 198/18
weaker [1] 69/17
weapons [1] 51/13
website [1] 115/20
Wednesday [2] 52/2
95/5
week [9] 34/2 52/2
59/4 124/5 141/23
145/18 162/15 176/13
184/23
weekend [3] 151/21
161/16 166/7
weekly [12] 7/23
19/14 58/17 58/24
59/4 59/10 124/1
130/6 131/13 145/17

176/21 177/7
weeks [6] 60/17
177/3 184/24 187/10
187/11 194/1
weeks' [1] 186/9
weight [1] 60/21
welcome [1] 134/6
welfare [1] 74/8
well [132] 3/15 4/15
TI17 8/7 8/25 13/5
13/6 14/12 14/19 15/3
18/14 19/10 20/4
20/23 22/3 24/1 25/19
28/15 28/25 29/6
29/16 30/3 30/16
32/12 33/6 33/24
34/16 34/20 35/20
36/5 36/20 36/21
37/12 40/24 41/1 41/9)
42/11 44/25 45/16
45/16 46/6 46/10 50/5
50/24 53/3 53/20
54/19 58/14 60/16
61/20 62/5 62/5 65/6
66/7 67/7 68/18 69/25)
70/5 70/25 75/1 75/19
76/14 85/12 86/3
87/21 88/4 89/5 90/15)
93/7 93/13 95/19
96/16 97/18 99/8
105/17 107/3 108/24
109/19 110/20 111/5
111/22 111/25 113/1
113/10 114/10 123/17)
126/6 128/14 129/5
130/17 131/17 133/15)
133/16 134/25 135/14)
136/22 139/13 140/7
142/16 143/16 144/2
146/22 148/9 149/11
153/4 153/11 156/4
157/17 168/7 168/16
168/23 171/22 172/21
173/13 176/12 177/2
180/24 182/18 183/18)
186/12 186/24 188/12)
188/24 190/22 193/21
197/19 197/19 198/17)
199/12 199/17 199/19)
199/20
went [9] 12/18 58/18
82/15 129/23 134/21
148/23 155/20 164/12)
202/17
were [305]
weren't [10] 5/18 9/3
25/10 27/1 30/8 34/19
65/3 93/14 140/23
188/23
what [160] 5/19 7/21
8/23 12/12 13/3 13/5
13/7 14/4 14/22 19/6
19/8 19/22 19/25
21/25 22/11 23/12

24/24 25/1 26/19
26/20 27/7 28/12 29/4
29/12 30/11 30/16
30/21 31/6 31/20
32/10 33/12 33/22
36/22 37/4 37/15
39/10 41/6 41/9 44/11
44/13 44/23 45/6 46/1
46/14 47/13 47/25
50/21 50/22 51/4
54/13 55/7 55/25 60/1
60/8 61/16 61/19
65/19 66/4 66/11 67/4
69/10 69/23 70/23
71/17 71/23 74/20
76/12 82/21 84/4
93/17 93/25 94/5 94/9
96/11 97/14 97/19
99/15 100/4 100/14
102/9 103/6 104/11
105/1 105/17 105/19
106/1 107/22 107/24
108/20 109/13 109/16
109/25 111/4 112/2
112/19 112/21 114/1
120/22 124/5 126/11
127/5 128/19 130/18
131/19 134/19 134/21
136/18 137/7 137/10
137/22 138/24 139/19}
139/21 139/22 140/13
141/1 141/5 146/22
152/21 153/20 154/7
162/8 162/23 162/25
163/9 164/2 164/10
164/12 164/13 164/17
165/6 165/12 168/10
170/16 171/7 173/11
175/11 175/12 176/9
176/14 177/11 177/20
178/10 179/16 179/18
181/4 182/19 183/20
184/2 186/23 187/3
188/19 188/21 189/9
193/1 193/9 193/20
196/8 198/18 201/1
what's [5] 23/19
30/13 40/25 50/25
104/9
whatever [5] 17/6
35/7 54/15 108/11
133/23
whatsoever [1]
166/25
wheel [1] 110/4
when [101] 6/8 6/16
7/2 8/3 8/22 9/13 10/2
10/4 10/17 10/24 12/1
12/17 13/5 13/7 13/15
13/22 13/23 14/9
14/19 14/25 15/4 18/8
19/11 24/14 25/2
26/25 27/8 29/1 31/20
32/2 36/18 37/1 37/10

