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Friday, 26 July 2024
(9.45 am)
MR STEVENS: Good morning, sir. Can you see and hear me?
SIR WYN WILLIAMS: Yes, thank you.
MR STEVENS: Sir, we are hearing from Allan Leighton today
and, as you will remember, but for the benefit of those
watching, Mr Leighton gave oral evidence to this Inquiry
‘on 17 April of this year and, on that occasion,
Mr Leighton confirmed the accuracy of his witness
statement, subject to one minor correction. The Unique
Reference Number for that statement is WITN04380100.
The statement and the transcript of Mr Leighton's oral
evidence is available on the Inquiry's website.
We weren't able to conclude his oral evidence on
17 April and I stress that was through no fault of his,
and Mr Leighton has agreed to the Inquiry's request to
re-attend to answer further questions today.
With that in mind, sir, unless you wish to say
anything I would ask that Mr Leighton be sworn in?
SIR WYN WILLIAMS: No, that's fine.
ALLAN LESLIE LEIGHTON (re-sworn)
Questioned by MR STEVENS
MR STEVENS: Thank you, Mr Leighton. Thank you for
attending the Inquiry again to complete your oral
evidence. I want to start by recapping on some of your
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structures are in place to enable any issue in the
business to be raised up the organisation. And,
therefore, you've got -- you have the, you know, the
Executive Management Team who are responsible do that.
You've got all the meeting structures from the POL Board
to the Royal Mail Board to the Audit and Risk Committee,
to the subcommittees of all those organisations, to the
Management Boards of those organisations that move all
the time and, over time", and then you go on to talk
about Have Your Say.
Do you remember giving that evidence?
A. Yes.
Q. Could we please then turn to page 38, A4-page 38, and
then internal page 152, please, at the bottom, line 7.
l asked:
"What is the Non-Executive Director or Non-Executive
Chairman's role in respect of risk management?"
Your answer says:
"To make sure that the processes are in place that
enable that to happen, in terms of risk management,
Audit and Risk Committee obviously are a big part of
that, but also a lot of risk doesn't just come through
the Audit and Risk Committee, it comes from the
day-to-day interface you have with people. So the most
important thing is to have some set processes, to make
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oral evidence from the last hearing and so if we could
please bring up the transcript of that, it's
1NQ00001131. While that's coming up, I will say that
I will use two pages references when referring to the
transcript, one the A4-page reference for the purposes
of our document management system and then the internal
page reference as well.
So if we could first, please, turn to page 32,
that's A4-page 32, and at internal page 126, we see
there your evidence begins, your oral evidence. Please
can we look at A4-page 35 and at internal page 138,
line 22, this follows a question I asked about Post
Office Limited issues. I asked:
"With hindsight, should added to that list be
prosecutions of subpostmasters and oversight of
prosecutions of subpostmasters?”
If we could go down the page, please, to page 139,
we don't need to read the whole of it but part of your
answer was:
"Non-execs are called non-execs because they don't
execute; executives are called executives because they
do execute."
That's at line 11, sorry.
Then carrying on from line 13:
"So our role, I think, really is to make sure the
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it clear where the responsibility lies and, again,
I think you can see, certainly in the Royal Mail pieces
of the report and accounts, that there were -- you know,
risk management was built up from the bottom of the
organisation."
Again, do you recall giving that evidence?
Yes.
So I think, summarising your evidence, is that
a non-executive had responsibility to see that
appropriate reporting structures were in place in the
group or business?
That's right.
Would that include a responsibility to see that there is
appropriate oversight of the group's operations?
Absolutely.
Can we turn, please, to page 40. I should say
A4-page 40. Then at internal page 159, line 13,
I asked:
"Well, when was the first time that you were aware
that subpostmasters were prosecuted for those offences
by a Royal Mail Group --"
I think I was going to say "company". You answered:
“When I joined the organisation".
At internal 160, line 3, it says:
"Were you aware that the decision of whether to
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prosecute someone or a subpostmaster, was made by
a Royal Mail Group company?"
You answered:
"Yeah."
Then at line 7:
"Were you aware that the prosecution was conducted
by a Royal Mail Group company?"
You answered:
"Yes."
Again, do you recall giving that evidence?
Yes.
Page 41, please -- thank you -- and down to internal
page 163. At line 6 I asked:
"So you were aware of the prosecutions. Were you
aware that prosecutions of subpostmasters relied on data
generated by the Horizon IT system?
“Answer: I'm not acutely aware of it but it would
be obvious that it would be because, obviously, that was
the EPOS system of the branches.
"Question: On an operational level, who or which
team did you think was responsible for investigating
suspected theft, fraud or false accounting on the part
of subpostmasters?
“Answer: Again, I can't recall exactly but I would
say it was in that sort of Security/Legal area of the
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"Question: So within Group in Legal?
"Answer: Yes.
"Question: Who did you think was responsible for
the conduct of those prosecutions? Would that be legal
again?
"Answer: Yes, I think so."
I think it's fair to say that those were all matters
that you -- your evidence is you knew those at the time
you were chairing; is that right?
Sorry, could you repeat that?
Is your evidence that you knew those matters, which
we've just gone through, at the time you were Chairman?
Largely, yes.
When you say "largely", what matters do you think you
weren't aware of when you were Chairman?
I mean, some of the detail, I would think, I was -- I'd
need to go back over things but, largely, I would have
been aware of all those things when I was Chairman.
Can we look, please, at A4-page 42 and then internal
page 165, line 1. It says:
"Were these matters actively on your mind at the
time when you were running the company?
“Answer: Not at all.
"Question: Why not?
“Answer: Because, obviously, there were many other
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business.
"Question: So we have the Security Team. Where did
you think the Security Team sat in the reporting line
within the group?
“Answer: Again, I can't -- I don't know exactly
because I haven't seen the organograms but I think my
recollection is that they worked into the Legal teams
and that they all worked into the Company Secretary.
"Question: So the Legal Team, where did the Legal
Team sit?
“Answer: Again, I'm not 100 per cent sure but
I think it reported into the company secretary.
"Question: The company secretary of which company?
“Answer: Of Royal Mail Group.
"Question: So Legal was a group function?
“Answer: I'm pretty -- yes, I think so, yeah."
Again, do you recall giving that evidence?
Yes.
Then, actually, line 16 as well, please, of internal
page 164.
“Question: Again, at the operational level, who did
you think was responsible for the decision as to whether
or not to prosecute a subpostmaster?"
“Answer: I would have -- again, I'm not -- I have
to say within the Legal Team.
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things that were being addressed both --", and you go on
to say what those were.
Just to clarify this, what is you're saying is that
you knew, as you say, largely the overview of what I've
just been through but it's not something that you
actively thought about when you were Chairman as to how
the process worked?
Absolutely.
We then turned in your evidence to look at the oversight
of prosecutions at the group level. I don't need to go
through the entire transcript for that. I'll take you
to one part. It's A4-page 44, please and internal
page 73, at line 25. I asked:
"Let's take it in charges. You say that Jonathan
Evans, the Company Secretary, that's the line of report
for Legal?
“Answer: That's what I think. I'm not 100 per
cent, as I said to you.
"Question: You said earlier you thought the
decision to prosecute and the investigation of offences,
responsibility for that lay with Legal —-
“Answer: Yes.
“Question: -- at Group level?
“Answer: Yes.
"Question: We see that the Audit and Risk Committee
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The Post Office Horizon IT Inquiry
of the Royal Mail Holdings Group are exercising
oversight of the prosecution of offences affecting Royal
Mail, yes?
“Answer: Yes, but their oversight is on the Royal
Mail and POL and Parcels. The Royal Mail Audit
Committee's oversight is across all of the elements of
the business.
"Question: Yes, so that's my question. Why, in
those circumstances, was the Audit and Risk Committee
not exercising the same type of oversight as we see here
in respect of prosecution of crime that was affecting
Post Office Limited?
“Answer: That I don't know.”
Is it fair to summarise your evidence as this: that
the Royal Mail Board in practice did not exercise
oversight of the prosecutions of subpostmasters?
That's correct.
You couldn't give us an answer to why that was at the
last time?
That's correct.
Can you give us an answer today?
No, I mean, I -- it's the same thing. Obviously, at the
Audit Committee, as you saw, some of these issues were
discussed. But it seems it would largely be a cost of
to Royal Mail, and so at no stage really was there any
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None at all.
So during your time as Chairman, is it the case that you
did not discuss prosecutions of subpostmasters with
anyone?
As far as I can recall, yes.
If we could please look back at your statement, page 23,
paragraph 45. You say:
"As a general matter, my role as Chairman and
[Non-Executive Director of Royal Mail Holdings] was one
which involved overseeing and advising on the strategic
objectives of [Royal Mail Holdings]."
Pausing there, you were also a Non-Executive
Director of Post Office Limited?
Absolutely.
"Where issues were raised to Board level, I would seek
to take an active role in discussing and probing the
best course of action. Since the litigation was taking
place within [Post Office], as with other companies with
whom I have worked over the years, I would have expected
the Board of [Post Office] to be kept up-to-date with
key litigation ongoing in the company."
What did you mean by "Since the litigation was
taking place within Post Office Limited"?
That the -- that that's where the interface was.
Basically, POL was in charge of the subpostmasters.
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information coming up the organisation that this was
an issue, or the issue that it was. And therefore,
I think that is why it was never really picked up at the
Audit Committee.
Can we look at Post Office Limited's oversight of
prosecutions and turn to your statement, please,
at page 23, paragraph 44. So you're discussing
oversight of legal departments for various other
departments, you'll see from the first line.
Midway down you say:
"I do not recall any discussion during Board
meetings of the prosecutions that [Post Office] was
pursuing against those [subpostmasters].”
Is that relating to all boards, Post Office Limited
and Royal Mail Holdings?
Absolutely.
Does it also apply to any subcommittees of the Boards of
either company that you sat on?
As far as I know, yes.
Do you recall having any discussion with any other
member of the Post Office Executive Team about
prosecutions?
None at all.
Do you recall having any such discussion with any other
Post Office Non-Executive Director?
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Obviously, they're working with Royal Mail Group, who
were doing the legal activity, but I'd have expected
both -- it to come to the Board of POL and, if
necessary, to the Board of the Royal Mail, if there were
significant issues in litigation, including litigation
against subpostmasters and/or any issues that resolve --
that were a cause of that.
Do you accept that oversight of the legal function in
Royal Mail Group was to the Royal Mail Group Board?
It was through the Royal Mail Group Board, yes. But,
also, had an interface with the POL Board because POL
‘operationally managed that piece of the business. So
I'd see it as a joint responsibility.
You say that you would have expected the Board of Post
Office Limited to be kept up to date with key litigation
ongoing in the company, and you go on to say:
"Usually this would include litigation which
impacted, or had the potential to impact, the strategic
‘objectives of the company. I would not have expected to
have been briefed on all litigation, but rather those
deemed by the Executive Team to be high cost or have the
potential to impact the strategic objectives of the
company. Within the business, the responsibility for
conducting and overseeing litigation is, in my
experience, the responsibility of the company's legal
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function."
When you say "high cost”, are you referring to the
legal costs, the risk of -- so what's at stake in the
litigation, the amount that's at stake in the
litigation, or both?
Both, and impact that it may have on the business, in
a negative sense, from either a revenue or a cost
perspective.
When you say "the potential to impact the strategic
objectives of the company", what did you mean by that?
Well, any -- I mean exactly that. If there is anything
that would affect the strategic impact -- have
a strategic impact on the company, from wherever it came
from, then I'd expect the Board to be aware of that.
And, again, if you look at this particular tragedy,
clearly, if there were issues with Horizon in a systemic
way, that would not just have a cost impact on the
business. It would have a strategic impact on the
business, because you would question why we were rolling
that system out because it was the backbone of
everything that was happening in the Post Office. So
Horizon was a major strategic activity within the Group.
Just looking at the prosecutorial function: reduced to
its simplest, this meant that Royal Mail and Post Office
would take people to court and, in certain
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the prosecutorial process was fair and lawful?
I think the role of the Board in this would be to ensure
that there were practices and policies and procedures in
place, and that those were taking place, and then would
expect to hear where that was not the case.
So is your evidence that the role of the Board is to set
up the process, firstly?
Yes, I think?
Yes.
Secondly, to see that that process is being followed
through?
Yes.
And, presumably as part of that, it's important that
people in the management chain know who is responsible
for what?
Absolutely, and not just in the management chain: in all
of the functions that were interfacing in that activity.
Is it the Board's responsibility to satisfy itself that
people in the management chain and elsewhere, as you
describe, knew the remit of their responsibility?
Absolutely.
I want to look at what was considered by the Post Office
Board and/or subcommittees. Could we please start with
POL00021483. It's a meeting of the Post Office Limited
Board of Directors on 20 August 2003, and we see on the
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circumstances, that would lead to sentences of
imprisonment; do you agree with that?
Yes.
You would have known, when you were Chairman, the very
serious consequences of a criminal conviction against
a subpostmaster?
Yes.
You would have known of the very serious consequences of
a term of imprisonment against a subpostmaster?
Yes.
In those circumstances, would you agree that the
exercise of the prosecutorial function should have been
at the forefront of the Board of Directors' minds?
I'm not sure that it should be at the forefront of the
Board's mind but it would -- certainly should have been
in scope. But I go to the same issue, which we come to
all the time here: the issue was that there was nothing
coming to the Board from any direction that suggested
there was any -- the scale of the activity or some
systemic issue in Horizon that was causing that.
Leaving Horizon to one side, when one of the operations
of the company had the potential to lead to terms of
imprisonment for members of the Group's workforce, or
past members of the workforce, wasn't it incumbent on
the Board take proactive steps to satisfy itself that
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"Present" side, three up from the bottom, you're listed
as being present.
Could we turn, please, to page 8. Under "POLB03/69"
it refers to Tony Marsh, who "presented a security paper
to the Board on behalf of David Miller". If you just
have a quick skim of that and let me know when you want
to go over the page. I don't need to read it on to the
transcript.
Okay to move on?
Go to the next page, please. That appears to be
relating to the security of sub post offices rather than
the investigation and prosecution of crime. Is that
your recollection of the meeting, if you have one?
Well, it was a long time ago, so I can't recall but way
I'd read it, I'd say that that's -- when you read it,
that's what it is.
Can we please look at POL00021485. That's a year and
a bit on in the chronology, 13 October 2004. We see,
again, three from the bottom of the "Present" list, you
are present, and it says, "For POLB04/86 -- 04/97".
I assume that means, where the references are in between
that number, you're present for the meeting: when it's
outside of that number range you aren't there?
Yeah, I can't recall that.
We see it's up to 97 on the right side.
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Yeah.
Can we go to page 13, please, so "POLB04/108". So it
appears that you wouldn't have been there at this
meeting. Would you have read the minutes of the meeting
at a later date?
Yes.
It says "Human Resources" and "The Board noted the
report":
"The Board agreed that in situations where fraud had
been perpetrated against the Company, the appropriate
Civil Orders would be used immediately and in advance of
any criminal proceedings. This would help recovery
efforts by ensuring that the assets of those involved in
criminal activity were quickly secured. David Miller
would verify the current procedures and report back to
the Board."
Given this is under the Human Resources section, can
you assist us with whether this is looking at alleged
fraud against the Post Office by its workforce?
I can't -- I mean, I can't recall that, no.
Do you recall this issue being raised or discussed with
other members of the Board?
I've no -- obviously it's a long time ago, so I don't
actually recall this. If you ask me to read it,
I would -- it's difficult to -- it's difficult to tell
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Just that we had no idea of the numbers of prosecutions
that were taking place. That was never raised up.
What was your understanding of the numbers of
prosecutions that were taking place at the time?
I had no understanding of the amount of prosecutions
taking place at the time.
Did you at any point ask how many people the Post Office
was prosecuting?
Not in that set of circumstances. There were
discussions at Royal Mail Group about the broader number
of prosecutions taking place across the group but, to my
recall, never a discussion about the number of
prosecutions actually taking place in POL itself.
Could we look, please, at -- actually, no, before we do:
why did you not ask for numbers of prosecutions in
relation to Post Office Limited itself and/or
prosecutions against subpostmasters?
Because it was never seen as an issue in the
organisation. It was never flagged up as an issue and,
frankly, there were so many other things going on,
unless it would have been raised, it wouldn't have been
picked up. But in -- as you can see, in bits of the
Royal Mail Group, or where issues were raised generally,
there was a discussion. But this was not a priority at
the time, which was a mistake.
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exactly who it's talking about.
You weren't aware, around this time, though, of the
Board considering the process of prosecutions, is that
right?
Sorry, I don't --
So with your -- any conversations you remember with
non-executives, it's right that you weren't aware of, or
told about, any discussion at Board level about the
process of prosecutions?
‘About the process of prosecutions?
Yes.
No, I thought you asked a question whether we knew about
numbers of prosecutions. Obviously, this talks about
the process of prosecutions.
Let me rephrase it. I asked you earlier if you were
ever involved in discussions about prosecutions with
members of the Board, Non-Executive Directors. My
question is: are you aware of any discussion at Board
level about oversight of prosecutions that occurred when
you were not there?
No. I mean, this is -- I don't think this is about
oversight of prosecutions. This is about, when I read
this, what happens when there is a recovery required.
You mentioned numbers of prosecutions before. What were
you going to say about that and your knowledge of —
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Is that a mistake because it was a reactive approach to
the oversight of the process of prosecutions, rather
than a proactive approach of the Board satisfying itself
that the prosecutions were being conducted fairly?
I think it's -- I think it was reactive and -- but
I think it's the context of it, which is there's, you
know, many, many other things happening in the business.
This was not seen as an issue, therefore, there were --
you know, there were clearly procedures that should have
been taking place. Clearly, there were teams working on
this that had the opportunity to flag this up, and it
didn't happen, and it didn't happen not just in the
organisation; it wasn't flagged up by -- you know, from
the National Federation of SubPostmasters. You name it,
this was never brought up as a significant issue, and
Boards tend to react to significant issues.
Can we please look at POL00021486. It's a meeting on
15 September 2024 of the Post Office Limited Board. If
we go down, we see you're not in attendance but, as
you've said before, you would have read the minutes?
Can we turn, please, to page 6.
When I asked "you would have read the minutes",
I think you nodded?
Yes.
Yes.
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Sorry.
Thank you. We have an entry about the "Risk and
Compliance Committee". It says:
"Peter Corbett provided a short presentation on to
highlight the work of the newly formed Risk and
Compliance Committee. The Board noted that ..."
If we go over the page, please:
"The scope of its activity included audit,
compliance and legal issues ...”
It says:
"Its primary aim was to ensure the service and
conformance elements of the business were working
together properly."
That's (d).
Then (e):
"The next quarterly meeting would be held on
5 January 20085 to discuss Branch Control, Vital Few
Controls, Audit Reports, Anti-Money Laundering measures,
Crime and Fraud and the work of the Group Audit
Committee.”
Do you remember what your understanding was of the
remit of the Risk and Compliance Committee within Post
Office Limited at this point?
No, I can't recall that.
Did you ever sit on the Risk and Compliance Committee or
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with those people.
Would it require input from the Legal Department?
I would imagine so, yes.
Could the Risk and Compliance Committee of Post Office
Limited effectively oversee prosecutions if it was not
able to oversee the Group Legal function?
Yes.
Why?
Because it's about information, and the members of the
Post Office Audit and Risk Committee, and the MD, and
the Chairman of Post Office Risk Committee, sat on the
Royal Mail Board.
Could we please look at POL00021490. It's another Post
Office Limited Board meeting, 14 December 2005. If we
go down, please. We see you have given your apologies.
Could we turn to page 14, please. Just scroll down
slightly, so we see -- that's perfect, thank you.
We have the "Risk and Compliance Committee" heading
and it says:
"The Board noted the Risk and Compliance Committee
minutes of 29 September 2005."
Would you have read those committee minutes as part
of the Board pack, even though you didn't attend the
meeting?
If they were in the Board pack, yes.
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attend it?
Not as far as I can recall.
Sir Michael Hodgkinson gave evidence to this Inquiry, we
don't need to bring up his witness statement, but at
paragraph 32, he said:
"I introduced a Risk and Compliance Committee
because the Board was conscious that it would need to
have greater corporate governance measures in place,
with the progression into financial market, specifically
because of the risk of mis-selling financial products."
Can you gainsay what Sir Michael says about the
purpose of the Risk and Compliance Committee?
No.
Please could we turn to -- actually, before we do,
sorry, would this, the Risk and Compliance Committee, in
your view, have been a suitable place for oversight of
prosecutions to take place -- when I say “oversight of
prosecutions", I mean against subpostmasters by the Post
Office?
I could be a place, yes.
In order for that to be an effective committee to
‘oversee such prosecutions, what types of attendees would
it require?
Again, largely the people that are on that list, I would
imagine. That's why it would have been set up that way
22
Because it says "the Board noted the minutes", is it
likely those minutes would have been in the Board pack?
Probably, I don't know. I wouldn't be able to comment.
Could we look, please, at POL00021418. We see the
minutes of the Risk and Compliance Committee on
29 September 2005 -- sorry, just getting my copy -- and
members, we have Sir Michael Hodgkinson, Peter
Corbett -- that was the Finance Director of Post Office
Limited; is that right?
I think so, yes.
Rod Ismay, who the Inquiry has heard evidence from.
Will he have been in the branch accounting team at that
point?
Again, I couldn't recall that but ...
Alwen Lyons, again, we've heard evidence from at the
Inquiry.
The Secretary, Michael Dadra: do you recall working
with him?
Sorry, no, I don't.
Apologies from lan Anderson; do you recall working with
him?
No.
Alan Cook we know and will come on to.
Keith Woollard; do you remember him?
Not necessarily. Long time ago.
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Are you aware if the Post Office Limited Risk and
Compliance Committee had any persons attending with
legal experience?
I couldn't tell from that list.
Could we turn, please, to page 6, and, if we go to the
bottom of the page, it says:
"Post Office Limited has a principle of undertaking
criminal prosecutions for all cases where it is in the
public interest, but noting that likelihood of recovery
and circumstances of the defendants and the victims may
be relevant to that decision."
Firstly, after reading that, do you recall whether
you turned your mind to whether this committee was
overseeing criminal prosecutions?
I wouldn't be able to -- I mean, I wouldn't know if
I saw this document. So it's difficult to comment,
really.
Secondly, the point of:
but noting that likelihood of recovery and
circumstances of the defendants and the victims may be
relevant to that decision."
The likelihood of recovery as being relevant to the
decision of whether a criminal prosecution is in the
public interest, is that something that would have
struck you as odd when you read it at the time?
25
No, not at all.
Can you assist us, is this a fair reading of what
happens here: firstly the Board is noting an increase in
volume of regulatory issues, yes?
You're nodding.
Yes, I'm waiting for you to finish, actually. Go on.
Regulatory issues, does that mean compliance, for
example, with financial services issues; is that how you
take that to --
It could be a number of different things. "Regulatory"
is quite a broad term.
It wouldn't be used to describe prosecutions, would it?
I'm not sure it would.
The decision is, in light of that, for the Compliance
Director of Royal Mail Group to be asked to join the
committee. Can you recall ever a similar decision or
discussion being made in respect of someone from Group
Legal joining the Compliance Committee?
No. Although this is actioned to Jonathan Evans, who
I think Legal reported to. I think Jonathan Evans is
on --
So he's the Company Secretary and your evidence, as
before, was the Legal Department -- Group Legal
department reported to him.
I think -- I'm pretty sure it did. So Jonathan would
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Well, I'm not sure I did read it at the time. As
I said, I don't recall seeing this document, so I'd only
be speculating. To be honest, it's not very clear at
all, as a --
Do I take it from this that, to the best of your
recollection at the time, you didn't turn your mind to
the circumstances in which Post Office Limited would
pursue prosecutions?
No.
That can come down. Thank you.
Could we look, please, at POL00032210. This is
another meeting of the Post Office Limited Board, this
time on 20 April 2006. We can see present, second from
bottom, you're in attendance. Yes?
Yes.
If we can turn to page 2, please, and then at the top
there's (c). It says:
"The Board noted the minutes of the Post Office
Limited Compliance Committee of 22 March 2006. In view
of the increasing volume of regulatory issues the Board
considered that it would be beneficial for the Committee
to recruit additional expertise. The Board agreed that
Luke March, Compliance Director Royal Mail Group, should
be asked to join the Compliance Committee."
Do you recall this discussion or this decision?
26
be -- you know, he would be the legal representative,
I would imagine, in this discussion.
My question is slightly different. I think you have
answered it, which is: was there a discussion ever at
Board level of having someone from Group Legal be put on
the Compliance Committee at Post Office level. I think
your answer is no, or you don't recall?
I don't recall but it looks here as if that's what's
happened.
Sorry, is your evidence that Luke March, as Compliance
Director, would be within the Legal function?
Would be -- no, but this is about regulatory -- I mean,
I'm trying to read what you said, but this is about
regulatory issues, and Luke March, who I don't recall,
but compliance generally is broader regulatory issues.
So I think this is -- when I read this, this is about
regulatory issues in the broadest sense. Not just about
legal issues.
No. I suppose I'll narrow my question further: do you
recall there ever being a conversation about the General
Counsel at group level, or a member of the Royal Mail
Group Legal team being asked to sit on the Post Office
Limited Compliance Committee?
Not that I can recall.
That can come down. Thank you.
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Is it fair to say that, looking at those Board
minutes -- leaving the Compliance Committee to the side
because you didn't sit on that, but at the Board
minutes -- is it fair to say that the Post Office Board
didn't exercise active or real oversight of the
prosecutions brought by Post Office Limited?
No, I don't think that's correct. I think what would
happen is the Post Office Board would have oversight of
those -- that activity, if the executives on that Board
felt and knew that there was a significant issue.
So, again, I think your evidence is it's for the
executives to raise the problem. Is your evidence that
there's no obligation on the Post Office Board
proactively to ask about the process of prosecutions?
Generally they -- they would -- the Board would ask
things proactively, if there was an issue or if somebody
had seen some data that flagged an issue.
Is that the general approach to matters, how a Board
operates generally?
Well, that's a big generalism. No, obviously not. But,
in essence, the Board focuses on one of the key
strategic issues facing the business and then relies on
the management teams within those businesses to manage
the pieces in their operational areas against the
policies and procedures that are put in place to do
29
of prosecutions, and it wasn't necessary to have
hindsight to do that?
No, I think that what was missing was the level of
prosecutions, and what was missing was the impact that
Horizon was having on that. And with those two
issues -- those two issues would weigh significantly on
whether the Board, you know, spent time on that
particular issue.
I want to look at some of the evidence given by other
senior figures within the Royal Mail Group and Post
Office Limited to this Inquiry, and I'll start with
Sir Michael Hodgkinson. He was Senior Non-Executive
Director of Royal Mail Holdings from 1 January 2003
until 31 August 2007 and Chair of Post Office from May
2003 to March 2007. I'm not asking you to remember the
specific dates but does that broadly sound right to you?
Yes.
You would have worked with him regularly in your role as
Chairman?
Yes.
Sorry, could you just speak up a bit, was that --
Yes. Sorry, yeah.
No need to apologise. From your evidence before, I take
it you didn't discuss the oversight of prosecutions of
subpostmasters with Sir Michael; is that correct?
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that, and those things tend to be reported up to the
Board on an ad hoc basis, generally driven by an issue
being raised that means it needs to be brought to the
attention of the Board. It's a top-down and bottom-up
approach.
I'll come back to the questions I asked earlier about
the consequences of the criminal process, of which you
were aware. Because of those significant consequences,
do you not think a more active or careful or different
approach to oversight was required by the Board because
of the significant consequences?
Well, obviously at the time, that was not the case.
People did not think that. With hindsight, obviously
that would -- I would change my opinion today. But
I think the crucial issue here is that the systemic
issues of Horizon then impacted the prosecutions of the
subpostmasters was not an issue that was ever raised
cover a long period of time, and a lot of governance
comes from intelligence up the organisation.
Again, I'm going to deal with Horizon shortly. You said
“with hindsight". The risk arising from prosecutions
was known and obvious at the time; would you agree?
Yes.
Would you accept that the Post Office Board should have,
knowing what it knew, exercised more proactive oversight
30
Not that I can recall.
I think you said, "Not that I can recall"?
Yeah.
Can we please bring up Sir Michael's statement. It is
WITN10660100. It came up before I finished the number,
very impressive.
Can we turn to page 22, please. Paragraph 56, it
says:
"I have been asked about where the responsibility
lay in the Holdings Group for criminal prosecutions and
civil proceedings of [subpostmasters] for shortfalls in
branch accounts. I cannot recall who would have been
responsible within [Post Office Limited], but my
assumption is that this would have been dealt with by
the [Post Office Limited] Legal Department who would
have reported any issues to the CEO or COO."
It goes on to say:
"I do not recall discussion about the risks and
compliance issues arising from the prosecution of
[subpostmasters] for theft and false accounting, or the
pursuit of civil litigation against [subpostmasters] to
recover alleged shortfalls in branch accounts. As far
as I was aware, there was a fully functioning Legal Team
responsible for these actions.”
Then if we can bring up on the screen, at the same
32
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time, please, Sir Michael's evidence to the Inquiry.
It's INQ00001128.
We'll see this is the transcript of the proceedings
on 11 April 2024. If we could go to page 32. That. Is
internal page 126 at line 9. Mr Blake is asking
questions and says:
“Putting those three together, did the Board, so far
as you recall, ever receive notice of concerns about
prosecutions relating to Horizon or problems with the
Horizon system itself?
“Answer: I was not made aware of those.
“Question: _ I'd just like to read paragraph 38.1 of
your statement which addresses the legal document. It
says:
"I do not believe the Board had direct oversight or
involvement with the Legal Department and I do not
recall the structures of the Legal Team. This was
ultimately the responsible of the CEO and COO."
"We saw when we started today the Board composition.
It doesn't seem as though there was what you might see
nowadays, a General Counsel
Yeah.
"Question: —- someone of an equivalent position.
“Answer:
"Was there, in your view, any gap in relation to
oversight of the Legal Department at the Post Office?
33
Crozier, please. He was Chief Executive between
February 2003 to April 2010; does that sound about
right?
Yes.
He reported to you; is that right?
Yes.
Would you have worked with him closely?
Yes.
Again, from your evidence before, I take it that you
don't discuss the oversight of prosecutions of
subpostmasters with Mr Crozier?
Yes.
Can we look at his witness statement please. It's
WITN04390100, page 14, please, paragraph 41.1. We see
from 41 it's talking about supervision, it says:
"As far as I can recall:
“Oversight for criminal prosecutions and civil
proceedings brought by [Post Office] would have sat with
the [Post Office] Legal Team, and oversight for
prosecutions brought on behalf of the rest of the Group
would have sat with the Group Legal team."
If we can then look at his evidence to the Inquiry;
it's INQ00001129. If we turn to page 27, please.
‘A4-page 27, please. Scroll down please, there we see
Mr Crozier giving evidence, questioned by Mr Beer.
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“Answer: I think there was and I think that was
part of the fact that some of the functions remained
central.
"Question: Can you expand on that, please?
“Answer: I think we had a subset of the Royal Mail
Legal department.
“Question: What was the problem with that?
“Answer: I think then it wasn't represented on its
‘own right on the [Post Office] Board.
"Question: Did that change at all during your time?
“Answer: No."
“Question: Was that something you were aware of at
the time or is that looking back now?
“Answer: I think more looking back."
Did you discuss the oversight of the Legal
Department, the Royal Mail Group Legal Department, did
you discuss that with Sir Michael at any point?
Not that I can recall.
In circumstances where Sir Michael was Chair of the Post
Office Limited Board and you were Chair of the Group,
and the Legal Department within the Group was providing
services to the subsidiary, why did you not discuss
oversight with Sir Michael?
Because we'd have no reason to discuss the oversight.
That can come down. Thank you. I'll turn to Adam
34
If we could turn, please, to page 35, that's
A4-page 35. Thank you. If you can go down to internal
page 140, we see there's a question that starts -- or
a quote, sorry -- at line 9, and then from line 21 it
says:
"Were you not aware that, in fact, there was no Post
Office Legal team, it had no separate legal in-house
function and that civil and criminal proceedings were
brought by lawyers within the Royal Mail Group Legal
Team?"
Over the page he goes on to say:
“Answer: I was not, no.
“Question: So lawyers from within the Group gave
advice on prosecutions, they made decisions about
prosecutions and within prosecutions, and they conducted
the proceedings, not any Post Office lawyers. You
didn't know that?
“Answer: Was that throughout the whole period or --
"Question: Yes.
“Answer: And I -- I'm sorry --
“Question: Throughout the whole of your period.
“Answer: My period?
“Question: Yes.
“Answer: I was not aware of that, no.
"Question: Given the facts that I've just
36
(9) Pages 33 - 36
The Post Office Horizon IT Inquiry
26 July 2024
1 described, that would mean, is this right, that your 1 Mail?
2 Board had a responsibility for the conduct of a team of 2 Not that I can recall.
3 lawyers within Royal Mail Group who were acting on 3 So for that reason, presumably you can't assist us with
4 behalf of the Post Office, rather than the Post Office 4 how Mr Crozier may have come to understand that there
5 Board having such a responsibility for them, wouldn't 5 was a Post Office Limited Legal Team responsible for
6 it? 6 prosecutions?
7 “Answer: In part yes, but also, they would be doing 7 Not at all. I mean, it may be worth -- it is not
8 that at the behest of the Post Office team who owned 8 unusual to have -- remember, the Royal Mail Group had
9 Horizon and any issues deriving out of that. 9 a number of ancillary companies: Post Office, GLS,
10 "Question: Well, they might be their clients. 10 Parcelforce, Royal Mail Holdings, the Royal Mail itself.
1 “Answer: Yes. 1 So it's not unusual at all to have a Group function at
12 "Question: Post Office Limited might be their 12 Royal Mail Group, where that group function supports
13 client? 13 those individual divisions. In fact, it's generally the
14 “Answer: Yes, sorry, yes. 14 case in most companies were you have a group set-up.
15 "Question: _ I'm talking about responsibility for the 15 So this structure is not unusual. And in that -- in
16 conduct and work of the lawyers. That fell, if I'm 16 the Royal Mail Group Legal team, it would also not be
17 right, to Royal Mail Group to manage and oversee? 17 unusual for that -- a team of that -- a part of that
18 “Answer: My understanding at the time was that was 18 team to be dedicated to Post Office Limited, and for
19 also under the supervision of the Company Secretary at 19 that team to have a dotted line into Post Office
20 the Post Office, in conjunction with the Royal Mail, and 20 Limited.
21 they used, I thought, a mix of Post Office Legal Team 21 So, you know, when I read these responses, they seem
22 augmented by Royal Mail Legal Team and outside legal 22 to be quite confused but it's very clear: Royal Mail
23 people, as well. That was my understanding." 23 Group had group functions. Those group functions
24 Did you discuss with Mr Crozier how the legal teams 24 assisted the divisions that worked within Royal Mail,
25 were structured across the group when you were at Royal 25 and that included the Legal Team supporting POL with,
37 38
1 I think, people who were dedicated to POL in that Legal 1 summary?
2 Team. So this is not an unusual structure in any way, 2 Yes, but also, sir, this point about -- obviously,
3 shape or form. 3 there's been some confusion with people as to -- the
4 Did you not see there being a problem with the Chief 4 first piece of confusion was, you know, did the --
5 Executive Officer of Royal Mail Group not being aware of 5 people not knowing that Royal Mail carried out these
6 precisely what the Legal team within Royal Mail was. 6 prosecutions, which it's been doing for a long, long
7 doing, namely involved in the prosecution of 7 period of time, and then, secondly, the structure of
8 subpostmasters for Post Office Limited? 8 where the Legal Team sat in Royal Mail and POL. And
9 Well, I think that's a question you need to ask the CEO 9 what I'm saying to everybody is this structure is not
10 of the Royal Mail. I mean —- i 10 unusual in any way, shape or form, and it's slightly
11. SIRWYN WILLIAMS: Gentlemen, I think I've got the general 11 surprising that people didn't know that this was the
12 structure quite a long time ago and I got Mr Crozier's 12 structure and this is how it worked.
13 evidence that he didn't know about it. Whether he 13 SIRWYN WILLIAMS: Well, clearly you knew.
14 should have known about it is quite another thing. 14 A. Absolutely.
15 MRSTEVENS: Mr Leighton, can I ask you this, then: why is 15 SIRWYN WILLIAMS: Yes.
16 it that you didn't discuss Royal Mail Group's legal 16 MRSTEVENS: I want to come back, Mr Leighton, to something
17 responsibilities with Mr Crozier? 17 you said in your evidence last time, which I repeated
18 A. Because we -- he never -- we'd never raised it as 18 this morning, which was, in relation to the roles of
19 an issue -~ 19 a Non-Executive Director or Chair, that the most
20 SIRWYN WILLIAMS: Again, Mr Leighton, can I shortcut this: 20 important thing is to have some set processes to make it
21 the impression I get from you is that, rightly or 21 clear where the responsibility lies.
22 wrongly, you did not discuss these issues, either 22 The Inquiry has also heard evidence from David Mills
23 formally in a Board or informally with anyone else, and 23 and Alan Cook. For example, Alan Cook said he wasn't
24 the reason you have given me is that because these 24 aware of the prosecutorial decisions being made in-house
25 issues were never raised with you. Now, is that it, in 25 until 2009. Do you accept any responsibility for the
39
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fact that key figures - Adam Crozier, David Mills, Alan
Cook -- appear to be confused about the role of Royal
Mail Legal and the oversight of prosecutions?
A. None at all.
Q. Why not?
A. Because it's very ~- to me, it's all been very clear
exactly what that structure is and these are executives
in the business working full time in the business and
I'm somewhat surprised that they didn't understand the
structure.
MR STEVENS: Sir, that's probably a good time to take the
morning break because we'll move on to a separate set of
topics thereafter.
SIR WYN WILLIAMS: I had assumed that Mr Leighton's evidence
would be completed reasonably quickly, since we dealt
with him for a couple of hours, and I'm anxious about
the timing for today altogether, if you see what I mean.
How much longer do you expect Mr Leighton to be giving
evidence?
MR STEVENS: Half an hour, sir, if that.
SIR WYN WILLIAMS: Fine. Okay, fine. That's fine.
MR STEVENS: I think with the transcriber it would be better
to have the break now.
SIR WYN WILLIAMS: Yes, by all means. Sure. So what time
shall we resume?
41
A. I would imagine so, yes.
Q. "The Chairman reported that he had become aware that
a suggestion may have been made by a DTI Minister that
Mr Colin Baker, General Secretary of the NFSP, should
become a Non-Executive Director of Post Office Limited.
After careful consideration the Board agreed that it
would reject the proposal, if made, for the following
reasons ..."
Firstly, and we can summarise them: Colin Baker's
position with the union would be compromised by a closer
relationship; over the page, a Non-Executive Director
would need to be independent of the day-to-day executive
affairs; and then another matter about the Nolan rules.
Do you recall that discussion?
A. I don't recall the discussion but I can see what the
discussion was from this note, yeah.
Q. Atany point, at this point or thereafter, do you recall
the Board considering whether there should be
a subpostmaster representative on the Board?
A. Not past this particular point, no.
Do you know why that was?
A. I think, for the reasons that are given here. I think
it's -- I think these are good reasons why this couldn't
happen. There would be a big conflict of interest and
the other piece of this is the Nolan rules are quite
43
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MR STEVENS: If we could say 11.00, sir.
‘SIR WYN WILLIAMS: Fine.
MR STEVENS: § Thank you.
(10.51 am)
(A short break)
(11.00 am)
MR STEVENS: Sir, can you still see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR STEVENS: I wanted to look at a topic about Board
composition. Would you agree that subpostmasters, as
individual businesses, invested significantly in the
Post Office Network?
A. Absolutely.
Who, at Board level, was considering their interests?
A. The team that were -- the POL team, the MD of POL and
the Chair of POL, and all the other Board members of the
Royal Mail.
Q. Could we look, please, at POL00021487, so a meeting of
the Post Office Limited Board on 23 February 2005. We
see, third from the bottom, you're in attendance. On
“Appointment of Directors", at the bottom of this page,
please, it says the Chairman -- pausing there, I'm
assuming that's referring to Sir Michael Hodgkinson as
Chairman of the Committee, rather than you as Chairman
of Royal Mail?
2
42
explicit on that you need to have a number of criteria,
of which part is quite a significant commercial
criteria.
So I think this was a -- the right decision, and
made sense. But, also, I think it's this point made
before: the interests of the subpostmasters was driven
by POL but also all the members of the Royal Mail Group
Board. Only this issue, and the significant tragedy, of
the Horizon issues and the systemic issues off the back
of that -- but in support of the Post Office and
subpostmasters, in my time at the Royal Mail, that was
always very significant across the Board, both boards.
Q. That can come down. Thank you.
I want to look at oversight of Horizon. I think you
agree, you say in your witness statement that the
transaction data recorded by Horizon was used to compile
Post Office Limited's management and statutory accounts?
A. I think so, yeah.
Q. A director of a company is required to prepare a set of
accounts that gives a true and fair view of the state of
affairs of the company; would you agree with that?
A. Yes.
Q. So the director must be able to have confidence in the
data being used to prepare those accounts?
A. Yes.
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So any allegation of a lack of integrity in the data
produced by Horizon would have been a significant issue
for both Post Office Limited and Royal Mail Group?
Yes.
Can we turn to your statement, please, page 18,
paragraph 35. You say:
“My main recollection of the Board's oversight of
the Horizon IT project is that a key focus, and repeated
discussion point within the Board of [Post Office
Limited], related to the timeline and headline content
of the project, the cost and its value for the UK
Government and by extension the taxpayer. This is
evident from the minutes provided to me by the Inquiry
but I also recall that, from the time I began working
with [Royal Mail Holdings] and [Post Office Limited],
[Post Office Limited] was in a difficult financial
position, and Horizon represented a significant cost.
I knew that projects of this nature often took
significantly more than the planned time and cost to
implement properly. This was therefore an area that was
tested by the Board -- the company needed a system which
was fit for purpose and represented value for money.”
Do you recall being told anything about Horizons
fitness for purpose when you served on the Board?
All of the time. I mean, the most significant thing
45
has heard evidence that Fujitsu thought this had been
resolved by the S90 release.
Can we look, please, at POL00032210. It's a Board
meeting on 20 April 2006. If we could please turn to
page 10. We can go down to the "Operations Report"
section, please. We see it says "Horizon S90
Release" -- firstly sorry, pausing there it says, "The
Board noted the report and in particular that"; where it
says "noted" does that mean that there was any
discussion on the report?
I can't recall it was such a long time ago, but I would
imagine there would have been some discussion on it.
"The Horizon S90 release", number (iv):
"provide for a plethora of change requests across
a variety of existing capabilities."
Do you recall whether or not any questions were
asked as to what changes were made to the system or if
there were any bug fixes?
No, I can't but I do read:
"The release continued to make good progress. There
had been number of issues in the pilot but these had
been quickly diagnosed and resolved."
And that's what we'd expect to see. We'd expect to
see what's actually happening, what's the state of play,
if there are any issues, are they being resolved? And
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about this Horizon project, and it's reflected in
certainly all the documentation you've given me, there's
not a Board meeting that goes by where it's not talked
about, and that's very unusual for an IT system, even
an IT system of this scale. So the amount of oversight
on Horizon within the organisation as a whole was
extremely high.
We won't go through them but would you accept that a lot
of the discussion at Board level was on the negotiation
of contracts relating to Horizon, rather than the
technical oversight of it?