37/12 49/2 49/18
51/12 54/1 54/23
58/12 58/15 60/2
67/14 68/19 71/6
73/11 73/17 75/22
76/23 81/7 82/8 83/8
85/20 87/8 87/22
89/19 90/8 91/1 91/6
91/13 92/16 98/15
100/3 102/11 102/25
103/4 105/9 105/20
105/22 105/24 107/9
109/13 109/14 109/22}
109/24 111/22 112/5
112/24 113/2 126/4
126/18 126/24 127/13
131/5 136/9 146/9
146/23 150/25 156/1
156/7 157/20 164/18
172/2 172/3 185/25
186/24 190/19 190/22}
191/12 194/18 199/20}
whenever [2] 89/18
154/10
where [36] 5/25 7/13
9/1 12/1 22/10 22/13
23/4 27/4 27/24 32/24
57/3 60/13 61/25
66/23 70/10 71/3
76/17 77/3 84/12
84/22 85/4 92/15
97/10 103/21 118/2
128/6 140/9 146/13
148/7 148/19 154/22
155/7 156/11 156/24
162/3 191/17
whereas [2] 43/12
169/14
whereby [2] 161/6
170/21
whether [58] 19/7
30/9 40/19 41/4 44/13
45/21 48/4 53/6 54/2
55/9 66/2 67/1 68/24
71/16 71/21 73/5
76/20 85/18 87/6 91/4
91/17 99/11 111/6
111/9 111/10 120/8
120/11 121/3 122/10
125/2 127/9 135/15
137/1 137/2 137/3
137/7 137/8 137/13
140/20 142/1 142/16
144/13 146/25 148/11
158/23 162/1 165/10
165/11 166/15 167/10
170/15 175/6 183/22
183/23 187/1 198/20
202/5 202/11
which [129] 1/15
3/18 4/18 5/7 5/12
5/16 5/20 6/7 7/1 9/19)
10/10 11/8 12/11 14/8}
14/23 15/2 15/16

15/19 16/7 17/10 22/4I
22/8 22/17 22/25
24/13 25/13 25/17
27/6 27/13 27/23
28/18 29/9 30/14
31/24 31/25 32/5
32/12 33/3 33/25 34/9I
36/13 40/10 40/18
42/3 42/14 43/14 45/3
46/19 49/7 50/18
58/12 59/7 60/7 68/20
70/3 70/11 74/3 71/20]
75/17 75/21 76/15
77/16 79/8 82/13 88/7I
90/7 90/22 94/17 96/9]
100/22 103/21 103/23I
105/8 108/9 113/4
113/11 119/19 122/7
122/12 123/25 125/2
125/16 126/22 128/15I
129/23 135/25 136/24I
145/12 145/16 145/23I
147/10 149/17 149/18I
151/4 153/6 157/14
159/19 160/8 160/21
161/11 164/21 165/9
167/2 168/13 169/2
169/13 171/9 171/10
173/7 176/14 178/14
179/20 181/22 182/11
182/16 183/3 184/2
186/7 186/9 189/22
189/23 191/3 192/15
198/1 199/10 200/17
200/19 200/20 202/9
while [11] 47/24
56/23 64/2 120/9
130/8 132/19 142/23
147/9 158/9 187/18
188/4
whilst [5] 57/21
96/11 100/8 128/2
170/10
Whip's [2] 94/19
94/23
who [98] 4/4 7/18
11/9 12/20 12/22
13/16 17/22 19/24
20/4 20/6 20/10 23/15I
25/25 26/10 33/13
34/6 34/6 34/7 35/7
36/9 39/25 40/20
41/18 48/17 50/8 51/4
52/6 53/22 54/2 54/13I
56/24 57/9 57/22
57/23 58/3 58/3 60/3
60/15 65/11 65/13
66/9 72/8 72/18 73/2
73/3 79/6 79/14 79/19]
79/20 80/4 80/6 84/9
90/5 96/1 96/21 96/21
96/23 99/8 99/10
99/22 99/23 101/18
104/19 104/20 108/3

(86) watched... - who
Ww

who... [33] 110/6
111/2 116/24 116/25
122/16 122/21 122/21
124/3 125/23 129/17
130/2 133/6 133/14
134/14 134/24 138/13}
139/12 141/12 141/15
146/1 148/11 150/20
151/9 161/22 171/13
176/6 181/6 192/7
193/21 199/19 199/22
199/24 202/23

whole [19] 8/3 12/7
22/10 34/5 50/6 60/1
60/9 67/10 75/17
76/16 110/1 111/25
138/2 162/18 177/14
191/1 194/7 194/23
199/16

wholly [2] 149/4
195/10

whom [3] 19/7
100/12 162/14
whose [4] 31/3 67/3
85/13 182/5

why [42] 5/15 5/18
6/4 11/14 23/24 25/16
34/1 34/7 34/18 37/8
41/21 42/9 46/8 46/16)
57/10 57/13 58/8
59/13 59/23 65/15
67/13 74/22 84/19
101/24 103/19 104/3
104/24 105/14 108/6
121/7 121/13 145/20
149/9 161/14 163/10
183/17 191/19 194/14
194/16 194/19 197/3
197/14

wide [3] 4/23 52/17
52/24

wider [7] 73/14 73/20
74/18 74/23 75/7
87/19 94/22
widespread [1] 78/7
wife [1] 17/8

will [69] 2/4 2/4 17/9
30/20 37/18 40/21
43/6 48/15 48/23
52/22 59/16 63/11
63/20 63/20 63/23
76/3 77/13 77/16
98/10 98/16 98/16
102/16 102/21 106/8
106/8 106/12 106/15
106/16 110/15 115/19}
117/5 118/7 118/13
119/22 132/19 136/6
136/23 139/24 140/17
141/22 143/18 144/18}
147/7 147/8 151/11
152/7 152/10 152/24

154/15 155/8 155/10
156/10 158/20 160/3
160/11 164/24 172/14)
173/5 174/13 174/16
176/24 180/17 181/18)
190/18 195/19 195/21
195/23 196/4 199/19
Willmer [1] 151/12
win [2] 40/21 80/14
wish [7] 57/15 57/15
66/1 108/21 114/3
147/12 172/20
wished [1] 116/25
within [29] 2/12 4/15
4/18 6/21 8/19 17/17
39/1 54/21 68/12 78/9
79/13 79/16 93/21
94/5 97/11 98/23
103/12 113/22 122/23)
123/10 123/15 124/12)
125/16 126/17 128/11
136/3 182/21 197/20
197/21
without [9] 20/21
21/10 25/12 33/17
48/16 49/17 125/10
184/21 185/8
WITN10830100 [1]
80/17
WITN10900100 [1]
115/19
WITN10900103 [1]
121/25
witness [48] 1/18
1/24 3/7 5/9 6/12 8/10
9/10 9/18 9/22 10/9
15/6 17/14 21/13
33/20 36/13 47/7
49/12 62/9 65/23
66/19 69/8 78/4 80/11
82/24 88/17 114/11
115/5 122/1 123/22
126/20 130/2 130/5
130/18 131/17 140/12)
140/18 149/7 149/11
153/17 154/3 156/19
176/11 180/21 196/21
202/4 202/11 202/18
203/10
witnesses [4] 126/6
127/6 137/12 199/22
woman [1] 11/9
won't [1] 190/1
wonder [1] 46/21
word [9] 7/21 22/11
75/24 99/14 145/15
146/17 152/21 153/8
153/12
wording [1] 21/2
words [6] 108/23
164/3 170/18 177/3
177/13 189/2
work [26] 6/21 7/24
35/5 35/6 36/25 39/9