No, I -- if you read -- certainly from the Board minutes
I've read, a lot of the discussion and a lot of the
documentation is absolutely about the enabling impacts
of Horizon. All of the new releases -- I mean, this is
a - this is a massive IT system with multiple releases,
with millions of transactions, which -- as all these
systems have -- have problems and issues along the way,
and I feel very confident, having read all the papers
and reminded myself, that the oversight on this -- on
the project, the Horizon project, was probably more
significant than I'd ever seen on any IT project.
You've referenced releases. The Inquiry has heard
evidence about the Callendar Square bug, the bug that
caused discrepancies in branch accounts, and the Inquiry
46
that, I think, was the theme of Horizon for a long
period of time.
So when you are referring to the oversight and the
detailed oversight you said, at Board level, this is the
type of thing?
This is the type of thing. "Network Resilience" is
a good example:
"... the software necessary to deploy ... for 2,000
large branches and ... solution to limit the period of
downtime for smaller branches", which was now ready for
implementation.
These are significant steps on the evolution of
Horizon.
That can come down. Thank you.
At paragraph 36, we don't need to bring it up, you
refer to a visit to Chesterfield, which was where the
Product and Branch Accounting was based at Post Office
Limited, and you say:
"Although there appear to be some day-to-day issues
that the staff in the office were dealing with, I do not
recall there were complaints which indicated major
issues with the system."
What were the day-to-day issues you were told about?
Again, I can't recall what they were, it was such a long
time ago. But most of the day-to-day issues were about
48
(12) Pages 45 - 48
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The Post Office Horizon IT Inquiry
slow running and some outages, and things like that.
The major point is, at no stage in any of the
documentation is there any clue that there's a systemic
issue with Horizon, and the opportunity for that to
arise is significant, because there's not a Board
meeting of the Royal Mail Group or the Post Office
Limited where that Horizon is not discussed.
Can we look, please, at POL00107538.
This is a letter addressed to you from Sir Alan
Bates on 7 August 2003. Paragraph 51 of your statement,
we don't need to turn it up, it says:
"I do not recall receiving these letters and I do
not know if I did.”
To be clear, is your evidence that you cannot
remember whether you did or did not receive them?
That's my evidence. But it's -- it looks more than
probable that I didn't because of what happened post.
So you can see that it's obviously been passed on to two
people -- in the top right-hand corner, that's not my
writing. And then in all the subsequent responses to
this, which went over quite a long period of time, about
six months, I'm not copied in on any of them. So
I would say the likelihood is I never saw this letter.
But I can't say for definite I didn't.
We see at paragraph 3, it says:
49
different exchanges between that which go on for quite
a long period of time. Lots of different people engaged
in it.
Obviously you worked at the company and with the people.
Do you have any insight or can you assist us with why
a letter like this wouldn't be passed up to you?
Lots of letters would not be passed up to me. You know,
I think other people have said the same: we would get
hundreds or thousands of letters and, often, they would
not come to us, they would be handled by one of the
Complaints Department or another department, and we
wouldn't necessarily see them. If we -- one thing's for
sure, if I'd have seen this letter, then I would have
been copied in on the correspondence post it.
Could we please look at POL00161769.
I think it's a very important letter, I think it also --
I want to say -- and I think you've seen, certainly in
the documentation, that the process -- there was
a process that was taken past this letter, which is the
process I'd expect to see, which is somebody responded
to it, another letter came back, there were more pieces
of dialogue. I think at one stage an MP got involved.
Then, to make sure there was not a biased response,
I think one of the --
Just pausing there, sorry, Mr Leighton, if your evidence
51
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"It is again trying to use what seems to be so often
described as its outdated 'Stalinistic' management
approach, in order to bludgeon its will onto the poor
subpostmaster, with an issue that could bankrupt every
sub post office in the country. Whilst I appreciate the
principle can be expensive, I cannot agree to any
position which would leave me (and every other
subpostmaster) liable for claims of millions of pounds
from the Post Office without any redress or access to
data to check such claims."
Then it goes on at page 3, paragraph 2 to say:
"My personal belief, based on my experiences and
from stories I hear, is that the Post Office are having
considerable problems with the Horizon software, and
that was especially true in the early days."
That effectively summarises the scandal, doesn't it,
or the problem that the subpostmasters were facing?
I think probably, yes. I mean it's hard to judge but
So this letter, who would be handling it on your behalf
if you say you didn't see it?
Well, I think it's the people on the -- if you look at
the top, I think there's a series of correspondence post
this from different people, who respond to Mr Bates,
I think there's a -- sorry, Sir Alan Bates. There's
50
is that you were not involved in that process, we can
read the documents to see what happened.
No, okay, I'm just saying that if I'd -- the process
that was then taken on board post-this would be the
process I would expect.
Please can we bring up POL00161769. If we could go to
page 8, please, you see there's an email from Karen
Arnold to Mr Hughes, 2 July 2006, asking for an update
about Hoylake:
"... is the [subpostmaster] still maintaining his
allegations about the Horizon system, I guess if this is
still the case then we won't be able to get it rolled
over..."
If we turn to page 7, please we see the response:
"Karen, [ex-subpostmaster] still raises issues
around Horizon hence our inability to reopen."
Then it goes on:
“When I reopened Gaerwen late last year within
a couple of hours of audit, I had to close almost
immediately because of a similar scenario."
Could we then, please, go to page 5. Mark
Partington's email on 5 July:
“We need to weigh up the cost to the business of the
installation at short notice of a new kit and the
configuration of this by Fujitsu. Against this we have
52
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The Post Office Horizon IT Inquiry
a closed branch, and the loss to the business this is
resulting in, and the exceedingly bad PR we will receive
if we cannot open this branch in the next week or so."
Then, bottom of page 2, please. You see an email
from John Breeden there 6 July. Go over the page:
“As mentioned on the phone the Chief Executive of
the local council has written again seeking assurances
this branch will be opened by the start of the Open Golf
later this month. I am pleased to see progress is being
made with the recruit of an interim.
It's probably a matter of public record, that's the
Open Championship at Hoylake. If we go to page 2,
7 July:
"Just to advise you I have been made aware that
Allan Leighton has been asked to be kept informed on
progress on the reopening.”
Do you recall what reasons you were given for the
Post Office being closed?
No.
Presumably, whether or not a Post Office is open or
closed isn't something that you would, as Chair of the
Royal Mail Group, usually get involved in?
No, unless in this particular case, what -- and again
I can't recall this but what it seems to me, I'm asking
about the reopening, so I think somebody has asked
53
"My understanding is that the integrity of the
Horizon data is sound and it is as a result of this that
persistent challenges that have been made in court have
always failed."
The Inquiry has heard evidence of the various
challenges that were made to Horizon. Again, is your
evidence that you were never informed of any of these
challenges in courts?
Absolutely. The systemic issues and some of the bugs
that came out since were never brought to either me or
the Board's attention.
If the Board, or the system, was operating as you think
it should have done, who should have brought those
concerns to you, in terms of the challenges made in
courts?
That should have come up via the operation and the legal
functions.
So the operation and legal functions?
Yeah.
So that included the Company Secretary?
Who would be head -- if the company secretary at this
stage -- i's 2010 -- I don't know, was in charge of
Legal. I've not seen this document so this is after
I've gone, presumably, isn't it?
Yes, yes.
55
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a question about will this post office be open for the
golf?
Yes, there's a massive golf tournament going on, which
encourages a lot of tourism, and you're being asked when
it will reopen.
I think that's what it looks like, yeah.
Surely, in those circumstances, would you not ask the
reasons as to why the post office closed?
Not necessarily, no.
Why not?
I just wouldn't. I'd be asking the question here about
why -- you know, when will it be reopened? I will be
addressing the question.
In order to address that question, you wouldn't have
thought it relevant to ask the reasons why it was.
closed?
No.
If we look, please, at POL00106867.
We see an email from Rob Wilson, Head of the
Criminal Law Team at Royal Mail; do you remember Rob
Wilson?
Not really, no.
3 March 2010, that's after you finished --
Yeah.
~- as Chair. It says:
54
Okay, yeah.
That can come down, thank you. I've one more point
I want to ask you on, please. Could I please have
POL00120833. It's an Excel spreadsheet. If we could go
to the "Risk/Opps" tab, P5, it says at the bottom. The
Inquiry has seen this before. It's been described as
a register of risk within the IT Directorate for Post
Office Limited. Would you have seen a document like
this at the time?
No.
If we look in the description, the first row, beneath
that, the description is:
"Damage to reputation of Post Office and potential
future financial losses if Post Office loses court case
relating to reliability of Horizon accounting data at
Cleveleys branch office."
Then "Action":
“Royal Mail Legal services have made an offer for
out-of-court settlement of the case.
“Review with Fujitsu of their processes to protect
against similar future cases."
We see the risk is put at £1 million.
From your perspective, should that have been raised
to the Royal Mail Group Board as a risk?
Which one?
56
(14) Pages 53 - 56
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The Post Office Horizon IT Inquiry
Q. The damage to reputation -- the first risk which
just —-
A. But is that being specific about that one branch office,
or -- I'm trying to
Q. Well, if we see, it says:
"Damage of reputation of Post Office and potential
future financial losses if Post Office loses court case
relating to the reliability of Horizon accounting data
at Cleveleys branch office.”
So it's referring to one case, namely the Cleveleys
case, but would you accept that it's raising the risk of
potential future financial losses?
A. Well, it's certainly -- it is but the risk that it's got
attached to it is -- looks relatively low. So if you're
asking me would I expect that that particular -- that
particular point to come to the Royal Mail Group Board,
probably because the level of risk is so low, probably
not.
Where are you saying that's a relatively low risk?
Well, 1 million.
Sorry?
1 million.
see. So because of the quantification of the risk?
Yes. So the level of risk plays a big part of what
comes into the risk thought process.
57
POoOrOoOPryo
A. -- and that basically it was made clear that the
prosecution would not succeed because there was.
a systemic issue in Horizon, and, for me, that would
have been a significant point.
SIR WYN WILLIAMS: = Right. So that I can understand this, in
the Cleveleys case -- and this may -- just to ensure
that we are not at cross purposes -- there had been
obtained a joint report, it was civil proceedings not
criminal proceedings, and there'd been a joint report
from an expert which suggested -- and I use the layman's
terms -- problems with Horizon, which had caused the
loss. As a result, that case was settled by the Post
Office.
Now, are you telling me that had you, not
necessarily in your capacity as Chair of our Royal Mail,
but as a senior Royal Mail or Post Office person, been
aware of an expert report which suggested problems with
Horizon, and, as a consequence, the Post Office were
proposing to settle the case, that that is something
which should have been taken very seriously and
investigated?
A. Absolutely.
‘SIR WYN WILLIAMS: So when earlier this morning Mr Stevens
took you to -- I'm now not quite sure whether it was
a policy or what, but let's call it a policy, whereby
59
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Q. But the fact that it says that the court case relating
to the reliability of the Horizon accounting data, that
wouldn't trigger it going higher, in your view?
I'd be guessing.
I'm going to ask you a hypothetical. If you had seen
this at the time, what do you think you would have done?
A. Well, I saw in the papers the Cleveleys piece. So, if
I'd have seen the Cleveleys piece, then that would have
raised a real issue.
Q. When you say that, do you mean the advice --
A. Yes, that would have raised a real issue.
Q. What would you have done, having read that advice?
A.
Q.
oP
I'd have had a massive dig into everything around it.
That document can come down. Thank you.
Sir, those are the questions I have. Do you have
anything?
Questioned by SIR WYN WILLIAMS
SIR WYN WILLIAMS: Yes, I wasn't quite clear about that last
answer. Did you say of the Cleveleys piece,
Mr Leighton?
A. Yes, sir, in the --
SIR WYN WILLIAMS: What do you mean by that, sorry?
A. In the documentation, there's a note on what happened at
Cleveleys --
SIR WYN WILLIAMS: Yes.
58
litigation which was going to cause very substantial
financial loss or relate to important policies of the
Post Office, should be brought to the Board, then this
case would have fallen into that category, in your
opinion?
A. Absolutely.
‘SIR WYN WILLIAMS: Fine. While we're on that, a couple of
years later Mr Castleton was sued, as you probably know
from press reports, by the Post Office for
a comparatively small sum of money, about £25,000. In
that case, he maintained that there were no losses to
the Post Office, that -- these are my words -- it was
all a figment of Horizon, rather than being a real loss.
That case was litigated in the High Court. Is that
also the sort of case, in your view, which should have
been raised to the level of the Board, given what was
involved in it?
A. I think the answer is yes, sir. I think the Cleveleys
‘one, in a strange way, more so because it meant that
a prosecution didn't take place.
SIR WYN WILLIAMS: All right. I take it that it's your
evidence that, at the time -- namely in 2004, Cleveleys;
2006, Mr Castleton -- you and/or the Board knew nothing
about them?
A. Absolutely, sir.
60
(15) Pages 57 - 60
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SIR WYN WILLIAMS: Fine. Sorry, Mr Stevens, but I wanted to
be clear about that.
MR STEVENS: Yes. Not at all, sir.
In fact I think I should clear one thing up, because
I can see the list of documents sent to Mr Leighton and
can we just bring on screen POLO0118229. When you were
earlier referring to a document on Cleveleys, was it
this document?
A. I think so, yes.
MR STEVENS: So that being the advice. Thank you. That can
come down.
Sir, I believe Mr Stein has two minutes’ of
questions. I think that's it: Mr Stein with two
minutes’ of questions.
‘SIR WYN WILLIAMS: Right. Over to you, Mr Stein.
Questioned by MR STEIN
MR STEIN: Mr Leighton, one area whereby information should
have been relayed to a board -- we'll talk about which
board in a moment -- could have been via company
accounts? So if we think about the situation that was
‘ongoing, as we know it, within the investigation and
prosecution of subpostmasters, somewhere within
accounting there should have been: the costs of that
system ongoing; costs including the costs of
Investigators; costs of the actual prosecutions; money
61
I suppose things can't be just pretty unique -- but even
though it is a very unusual situation for a company to
prosecute its own people, in other words subpostmasters,
you are saying that you don't think it is likely that it
would have had a separate accounting?
A. I think so, yes.
Q. Allright.
Ona slightly more granular level, there must have
somewhere been accounting for those costs within the
organisation. It must have existed at some level, do
you agree?
A. Yeah, but probably not in a joined-up way as you
described.
Q. Right. So in other words, the individual costs of
prosecutions, the number of prosecutions, it must have
been known about at some point within the accounting
department at --
A. Yeah, in -- well, it would probably show in the
divisions where that money was taking place. II'm sort
of not 100 per cent, but based on what I would imagine,
what I know on what I see every day, I would imagine it
would show in each cost centre of the individual
division that was responsible for that particular piece
of activity.
MR STEIN: Right. Thank you, Mr Leighton.
63
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26 July 2024
coming back another way, which is via the court process,
which would include any recovery of monies through those
processes; and then through the civil system of
investigations, the taking of individuals to the civil
courts, the same?
One other aspects of costs that we have been hearing
about within the Inquiry has of course been the costs
of, on occasions, when there was information requested
from Fujitsu to support prosecutions or civil actions,
those costs as well?
So, in that general area of costing, do you agree it
would have been somewhere in company accounts?
A. Not necessarily.
Right. Help us understand why not.
A. Largely, when -- those types of issues would be picked
up with the auditors. So what tends to happen, you have
a discussion with the auditors about what you disclose,
what you don't disclose, what needs to be -- so I would
imagine if a -- and I don't know this -- a conversation
may well have taken place along that line, and the
auditors would probably have said that, you know, that
sort of disclosure is not necessary. It is -- we're in
a - we're a unique organisation but it would be quite
unique to show that in a set of accounts, I think.
Q._ Even though it’s a unique situation or pretty - well,
62
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THE WITNESS: = Thank you.
SIR WYN WILLIAMS: I Is that it, Mr Stevens?
MR STEVENS: Yes, sir, that's it.
‘SIR WYN WILLIAMS: Let me thank you, Mr Leighton, for
returning to give evidence before the Inquiry. There
was unfortunately a long delay between your two
appearances but, as I expect you'll have understood, we
have been busy hearing from a great number of people,
and we couldn't fit you in more quickly than we did.
But I'm very grateful to you for coming back and for
answering the further questions.
THE WITNESS: Thank you.
MR STEVENS: Thank you, sir.
I think it would be best to take a 10-minute break
now, more time efficient, and then we run until lunch.
So if I could say we come back at 11.45.
‘SIR WYN WILLIAMS: Certainly.
MR STEVENS: Thank you, sir.
(11.35 am)
(A short break)
(11.45 am)
MR BLAKE: Good morning, sir. Can you see and hear me?
SIR WYN WILLIAMS: Yes, thank you very much. Yes.
MR BLAKE: Can I call Mr Edwards, please?
MARTIN ANTHONY EDWARDS (affirmed)
64
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Questioned by MR BLAKE
MR BLAKE: Can you state your full name, please?
A. Martin Anthony Edwards.
Q. Thank you. Mr Edwards, you should have in front of you
a witness statement.
A. Yes.
Q. Can I ask you to have look at that witness statement.
Is it dated 18 April this year?
A. Yes.
Q. Could I ask you to turn to the final substantive page,
please, that's page 45. Can you confirm that that is.
your signature?
A. Itis.
Q. Can you confirm that that statement is true to the best
of your knowledge and belief?
A. itis.
Q. I believe there's one change that you would like to make
to that statement?
A. Yes.
Q. Can you assist us with what that is?
A. So, paragraph 23.
Q. Perhaps we could bring it up on the screen. It's
WITNO9760100.
A. So the sentence beginning "The reports I refer to".
Q. It's page 8, paragraph 23, it's about halfway through.
65
terms, so middle management.
Q. You joined the Post Office in September 2012; is that
right?
A. Yes.
Q. Did you know anybody at the Post Office when you joined?
A. No.
Q. I mean, we've heard from, for example, Patrick Bourke
and Mark Davies, both of them previously worked in the
Civil Service or as Special Advisers. You weren't aware
of them before?
A. No, I hadn't dealt with them in my previous life, no.
Q. In your role at the Post Office, you were Chief of Staff
to Paula Vennells; is that correct?
A. Yes.
Q. If we could bring up your witness statement onto screen,
please, and if we could start paragraph 4. You've set
‘out your evidence as to the role that you played. It
begins at paragraph 4. About halfway down you say as
follows:
"A major part of the role involved coordinating and
editing numerous briefings, reports and correspondence,
either going to [Paula Vennells] (for example to prepare
her for meetings) or being issued from her, such as
letters to external stakeholders or updates to the [Post
Office] Board. The substance and technical detail for
67
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So please could we delete "POL's prosecution process"
and replace that with "the Cartwright King review".
And to explain, at the time, in preparing my witness
statement, I hadn't seen the Altman advice and I was
relying on a secondhand summary of that advice, which
led me to believe the quote of "fundamentally sound"
referred to the prosecution process in general.
Having now seen the Altman advice, I understand he
was specifically referring to the Cartwright King
review.
Thank you very much. That statement can come down, and
the statement will be uploaded onto the Inquiry's
website.
By way of background, after graduating university
you joined the Civil Service; is that right?
Yes.
Where you worked for about 11 years?
Yes.
I think you worked in the Treasury, UK Financial
Investments, the Home Office and the Scottish
Government; is that right?
Yes.
Can you assist us with what grade you reached in the
Civil Service?
It was what was known as a Grade 7 in Civil Service
66
these documents would typically come from the relevant
SMEs..."
Is that Subject Matter Experts?
Yes.
"... for the topic in question, and my role was to edit
this information to ensure the end product was suitably
clear and succinct for the target audience."
If we move to paragraph 31, which can be found at
page 11, you say, in broadly similar terms:
"My role as part of [Paula Vennells'] office was to:
(a) ensure the briefing was provided on time to inform
the engagement; (b) edit the document to ensure that it
covered an appropriate amount of detail, taking into
account the target audiences's time constraints; and (c)
make sure that it was clear and succinct. When the
topic was not entirely familiar to me, I would prepare
the draft briefing paper and then send it to the
[Subject Matter Expert] to check that the important
messages had been captured correctly and comprehensively
in my summary."
Turning to paragraph 50, that's at page 22, you say:
"My involvement with [Post Office's] preparation
for, and response to the Second Sight Interim Report was
consistent with the responsibilities of my Chief of
Staff role. As noted above, my role was primarily one
68
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of a conduit: to collate information from the relevant
business leads and SMEs, then to synthesise such
information into an accessible format for [Paula
Vennells], the Board or other audiences."
Moving on to paragraph 99, that's page 44, again,
similarly:
"I was not the [Subject Matter Expert] on any
particular issue, nor did I have any substantive
decision making accountabilities."
So it seems from your statement that your role was
principally one of a conduit, that you relied on Subject
Matter Experts and that you didn't have decision making
accountabilities; is that correct?
Yes.
Moving now -- that can come down, thank you -- to the
initial months in your post, you became aware of the
Computer Weekly interest in matters relating to Horizon
quite early on; is that correct?
Yes, very soon after I'd joined, I was asked to join
Paula in a meeting with James Arbuthnot and Alan Bates,
for an update on the Second Sight investigation.
I think that was within two weeks of me joining, so as
part of getting ready for that meeting, I was brought up
to speed on the issues.
Thank you, Sorry, one matter I forgot to ask you about.
69
around stakeholder engagement and public affairs, we
need as a business to work more effectively at bringing
together our collective knowledge, particularly in the
Government space.”
Were you aware of a greater degree of coordination
taking place in the business at this time, in respect of
the public responses to matters such as Horizon?
I think this email and the driver for it, it partly
related to the Horizon matters but I think it was
broader than that. There were lots of interactions
underway with Government at the time, funding
negotiations, seeking to win new business from
Government, discussions around the future of the
network. So I think the drive for greater coordination
was across all of those fronts.
Was there a greater centralisation of company messaging?
There was certainly a desire for greater coordination,
lots of different bits of busy would come into contact
with the Government and I think there was desire from
the Communications Team to bring some more coordination
to that.
"Key to this is a degree of discipline around planning
of meetings and coordination of messaging at such
meetings. Being more aware of what meetings are being
held and when will enable us to ensure that the right
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After your Chief of Staff position, you moved in 2014
and you became Group Strategy Director; is that right?
Yes.
Then you have worked in various other roles since then
at the Post Office and you are still employed by the
Post Office?
Yes.
What role to you currently have?
Currently Network Strategy and Delivery Director.
Does that involve liaising with subpostmasters?
Yes.
Thank you. I'm going to turn to my first document which
is relatively early on in your time at the Post Office.
It's a January 2013 email. Can we please turn to
POL00380018.
By this time, you've had a meeting with Second
Sight, James Arbuthnot and Alan Bates?
(No audible answer)
Presumably you joined at a time when those kind of
issues, the Horizon issues, were rather prominent in the
company?
Yes, they were, yes.
29 January 2013. This is an email from Mark Davies,
Communications Director. He says as follows:
“As we move towards a greater degree of coordination
70
messages are delivered, and that we can ensure clarity
of messaging. There is real reputational risk at play
when we don't have this oversight."
It then says, further down:
"Alongside this we are developing more disciplined
and coordinated approach to briefing materials", and it
sets out who is responsible for that.
Then it goes on to say:
“I will go into more detail on this when I update
[the Executive Committee] on the wider changes to our
communications approach. But as a first step I would be
grateful if you could ask your office and your team to
ensure:
"That all government ... and other stakeholder
meetings are communicated in advance ...
"The short readouts of all such meetings are sent to
[those two individuals] for appropriate cascade.”
This was sent to you, presumably as part of Paula
Vennells' team at that time?
Yes.
Could we please turn now to POL00097786. Moving now to
March of that year. This is an email from yourself to
Mr Davies and you say as follows:
"Would be good to have a quick word in the morning
about MP handling [regarding] the Horizon investigation.
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Paula asked me on Friday morning whether I still thought
it was the right call that we should not attend the
meeting with Arbuthnot and co -- I said yes on balance,
but it might be sensible to get a separate opportunity
for her to engage directly with the relevant MPs, given
that she was persuasive and convincing in explaining
that we're taking this all seriously and are changing
culture of the Post Office ..."
So there was due to be a meeting of Members of
Parliament with James Arbuthnot and the decision had
been taken that Paula Vennells shouldn't attend that
meeting; is that right?
Yes, as I recall, yeah.
"I said I'd discuss with you."
You say at the bottom:
"Looking at the list, Tessa Munt is obviously a good
friend of ours (and fan of Paula) -- I wondered if it
was worth Paula speaking to her before the meeting to
feed in our side of the story. Although not without
risk, so I'm unsure. Let's discuss."
Now, in this email, you're not synthesising, you're
not gathering the views of Subject Matter Experts; it
does seem as though you are playing a role in the
advising Paula Vennells about her attendance at
a meeting. Is that a fair summary?
73
Can you assist us, what was the meeting that was
taking place at this time?
I think the meeting was particularly to discuss --
I think it was about this time that the two bugs which
were disclosed to the Second Sight Report had been
shared with the Executive Team. As I recall, it was
a meeting with the likes of Lesley Sewell, Alwen Lyons,
Mark Davies and Paula. The primary purpose of the
meeting, as I recall, was to get more detail on those
bugs, and understand the detail behind them, but I think
it's the meeting then moved on to the wider progress of
the Second Sight investigation.
If we scroll up, we can see your response. In the
second paragraph, you say:
"My only other concern at the meeting was around the
feasibility of some of the options/levers that [we]
raised. As discussed we need to think about a Plan B
given the likelihood that James wouldn't agree to delay
the meeting/report.”
So at that point in time, there was discussion over
whether the Interim Report itself could be delayed or
not published; is that right?
Yes, certainly a range of options were raised at that
meeting.
"We also need to be very careful not to overplay our
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Yes, that's a fair summary, yes. That would be part of
the role.
Part of your role it seems, having been in the Civil
Service, I think you had a fair understanding of Members
of Parliament and perhaps that was an area in particular
that you considered you were able to advise on?
Yes, probably more so on the Government side than the
Parliamentary side. I think Mark Davies would have more
experience on the Parliamentary side but, yes,
I certainly brought experience of Government issues.
So when we read your statement and those passages that
I've just been taking you to, where you set out your
role, can we add to that that did advise Paula Vennells
in respect of certain matters?
Yes.
Can we turn to POL00098777. If we could start with the
bottom email, please. This relates to the handling of
Second Sight before the Interim Report is published and
this is an email from Ms Vennells to you, and she says
as follows:
"Martin, I wondered if you had any further thoughts
‘on [James Arbuthnot].
"You were looking thoughtful throughout the meeting.
Although I didn't get the sense you were holding back --
you asked some good questions.”
74
hand with [Second Sight] -- they could turn out to be
quite dangerous if we threaten them with legal action or
attempt to replace them with another firm. Easy for
this to be portrayed in the media as heavy-handed
tactics because we don't like their findings (it plays
directly into the existing perceptions we're trying to
counteract)."
So it seems as though you are also advising Paula
Vennells in relation to media handling?
I mean, less media handling -- handling of issues
generally, she would sometimes ask for my advice on,
yes.
"So I think we're stuck with the softer option of
explaining to [James Arbuthnot] calmly but firmly why he
cannot allow Second Sight to disseminate a misleading
Interim Report -- it either needs to be delayed or
repositioned as a very neutral status update (with more
detail on the one case that has been resolved).”
He can't allow Second Sight to disseminate
a misleading Interim Report; what was misleading about
the Interim Report?
So we haven't seen the report at this stage but the team
which were working directly with Second Sight were
concerned about the direction it could go, there was --
the impression conveyed by the team was that there was
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a risk they might make statements before the evidence
had been gathered. There was a lot of pressure from
Parliamentary stakeholders to get a report out before
summer recess and there was a concern that that report
wasn't going to be fully evidence based.
It seems as though you have formed the view, though, in
this email that it was going to be a misleading Interim
Report. If that's the case, where did you form that
view from?
So, I don't think -- I hadn't formed that view
independently. That was the concern being conveyed by
the team working with Second Sight. The team were
concerned about that risk and a range of options were
being discussed about how to handle that. I think I was
steering the conversation away from some of what felt to
be more overly aggressive options.
What was your personal individual knowledge about what
the Interim Report was likely to say?
I was wholly dependent on what the team were briefing us
‘on this. I had no direct insight into the reports.
Who was the team?
So the team closest to it is Susan Crichton, Simon
Baker, Lesley Sewell, Alwen Lyons.
The passages I took you to in your witness statement
earlier, about the involvement of Subject Matter
77
"Do you need me to dig out any more on this?
I think the key point is that the fact that Horizon did
have bugs has been discussed in court and [the Post
Office] still won the case."
If we scroll up to the top, we can see that Lesley
Sewell emails a limited number of individuals: Alwen
Lyons, you and Mr Davies, on an FYI basis. Why that
small number of people? What did you, the three of you,
have in common that needed that information drawn to
your attention?
So, again, I think this was a follow-up to -- it was
about this time that the two bugs which were disclosed
in the Second Sight Report -- and I think what was known
as the Falkirk bug, the earlier bug, had been shared
with the Executive Team, and Lesley in particular was
tasked with getting more detail and background on these.
I think she reached out to Gareth Jenkins for --
particularly on the Falkirk bug. So I think this was
a follow-up to that action and conversation.
Why to you?
I was part of that -- I was part of that group
discussing how we respond to the Second Sight Report.
I'd been in that earlier meeting which Paula had asked
me to join.
What did you know about Gareth Jenkins at that time?
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Experts, this is you giving advice to Paula Vennells in
relation to handling James Arbuthnot, handling Second
Sight. There's no direct involvement here of any
Subject Matter Experts, is there?
Not -- no, not in this specific email, but it's
a follow-on from a meeting with the Subject Matter
Experts.
Who would you consider the Subject Matter Experts, in
relation to the matters being discussed here, are?
So I think, on the contents of the Second Sight Report
itself, it was the team who were directly interfacing
with them.
Who is that? The names you mentioned --
The names I just mentioned before, yes.
Can we please turn to POL00098778. Thank you. So
a very similar time. This is the day after that email
exchange. If we scroll down, we can see that Gareth
Jenkins emails Lesley Sewell, attaching his witness
statement from the earlier Seema Misra case. He says:
"This was heard in Guildford Crown Court in October
2010 and concerned West Byfleet Post Office.
“Page 14 covers my response to a problem that had
been identified in an earlier case, (that involving Lee
Castleton who took [Post Office] to court for unfair
dismissal which he lost).
78
Nothing at all at that time.
Did you ask Lesley Sewell, "Who is this? What's this
all about?"
I don't recall any follow-up conversation to this.
I mean, I saw the -- I saw his role description at the
bottom of the email, described a Distinguished Engineer
at Fujitsu, and kind of took it from that that he was
the relevant expert on this topic.
At this point in time, had you had any discussions with
Paula Vennells about Gareth Jenkins?
No.
Could we please turn to POL00098806. This is the same
day. The top email is from Mark Davies, again, to the
small group. He say:
"This is massively important.
"Is there any possibility that all incidents -- 14
and 64 [those are the two bugs that you've mentioned] --
have been referenced in court?"
So Mark Davies seems to have seen it as massively
important, possibly because it showed that the Post
Office had previously disclosed the existence of a bug
in a court case. What did you do to familiarise
yourself with those underlying issues?
I don't recall any specific action myself. I think
there'd already been action underway to get more detail
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about the bugs themselves and, if I recall, off the back
of this, the Legal Team were tasked with understanding
what had been disclosed previously in court cases.
I don't recall seeing a follow-up to that.
There is then a meeting with James Arbuthnot on 3 July.
So soon after. I'm just going to begin by taking you to
2 July. Can we please start with POL00190092. By this
stage, you are part of group who is drafting a briefing
for Paula Vennells and Alice Perkins, I think in
relation to a discussion with James Arbuthnot; do you
remember that brief?
Yes.
Thank you. If we look at the bottom of the page, we can
see an email from Susan Crichton to you and to Mark
Davies as well, and it's sent from, it says, Alwen at
Susan. They say:
"Susan and I have pulled this together with help, so
it is now over to you, to work your magic and send on
the final document to Paula, Alice and me tonight."
So this, I think, the day before the meeting with
James Arbuthnot?
If we scroll up, we can see your first response, and
you say as follows:
"On the prosecution section of the brief there is
a half-finished sentence (see blow) -- what were you
81
(and this is why some prosecutions are still happening)?
Presumably there is some kind of reasonableness test
here -- ie a [subpostmaster] can't just get off
scot-free by saying it's an Horizon issue, irrespective
of the circumstances?"
Then below that, it has a section that had been
drafted and that had been sent to you and that reads as
follows:
“Prosecutions
"Where cases have been preferred to [Second Sight]
via JFSA these are subjective to the immunity agreement.
Where we have investigated subpostmasters since the
start of the [Second Sight] work, and the subpostmaster
has said that the Horizon computer systems has been key
to the issues that have arisen in the branch we have not
taken action against the subpostmaster."
So the immunity agreement was, if a case was lodged
with Second Sight, there would not be a prosecution?
Yes.
Then it continues:
"Where [the Post Office] takes legal action against
Then if we scroll up, that hadn't been completed in
the draft that you received; is that right?
Yes. So that was the sentence I was querying with Susan
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planning to say?! Was this going to cover the issue
around previous convictions? If not, what is our best
possible defence against the suggestion that this
process had called into question the validity of
previous prosecutions? Think we definitely need a line
on this."
So, at this stage, you were aware that there was
a concern that had been raised that Second Sight's
findings could potentially call into question the
validity of previous prosecutions?
I was aware it was a question which James Arbuthnot had
raised in previous meetings with Paula, so it felt
necessary to ensure she had a position to take on that.
Not just a position to take but a defence against that
suggestion?
Yes, informed by -- so, at this point, we hadn't seen
the final report but the preliminary view from Susan
Crichton and the Legal Team was there was nothing at
this stage to expect that it would change the safety of
previous convictions.
It then says:
"On the first bullet below, presumably we should add
a sentence to state that where it is clear that the
Horizon system isn't the issue at stake, we have a duty
to protect public money by pursuing appropriate action
82
and asking her to complete it.
Then if we scroll up, we can see Susan Crichton saying
to yourself and others:
"Hugh and I are just discussing will get back to you
shortly."
We can see a continuation of this issue at
POL00190132.
Thank you. Now, we have to be a bit careful reading
this email. If we scroll down, the best way to read it
is to begin with Susan Crichton's email, which is the
final substantive email on the page. Then she has made
comments below on the original email. So she says as
follows:
"Martin -- following your conversation with Hugh, he
and I have discussed and I think that this is the best
wording we can use (see below). The bottom line is that
this dialogue and resulting potential publicity -- could
increase the risk of appeals being made against previous
convictions, we have no reason to believe that those
appeals would be automatically successful we would have
to deal with each on a case-by-case basis. There would
be significant cost implications.
“It is interesting that neither of us can think of
one.”
So it seems as though she is outlining there to you
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that there is an increased risk of appeals and, although
they wouldn't be automatically successful, they'd have
to be dealt with on a case-by-case basis?
Yes.
Then, if we scroll down, we can see how she has filled
in that prosecution section. It now reads:
"Where cases have been referred to [Second Sight]
via JFSA they are subject to the terms of the immunity
agreement, which allows non-MP generated cases to be put
before the JFSA and/or [Second Sight].
“For criminal prosecutions we treat each matter on
a case-by-case basis, with an investigation and legal
review (generally involving external lawyers). We have
a duty to protect public money and take appropriate
action to safeguard such public money.
"In the event that any concern considers that there
has been a miscarriage of justice they have the right to
apply to the Court of Appeal to have their conviction
reviewed."
We can see your response on the first page. You
say:
“Thanks both.
"On the point about current investigations/
prosecutions, that's a significant weakening of the
reassuring line we discussed earlier. Can we add
85
publicity -- could increase the risk of appeals being
made against previous convictions, we have no reason to
believe that those appeals would be automatically
successful. We would have to deal with them on
a case-by-case basis".
She has amended the wording with some more balanced
and neutral wording over the page. Your comment there,
if we scroll up slightly, for example, on the past
convictions:
"... can we say that we're not aware of any cases
there we believe an appeal would now result in
a different judgment ..."
Where did you get that information from? You said
you spoke to Subject Matter Experts and that you relied
on Subject Matter Experts. Susan Crichton is a Subject
Matter Expert. You're proposing amending wording.
Where did that come from?
Well, I am asking her the question. In her covering
email, I think the -- if we could scroll back up to
it~
Down, I think.
Sorry.
Yes.
I think I took this -- this covering email and the
previous dialogue as quite reassuring. She includes the
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something along the lines of ‘since start of
investigation we have not pursued action against
[subpostmasters] where it is apparent that Horizon
system may be involved'?"
Just pausing there, where did you get that
information from?
I think it had been conveyed to me by Susan and Hugh.
The second paragraph says:
"And on past convictions, if pushed, can we say that
we're not aware of any cases where we believe an appeal
would now result in a different judgment (but clearly we
need to take these on a case-by-case basis)? Difficult
not to say something like this ..."
What research had you undertaken to be able to draft
both of those lines?
So these were -- as I referred to in the earlier emails,
there'd been conversations with Hugh and Susan about the
preliminary interpretation of the -- the implications of
this. So this wasn't based on personal research; this
was based on the messages I'd been given to them earlier
(sic).
The message is below though, isn't it? The message is
from Susan Crichton below. If we scroll down, we can
see what she says. She says:
"The bottom line is that dialogue and resulting
86
words "We have no reason to believe that those appeals
would be automatically successful", and goes on to say,
"It's interesting that neither of us can think of one",
which I interpreted to mean that neither of us can think
of grounds for a successful appeal. So that covering
email was reassuring and all of my dialogue which --
with Susan and Hugh, which preceded this email
exchange -- had been quite reassuring and strong on this
point, and it felt that Paula was clearly going to be
pushed quite hard on this point in the meeting with
James Arbuthnot, so I want to -- I'm basically asking
the team to give us the best line they felt comfortable
with.
But you're changing the line that she has provided you
with?
I'm asking "Can we say what you've said elsewhere and in
your covering email?"
If we scroll up, we can see you you're also
communicating thoughts from Mark Davies. You say:
"Mark just raised a similar point (with slightly
different suggestion on language).”
‘Are you quoting below from Mark Davies or is this --
Yes, I think that text in the darker font is a cut and
paste from an email from Mark.
So it seems as though Mark Davies had said:
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"Do they need an if pressed line on miscarriages of
justice? ‘Nothing has emerged in this report to suggest
a wrongful conviction. Cases have been through the
judicial process and we have never relied entirely on
Horizon in any court case’."
Your witness statement refers throughout to reliance
on Subject Matter Experts but it does seem as though we
have the Head of Communications here and the Chief of
Staff, drafting quite significant lines to take. Do you
agree with that?
I'd agree we're absolutely reiterating the lines to take
with the subject matter experts, I personally wouldn't
have put anything into a brief. I wouldn't have amended
something as significant as this in a brief without
checking back with the relevant Subject Matter Experts
and ensuring they were comfortable with this.
Okay, so --
So we are --
Before the final version is agreed, you would go back to
the Subject Matter Expert and consult them and ensure
that it's accurate and fair?
Yes, absolutely. I mean, all of this, as you can see,
is unfolding quite late at night, the day before the
meeting. So it's kind of very much happening in real
time. But what I'm not doing is unilaterally altering
89
So now we're at 11.00 at night, we have below Mark
Davies email but, again, we'll have to read that a bit
carefully because that's his email but with your
comments within it. So if we scroll down, he says:
"Current version is pretty weak.
"The speaking note needs to be firmer -- we want to
make clear our position and underline our view that no
evidence to support the systemic failures .
"It should specifically address the BBC point."
I think this is your wording in capitals, is it?
Yes.
"WHAT POINT SHOULD WE MAKE. GRATEFUL FOR SOME WORDS.
"A really key point is that we should not guarantee
to agree our media lines with [James Arbuthnot]. If he
comes out strongly as it sounds as though he will, we
will have no choice but to come back strongly. So am
concerned about the line where it talks about agreeing
media statements."
You say:
"SO SHOULD WE REMOVE THIS ALTOGETHER? DIFFICULT TO
ASK FOR HIS MEDIA STATEMENT WITHOUT OFFERING TO SHARE
OURS..."
He then says:
"There needs to be a line in there about Fujitsu if
there isn't currently."
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the brief and putting it direct to Paula; I'm iterating
it with the input of the Legal Team.
So Susan Crichton there being the Subject Matter
Expert -—
Yes.
-- and you're relying on her to ensure that the changes
you're making are accurate?
Yes, and that they are comfortable with the position
we're taking. And to reiterate, I'm not -- on any of
those suggestions on wording, they're not things which
I have invented; they're things which have come either
from the preceding emails from Susan or the preceding
dialogue.
We can continue this chain. There's a separate chain,
I think, with Mr Davies. Can we please turn to
POL00297040.
So this email, the top one, I think 10.41 at night,
so this is a late-night discussion.
If we could turn to the third page, please, of
POL00297040. Page 3, we have an email from you, just
above one from Mark Davies. Thank you. So you write
here:
"Thanks -- questions/comments below. Current draft
attached (so far I've only reworked the summary box, but
that's the key section I think)."
90
Your response "WHAT LINE?"
He says:
I think it needs to be upfront in addressing the
issue where [James Arbuthnot] is said to be angry -- the
prosecutions and the new evidence.
"On training we need to be very careful about
language -- the current version is too loose -- this is.
your point about not leaving any glimmer which suggests
that cases might need to be reopened.”
So he says "this is your point about not leaving any
glimmer which suggests that cases might need to be
reopened". What was your point there about not leaving
a glimmer?
I mean, I don't recall specifically saying that but
I guess the general concern at the time, this was
clearly a major question for James Arbuthnot. He had
raised the question of past convictions. The emerging
advice we were getting from the Legal Team at the time
was, as we've seen that they didn't see grounds for --
yes, there may be more appeals but they didn't see
grounds for, let's say, successful appeals and I guess
what we're anxious to do is to avoid raising
expectations externally on the basis of the Interim
Report hadn't even been published yet so it's about --
So --
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-- managing expectations.
- "not leaving a glimmer" is about managing
expectations, is it?
Managing expectations on the basis of the evidence we
had at that point and the emerging interpretation of
what that evidence meant.
He says:
"So we need to acknowledge that training can always
be improved (rather than our training must be
improved -- important difference) and need to follow
that with further statement that there is no evidence of
systemic failures.
"The brief needs to make clear that none of the 14
or the 62 [those are the two bugs mentioned in the
Interim Report] impact on the spot reviews on the
Interim Report and are therefore not relevant to the
Interim Report."
"We shouldn't call the user group a 'Horizon' user
group -- makes it clear we are acknowledging issue with
Horizon -- branch management user group?”
You say:
"CAN WE CALL IT A HORIZON SUPPORT USER GROUP?"
So you're there discussing how to rename the group
so that it didn't sound like it affected the computer
system; is that right?
93
If we scroll back up now to the previous page -- in
fact, if we start on the second page -- Mr Davies has
seen a further rewrite from yourself. We're now at
11.38 at night. He says:
"I think in the main body we really need to
emphasise more that there is no connection between the
14 in the 64 and the spot review ..."
Is that possibly “to prosecutions", so no link to
the prosecutions?
I think so, yes.
"Do they need an if pressed line on miscarriage of
justice? ‘Nothing has emerged in this report to suggest
a wrongful conviction. Cases have been through the
judicial process and we have never relied entirely on
Horizon in any court case’."
That's the comment I think you made in the other
chain, isn't it?
Yes.
"I'd like to use the bit at the bottom of my email,
reproduced here for ease of reading.”
And he has repeated -- if we scroll down, there's
another email from him that was slightly earlier.
Can we please now turn to page 1., and the bottom
email there is from you. You say:
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Yes.
"Can you send final version to me before it goes wider
so I can go through one more time? Will look back on
notes to see what missed?