51/17 52/22 58/5
61/12 65/16 69/21
70/3 70/5 81/12 84/4
97/2 98/17 99/22
101/24 109/1 123/16
144/18 195/2 195/13
198/16
worked [11] 2/15
3/20 31/11 34/22
56/24 70/7 99/21
109/2 109/3 123/17
139/10
workers [3] 41/18
51/17 107/12
working [11] 20/6
43/5 57/1 73/5 83/14
89/21 106/21 118/2
118/16 118/18 129/16
workings [1] 72/4
workload [1] 25/23
works [4] 20/15
57/11 110/9 195/17
world [1] 33/25
worried [2] 37/13
96/22
worrisome [1] 69/3
worrying [4] 47/25
96/25 98/24 178/3
worst [1] 152/1
worst-case [1] 152/1
worth [1] 91/6
would [190] 9/5
12/12 12/14 16/2
16/24 17/1 17/20
17/21 17/23 18/2 18/2}
18/8 18/16 18/18
18/22 19/1 19/6 19/10}
19/12 19/25 20/7
20/18 20/25 21/3
21/11 22/25 23/21
23/24 24/3 24/6 25/11
25/25 26/2 26/20
26/24 28/13 29/4
29/12 30/21 31/10
33/2 33/6 34/20 34/25
35/25 37/20 38/8
38/13 41/3 45/11
45/19 46/13 47/23
51/16 54/19 55/3
55/22 58/14 60/5 60/7
61/16 61/18 61/20
61/23 62/1 62/3 62/6
62/18 64/14 64/17
65/1 65/6 65/7 65/12
65/12 65/18 65/19
65/20 66/9 66/15
67/18 68/23 70/9
70/10 70/11 72/15
72/21 73/3 73/6 75/13)
77/3 78/21 82/25 83/6
84/4 85/25 86/14
86/19 86/21 86/23
88/2 91/12 91/13
91/19 91/24 92/22

96/24 97/17 107/17
108/6 109/25 110/7
112/11 112/15 112/22)
117/21 122/6 122/19
123/19 124/5 124/7
125/8 129/18 132/5
133/8 134/19 135/6
136/22 138/19 139/22
141/16 141/17 143/18
145/14 146/10 146/20}
146/24 147/2 147/13
147/15 148/7 151/6
155/2 155/4 156/16
157/19 158/2 158/13
159/20 162/12 164/15)
166/18 167/3 167/14
169/11 171/16 171/18}
175/17 175/17 176/15)
176/23 177/7 177/12
177/15 178/4 183/23
184/9 185/4 185/8
185/9 187/6 187/6
187/8 187/12 187/15
188/7 188/8 188/10
188/24 191/20 193/2
194/13 197/17 197/19}
197/20 198/16 199/15]
199/18 201/1 202/24
wouldn't [7] 4/1
19/21 29/25 35/16
81/12 138/15 184/14
write [2] 47/23
145/20

writes [1] 135/18
writing [3] 51/25 61/4)
169/22

written [10] 26/11
59/5 59/9 59/10
101/12 135/18 155/22}
155/24 171/23 180/11
wrong [13] 12/11
66/22 67/4 70/4 72/20
76/23 121/10 138/2
145/15 153/3 159/15
164/7 187/14
wrongly [1] 190/22
wrote [4] 36/9 60/24
138/13 146/23

Wyn [4] 114/14
187/20 188/7 203/3

Y

Yasmin [1] 23/7
yeah [8] 35/21 41/21
47/15 121/23 142/4
144/25 146/19 147/22)
year [16] 3/10 6/19
6/21 6/25 7/7 7/13
7/16 34/5 101/10
109/4 115/8 115/22
127/12 127/13 131/23}
192/17

years [38] 2/11 2/24
2/25 4/2 6/13 8/3 9/19)