"Overall it didn't feel to me that it captured
Alice's views and I think she was right to be so clear.
“It may be worth setting out three overall 'rocks'
for the two of them to return to:
"[The first rock being] there is no evidence in the
Interim Report to support any suggestion of systemic
failures.
"[Second] this is a system which deals with six
million transactions a day or more than 40 million
a week [et cetera].
"we must be satisfied that when the report is
released it truly reflects the position -- the Post
Office business is too important to too many people for
faith to be questioned unfairly.
“Another point which needs bringing out is the
public money point ..."
Then a further paragraph, and this is the kinds of
figures that we've seen in a number of lines over the
years:
many convictions over what period compared with
[what number of] transactions in 11,800 branches etc
94
"Many thanks, I will integrate your language below,
which is spot on.
"Exchanging phone calls/emails with Susan and Hugh
to try to pin them down on the prosecutions point ...
I agree we need something fairly clear if pressed on
miscarriages of justice
"The whole brief needs rewriting, infuriating!"
If you scroll up we can see there's a discussion
about whether you're doing it now -- sorry, if we scroll
down, slightly, mark Davies emails you to say:
"Are you doing it now? Doesn't seem right! I am
happy to have a go if you prefer."
So this is almost at midnight. The two of you are
together rewording it, and your response:
"Sorry, just saw this, not ignoring you! Yes, I'm
doing it now."
You're after midnight now, it's 12.17:
“Not right that either of us should have to rewrite
so significantly at this time of night!"
So it seems as though between the two of you, you
are significantly rewriting the wording that was sent to
you by the Subject Matter Experts: is that a fair
summary?
I think that's fair, yes.
As it happened, on this particular day -- the Inquiry
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has seen evidence, I don't need to take you to it, the
reference is POL00380985 -- this was a day where there
is another email distribution relating to non-emotive
language for the use of bugs and the response from
Ms Vennells is exception or anomaly; do you recall that
exchange?
1 do, having seen it come up in other hearings, yes.
Yes, and you are a recipient of that email?
Yes.
So quite a lot to is going on at this particular day
before the James Arbuthnot meeting?
There is, yes.
Can we please turn to POL00145089.
Did you sleep at all that night? It seems as though
it was a particularly late night.
Itwas a late night, yes.
So I think the actual final lines that were circulated
quite early -- in fact, if we look at POL00145089, and
we look at page 2, we can see that you send it through
at 2.04 in the morning:
“Alice, Paula
“With many thanks to Susan, Alwen, Mark and everyone
else involved, here's the briefing note for the meeting
with [James Arbuthnot]."
If we scroll down we can see the speaking notes. So
97
a case-by-case basis, with a detailed investigation and
legal review (generally involving external lawyers)."
Then there's a section on “Historical convictions",
and it's this passage, I think, that formed the final
version of what was being discussed. It says:
"Nothing has emerged from the interim findings given
to us by [Second Sight] which would point to specific
convictions being unsafe. Cases have been through the
judicial process and the Court considers all relevant
evidence not just that relating to the Horizon computer
system.
"In the event that any person considers that there
has been a miscarriage of justice they have the right to
apply to the Court of Appeal to have their conviction
reviewed."
Over the page, we have a heading "System
exceptions", so that is in line with that email
correspondence about, we see here, exceptions and then,
in brackets, anomalies:
"... under the current Horizon system [we know of
two of them].
"Key point to note is that in both cases our
processes picked up these issues, appropriate remedial
action has been taken and they did not lead to any
disciplinary action against the affect [subpostmasters].
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it's been sent in a Word document but also a PDF and
it's copied below, “Brief for meeting with James
Arbuthnot, 3 July".
If we scroll down, we can see speaking notes. If we
carry on down to the fourth page, we see there, there's
a section on current prosecutions. There we go. I'm
just going to read a few passages out from that
briefing, so this is the final version that is sent to
Paula Vennells:
"Current prosecutions
"Since the start of the [Second Sight] investigation
we have not pursued a criminal conviction which relies
solely on Horizon computer system evidence. We have
also put on hold civil recovery proceedings in certain
cases while we await final report.
"As you know, we had prepared an ‘immunity
agreement' with the JFSA to provide reassurance to
[subpostmasters] thinking of submitting evidence to the
process."
So those are the kinds of lines that we saw earlier
in that earlier draft about the immunity agreement:
“But in cases where it is clear that the Horizon
system isn't the issue, we have a duty to take
appropriate action to safeguard public money. For
criminal prosecutions we treat each matter on
98
"Absolutely no reason to believe that there are
other undiscovered issues."
Could we please turn to the first page. If we
scroll down to the middle email, please, Paula Vennells
has thanked you for it, and you say:
"I think sharing with BIS [the Department for
Business] would be helpful -- I know they would
certainly appreciate it. I'll just re-read to check for
any issues which could be misinterpreted or unhelpful to
our position, but otherwise I'll forward ... unless
anyone objects ..."
Just pausing there, “unhelpful to our position", the
Department for Business were your sole shareholder, what
might it be that would be unhelpful to your position?
I'm not sure, I think I was making the -- Paula had
said -- suggested that we forward it on to the BIS team.
I'm not sure I was referring to any specific risks,
I think I was just conscious this was a brief which had
been prepared for an internal audience, rather than the
BIS audience because, obviously, I would want to check
it was also suitable for the BIS audience.
The types of issues which -- I mean, there were
concerns at the time around the progress of the
investigation, how long it was going to -- how long it
had taken, how long it was going to take going forwards,
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the costs involved. So I think I would have wanted to
check that everything that was in the brief was
consistent with what we had briefed with the BIS team
‘on -- or, you know, was there anything in particular
which we need to explain to them.
What was the position? Why might it be unhelpful to.
your position; did you have a particular position in
respect of the Department for Business?
I'm not sure what I was referring to specifically there,
I think it was the whole conduct of the investigation,
what we had found from it so far, what the next steps
were.
You then say that you'll send it to the Executive
Committee on behalf of Paula.
Now, can we turn to the top email, please. This is
a response from Susan Crichton, she says:
"Hi there -- so I have not read the reworked
document, are you happy that there are no hostages to
fortune? We shouldn't send Rod's note as there is
updating required.”
So earlier your evidence was that you would have
consulted with the Subject Matter Experts before
finalising. It's clear here, the lawyer who is, to some
extent a Subject Matter Expert, hasn't in fact read the
briefing. Now, it's been drafted very late at night
101
you edited things for clarity. But here we have, late
at night between yourself and the Head of
Communications, a significant reworking of a briefing,
and it's very clear here that it hadn't been seen by the
Subject Matter Experts, the final version; is that
right?
Yes, I mean, she clearly hadn't re-read the whole
reworked document.
Are we to read into your witness statement an additional
line that is that your role also involved deep
involvement in briefing Paula Vennells in relation to
matters affecting the Horizon system?
So, I was absolutely at points in time involved in
pulling together and editing briefs which went to Paula
‘on the Horizon system. I don't believe -- whilst it
involved a significant rewrite, I think a lot of that
would have been around how the brief was structured, the
clarity of the messaging, how the key points were
highlighted in the brief. I don't believe I would have
been unilaterally changing the substance of what was
contained in the brief without that being signed off by
the Subject Matter Experts.
But we saw the communications with Mark Davies,
complaints about how weak it was in certain points --
"needs to be firmer". You were strengthening up the
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between yourself and the Head of Communications, and
sent to the CEO, potentially going to the Department for
Business and the Executive Committee.
That's problematic, isn't it?
I mean, I think it's fair to say clearly the whole
last-minute construction of this brief was very far from
ideal. It's not the right way to be constructing briefs
‘on such important topics. What you saw in the earlier
email exchange was the iteration of specific topics.
I know alongside the email exchange, there are also
telephone calls, and I think I refer to them in my
email, particularly with Hugh, and I think we saw in the
final briefing that the wording on -- particularly on
past prosecutions, had evolved from the suggestion/
questions in my email exchange. So I can't recall the
exact sequence but I think there clearly had been
iteration and input from a combination of Susan and
Hugh.
So I would completely admit this was a far from
ideal way of constructing a brief and getting it
properly signed off. It was far too last minute but
they had been involved in the process.
It's not just the timing though, is it? It's the people
as well. I mean, in your witness statement, you've been
very careful to set out that you were a conduit, that
102
wording, weren't you, not just making it clearer, but
also strengthening it and had --
Yes, there was --
-- to (unclear) ~~
Yes, there was clearly some substantial input from Mark
‘on the wording.
Mark and yourself?
I'm -- yes, I mean, I'm holding the pen on the overall
brief. I think a lot of the specific wording changes.
came from Mark.
Would you describe Mark as a Subject Matter Expert?
Clearly not on legal affairs and IT affairs.
Was it appropriate for somebody with expertise in
communications to be so heavily involved in drafting
such a brief?
I think it was appropriate for the Communications
Director to be involved in the iteration of the brief.
It wouldn't be appropriate for the Communications
Director to fundamentally change the message of the
brief without the Subject Matter Experts being
comfortable with that.
I'm going to move on to Second Sight, and the report and
the response. Could we please turn to POLO00099021,
please.
We're now on 5 July. If we could turn to the second
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page, Paula Vennells has circulated:
"a brief email to update [the recipients] on
where we are with the Second Sight investigation."
If we turn to the first page, you have drafted,
presumably from what she sent you but also from
discussions -- if we scroll up to the top -- a suggested
draft email to the Board.
Do you recall how you came about drafting this email
to the Board?
Well, I mean, it was -- consistent with part of my role
would be to draft correspondence on behalf of Paula.
I think it would have been the synthesis of
conversations with her and with others on the team
working on this, and it was pulling that together into
a draft.
If you say there:
"Obviously the points about the ombudsman and past
prosecutions could set hares running, but equally we
probably do need to register these issues with the Board
at this stage. Obviously feel free to change or expand
the drafting.”
What do you mean by “set hares running"?
I assume what I meant -- at this point I'm not sure
there had been much conversation with the Board about
the implications of the Second Sight Report for past
105
Doesn't "set the hares running" suggest some sort of
negative implication: things that shouldn't be taking
place, things that --
I don't think I would have -- no, I don't think that's
what I meant by that phrase. I don't think I'd be
suggesting it would be inappropriate for the Board to be
asking questions about that. Not at all.
If we could scroll down, please, we can have a look at
the penultimate bullet point. This is a draft brief to
the Board. It says as follows:
"One of the main reputational and potentially
financial risks arising from the review relates to
possible attempts to reopen past prosecutions based on
the findings. James Arbuthnot was certainly focused on
this point. Susan and the Legal Team are working with
our external lawyers to consider whether there are any
implications arising from the report for past cases, and
we can provide a further update on this work next week."
This is, in particular, the paragraph that you were
concerned about setting hares running, was it?
Yes, as I say, I think this was probably going further
than had been briefed to the Board previously.
"One of the main reputational and potentially financial
risks"; how about human impact, impact on individual's
lives, possible attempts to reopen past prosecutions?
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prosecutions, and I think what the email’s raising
possibly for the first time is it could result in more
appeals being made. So it's kind of recognising that
that maybe new news or going further than some of the
previous briefings to the Board.
Are the hares running from the Board, so is the
suggestion that it could get the Board asking questions
about past prosecutions, and that was something of
concern?
Yes, I mean, I think it must have meant -- I think I was
absolutely referring to the potential reaction of the
Board.
Why would that be a concern?
Why would -- why would what be a concern?
Isn't the Board's purpose to ask questions, to
scrutinise; what would be wrong with setting hares
running at Board level in relation to past prosecutions?
I don't think I'm saying there's anything wrong with
them asking questions. I think, clearly, that would be
their role too. I think I'm just highlighting that
this, as I understood it, was perhaps going further than
Paula had briefed the Board on previously. So, you
know, be aware this may well provoke questions. I don't
think I was suggesting there was anything inappropriate
about that.
106
I mean, might have been an impact for the Board that
people had been wrongly prosecuted?
Absolutely, and clearly, in hindsight and everything we
know now, it absolutely should have been the top
concern. At the time, the view of the business wasn't
that the previous prosecutions had been unsound.
But that's what James Arbuthnot was saying, wasn't he?
He was concerned --
Yes.
-- about actual humans, individuals being prosecuted --
(The witness nodded)
-- and having been prosecuted when they should not have
been.
Yes, yeah. I think it's completely fair to say this
email reflects the mindset of the business at the time,
and there wasn't a -- there clearly wasn't enough focus
on the actual safety of those prosecutions and the human
impact.
The second half of that sentence -- of that paragraph,
sorry:
"Susan and the Legal Team are working with our
external lawyers to consider whether there are any
implications arising from the report for past cases ..."
So we're here at 5 July, you were aware that Susan
Crichton was working with an external law firm to
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consider the implications: is that right?
Yes.
The Second Sight Report itself was dated 8 July. Can we
have a look at that day. Can we turn to POL00381077,
and could we start by looking at the bottom email on
that page, please.
So the Head of Public Relations has emailed about
BBC News. So this is on the day of Second Sight's
publication:
"Just to let you know that BBC News has carried
a news in brief piece with accompanying branch footage
which lasted about 20 seconds.
"Ran along the lines of ‘Around 100 [subpostmasters]
are embroiled in a bitter dispute with the Post Office
over a computer system they claim is losing them money
every year’. Not ideal but probably the next best thing
to nothing appearing at all. We'll circulate the clip
once we receive it.
"Nothing on BBC Online yet. Expecting two
human-interest style regional TV pieces from BBC Look
North and BBC Look South."
You respond to say, "Hi" -- this is to Mark Davies:
"assume you've seen completely erroneous
headline on BBC website and are on to them?"
Can you recall what the headline was at all?
109
confidence in possibly an unfair way.
If we scroll up, Mark Davies says:
"Hugely yes."
Your response is:
"Thought you would be. Arseholes."
Who are the "arseholes"?
I'm referring to the BBC coverage there.
Was it part of your job to seek to control the narrative
of the press?
No. I mean, not specifically. That was Mark's job.
I think there are very limited numbers of occasions
where I would comment on this, but this came to my
attention -- as I describe, the reaction I had at the
time is it felt like it was a -- wasn't entirely
appropriate for the BBC to be reporting on allegations
against Horizon. It felt like it had misrepresented it
and turned it into a different story, which had far
greater ongoing implications for the safety of Horizon.
So I was reacting emotionally to that and issuing
what was probably a bit of an uncharacteristic email for
me.
But, again, we saw that brief to the Board in which you
describe some sort of corporate mindset. Is this
another display of that corporate mindset at the time,
an "us versus them" attitude?
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I think it was long the lines of what Nina Amott quotes
in her email.
If we scroll down, let's have a look at that. What's
wrong with that?
I think the specific bit I was reacting to was the end
of that statement, that it's the computer system is
losing them money every year. So I think the bit which
felt to me at the time a misrepresentation of the
position, misrepresentation of the allegations being
made against Horizon, was it had been changed from
a historical issue to there was ongoing problems with
the computer system and that's losing postmasters money
every year.
Now, in hindsight, we may -- we might give more
credence to that but, at the time, that felt a very
different representation to the allegations we were
dealing with.
But all it's saying is 100 people are claiming that it
is losing them money every year; it's not presenting it
as fact, is it?
No, but I think I was very conscious of -- we're all
very conscious of what impact headlines could have on
postmaster confidence, public confidence, client
confidence, in the computer system, and I think we all
knew it was quite easy for headlines to undermine
110
The mindset I was referring to earlier was there was
absolutely a mindset that -- clearly a strong conviction
at the time of the integrity of Horizon. That was the
mindset I was referring to. I don't think at the time
I would particularly have recognised a them versus us
mindset. I don't think -- I wouldn't describe that
email as part of that. As I say, I was reacting to
a specific aspect of that headline.
It's quite a strong reaction to have to something that
simply states an allegation from subpostmasters, isn't
it?
Itis a strong -- our reaction, it's clearly one of
those emails you regret. I think it was an over-the-top
reaction.
But does it display something wider than just your own
personal reaction, a corporate reaction to a BBC report?
As I say, I don't think it does at the time. And
maybe -- maybe this is unfounded but at the time there
was a lot of concern around what the -- would
allegations and headlines about Horizon undermine wider
public confidence in the system? At the time, the
financial crisis was still recent memory. We all know
media headlines provoked and undermined public
confidence in systems back then. So that type of
experience was front of mind, and we were concerned
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about what impact media statements could have on the
wider market position of Post Office.
In hindsight, I agree, it was an overreaction, but
I think it was -- I think what it represents was anxiety
around what statements about Horizon could have for
wider client and customer confidence and postmaster
confidence in Horizon.
Just customer confidence or potential flotation business
interests?
I didn't -- I wasn't -- that wasn't drawing anything
whatsoever to the Royal Mail flotation. That absolutely
wasn't in my mind at the time.
In terms of timing, that was 8 July. 15 July was the
date, we know, of the Simon Clarke Advice. You also
mentioned in your briefing to the Board about Susan
Crichton meeting with lawyers. She's given us evidence
on that. She said that there was a meeting on 3 July.
There was also a meeting on 10 July addressing the
Gareth Jenkins issue?
At this stage, were you aware of the Gareth Jenkins
issue?
No, I wasn't.
Could we please look at the final document before the
lunch break. POL00297915. Page 3, please. If we
scroll down, sorry, page 3, over the page, please. The
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with that view.
Itisn't every day that the Criminal Cases Review
Commission writes to the CEO of a company. What kinds
of discussions did you have with Paula Vennells about
the CCRC's interest at that time?
I don't recall any conversations with Paula on this.
None at all?
No. No.
Would you have discussed with her who should send the
letter?
As I say, I was aware, I think she had already -- what
I'd already seen was she had -- if recall correctly, she
had forwarded on the original letter to Susan and asked
her to respond. So I kind of was conscious she'd
already given that steer.
Were you aware of Mr Clarke's advice or concerns about
the use of Gareth Jenkins at that time?
No, I wasn't.
You were aware that Susan Crichton was liaising with
external lawyers during that period, and the brief to
the Board said something along the lines of, "We can
provide a further update on this work next week".
That was 5 July. What investigations or enquiries
did you make into the discussions that Susan Crichton
was having?
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bottom email of page 3, thank you. A solicitor Rosie
Gaisford, from Bond Dickinson, has emailed you and she
says as follows:
"A later from the CCRC dated 12 July 2013 addressed
to Paula Vennells is attached above. We have drafted
a holding response to the CCRC's letter, to be sent
auditor tomorrow morning ... The holding response is
currently in Paula's name. Are you happy for this to be
sent out in Paula's name or would you rather it was sent
out in your name, Susan Crichton's name, or the name of
another individual?
“A substantive response has also been drafted to the
CCRC's letter. Once this substantive response has been
discussed with Brian Altman QC, a leading criminal
barrister and former First Treasury Counsel, it will be
sent out, by the end of the week."
If we look above, it's a response from you, and you
say:
"Thanks Rosie -- I think both this and the
substantive response should come from Susan."
Did you discuss this with Paula Vennells?
I mean, I think, at the time, Paula had already given
a steer to Susan that it should come from her, so I was
conscious of that. As you see in the next sentence,
I asked Susan if - give her the opportunity to disagree
114
I think the next step in the chronology -- and we might
come on to this -- if I recall correctly, there was then
a broader Board update note prepared, I think, on
26 July, which included updates on all of the
workstreams relate to this matter, including where Susan
had got to with the external lawyers. So I think that
was the next step, and that was based on input from
Susan and a number of others.
Did that refer to, for example, Mr Jenkins --
No, it didn't.
-- and who drafted that brief?
So, it's in another document which I coordinated.
I held the pen on it but it was based on input from
Susan on the legal side, Alwen -- I think the network
side on the branch improvement workstream. It was based
‘on input from number of different workstream leads
across the business.
MR BLAKE: Thank you.
Sir, that may be an appropriate moment to take our
lunch break.
SIR WYN WILLIAMS: Yes.
MR BLAKE: Can we come back at 1.50, please?
SIR WYN WILLIAMS: Yes, certainly.
MR BLAKE: Thank you very much.
(1.00 pm)
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MR BLAKE: Good afternoon, sir, can you see and hear me?
SIR WYN WILLIAMS: Yes, thank you.
MR BLAKE: Thank you very much.
2
Mr Edwards, before the break you mentioned the Board
briefing of 26 July. I'm just going to bring that up on
to screen, so you can confirm this is the document you
were talking about. It's POLO0006590.
Is this the document you were referring to?
Yes, it is.
Were you involved in the drafting of this document?
I was, yes. I kind of coordinated the preparation of
this.
Is it at this point in time where there seems to be
a movement towards restricting the involvement of Second
Sight or limiting their involvement going forwards?
I think the discussion around Second Sight's ongoing
role had probably been iterating for a number of weeks
leading up to this and beyond it, so I'm not sure it
was -- particularly the development of this report,
I think it was about this time.
That individuals’ thoughts are gathering as to the
future for Second Sight and limiting their input?
The question I recall at the time was: there was clearly
117
is very problematic -- it highlights all the risks which
NFSP and others claim, and therefore supports the
campaign. I don't suggest such risks should not be
discussed but it does so [badly] without mitigation and
is poorly drafted in places -- specifically on Horizon."
Then if we scroll up Mr Gibson has responded.
You're copied in on correspondence, he says:
"Hi Mark, I share your concerns and we've gone to
[Royal Mail] on them. I sent the comments we sent over
to Susan so feel free to have a look.
"The [Royal Mail] suggestion it's our document is
nonsense -- Slaughters are holding the pen and [Royal
Mail] directors are responsible for it. That said, we
can certainly influence its drafting as I'd be keen to
ensure in this case."
So the complaint there from Mr Davies, if we scroll
down, is about the risk section. We can then see what
happens to that risk section. Can we please turn to
POL00381531. There is an email from Mark Davies on the
second page, to Paula Vennells, and she has inserted
some words in capitals. So if we scroll up slightly we
can see her response -- a little bit more, thank you.
She's responded to Mr Davies, and said:
"Mark, thank you this is very helpful. I have made
some comments below in caps (nb, if someone can show me
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a cohort of cases which had been submitted as part of
the first phase of the Second Sight investigation.
I think it was about 47, and I think the debate is do
they -- just focused on them, is their role beyond that?
Those were the types of questions being raised.
I think in your document pack, there's a reference to
just keeping it at 47; do you recall that?
Yes, I recall that being a suggestion from some of the
business.
Thank you, that can come down, I'm going to move to
a different topic and that is the flotation prospectus
and I think you said you weren't involved in the
flotation of Royal Mail itself?
Not itself but, as I'm sure we'll come on to, I was
involved at one point in providing some comments on
specific references to the Post Office in the
prospectus.
Can we please turn to UKGI00001916. If we look at the
second email on the page it's an email from Mr Davies to
Will Gibson at ShEx and he says:
“Just wanted to touch base on prospectus which
I know you have talked to Susan about. [Royal Mail]
described it to me as a BIS document [that's
a Department for Business document] but I think you
don't share view? Anyway the unvarnished risk section
118
how to change the colour -- that would be far more
effective ..."
If we scroll down, we can see Mr Davies’ email to
Paula Vennells and also her response, and it's the
bottom of that page that I'd just like to take you to.
He says:
"RMG prospectus: We are working with legal on this.
The section on risk is very problematic for [the Post
Office]. The PR team are across it and I have asked
Mike to also work on it from his perspective."
Then that's the response from Paula Vennells in
capitals "AM AWARE [THANKS]".
What was the purpose of the prospectus?
So it was clearly Royal Mail's documents to inform
prospective buyers for their shares.
Thank you. Can we please turn to POL00299534. If we
could start on the second page, please. So this is your
involvement, if we look at the bottom of page 2,
an email from Tim MciInnes from ShEx. He says:
"Martin ..."
That's a reference to you:
"Can you let me know the time/status of [Post
Office's] most recent conversations with [Royal Mail] on
the prospectus. We think someone on the other side
might be saying that [the Post Office] has signed off,
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and to bat this away (which we will) it will be useful
to understand comms channels and what has been
said/agreed.
"And further to our chat a few minutes ago it would
be good if you can leave this with us for the moment.
We will keep you updated on progress in real time but
there are some weapons we want to keep in the arsenal
and only use if they are absolutely necessary. We have
a couple of avenues to try still so let’s see where we
get to with those."
Why is Tim Mcinnes contacting you specifically?
Part of my role as Chief of Staff, and I think I have
referred to this in my witness statement, was to be part
of an informal line of communication into the ShEx and
BIS teams, so they were in contact with lots of people
in the Post Office but, if they weren't sure where to
go, they could pick up the phone to me and I could help
them out and direct them to the right place. So that
was part of my role.
Were there others assigned to that role or was that
a role you specifically held?
I'd say the Comms Team had primary accountability for
Government relations. I think my role was particularly
to help -- an additional line of communication into the
BIS and ShEx teams.
121
Office and Royal Mail, raising the possibility that
relationship could break and raising risks about our
operational dependability.
And I think our concern was, whilst we recognised
prospectus, by definition, needs to be clear to
investors about prospective risks, we were concerned
that without the right context, that would kind of play
into some of these anxieties of the network about what
impact separation would have.
But, of course, a risk section in a prospectus has to be
absolutely accurate about the risks that the company
faces?
Yes, yeah and obviously what we're trying to finding the
right balance here, is factual description of risk but
making sure they're understood in the right context.
Thank you. Can we turn to the first page, please. At
the bottom of the first page, you email Susan Crichton
and Hugh Flemington:
would you be able to ask Slaughters to send
across the latest extracts on [Post Office] from the
prospectus please? Just spoke to Will G for an update
from their perspective -- he said the main sticking
point was the sentence on Horizon/Second Sight in the IT
risks section, which they're still pushing to have
removed but are facing some resistance.
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Because it's not just communications that you need that
relationship with ShEx; it's also because they have
a seat on the Board, and there is a direct line of
accountability of some sort, isn't there?
Yes, yeah. It clearly had interests across the full
span of the business.
If we scroll up, the response from yourself:
"Tim -- the only other channel of communication with
[Royal Mail] on the prospectus has been between our
Legal Team (Susan and Hugh, who I have copied) and
a lawyer at Slaughters. Hugh can confirm, but as far as
I'm aware the last communication with them was 1-2 weeks
ago, and focused on narrower points of legal/factual
detail rather than the reputational/PR issues that
I flagged to you".
What were those issues that you had flagged?
I think the context for this, there was a huge amount of
anxiety at the time about the separation of Royal Mail
and Post Office: a lot of anxiety from the network, from
the NFSP, from the CWU about what repercussions this
would have for the long-term relationship between Post
Office and the Royal Mail. And so I think the
particular concerns were, as you'd expect in a risk
statement, there were lots of quite extensive
description of risk about the relationship between Post
122
"I asked if that meant the other issues had been
resolved (on MDA language etc) ..."
What was MDA?
MDA that was the Master Distribution Agreement, so that
was the long-term agreement between Post Office and
Royal Mail so that governed our ongoing relationship
post-separation.
"... he said he didn't think there was any pushback
there but wasn't able to confirm whether our comments
had been taken on board. He said he would do some
digging -- but it might just be quicker to get hold of
the latest language direct from Slaughters."
So at this point there was issues principally with
the prospectus. One of them, relating to Horizon/Second
Sight, and the other was on the MDA language, is at
right?
Yes, the MDA language, that broader ongoing relationship
between Post Office and Royal Mail.
The response from Susan Crichton:
"We cannot go direct to Slaughters they would have
to ask RMG to approve giving us the information, so
I will ask [Royal Mail] but as I understand it the
Horizon/IT reference was taken directly from our press
release."
You say:
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"Thanks Susan. Looks like none of our changes have
been taken on board ..."
Susan Crichton responds:
"So are you going back to BIS -- not sure our
protesting about this will make any difference?"
You say:
"Yes, I will pick up with BIS and keep you posted.”
Could we please turn to UKGI00002065. If we scroll
down slightly, an email from Mr Mcinnes to Mr Gibson at
ShEx and also to yourself. He says:
"Will, Martin,
"See below an extract from an email just received
from Freshfields related to the Horizon disclosure.
"Martin, I want to wait for the fat lady to sing,
but it looks like you managed to make more progress (or
rather progress) than we could at this end. Many thanks
for taking the baton."
The extract from the email is:
"The Horizon language is still in the draft, but
I spoke to Alex Dunn just now and he says that all of
the Horizon disclosure will be taken out today -- which
is good news."
If we scroll up, we can see your response:
"Thanks, Tim, that's very good to hear. We
intervened with Jon M last night ..."
125
wide problems had been founding in relation to the
‘Horizon’ software, but suggests that [Post Office]
should examine its support and training processes for
subpostmasters.”
That was accurate, as a statement, wasn't it?
Yes, I think the statement itself was accurate and, as
we saw in the earlier exchanges, I think it had been
lifted from a Post Office press notice.
Ms Vennells says below:
"Our challenge is that this is not a risk to [Royal
Mail] and is particularly misleading in the IT risks
section. As your paragraph states, the findings of the
Interim Report related to [subpostmaster] training and
support not IT faults."
Do you agree with that final distinction?
I mean, yes, it's -- we didn't see this as a risk to
Royal Mail at that point and, as was described in the
email, the key finding from the Second Sight Interim
Report was around postmaster training and support. We
didn't, at that point, see it as an IT system; it was
the broader process of support and training. So yes, it
felt like a -- that was the right summing-up in Paula's
email.
So in your view, the Second Sight report was not
addressing IT issues; it was relating simply to the
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Is that Jon Millidge?
Yes, I believe so.
He was the Company Secretary of Royal Mail?
Yes.
"... last night and he said he would pick this up with
the team."
Now, we can see how that occurred, and I'm going to
take you to correspondence between Paula Vennells and
Mr Millidge that is referred to there. Could we please
turn to POL00146462, and can we start at the bottom of
page 2, please. Thank you.
So this is a Friday night email from Ms Vennells to
Mr Millidge, and she says:
"Hi Jon, I realise this is ridiculously late and for
that my sincere apologies. However, I have just seen
an email that our team in BIS appear to have hit a brick
wall on one particular para in the prospectus. And I'm
told it has to be lodged with UKLA by 8.00 am on
Monday."
This is the passage that has been objected to from
the prospectus:
“In July 2013, an Interim Report was published into
alleged problems with [Post Office's] 'Horizon' computer
system, which is used to record transactions in its
branch network. The report confirmed that no system
126
subpostmaster training and support?
No, it clearly addressed both but the major finding,
major focus was particularly around training and
support.
Was that training and support generally or training and
support in relation to the Horizon system?
In relation to use of the Horizon system, yes.
Therefore, is it inappropriate for that to have been
included in a section under IT?
I think it was felt to be inappropriate in a section on
Royal Mail IT risks. That felt like kind of
an inappropriate place to be talking about this risk.
We can read here the feeling that it's inappropriate, as
expressed by Ms Vennells, but what is your personal
view? Is there an issue with what was in a press line
relating to the Second Sight Report, which was
an investigation into the Horizon IT System, being in
a section in a prospectus under the IT section?
I think I -- I mean, I think I would agree with the
assessment that repeating language about the findings of
the Second Sight Reports in a section on Royal Mail IT
risks doesn't accurately describe the nature of that
risk. So it does feel to me like a fair concern.
Was it a risk, the matters that were identified by
Second Sight were they a risk more broadly to the Royal
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Mail?
Not as we understood them to be at the time, no.
So they are not risks that would have affected the Royal
Mail Group?
We didn't perceive them to be. I think clearly the
chief concern at this stage was reputational risks for
Post Office.
It says:
"Can you get this paragraph removed? Alice had
offered to contact Donald if necessary but I don't want
to disturb her this weekend.
"So sorry to bother you with this. And I recognise
that the para makes it clear that there isn’t an IT
fault. But its presence in an IT risk section
potentially opens up a sensitive and politically high
profile situation."
How would the inclusion of a line that is your own
press line potentially open up a sensitive and
politically high-profile situation?
I think our feeling was we'd obviously -- the Second
Sight Report had been published. We had published our
response to that Second Sight Report. All of that had
been disclosed, re-airing that particular information in
the context of a Royal Mail prospectus and a section
talking about Royal Mail IT risks. Clearly the concern
129
"This is not a [Royal Mail] contract risk either."
Then if we control up above he says:
"Okay. I think we should be able to remove but I
will need to confirm on Monday.”
Then if we look at the top email, Paula Vennells to
Alice Perkins:
"Not sure how much you want keeping in the loop.
But hoping it goes through, I have earned my keep on
this one. Unusually BIS misjudged it: they were unable
get the changes through and seemed to be unclear(?) on
how much time we had before the deadline. So we were
told our luck and time that run out of Friday."
“Read bottom up. I hope it is now resolved."
This seems to suggest quite a lot of micromanaging
of information relating to the Second Sight Report;
would you agree with that?
I think I'd agree it reflects a high degree of anxiety
of that information being recirculated, in what we felt
to be out of context and clearly an extraordinary
high-profile context. So yes, I think it reflects
a high degree of anxiety about that.
We saw before lunch your comment on the BBC article and
their report on the Interim Report.
Similar approach here, trying to clamp down on
references to the Second Sight Report and their
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was that, yes, it was raising attention to that issue
and, again, in the wrong context and that was causing us
some anxiety.
If we scroll up on page 2, we can see Mr Millidge’s
response:
"I thought that this risk only repeated the press
release and that your team were ok with it.
"Evidently not! So let me check with the team.
I will get back to you."
If we scroll up, Ms Vennells says:
"It is. Just odd therefore that it features in
an IT risk section."
If we continue scrolling up, please. The response
from Mr Millidge, if we scroll up to the bottom of the
next page -- oh, yes, its just there, at the bottom of
this page:
“And that is the point I have just raised with the
team -- maybe better under contracts.”
So Mr Millidge is saying, "Okay, I get the point
about it not going under IT, it should maybe be better
under the contract section".
Is that what you understand his email to suggest?
Yes, yes.
Then Ms Vennells says:
"No Jon, the request is to remove it.
130
findings; would you agree with that?
I'm not sure I'd quite agree with that characterisation.
As we discussed before lunch, the concern about that
report wasn't referenced to the Second Sight Report; it
was the way it had been described to be an ongoing
problem of Horizon. That was the specific concern here.
We had published the Second Sight Report, we had
published our response to it. So I don't think it was
an issue per se with that being in the public domain.
I think it was an anxiety about how that information
might be represented in the wrong context.
Can we please look at POL00299535, this is an email from
yourself, 25th September. You're emailing Mark Davies
and others. You say:
"Mark, Ruth and team.
"Here is the latest (and I understand final) draft
of the [Post Office] extracts from the [Royal Mail]
prospectus. It's certainly much better than it was, and
we managed to get the sentences on the Second Sight
review deleted. But the risks section is still,
inevitably, negative in tone -- whilst the standard
audience for such documents (ie investors) would expect
this and not take it out of context, clearly journalists
and unions may seek to misuse it. So I guess over to
you guys to work with BIS and [Royal Mail] comms on the
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defensive lines! Let me know if there is anything to do
to help. I've asked BIS to see if they can get hold of
the wider marketing materials for the IPO, which will
hopefully include some more positive statements on the
[Post Office-Royal Mail] relationship -- but probably
worth asking your counterparts in [Royal Mail] too as
they may be a quicker route.”
So significant efforts have been put into getting
the Second Sight review deleted from that report?
Yes.
Do you consider the actions that took place in relation
to that prospectus to have been appropriate?
I think they do clearly reflect a very high degree of
anxiety around the positioning of the Second Sight
Report and how that was reflected, but -- and as we see
in this email, they also reflect broader anxiety about
the whole separation process, which -- I mean, this was
one of the most seismic events to impact the Post Office
in its history, so the whole process of Post Office
separation and privatisation was intensely sensitive to
the business.
It's editing a section on risks to investors. Surely it
has been shown to be quite right that it is and was
a very significant risk to investors; do you agree with
that?
133
A. Correct, yes.
SIR WYN WILLIAMS: Okay. So from your personal perspective,
at the time, were you looking at this as a risk to Post
Office alone or were you thinking that there may be
wider implications with there being a risk to Royal
Mail?
I think I and everyone working on this was very much
focused on the risk to Post Office. I really don't
think the -- the driver for this wasn't concerns around
Royal Mail, per se. We were very much looking to
protect Post Office's reputation on the range of issues
raised by separation.
SIR WYN WILLIAMS: So that I'm not -- because I don't claim
to have any expertise in what happens when companies
separate but the actual separation had taken place
a year before, had it not?
In terms of corporate separation, I'm not quite sure
when, corporately, the two companies separated. I think
you may be right and then, obviously operationally, it
was an ongoing process.
SIR WYN WILLIAMS: Yes. I think I'm right in saying that
the act which enabled the separation --
A. Yes.
SIR WYN WILLIAMS: = -- was January 2012 and the actual
separation was April 2012?
135
26 July 2024
A. I'm not sure, to be honest, whether, even in hindsight,
this whole affair has represented a risk to Royal Mail,
per se. I'm not sure. I don't feel well placed to
qualify that. That wasn't my understanding.
Q. In relation to the Post Office, though, it's been
a significant risk; would you agree with that?
A. Yes, it's been a monumental risk to the Post Office,
yes.
SIR WYN WILLIAMS: Just so I can understand this,
Mr Edwards, in the emails we've been going through,
especially from Ms Vennells, as I read them at least,
she was making it clear that the risk was to the Post
Office; it was a Post Office risk, not a Royal Mail
tisk, and that was at least one of the reasons which was
motivating her to ask that the risk be removed. Have
I got that right?
A. Yes, I think that's absolutely correct, sir. Yes. That
was the key concern. We understood it to be a risk to
the Post Office. It wasn't necessarily a risk to Royal
Mail, which is why it felt inappropriate to be in
a Royal Mail prospectus.
SIR WYN WILLIAMS: That debate about whether it should be
under IT risks or contract risks, the point is made
explicitly, "It's not a risk to you", in effect, "it's
a risk to us".
134
A. Yes, I think you're correct.
SIR WYN WILLIAMS: So this is a process, in effect, to sell
shares in Royal Mail?
A. Correct, yes.
SIR WYN WILLIAMS: = Right. Okay, thank you.
MR BLAKE: I'm going to go back slightly in time to
POL00112856, to 9 September. This is the insurance
notification that the Inquiry has seen. If we scroll
over the page, we can see that it was communicated via
a note on Bond Dickinson headed paper and, if we scroll
down, and over the page, to page 3, we can see the
section there on risk to the Post Office, and we have
dealt with other witnesses on how this came to be
formulated.
Were you involved in this at all?
A. No.
Q. Were you aware of concerns about the provision of
information to the Post Office's insurers around this
time?
A. I was aware that the -- I think at the July Board,
questions had been raised by some of the board of
directors about the insurance position. I think that's
referenced in the 26th July paper which we looked at
earlier. So I was aware of it to that extent and,
obviously, was aware of what was covered in that paper.
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I wasn't close to what happened to that discussion after
the 26th July.
You say in relation to the prospectus that you were
aware of a general concern around insensitivity to the
overall issues in the business. Were you aware of those
concerns and sensitivities when it came to the type of
information that was provided to Post Office's insurers?
No, I really wasn't close to that process at all. It
was being led by, I think, our CFO at the time.
Thank you. Can we please turn to POL00382001, and the
bottom of the page, please.
This is the email that the Inquiry has seen several
times, it's at the bottom of the page from Paula
Vennells to Alice Perkins:
"Hi Alice, don't worry about the lateness of this
not -- I'm clearing the tray before signing out.”
Then it's the bottom of this page, it says:
"My concern re Sparrow currently is our obligations
of disclosure regarding an unsafe witness (the
representative from Fujitsu made statements about no
bugs, which later could be seen to have been undermined
by the [Second Sight] report.) we do not think it
material but it could be high profile. Martin E is
briefed if you want more detail."
Who had you been briefed by?
137
aware, this is a period where Susan Crichton was in the
process of leaving the business. As I recall, Paula
brought me into the loop. She wanted to let Alice know
but she also wanted to give Alice a point of contact
that she could reach to whilst Paula was away and, for
obvious reasons, Susan probably wasn't the appropriate
point of contact, so she brought me into other loop so
Alice could reach at to me if she wanted further
information.
So your briefing there was only from Paula Vennells?
I can't recall being briefed on this directly by the
Legal Team. I can't recall anything verbally.
I haven't seen anything in the documentation.
Had you seen the review by Brian Altman?
No. I'd seen it being referred to and brief bits of it
summarised but no, I hadn't seen the review itself.
Summarised by who?
I think Rodric Williams. It may have been -- it was
around this time, particularly as part of the drafting
of the CO's report, Rodric sent me some contributions to
that and included brief summaries of what Brian Altman
was concluding.
So Mr Altman's review is dated 15 October. Perhaps we
can very briefly go to that, that's POL00006803. If we
turn to page 18. If we scroll down, he addresses the
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As far as I recollect, it was by Paula herself.
And what did she say?
So my recollection is hazy. It was a verbal
conversation. I think she'd been updated by the Legal
Team. I assume Susan, but I can only remember broad --
similar details to what she gave us in this email, that
there was a concern that a Fujitsu witness hadn't
disclosed the bugs which became apparent, which were
disclosed in the Second Sight Report, that would most
likely need to be disclosed to previous prosecutions.
As I understood it, that had been put into the
Cartwright King review process.
My recollection, the general impression I got from
that conversation kind of accords with what we've got
here, which -- it was sensitive, it clearly wasn't
helpful, but it wasn't viewed to be material to the
outcome of those prosecutions. That was the general --
that's the best of my recollection.
So "we do not think the material", is that yourself and
Ms Vennells?
No, certainly not my opinion. I think my impression, my
recollection, is that that was the opinion that Paula
had formed, having discussed this with the Legal Team.
And just for -- I mean, I think the reason I was brought
into the loop at this point, as the Inquiry is probably
138
issue of Gareth Jenkins. He then addresses the issue
over the page of the Helen Rose Report. He says at
paragraph 50:
"The draft report is based on an exchange ...
between Gareth Jenkins and Helen Rose ..."
If we perhaps move on to page 44, Mr Altman had
addressed Gareth Jenkins and the impact on possible
appeals. Perhaps we could turn to paragraph 142, he
said:
"Of grave concern is that Mr Jenkins informed the
[Second Sight] inquiry of the two defects, which they
reported at section 6 of the report, suggesting that he
knew of them in a period Mr Clarke argues in his 15 July
2013 Advice to be between 5 October 2012 and 3 April
2013, which are the dates of essentially five Jenkins
witness statements Mr Clarke sampled. Yet in none of
them is there to be found any reference to these two
system defects. On the contrary, his reports speak to
the general integrity of the system."
Had this kind of information been brought to your
attention?
No. Not -- no, not in this level of detail or candour.
The only bit which resonates is some of the -- which
resonates from the conversation I had with Paula was
around the number of past cases which might be impacted.
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So the figure of five sounds familiar but none of this
detail I'd seen before.
So you think around this time you were aware that around
five cases had been impacted by, what, the provision of
evidence by Mr Jenkins?
What I recall, in Paula's description of what impacts
the Gareth Jenkins issue might have, I recognise
a figure of five being described here as one of the
reasons why she or the Legal team didn't view this to be
highly material.
Because of the small number of people that it directly
involved?
I think the combination of the small number of people
and, I guess, a question -- the impression I was given
is that it was clearly deeply unhelpful and deeply
inappropriate but didn't necessarily add to the
disclosure of the two bugs themselves, which had been
disclosed to past prosecutions with the Second Sight
Report. It wasn't conveyed to me that it added very
much to that.
Conveyed to you by who?
As I say, I'm basing this on the briefing -- the verbal
briefing I was given by Paula.
So Paula Vennells had sent an email to Alice Perkins,
she was about to go away, you were the person who had
144
Could we please turn to POL00407608. Now, this is
going slightly back in time and nearly two months before
that email from Paula Vennells to Alice Perkins. If we
scroll down to the bottom, we can see an email from
Susan Crichton, and she says:
"Paula
“Further to our conversation this afternoon."
This is 3 September:
"There are two issues that we need to obtain JA's
view on our approach."
That must be James Arbuthnot.
If we keep on scrolling, there's a section in that
email entitled "Legal and Adjudication of future case",
and it's the bullet points below that that I would like
to draw to your attention.
"Meeting was held with our external law firm who
have been completing the criminal case review.
"The issues that we want Brian Altman QC to advise
on were agreed, final sign off of review process;
options re appointment of independent expert witness
(paper to follow); advice on prosecutions going forward.
"Following this discussion [terms of reference] for
his review to be finalised.”
It's the reference there to the appointment of
an independent expert witness.
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been briefed on the issue. Do you think that you were
sufficiently briefed?
No, and I think, in practice, what she was expecting me
to do -- she wanted me to give Alice the name of someone
she could contact in her absence. Susan Crichton,
I think, if she hadn't formally left the business was
effectively left. I think, from memory, Chris Aujard
had only just started, so it wasn't really appropriate
to give his name. I don't think Alice would have known
the names of the people who sat below Susan, so she was.
giving Alice my name to reaching out to and I would then
liaise with the likes of Rodric Williams if further
information was needed.
If we scroll down, we can see further sections
addressing the Gareth Jenkins issue, and something we're
going to come to in a moment, if we turn to page 54,
paragraph 173, Mr Altman has said:
"The Helen Rose Report adds very little, it seems to
me, other than to point to a particular issue at Lepton,
and the implications from the report that as early as
February 2013 Gareth Jenkins was aware of integrity
issues with Horizon, none of which he revealed. The
[Second Sight] report and the Rose Report are the limit
of the current disclosure recovered. I am unaware of
anyone being provided with anything more than this."
142
Were you aware at that time, September 2013, that
there was an issue with the expert witness?
I'm not sure I was. The clearest first recollection
I've got of this was in October, in relation to the
exchange we've been just discussing. I don't recall
picking up on this point or particularly understanding
it. I certainly don't think I'd linked this to what
I now understand to be the Gareth Jenkins issue.
Because, if we scroll up, we can see that Paula Vennells
has sent this email to you. If we scroll up slightly,
can you see there?
But that's not something that sunk in at all about
a concern regarding an expert witness, or the
appointment of a new expert witness?
It's not something which I -- no, I certainly didn't
pick up on that. I think the main reason I was being
copied in -- at that point I think I was supporting on
some of the preparations for the appointment of the
chair of the Working Group, obviously, what ultimately
became Sir Anthony Hooper. So I think that's why Paula
Vennells added me to the copy list.
I certainly don't recall reading this email and
picking up on that specific bullet point.
But by the time of that Paula Vennells email to Alice
Perkins, saying that you had been briefed, you were
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aware of that concern?
Yes, yes.
I said I'd move on to the issue of the Helen Rose
Report, and I'm going to do that now. Could we please
turn to POL00196707, and if we could start on page 5,
please. Thank you. There's an email here from you to
Rodric Williams and the subject is "CEO's report text on
criminal cases review".
So this was going to be a report from Paula
Vennells. Is that to the Board?
Yes, this was part of -- as part of each Board meeting
there would be what's known as the CEO's report, which
is a four or five-page summary of issues going on across
the business and part of my job was to collate the
production of that report.
You say:
"Hi Rodric -- as discussed, here's the text.
Grateful if you could amend as appropriate ..."
The text as drafted at that point was as follows:
“Our criminal barrister, Brian Altman, has now
completed his review of the approach we are taking to
reviewing cases that have been subject to prosecution,
in particular looking at whether we are complying with
our duty to disclose the findings of the Second Sight
Report to the defence team in cases where it is
145
provided some input. So, in short, this text was
a synthesis of what I'd been given from the team. So
this is basically their substance which I then edited
down into a short paragraph.
Can we scroll up, please. Mr Williams responds. He
says:
"_. [have highlighted my amendments in bold below.
"Please note [and there are two points]:
"I have left in ‘fundamentally sound’ as Brian uses
it in his report..."
But then he says:
"Brian's view on the CCRC is that we have ‘responded
to the Criminal Cases Review Commission appropriately
... but should the Commission continue to show interest
in these cases there might have to come a time when Post
Office considers sharing Cartwright King's review
findings with the Commission, and cooperating with the
Commission’."
So Mr Williams is highlighting there that the
section on the Criminal Cases Review Commission needs to
be a little bit more nuanced because it might be that
the Post Office do have to, in due course, cooperate
with them?
Yes, yeah, and I mean to explain, part of -- the CEO's
report itself tended to be very concise but it was
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appropriate to do so."
Just pausing there had you, by this stage, read
Mr Altman's report?
No, I don't believe I ever received the Brian Altman
report. The first time I saw the actual report was when
it was disclosed to me a few weeks back.
You say:
"His conclusion is that our approach is
‘fundamentally sound’ ...”
That's in quotation marks.
". providing us with strong grounds to resist any
formal review of our historic prosecutions (for example
by the Criminal Cases Review Commission). To date,
following several sifts our external firm of solicitors
has identified 11 cases where disclosure is required.
It is now a matter for the defence in those particular
cases to determine what action (if any) they might take
in light of this additional information.”
How did you draft that if you hadn't read
Mr Altman's report?
So this drafting was based on -- I think there was
a first draft produced by Andy Holt who was then the
Programme Manager for what was now known as the Sparrow
process. I'd raised some questions on that, I think
that had then been farmed out to Andy Parsons who had
146
accompanied bid Chief Executive, who would then deliver
it in the Board, alongside a verbal briefing. So part
of the process of this was, alongside the report itself
giving Paula background notes, so she could voice over
more detail. So this might be the type of thing which
fed into her background briefing.
But this was the actual wording which went directly to
the Board -- I mean, not this particular wording, we'll
come to the wording, but the ultimate CEO report text
would go to the Board?
Yes, yes.
He has added after "Second Sight" regarding disclosure
of the Helen Rose Report, and he has amended the wording
regarding the Criminal Cases Review Commission to say
that Mr Altman's review has enabled us to assert to the
Criminal Cases Review Commission that:
insofar as our historic prosecutions are
concerned, we responded to the Second Sight Report in
a prudent and responsible manner."
So it's watered down in light of that caveat from
Mr Altman, it seems?
Yes.
If we scroll up, we can see your response. You say:
"Hi Rodric -- thanks for this. Is the Helen Rose
Report a key part of the disclosure? If so I think
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we'll need to include a reference to it in square
brackets below. But we'll also need a sentence to
explain what it is, as Paula and the Board won't have
heard of it. Please could you suggest some wording?”
If we scroll up, we can see Mr Williams’ response.
He says:
"Cartwright King advised that the Helen Rose Report
meets the test for disclosure (ie it might undermine the
prosecution's case or assist the accused's), and is
therefore being disclosed where appropriate.
"I have added a very high level sentence to address
this (again in bold). I have quite a bit of further
information on the Helen Rose Report, so can go into it
in more detail if required. Please let me know if you
would like me to do so, or if you would like to See any
of the underlying documents (eg the report itself, or
Cartwright King's or Brian Altman's advice on it)."
He has there inserted a summary of the Helen Rose
Report, and says:
"The Helen Rose Report was prepared in June 2013 by
a member of the Post Office Security Team, and refers to
emails with Fujitsu from January and February 2013
suggestive of there being issues with Horizon, training
and support."
It's worded slightly strangely there at the end,
149
from her and the Board! Please could you send me the
report and any associated advice, etc?”
If we scroll up, he said:
“I thought as much!
"Can I suggest we take 10-15 minutes tomorrow
morning to go over what we have and where it goes to
help me tailor the response?”
Then above you say:
"... yes, agree a quick catch-up tomorrow ...
"As you'll see from the text I've just
re-articulated, I've decided it's probably better not to
mention the Helen Rose Report specifically, as it will
only serve to confuse things with the Board (although
I will still need to give Paula background notes on the
issue).
"I've also cut back the text review of past cases --
hope this still works."
Now, having seen that there are still issues with
Horizon, rather than removing reference to that report,
wouldn't you want to find out quite a bit more about it
at that stage?
Yes, and I think as we'll hopefully come on to, part of
the follow-up actions was to arrange a proper briefing
for the team to pull on these issues. I think my
concern at this point -- and this is another late-night
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isn't it, with the comma? It was your reading of that
it was suggestive of there being issues with Horizon and
issues with training and support, or that it identified
issues with Horizon training and support?
I think candidly I wasn't sure, and this wording begged
lots of questions to me, and it felt like we were
getting into territory which needed much more
explanation and you'll probably going to come on to
it
Because --
To be honest, I wasn't -- this raised more questions to
me than it answered. I don't think it particularly
helped explain the full implications of the Helen Rose
Report.
No, but not just questions but also presumably concerns,
because there appears to be a report which is suggestive
of there being issues with Horizon.
Yes, yeah, it was -- yes, absolutely, and it was the
first I'd heard of this and I was pretty sure it wasn't
something which had been briefed to Paula or the Board
at that point.
If we look above, you say:
"Thanks very much Rodric. Unfortunately I think
I probably do need to give Paula more information on
this, as this is going to raise all sorts of questions.
150
email -- I think I was concerned that this
potentially -- I didn't know what to make of this.
reference to the Helen Rose Report. All I did know was
it was new news and Rodric's explanation in the
preceding text, as I say, raised more questions than it
answered. Candidly, I was quite concerned about putting
in information into a report going out in Paula's name
when she wasn't familiar with this issue. It felt
inappropriate to put something in a report in her name
before she'd been properly briefed.
So I took the judgement call, late at night, to take
it out and instead arranged for a briefing for her and
then she could decide what to do with that information.
So it was a kind of judgement late at night, based on
limited information. I think that the key thing, which
we'll come on to, is I then arranged a briefing -- the
team to give Paula a briefing on the topics so she could
take a view.
Were you present at the briefing?
No, I was just about to go on leave, so I commissioned
Belinda Crowe to coordinate that briefing and give it to
Paula.
Yes. We'll come and look at that document but, before
we do, can we please turn to the first page. Rodric
Williams has responded to you, the next morning:
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"Thanks, Martin -- I'll comment separately on your
revised text (which read well), as amended by Andy Holt.
"I attach a Briefing Note from Cartwright King
addressing the issue we discussed yesterday, namely:
"I, Update on the criminal case reviews to date ...
"ii. A summary of the appeal steps a defendant can
take in those (few) cases where further disclosure had
been made
"iii. Whether the 'Helen Rose Report’ is in the
public domain (it's not) (copy attached along with
covering letter).
"I think it is sensible to keep references to the
Helen Rose Report at a minimum as it may not be a live
issue going forward. You will see from the final
paragraph of the Briefing Note that it is ‘unlikely to
require disclosure in any further cases and will not be
disclosed in any pending or future prosecution’. Brian
Altman QC was also of the view that it 'added very
little’."
We can see the attachments that Mr Williams sent
alongside that email. The first is the Helen Rose
Report. Can we turn to POL00196708. The document I'm
taking you to is known as a family document, so we are
sure that those are the actual attachments to this
email, though other versions exist. But if we look at
153
email where he quotes Brian Altman and generally gives
quite a lot of reassurance that it isn't a material
issue and doesn't add very much. So I think, at that
point in time, I was probably reassured that, actually,
maybe this isn't such a material part of the disclosure,
but, I mean, what I would emphasise is I did still
arrange for the team to give a briefing to Paula and to
follow up on it, and --
If we look at the second attachment, that's POL00196709,
this is the briefing note that was produced by
Cartwright King that's referred to in Mr Williams's
email. If we scroll over the page, please, we can see
there's reference -- one of the purposes of this was to
provide a short explanation of the status of the Helen
Rose Report. If we look at paragraph 4 on that page, we
see there it says:
"The Helen Rose Report is not in the public domain
and should not be placed in the public domain.
Nevertheless it is subject to the disclosure rules ...
"As a matter of law, a defendant to whom any
material ... is disclosed is constrained from using that
material ...
If we scroll down, it says there:
"Because this report goes only to the apparent
knowledge of [Gareth Jenkins] at the time of his writing
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this document, this is the Helen Rose Report, but it is
the redacted version of the Helen Rose Report. And, if
we scroll down, over the page, we can see this is the
one where in fact Gareth Jenkins’ name has been
redacted.
What we do see, though, on page 3, about three
quarters of the way down, is the part of the Helen Rose
Report where it says:
"I know you are aware of all the Horizon integrity
issues."
Did you read this at the time?
I think I may have skim read it. I'm not sure I'd have
known what to make of it. It's obviously a relatively
operational and technical report. I think I skim read
it and I didn't come away from it thinking, "Oh, I see
what the key issue is here".
So we had Mr Williams suggest the form of words in that
briefing to the Board that said, "Suggestive of there
being issues with Horizon".
That particular paragraph suggests perhaps that
there are issues with Horizon. But that wasn't
something that you thought of at the time?
I'm not sure if -- so this particular paragraph doesn't
jump out, clearly wrongly in hindsight. I probably put
more weight on some of the text in Rodric's covering
154
of his expert court reports, its status as a disclosable
document ends where he no longer provides such reports.
Accordingly, it's unlikely to require disclosure in any
further cases and will not be disclosed any pending or
future prosecution."
There is also another attachment to that email it's
POLO00196710, and that's an example covering letter that
was sent out regarding disclosure, and it's the second
paragraph that refers to the Second Sight Report and the
Helen Rose Report.
I'd like to take you to the final report to the
Board, that's POLO00196706. So this is the ultimate
briefing that was produced, presumably finalised after
you had received those documents?
Yes.
If we have a look at the third bullet point, it's dated
24 October:
“Our external firm of criminal solicitors,
Cartwright King, has now completed a review of 301 cases
subject to past prosecution to identify whether we have
a duty to disclose the findings of the Second Sight
Report and associated issues.”
So now the Helen Rose Report is now referred to as
“associated issues"; is that right?
Yes.
156
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[Cartwright King] has concluded that disclosure is
appropriate in 10 of these cases, and a short letter has
therefore been sent to each of the dense teams to bring
their attention to the report. It is now a matter for
the defence in each case to determine what action, if
any, they might take in light of this additional
information. We are also awaiting an unknown number of
further historical prosecution files from Royal Mail,
although at this stage we have no reason to believe
these will subsequently increase the number of actual
disclosures. In view of the potential interest from the
Criminal Cases Review Commission, we have also asked our
criminal barrister, Brian Altman QC, to conduct
an independent review of the overall process we have
taken to review past cases, reaching the conclusion that
‘our approach is ‘fundamentally sound’.”
So that was the ultimate summary of the passage that
we have been looking at. Perhaps we could bring it up
‘on to screen alongside POL00196707, page 4 of that
document, if that's possible. Thank you. So if we
scroll down slightly on the left-hand side we can see,
it was that second passage that I took you to, earlier,
the slightly more nuanced approach to references to the
Criminal Cases Review Commission, and it seems as though
that, to some extent, has been lost in the final
157
expected role going forwards (bearing in mind that
certain Board members will have a strong expectation
that they should be out of the process by the end of
December -- so we may have to manage these
expectations)."
This is a separate issue but it's something we
discussed earlier about moves to limit or end Second
Sight's involvement.
Then:
"Any additional detail on the settlement policy
which we're in the process of developing ..."
I think it's the final bullet point here:
“Any explanation of the issues around the review of
past criminal cases, which Rodric can help provide,
covering: a) what exactly has been disclosed so far; and
b) our best guess of the implications of these
disclosures (ie explaining that at this stage we have no
reason to believe that this means past cases will be
found to be unsafe)."
Just pausing there, how had you formed that view?
I think that had been informed by the emails we'd seen
earlier from Rodric and others, including some fairly
reassuring quotations from the Brian Altman reports.
"I've attached an email from Rodric, which contains some
of the answers to these questions, but would be useful
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briefing; would you agree with that?
Yes, it's clearly gone through further editing, yes, I'd
agree with that.
Can we please turn to POL00196705, and this is the
reference to the briefing that you have mentioned. It's
28 October 2013. One of those attachments is the email
chain that we've been looking at with those various
attachments, and you say as follows:
"Hi Belinda, here's the final text on Sparrow [so
that's the final text that I just took you to, the
separate attachment] which went into the CEO's report.
As discussed earlier, very grateful if you could
coordinate the briefing which Paula will need ahead of
the Board to bring her up to speed on the issues and
prepare her for any difficult questions from the
[Non-Executive Directors]. It now looks highly likely
that Paula won't be able to attend tomorrow's steering
group -- if we can fit in a separate short catch-up for
you, Chris and her, we will but this might not be
possible.”
Then there are various bullet points, one is "Update
‘on any mediation/Working Group process”, including
feedback from Tony Hooper's first meeting in the Working
Group:
“Linked to this, an explanation of [Second Sight's]
158
to have this together in one place."
Then if we look at the bottom of that email, it
says:
"The Board is on Thursday, so it would be useful for
her to have this by tomorrow evening or Wednesday
morning. As you know, I'm on leave after today -- I may
have an opportunity to log on in the evenings to look at
things, but if not then I suggest you send directly to
Paula copied to me."
So the work that you had been carrying out in the
previous days on the CEO's report to the Board and the
information that you had gathered from Rodric Williams
has now just been handed over Belinda Crowe to summarise
for Paula Vennells; is that right?
Yes, essentially.
Did you keep tabs on what form the briefing ultimately
took?
I don't believe I did. I think I followed it up -- by
the time I returned, the Board meeting had already
happened, so the kind of the moment had passed but
I recall -- I remember seeing confirmation that
a briefing had been sent.
But you don't recall reading the briefing?
No, by then I was on leave.
We saw those discussions about the Helen Rose Report and
160
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its implications, and your view was to leave it out of
the Board -- the paper that went to the Board but
I think you had confidence that it would be raised by
Ms Vennells at the Board. Did you take any steps to
make sure that there was a proper briefing in that
respect?
I think I relied on -- I clearly here have passed the
baton to Belinda to coordinate with input from Rodric,
I've relied on that process and that input to Paula to
get to the right answer.
What was Belinda Crowe's role?
I think by now she had just taken over as Programme
Manager for what was then called the Sparrow process, so
coordinating all of these workstreams.
I think you said that you didn't have a good knowledge,
or any knowledge, of the contents of the Helen Rose
Report before you had seen it, or even the Brian Altman
report up until very recently. Were you aware of her
state of knowledge of the underlying issues when you
sent this email?
I was aware she was -- she was also new to these topics
and would be heavily reliant on input from Rodric to get
to the right information. I think Rodric was copied
into this email.
Thank you. Can we please turn to POL00029707. This is
161
The first is ShEx, and your involvement and
relationship with them. Could we please turn to
UKGI00001852.
I think you said you were the main liaison when it
came to non-communications matters; is that right?
I think -- yeah, I provided an informal channel of
communication, if they needed to pick up the phone to
someone, I was a point of contact they could use, yes.
If we look at the bottom of page 2, we see
correspondence between Mr Batten and Rodric Williams,
and you're copied in to this email. This is an email
that we saw with Jo Swinson because she was going to be
making an announcement to Parliament and they were
seeking information about numbers of convictions. If we
look above, there's a series of questions that have been
posed by Mr Gibson of the Shareholder Executive.
If we go to the first page, at the bottom of the
page, Susan Crichton has said, “On to it". So they're
‘on to finding out the questions, and also "we are
working on this".
Then if we scroll up slightly, Mr Batten said -- and
this is 16 July, so a week later:
"Did Susan, Rodric or Martin ever come back to
either of you on this? (I know [Post Office] often drop
me off their copy lists -- I try not to take it
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a much later email, and I don't think you're involved in
this correspondence, but it's a document that I took
Mr Parsons to, where he talks about the Helen Rose
Report. If we scroll down to the penultimate paragraph,
he says as follows:
"Putting this issue aside, the real (and
confidential) reason that the report was disclosed was
because Helen's comment at the bottom of page 3 suggests
that it was widely known that there were problems with
Horizon. This statement (regardless of whether it is
correct) could have been used to attack Gareth Jenkins’
credibility as [Post Office's] Horizon expert as he had
previously stated that there were no problems with
Horizon."
Is that something that you were aware of?
No, no. This very clear explanation of the implication
of the Helen Rose Report wasn't apparent to me until
I read -- until this document was disclosed to me and
I have followed some of the other evidence. So
candidly, the penny only dropped very recently on
exactly why the Helen Rose Report was significant. That
wasn't apparent to me in this very clear way at the
time.
Thank you. I have two very brief topics to address
before I hand over to others.
162
personally)."
Then above we have Mr Whitehead saying:
"Sadly they have a habit of dropping everybody off
when we seek ‘awkward’ data. I have not seen anything
and my guess is that without a chaser, they'll
unilaterally decide we don't need it!"
Was that typical of your relationship with UKGI?
I don't think -- I think what it probably does reflect
is a bit of mutual frustration on the way information
was requested and shared between the business and UKGI
and there were two perspectives on that. Clearly what
we've seen here is a frustration from the ShEx team, not
getting the information they need. On the other side,
the frustration from the business is requests appear to
come in quite -- in an unstructured way at short notice,
and there were frustrations on both sides and it clearly
wasn't always working very well.
I think over time, we moved on to a more structured
basis, to the benefit of both sights, but I think this
does absolutely reflect a bit of a kind of teething
problem on the early relationship between the business
and the shareholder, post-separation.
Could we please turn to POL00373845, and this relates to
Mr Callard becoming a new Non-Executive Director of the
Post Office. So we're moving on now to February 2014.
164
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If we look at the bottom email, Ms Vennells sends
an email to a group, and if we look slightly below that,
just at the top of the next page, she says:
"Richard's scope has not yet picked up Sparrow or
Business Transformation. It will as he is attending
next week's Board meeting. But as this is the case,
I suggest that we leave him off the ShEx review agenda
as he will be well briefed by then.”
If we scroll up, please, to your response, you say
as follows:
"On a separate but related topic, it's just struck
me this evening (belatedly) that I, Alwen or Chris D (or
a combination of all three) need to get into the
discipline of reading the draft Board papers with
a specific focus on checking for ShEx sensitivities, now
that [Mr Callard] will be receiving them. There are
numerous small points we need to watch out for. I'll
read through the ones I haven't checked in the morning,
kids permitting."
Can you assist us, why would you need to redraft
papers with a specific focus on checking for ShEx
sensitivities?
So I think this would have been a general point. It was
recognising -- whilst it was quite right that we moved
to the position of ShEx having a representative on the
165
Was about that removing Second Sight or limiting
their involvement?
I think that may well have been -- that's probably what
it was referring to. I think, by then, there had been
some ongoing debates with the business about Second
Sight's role, so yes, that's highly likely to be that --
what I was referring to.
Thank you. That can come down.
We've spoken today about one particular role you
had. How do you consider that role as Chief of Staff
prepared you for your subsequent roles at the Post
Office?
Well, it clearly gave me a broad insight across the
business. A lot of my time as Chief of Staff was
actually spent more on the strategy and funding side and
that was kind of very squarely what I worked on in the
next job.
Is that as Group Strategy Director?
Yes, yes, and, I mean, more generally, this whole
experience has, I think, given me lots of lessons for
subsequent roles in the Post Office.
Have you taken part in any lessons learned exercises?
I mean, I think it's fair to say the whole business has
been going through a lessons learned process over the
past few years. I think it's kind of built into the
167
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Board that was new for the business, and there were
sometimes tensions and conflicts of interest,
particularly part of our relationship between ShEx and
the Board of ShEx was our funder, so for example we
might be putting papers to the business which are
relevant to our funding position.
Previously, the business could have drafted papers
without worrying about ShEx seeing that paper. So
clearly there were, I think, it's -- there was
a potential for sensitivities across the piece, as
I say, numerous small sensitivities. It just felt like
good discipline to make sure there is a kind of filter
on the papers, that we are reviewing the papers for any
watch outs.
"NB on your point below about Sparrow, Belinda and I met
[Richard Callard] yesterday afternoon so he's now fully
up to speed (and understands why this was high on your
list of things that keep you awake at night!).”
What did you mean there?
I think really it was clearly it was a major issue for
the business and major issue for the Chief Executive,
and Richard Callard was now briefed on that.
"He now has a good understanding often the handling
issues around Second Sight and the scenarios in which we
may need further support/cover from ministers.”
166
business now.
For you personally, what have you particularly
identified as your own lessons to be learnt from the
role that you played?
So I think there's a number. I think the first one,
it's very apparent in hindsight that I had been -- the
business was caught up in groupthink and I was part of
that, and at no point do I see myself properly stepping
outside that and challenging it. And I deeply regret
that and I think that's been a hugely important lesson
tome.
I think a second lesson which links to that, at that
point in my career, I would have taken advice from legal
experts or IT experts at face value and I'm now far more
aware that advice from experts needs to be properly
challenged and scrutinised. Everyone has biases in the
advice they need to provide and that needs appropriate
scrutiny.
And I think the third lesson is the important,
particularly for the roles which I do, which tend to be
working at the centre of the business working on
high-level strategy is balancing that with
an understanding of individual perspectives.
MR BLAKE: Thank you.
Sir, it's now time for some questions from Core
168
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Participants. Are you happy for us to proceed with
Mr Henry, and then perhaps take a short break. We have
a very small number of questions from Mr Jacobs,
Mr Moloney and Ms Watt, which shouldn't be too long.
I think Mr Henry has the larger number of questions.
SIR WYN WILLIAMS: Well, I'll do whatever suits the
transcriber best on this occasion. So we've been going
for --
MR BLAKE: 1 hour 10 minutes.
SIR WYN WILLIAMS: I don't want to necessarily circumscribe
Mr Henry but if he's going to be ten minutes we'll do as
you say, if he's going to be 20 minutes, I think it's
probably appropriate to have a break.
MR HENRY: I Sir, I think the shorthand writer would like
a break.
MR BLAKE: Yes. So perhaps we could take a ten-minute break
now.
SIR WYN WILLIAMS: Fine. All right.
(3.06 pm)
(A short break)
(3.16 pm)
MR BLAKE: Thank you, sir. We have Mr Henry, followed by
Ms Watt, followed by Mr Moloney.
SIR WYN WILLIAMS: Fine.
MR BLAKE: Thank you.
169
Q. You recall that from as long ago as 2013 but you did not
mention it once in your witness statement. You were
holding it back, weren't you?
A. I focused my witness statements on the questions posed
to me as part of my Rule 9 Request there. There was
nothing on this specific topic.
Q. But it was a very significant matter and you did not
volunteer it, did you?
A. Candidly, I certainly didn't appreciate the significance
of this matter at the time. I didn't appreciate it when
I constructed my witness statements. Everything I've
heard since then, I do understand its important but it
was certainly not a deliberate withholding of that.
Q. You are telling the Inquiry Chairman that you did not
appreciate its significance at the time. You obviously
appreciated its significance at the time when you were
told it. Correct?
A. In the terms I described earlier.
Q. You know the purpose of this Inquiry, it's a highly
material issue, an issue of extraordinary importance.
I suggest that you were hoping it would not be
discovered.
A. No, that's not the case.
Q. You knew that the Inquiry was not aware of the issue at
the time and hadn't unearthed the email from Paula
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Questioned by MR HENRY
MR HENRY: = Mr Edwards, you were part of an Executive Team
that used all its guile and skill to suppress the
reputational and financial risk of historical
prosecutions being reopened, weren't you?
A. I think I was clearly part of an Executive Team which
didn't do enough to put this right at that stage.
Q. You did precisely the opposite of furthering the right;
you were actually involved in suppressing the matter,
weren't you?
A. I'm not sure I'd agree with that.
Q. You were even complicit in a cover-up concerning the
unsafe witness, were you not?
A. I certainly wasn't, no.
Q. Now, you do not mention the issue of the unsafe witness
at any stage in your witness statement of the 18 April
2024, nor in that witness statement do you mention any
conversation you had with Paula Vennells in respect of
that issue of the unsafe witness; do you accept that?
A. Yes, it's not in my witness statement.
Q. Yet when Mr Blake asked you about this very significant
conversation, you offered an account that the unsafe
witness, so you were told by Ms Vennells, was implicated
in five cases; is that correct?
A. I recollected that being a small number, yes.
170
Vennells to Alice Perkins, but you were aware of the
issue, Mr Edwards, and you didn't volunteer it. That's
the truth, isn't it?
A. No, that's not the case. I didn't recollect that email,
I didn't particularly have a strong recollection of this
issue. I didn't -- my appreciation of the significance
of this issue has been very recent. I certainly did not
appreciate the significance of this issue at the time.
Q. I suggest that that cannot be right. At the very least,
from what you knew at the time, back in 2013, was the
risk that five people may have been convicted on the
back of evidence from an unsafe witness. That surely
would have been obvious to you?
A. AsI described, the account I was given of this was it
was clearly important. My understanding at the time was
that was going to be disclosed to the past prosecutions
but I was not led to believe at the time that it was
highly material on top of other information which had
been disclosed. I completely did not appreciate the
significance of this at the time.
Q. So when you say that your understanding at the time was
that it was going to be disclosed to the past
prosecutions, was that something that just floated into
your head or were you told that by Paula Vennells?
A. That was my under --
172
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The Post Office Horizon IT Inquiry
Where did you get the understanding from?
That was the nature of the conversation, indeed, I think
in the email we looked at from Ms Vennells to (unclear)
it talks about the disclosure of this information.
On the contrary, that email reads -- and there's no need
to get it up on screen:
"My concern re Sparrow currently is our obligations
of disclosure re an unsafe witness. The representative
from Fujitsu made statements about no bugs which could
later to have been seen to be undermined by the Second
Sight Report. We do not think it material, but it could
be high profile. Martin E is briefed if you want more
detail. This is just in case."
Do you want to reflect on the answer you've just
given?
I think what that email refers to, it talks about
obligations re disclosure. My -- as I said my
recollection of this conversation is hazy, but as
I understood it, Cartwright King, as our external
lawyers, were reviewing the disclosure of this
information to the past cases and, as Paula goes on to
describe, it wasn't viewed to be material. That is
consistent with my recollection and understanding at the
time.
Well, I'll come back to that. I want to go quickly to
173
Yes, I'd agree with that.
You were told, you claim by Ms Vennells, that the unsafe
witness concerned five cases. Five, 50 or one case:
an unsafe witness had given evidence against
subpostmasters and people had been convicted, hadn't
they; you knew that?
Yes.
Right. Now, you were the Chief Executive Officer's
Chief of Staff and yet you claim you hadn't read the
Altman General Review of 15 October 2013, before
drafting her report to the Board?
I hadn't -- no, I hadn't been given that document.
You stand by that?
Yes.
You're admitting negligence, aren't you? It would be
negligent to draft a Chief Executive Officer's report to
the Board on a very serious matter, without having read
the Altman General Review?
In the role I was performing -- so in that Chief
Executive's report, I'd been covering maybe a dozen
major topics on the business, I was heavily dependent,
completely dependent on the input from Subject Matter
Experts. I didn't have the capacity to read every
document and do everything they were doing. I think in
hindsight, I would agree there was not enough scrutiny
175
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your statement, no need to get it up on the screen I'll
read it verbatim, paragraph 13.
"I believe I first became aware of concerns raised
about bugs, errors or defects with Horizon due to the
campaigning work of Alan Bates and the Justice for
Subpostmasters Alliance. On 4 October 2012, a couple of
weeks after I joined the Post Office, I attended
a meeting with Paula Vennells, James Arbuthnot and Alan
Bates of the JFSA in relation to the Second Sight
investigation. I attended the meeting in a note-taking
capacity only. During the meeting, alleged Horizon
errors were raised by Alan Bates."
I don't need to take you to the document but your
notes of that meeting are recorded at POL00295635, notes
which are dated 5 October 2012. Amongst those notes:
"Meeting with JA and AB. Paula said it was
absolutely essential that the judicial process was
flawless and, therefore, would consider this point which
had been raised by [Sir Alan Bates] in detail."
That was about unfairness to subpostmasters.
If it is absolutely essential, Mr Edwards, that the
judicial process is flawless, would you agree that that
would mandate disclosing to the defence any wrongdoing
by an expert who had secured a conviction for the Post
Office against a hapless defendant?
174
by the Executive Team of, as we've heard, there wasn't
enough sharing of legal advice. I didn't see that at
the time.
But this is totally contrary to your role. A top,
politically astute and well-connected Queen's Counsel
has been appointed to do a general review and yet are
you telling the Chairman that nobody in the Executive
Team read the general review by Brian Altman QC?
I. can only comment on -- I didn't see it.
It's totally contrary to your role because, when you
were suggesting, at an early stage in your evidence --
but I think you've resiled from it -- that you were
a mere conduit, nevertheless you were digesting and
appraising material that was directed to the CEO, so you
could apprise her of the contents. You must had read
the Altman General Review?
I did not read the Altman General Review. I did not see
it.
Right, well we see in the email that I have quoted,
already, that Paula Vennells used the term "material"
when she was writing her email to Alice Perkins. In the
Altman General Review, the term "material" is mentioned
35 times. Were you familiar with the term "material"?
Not specifically, no.
Yet, according to your boss, "Martin E is briefed if you
176
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The Post Office Horizon IT Inquiry
want more detail" -- and I emphasise "more detail" --
"this is just in case".
Are you telling the truth, Mr Edwards?
I am absolutely. I gave my evidence on that earlier.
I was given as a point of contact for Alice, if she
needed more detail. In practice, I'd clearly be reliant
‘on the legal teams to provide that.
So, although you were briefed on the issue, again,
you're merely saying that you're just, as it were,
a conduit, that she'll contact you and then you'll put
her in touch with who: Rodric Williams, Hugh Flemington,
et cetera, et cetera?
Yes, I think it would have been more appropriate for her
to be in contact with the General Counsel but, as you're
aware at that point in time, one General Counsel was
leaving and another one was just about to join. So
I was there as a point of contact for Alice but, yes,
I would have been reliant on getting answers to the
questions from the Legal team.
Now, you knew why General Counsel was leaving,
presumably: because you were the Chief of Staff to Paula
Vennells. What had she told you about the departure of
Susan Crichton?
I was aware that there had been tensions between Susan
and Alice and the broader Board. I wasn't party to all
177
the issue."
Not, "I will get Flemington, Williams -- God
forbid -- Singh to give background notes on the issue:
I will still need to give Paula background notes on the
issue".
How were you going to do that, if you hadn't read
Altman?
When I say “I will need to give Paula background notes",
that doesn't mean I will need to be responsible for
drafting them. My role was to make sure Paula had the
briefing she needed. I was heavily dependent on Subject
Matter Experts to provide that and I therefore arranged
for that to be provided.
I suggest that the Helen Rose Report -- and we can deal
with this very quickly -- would reveal that Gareth
Jenkins had a credibility problem, that he'd not been
frank about bugs, errors and defects, and Mr Blake took
you to paragraph 173 of the Altman General Review, which
says just that. You were making sure the Board were not
told about a document which might have brought up the
potentially high-profile issue of the unsafe witness;
isn't that right?
No, absolutely not.
If, as the Helen Rose Report suggested, it was widely
known that there were problems with Horizon, that could
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of the detail which the Inquiry has now seen.
Did Paula Vennells say that Susan Crichton's loyalties
were misplaced and that she was ascribing too much
loyalty to her professional obligations?
No, that wouldn't be the type of conversation we'd
have -- she would have with me.
Yet you were her Chief of Staff?
Yes.
I want to go now to POL00372558, and I want to enquire
with you about why you took certain decisions in respect
of this exchange between you and Rodric Williams.
Again, it's in the context of the report of the CEO to
the Board. Just dealing with that:
"As you'll see from the text I've just
re-articulated, I've decided it's probably better not to
mention the Helen Rose Report specifically, as it will
only serve to confuse things with the Board (although
I will still need to give Paula background notes on the
issue)."
How were you going to do that, if you hadn't read
Altman?
Well, as we covered earlier, the practical step I took
was to arrange for the team to give Paula a briefing on
this.
"... [will still need to give Paula background notes on
178
have been used to attack Gareth Jenkins’ credibility.
You can't deny that, can you?
Sorry, can you repeat the question?
It's not a coincidence that you decided it's probably
better not to mention the Helen Rose Report because the
Helen Rose Report was welded together with the issue of
Gareth Jenkins’ credibili
No, I didn't, and I think it's evident from my email
exchange with Rodric that I'm none the wiser on the
significance of the Helen Rose Reports. I absolutely
didn't understand its significance and, as I described
earlier, I didn't understand its significance until
extremely recently, and I've seen other disclosures
which spell it out very clearly. I did not have that
awareness at the time.
You're presenting yourself as some naif, and yet you're
the Chief of Staff to the CEO. I suggest that your
response there is dissembling.
No, it's not. It's become apparent to me that there
were a number of topics which, candidly, I was naive
about, so I didn't understand the full details. The
ou knew that?
nature of the Chief of Staff role: I was spread across
dozens of major topics across the business. It simply
wasn't possible to understand the detail of everyone
but, yes, candidly, I was naive on some of these topics.
180
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Q. Let me go to page 4 of that document, please. This was
your first stab at a précis, and I want to go through it
very, very quickly:
"Our criminal barrister, Brian Altman, has now
completed his review [et cetera, et cetera, et cetera]
‘our approach is ‘fundamentally sound’, providing us with
strong grounds to resist any formal review of our
historic prosecutions (for example by the Criminal Cases
Review Commission)."
Who had suggested that the Altman Review would
justify stonewalling the Criminal Cases Review
Commission?
A. I think, as I described earlier, this text was the
synthesis of some contributions from Andy Holt, which
I then asked some questions on, and I think it was then
farmed out to Andy Parsons to provide input. I took
that input and crafted this sentence, and sent it to
Rodric to check.
Q. Ofcourse, he moderates it, to some extent, but was this
reflecting the views of Paula Vennells that had already
been disseminated, or were the people that you say are
responsible for this text quite confident that this
pre-packed approach would be accepted by the CEO; this
obdurate opposition to the appeals would be accepted,
without demur, by the CEO?
181
Q. Well, we've gone through this already at great length
with Mr Blake but there was, if not consternation or
near panic, there was great anxiety in the Executive
Team. Mr Blake has taken you, for example, to
POL00098778, 28 June 2013, where Gareth Jenkins writes
the email saying:
"Lesley, attached is my final witness statement for
the Misra case. This was heard in Guildford Crown Court
in October 2010 and concerned the West Byfleet Post
Office."
You get a copy of that email; it's forwarded to you;
it's 28 June. So you know that Gareth Jenkins has given
evidence against Seema Misra and you also know that
Gareth Jenkins has caused a problem in the disclosure,
or rather non-disclosure, of bugs, don't you?
A. No. The second half of that is not correct.
Q. Well, you knew that he was the person who had spoken to
Second Sight?
A. I did not know that, no.
Q. I suggest that's all in the context of him suppressing
the evidence of bugs, errors and defects, as confided to
Second Sight, and that you were well aware of that?
A. That's not correct.
Q. Then on 1 July, there's a high-level briefing for the
Board, POL00060587. Mrs Misra is mentioned in the
183
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A. I don't know and I think, in hindsight, the CEO's report
was the wrong place to be -- the CEO's report covers
a number of major topics in very brief detail, as you
see, in really short paragraphs. It's really clear, in
hindsight, that this wasn't appropriate to be covering
this information. I wasn't the right person to be the
intermediary of this. In hindsight, this warranted
a separate, full briefing note from the Legal Team, and
that's what should have gone to the Board.
Q. I want to deal with the unsafe witness in conclusion one
final time. The evidence base, by 23 October,
I suggest, was that Paula Vennells knew that Gareth
Jenkins was unsafe. She knew that he had given evidence
against Seema Misra and she decided not to disclose that
to the CCRC or Mrs Misra's lawyers; you knew that,
didn't you?
A. No.
Q. In June 2013 -- because there is a run-up to this -- in
June 2013 it had become apparent, had it not, that
Gareth Jenkins had disclosed to Second Sight the
existence of bugs, errors and defects in the Horizon
system, and you were aware of that?
A. What I was briefed on at the time is those bugs had been
passed on by the Post Office team. That was what's kind
of contained in the briefings at the time.
182
context of her trial. Then we've seen again, with
Mr Blake taking you to it, the strapline is "Re PV and
AP brief". It's POLO0190092.
The Board had to have a line on historic
prosecutions. Do you remember that this morning: that
you needed to have a line on historic prosecutions?
That, again, is connected to Gareth Jenkins because he
was the flawed expert who had failed to disclose bugs,
errors and defects; you must accept that?
A. I'm afraid I didn't follow all of that. Can you break
that down: which specific document and point in time are
we referring to? I'm afraid --
‘SIR WYN WILLIAMS: Well, I think Mr Henry is right in the
sense we did go through that this morning, so I don't
think I need to have it again, Mr Henry.
MR HENRY: Right. Certainly, sir.
You knew, because you drafted the briefing for Paula
Vennells, that Gareth Jenkins had given evidence against
Seema Misra; you must accept that?
A. I saw that, that witness statement which Lesley Sewell
forwarded, yes.
Q. Also you actually drafted it, as well, on 1 July for --
forgive me, no need to take you to it -- POL00113367.
It's a document you've seen but at page 1 of 13 you
raise the issue of James Arbuthnot perhaps reviving
184
(46) Pages 181 - 184
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The Post Office Horizon IT Inquiry
historic prosecutions, and at page 5 of 13 you raise the
issue that Gareth Jenkins had given evidence against
Seema Misra.
I'm sorry, I don't --
You don't --
I don't recognise that, sorry.
Let's quickly go to that document, then. POL00113367.
This isn't a document I produced.
But you certainly saw it?
I saw it, yes.
Yes, and you read it?
I believe so, yes.
Let's scroll up, please, on page 1. Do you see
paragraph 8?
Yes.
Clear risk identified.
Could we go to page 5, please. We can see
paragraph 30:
"The Falkirk Anomaly", et cetera, et cetera.
(b):
"The prosecution expert (Gareth Jenkins from
Fujitsu)", et cetera, et cetera.
So what I'm trying to establish, through you, is
that both your state of mind and Paula Vennells' state
of mind is that Gareth Jenkins was the expert and Gareth
185
SIR WYN WILLIAMS: Yeah, fine.
A.
While we're waiting for the next set of questions,
can I ask you, Mr Edwards, in the email of October when
Ms Vennells told Ms Perkins that you were briefed if she
needed any more information, nobody has asked you the
direct question but, just in case: did Ms Perkins ask
you any questions or ask you to explain anything further
following that email?
No, sir. I don't recall any follow-up from Alice
Perkins.
SIR WYN WILLIAMS: = Right. Fine. Thanks.
Yes, who's next?
MR BLAKE: It's Ms Watt.
MS WATT: Thank you, sir.
Questioned by MS WATT
MS WATT: Good afternoon, Mr Edwards. I ask questions on
behalf of the NFSP.
I think it's fair to say that there are few
survivors at the Post Office today from what we might
term the "Paula Vennells era", and I think you and
Rodric Williams are among the main ones; is that
correct?
I'm one of the few people from that era, yes.
You're currently the Network Strategy and Delivery
Director and you advised Mr Blake this morning that this
187
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26 July 2024
Jenkins had given evidence against Seema Misra.
I think, yes, that's evident from this.
And that you, therefore, both of you, were aware of that
at the time of the conversation on 21 October 2013,
which was about a week after the Altman General Review.
You were both aware of the significance of the unsafe
witness in relation to not five cases, but that one
specific case concerning Seema Misra.
Candidly, I don't recall drawing a specific link back to
this document, which I saw four or five months earlier.