12/18 22/5 24/22
32/11 52/18 53/1
53/23 56/8 56/13 67/8I
83/11 83/12 86/23
87/3 101/1 107/20
108/14 109/3 109/4
109/5 109/20 111/15
113/15 128/1 138/8
138/17 144/3 170/23
171/8 198/7 201/17
yes [148] 1/4 1/23 2/1
2/8 2/8 2/11 2/17 2/22)
2/25 3/3 3/12 6/5 8/15]
9/21 9/25 17/1 17/18
18/11 20/16 21/5
21/11 23/13 23/20
24/20 26/24 27/5 29/3I
29/24 30/16 31/9
31/11 31/19 32/9 32/9
33/21 37/22 38/10
38/25 38/25 39/4
39/16 39/22 40/24
41/12 44/12 46/18
46/20 46/23 47/5
49/18 50/19 53/18
53/25 57/7 59/21 61/1
61/18 63/5 63/5 64/13
64/23 71/24 72/15
73/21 74/3 74/19
74/20 77/9 78/24
78/24 80/8 81/22 82/1
82/3 82/3 82/6 82/15
82/19 82/23 82/23
83/6 83/19 85/1 86/7
86/21 88/15 88/20
88/21 90/19 90/19
90/24 91/4 91/6 91/12
92/3 92/21 93/3 93/7
96/10 96/16 97/14
97/18 99/2 99/3
102/23 103/15 110/23}
4111/5 111/16 111/17
114/5 114/9 114/16
115/12 116/6 118/4
122/4 126/2 127/21
128/12 129/1 130/7
130/11 131/8 131/12
139/7 141/11 142/16
145/9 149/8 150/15
151/10 154/24 155/21
155/25 156/3 157/25
162/10 165/17 165/24)
166/12 185/16 185/20}
188/1 190/3 203/9
203/11 203/12
yesterday [1] 145/2
yet [2] 48/9 162/19
you [635]
you'd [4] 84/5 108/16
108/22 185/6
you'll [12] 16/8 23/6
23/9 23/14 27/18 42/2I
80/9 100/23 101/5
101/12 162/23 178/2

(87) who... - you'll
Y

you're [26] 9/12 9/22
12/13 33/10 35/10
35/12 57/21 57/22
57/23 61/17 81/21
99/13 99/14 101/4
104/10 105/8 108/24
109/12 111/18 112/7
116/23 117/19 170/1
187/19 198/20 203/5
you've [29] 1/18
16/23 20/22 69/18
79/5 79/6 80/13 80/24,
81/3 85/16 100/1
100/14 100/15 101/3
108/15 108/19 112/19
115/24 121/3 130/6
131/14 154/3 156/19
159/24 168/5 198/13
200/24 201/8 202/25
your [167] 1/10 1/21
1/25 3/7 4/11 4/24 5/9
5/16 5/17 6/12 6/13
6/14 7/14 7/15 8/10
8/13 8/23 9/8 9/10
9/12 9/18 9/22 9/23
10/9 13/3 14/18 15/6
16/22 17/9 17/14
17/17 18/9 20/21
21/13 21/25 24/16
25/14 27/20 28/15
30/9 31/14 33/2 33/20
34/13 36/13 37/18
38/23 39/13 43/2
44/10 45/12 47/7
49/12 49/14 49/15
50/16 51/25 52/2 52/4
52/6 53/15 54/9 55/15
62/9 63/3 63/25 64/10)
64/21 65/23 66/19
68/16 69/8 71/18
74/16 78/4 79/11
80/11 80/12 81/14
81/23 81/24 82/24
83/25 84/16 85/17
85/17 86/1 86/12
86/21 88/14 88/16
88/22 89/24 89/24
90/20 90/25 93/22
95/19 96/8 97/13
98/22 99/5 100/3
100/5 100/14 101/1
106/25 108/14 108/15}
108/21 108/23 110/17)
114/2 114/11 115/2
115/13 115/15 116/18
116/23 118/7 118/9
118/14 118/25 119/4
119/6 119/7 119/10
119/23 120/19 120/22
122/1 122/3 130/5
132/12 133/2 133/15
133/16 134/16 135/11

138/14 139/3 140/4
143/9 145/19 149/6
150/14 154/3 155/10
156/19 156/20 162/8
167/14 171/25 180/21
185/14 186/11 189/18)
190/7 191/18 193/20
195/7 198/13 201/11
202/18 202/19 202/19)
202/20

yours [1] 116/21
yourself [9] 23/11
23/22 91/25 116/22
125/5 138/13 166/10
168/15 190/12

,
zoom [1] 94/11

(88) you're - zoom