‘SIR WYN WILLIAMS: I Is that it, Mr Henry?
MR HENRY: That's it, sir.
SIR WYN WILLIAMS: = Thank you.
Before we get the next one, could you just,
Mr Henry, confirm the reference you gave for the note of
the meeting which is described at paragraph 13 of the
witness statement? I wasn't sure whether I got it down
accurately.
MRHENRY: Certainly, sir. Do you want me to give it to you
now?
SIR WYN WILLIAMS: Yes, I'll read it to you. It's
POL00295635, is what I've written.
MRHENRY: That's correct, sir.
SIR WYN WILLIAMS: = That's correct. Fine.
MR HENRY: = Thank you so much, sir.
186
involves working with the Subpostmaster Network; is that
correct?
Yes.
I think it's the case that you currently have a senior
role in a wide range of business decisions that affect
subpostmasters, broadly including things such as, for
instance, the number of sub post office branches in the
network, the number of subpostmasters in the network,
financial packages, decisions on closure of branches,
compensation in the Hard to Place scheme, and generally
just a great deal of what affects postmasters today;
would that be fair?
Yes.
So thinking about that, taking account of that, and
given the evidence that we've heard from you today about
your knowledge and role in working with the former Chief
Executive, Paula Vennells, and Horizon-related issues,
including some things that we saw, comments you had
made, such as "making sure subpostmasters don't get off
scot-free" -- in other words, escape deserved punishment.
and suchlike -- would you accept that it is -- should be
and can be -- a significant concern to the subpostmaster
network of today, and those representing them, that you
should be in a role now that affects their working and
financial relationships?
188
(47) Pages 185 - 188
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The Post Office Horizon IT Inquiry
A. I think that is a question for others to judge. As
I mentioned in my evidence earlier, I fully accept I was
caught up in part of the groupthink back in 2013 and
I didn't -- I don't believe I provided enough challenge,
I didn't step outside of the mindset at the time, and
I deeply regret that. I think I have learnt a huge
amount from that and I think I am still able to do
a good job for the business and for postmasters but it's
ultimately for others to judge that question.
MS WATT: Thank you.
‘SIR WYN WILLIAMS: Thank you, Ms Watt.
Is it Mr Moloney now?
MR BLAKE: It is, yes.
Questioned by MR MOLONEY
MR MOLONEY: Mr Edwards, I simply want to ask you very
briefly about Project Zebra and the Deloitte report.
A. Yes.
Q. In 2013/2014 you were aware that there was an issue
around remote access?
A. Yes.
Q. Yeah, and the Deloitte report for Project Zebra was
delivered in mid-2014?
A. Yes.
Q. Did you read that report, Mr Edwards?
A. I didn't, no.
189
(The hearing adjourned until 9.45 am
on Monday, 29 July 2024)
191
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Q. Did you read the Board's summary?
A. No. AllI recall reading on this -- I wasn't
particularly closely involved with the matters at this
point. So I recall reading a summary email from Chris
Aujard to the Board but I didn't read the report itself.
Q. Did you discuss the findings of the report with
Mrs Vennells?
A. No, I was very ~- I wasn't closely involved with matters
at this time.
MR MOLONEY: = Thank you very much, Mr Edwards.
‘SIR WYN WILLIAMS: I Is that it, Mr Blake?
MR BLAKE: Thatis, yes, sir.
SIR WYN WILLIAMS: = Well, thank you, Mr Edwards, for making
your witness statement and for giving evidence orally
before me today. I'm grateful to you.
THE WITNESS: Thank you.
SIR WYN WILLIAMS: = Right. Two days next week, starting on
Monday, Mr Blake?
MR BLAKE: That's correct.
‘SIR WYN WILLIAMS: All right, 9.45. It's one witness on
Monday. I take it we still want to start at 9.45, do
we?
MR BLAKE: Yes. Thank you, sir.
SIR WYN WILLIAMS: Fine. All right.
(3.50 pm)
190
INDEX
ALLAN LESLIE LEIGHTON (re-sworn) .....
Questioned by MR STEVENS .
Questioned by SIR WYN WILLIAMS .. 58
Questioned by MR STEIN ..... 61
MARTIN ANTHONY EDWARDS (affirmed) ........ 64
Questioned by MR BLAKE .... 65
Questioned by MR HENRY ... 170
Questioned by MS WATT .. 187
Questioned by MR MOLONEY ... 189
192
(48) Pages 189 - 192
MR BLAKE: [19]
64/22 64/24 65/2
116/18 116/22 116/24]
117/3 117/5 136/6
168/24 169/9 169/16
169/22 169/25 187/13
189/13 190/12 190/19
190/23
MR HENRY: [7]
169/14 170/2 184/16
186/12 186/19 186/23
186/25
MR MOLONEY: [2]
189/15 190/10
MR STEIN: [2] 61/17
63/25
MR STEVENS: [17]
113 115 1/23 39/15
40/16 41/11 41/20
41/22 42/1 42/3 42/7
42/9 61/3 61/10 64/3
64/13 64/18
MS WATT: [3]
187/14 187/16 189/10
SIR WYN WILLIAMS:
[52] 1/4 1/20 39/11
39/20 40/13 40/15
41/14 41/21 41/24
42/2 42/8 58/18 58/22!
58/25 59/5 59/23 60/7
60/21 61/1 61/15 64/2
64/4 64/17 64/23
116/21 116/23 117/4
134/9 134/22 135/2
135/13 135/21 135/24
136/2 136/5 169/6
169/10 169/18 169/24
184/13 186/11 186/13
186/21 186/24 187/1
187/11 189/11 190/41
190/13 190/17 190/20
190/24
THE WITNESS: [3]
64/1 64/12 190/16
‘added [1] 153/18
"Around [1] 109/13
‘awkward’ [1] 164/4
‘fundamentally [4]
146/9 147/9 157/16
181/6
"Helen [1] 153/9
‘Horizon’ [3] 93/18
126/23 127/2
‘I[4] 33/15
‘Ido [1] 33/15
‘immunity [1] 98/16
‘Nothing [2] 89/2
95/13
‘responded [1]
147/12
‘rocks' [1] 94/7
‘since [1] 86/1
*Stalinistic’ [1] 50/2
"unlikely [1] 153/15
= about [1] 108/10
--to [1] 104/4
0
04/97 [1] 16/20
1
1 January [1] 31/13
4 July [2] 183/24
184/22
1 million [3] 56/22
57/20 57/22
4-2 [4] 122/12
1.00 [4] 116/25
4.50 [2] 116/22 117/2
10 [3] 47/5 157/2
169/9
10 July [1] 113/18
10-15 [1] 151/5
10.41 [1] 90/17
10.54 [1] 42/4
100 [5] 6/11 8/17
63/20 109/13 110/18
108 [1] 17/2
11 [3] 2/23 68/9
146/15
14 April [1] 33/4
11 years [1] 66/17
11,800 [1] 94/25
11.00 [3] 42/1 42/6
91/1
11.35 [1] 64/19
11.38 [4] 95/5
11.45 [2] 64/16 64/21
12 July [4] 114/4
12.17 [1] 96/17
126 [2] 2/9 33/5
13 [7] 2/24 4/17 17/2
174/2 184/24 185/1
186/16
13 October [1] 16/18
138 [1] 2/11
139 [1] 2/17
14 [6] 23/16 35/14
78/22 80/16 93/13
95/8
14 December [1]
23/14
140 [1] 36/3
142 [1] 140/8
15 [4] 151/5
15 July [2] 113/13
140/13
15 October [2]
139/23 175/10
15 September [1]
20/18
152 [1] 3/14
159 [1] 4/17
16 [1] 6/19
16 July [1] 163/22
160 [1] 4/24
163 [1] 5/13
164 [1] 6/20
165 [1] 7/20
17 April [2] 1/8 1/15
173 [2] 142/17
179/18
18 [2] 45/5 139/25
18 April [2] 65/8
170/16
2
2 July [2] 52/8 81/7
2,000 [1] 48/8
2.04 [1] 97/20
20 [2] 109/12 169/12
20 April [2] 26/13
47/4
20 August [1] 15/25
2003 [5] 15/25 31/13
31/15 35/2 49/10
2004 [2] 16/18 60/22
2005 [5] 21/17 23/14
23/21 24/6 42/19
2006 [5] 26/13 26/19
47/4 52/8 60/23
2007 [2] 31/14 31/15
2009 [1] 40/25
2010 [5] 35/2 54/23
55/22 78/21 183/9
2012 [6] 67/2 135/24
135/25 140/14 174/6
174/15
2013 [18] 70/14
70/23 114/4 126/22
140/14 140/15 142/21
144/1 149/22 158/6
171/1 172/10 175/10
182/18 182/19 183/5
186/4 189/3
2013 by [1] 149/20
2013/2014 [1] 189/18
2014 [4] 70/1 164/25
189/18 189/22
2024 [5] 1/1 20/18
33/4 170/17 191/2
21 [1] 36/4
21 October [1] 186/4
22 [3] 2/12 32/7
68/21
22 March [1] 26/19
23 [4] 10/7 11/6
65/21 65/25
23 February [1]
42/19
23 October [1]
182/11
24 October [1]
156/17
25 [1] 8/13
25,000 [1] 60/10
25th September [1]
132/13
26 July [2] 116/4
4117/7
26 July 2024 [4] 1/1
26th July [2] 136/23
137/2
27 [2] 35/23 35/24
28 June [2] 183/5
183/12
28 October 2013 [1]
158/6
29 January [1] 70/23
29 July 2024 [1]
191/2
29 September [2]
23/21 24/6
3
3 April [1] 140/14
3 July [3] 81/5 98/3
113/17
3 March [1] 54/23
3 September [1]
143/8
3.06 [1] 169/19
3.16 [1] 169/21
3.50 [1] 190/25
30 [4] 185/18
301 [1] 156/19
34 [1] 68/8
31 August [1] 31/14
32 [4] 2/8 2/9 22/5
33/4
35 [5] 2/11 36/1 36/2
45/6 176/23
36 [1] 48/15
38 [2] 3/13 3/13
38.1 [4] 33/12
4
4 October [1] 174/6
40 [2] 4/16 4/17
40 million [1] 94/13
41 [2] 5/12 35/15
41.1 [4] 35/14
42 [1] 7/19
44 [4] 8/12 10/7 69/5
140/6
45 [2] 11/7 65/11
47 [2] 118/3 118/7
5
5 January [1] 21/17
5 July [4] 52/22
104/25 108/24 115/23}
5 October [1] 140/14
5 October 2012 [1]
174/15
50 [3] 68/21 140/3
175/3
51 [1] 49/10
54 [4] 142/16
56 [1] 32/7
6
6 July [1] 53/5
62 [1] 93/14
64 [2] 80/17 95/8
69 [1] 16/3
7 August [1] 49/10
7 July [1] 53/13
73 [1] 8/13
8 July [2] 109/3
113/13
8.00 [1] 126/18
86 [1] 16/20
9
9 September [1]
136/7
9.45 [4] 1/2 190/20
190/21 191/1
97 [2] 16/20 16/25
99 [1] 69/5
A
A4 [9] 2/5 2/9 2/11
3/13 4/17 7/19 8/12
35/24 36/2
A4-page [1] 2/5
A4-page 27 [1] 35/24
A4-page 32 [1] 2/9
A4-page 35 [2] 2/11
36/2
A4-page 38 [1] 3/13
A4-page 40 [1] 4/17
A4-page 42 [1] 7/19
A4-page 44 [1] 8/12
AB [1] 174/16
able [13] 1/14 23/6
24/3 25/15 44/23
52/12 74/6 86/14
123/19 124/9 131/3
158/17 189/7
about [172] 2/12 3/10
8/6 10/21 18/1 18/8
18/8 18/10 18/12
18/13 18/16 18/19
18/21 18/22 18/25
19/10 19/12 21/2
22/11 23/9 28/12
28/13 28/16 28/17
28/20 29/14 30/6 32/9I
32/18 33/8 35/2 35/15]
36/14 37/15 39/13
39/14 40/2 41/2 41/16
42/9 43/13 45/23 46/1
46/4 46/14 46/24
48/23 48/25 49/21
52/9 52/11 53/25 54/1
54/11 57/3 58/18
60/10 60/24 61/2
61/18 61/20 62/7
(49) MR BLAKE: - about
A
about... [110] 62/17
63/16 65/25 66/17
67/18 69/25 72/25
73/24 75/4 75/17
76/20 76/24 77/13
77/14 77/17 77/25
79/12 79/25 80/3
80/10 81/1 85/23
86/17 91/17 91/17
91/24 92/6 92/8 92/10
92/12 92/24 93/2 96/9
98/21 99/18 103/24
105/8 105/17 105/24
106/8 106/25 107/7
107/20 107/24 108/10
109/7 109/12 112/20
113/1 113/5 113/15
115/4 115/16 117/9
117/22 118/3 118/22
119/17 122/18 122/20)
122/25 123/2 123/6
123/8 123/11 125/5
128/12 128/20 129/25}
130/20 131/21 132/3
132/10 133/16 134/22)
136/17 136/22 137/15
137/20 141/25 144/12)
151/20 152/6 152/20
154/6 159/7 160/25
162/3 163/14 166/8
166/15 167/1 167/5
167/9 170/21 173/4
173/9 173/16 174/4
174/20 177/16 177/22)
178/10 179/17 179/20)
180/21 186/5 188/14
188/15 189/16
above [9] 68/25
90/21 114/5 114/17
131/2 150/22 151/8
163/15 164/2
absence [1] 142/5
absolutely [32] 4/15
8/8 10/16 11/14 15/16
15/21 40/14 42/13
46/14 55/9 59/22 60/6)
60/25 89/11 89/22
100/1 103/13 106/11
108/3 108/4 112/2
113/11 121/8 123/11
134/17 150/18 164/20
174/17 174/21 177/4
179/23 180/10
accept [10] 12/8
30/24 40/25 46/8
57/11 170/19 184/9
184/19 188/21 189/2
accepted [2] 181/23
181/24
access [2] 50/9
189/19
accessible [1] 69/3
accompanied [1]
148/1
accompanying [1]
109/11
according [1] 176/25
Accordingly [1]
156/3
accords [1] 138/14
account [4] 68/14
170/22 172/14 188/14)
accountabilities [2]
69/9 69/13
accountability [2]
121/22 122/4
accounting [11] 5/22
24/12 32/20 48/17
56/15 57/8 58/2 61/23)
63/5 63/9 63/16
accounts [10] 4/3
32/12 32/22 44/17
44/20 44/24 46/25
61/20 62/12 62/24
accuracy [1] 1/9
accurate [5] 89/21
90/7 123/11 127/5
127/16
accurately [2] 128/22
186/18
accused's [1] 149/9
acknowledge [1]
93/8
acknowledging [1]
93/19
across [15] 9/6 19/11
37/25 44/12 47/14
71/15 116/17 120/9
122/5 123/20 145/13
166/10 167/13 180/22)
180/23
act [1] 135/22
acting [1] 37/3
action [16] 11/17
56/17 76/2 79/19
80/24 80/25 82/25
83/16 83/21 85/15
86/2 98/24 99/24
99/25 146/17 157/5
actioned [1] 27/19
actions [4] 32/24
62/9 133/11 151/23
active [3] 11/16 29/5
30/9
actively [2] 7/21 8/6
activity [8] 12/2
13/22 14/19 15/17
17/14 21/8 29/9 63/24
actual [10] 61/25
97/17 108/10 108/17
135/15 135/24 146/5
148/7 153/24 157/10
actually [11] 6/19
17/24 19/13 19/14
22/14 27/6 47/24
155/4 167/15 170/9
184/22
acutely [1] 5/17
ad [1] 30/2
ad hoc [1] 30/2
Adam [2] 34/25 41/1
add [5] 74/13 82/22
85/25 141/16 155/3
added [5] 2/14
141/19 144/21 148/12)
149/11
additional [6] 26/22
103/9 121/24 146/18
157/6 159/10
address [4] 54/14
91/9 149/11 162/24
addressed [5] 8/1
49/9 114/4 128/2
140/7
addresses [3] 33/13
139/25 140/1
addressing [6] 54/13
92/3 113/18 127/25
142/15 153/4
adds [1] 142/18
adjourned [1] 191/1
Adjournment [1]
117/1
Adjudication [1]
143/13
admit [1] 102/19
admitting [4] 175/15
advance [2] 17/11
72/15
advice [20] 36/14
58/10 58/12 61/10
66/4 66/5 66/8 76/11
78/1 92/18 113/14
115/16 140/14 143/21
149/17 151/2 168/13
168/15 168/17 176/2
advise [4] 53/14 74/6
74/13 143/18
advised [2] 149/7
187/25
Advisers [1] 67/9
advising [3] 11/10
73/24 76/8
affair [1] 134/2
affairs [5] 43/13
44/21 71/1 104/12
104/12
affect [3] 13/12 99/25}
188/5
affected [2] 93/24
129/3
affecting [3] 9/2 9/11
103/12
affects [2] 188/11
188/24
affirmed [2] 64/25
192/10
afraid [2] 184/10
184/12
after [16] 25/12 43/6
54/23 55/23 66/14
69/19 70/1 78/16 81/6
96/17 137/1 148/12
156/13 160/6 174/7
186/5
afternoon [4] 117/3
143/7 166/16 187/16
again [37] 1/24 4/1
4/6 5/10 5/24 6/5 6/11
6/17 6/21 6/24 7/5
13/15 16/19 22/24
24/14 24/15 29/11
30/20 35/9 39/20
48/24 50/1 53/7 53/23)
55/6 69/5 79/11 80/13
91/2 111/22 130/2
149/12 177/8 178/12
184/1 184/7 184/15
against [29] 10/13
12/6 14/5 14/9 17/10
17/19 19/17 22/18
29/24 32/21 52/25
56/21 82/3 82/14
83/16 83/21 84/18
86/2 87/2 99/25
110/10 111/16 174/25}
175/4 182/14 183/13
184/18 185/2 186/1
agenda [1] 165/7
aggressive [1] 77/16
ago [9] 16/14 17/23
24/25 39/12 47/11
48/25 121/4 122/13
171/1
agree [30] 14/2 14/11
30/22 42/10 44/15
44/21 50/6 62/11
63/11 75/18 89/10
89/11 91/14 96/5
113/3 127/15 128/19
131/16 131/17 132/1
132/2 133/24 134/6
151/9 158/1 158/3
170/11 174/22 175/1
175/25
agreed [7] 1/16 17/9
26/22 43/6 89/19
121/3 143/19
agreeing [1] 91/17
agreement [6] 83/11
83/17 85/9 98/21
124/4 124/5
agreement' [1] 98/17
ahead [1] 158/13
aim [1] 21/11
airing [1] 129/23
Alan [12] 24/23 40/23)
40/23 41/1 49/9 50/25
69/20 70/17 174/5
174/8 174/12 174/19
Alex [1] 125/20
Alice [22] 81/9 81/19
97/21 129/9 131/6
137/14 137/15 139/3
139/4 139/8 141/24
142/4 142/9 142/11
143/3 144/24 172/1
176/21 177/5 177/17
177/25 187/9
Alice's [1] 94/6
all [74] 3/5 3/7 3/8 6/8I
TIT 7/18 7/23 9/6
10/14 10/23 11/1
12/20 14/17 15/16
25/8 26/4 27/1 34/10
38/7 38/11 41/4 41/6
41/24 42/16 44/7
45/25 46/2 46/15
46/17 46/19 49/20
60/13 60/21 61/3 63/7
71/15 72/14 72/16
73/7 80/1 80/3 80/16
88/6 89/22 97/14 99/9
107/7 109/17 109/25
110/18 110/21 110/24}
112/22 115/7 116/4
119/1 125/20 129/22
136/15 137/8 144/12
150/25 152/3 154/9
161/14 165/13 169/18)
170/3 177/25 183/20
184/10 190/2 190/20
190/24
Allan [4] 1/5 1/21
53/15 192/2
allegation [2] 45/1
112/10
allegations [5] 52/11
1410/9 110/16 111/15
112/20
alleged [4] 17/18
32/22 126/23 174/11
Alliance [1] 174/6
allow [2] 76/15 76/19
allows [1] 85/9
almost [2] 52/19
96/13
alone [1] 135/4
along [6] 46/18 62/20
86/1 109/13 115/21
153/10
alongside [6] 72/5
102/10 148/2 148/3
153/21 157/19
already [9] 80/25
114/22 115/11 115/12)
115/15 160/19 176/20)
181/20 183/1
also [44] 3/22 10/17
11/12 12/11 37/7
37/19 38/16 40/2
40/22 44/5 44/7 45/14
51/16 60/15 75/25
76/8 88/18 98/1 98/14
100/21 102/10 103/10)
104/2 105/5 113/14
113/18 114/12 120/4
120/10 122/2 125/10
(50) about... - also
A
also... [13] 133/16
139/4 149/2 150/15
151/16 153/18 156/6
157/7 157/12 161/21
163/19 183/13 184/22)
altering [1] 89/25
although [9] 27/19
48/19 73/19 74/24
85/1 151/13 157/9
177/8 178/17
Altman [28] 66/4
66/8 114/14 139/14
139/21 140/6 142/17
143/18 145/20 146/4
148/21 153/18 155/1
157/13 159/23 161/17)
175/10 175/18 176/8
176/16 176/17 176/22
178/21 179/7 179/18
181/4 181/10 186/5
Altman's [5] 139/23
146/3 146/20 148/15
149/17
altogether [2] 41/17
91/20
always [4] 44/12 55/4)
93/8 164/17
Alwen [8] 24/15 75/7
77/23 79/6 81/15
97/22 116/14 165/12
am [15] 1/2 42/4 42/6
53/9 64/19 64/21
87/18 91/16 96/11
120/12 126/18 142/24}
177/4 189/7 191/1
amend [1] 145/18
amended [4] 87/6
89/13 148/13 153/2
amending [1] 87/16
amendments [1]
147/7
among [1] 187/21
Amongst [1] 174/15
amount [6] 13/4 19/5
46/5 68/13 122/17
189/7
ancillary [1] 38/9
Anderson [1] 24/20
Andy [5] 146/22
146/25 153/2 181/14
181/16
angry [1] 92/4
announcement [1]
163/13
anomalies [1] 99/19
anomaly [2] 97/5
185/19
another [17] 23/13
26/12 39/14 43/13
51/11 51/21 62/1 76/3
94/19 95/23 97/3
111/24 114/11 116/12)
151/25 156/6 177/16
answer [11] 1/17
2/19 3/18 9/18 9/21
28/7 58/19 60/18
70/18 161/10 173/14
answered [6] 4/22
5/3 5/8 28/4 150/12
152/6
answering [1] 64/11
answers [2] 159/25
177/18
ANTHONY [4] 64/25
65/3 144/20 192/10
Anti [4] 21/18
Anti-Money [1] 21/18
anxieties [1] 123/8
anxiety [10] 113/4
122/18 122/19 130/3
131/17 131/21 132/10)
133/14 133/16 183/3
anxious [2] 41/16
92/22
any [95] 3/1 9/25
10/11 10/17 10/20
10/20 10/24 10/24
12/6 13/11 14/18
14/19 17/12 18/6 18/8)
18/18 19/7 25/2 32/16
33/24 34/17 36/16
37/9 39/2 40/10 40/25
43/17 45/1 46/22 47/9
47/16 47/18 47/25
49/2 49/3 49/22 50/6
50/9 51/5 55/7 62/2
69/7 69/8 74/21 78/3
79/1 80/4 80/9 80/16
80/24 85/16 86/10
87/10 89/5 90/9 92/8
92/10 94/10 95/16
99/12 99/24 100/9
100/17 107/16 108/22)
115/6 124/8 125/5
135/14 140/17 146/11
146/17 149/15 151/2
153/16 153/17 155/20)
156/3 156/4 157/6
158/15 158/22 159/10)
159/13 161/4 161/16
166/13 167/22 170/16)
170/17 174/23 181/7
187/5 187/7 187/9
anybody [1] 67/5
anyone [4] 11/4
39/23 100/11 142/25
anything [15] 1/19
13/11 45/23 58/16
89/13 101/4 106/18
106/24 113/10 133/1
139/12 139/13 142/25)
164/4 187/7
Anyway [1] 118/25
AP [4] 184/3
apologies [3] 23/15
24/20 126/15
apologise [1] 31/23
apparent [8] 86/3
138/8 155/24 162/17
162/22 168/6 180/19
182/19
appeal [6] 85/18
86/10 87/11 88/5
99/14 153/6
appeals [11] 84/18
84/20 85/1 87/1 87/3
88/1 92/20 92/21
106/3 140/8 181/24
appear [4] 41/2 48/19)
126/16 164/14
appearances [1]
64/7
appearing [1] 109/17
appears [3] 16/10
17/3 150/16
apply [3] 10/17 85/18
99/14
appointed [1] 176/6
appointment [5]
42/21 143/20 143/24
144/14 144/18
appraising [1]
176/14
appreciate [7] 50/5
100/8 171/9 171/10
171/15 172/8 172/19
appreciated [1]
171/16
appreciation [1]
172/16
apprise [1] 176/15
approach [16] 20/1
20/3 29/18 30/5 30/10
50/3 72/6 72/11
131/24 143/10 145/21
146/8 157/16 157/23
181/6 181/23
appropriate [25] 4/10)
4/14 17/10 68/13
72/17 82/25 85/14
98/24 99/23 104/13
104/16 104/18 111/15}
116/19 133/12 139/6
142/8 145/18 146/1
149/10 157/2 168/17
169/13 177/13 182/5
appropriately [1]
147/13
approve [1] 124/21
April [10] 1/8 1/15
26/13 33/4 35/2 47/4
65/8 135/25 140/14
170/16
Arbuthnot [23] 69/20
70/17 73/3 73/10
74/22 76/14 78/2 81/5
81/10 81/21 82/11
88/11 91/14 92/4
92/16 97/11 97/24
98/3 107/14 108/7
143/11 174/8 184/25
are [113] 1/5 2/20
2/21 3/1 3/4 3/19 3/21
9/1 13/2 16/20 16/21
18/18 22/24 25/1
29/25 41/7 43/22
43/23 43/25 47/25
47/25 48/3 48/12
50/13 57/19 58/15
59/7 59/14 60/12 63/4)
70/5 71/24 72/1 72/5
72/15 72/16 73/7
73/23 76/8 78/9 80/17,
81/8 83/1 83/11 84/4
85/8 88/22 89/18 90/7
90/8 93/14 93/16
93/19 96/11 96/13
96/21 97/8 98/20
100/1 101/18 101/18
102/10 103/9 105/3
106/6 107/15 107/16
108/21 108/22 109/14}
109/24 110/18 111/6
111/11 114/8 117/23
119/12 119/13 120/7
120/9 121/7 121/8
123/25 125/4 129/3
140/15 142/23 143/9
145/21 145/23 147/8
148/17 151/18 153/23
153/24 154/9 154/21
157/7 158/21 163/19
165/16 166/5 166/13
169/1 171/14 174/14
174/15 176/6 177/3
181/21 184/11 187/18)
187/21
area [5] 5/25 45/20
61/17 62/11 74/5
areas [1] 29/24
aren't [2] 16/23
175/15
argues [1] 140/13
arise [1] 49/5
arisen [1] 83/15
arising [5] 30/21
32/19 107/12 107/17
108/23
Arnold [1] 52/8
Arnott [1] 110/1
around [26] 18/2
52/16 58/13 71/1
71/13 71/22 75/15
82/2 100/23 103/17
112/19 113/5 117/18
127/19 128/3 133/14
135/9 136/18 137/4
139/19 140/25 141/3
141/3 159/13 166/24
189/19
arrange [3] 151/23
155/7 178/23
arranged [3] 152/12
152/16 179/12
arseholes [2] 111/5
111/6
arsenal [1] 121/7
article [1] 131/22
articulated [2]
151/11 178/15
as [231]
ascribing [1] 178/3
aside [1] 162/6
ask [29] 1/19 17/24
19/7 19/15 29/14
29/15 39/9 39/15 54/7
54/15 56/3 58/5 65/7
65/10 69/25 72/12
76/11 80/2 91/21
106/15 123/19 124/21
124/22 134/15 187/3
187/6 187/7 187/16
189/15
asked [31] 2/12 2/13
3/15 4/18 5/13 8/13
18/12 18/15 20/22
26/24 27/15 28/22
30/6 32/9 47/17 53/15
53/25 54/4 69/19 73/1
74/25 79/23 114/25
115/13 120/9 124/1
133/2 157/12 170/21
181/15 187/5
asking [14] 31/15
33/5 52/8 53/24 54/11
57/15 84/1 87/18
88/11 88/16 106/7
106/19 107/7 133/6
aspect [1] 112/8
aspects [1] 62/6
assert [1] 148/15
assessment [1]
128/20
assets [1] 17/13
assigned [1] 121/20
assist [9] 17/18 27/2
38/3 51/5 65/20 66/23}
75/1 149/9 165/20
assisted [1] 38/24
associated [3] 151/2
156/22 156/24
assume [4] 16/21
105/23 109/23 138/5
assumed [1] 41/14
assuming [1] 42/23
assumption [1]
32/14
assurances [1] 53/7
astute [1] 176/5
at [326]
at page 23 [1] 10/7
attach [1] 153/3
attached [6] 57/14
90/24 114/5 153/10
159/24 183/7
attaching [1] 78/18
attachment [3] 155/9
156/6 158/11
(61) also... - attachment
A
attachments [4]
153/20 153/24 158/6
158/8
attack [2] 162/11
180/1
attempt [1] 76/3
attempts [2] 107/13
107/25
attend [6] 1/17 22/1
23/23 73/2 73/11
158/17
attendance [4] 20/19
26/14 42/20 73/24
attended [2] 174/7
174/10
attendees [1] 22/22
attending [3] 1/24
25/2 165/5
attention [8] 30/4
55/11 79/10 111/13
130/1 140/21 143/15
157/4
attitude [1] 111/25
audible [1] 70/18
audience [5] 68/7
100/19 100/20 100/21
132/22
audiences [1] 69/4
audiences's [1]
68/14
audit [13] 3/6 3/21
3/23 8/25 9/5 9/9 9/23
10/4 21/8 21/18 21/19
23/10 52/19
auditor [1] 114/7
auditors [3] 62/16
62/17 62/21
augmented [1] 37/22
August [3] 15/25
31/14 49/10
Aujard [2] 142/7
190/5
automatically [4]
84/20 85/2 87/3 88/2
available [1] 1/13
avenues [1] 121/9
avoid [1] 92/22
await [1] 98/15
awaiting [1] 157/7
awake [1] 166/18
aware [66] 4/19 4/25
5/6 5/14 5/15 5/17
7/15 7/18 13/14 18/2
18/7 18/18 25/1 30/8
32/23 33/11 34/12
36/6 36/24 39/5 40/24
43/2 53/14 59/17 67/9)
69/16 71/5 71/24 82/7
82/11 86/10 87/10
106/23 108/24 113/20}
115/11 115/16 115/19)
120/12 122/12 136/17)
136/20 136/24 136/25)
137/4 137/5 139/1
141/3 142/21 144/1
145/1 154/9 161/18
161/21 162/15 168/15)
171/24 172/1 174/3
177/15 177/24 182/22)
183/22 186/3 186/6
189/18
awareness [1]
180/15
away [5] 77/15 121/1
139/5 141/25 154/15
back [36] 7/17 11/6
17/15 30/6 34/13
34/14 40/16 44/9
51/21 62/1 64/10
64/16 74/24 81/1 84/4
87/19 89/15 89/19
91/16 94/3 95/2
112/24 116/22 125/4
130/9 136/6 143/2
146/6 151/16 163/23
1714/3 172/10 172/12
173/25 186/9 189/3
backbone [1] 13/20
background [10]
66/14 79/16 148/4
148/6 151/14 178/18
178/25 179/3 179/4
179/8
bad [1] 53/2
badly [1] 119/4
Baker [2] 43/4 77/23
Baker's [1] 43/9
balance [2] 73/3
123/14
balanced [1] 87/6
balancing [1] 168/22
bankrupt [1] 50/4
barrister [4] 114/15
145/20 157/13 181/4
base [2] 118/21
182/11
based [13] 48/17
50/12 63/20 77/5
86/19 86/20 107/13
116/7 116/13 116/15
140/4 146/21 152/14
basically [4] 11/25
59/1 88/11 147/3
basing [1] 141/22
basis [11] 30/2 79/7
84/21 85/3 85/12
86/12 87/5 92/23 93/4
99/1 164/19
bat [1] 121/1
Bates [9] 49/10 50/24)
50/25 69/20 70/17
174/5 174/9 174/12
174/19
baton [2] 125/17
161/8
Batten [2] 163/10
163/21
BBC [11] 91/9 109/8
109/10 109/19 109/20}
109/21 109/24 111/7
111/15 112/16 131/22
BBC News [2] 109/8
109/10
be [243]
bearing [1] 159/1
became [5] 69/16
70/2 138/8 144/20
174/3
because [51] 2/20
2/21 5/18 6/6 7/25
12/11 13/19 13/20
19/18 20/1 22/7 22/10
23/9 24/1 29/3 30/8
30/10 34/24 39/18
39/24 41/6 41/12 49/5
49/17 52/20 57/17
57/23 59/2 60/19 61/4
76/5 80/20 91/3
100/20 122/1 122/2
135/13 141/11 144/9
147/21 150/10 150/16}
155/24 162/8 163/12
176/10 177/21 180/5
182/18 184/7 184/17
become [4] 43/2 43/5
180/19 182/19
becoming [1] 164/24
been [176] 7/18 8/5
12/20 14/12 14/15
17/3 17/10 19/21
19/21 20/10 22/16
22/25 24/2 24/12 32/9
32/12 32/14 40/3 40/6
41/6 43/3 45/2 47/1
47/12 47/21 47/22
49/18 51/14 53/14
53/15 55/3 56/6 56/23,
59/4 59/7 59/9 59/16
59/20 60/16 61/18
61/19 61/23 62/6 62/7
62/12 63/9 63/16 64/8
68/19 73/11 74/3
74/12 75/5 76/18 77/2
78/23 79/3 79/14
79/23 80/18 80/25
81/3 82/8 83/6 83/7
83/10 83/14 83/23
85/7 85/17 86/7 86/17
86/20 88/8 89/3 92/24
95/14 98/1 99/8 99/13
99/24 100/19 101/25
102/16 102/22 102/24
103/4 103/17 103/20
105/12 105/24 107/22I
108/1 108/2 108/4
108/6 108/12 108/13
110/10 114/12 114/13
117/19 118/14 121/2
122/9 124/1 124/10
125/2 126/20 127/1
127/7 128/8 129/21
129/23 132/5 133/8
133/12 133/23 134/5
134/7 134/10 136/21
137/21 137/25 138/4
138/11 139/18 140/20
141/4 141/17 142/1
143/17 144/5 144/25
145/22 146/25 147/2
150/20 152/10 153/8
154/4 157/3 157/18
157/25 158/7 159/15
159/21 160/10 160/13}
160/22 162/11 163/15]
165/23 167/3 167/4
167/24 168/6 168/10
169/7 172/7 172/11
172/13 172/19 173/10
174/19 175/5 175/12
175/20 176/6 177/13
177/18 177/24 179/16}
180/1 181/21 182/23
Beer [1] 35/25
before [40] 18/24
19/14 20/20 22/14
27/23 31/23 32/5 35/9)
44/6 56/6 64/5 67/10
73/18 74/18 77/1 77/3;
78/14 81/20 85/10
89/19 89/23 94/2
97/11 101/22 113/23
117/6 131/11 131/22
132/3 135/16 137/16
141/2 143/2 152/10
152/23 161/17 162/25}
175/10 186/14 190/15)
began [1] 45/14
begged [1] 150/5
begin [2] 81/6 84/10
beginning [1] 65/24
begins [2] 2/10 67/18
behalf [7] 16/5 35/20
37/4 50/20 101/14
105/11 187/17
behest [1] 37/8
behind [1] 75/10
being [58] 8/1 15/10
16/2 17/21 20/4 25/22}
27/17 28/20 28/22
30/3 39/4 39/5 40/24
44/24 45/23 47/25
53/9 53/18 54/4 57/3
60/13 61/10 67/23
71/24 71/24 77/11
77/14 78/9 84/18 87/1
90/3 94/9 99/5 99/8
103/21 104/20 106/3
108/10 110/9 118/5
118/8 128/17 131/18
132/9 135/5 137/9
139/11 139/15 141/8
142/25 144/16 149/10
149/23 150/2 150/17
154/19 170/5 170/25
belatedly [1] 165/12
belief [2] 50/12 65/15
believe [21] 33/15
61/12 65/17 66/6
84/19 86/10 87/3
87/11 88/1 100/1
103/15 103/19 126/2
146/4 157/9 159/18
160/18 172/17 174/3
185/12 189/4
Belinda [6] 152/21
158/9 160/13 161/8
161/11 166/15
below [20] 82/22
83/6 84/12 84/16
86/22 86/23 88/22
90/23 91/1 96/1 98/2
119/25 125/12 127/9
142/10 143/14 147/7
149/2 165/2 166/15
beneath [1] 56/11
beneficial [1] 26/21
benefit [2] 1/6 164/19)
best [12] 11/17 26/5
64/14 65/14 82/2 84/9
84/15 88/12 109/16
138/18 159/16 169/7
better [7] 41/22
130/18 130/20 132/18}
151/11 178/15 180/5
between [22] 16/21
35/1 51/1 64/6 95/7
96/20 102/1 103/2
122/9 122/21 122/25
124/5 124/18 126/8
140/5 140/14 163/10
164/10 164/21 166/3
177/24 178/11
beyond [2] 117/20
118/4
biased [1] 51/23
biases [1] 168/16
bid [1] 148/1
big [4] 3/21 29/20
43/24 57/24
BIS [14] 100/6
100/16 100/20 100/21
101/3 118/23 121/15
121/25 125/4 125/7
126/16 131/9 132/25
133/2
bit [15] 16/18 31/21
84/8 91/2 95/20 110/5I
110/7 111/20 119/22
140/23 147/21 149/12!
151/20 164/9 164/20
bits [3] 19/22 71/18
139/15
bitter [1] 109/14
Blake [11] 33/5 65/1
170/21 179/17 183/2
183/4 184/2 187/25
(62) attachments - Blake
B
Blake... [3] 190/11
190/18 192/12
blow [1] 81/25
bludgeon [1] 50/3
board [155] 3/5 3/6
9/15 10/11 11/15
11/20 12/3 12/4 12/9
12/10 12/11 12/14
13/14 14/13 14/18
14/25 15/2 15/6 15/23
15/25 16/5 17/7 17/9
17/16 17/22 18/3 18/8}
18/17 18/18 20/3
20/18 21/6 22/7 23/12
23/14 23/20 23/23
23/25 24/1 24/2 26/12
26/18 26/20 26/22
27/3 28/5 29/1 29/3
29/4 29/8 29/9 29/13
29/15 29/18 29/21
30/2 30/4 30/10 30/24
31/7 33/7 33/15 33/19
34/9 34/20 37/2 37/5
39/23 42/9 42/14
42/16 42/19 43/6
43/18 43/19 44/8
44/12 45/9 45/21
45/24 46/3 46/9 46/12
47/3 47/8 48/4 49/5
52/4 55/12 56/24
57/16 60/3 60/16
60/23 61/18 61/19
67/25 69/4 105/7
105/9 105/19 105/24
106/5 106/6 106/7
106/12 106/17 106/22)
107/6 107/10 107/22
108/1 111/22 113/15
115/21 116/3 117/6
122/3 124/10 125/2
136/20 136/21 145/10}
145/11 148/2 148/8
148/10 149/3 150/20
151/1 151/13 154/18
156/12 158/14 159/2
160/4 160/11 160/19
161/2 161/2 161/4
165/6 165/14 166/1
166/4 175/11 175/17
177/25 178/13 178/17)
179/19 182/9 183/25
184/4 190/5
Board's [6] 14/15
15/18 45/7 55/11
106/15 190/1
boards [5] 3/8 10/14
10/17 20/16 44/12
body [1] 95/6
bold [2] 147/7 149/12
Bond [2] 114/2
136/10
boss [1] 176/25
both [17] 8/1 12/3
13/5 13/6 44/12 45/3
67/8 85/22 86/15
99/22 114/19 128/2
164/16 164/19 185/24)
186/3 186/6
bother [1] 129/12
bottom [37] 3/14 4/4
16/1 16/19 25/6 26/14
30/4 42/20 42/21 53/4
56/5 73/15 74/17 80/6
81/13 84/16 86/25
95/20 95/24 109/5
114/1 120/5 120/18
123/17 126/10 130/14)
130/15 131/13 137/11
137/13 137/17 143/4
160/2 162/8 163/9
163/17 165/1
bottom-up [1] 30/4
Bourke [1] 67/7
box [1] 90/24
brackets [2] 99/19
149/2
branch [17] 21/17
24/12 32/12 32/22
46/25 48/17 53/1 53/3
53/8 56/16 57/3 57/9
83/15 93/20 109/11
116/15 126/25
branches [6] 5/19
48/9 48/10 94/25
188/7 188/9
break [15] 41/12
41/23 42/5 64/14
64/20 113/24 116/20
117/6 123/2 169/2
169/13 169/15 169/16)
169/20 184/10
Breeden [1] 53/5
Brian [15] 114/14
139/14 139/21 143/18)
145/20 146/4 147/9
149/17 153/17 155/1
157/13 159/23 161/17)
176/8 181/4
Brian's [1] 147/12
brick [1] 126/16
brief [30] 81/11 81/24
89/13 89/14 90/1
93/13 96/7 98/2
100/18 101/2 102/6
102/20 103/17 103/19)
103/21 104/9 104/15
104/17 104/20 105/2
107/9 109/11 111/22
115/20 116/11 139/15)
139/21 162/24 182/3
184/3
briefed [19] 12/20
101/3 106/22 107/22
137/24 137/25 139/11
142/1 142/2 144/25
150/20 152/10 165/8
166/22 173/12 176/25}
177/18 182/23 187/4
briefing [42] 68/11
68/17 72/6 77/19 81/8
97/23 98/8 101/25
102/13 103/3 103/11
113/15 117/7 139/10
141/22 141/23 148/2
148/6 151/23 152/12
152/16 152/17 152/19}
152/21 153/3 153/15
154/18 155/7 155/10
156/13 158/1 158/5
158/13 160/16 160/22
160/23 161/5 178/23
179/11 182/8 183/24
184/17
briefings [3] 67/21
106/5 182/25
briefly [2] 139/24
189/16
briefs [2] 102/7
103/14
bring [14] 2/2 22/4
32/4 32/25 48/15 52/6
61/6 65/22 67/15
71/20 117/7 157/3
157/18 158/14
bringing [2] 71/2
94/19
broad [3] 27/11
138/5 167/13
broader [8] 19/10
28/15 71/10 116/3
124/17 127/21 133/16}
177/25
broadest [1] 28/17
broadly [4] 31/16
68/9 128/25 188/6
brought [16] 20/15
29/6 30/3 35/18 35/20
36/9 55/10 55/13 60/3
69/23 74/10 138/24
139/3 139/7 140/20
179/20
bug [7] 46/24 46/24
47/18 79/14 79/14
79/18 80/21
bugs [20] 55/9 75/4
75/10 79/3 79/12
80/17 81/1 93/14 97/4
137/21 138/8 141/17
173/9 174/4 179/17
182/21 182/23 183/15}
183/21 184/8
built [2] 4/4 167/25
bullet [7] 82/22 107/9
143/14 144/23 156/16
158/21 159/12
business [55] 3/2
4/11 6/1 9/7 12/12
12/23 13/6 13/18
13/19 20/7 21/12
29/22 41/8 41/8 52/23
53/1 69/2 71/2 71/6
71/12 94/17 100/7
100/13 101/8 102/3
108/5 108/15 113/8
116/17 118/9 118/24
122/6 133/21 137/5
139/2 142/6 145/14
164/10 164/14 164/21
165/5 166/1 166/5
166/7 166/21 167/5
167/14 167/23 168/1
168/7 168/21 175/21
180/23 188/5 189/8
businesses [2] 29/23)
42/11
busy [2] 64/8 71/18
but [186] 1/6 2/18
3/22 5/17 5/24 6/6
6/11 7/17 8/5 9/4 9/24,
12/2 12/10 12/20
14/15 14/16 16/14
19/11 19/22 19/24
20/5 20/19 22/4 24/14,
25/9 25/19 28/8 28/12,
28/13 28/15 29/3
29/20 30/14 31/16
32/13 37/7 38/22 40/2
43/15 44/5 44/7 44/10
45/14 46/8 47/11
47/19 47/21 48/25
49/16 49/24 50/18
53/24 57/3 57/11
57/13 58/1 59/16
59/25 61/1 62/23 63/1
63/12 63/20 64/7
64/10 71/9 72/11 73/4,
74/9 75/10 76/14
76/22 78/5 82/14
82/17 86/11 88/14
89/7 89/25 90/24 91/2,
91/3 91/16 92/14
92/20 98/1 98/22
100/10 102/16 102/21
103/1 103/23 104/1
105/5 105/18 108/7
109/16 110/15 110/18
110/21 111/12 111/22}
112/15 112/18 113/3
116/13 118/14 118/24)
119/4 121/6 121/16
122/11 123/10 123/14}
123/25 124/9 124/11
124/22 125/15 125/19)
127/2 128/2 128/14
129/10 129/14 131/3
131/8 132/20 133/5
133/15 135/15 137/23
138/5 138/16 139/4
139/16 141/1 141/16
144/12 144/24 147/11
147/14 147/25 148/7
148/9 149/2 150/15
150/15 152/23 153/25]
154/1 154/21 155/6
158/19 159/6 159/25
160/8 160/20 160/23
161/2 162/2 164/19
165/6 165/11 169/11
4714/1 171/7 171/12
172/1 172/17 173/11
173/18 174/13 176/4
176/12 177/14 177/17)
180/25 181/19 183/2
184/24 185/9 186/7
187/6 189/8 190/5
buyers [1] 120/15
Byfleet [2] 78/21
183/9
c
call [7] 59/25 64/24
73/2 82/9 93/18 93/22
152/11
Callard [4] 164/24
165/16 166/16 166/22)
called [4] 2/20 2/21
82/4 161/13
Callendar [1] 46/24
calls [2] 96/3 102/11
calls/emails [1] 96/3
calmly [1] 76/14
came [10] 13/13 32/5
51/21 55/10 104/10
105/8 111/12 136/13
137/6 163/5
campaign [1] 119/3
campaigning [1]
174/5
can [175] 1/3 2/11
4/2 4/16 7/19 9/21
10/5 11/5 16/17 17/2
17/17 19/22 20/17
20/21 22/2 22/11
26/10 26/13 26/16
27/2 27/16 28/24
28/25 32/1 32/2 32/4
32/7 32/25 34/4 34/18)
34/25 35/13 35/16
35/22 36/2 38/2 39/15
39/20 42/7 43/9 43/15]
44/13 45/5 47/3 47/5
48/14 49/8 49/18 50/6)
51/5 52/1 52/6 56/2
58/14 59/5 61/5 61/6
61/10 64/22 64/24
65/2 65/7 65/11 65/14
65/20 66/11 66/23
68/8 69/15 70/14 72/1
74/13 74/16 75/1
75/13 78/15 78/17
79/5 81/7 81/13 81/22I
84/2 84/6 84/16 84/23
85/5 85/20 85/25 86/9
86/23 87/10 88/3 88/4I
88/16 88/18 89/22
90/14 90/15 93/8
93/22 94/2 94/3 95/24
96/8 97/13 97/19
(53) Blake... - can
Cc
can... [69] 97/25 98/4
101/15 107/8 107/18
109/3 109/4 109/25
115/21 116/22 117/3
117/8 118/10 118/18
119/14 119/17 119/18}
119/22 119/25 120/3
120/16 120/22 121/5
122/11 123/16 125/23)
126/7 126/10 128/13
129/9 130/4 132/12
133/2 134/9 136/9
136/11 137/10 138/5
139/24 142/14 143/4
144/9 144/11 147/5
148/23 149/5 149/13
151/5 152/24 153/6
153/20 153/22 154/3
155/12 157/21 158/4
158/18 159/14 161/25)
165/20 167/8 176/9
179/14 180/2 180/3
184/10 185/17 187/3
188/22
can't [20] 5/24 6/5
16/14 16/24 17/20
17/20 21/24 38/3
47/11 47/19 48/24
49/24 53/24 63/1
76/19 83/3 102/15
139/11 139/12 180/2
candidly [7] 150/5
152/6 162/20 171/9
180/20 180/25 186/9
candour [1] 140/22
cannot [7] 32/12
49/14 50/6 53/3 76/15)
124/20 172/9
capabilities [1] 47/15
capacity [3] 59/15
174/11 175/23
capitals [3] 91/10
119/21 120/12
caps [1] 119/25
captured [2] 68/19
94/5
career [1] 168/13
careful [6] 30/9 43/6
75/25 84/8 92/6
102/25
carefully [1] 91/3
carried [2] 40/5
109/10
carry [1] 98/5
carrying [2] 2/24
160/10
Cartwright [11] 66/2
66/9 138/12 147/16
149/7 149/17 153/3
155/11 156/19 157/1
173/19
cascade [1] 72/17
case [54] 11/2 15/5
30/12 38/14 52/12
53/23 56/14 56/19
57/7 57/10 57/11 58/1
59/6 59/12 59/19 60/4
60/11 60/14 60/15
76/18 77/8 78/19
78/23 79/4 80/22
83/17 84/21 84/21
85/3 85/3 85/12 85/12
86/12 86/12 87/5 87/5)
99/1 99/1 119/15
143/13 143/17 149/9
153/5 157/5 165/6
171/23 172/4 173/13
175/3 177/2 183/8
186/8 187/6 188/4
case’ [2] 89/5 95/16
cases [50] 25/8
56/21 81/3 83/10 85/7
85/9 86/10 87/10 89/3)
92/9 92/11 95/14
98/15 98/22 99/8
99/22 107/17 108/23
115/2 118/1 140/25
141/4 145/8 145/22
145/25 146/13 146/15)
146/17 147/13 147/15)
147/20 148/14 148/16)
151/16 153/7 153/16
156/4 156/19 157/2
157/12 157/15 157/24)
159/14 159/18 170/24)
173/21 175/3 181/8
181/11 186/7
Castleton [3] 60/8
60/23 78/24
catch [2] 151/9
158/18
catch-up [2] 151/9
158/18
category [1] 60/4
caught [2] 168/7
189/3
cause [2] 12/7 60/1
caused [3] 46/25
59/11 183/14
causing [2] 14/20
130/2
caveat [1] 148/20
CCRC [3] 114/4
147/12 182/15
CCRC's [3] 114/6
114/13 115/5
cent [3] 6/11 8/18
63/20
central [1] 34/3
centralisation [1]
71/16
centre [2] 63/22
168/21
CEO [11] 32/16 33/18}
39/9 102/2 115/3
148/9 176/14 178/12
180/17 181/23 181/25]
CEO's [7] 145/7
145/12 147/24 158/11
160/11 182/1 182/2
certain [6] 13/25
74/14 98/14 103/24
159/2 178/10
certainly [26] 4/2
14/15 46/2 46/12
51/17 57/13 64/17
71/17 74/10 75/23
100/8 107/14 116/23
119/14 132/18 138/21
144/7 144/15 144/22
170/14 171/9 171/13
172/7 184/16 185/9
186/19
cetera [10] 94/14
177/12 177/12 181/5
181/5 181/5 185/19
185/19 185/22 185/22
CFO [1] 137/9
chain [7] 15/14 15/16
15/19 90/14 90/14
95/18 158/7
chair [9] 31/14 34/19
34/20 40/19 42/16
53/21 54/25 59/15
144/19
chairing [1] 7/9
Chairman [15] 7/12
7/15 7/18 8/6 11/2
11/8 14/4 23/11 31/19
42/22 42/24 42/24
43/2 171/14 176/7
Chairman's [1] 3/17
challenge [2] 127/10
189/4
challenged [1]
168/16
challenges [4] 55/3
55/6 55/8 55/14
challenging [1] 168/9I
Championship [1]
53/12
change [8] 30/14
34/10 47/14 65/17
82/19 104/19 105/20
120/1
changed [1] 110/10
changes [6] 47/17
72/10 90/6 104/9
125/1 131/10
changing [3] 73/7
88/14 103/20
channel [2] 122/8
163/6
channels [1] 121/2
characterisation [1]
132/2
charge [2] 11/25
55/22
charges [1] 8/14
chaser [1] 164/5
chat [1] 121/4
check [7] 50/10
68/18 100/8 100/20
101/2 130/8 181/18
checked [1] 165/18
checking [3] 89/15
165/15 165/21
Chesterfield [1]
48/16
chief [22] 35/1 39/4
53/6 67/12 68/24 70/1
89/8 121/12 129/6
148/1 166/21 167/10
167/14 175/8 175/9
175/16 175/19 177/21
178/7 180/17 180/22
188/16
choice [1] 91/16
Chris [4] 142/7
158/19 165/12 190/4
chronology [2] 16/18
116/1
circulate [1] 109/17
circulated [2] 97/17
105/1
circumscribe [1]
169/10
circumstances [10]
9/9 14/1 14/11 19/9
25/10 25/20 26/7
34/19 54/7 83/5
civil [15] 17/11 32/11
32/21 35/17 36/8 59/8)
62/3 62/4 62/9 66/15
66/24 66/25 67/9 74/3
98/14
claim [5] 109/15
119/2 135/13 175/2
175/9
claiming [1] 110/18
claims [2] 50/8 50/10
clamp [1] 131/24
clarify [1] 8/3
clarity [3] 72/1 103/4
103/18
Clarke [3] 113/14
140/13 140/16
Clarke's [1] 115/16
clear [28] 4/1 26/3
38/22 40/21 41/6
49/14 58/18 59/1 61/2)
61/4 68/7 68/15 82/23
91/7 93/13 93/19 94/6
96/5 98/22 101/23
103/4 123/5 129/13
134/12 162/16 162/22}
182/4 185/16
clearer [1] 104/1
clearest [1] 144/3
clearing [1] 137/16
clearly [40] 13/16
20/9 20/10 40/13
86/11 88/9 92/16
102/5 102/16 103/7
104/5 104/12 106/19
108/3 108/16 112/2
112/12 117/25 120/14}
122/5 128/2 129/5
129/25 131/19 132/23}
133/13 138/15 141/15)
154/24 158/2 161/7
164/11 164/16 166/9
166/20 167/13 170/6
172/15 177/6 180/14
Cleveleys [11] 56/16
57/9 57/10 58/7 58/8
58/19 58/24 59/6
60/18 60/22 61/7
client [3] 37/13
110/23 113/6
clients [1] 37/10
clip [1] 109/17
close [3] 52/19 137/1
137/18
closed [5] 53/1 53/18
53/21 54/8 54/16
closely [3] 35/7
190/3 190/8
closer [1] 43/10
closest [1] 77/22
closure [1] 188/9
clue [1] 49/3
co [1] 73/3
CO's [1] 139/20
cohort [1] 118/1
coincidence [1]
180/4
Colin [2] 43/4 43/9
collate [2] 69/1
145/14
collective [1] 71/3
colour [1] 120/1
combination [3]
102/17 141/13 165/13)
come [45] 3/22 12/3
14/16 24/23 26/10
28/25 30/6 34/25 38/4I
40/16 44/13 48/14
51/10 55/16 56/2
57/16 58/14 61/11
64/16 66/11 68/1
69/15 71/18 87/17
90/11 91/16 97/7
114/20 114/23 116/2
116/22 118/10 118/14)
142/16 147/15 148/9
150/8 151/22 152/16
152/23 154/15 163/23)
164/15 167/8 173/25
comes [4] 3/23 30/19
57/25 91/15
comfortable [4]
88/12 89/16 90/8
104/21
coming [5] 2/3 10/1
14/18 62/1 64/10
comma [1] 150/1
comment [9] 24/3
(64) can... - comment
Cc
comment... [8] 25/16
87/7 95/17 111/12
131/22 153/1 162/8
176/9
comments [8] 84/12
90/23 91/4 118/15
119/9 119/25 124/9
188/18
commercial [1] 44/2
Commission [12]
115/3 146/13 147/13
147/14 147/17 147/20}
148/14 148/16 157/12)
157/24 181/9 181/12
Commission’ [1]
147/18
commissioned [1]
152/20
committee [37] 3/6
3/21 3/23 8/25 9/9
9/23 10/4 21/3 21/6
21/20 21/22 21/25
22/6 22/12 22/15
22/21 23/4 23/10
23/11 23/18 23/20
23/22 24/5 25/2 25/13
26/19 26/21 26/24
27/16 27/18 28/6
28/23 29/2 42/24
72/10 101/14 102/3
Committee's [1] 9/6
common [1] 79/9
comms [3] 121/2
121/22 132/25
communicated [2]
72/15 136/9
communicating [1]
88/19
communication [5]
121/14 121/24 122/8
122/12 163/7
communications [12]
70/24 71/20 72/11
89/8 102/1 103/3
103/23 104/14 104/16)
104/18 122/1 163/5
companies [5] 11/18
38/9 38/14 135/14
135/18
company [34] 4/22
5/2 5/7 6/8 6/12 6/13
6/13 7/22 8/15 10/18
11/21 12/16 12/19
12/23 13/10 13/13
14/22 17/10 27/22
37/19 44/19 44/21
45/21 51/4 55/20
55/21 61/19 62/12
63/2 70/21 71/16
115/3 123/11 126/3
company's [1] 12/25
comparatively [1]
60/10
compared [1] 94/24
compensation [1]
188/10
compile [1] 44/16
complaint [1] 119/16
complaints [3] 48/21
51/11 103/24
complete [2] 1/24
84/1
completed [5] 41/15
83/23 145/21 156/19
181/5
completely [5]
102/19 108/14 109/23}
172/19 175/22
completing [1]
143/17
compliance [25] 21/3)
21/6 21/9 21/22 21/25)
22/6 22/12 22/15 23/4
23/18 23/20 24/5 25/2
26/19 26/23 26/24
27/7 27/14 27/18 28/6
28/10 28/15 28/23
29/2 32/19
complicit [1] 170/12
complying [1] 145/23
composition [2]
33/19 42/10
comprehensively [1]
68/19
compromised [1]
43/10
computer [10] 69/17
83/14 93/24 98/13
99/10 109/15 110/6
110/12 110/24 126/23}
concern [27] 75/15
77/4 77/11 82/8 85/16
92/15 106/9 106/13
106/14 108/5 112/19
123/4 128/23 129/6
129/25 132/3 132/6
134/18 137/4 137/18
138/7 140/10 144/13
145/1 151/25 173/7
188/22
concerned [13]
76/24 77/13 78/21
91/17 107/20 108/8
112/25 123/6 148/18
152/1 152/6 175/3
183/9
concerning [2]
170/12 186/8
concerns [11] 33/8
55/14 100/23 115/16
119/8 122/23 135/9
136/17 137/6 150/15
174/3
concise [1] 147/25
conclude [1] 1/14
concluded [1] 157/1
concluding [1]
139/22
conclusion [3] 146/8
157/15 182/10
conduct [5] 7/4 37/2
37/16 101/10 157/13
conducted [3] 5/6
20/4 36/15
conducting [1] 12/24
conduit [5] 69/1
69/11 102/25 176/13
177/10
confided [1] 183/21
confidence [11]
44/23 110/23 110/23
110/24 111/1 112/21
112/24 113/6 113/7
113/8 161/3
confident [2] 46/19
181/22
confidential [1]
162/7
configuration [1]
52/25
confirm [7] 65/11
65/14 117/8 122/11
124/9 131/4 186/15
confirmation [1]
160/21
confirmed [2] 1/9
126/25
conflict [1] 43/24
conflicts [1] 166/2
conformance [1]
21/12
confuse [2] 151/13
178/17
confused [2] 38/22
41/2
confusion [2] 40/3
40/4
conjunction [1]
37/20
connected [2] 176/5
184/7
connection [1] 95/7
conscious [6] 22/7
100/18 110/21 110/22
114/24 115/14
consequence [1]
59/18
consequences [5]
14/5 14/8 30/7 30/8
30/11
consider [7] 78/8
107/16 108/22 109/1
133/11 167/10 174/18}
considerable [1]
50/14
consideration [1]
43/6
considered [3] 15/22
26/21 74/6
considering [3] 18/3
42/14 43/18
considers [4] 85/16
99/9 99/12 147/16
consistent [4] 68/24
101/3 105/10 173/23
consternation [1]
183/2
constrained [1]
155/21
constraints [1] 68/14
constructed [1]
171/11
constructing [2]
102/7 102/20
construction [1]
102/6
consult [1] 89/20
consulted [1] 101/22
contact [11] 71/18
121/15 129/10 139/4
139/7 142/5 163/8
177/5 177/10 177/14
1777
contacting [1]
121/11
contained [2] 103/21
182/25
contains [1] 159/24
content [1] 45/10
contents [3] 78/10
161/16 176/15
context [13] 20/6
122/17 123/7 123/15
129/24 130/2 131/19
131/20 132/11 132/23
178/12 183/20 184/1
continuation [1] 84/6
continue [3] 90/14
130/13 147/14
continued [1] 47/20
continues [1] 83/20
contract [3] 130/21
131/1 134/23
contracts [2] 46/10
130/18
contrary [4] 140/18
173/5 176/4 176/10
contributions [2]
139/20 181/14
control [3] 21/17
111/8 131/2
Controls [1] 21/18
conversation [17]
28/20 62/19 77/15
79/19 80/4 84/14
105/24 138/4 138/14
140/24 143/7 170/18
170/22 173/2 173/18
178/5 186/4
conversations [5]
18/6 86/17 105/13
115/6 120/23
conveyed [5] 76/25
77/11 86/7 141/19
141/21
convicted [2] 172/11
175/5
conviction [8] 14/5
85/18 89/3 95/14
98/12 99/14 112/2
174/24
convictions [11] 82/2
82/20 84/19 86/9 87/2
87/9 92/17 94/24 99/3}
99/8 163/14
convincing [1] 73/6
COO [1] 32/16
COO." [1] 33/18
Cook [4] 24/23 40/23
40/23 41/2
cooperate [1] 147/22
cooperating [1]
147/17
coordinate [3]
152/21 158/13 161/8
coordinated [3] 72/6
116/12 117/13
coordinating [2]
67/20 161/14
coordination [6]
70/25 71/5 71/14
71/17 71/20 71/23
copied [9] 49/22
51/14 98/2 119/7
122/10 144/17 160/9
161/23 163/11
copy [5] 24/6 144/21
153/10 163/25 183/11
Corbett [2] 21/4 24/8
Core [1] 168/25
corner [1] 49/19
corporate [5] 22/8
111/23 111/24 112/16)
135/17
corporately [1]
135/18
correct [21] 9/17
9/20 29/7 31/25 67/13}
69/13 69/18 134/17
135/1 136/1 136/4
162/11 170/24 171/17)
183/16 183/23 186/23}
186/24 187/22 188/2
190/19
correction [1] 1/10
correctly [3] 68/19
115/12 116/2
correspondence [9]
50/23 51/14 67/21
99/18 105/11 119/7
126/8 162/2 163/10
cost [11] 9/24 12/21
13/2 13/7 13/17 45/11
45/17 45/19 52/23
63/22 84/22
costing [1] 62/11
costs [11] 13/3 61/23
61/24 61/24 61/25
(55) comment... - costs
Cc
costs... [6] 62/6 62/7
62/10 63/9 63/14
101/1
could [98] 2/1 2/8
2/17 3/13 7/10 11/6
15/23 16/3 19/14
22/14 22/20 23/4
23/13 23/16 24/4 25/5)
26/11 27/10 31/21
33/4 36/1 42/1 42/18
47/4 50/4 51/15 52/6
52/21 56/3 56/4 61/19)
64/16 65/10 65/22
66/1 67/15 67/16
72/12 72/21 74/16
75/21 76/1 76/24
80/12 82/9 84/17 87/1
87/19 90/19 100/3
100/9 104/23 104/25
105/18 106/2 106/7
107/8 109/5 110/22
113/1 113/5 113/23
120/17 121/17 121/17}
123/2 125/8 125/16
126/9 137/21 137/23
139/5 139/8 140/8
142/5 143/1 145/4
145/5 145/18 148/4
149/4 151/1 152/13
152/17 157/18 158/12)
162/11 163/2 163/8
164/23 166/7 169/16
173/9 173/11 176/15
179/25 185/17 186/14}
couldn't [5] 9/18
24/14 25/4 43/23 64/9
council [1] 53/7
Counsel [7] 28/21
33/21 114/15 176/5
177/14 177/15 177/20
counteract [1] 76/7
counterparts [1]
133/6
country [1] 50/5
couple [5] 41/16
52/19 60/7 121/9
174/6
course [5] 11/17 62/7I
123/10 147/22 181/19}
court [21] 13/25 55/3
56/14 56/19 57/7 58/1
60/14 62/1 78/20
78/24 79/3 80/18
80/22 81/3 85/18 89/5
95/16 99/9 99/14
156/1 183/8
courts [3] 55/8 55/15
62/5
cover [3] 82/1 166/25
170/12
coverage [1] 111/7
covered [3] 68/13
136/25 178/22
covering [10] 87/18
87/24 88/5 88/17
153/11 154/25 156/7
159/15 175/20 182/5
covers [2] 78/22
182/2
crafted [1] 181/17
credence [1] 110/15
credibility [4] 162/12
179/16 180/1 180/7
Crichton [20] 77/22
81/14 82/18 84/2
86/23 87/15 90/3
101/16 108/25 113/16
115/19 115/24 123/17,
124/19 125/3 139/1
142/5 143/5 163/18
177/23
Crichton's [3] 84/10
114/10 178/2
crime [3] 9/11 16/12
21/19
criminal [34] 14/5
17/12 17/14 25/8
25/14 25/23 30/7
32/10 35/17 36/8
54/20 59/9 85/11
98/12 98/25 114/14
115/2 143/17 145/8
145/20 146/13 147/13)
147/20 148/14 148/16)
153/5 156/18 157/12
157/13 157/24 159/14)
181/4 181/8 181/11
crisis [1] 112/22
criteria [2] 44/1 44/3
cross [1] 59/7
Crowe [2] 152/21
160/13
Crowe's [1] 161/11
Crown [2] 78/20
183/8
Crozier [7] 35/1
35/11 35/25 37/24
38/4 39/17 41/1
Crozier's [1] 39/12
crucial [1] 30/15
culture [1] 73/8
current [9] 17/15
85/23 90/23 91/5 92/7
98/6 98/10 99/20
142/24
currently [8] 70/8
70/9 91/25 114/8
137/18 173/7 187/24
188/4
customer [2] 113/6
113/8
cut [2] 88/23 151/16
CWu [1] 122/20
DO
Dadra [1] 24/17
damage [3] 56/13
57/1 57/6
dangerous [1] 76/2
darker [1] 88/23
data [11] 5/15 29/17
44/16 44/24 45/1
50/10 55/2 56/15 57/8
58/2 164/4
date [6] 11/20 12/15
17/5 113/14 146/13
153/5
dated [6] 65/8 109/3
114/4 139/23 156/16
174/15
dates [2] 31/16
140/15
David [4] 16/5 17/14
40/22 41/1
Davies [25] 67/8
70/23 72/23 74/8 75/8
79/7 80/13 80/19
81/15 88/19 88/22
88/25 90/15 90/21
91/2 95/3 96/10
103/23 109/22 111/2
118/19 119/16 119/19]
119/23 132/13
Davies' [1] 120/3
day [22] 3/24 3/24
43/12 43/12 48/19
48/19 48/23 48/23
48/25 48/25 63/21
78/16 80/13 81/20
89/23 94/13 96/25
97/2 97/10 109/4
109/8 115/2
days [3] 50/15
160/11 190/17
deadline [1] 131/11
deal [6] 30/20 84/21
87/4 179/14 182/10
188/11
dealing [3] 48/20
110/17 178/13
deals [1] 94/12
dealt [5] 32/14 41/15
67/11 85/3 136/13
debate [2] 118/3
134/22
debates [1] 167/5
December [2] 23/14
159/4
decide [2] 152/13
164/6
decided [4] 151/11
178/15 180/4 182/14
decision [13] 4/25
6/22 8/20 25/11 25/21
25/23 26/25 27/14
27/16 44/4 69/9 69/12
73/10
decisions [5] 36/14
40/24 178/10 188/5
188/9
dedicated [2] 38/18
39/1
deemed [1] 12/21
deep [1] 103/10
deeply [4] 141/15
141/15 168/9 189/6
defects [7] 140/11
140/18 174/4 179/17
182/21 183/21 184/9
defence [6] 82/3
82/14 145/25 146/16
157/5 174/23
defendant [3] 153/6
155/20 174/25
defendants [2] 25/10
25/20
defensive [1] 133/1
definite [1] 49/24
definitely [1] 82/5
definition [1] 123/5
degree [6] 70/25 71/5)
71/22 131/17 131/21
133/13
delay [2] 64/6 75/18
delayed [2] 75/21
76/16
delete [1] 66/1
deleted [2] 132/20
133/9
deliberate [1] 171/13
deliver [1] 148/1
delivered [2] 72/1
189/22
Delivery [2] 70/9
187/24
Deloitte [2] 189/16
189/21
demur [1] 181/25
dense [1] 157/3
deny [1] 180/2
department [18] 23/2)
27/23 27/24 32/15
33/16 33/25 34/6
34/16 34/16 34/21
51/11 51/11 63/17
100/6 100/13 101/8
102/2 118/24
departments [2] 10/8}
10/9
departure [1] 177/22
dependability [1]
123/3
dependent [4] 77/19
175/21 175/22 179/11
deploy [1] 48/8
deriving [1] 37/9
describe [8] 15/20
27/12 104/11 111/13
111/23 112/6 128/22
173/22
described [14] 37/1
50/2 56/6 63/13 80/6
118/23 127/17 132/5
141/8 171/18 172/14
180/11 181/13 186/16
description [6] 56/11
56/12 80/5 122/25
123/14 141/6
deserved [1] 188/20
desire [2] 71/17
71N9
detail [24] 7/16 67/25
68/13 72/9 75/9 75/10
76/18 79/16 80/25
122/14 137/24 140/22)
141/2 148/5 149/14
159/10 173/13 174/19)
177/1 177/14 177/6
178/1 180/24 182/3
detailed [2] 48/4 99/1
details [2] 138/6
180/21
determine [2] 146/17
157/5
developing [2] 72/5
159/11
development [1]
117/21
diagnosed [1] 47/22
dialogue [6] 51/22
84/17 86/25 87/25
88/6 90/13
Dickinson [2] 114/2
136/10
did [76] 5/21 6/2 6/9
6/21 7/3 9/15 11/3
11/22 13/10 19/7
19/15 21/25 26/1
27/25 30/13 33/7
34/10 34/15 34/16
34/22 37/24 39/4
39/22 40/4 49/13
49/15 49/15 58/19
64/9 67/5 69/8 74/13
77/8 79/2 79/8 79/25
80/2 80/22 86/5 87/13
87/17 97/14 99/24
101/7 114/21 115/4
115/24 116/9 138/2
146/19 152/3 154/11
155/6 160/16 160/18
161/4 163/23 166/19
170/8 171/1 171/7
171/8 171/14 172/7
172/19 173/1 176/17
176/17 178/2 180/14
183/19 184/14 187/6
189/24 190/1 190/6
didn't [54] 20/12
20/12 23/23 26/6 29/3
29/5 31/24 36/17
39/13 39/16 40/11
41/9 49/17 49/24
50/21 60/20 69/12
74/124 92/19 92/20
93/24 94/5 113/10
116/10 124/8 127/16
127/20 129/5 141/9
(66) costs... - didn't
D
144/15 152/2 154/15
161/15 170/7 171/9
171/10 172/2 172/4
172/5 172/6 175/23
176/2 176/9 180/8
180/11 180/12 180/21
182/16 184/10 189/4
189/5 189/25 190/5
difference [2] 93/10
125/5
different [14] 27/10
28/3 30/9 50/24 51/1
51/2 71/18 86/11
87/12 88/21 110/16
111/17 116/16 118/11
difficult [7] 17/25
17/25 25/16 45/16
86/12 91/20 158/15
dig [2] 58/13 79/1
digesting [1] 176/13
digging [1] 124/11
78/3 90/1 121/18
122/3 124/12 124/20
187/6
directed [1] 176/14
direction [2] 14/18
76/24
directly [9] 73/5 76/6
76/23 78/11 124/23
139/11 141/11 148/7
160/8
director [22] 3/16
10/25 11/9 11/13 24/8)
26/23 27/15 28/11
31/13 40/19 43/5
43/11 44/19 44/23
70/2 70/9 70/24
104/17 104/19 164/24
167/18 187/25
Directorate [1] 56/7
directors [6] 15/25
18/17 42/21 119/13
136/22 158/16
Directors’ [1] 14/13
disagree [1] 114/25
disciplinary [1] 99/25]
discipline [3] 71/22
165/14 166/12
disciplined [1] 72/5
disclosable [1] 156/1
disclose [6] 62/17
62/18 145/24 156/21
182/14 184/8
disclosed [21] 75/5
79/12 80/21 81/3
129/23 138/8 138/9
138/10 141/18 146/6
149/10 153/17 155/21
156/4 159/15 162/7
162/18 172/16 172/19}
didn't... [25] 141/16
direct [9] 33/15 77/20
172/22 182/20
disclosure [23]
62/22 125/13 125/21
149/8 153/7 153/16
155/5 155/19 156/3
156/8 157/1 173/4
173/8 173/17 173/20
183/14 183/15
disclosures [3]
discovered [1]
171/22
discrepancies [1]
46/25
discuss [16] 11/3
21/17 31/24 34/15
34/17 34/22 34/24
35/10 37/24 39/16
39/22 73/14 73/20
75/3 114/21 190/6
discussed [19] 9/24
17/21 49/7 75/17
77/14 78/9 79/3 84/15)
85/25 99/5 114/14
115/9 119/4 132/3
138/23 145/17 153/4
158/12 159/7
discussing [6] 10/7
11/16 79/22 84/4
93/23 144/5
discussion [28]
10/11 10/20 10/24
18/8 18/18 19/12
19/24 26/25 27/17
28/2 28/4 32/18 43/14
43/15 43/16 45/9 46/9
46/13 47/10 47/12
62/17 75/20 81/10
90/18 96/8 117/18
137/1 143/22
discussions [8]
18/16 19/10 71/13
80/9 105/6 115/4
115/24 160/25
dismissal [1] 78/25
display [2] 111/24
112/15
dispute [1] 109/14
dissembling [1]
180/18
disseminate [2]
76/15 76/19
disseminated [1]
181/21
distinction [1]
127/15
Distinguished [1]
80/6
distribution [2] 97/3
124/4
disturb [1] 129/11
disclosing [1] 174/23
137/19 141/17 142/24,
146/15 148/12 148/25,
157/11 159/17 180/13)
38/24 63/19
do [102] 2/22 3/4
3/11 4/6 5/10 6/17
7/14 10/11 10/20
10/24 12/8 14/2 17/21
19/14 21/21 22/14
24/17 24/20 24/24
25/12 26/5 26/25
32/18 33/15 33/16
40/25 41/18 43/14
43/17 43/21 45/23
47/16 47/19 48/20
49/12 49/12 51/5
53/17 54/20 58/6
58/10 58/15 58/22
62/11 63/10 79/1
105/8 105/19 105/22
118/3 118/7 124/10
127/15 133/1 133/11
138/19 142/1 142/4
145/4 146/1 147/22
152/24 154/6 167/10
168/8 168/20 169/6
169/11 170/7 170/15
170/17 170/19 171/12
173/11 173/14 175/24
176/6 178/20 179/6
184/5 185/13 186/19
189/7 190/21
document [42] 2/6
25/16 26/2 33/13
55/23 56/8 58/14 61/7
61/8 68/12 70/12
81/19 98/1 101/18
103/8 113/23 116/12
117/8 117/10 117/12
118/6 118/23 118/24
119/11 152/23 153/22
153/23 154/1 156/2
157/20 162/2 162/18
174/13 175/12 175/24
179/20 181/1 184/11
184/24 185/7 185/8
186/10
documentation [6]
46/2 46/14 49/3 51/18
58/23 139/13
documents [7] 52/2
61/5 68/1 120/14
132/22 149/16 156/14]
does [14] 10/17 27/7
31/16 35/2 47/9 70/10)
73/23 89/7 112/15
112/17 119/4 128/23
164/8 164/20
doesn't [9] 3/22
33/20 50/16 96/11
28/19 29/25 30/9 31/2
80/22 81/10 89/1 89/9
92/22 95/12 97/5 97/7
133/13 133/24 137/22
149/15 150/24 152/13
107/1 128/22 154/23
155/3 179/9
doing [9] 12/2 37/7
39/7 40/6 89/25 96/9
96/11 96/16 175/24
domain [4] 132/9
don't [75] 2/18 2/20
6/5 8/10 9/13 16/7
24/3 24/19 26/2 28/7
43/15 48/15 49/11
55/22 62/18 62/19
63/4 72/3 76/5 77/10
97/1 103/15 103/19
106/18 106/23 107/4
107/4 107/5 112/4
112/6 112/17 115/6
118/25 119/3 129/10
132/8 134/3 135/8
135/13 137/15 142/9
144/5 144/7 144/22
146/4 150/12 160/18
160/23 162/1 164/6
164/8 169/10 174/13
182/1 183/15 184/14
185/4 185/5 185/6
186/9 187/9 188/19
189/4
Donald [1] 129/10
done [3] 55/13 58/6
58/12
dotted [1] 38/19
down [57] 2/17 5/12
10/10 20/19 23/15
23/16 26/10 28/25
30/4 34/25 35/24 36/2
44/13 47/5 48/14 56/2)
58/14 61/11 66/11
67/18 69/15 72/4
78/17 84/9 85/5 86/23)
87/21 91/4 95/22 96/4,
96/10 97/25 98/4 98/5
100/4 107/8 110/3
113/25 118/10 119/17}
120/3 125/9 131/24
136/11 139/25 142/14,
143/4 147/4 148/20
154/3 154/7 155/23
157/21 162/4 167/8
184/11 186/17
downtime [1] 48/10
dozen [1] 175/20
dozens [1] 180/23
draft [16] 68/17
83/24 86/14 90/23
98/21 105/7 105/11
105/15 107/9 125/19
132/16 140/4 146/19
146/22 165/14 175/16}
drafted [11] 83/7
101/25 105/4 114/5
153/10 155/17 155/18}
17/23 18/5 18/21 22/4)
28/8 28/14 29/7 35/10)
80/4 80/24 81/4 92/14
114/12 116/11 119/5
145/19 166/7 184/17
184/22
drafting [11] 81/8
89/9 104/14 105/8
105/21 117/12 119/14}
139/19 146/21 175/11
179/10
draw [1] 143/15
drawing [2] 113/10
186/9
drawn [1] 79/9
drive [1] 71/14
driven [2] 30/2 44/6
driver [2] 71/8 135/9
drop [1] 163/24
dropped [1] 162/20
dropping [1] 164/3
DTI [1] 43/3
due [3] 73/9 147/22
174/4
Dunn [1] 125/20
during [5] 10/114 11/2
34/10 115/20 174/11
duty [5] 82/24 85/14
98/23 145/24 156/21
E
each [7] 63/22 84/21
85/11 98/25 145/11
157/3 157/5
earlier [32] 8/19
18/15 30/6 59/23 61/7I
77/25 78/19 78/23
79/14 79/23 85/25
86/16 86/20 95/23
98/20 98/21 101/21
102/8 112/1 127/7
136/24 157/22 158/12)
159/7 159/22 171/18
177/4 178/22 180/12
181/13 186/10 189/2
early [7] 50/15 69/18
70/13 97/18 142/20
164/21 176/11
earned [1] 131/8
ease [1] 95/21
easy [2] 76/3 110/25
edit [2] 68/5 68/12
edited [2] 103/1
147/3
editing [4] 67/21
103/14 133/22 158/2
Edwards [17] 64/24
64/25 65/3 65/4 117/6
134/10 170/2 172/2
174/21 177/3 187/3
187/16 189/15 189/24I
190/10 190/13 192/10}
effect [2] 134/24
136/2
effective [2] 22/21
120/2
effectively [4] 23/5
(67) didn't... - effectively
E
effectively... [3]
50/16 71/2 142/7
efficient [1] 64/15
efforts [2] 17/13
133/8
eg [1] 149/16
eg the [1] 149/16
either [10] 10/18 13/7I
39/22 55/10 67/22
76/16 90/11 96/18
131/1 163/24
elements [2] 9/6
21/12
else [2] 39/23 97/23
elsewhere [2] 15/19
88/16
email [108] 52/7
52/22 53/4 54/19
70/14 70/23 71/8
72/22 73/21 74/17
74/19 77/7 78/5 78/16)
80/6 80/13 81/14 84/9
84/10 84/11 84/12
87/19 87/24 88/6 88/7
88/17 88/24 90/17
90/20 91/2 91/3 95/20
95/23 95/25 97/3 97/8
99/17 100/4 101/15
102/9 102/10 102/12
102/15 105/2 105/7
105/8 108/15 109/5
110/2 111/20 112/7
114/1 118/19 118/19
119/19 120/3 120/19
123/17 125/9 125/12
125/18 126/12 126/16)
127/18 127/23 130/22
131/5 132/12 133/16
137/12 138/6 141/24
143/3 143/4 143/13
144/10 144/22 144/24}
145/6 152/1 153/21
153/25 155/1 155/12
156/6 158/6 159/24
160/2 161/20 161/24
162/1 163/11 163/11
165/1 165/2 171/25
172/4 173/3 173/5
173/16 176/19 176/21
180/8 183/6 183/11
187/3 187/8 190/4
email's [1] 106/1
emailed [2] 109/7
114/2
emailing [1] 132/13
emails [10] 78/18
79/6 86/16 90/12 96/3,
96/10 112/13 134/10
149/22 159/21
embroiled [1] 109/14
emerged [3] 89/2
95/13 99/6
emerging [2] 92/17
93/5
emotionally [1]
111/19
emotive [1] 97/3
emphasise [3] 95/7
155/6 177/1
employed [1] 70/5
enable [3] 3/1 3/20
71/25
enabled [2] 135/22
148/15
enabling [1] 46/14
encourages [1] 54/4
end [7] 68/6 110/5
114/16 125/16 149/25)
159/3 159/7
ends [1] 156/2
engage [1] 73/5
engaged [1] 51/2
engagement [2]
68/12 71/1
Engineer [1] 80/6
enough [5] 108/16
170/7 175/25 176/2
189/4
enquire [1] 178/9
enquiries [1] 115/23
ensure [13] 15/2
21/11 59/6 68/6 68/11
68/12 71/25 72/1
72/13 82/13 89/20
90/6 119/15
ensuring [2] 17/13
89/16
entire [1] 8/11
entirely [4] 68/16
89/4 95/15 111/14
entitled [4] 143/13
entry [1] 21/2
EPOS [1] 5/19
equally [1] 105/18
equivalent [1] 33/23
era [2] 187/20 187/23
erroneous [1] 109/23
errors [6] 174/4
174/12 179/17 182/21
183/21 184/9
escape [1] 188/20
especially [2] 50/15
134/11
essence [1] 29/21
essential [2] 174/17
174/21
essentially [2]
140/15 160/15
establish [1] 185/23
et [10] 94/14 177/12
177/12 181/5 181/5
181/5 185/19 185/19
185/22 185/22
et cetera [9] 94/14
177/12 177/12 181/5
181/5 185/19 185/19
185/22 185/22
etc [3] 94/25 124/2
151/2
Evans [3] 8/15 27/19
27/20
even [8] 23/23 46/4
62/25 63/1 92/24
134/1 161/17 170/12
evening [2] 160/5
165/12
evenings [1] 160/7
event [2] 85/16 99/12
events [1] 133/18
ever [10] 18/16 21/25
27/16 28/4 28/20
30/17 33/8 46/22
146/4 163/23
every [9] 50/4 50/7
63/21 109/16 110/7
110/13 110/19 115/2
175/23
everybody [2] 40/9
164/3
everyone [4] 97/22
135/7 168/16 180/24
everything [6] 13/21
58/13 101/2 108/3
171/11 175/24
evidence [75] 1/7
1/13 1/14 1/25 2/1
2/10 2/10 3/11 4/6 4/8
5/10 6/17 7/8 7/11 8/9
9/14 15/6 22/3 24/11
24/15 27/22 28/10
29/11 29/12 31/9
31/23 33/1 35/9 35/22,
35/25 39/13 40/17
40/22 41/14 41/19
46/24 47/1 49/14
49/16 51/25 55/5 55/7,
60/22 64/5 67/17 77/1
77/5 91/8 92/5 93/4
93/6 93/11 94/9 97/1
98/13 98/18 99/10
101/21 113/16 141/5
162/19 172/12 175/4
176/11 177/4 182/11
182/13 183/13 183/21
184/18 185/2 186/1
188/15 189/2 190/14
evident [3] 45/13
180/8 186/2
Evidently [1] 130/8
evolution [1] 48/12
evolved [1] 102/14
ex [1] 52/15
ex-subpostmaster
[4] 52/15
exact [1] 102/16
exactly [7] 5/24 6/5
13/11 18/1 41/7
159/15 162/21
examine [1] 127/3
example [12] 27/8
40/23 48/7 67/7 67/22)
87/8 116/9 146/12
156/7 166/4 181/8
183/4
exceedingly [1] 53/2
Excel [1] 56/4
exception [1] 97/5
exceptions [2] 99/17
99/18
exchange [10] 78/17
88/8 97/6 102/9
102/10 102/15 140/4
144/5 178/11 180/9
exchanges [2] 51/1
127/7
Exchanging [1] 96/3
execs [2] 2/20 2/20
execute [2] 2/21 2/22
executive [36] 3/4
3/16 3/16 4/9 10/21
10/25 11/9 11/12
12/21 18/17 31/12
35/1 39/5 40/19 43/5
43/11 43/12 53/6
72/10 75/6 79/15
101/13 102/3 148/1
158/16 163/16 164/24)
166/21 170/2 170/6
175/8 175/16 176/1
176/7 183/3 188/17
Executive's [1]
175/20
executives [6] 2/21
2/21 18/7 29/9 29/12
41/7
exercise [3] 9/15
14/12 29/5
exercised [1] 30/25
exercises [1] 167/22
exercising [2] 9/1
9/10
exist [1] 153/25
existed [1] 63/10
existence [2] 80/21
182/21
existing [2] 47/15
76/6
expand [2] 34/4
105/20
expect [12] 13/14
15/5 41/18 47/23
47/23 51/20 52/5
57/15 64/7 82/19
122/23 132/22
expectation [1]
159/2
expectations [5]
92/23 93/1 93/3 93/4
159/5
expected [5] 11/19
12/2 12/14 12/19
159/1
expecting [2] 109/19
142/3
expensive [1] 50/6
experience [6] 12/25
25/3 74/9 74/10
112/25 167/20
experiences [1]
50/12
expert [21] 59/10
59/17 68/18 69/7 80/8
87/16 89/20 90/4
101/24 104/11 143/20)
143/25 144/2 144/13
144/14 156/1 162/12
174/24 184/8 185/21
185/25
expertise [3] 26/22
104/13 135/14
experts [22] 68/3
69/12 73/22 78/1 78/4I
78/7 78/8 87/14 87/15
89/7 89/12 89/15
96/22 101/22 103/5
103/22 104/20 168/14!
168/14 168/15 175/23}
179/12
explain [6] 66/3
101/5 147/24 149/3
150/13 187/7
explaining [3] 73/6
76/14 159/17
explanation [6] 150/8}
152/4 155/14 158/25
159/13 162/16
explicit [1] 44/1
explicitly [1] 134/24
expressed [1] 128/14!
extension [1] 45/12
extensive [1] 122/24
extent [4] 101/24
136/24 157/25 181/19)
external [12] 67/24
85/13 99/2 107/16
108/22 108/25 115/20)
116/6 143/16 146/14
156/18 173/19
externally [1] 92/23
extract [2] 125/12
125/18
extracts [2] 123/20
132/17
extraordinary [2]
131/19 171/20
extremely [2] 46/7
180/13
F
face [1] 168/14
faces [1] 123/12
facing [3] 29/22
50/17 123/25
fact [12] 34/2 36/6
38/13 41/1 58/1 61/4
79/2 95/3 97/18
101/24 110/20 154/4
facts [1] 36/25
(68) effectively... - facts
F
factual [2] 122/13
123/14
failed [2] 55/4 184/8
failures [3] 91/8
93/12 94/11
fair [19] 7/7 9/14 15/1
27/2 29/1 29/4 44/20
73/25 74/1 74/4 89/21
96/22 96/24 102/5
108/14 128/23 167/23
187/18 188/12
fairly [3] 20/4 96/5
159/22
faith [1] 94/18
Falkirk [3] 79/14
79/18 185/19
fallen [1] 60/4
false [2] 5/22 32/20
familiar [4] 68/16
141/1 152/8 176/23
familiarise [1] 80/22
family [1] 153/23
fan [1] 73/17
far [17] 10/19 11/5
22/2 32/22 33/7 35/16
90/24 101/11 102/6
102/19 102/21 111/17)
120/1 122/11 138/1
159/15 168/14
farmed [2] 146/25
181/16
fat [1] 125/14
fault [2] 1/15 129/14
faults [1] 127/14
feasibility [1] 75/16
features [1] 130/11
February [5] 35/2
42/19 142/21 149/22
164/25
February 2013 [1]
142/21
fed [1] 148/6
Federation [1] 20/14
feed [1] 73/19
feedback [1] 158/23
feel [6] 46/19 94/5
105/20 119/10 128/23
134/3
feeling [2] 128/13
129/20
fell [1] 37/16
felt [17] 29/10 77/15
82/12 88/9 88/12
110/8 110/15 111/14
111/16 127/22 128/10
128/11 131/18 134/20}
150/6 152/8 166/11
few [8] 21/17 98/7
121/4 146/6 153/7
167/25 187/18 187/23}
figment [1] 60/13
figure [2] 141/1
141/8
figures [3] 31/10
41/1 94/22
files [1] 157/8
filled [1] 85/5
filter [1] 166/12
final [24] 65/10 81/19
82/17 84/11 89/19
94/2 97/17 98/8 98/15
99/4 102/13 103/5
113/23 127/15 132/16)
143/19 153/14 156/11
157/25 158/9 158/10
159/12 182/11 183/7
finalised [2] 143/23
156/13
finalising [1] 101/23
Finance [1] 24/8
financial [15] 22/9
22/10 27/8 45/16
56/14 57/7 57/12 60/2
66/19 107/12 107/23
112/22 170/4 188/9
188/25
find [1] 151/20
finding [4] 123/13
127/18 128/2 163/19
findings [11] 76/5
82/9 99/6 107/14
127/12 128/20 132/1
145/24 147/17 156/21
190/6
fine [13] 1/20 41/21
41/21 41/21 42/2 60/7)
61/1 169/18 169/24
186/24 187/1 187/11
190/24
finish [1] 27/6
finished [3] 32/5
54/23 81/25
firm [5] 76/3 108/25
143/16 146/14 156/18)
firmer [2] 91/6
103/25
firmly [1] 76/14
first [31] 2/8 4/19
10/9 40/4 56/11 57/1
70/12 72/11 81/22
82/22 85/20 94/9
100/3 105/4 106/2
114/15 118/2 123/16
123/17 144/3 146/5
146/22 150/19 152/24)
153/21 158/23 163/1
163/17 168/5 174/3
181/2
firstly [5] 15/7 25/12
27/13 43/9 47/7
fit [3] 45/22 64/9
158/18
fitness [1] 45/24
five [11] 140/15
141/1 141/4 141/8
145/13 170/24 172/11
175/3 175/3 186/7
186/10
five-page [1] 145/13
fixes [1] 47/18
flag [1] 20/11
flagged [5] 19/19
20/13 29/17 122/15
122/16
flawed [1] 184/8
flawless [2] 174/18
174/22
Flemington [3]
123/18 177/11 179/2
floated [1] 172/23
flotation [4] 113/8
113/11 118/11 118/13}
focus [5] 45/8 108/16
128/3 165/15 165/21
focused [5] 107/14
118/4 122/13 135/8
171/4
focuses [1] 29/21
follow [11] 78/6
79/11 79/19 80/4 81/4
93/10 143/21 151/23
155/8 184/10 187/9
follow-up [3] 80/4
151/23 187/9
followed [5] 15/10
160/18 162/19 169/22)
169/23
following [5] 43/7
84/14 143/22 146/14
187/8
follows [14] 2/12
67/19 70/24 72/23
74/20 81/23 83/8
84/13 107/10 114/3
145/19 158/8 162/5
165/10
font [1] 88/23
footage [1] 109/11
forbid [1] 179/3
forefront [2] 14/13
14/14
forgive [1] 184/23
forgot [1] 69/25
form [5] 39/3 40/10
77/8 154/17 160/16
formal [2] 146/12
181/7
formally [2] 39/23
142/16
format [1] 69/3
formed [6] 21/5 77/6
77/10 99/4 138/23
159/20
former [2] 114/15
188/16
formulated [1]
136/14
fortune [1] 101/19
forward [4] 100/10
100/16 143/21 153/14]
forwarded [3] 115/13
183/11 184/21
forwards [3] 100/25
117/17 159/1
found [4] 68/8 101/11
140/17 159/19
founding [1] 127/1
four [2] 145/13
186/10
fourth [1] 98/5
frank [1] 179/17
frankly [1] 19/20
fraud [4] 5/22 17/9
17/19 21/19
free [4] 83/4 105/20
119/10 188/20
Freshfields [1]
125/13
Friday [4] 1/1 73/4
126/12 131/12
friend [1] 73/17
front [2] 65/4 112/25
fronts [1] 71/15
frustration [3] 164/9
164/12 164/14
frustrations [1]
164/16
Fujitsu [11] 47/1
52/25 56/20 62/9 80/7,
91/24 137/20 138/7
149/22 173/9 185/22
full [6] 41/8 65/2
122/5 150/13 180/21
182/8
fully [4] 32/23 77/5
166/16 189/2
function [10] 6/15
12/8 13/1 13/23 14/12,
23/6 28/11 36/8 38/11
38/12
functioning [1] 32/23
functions [6] 15/17
34/2 38/23 38/23
55/17 55/18
fundamentally [2]
66/6 104/19
funder [1] 166/4
funding [3] 71/11
166/6 167/15
further [26] 1/17
28/19 64/11 72/4
74/21 93/11 94/21
95/4 106/4 106/21
107/18 107/21 115/22}
121/4 139/8 142/12
142/14 143/7 149/12
153/7 153/16 156/4
157/8 158/2 166/25
187/7
furthering [1] 170/8
future [9] 56/14
56/21 57/7 57/12
71/13 117/24 143/13
153/17 156/5
FYI [1] 79/7
G
Gaerwen [1] 52/18
gainsay [1] 22/11
Gaisford [1] 114/2
gap [1] 33/24
Gareth [31] 78/17
79/17 79/25 80/10
113/19 113/20 115/17)
140/1 140/5 140/7
141/7 142/15 142/21
144/8 154/4 155/25
162/11 179/15 180/1
180/7 182/12 182/20
183/5 183/12 183/14
184/7 184/18 185/2
185/21 185/25 185/25}
gathered [2] 77/2
160/12
gathering [2] 73/22
117/23
gave [7] 1/7 22/3
36/13 138/6 167/13
177/4 186/15
general [26] 11/8
28/20 29/18 33/21
39/11 43/4 62/11 66/7I
92/15 137/4 138/13
138/17 140/19 165/23}
175/10 175/18 176/6
176/8 176/16 176/17
176/22 177/14 177/15)
177/20 179/18 186/5
generalism [1] 29/20
generally [13] 19/23
28/15 29/15 29/19
30/2 38/13 76/11
85/13 99/2 128/5
155/1 167/19 188/10
generated [2] 5/16
85/9
Gentlemen [1] 39/11
get [32] 39/21 51/8
52/12 53/22 73/4
74/24 75/9 77/3 80/25
83/3 84/4 86/5 87/13
106/7 121/10 124/11
129/9 130/9 130/19
131/10 132/19 133/2
161/10 161/22 165/13)
173/1 173/6 174/1
179/2 183/11 186/14
188/19
getting [9] 24/6 69/23}
79/16 92/18 102/20
133/8 150/7 164/13
177/18
Gibson [4] 118/20
119/6 125/9 163/16
give [21] 9/18 9/21
64/5 88/12 110/14
114/25 139/4 142/4
142/9 150/24 151/14
(59) factual - give
G
give... [10] 152/17
152/21 155/7 178/18
178/23 178/25 179/3
179/4 179/8 186/19
given [31] 17/17
23/15 31/9 36/25
39/24 43/22 46/2
53/17 60/16 73/5
75/18 86/20 99/6
113/16 114/22 115/15}
141/14 141/23 147/2
167/20 172/14 173/15}
175/4 175/12 177/5
182/13 183/12 184/18)
185/2 186/1 188/15
gives [2] 44/20 155/1
giving [11] 3/11 4/6
5/10 6/17 35/25 41/18
78/1 124/21 142/11
148/4 190/14
glimmer [4] 92/8
92/11 92/13 93/2
GLS [1] 38/9
go [48] 2/17 3/9 7/17
8/1 8/10 12/16 14/16
16/7 16/10 17/2 20/19
21/7 23/15 25/5 27/6
33/4 36/2 46/8 47/5
51/1 52/6 52/21 53/5
53/12 56/4 72/9 76/24
89/19 94/3 96/12 98/6
121/17 124/20 136/6
139/24 141/25 148/10
149/13 151/6 152/20
163/17 173/25 178/9
181/1 181/2 184/14
185/7 185/17
God [1] 179/2
goes [12] 32/17
36/11 46/3 50/11
52/17 72/8 88/2 94/2
131/8 151/6 155/24
173/21
going [53] 4/22 18/25
19/20 30/20 54/3 58/3}
58/5 60/1 67/22 70/12
77/5 77/7 81/6 82/1
88/9 97/10 98/7
100/24 100/25 100/25}
102/2 104/22 106/4
106/21 107/21 117/7
117/17 118/10 125/4
126/7 130/20 134/10
136/6 142/16 143/2
143/21 145/4 145/9
145/13 150/8 150/25
152/7 153/14 159/1
163/12 167/24 169/7
169/11 169/12 172/16
172/22 178/20 179/6
golf [3] 53/8 54/2
54/3
gone [6] 7/12 55/24
119/8 158/2 182/9
183/1
good [18] 1/3 41/11
43/23 47/20 48/7
64/22 72/24 73/16
74/25 117/3 121/5
125/22 125/24 161/15)
166/12 166/23 187/16)
189/8
got [12] 3/3 3/5 39/11
39/12 51/22 57/13
116/6 134/16 138/13
138/14 144/4 186/17
governance [2] 22/8
30/18
governed [1] 124/6
government [10]
45/12 66/21 71/4
71/11 71/13 71/19
72/14 74/7 74/10
121/23
grade [2] 66/23 66/25]
graduating [1] 66/14
granular [1] 63/8
grateful [6] 64/10
72/12 91/12 145/18
158/12 190/15
grave [1] 140/10
great [4] 64/8 183/1
183/3 188/11
greater [7] 22/8
70/25 71/5 71/14
71/16 71/17 111/18
grounds [5] 88/5
92/19 92/21 146/11
181/7
group [72] 4/11 4/21
5/2 5/7 6/4 6/14 6/15
7/1 8/10 8/23 9/1 12/1
12/9 12/9 12/10 13/22
19/10 19/11 19/23
21/19 23/6 26/23
27/15 27/17 27/23
28/5 28/21 28/22
31/10 32/10 34/16
34/20 34/21 35/20
35/21 36/9 36/13 37/3
37/17 37/25 38/8
38/11 38/12 38/12
38/14 38/16 38/23
38/23 38/23 39/5 44/7
45/3 49/6 53/22 56/24
57/16 70/2 79/21
80/14 81/8 93/18
93/19 93/20 93/22
93/23 129/4 144/19
158/18 158/22 158/24)
165/2 167/18
group's [3] 4/14
14/23 39/16
groupthink [2] 168/7
189/3
guarantee [1] 91/13
guess [7] 52/11
92/15 92/21 132/24
141/14 159/16 164/5
guessing [1] 58/4
Guildford [2] 78/20
183/8
guile [1] 170/3
guys [1] 132/25
AO
habit [4] 164/3
had [158] 4/9 12/11
12/18 14/22 17/9 19/1
19/5 20/11 25/2 29/17
33/15 34/5 36/7 37/2
38/8 38/23 41/14 43/2
47M 47/21 47/21
52/19 58/5 58/13 59/7I
59/11 59/14 63/5
68/19 70/16 73/10
74/4 74/21 75/5 77/2
77120 78/22 79/14
79/23 80/9 80/9 80/21
81/3 82/4 82/8 82/11
82/13 83/6 83/7 86/7
86/14 88/8 88/25
92/16 93/5 98/16
100/15 100/18 100/25I
1041/3 101/11 102/14
102/16 102/22 104/2
105/24 106/22 107/22
108/2 108/6 110/10
114/13 111/16 111/17I
114/22 115/11 115/12
115/13 116/6 117/19
118/1 121/22 122/5
122/16 124/1 124/10
4127/1 127/7 129/9
129/21 129/21 129/22
131/11 132/5 132/7
132/7 135/15 135/16
136/21 137/25 138/11
138/23 139/14 140/6
140/20 140/24 141/4
141/17 141/24 141/25I
142/8 144/25 146/2
146/25 146/25 150/20
153/7 154/17 156/14
159/20 159/21 160/10
160/12 160/19 160/20
160/22 161/3 161/12
161/17 162/12 167/4
167/10 168/6 170/18
172/18 174/19 174/24
175/4 175/5 176/15
177/22 177/24 179/10
179/16 181/10 181/20
182/13 182/19 182/19I
182/20 182/23 183/17I
184/4 184/8 184/18
185/2 186/1 188/18
hadn't [19] 66/4
67/11 77/10 82/16
83/23 92/24 103/4
103/7 138/7 139/16
142/6 146/19 171/25
175/5 175/9 175/12
175/12 178/20 179/6
half [4] 41/20 81/25
108/19 183/16
halfway [2] 65/25
67/18
hand [4] 49/19 76/1
157/21 162/25
handed [2] 76/4
160/13
handle [1] 77/14
handled [1] 51/10
handling [9] 50/20
72/25 74/17 76/9
76/10 76/10 78/2 78/2
166/23
hapless [1] 174/25
happen [6] 3/20
20/12 20/12 29/8
43/24 62/16
happened [7] 28/9
49/17 52/2 58/23
96/25 137/1 160/20
happening [5] 13/21
20/7 47/24 83/1 89/24
happens [4] 18/23
27/3 119/18 135/14
happy [4] 96/12
101/18 114/8 169/1
hard [3] 50/18 88/10
188/10
hares [6] 105/18
105/22 106/6 106/16
107/1 107/20
has [81] 1/16 24/11
25/7 40/22 46/23 47/1
53/7 53/15 53/25 55/5)
56/6 61/12 62/7 76/18)
79/3 83/6 83/14 83/14
84/11 85/5 85/17 87/6
88/14 89/2 95/3 95/13)
95/22 97/1 99/6 99/13)
99/24 100/5 105/1
109/7 109/10 114/2
114/12 114/13 119/6
119/20 120/25 121/2
122/9 123/10 126/18
126/20 133/23 134/2
136/8 137/12 142/17
144/10 145/20 146/15}
148/12 148/13 148/15
149/18 152/25 154/4
156/19 157/1 157/2
157/25 159/15 160/13}
163/18 165/4 166/23
167/20 167/23 168/16}
169/5 172/7 176/6
178/1 181/4 183/4
183/12 183/14 187/5
hasn't [1] 101/24
have [285]
haven't [4] 6/6 76/22
139/13 165/18
having [17] 10/20
10/24 28/5 31/5 37/5
46/19 50/13 58/12
66/8 74/3 97/7 108/12
115/25 138/23 151/18)
165/25 175/17
hazy [2] 138/3 173/18
he [74] 22/5 24/12
28/1 31/12 35/1 35/5
36/11 39/13 39/13
39/18 40/23 43/2
60/11 66/8 70/24
76/14 76/19 78/19
78/25 80/7 80/14
84/14 91/4 91/14
91/15 91/23 92/2
92/10 92/16 93/7 95/5I
95/22 108/7 108/8
118/20 119/7 120/6
120/19 123/22 124/8
124/8 124/10 124/10
125/10 125/20 126/3
126/5 126/5 131/2
139/25 140/1 140/2
140/8 140/12 142/22
147/5 147/11 148/12
148/13 149/6 149/18
151/3 155/1 156/2
162/3 162/5 162/12
165/5 165/8 166/23
181/19 182/13 183/17)
184/7
he'd [1] 179/16
he's [4] 27/22 166/16
169/11 169/12
head [7] 54/19 55/21
89/8 102/1 103/2
109/7 172/24
headed [1] 136/10
heading [2] 23/18
99/16
headline [4] 45/10
109/24 109/25 112/8
headlines [4] 110/22
110/25 112/20 112/23}
hear [7] 1/3 15/5 42/7I
50/13 64/22 117/3
125/24
heard [14] 24/11
24/15 40/22 46/23
47/1 55/5 67/7 78/20
149/4 150/19 171/12
176/1 183/8 188/15
hearing [5] 1/5 2/1
62/6 64/8 191/1
hearings [1] 97/7
heavily [4] 104/14
161/22 175/21 179/11
heavy [1] 76/4
heavy-handed [1]
76/4
held [5] 21/16 71/25
116/13 121/21 143/16
(60) give... - held
H
Helen [33] 140/2
140/5 142/18 145/3
148/13 148/24 149/7
149/13 149/18 149/20
150/13 151/12 152/3
153/13 153/21 154/1
154/2 154/7 155/14
155/17 156/10 156/23}
160/25 161/16 162/3
162/17 162/21 178/16)
179/14 179/24 180/5
180/6 180/10
Helen's [1] 162/8
help [8] 17/12 62/14
81/17 121/17 121/24
133/2 151/7 159/14
helped [1] 150/13
helpful [3] 100/7
119/24 138/16
hence [1] 52/16
Henry [10] 169/2
169/5 169/11 169/22
170/1 184/13 184/15
186/11 186/15 192/14}
her [37] 67/23 67/23
73/5 73/18 73/24 84/1
87/18 87/18 90/6
105/13 110/2 114/23
114/25 115/9 115/14
119/22 120/4 129/11
134/15 142/5 148/6
151/1 152/9 152/12
158/14 158/15 158/19
160/5 161/18 175/11
176/15 176/21 177/11
177/13 178/4 178/7
184/1
here [30] 9/10 14/17
27/3 28/8 30/15 43/22
54/11 78/3 78/9 83/3
89/8 90/22 95/21
99/18 101/23 103/1
103/4 108/24 123/14
128/13 131/24 132/6
132/16 138/15 141/8
145/6 154/16 159/12
161/7 164/12
here's [3] 97/23
145/17 158/9
herself [1] 138/1
Hi [8] 101/17 109/22
119/8 126/14 137/15
145/17 148/24 158/9
high [17] 12/21 13/2
46/7 60/14 129/15
129/19 131/17 131/20}
131/21 133/13 137/23)
149/11 166/17 168/22)
173/12 179/21 183/24
high-level [1] 168/22
high-profile [3]
129/19 131/20 179/21
higher [1] 58/3
highlight [1] 21/5
highlighted [2]
103/19 147/7
highlighting [2]
106/20 147/19
highlights [1] 119/1
highly [5] 141/10
158/16 167/6 171/19
172/18
him [10] 24/18 24/21
24/24 27/24 31/18
35/7 41/16 95/23
165/7 183/20
hindsight [14] 2/14
30/13 30/21 31/2
108/3 110/14 113/3
134/1 154/24 168/6
175/25 182/1 182/5
182/7
his [23] 1/9 1/14 1/15
22/4 35/13 35/22
52/10 78/18 80/5 91/3
91/21 120/10 130/22
140/13 140/18 142/9
143/23 145/21 146/8
147/10 155/25 156/41
181/5
historic [6] 146/12
148/17 181/8 184/4
184/6 185/1
historical [4] 99/3
110/11 157/8 170/4
history [1] 133/19
hit [1] 126/16
hoc [1] 30/2
Hodgkinson [4] 22/3
24/7 31/12 42/23
hold [3] 98/14 124/11
133/2
holding [6] 74/24
104/8 114/6 114/7
119/12 171/3
Holdings [8] 9/1
10/15 11/9 11/11
31/13 32/10 38/10
45/15
Holt [3] 146/22 153/2
181/14
Home [1] 66/20
honest [3] 26/3 134/1
150/11
Hooper [1] 144/20
Hooper's [1] 158/23
hope [2] 131/13
151/17
hopefully [2] 133/4
151/22
hoping [2] 131/8
171/21
Horizon [95] 5/16
13/16 13/22 14/20
14/21 30/16 30/20
31/5 33/9 33/10 37/9
44/9 44/14 44/16 45/2
45/8 45/17 46/1 46/6
46/10 46/15 46/21
47/6 47/13 48/1 48/13
49/4 49/7 50/14 52/11
52/16 55/2 55/6 56/15)
57/8 58/2 59/3 59/11
59/18 60/13 69/17
70/20 71/7 71/9 72/25
79/2 82/24 83/4 83/14
86/3 89/5 93/20 93/22
95/16 98/13 98/22
99/10 99/20 103/12
103/15 110/10 111/16
111/18 112/3 112/20
113/5 113/7 119/5
123/23 124/14 124/23
125/13 125/19 125/21
128/6 128/7 128/17
132/6 142/22 149/23
150/2 150/4 150/17
151/19 154/9 154/19
154/21 162/10 162/12
162/14 174/4 174/11
179/25 182/21 188/17
Horizon's [1] 45/23
Horizon-related [1]
188/17
Horizon/IT [1] 124/23
Horizon/Second [2]
123/23 124/14
hostages [1] 101/18
hour [2] 41/20 169/9
hours [2] 41/16
52/19
house [2] 36/7 40/24
how [33] 8/6 19/7
27/8 29/18 37/24 38/4
40/12 41/18 77/14
79/22 85/5 93/23
100/24 100/24 100/25
103/17 103/18 103/24]
105/8 107/24 120/1
126/7 129/17 131/7
131/11 132/10 133/15}
136/13 146/19 159/20}
167/10 178/20 179/6
However [1] 126/15
Hoylake [2] 52/9
53/12
huge [2] 122/17
189/6
hugely [2] 111/3
168/10
Hugh [12] 84/4 84/14
86/7 86/17 88/7 96/3
102/12 102/18 122/10}
122/11 123/18 177/11
Hughes [1] 52/8
human [5] 17/7 17/17
107/24 108/17 109/20
human-interest [1]
109/20
humans [1] 108/10
hundreds [1] 51/9
hypothetical [1] 58/5
I absolutely [1]
180/10
l agree [2] 96/5 113/3
lalso [1] 45/14
lam [6] 53/9 87/18
96/11 142/24 177/4
189/7
land [1] 135/7
l appreciate [1] 50/5
lare [1] 84/4
ask [5] 39/15 65/7
65/10 187/3 187/16
lasked [11] 2/12
2/13 3/15 4/18 5/13
8/13 18/15 20/22 30/6
114/25 124/1
lassume [3] 16/21
105/23 138/5
lattach [1] 153/3
I attended [2] 174/7
174/10
I began [1] 45/14
I believe [4] 65/17
126/2 174/3 185/12
Icall [1] 64/24
lean [15] 11/5 22/2
28/24 32/1 32/2 34/18
35/16 38/2 43/15 59/5)
61/5 94/3 134/9 138/5
176/9
I can't [15] 5/24 6/5
16/14 16/24 17/20
17/20 21/24 47/11
47/19 48/24 49/24
53/24 102/15 139/11
139/12
I cannot [2] 32/12
50/6
I certainly [7] 74/10
144/7 144/15 144/22
170/14 171/9 172/7
I clearly [1] 161/7
I commissioned [1]
152/20
I completely [1]
172/19
I constructed [1]
171/11
I coordinated [1]
116/12
I could [3] 22/20
64/16 121/17
I couldn't [2] 24/14
25/4
I deeply [2] 168/9
189/6
I describe [1] 111/13
I described [4]
171/18 172/14 180/11
181/13
I did [9] 26/1 49/13
152/3 155/6 160/18
176/17 176/17 180/14)
183/19
I didn't [20] 49/17
49/24 74/24 113/10
152/2 154/15 171/10
172/4 172/5 172/6
175/23 176/9 180/8
180/12 180/21 184/10)
189/4 189/5 189/25
190/5
Ido [10] 10/11 32/18
33/16 47/19 48/20
49/12 49/12 97/7
168/20 171/12
I don't [51] 6/5 8/10
9/13 16/7 17/23 18/5
18/21 24/3 24/19 26/2)
28/8 28/14 29/7 43/15
55/22 77/10 80/4
80/24 81/4 92/14 97/1
103/15 103/19 106/18}
106/23 107/4 107/4
107/5 112/4 112/6
112/17 115/6 119/3
129/10 134/3 135/13
142/9 144/5 146/4
150/12 160/18 162/1
164/8 169/10 174/13
182/1 184/14 185/4
185/6 186/9 189/4
l emphasise [1]
17/1
lever [1] 146/4
l expect [2] 57/15
64/7
I feel [1] 46/19
I finished [1] 32/5
first [1] 174/3
I flagged [1] 122/15
I focused [1] 171/4
I followed [1] 160/18
I forgot [1] 69/25
I fully [1] 189/2
I gave [1] 177/4
I get [2] 39/21 130/19
Igo [1] 14/16
I got [4] 39/12 134/16)
138/13 186/17
I guess [5] 52/11
92/15 92/21 132/24
141/14
I had [6] 19/5 41/14
52/19 111/13 140/24
168/6
I hadn't [6] 66/4
67/11 77/10 139/16
175/12 175/12
I hand [4] 162/25
Ihave [26] 6/24
11/19 32/9 53/14
58/15 69/8 81/17
84/15 90/11 101/17
(61) Helen - Ihave
Ihave... [16] 119/24
120/9 121/12 122/10
126/15 130/17 131/8
1447/7 147/9 149/11
149/12 162/19 162/24)
164/4 176/19 189/6
I haven't [3] 6/6
139/13 165/18
I hear [1] 50/13
Iheld [1] 116/13
I hope [1] 131/13
linterpreted [1] 88/4
l introduced [1] 22/6
I joined [2] 4/23
174/7
I just [4] 54/11 57/2
78/14 158/10
I kind [2] 115/14
117/13
I knew [1] 45/18
I know [7] 10/19
63/21 100/7 102/10
118/22 154/9 163/24
I may [2] 154/12
160/6
I mean [38] 7/16 9/22
13/11 17/20 18/21
22/18 25/15 28/12
38/7 39/10 41/17
45/25 46/15 50/18
67/7 76/10 80/5 89/22
92/14 100/22 102/5
102/24 103/7 104/8
105/10 106/10 108/1
111/10 114/22 127/16)
128/19 133/17 138/24)
147/24 148/8 155/6
167/19 167/23
I meant [2] 105/23
107/5
I mentioned [1]
189/2
I met [1] 166/15
Ineed [1] 184/15
I never [1] 49/23
I now [1] 144/8
I personally [1] 89/12)
I please [1] 56/3
I probably [2] 150/24
154/24
I produced [1] 185/8
I provided [2] 163/6
189/4
Iread [5] 18/22 28/16
38/21 134/11 162/18
lrealise [1] 126/14
really [2] 135/8
137/18
I recall [12] 73/13
75/6 75/9 81/1 116/2
117/25 118/8 139/2
141/6 160/21 190/2
190/4
I recognise [2]
129/12 141/7
I recollect [1] 138/1
I recollected [1]
170/25
refer [2] 65/24
102/11
Ireferred [1] 86/16
relied [1] 161/7
I remember [1]
160/21
l reopened [1] 52/18
I repeated [1] 40/17
I returned [1] 160/19
I said [6] 8/18 26/2
73/3 73/14 145/3
173/17
I saw [8] 25/16 58/7
80/5 80/5 146/5
184/20 185/10 186/10)
I say [9] 22/17 107/21
1142/7 112/17 115/11
141/22 152/5 166/11
179/8
Isee [4] 57/23 63/21
154/15 168/8
Isent [1] 119/9
I share [1] 119/8
I shortcut [1] 39/20
I should [1] 4/16
I simply [1] 189/15
I skim [1] 154/14
I spoke [1] 125/20
I still [1] 73/1
I stress [1] 1/15
I suggest [9] 151/5
160/8 165/7 171/21
172/9 179/14 180/17
182/12 183/20
I suppose [2] 28/19
63/1
I take [5] 26/5 31/23
35/9 60/21 190/21
I then [3] 147/3
152/16 181/15
I therefore [1] 179/12
I think [239]
I thought [4] 18/12
37/21 130/6 151/4
I took [6] 77/24 87/24
152/11 157/22 178/22)
181/16
I try [1] 163/25
l understand [3] 66/8
124/22 132/16
I understood [3]
106/21 138/11 173/19)
l update [1] 72/9
use [1] 59/10
I want [14] 1/25
15/22 31/9 40/16
44/14 51/17 56/3
88/11 125/14 173/25
178/9 178/9 181/2
182/10
I wanted [2] 42/9
61/1
I was [67] 4/22 7/16
7/18 32/23 33/11
36/12 36/24 66/4 69/7
69/19 69/23 77/14
77/19 79/21 79/21
82/11 83/25 100/15
100/17 100/18 101/9
103/13 106/10 106/24]
110/5 110/21 111/19
112/1 112/4 112/7
114/23 115/11 117/13
118/14 136/20 136/24]
138/24 141/14 141/23
144/3 144/16 144/17
150/19 152/1 152/6
152/20 155/4 160/24
161/21 163/8 167/7
168/7 170/6 172/14
172/17 175/19 175/21
17715 177/17 177/24
179/11 180/20 180/22
180/25 182/23 189/2
190/8
I wasn't [12] 58/18
113/10 113/22 115/18
137/1 150/5 150/11
177/25 182/6 186/17
190/2 190/8
Iwill [15] 2/3 2/4
54/12 72/9 96/1
124/22 125/7 130/9
151/14 178/18 178/25
179/2 179/4 179/8
179/9
I wondered [2] 73/17
74/21
I worked [1] 167/16
I would [37] 1/19
5/24 6/24 7/16 7/17
11/15 11/19 12/19
17/25 22/24 23/3 28/2
30/14 43/1 47/11
49/23 51/13 52/5
62/18 63/20 63/21
68/16 72/11 100/20
101/1 102/19 103/19
107/4 111/12 112/5
128/19 142/11 143/14
155/6 168/13 175/25
177/18
I wouldn't [5] 24/3
25/15 25/15 89/13
112/16
I'd [43] 7/16 12/2
12/13 13/14 16/15
16/15 26/2 33/12
46/22 51/13 51/20
52/3 54/11 58/4 58/8
58/13 69/19 73/14
79/23 86/20 89/11
95/20 107/5 115/12
119/14 120/5 121/22
131/17 132/2 139/15
141/2 144/7 145/3
146/24 147/2 150/19
154/12 156/11 158/2
170/11 175/1 175/20
177/16
Ill [13] 8/11 28/19
30/6 31/11 34/25
100/8 100/10 153/1
165/17 169/6 173/25
174/1 186/21
I'm [79] 5/17 6/11
6/16 6/24 8/17 14/14
26/1 27/6 27/13 27/25
28/13 30/20 31/15
36/20 37/15 37/16
40/9 41/9 41/16 42/22
49/22 52/3 53/24 57/4)
58/5 59/24 63/19
64/10 70/12 73/20
81/6 88/11 88/16
89/25 90/1 90/9 96/15)
98/6 100/15 100/17
101/9 104/8 104/8
104/22 105/23 106/18
106/20 111/7 117/7
117/20 118/10 118/14}
122/12 126/7 126/17
132/2 134/1 134/3
135/13 135/17 135/21
136/6 137/16 141/22
144/3 145/4 153/22
154/12 154/23 160/6
168/14 170/11 180/9
184/10 184/12 185/4
185/23 187/23 190/15}
I've [22] 8/4 17/23
36/25 39/11 46/13
55/23 55/24 56/2
74/12 90/24 133/2
144/4 151/10 151/11
151/16 159/24 161/9
171/11 178/14 178/15)
180/13 186/22
lan [1] 24/20
idea [1] 19/1
ideal [3] 102/7
102/20 109/16
identified [6] 78/23
128/24 146/15 150/3
168/3 185/16
identify [1] 156/20
ie [4] 83/3 132/22
149/8 159/17
ie a [1] 83/3
ie explaining [1]
159/17
ie investors [1]
132/22
if [210]
ignoring [1] 96/15
ii [1] 153/6
iti [1] 153/9
imagine [8] 22/25
23/3 28/2 43/1 47/12
62/19 63/20 63/21
immediately [2]
17/11 52/20
immunity [4] 83/11
83/17 85/8 98/21
impact [19] 12/18
12/22 13/6 13/9 13/12
13/13 13/17 13/18
31/4 93/15 107/24
107/24 108/1 108/18
110/22 113/1 123/9
133/18 140/7
impacted [4] 12/18
30/16 140/25 141/4
impacts [2] 46/14
141/16
implement [1] 45/20
implementation [1]
48/11
implicated [1] 170/23
implication [2] 107/2
162/16
implications [12]
84/22 86/18 105/25
107/17 108/23 109/1
111/18 135/5 142/20
150/13 159/16 161/1
importance [1]
171/20
important [15] 3/25
15/13 40/20 51/16
60/2 68/18 80/15
80/20 93/10 94/17
102/8 168/10 168/19
171/12 172/15
impression [5] 39/21
76/25 138/13 138/21
141/14
impressive [1] 32/6
imprisonment [3]
14/2 14/9 14/23
improved [2] 93/9
93/10
improvement [1]
116/15
inability [4] 52/16
inappropriate [9]
106/24 107/6 128/8
128/10 128/12 128/13)
134/20 141/16 152/9
incidents [1] 80/16
include [5] 4/13
12/17 62/2 133/4
149/1
included [6] 21/8
38/25 55/20 116/4
128/9 139/21
includes [1] 87/25
including [7] 12/5
61/24 116/5 158/22
159/22 188/6 188/18
(62) I have... - including
inclusion [1] 129/17
increase [4] 27/3
84/18 87/1 157/10
increased [1] 85/1
increasing [1] 26/20
incumbent [1] 14/24
indeed [1] 173/2
independent [4]
43/12 143/20 143/25
157/14
independently [1]
77/11
indicated [1] 48/21
individual [7] 38/13
42/11 63/14 63/22
TTI17 114/11 168/23
individual's [1]
107/24
individuals [4] 62/4
72/17 79/6 108/10
individuals’ [1]
117/23
inevitably [1] 132/21
influence [1] 119/14
inform [2] 68/11
120/14
informal [2] 121/14
163/6
informally [1] 39/23
information [37] 10/1
23/9 61/17 62/8 68/6
69/1 69/3 79/9 86/6
87/13 124/21 129/23
131/15 131/18 132/10}
136/18 137/7 139/9
140/20 142/13 146/18)
149/13 150/24 152/7
152/13 152/15 157/7
160/12 161/23 163/14}
164/9 164/13 172/18
173/4 173/21 182/6
187/5
informed [5] 53/15
55/7 82/16 140/10
159/21
infuriating [1] 96/7
initial [1] 69/16
input [15] 23/2 90/2
102/17 104/5 116/7
116/13 116/16 117/24}
147/1 161/8 161/9
161/22 175/22 181/16}
181/17
INQ00001128 [1]
33/2
INQ00001129 [1]
35/23
INQ00001131 [1] 2/3
inquiry [25] 1/7 1/24
22/3 24/11 24/16
31/11 33/1 35/22
40/22 45/13 46/23
46/25 55/5 56/6 62/7
64/5 96/25 136/8
137/12 138/25 140/11
171/14 171/19 171/24)
178/1
Inquiry's [3] 1/13
1/16 66/12
insensitivity [1]
137/4
inserted [2] 119/20
149/18
insight [3] 51/5 77/20
167/13
insofar [1] 148/17
installation [1] 52/24
instance [1] 188/7
instead [1] 152/12
insurance [2] 136/7
136/22
insurers [2] 136/18
137/7
integrate [1] 96/1
integrity [6] 45/1
55/1 112/3 140/19
142/21 154/9
intelligence [1] 30/19)
intensely [1] 133/20
interactions [1]
71/10
interest [9] 25/9
25/24 43/24 69/17
109/20 115/5 147/14
157/11 166/2
interesting [2] 84/23
88/3
interests [4] 42/14
44/6 113/9 122/5
interface [3] 3/24
11/24 12/11
interfacing [2] 15/17
78/11
interim [19] 53/10
68/23 74/18 75/21
76/16 76/20 76/21
77/7 77/18 92/23
93/15 93/16 93/17
94/10 99/6 126/22
127/13 127/18 131/23)
intermediary [1]
182/7
internal [13] 2/6 2/9
2/11 3/14 4/17 4/24
5/12 6/19 7/19 8/12
33/5 36/2 100/19
interpretation [2]
86/18 93/5
interpreted [1] 88/4
intervened [1]
125/25
into [41] 6/7 6/8 6/12
22/9 38/19 57/25
58/13 60/4 68/13 69/3
71/18 72/9 76/6 77/20
82/4 82/9 89/13 103/9
105/14 111/17 115/24)
121/14 121/24 123/8
126/22 128/17 133/8
138/11 138/25 139/3
139/7 147/4 148/6
149/13 150/7 152/7
158/11 161/24 165/13
167/25 172/23
introduced [1] 22/6
invented [1] 90/11
invested [1] 42/11
investigated [2]
59/21 83/12
investigating [1]
5/21
investigation [16]
8/20 16/12 61/21
69/21 72/25 75/12
85/12 86/2 98/11 99/1
100/24 101/10 105/3
118/2 128/17 174/10
investigations [3]
62/4 85/23 115/23
Investigators [1]
61/25
Investments [1]
66/20
investors [4] 123/6
132/22 133/22 133/24
involve [1] 70/10
involved [26] 11/10
17/13 18/16 39/7
51/22 52/1 53/22
60/17 67/20 97/23
101/1 102/22 103/10
103/13 103/16 104/14
104/17 117/12 118/12
118/15 136/15 141/12)
162/1 170/9 190/3
190/8
involved' [1] 86/4
involvement [11]
33/16 68/22 77/25
78/3 103/11 117/16
117/17 120/18 159/8
163/1 167/2
involves [1] 188/1
involving [3] 78/23
85/13 99/2
IPO [1] 133/3
irrespective [1] 83/4
is [427]
Ismay [1] 24/11
isn't [19] 53/21 55/24
82/24 86/22 91/25
95/18 98/23 102/4
106/15 112/10 115/2
122/4 129/13 150/1
155/2 155/5 172/3
179/22 185/8
issue [78] 3/1 10/2
10/2 14/16 14/17
14/20 17/21 19/18
19/19 20/8 20/15
29/10 29/16 29/17
30/2 30/15 30/17 31/8
39/19 44/8 45/2 49/4
50/4 58/9 58/11 59/3
69/8 82/1 82/24 83/4
84/6 92/4 93/19 98/23)
110/11 113/19 113/21
128/15 130/1 132/9
140/1 140/1 141/7
142/1 142/15 142/19
144/2 144/8 145/3
151/15 152/8 153/4
153/14 154/16 155/3
159/6 162/6 166/20
166/21 170/15 170/19)
171/20 171/20 171/24,
172/2 172/6 172/7
172/8 177/8 178/19
179/1 179/3 179/5
179/21 180/6 184/25
185/2 189/18
issued [1] 67/23
issues [78] 2/13 9/23
11/15 12/5 12/6 13/16}
19/23 20/16 21/9
26/20 27/4 27/7 27/8
28/14 28/15 28/17
28/18 29/22 30/16
31/6 31/6 32/16 32/19)
37/9 39/22 39/25 44/9
44/9 46/18 47/21
47/25 48/19 48/22
48/23 48/25 52/15
55/9 62/15 69/24
70/20 70/20 74/10
76/10 80/23 83/15
99/23 100/2 100/9
100/22 105/19 122/14,
122/16 124/1 124/13
127/25 135/11 137/5
142/22 143/9 143/18
145/13 149/23 150/2
150/3 150/4 150/17
151/18 151/24 154/10}
154/19 154/21 156/22)
156/24 158/14 159/13
161/19 166/24 188/17]
issuing [1] 111/19
it [573]
it's [147] 2/2 7/7 8/5
8/12 9/22 15/13 15/24)
16/22 16/25 17/23
17/25 17/25 18/1 18/7,
20/5 20/6 20/17 23/9
23/13 25/16 26/3
29/11 30/4 33/2 35/13
35/15 35/23 38/11
38/13 38/22 40/6
40/10 41/6 41/6 43/23)
44/5 46/1 46/3 47/3
49/16 49/18 50/18
50/22 51/16 53/11
55/22 56/4 56/6 57/10
57/11 57/13 57/13
60/21 62/25 65/22
65/25 65/25 70/14
75/11 78/5 81/15 83/4I
88/3 89/21 89/24
92/24 96/17 98/1 98/2
99/4 101/23 101/25
102/5 102/7 102/23
102/23 103/4 106/3
108/14 110/6 110/18
110/19 112/9 112/12
114/17 116/12 117/9
118/19 119/11 120/4
122/1 122/2 127/16
128/13 132/18 133/22)
134/5 134/7 134/24
134/24 137/13 137/17
143/14 143/24 144/15)
148/20 149/25 151/11
153/10 154/13 156/3
156/6 156/8 156/16
158/2 158/5 159/6
159/12 162/2 165/11
166/9 167/23 167/25
168/6 168/25 169/12
170/20 171/19 176/10)
178/12 178/15 180/4
180/4 180/8 180/19
180/19 182/4 183/11
183/12 184/3 184/24
186/21 187/13 187/18)
188/4 189/8 190/20
iterating [2] 90/1
117/19
iteration [3] 102/9
102/17 104/17
its [23] 13/24 17/19
21/8 21/11 34/8 45/11
50/2 50/3 63/3 119/14
126/24 127/3 129/14
130/15 133/19 156/1
161/1 170/3 171/12
171/15 171/16 180/11
180/12
itself [18] 14/25
15/18 19/13 19/16
20/3 33/10 38/10
75/21 78/11 109/3
118/13 118/14 127/6
139/16 147/25 148/3
149/16 190/5
iv [1] 47/13
qa
JA [1] 174/16
JA's [1] 143/9
Jacobs [1] 169/3
James [23] 69/20
70/17 73/10 74/22
75/18 76/14 78/2 81/5I
81/10 81/21 82/11
88/11 91/14 92/4
92/16 97/11 97/24
98/2 107/14 108/7
143/11 174/8 184/25
(63) inclusion - James
J
January [6] 21/17
31/13 70/14 70/23
135/24 149/22
Jenkins [31] 78/18
79/17 79/25 80/10
113/19 113/20 115/17)
116/9 140/1 140/5
140/7 140/10 140/15
141/5 141/7 142/15
142/21 144/8 155/25
179/16 182/13 182/20
183/5 183/12 183/14
184/7 184/18 185/2
185/21 185/25 186/1
Jenkins’ [4] 154/4
162/11 180/1 180/7
JFSA [5] 83/11 85/8
85/10 98/17 174/9
Jo [1] 163/12
job [5] 111/8 111/10
145/14 167/17 189/8
John [1] 53/5
join [5] 26/24 27/15
69/19 79/24 177/16
joined [8] 4/23 63/12
66/15 67/2 67/5 69/19
70/19 174/7
joining [2] 27/18
69/22
joint [3] 12/13 59/8
59/9
Jon [4] 125/25 126/1
126/14 130/25
Jon M [4] 125/25
Jonathan [4] 8/14
27/19 27/20 27/25
journalists [1]
132/23
judge [3] 50/18 189/1
189/9
judgement [2]
152/11 152/14
judgment [2] 86/11
87/12
judicial [5] 89/4
95/15 99/9 174/17
174/22
July [28] 1/1 52/8
52/22 53/5 53/13 81/5)
81/7 98/3 104/25
108/24 109/3 113/13
113/13 113/17 113/18}
114/4 115/23 116/4
117/7 126/22 136/20
136/23 137/2 140/13
163/22 183/24 184/22)
191/2
July 2013 [1] 126/22
jump [1] 154/24
June [5] 149/20
182/18 182/19 183/5
183/12
just [86] 3/22 7/12
8/3 8/5 13/17 13/23
15/16 16/5 19/1 20/12
23/16 24/6 28/17
31/21 33/12 36/25
51/25 52/3 53/14
54/11 57/2 59/6 61/6
63/1 74/12 78/14 81/6
82/14 83/3 84/4 86/5
88/20 90/20 96/15
98/7 99/10 100/8
100/12 100/18 102/23
104/1 106/20 109/10
112/15 113/8 117/7
118/4 118/7 118/21
120/5 122/1 123/21
124/11 125/12 125/20
126/15 130/11 130/15
130/17 134/9 138/24
142/8 144/5 146/2
150/15 151/10 152/20
158/10 159/20 160/13
161/12 165/3 165/11
166/11 172/23 173/13
173/14 177/2 17719
177/16 178/13 178/14)
179/19 186/14 187/6
188/11
justice [6] 85/17 89/2
95/13 96/6 99/13
4174/5
justify [1] 184/11
K
Karen [2] 52/7 52/15
keen [1] 119/14
keep [8] 121/6 121/7
125/7 131/8 143/12
153/12 160/16 166/18)
keeping [2] 118/7
1341/7
Keith [1] 24/24
kept [3] 11/20 12/15
53/15
key [17] 11/21 12/15
29/21 41/1 45/8 71/22
79/2 83/14 90/25
91/13 99/22 103/18
127/18 134/18 148/25)
152/15 154/16
kids [1] 165/19
kind [18] 70/19 80/7
83/2 89/24 106/3
115/14 117/13 123/7
128/11 138/14 140/20)
152/14 160/20 164/20)
166/12 167/16 167/25)
182/24
kinds [3] 94/21 98/20
115/3
King [9] 66/2 66/9
138/12 149/7 153/3
155/11 156/19 157/41
173/19
King's [2] 147/16
149/17
kit [1] 52/24
knew [22] 7/8 7/11
8/4 15/20 18/12 29/10
30/25 40/13 45/18
60/23 110/25 140/13
171/24 172/10 175/6
177/20 180/7 182/12
182/13 182/15 183/17]
184/17
know [57] 3/3 4/3 6/5
9/13 10/19 15/14 16/6
20/7 20/9 20/13 24/3
24/23 25/15 28/1 31/7
36/17 38/21 39/13
40/4 40/11 43/21
49/13 51/7 54/12
55/22 60/8 61/21
62/19 62/21 63/21
67/5 79/25 98/16
99/20 100/7 101/4
102/10 106/23 108/4
109/10 112/22 113/14
118/22 120/22 133/1
139/3 149/14 152/2
152/3 154/9 160/6
163/24 171/19 182/1
183/12 183/13 183/19]
knowing [2] 30/25
40/5
knowledge [9] 18/25
65/15 71/3 77/17
155/25 161/15 161/16
161/19 188/16
known [14] 14/4 14/8
30/22 39/14 63/16
66/25 79/13 142/9
145/12 146/23 153/23
154/13 162/9 179/25
L
lack [1] 45/1
lady [4] 125/14
language [10] 88/21
92/7 96/1 97/4 124/2
124/12 124/15 124/17!
125/19 128/20
large [1] 48/9
largely [7] 7/13 7/14
TIN1T 8/4 9/24 22/24
62/15
larger [1] 169/5
last [10] 2/1 9/19
40/17 52/18 58/18
102/6 102/21 122/12
125/25 126/5
last-minute [1] 102/6
lasted [1] 109/12
late [11] 52/18 89/23
90/18 97/15 97/16
101/25 103/1 126/14
151/25 152/11 152/14]
late-night [1] 151/25
lateness [1] 137/15
later [8] 17/5 53/9
60/8 114/4 137/21
162/1 163/22 173/10
latest [3] 123/20
124/12 132/16
Laundering [1] 21/18
law [4] 54/20 108/25
143/16 155/20
lawful [1] 15/1
lawyer [2] 101/23
122/11
lawyers [14] 36/9
36/13 36/16 37/3
37/16 85/13 99/2
107/16 108/22 113/16
115/20 116/6 173/20
182/15
lay [2] 8/21 32/10
layman's [1] 59/10
lead [3] 14/1 14/22
99/24
leading [2] 114/14
117/20
leads [2] 69/2 116/16
learned [2] 167/22
167/24
learnt [2] 168/3 189/6
least [3] 134/11
134/14 172/9
leave [7] 50/7 121/5
152/20 160/6 160/24
161/1 165/7
leaving [9] 14/21
29/2 92/8 92/10 92/12
93/2 139/2 177/16
177/20
led [3] 66/6 137/9
172/17
Lee [1] 78/23
left [4] 142/6 142/7
147/9 157/21
left-hand [1] 157/21
legal [84] 5/25 6/7
6/9 6/9 6/15 6/25 7/1
7/4 8/16 8/21 10/8
12/2 12/8 12/25 13/3
21/9 23/2 23/6 25/3
27/18 27/20 27/23
27/23 28/1 28/5 28/11
28/18 28/22 32/15
32/23 33/13 33/16
33/17 33/25 34/6
34/15 34/16 34/21
35/19 35/21 36/7 36/7,
36/9 37/21 37/22
37/22 37/24 38/5
38/16 38/25 39/1 39/6
39/16 40/8 41/3 55/16)
55/18 55/23 56/18
76/2 81/2 82/18 83/21
85/12 90/2 92/18 99/2,
104/12 107/15 108/21
116/14 120/7 122/10
122/13 138/4 138/23
139/12 141/9 143/13
168/13 176/2 177/7
177/19 182/8
legal/factual [1]
122/13
Leighton [19] 1/5 1/7
1/9 1/16 1/19 1/21
1/23 39/15 39/20
40/16 41/18 51/25
53/15 58/20 61/5
61/17 63/25 64/4
192/2
Leighton's [2] 1/12
41/14
length [1] 183/1
Lepton [1] 142/19
Lesley [8] 75/7 77/23
78/18 79/5 79/15 80/2
183/7 184/20
LESLIE [2] 1/21
192/2
less [1] 76/10
lesson [3] 168/10
168/12 168/19
lessons [4] 167/20
167/22 167/24 168/3
let [10] 16/6 18/15
64/4 109/10 120/22
130/8 133/1 139/3
149/14 181/41
let's [8] 8/14 59/25
73/20 92/21 110/3
121/9 185/7 185/13
letter [15] 49/9 49/23
50/20 51/6 51/13
51/16 51/19 51/21
114/6 114/13 115/10
115/13 153/11 156/7
157/2
letters [4] 49/12 51/7
51/9 67/24
level [24] 5/20 6/21
8/10 8/23 11/15 18/8
18/19 28/5 28/6 28/21
31/3 42/14 46/9 48/4
57/17 57/24 60/16
63/8 63/10 106/17
140/22 149/11 168/22!
183/24
levers [1] 75/16
liable [1] 50/8
liaise [1] 142/12
liaising [2] 70/10
115/19
liaison [1] 163/4
lies [2] 4/1 40/21
life [1] 67/11
lifted [1] 127/8
light [4] 27/14 146/18
148/20 157/6
like [25] 33/12 49/1
51/6 54/6 56/8 65/17
76/5 86/13 93/24
(64) January - like
L
111/14 111/16 120/5
125/1 125/15 127/22
149/15 149/15 150/6
likelihood [5] 25/9
25/19 25/22 49/23
75/18
likely [6] 24/2 63/4
77/18 138/10 158/16
167/6
likes [2] 75/7 142/12
limit [3] 48/9 142/23
159/7
limited [41] 2/13 9/12
10/14 11/13 11/23
12/15 15/24 19/16
20/18 21/23 23/5
23/14 24/9 25/1 25/7
26/7 26/12 26/19
45/16 48/18 49/7 56/8
79/6 111/11 152/15
Limited's [2] 10/5
44/17
limiting [3] 117/17
117/24 167/1
line [40] 2/12 2/23
2/24 3/14 4/17 4/24
5/5 5/13 6/3 6/19 7/20)
8/13 8/15 10/9 33/5
36/4 36/4 38/19 62/20
82/5 84/16 85/25
86/25 88/12 88/14
89/1 91/17 91/24 92/1
95/12 99/17 103/10
121/14 121/24 122/3
128/15 129/17 129/18}
184/4 184/6
line 11 [1] 2/23
line 16 [1] 6/19
line 21 [1] 36/4
line 22 [1] 2/12
line 25 [1] 8/13
line 3 [4] 4/24
line 6 [1] 5/13
line 7 [2] 3/14 5/5
line 9 [1] 33/5
lines [12] 86/1 86/15
89/9 89/11 91/14
94/22 97/17 98/20
109/13 110/1 115/21
133/1
link [2] 95/9 186/9
linked [2] 144/7
158/25
links [1] 168/12
like... [16] 95/20
128/11 128/23 143/14)
156/11 166/11 169/14}
28/23 29/6 31/11 I agi24 49/21 51/2 64/6
32/13 32/15 34/20
ae le aae seg, I 100/24 100/24 100/25
4110/1 122/21 124/5
38/20 39/8 42/19 43/5] 11011 12212
45/3 45/10 45/15
list [8] 2/14 16/19
22/24 25/4 61/5 73/16
144/21 166/18
listed [1] 16/4
lists [1] 163/25
litigated [1] 60/14
litigation [13] 11/17
11/21 11/22 12/5 12/5)
12/15 12/17 12/20
12/24 13/4 13/5 32/21
60/1
little [3] 119/22
142/18 147/21
little’ [1] 153/19
live [1] 153/13
lives [1] 107/25
local [1] 53/7
lodged [2] 83/17
126/18
log [1] 160/7
long [21] 16/14 17/23
24/25 30/18 39/12
40/6 40/6 47/11 48/1
long-term [2] 122/21
124/15
longer [2] 41/18
156/2
look [54] 2/11 7/19
8/9 10/5 11/6 13/15
15/22 16/17 19/14
20/17 23/13 24/4
26/11 31/9 35/13
35/22 42/9 42/18
44/14 47/3 49/8 50/22
51/15 54/18 56/11
65/7 81/13 94/3 97/18)
97/19 107/8 109/4
109/20 109/21 110/3
113/23 114/17 118/18)
119/10 120/18 131/5
132/12 150/22 152/23)
153/25 155/9 155/15
156/16 160/2 160/7
163/9 163/15 165/1
165/2
looked [2] 136/23
173/3
looking [13] 13/23
17/18 29/1 34/13
34/14 73/16 74/23
109/5 135/3 135/10
145/23 157/18 158/7
looks [7] 28/8 49/16
54/6 57/14 125/1
125/15 158/16
loop [4] 131/7 138/25
139/3 139/7
loose [1] 92/7
loses [2] 56/14 57/7
losing [4] 109/15
110/7 110/12 110/19
loss [4] 53/1 59/12
60/2 60/13
losses [4] 56/14 57/7
57/12 60/11
lost [2] 78/25 157/25
lot [15] 3/22 30/18
77/2 97/10 103/16
104/9 112/19 122/19
131/14 155/2 167/14
lots [8] 51/2 51/7
71/10 71/18 121/15
122/24 150/6 167/20
low [3] 57/14 57/17
57/19
loyalties [1] 178/2
loyalty [1] 178/4
luck [1] 131/12
Luke [3] 26/23 28/10
28/14
lunch [5] 64/15
113/24 116/20 131/22
132/3
Lyons [4] 24/15 75/7
77/23 79/7
made [29] 5/1 27/17
33/11 36/14 40/24
43/3 43/7 44/5 44/5
47/17 53/10 53/14
55/3 55/6 55/14 56/18}
59/1 84/11 84/18 87/2
95/17 106/3 110/10
119/24 134/23 137/20
153/8 173/9 188/19
magic [1] 81/18
Mail [101] 3/6 4/2
4/21 5/2 5/7 6/14 9/1
9/3 9/5 9/5 9/15 9/25
10/15 11/9 11/11 12/1
12/4 12/9 12/9 12/10
13/24 19/10 19/23
23/12 26/23 27/15
28/21 31/10 31/13
34/5 34/16 36/9 37/3
37/17 37/20 37/22
38/1 38/8 38/10 38/10
38/12 38/16 38/22
38/24 39/5 39/6 39/10)
39/16 40/5 40/8 41/3
42/17 42/25 44/7
44/11 45/3 45/15 49/6
53/22 54/20 56/18
56/24 57/16 59/15
59/16 113/11 118/13
118/22 119/9 119/11
119/13 120/23 122/9
122/18 122/22 123/1
124/6 124/18 124/22
126/3 127/11 127/17
128/11 128/21 129/1
129/4 129/24 129/25
46/8 46/13 46/13 54/4
1341/1 132/17 132/25
133/5 133/6 134/2
134/13 134/20 134/21
135/6 135/10 136/3
157/8
Mail's [1] 120/14
main [8] 45/7 95/6
144/16 163/4 187/21
maintained [1] 60/11
maintaining [1]
52/10
major [12] 13/22
48/21 49/2 67/20
92/16 128/2 128/3
166/20 166/21 175/21
180/23 182/3
make [20] 2/25 3/19
3/25 40/20 47/20
51/23 65/17 68/15
77/1 91/7 91/12 93/13}
115/24 125/5 125/15
152/2 154/13 161/5
166/12 179/10
makes [2] 93/19
129/13
making [11] 69/9
69/12 90/7 100/15
104/1 123/15 134/12
163/13 179/19 188/19}
190/13
manage [3] 29/23
37/17 159/4
managed [3] 12/12
125/15 132/19
management [14]
2/6 3/4 3/8 3/17 3/20
4/4 15/14 15/16 15/19)
29/23 44/17 50/2 67/1
93/20
Manager [2] 146/23
161/13
managing [3] 93/1
93/2 93/4
mandate [1] 174/23
manner [1] 148/19
many [10] 7/25 19/7
19/20 20/7 20/7 94/17}
94/24 96/1 97/22
125/16
March [7] 26/19
26/23 28/10 28/14
31/15 54/23 72/22
mark [29] 52/21 67/8
70/23 74/8 75/8 80/13)
80/19 81/14 88/19
88/20 88/22 88/24
88/25 90/21 91/1
96/10 97/22 103/23
104/5 104/7 104/10
104/11 109/22 111/2
119/8 119/19 119/24
132/13 132/15
Mark's [1] 111/10
107/11 107/23 123/22}
market [2] 22/9 113/2!
marketing [1] 133/3
marks [1] 146/10
Marsh [1] 16/4
MARTIN [13] 64/25
65/3 74/21 84/14
120/20 125/11 125/14)
137/23 153/1 163/23
173/12 176/25 192/10}
massive [3] 46/16
54/3 58/13
massively [2] 80/15
80/19
Master [1] 124/4
material [16] 137/23
138/16 138/19 141/10}
155/2 155/5 155/21
155/22 171/20 172/18)
173/11 173/22 176/14)
176/20 176/22 176/23}
materials [2] 72/6
133/3
matter [40] 11/8
43/13 53/11 68/3
68/18 69/7 69/12
69/25 73/22 77/25
78/4 78/6 78/8 85/11
87/14 87/15 87/16
89/7 89/12 89/15
89/20 90/3 96/22
98/25 101/22 101/24
103/5 103/22 104/11
104/20 116/5 146/16
155/20 157/4 170/9
1714/7 171/10 175/17
175/22 179/12
matters [15] 7/7 7/11
7/14 7/21 29/18 69/17
71/7 7119 74/14 78/9
103/12 128/24 163/5
190/3 190/8
may [27] 13/6 25/10
25/20 31/14 38/4 38/7I
43/3 59/6 62/20 86/4
92/20 94/7 106/23
110/14 116/19 132/24I
133/7 135/4 135/19
139/18 153/13 154/12)
159/4 160/6 166/25
167/3 172/11
maybe [7] 106/4
112/18 112/18 130/18)
130/20 155/5 175/20
McInnes [3] 120/19
121/11 125/9
MD [2] 23/10 42/15
MDA [5] 124/2 124/3
124/4 124/15 124/17
me [69] 1/3 16/6
17/24 18/15 39/24
41/6 45/13 46/2 50/7
51/7 53/24 55/10
57/15 59/3 59/14 64/4
64/22 66/6 68/16
(65) like... - me
me... [50] 69/22 73/1
79/1 79/24 81/19 86/7,
94/2 94/5 110/8
111/21 117/3 118/23
119/25 120/22 121/17)
128/23 130/8 133/1
139/3 139/7 139/8
139/20 141/19 142/3
142/4 142/19 144/21
146/6 149/14 149/15
150/6 150/12 151/1
151/7 160/9 162/17
162/18 162/22 163/25)
165/12 167/13 167/20
168/11 171/5 178/6
180/19 181/1 184/23
186/19 190/15
mean [49] 7/16 9/22
11/22 13/10 13/11
17/20 18/21 22/18
25/15 27/7 28/12 37/1
38/7 39/10 41/17
45/25 46/15 47/9
50/18 58/10 58/22
67/7 76/10 80/5 88/4
89/22 92/14 100/22
102/5 102/24 103/7
104/8 105/10 105/22
106/10 108/1 111/10
114/22 127/16 128/19}
133/17 138/24 147/24)
148/8 155/6 166/19
167/19 167/23 179/9
means [4] 16/21 30/3
41/24 159/18
meant [7] 13/24
60/19 93/6 105/23
106/10 107/5 124/1
measures [2] 21/18
22/8
media [8] 76/4 76/9
76/10 91/14 91/18
91/21 112/23 113/1
mediation [1] 158/22
mediation/Working
[1] 158/22
meeting [55] 3/5
15/24 16/13 16/22
17/4 17/4 20/17 21/16}
23/14 23/24 26/12
42/18 46/3 47/4 49/6
69/20 69/23 70/16
73/3 73/9 73/12 73/18
73/25 74/23 75/1 75/3
75/7 75/9 75/11 75/15)
75/19 75/24 78/6
79/23 81/5 81/20
88/10 89/24 97/11
97/23 98/2 113/16
113/17 113/18 143/16}
145/11 158/23 160/19)
165/6 174/8 174/10
174/11 174/14 174/16)
186/16
meeting/report [1]
75/19
meetings [8] 10/12
67/23 71/23 71/24
71/24 72/15 72/16
82/12
meets [1] 149/8
member [3] 10/21
28/21 149/21
members [11] 14/23
14/24 17/22 18/17
23/9 24/7 42/16 44/7
73/9 74/4 159/2
memory [2] 112/22
142/7
mention [6] 151/12
170/15 170/17 171/2
178/16 180/5
mentioned [12]
18/24 53/6 78/13
78/14 80/17 93/14
113/15 117/6 158/5
176/22 183/25 189/2
mere [1] 176/13
merely [1] 177/9
message [3] 86/22
86/22 104/19
messages [3] 68/19
72/1 86/20
messaging [4] 71/16
71/23 72/2 103/18
met [1] 166/15
Michael [10] 22/3
22/11 24/7 24/17
31/12 31/25 34/17
34/19 34/23 42/23
Michael's [2] 32/4
33/1
micromanaging [1]
131/14
mid [1] 189/22
mid-2014 [1] 189/22
middle [2] 67/1 100/4
midnight [2] 96/13
96/17
Midway [1] 10/10
might [27] 33/20
37/10 37/12 73/4 77/1
92/9 92/11 100/14
101/6 108/1 110/14
116/1 120/25 124/11
132/11 140/25 141/7
146/17 147/15 147/21
148/5 149/8 157/6
158/19 166/5 179/20
187/19
Mike [4] 120/10
Miller [2] 16/5 17/14
Millidge [5] 126/1
126/9 126/13 130/14
130/19
Millidge's [1] 130/4
million [5] 56/22
57/20 57/22 94/13
94/13
millions [2] 46/17
50/8
Mills [2] 40/22 41/1
mind [10] 1/18 7/21
14/15 25/13 26/6
112/25 113/12 159/1
185/24 185/25
minds [1] 14/13
mindset [8] 108/15
111/23 111/24 112/1
112/2 112/4 112/6
189/5
minimum [1] 153/13
Minister [1] 43/3
ministers [1] 166/25
minor [1] 1/10
minute [4] 64/14
102/6 102/21 169/16
minutes [18] 17/4
20/20 20/22 23/21
23/22 24/1 24/2 24/5
26/18 29/2 29/4 45/13)
46/12 121/4 151/5
169/9 169/11 169/12
minutes' [2] 61/12
61/14
mis [1] 22/10
mis-selling [1] 22/10
miscarriage [3]
85/17 95/12 99/13
miscarriages [2]
89/1 96/6
misinterpreted [1]
100/9
misjudged [1] 131/9
misleading [5] 76/15
76/20 76/20 77/7
127/11
misplaced [1] 178/3
Misra [9] 78/19
182/14 183/8 183/13
183/25 184/19 185/3
186/1 186/8
Misra's [1] 182/15
misrepresentation
[2] 110/8 110/9
misrepresented [1]
111/16
missed [1] 94/4
missing [2] 31/3 31/4
mistake [2] 19/25
20/1
misuse [1] 132/24
mitigation [1] 119/4
mix [1] 37/21
moderates [1]
181/19
Moloney [5] 169/4
169/23 189/12 189/14
192/18
moment [5] 61/19
116/19 121/5 142/16
160/20
Monday [5] 126/19
131/4 190/18 190/21
191/2
money [14] 21/18
45/22 60/10 61/25
63/19 82/25 85/14
85/15 94/20 98/24
109/15 110/7 110/12
110/19
monies [1] 62/2
month [1] 53/9
months [4] 49/22
69/16 143/2 186/10
monumental [1]
134/7
more [59] 30/9 30/25
34/14 45/19 46/21
49/16 51/21 56/2
60/19 63/8 64/9 64/15)
71/2 71/20 71/24 72/5)
72/9 TAIT 74/8 75/9
76/17 77/16 79/1
79/16 80/25 87/6
92/20 94/3 94/13 95/7
106/2 110/14 119/22
120/1 125/15 128/25
133/4 137/24 142/25
147/21 148/5 149/14
150/7 150/11 150/24
151/20 152/5 154/25
157/23 164/18 167/15)
167/19 168/14 173/12)
1477/1 177/1 17716
177/13 187/5
morning [16] 1/3
40/18 41/12 59/23
64/22 72/24 73/1
97/20 114/7 151/6
152/25 160/6 165/18
184/5 184/14 187/25
most [8] 3/24 38/14
40/19 45/25 48/25
120/23 133/18 138/9
motivating [1]
134/15
move [9] 3/8 16/9
41/12 68/8 70/25
104/22 118/10 140/6
145/3
moved [4] 70/1 75/11
164/18 165/24
movement [1]
117/16
moves [1] 159/7
moving [4] 69/5
69/15 72/21 164/25
MP [3] 51/22 72/25
85/9
MPs [1] 73/5
Mr [122] 1/7 1/9 1/12
1/16 1/19 1/22 1/23
33/5 35/11 35/25
35/25 37/24 38/4
39/12 39/15 39/17
39/20 40/16 41/14
41/18 43/4 50/24
51/25 52/8 58/20
59/23 60/8 60/23 61/1
61/5 61/12 61/13
61/15 61/16 61/17
63/25 64/2 64/4 64/24
65/1 65/4 72/23 79/7
90/15 95/3 115/16
116/9 117/6 118/19
119/6 119/16 119/23
120/3 125/9 125/9
126/9 126/13 130/4
130/14 130/19 134/10}
139/23 140/6 140/10
140/13 140/16 141/5
142/17 146/3 146/20
147/5 147/19 148/15
148/21 149/5 153/20
154/17 155/11 162/3
163/10 163/16 163/21
164/2 164/24 165/16
169/2 169/3 169/4
169/5 169/11 169/22
169/23 170/1 170/2
170/21 172/2 174/21
177/3 179/17 183/2
183/4 184/2 184/13
184/15 186/11 186/15}
187/3 187/16 187/25
189/12 189/14 189/15)
189/24 190/10 190/11
190/13 190/18 192/4
192/8 192/12 192/14
192/18
Mr Altman [3] 140/6
142/17 148/21
Mr Altman's [4]
139/23 146/3 146/20
148/15
Mr Bates [1] 50/24
Mr Batten [2] 163/10
163/21
Mr Beer [1] 35/25
Mr Blake [9] 33/5
170/21 179/17 183/2
183/4 184/2 187/25
190/11 190/18
Mr Callard [2] 164/24)
165/16
Mr Castleton [2] 60/8}
60/23
Mr Clarke [2] 140/13
140/16
Mr Clarke's [1]
115/16
Mr Colin [4] 43/4
Mr Crozier [5] 35/11
35/25 37/24 38/4
39/17
Mr Crozier's [1]
39/12
(66) me... - Mr Crozier’s
Mr Davies [7] 72/23
79/7 90/15 95/3
Mr Davies’ [1] 120/3
Mr Edwards [14]
64/24 65/4 117/6
134/10 170/2 172/2
174/21 177/3 187/3
190/10 190/13
Mr Gibson [3] 119/6
125/9 163/16
Mr Henry [10] 169/2
169/5 169/11 169/22
170/1 184/13 184/15
186/11 186/15 192/14}
Mr Hughes [1] 52/8
Mr Jacobs [1] 169/3
Mr Jenkins [3] 116/9
140/10 141/5
Mr Leighton [15] 1/7
1/9 1/16 1/19 1/23
39/15 39/20 40/16
41/18 51/25 58/20
61/5 61/17 63/25 64/4
Mr Leighton's [2]
1/12 41/14
Mr Mcinnes [1] 125/9)
Mr Millidge [4] 126/9
126/13 130/14 130/19}
Mr Millidge's [4]
130/4
Mr Moloney [3] 169/4I
169/23 189/12
Mr Parsons [1] 162/3
Mr Stein [5] 61/12
61/13 61/15 61/16
192/8
MR STEVENS [5]
1/22 59/23 61/1 64/2
192/4
Mr Whitehead [1]
164/2
Mr Williams [4]
147/5 147/19 153/20
154/17
Mr Williams' [1]
149/5
Mr Williams's [1]
155/11
Mrs [3] 182/15
183/25 190/7
Mrs Misra [1] 183/25
Mrs Misra's [1]
182/15
Mrs Vennells [1]
190/7
Ms [23] 74/19 97/5
126/12 127/9 128/14
130/10 130/24 134/11
138/20 161/4 165/1
169/4 169/23 170/23
118/19 119/16 119/23}
187/16 189/15 189/24}
173/3 175/2 187/4
187/4 187/6 187/13
Ms Perkins [2] 187/4
187/16
Ms Vennells [14]
74/19 97/5 126/12
127/9 128/14 130/10
130/24 134/11 161/4
165/1 170/23 173/3
175/2 187/4
Ms Watt [4] 169/4
169/23 187/13 189/11
much [21] 41/18
64/23 66/11 89/24
105/24 116/24 117/5
131/7 131/11 132/18
135/7 135/10 141/20
150/7 150/23 151/4
155/3 162/1 178/3
186/25 190/10
multiple [1] 46/16
Munt [1] 73/16
must [11] 44/23 63/8
63/10 63/15 93/9
94/15 106/10 143/11
176/15 184/9 184/19
mutual [1] 164/9
my [78] 6/6 9/8 11/8
12/24 18/17 19/11
24/6 28/3 28/19 30/14
32/13 36/22 37/18
37/23 44/11 45/7
49/16 49/19 50/12
50/12 55/1 60/12 66/3
67/11 68/5 68/10
68/20 68/22 68/24
68/25 70/12 75/15
76/11 78/22 88/6
95/20 102/11 102/15
105/10 111/12 113/12)
121/12 121/13 121/19)
121/23 126/15 131/8
134/4 137/18 138/3
138/13 138/18 138/21
138/21 138/21 142/11
145/14 147/7 151/24
164/5 167/14 168/13
170/20 171/4 171/5
171/11 172/6 172/15
172/25 173/7 173/17
173/17 173/23 177/4
179/10 180/8 183/7
189/2
myself [3] 46/20
80/24 168/8
No
naive [2] 180/20
180/25
name [13] 20/14 65/2
114/8 114/9 114/10
114/10 114/10 142/4
142/9 142/11 152/7
187/15 189/11 192/16)
152/9 154/4
namely [4] 39/7
57/10 60/22 153/4
names [3] 78/13
78/14 142/10
narrative [1] 111/8
narrow [1] 28/19
narrower [1] 122/13
National [1] 20/14
nature [4] 45/18
128/22 173/2 180/22
naif [1] 180/16
nb [2] 119/25 166/15
near [1] 183/3
nearly [1] 143/2
necessarily [8] 24/25
51/12 54/9 59/15
62/13 134/19 141/16
169/10
necessary [7] 12/4
31/1 48/8 62/22 82/13
121/8 129/10
need [57] 2/18 7/17
8/10 16/7 22/4 22/7
31/23 39/9 43/12 44/1
48/15 49/11 52/23
71/2 75/17 75/25 79/1
82/5 86/12 89/1 92/6
92/9 92/11 93/8 93/10)
95/6 95/12 96/5 97/1
101/5 105/19 122/1
131/4 138/10 143/9
149/1 149/2 150/24
151/14 158/13 164/6
164/13 165/13 165/17I
165/20 166/25 168/17
173/5 174/1 174/13
178/18 178/25 179/4
179/8 179/9 184/15
184/23
needed [9] 45/21
79/9 142/13 150/7
163/7 177/6 179/11
184/6 187/5
needs [14] 30/3
62/18 76/16 91/6
91/24 92/3 93/13
94/19 96/7 103/25
123/5 147/20 168/15
168/17
negative [3] 13/7
107/2 132/21
negligence [1]
175/15
negligent [1] 175/16
negotiation [1] 46/9
negotiations [1]
71/12
neither [3] 84/23
88/3 88/4
network [13] 42/12
48/6 70/9 71/14
116/14 122/19 123/8
126/25 187/24 188/1
188/8 188/8 188/23
neutral [2] 76/17
87/7
never [14] 10/3 19/2
19/12 19/18 19/19
20/15 39/18 39/18
39/25 49/23 55/7
55/10 89/4 95/15
nevertheless [2]
155/19 176/13
new [10] 46/15 52/24
71/12 92/5 106/4
144/14 152/4 161/21
164/24 166/1
newly [1] 21/5
news [6] 106/4 109/8
109/10 109/11 125/22}
152/4
next [19] 16/10 21/16.
53/3 101/11 107/18
109/16 114/24 115/22}
116/1 116/7 130/15
152/25 165/3 165/6
167/17 186/14 187/2
187/12 190/17
NFSP [4] 43/4 119/2
122/20 187/17
night [18] 89/23
90/17 90/18 91/1 95/5)
96/19 97/14 97/15
97/16 101/25 103/2
125/25 126/5 126/12
151/25 152/11 152/14}
166/18
Nina [1] 110/41
no [116] 1/15 1/20
9/22 9/25 17/20 17/23}
18/12 18/21 19/1 19/5)
19/14 21/24 22/13
24/19 24/22 26/9 27/1
27/19 28/7 28/12
28/19 29/7 29/13
29/20 31/3 31/23
34/11 34/24 36/6 36/7,
36/12 36/24 43/20
46/12 47/19 49/2 52/3)
53/19 53/23 54/9
54/17 54/22 56/10
60/11 67/6 67/11
67/11 70/18 77/20
78/3 78/5 80/11 84/19)
87/2 88/1 91/7 91/16
93/11 94/9 95/7 95/9
100/1 101/18 107/4
110/21 111/10 113/22)
115/8 115/8 115/18
116/10 126/25 128/2
129/2 130/25 136/16
137/8 137/20 138/21
139/15 139/16 140/22,
140/22 142/3 144/15
146/4 150/15 152/20
156/2 157/9 159/17
160/24 162/13 162/16
162/16 168/8 170/14
171/23 172/4 173/5
173/9 174/1 175/12
176/24 178/5 179/23
180/8 180/19 182/17
183/16 183/19 184/23)
187/9 189/25 190/2
190/8
nobody [2] 176/7
187/5
nodded [2] 20/23
108/11
nodding [1] 27/5
Nolan [2] 43/13
43/25
non [20] 2/20 2/20
3/16 3/16 4/9 10/25
11/9 11/12 18/7 18/17)
31/12 40/19 43/5
43/11 85/9 97/3
158/16 163/5 164/24
183/15
non-communicationsI
[1] 163/5
non-disclosure [1]
183/15
non-emotive [1] 97/3
non-execs [2] 2/20
2/20
Non-Executive [8]
3/16 3/16 10/25 11/9
18/17 31/12 158/16
164/24
non-executives [1]
18/7
non-MP [1] 85/9
none [10] 10/23 11/1
41/4 93/13 115/7
125/1 140/16 141/1
142/22 180/9
nonsense [1] 119/12
nor [2] 69/8 170/17
North [1] 109/21
not [229]
note [15] 43/16 58/23
91/6 97/23 99/22
101/19 116/3 136/10
147/8 153/3 153/15
155/10 174/10 182/8
186/15
noted [8] 17/7 21/6
23/20 24/1 26/18 47/8I
47/9 68/25
notes [13] 94/4 97/25
98/4 148/4 151/14
174/14 174/14 174/15)
178/18 178/25 179/3
179/4 179/8
nothing [8] 14/17
60/23 80/1 82/18 99/6
109/17 109/19 171/6
notice [4] 33/8 52/24
127/8 164/15
notification [1] 136/8
(67) Mr Davies - notification
N
noting [3] 25/9 25/19
27/3
now [65] 34/13 39/25
41/23 48/10 59/14
59/24 64/15 66/8
69/15 72/21 72/21
73/21 81/18 84/8 85/6
86/11 87/11 91/1 95/2
95/4 95/24 96/9 96/11
96/16 96/17 101/15
101/25 104/25 108/4
110/14 125/20 126/7
131/13 143/1 144/8
145/4 145/20 146/16
146/23 151/18 156/19
156/23 156/23 157/4
158/16 160/13 161/12
164/25 165/15 166/16
166/22 166/23 168/1
168/14 168/25 169/17)
170/15 175/8 177/20
178/1 178/9 181/4
186/20 188/24 189/12)
nowadays [1] 33/21
nuanced [2] 147/21
157/23
number [33] 1/11
16/22 16/23 19/10
19/12 27/10 32/5 38/9
44/1 47/13 47/21
63/15 64/8 79/6 79/8
94/22 94/25 116/8
116/16 117/19 140/25
141/11 141/13 157/7
157/10 168/5 169/3
169/5 170/25 180/20
182/3 188/7 188/8
numbers [7] 18/13
18/24 19/1 19/3 19/15)
111/11 163/14
numerous [3] 67/21
165/17 166/11
[e)
obdurate [1] 181/24
objected [1] 126/20
objectives [4] 11/11
12/19 12/22 13/10
objects [1] 100/11
obligation [1] 29/13
obligations [4]
137/18 173/7 173/17
178/4
obtain [1] 143/9
obtained [1] 59/8
obvious [4] 5/18
30/22 139/6 172/13
obviously [24] 3/21
5/18 7/25 9/22 12/1
17/23 18/13 29/20
30/12 30/13 40/2
49/18 51/4 73/16
100/20 105/17 105/20;
123/13 129/20 135/19)
136/25 144/19 154/13)
171/15
occasion [2] 1/8
169/7
occasions [2] 62/8
111/11
occurred [2] 18/19
126/7
October [14] 16/18
78/20 139/23 140/14
144/4 156/17 158/6
174/6 174/15 175/10
182/11 183/9 186/4
187/3
odd [2] 25/25 130/11
off [11] 44/9 81/1
83/3 102/21 103/21
120/25 143/19 163/25)
164/3 165/7 188/19
offences [3] 4/20
8/20 9/2
offer [1] 56/18
offered [2] 129/10
170/22
OFFERING [1] 91/21
office [151] 2/13 9/12
10/5 10/12 10/14
10/21 10/25 11/13
11/18 11/20 11/23
12/15 13/21 13/24
15/22 15/24 17/19
19/7 19/16 20/18
21/23 22/19 23/4
23/10 23/11 23/14
24/8 25/1 25/7 26/7
26/12 26/18 28/6
28/22 29/4 29/6 29/8
29/13 30/24 31/11
31/14 32/13 32/15
33/25 34/9 34/20
35/18 35/19 36/7
36/16 37/4 37/4 37/8
37/12 37/20 37/21
38/5 38/9 38/18 38/19
39/8 42/12 42/19 43/5)
44/10 44/17 45/3 45/9
45/15 45/16 48/17
48/20 49/6 50/5 50/9
50/13 53/18 53/20
54/1 54/8 56/8 56/13
56/14 56/16 57/3 57/6
57/7 57/9 59/13 59/16)
59/18 60/3 60/9 60/12
66/20 67/2 67/5 67/12
67/25 68/10 70/5 70/6
70/13 72/12 73/8
78/21 78/24 79/4
80/21 83/21 94/17
109/14 113/2 118/16
120/9 120/25 121/16
122/19 122/22 123/1
123/20 124/5 124/18
127/2 127/8 129/7
132/17 133/5 133/18
133/19 134/5 134/7
134/13 134/13 134/19}
135/4 135/8 136/12
147/16 147/22 149/21
163/24 164/25 167/12
167/21 174/7 174/25
182/24 183/10 187/19}
188/7
Office's [7] 68/22
120/23 126/23 135/11
136/18 137/7 162/12
Office-Royal [1]
133/5
Officer [1] 39/5
Officer's [2] 175/8
175/16
offices [1] 16/11
often [5] 45/18 50/1
51/9 163/24 166/23
oh [2] 130/15 154/15
ok [1] 130/7
okay [9] 16/9 41/21
52/3 56/1 89/17
130/19 131/3 135/2
136/5
ombudsman [1]
105/17
on [398]
once [3] 109/18
114/13 171/2
one [55] 1/10 2/5
8/12 11/9 14/21 14/21
16/13 29/21 51/10
51/12 51/22 51/24
56/2 56/25 57/3 57/10
60/19 61/4 61/17 62/6
65/17 68/25 69/11
69/25 76/18 84/24
88/3 90/17 90/21 94/3
107/11 107/23 112/12]
118/15 124/14 126/17]
131/9 133/18 134/14
141/8 154/4 155/13
158/6 158/21 160/1
167/9 168/5 175/3
177/15 177/16 182/10
186/7 186/14 187/23
190/20
ones [2] 165/18
187/21
ongoing [12] 11/21
12/16 61/21 61/24
110/11 111/18 117/18
124/6 124/17 132/5
135/20 167/5
Online [1] 109/19
only [17] 26/2 44/8
75/15 90/24 121/8
122/8 130/6 138/5
139/10 140/23 142/8
151/13 155/24 162/20
174/11 176/9 178/17
onto [3] 50/3 66/12
67/15
open [6] 53/3 53/8
53/12 53/20 54/1
129/18
opened [1] 53/8
opens [1] 129/15
operates [1] 29/19
operating [1] 55/12
operation [2] 55/16
55/18
operational [5] 5/20
6/21 29/24 123/3
154/14
operationally [2]
12/12 135/19
operations [3] 4/14
14/21 47/5
opinion [4] 30/14
60/5 138/21 138/22
opportunity [5] 20/11
49/4 73/4 114/25
160/7
opposite [1] 170/38
opposition [1]
181/24
Opps [1] 56/5
option [1] 76/13
options [5] 75/16
75/23 77/13 77/16
143/20
options/levers [1]
75/16
or [122] 3/16 4/11 5/1
5/20 5/22 6/23 10/2
12/6 12/18 12/21 13/5)
13/7 14/19 14/23
15/23 17/21 18/7
19/16 19/23 21/25
26/25 27/16 28/7
28/21 29/5 29/16 30/9
30/9 32/16 32/20 33/9
33/15 34/13 36/3
36/18 39/3 39/21
39/23 40/10 40/19
43/17 47/16 47/17
49/6 49/15 50/9 50/17
51/5 51/9 51/11 53/3
53/20 53/20 55/10
55/12 57/4 59/16
59/25 60/2 60/23 62/9)
62/25 67/9 67/23
67/24 69/4 75/21 76/2
76/16 85/10 88/22
90/12 93/14 94/13
97/5 100/9 101/4
105/20 106/4 113/8
114/9 114/10 115/16
115/23 117/17 121/20}
125/15 128/5 134/23
135/4 140/22 141/9
144/6 144/13 145/13
149/9 149/15 149/16
149/17 150/3 150/20
153/17 156/4 159/7
160/5 161/16 161/17
163/23 165/4 165/12
165/12 167/1 168/14
172/24 174/4 175/3
181/21 182/15 183/2
183/15 186/10 187/7
oral [6] 1/7 1/12 1/14
1/24 2/1 2/10
orally [1] 190/14
order [3] 22/21 50/3
54/14
Orders [1] 17/11
organisation [10] 3/2
4/5 4/23 10/1 19/19
20/13 30/19 46/6
62/23 63/10
organisations [2] 3/7
3/8
organograms [1] 6/6
original [2] 84/12
115/13
other [36] 7/25 10/8
10/20 10/24 11/18
17/22 19/20 20/7 31/9)
42/16 43/25 50/7 51/8
62/6 63/3 63/14 69/4
70/4 72/14 75/15
95/17 97/7 100/2
120/24 122/8 124/1
124/15 136/13 139/7
142/19 153/25 162/19)
164/13 172/18 180/13)
188/20
others [10] 84/3
105/13 116/8 119/2
121/20 132/14 159/22)
162/25 189/1 189/9
otherwise [1] 100/10
our [59] 2/6 2/25
52/16 59/15 71/3
72/10 73/19 75/25
82/2 91/7 91/7 91/14
93/9 99/22 100/10
100/12 107/16 108/21
112/12 116/19 119/11
121/4 122/9 123/2
123/4 124/6 124/9
124/23 125/1 125/4
126/16 127/10 129/20)
129/21 131/12 132/8
137/9 137/18 143/7
143/10 143/16 145/20)
145/24 146/8 146/12
146/14 148/17 156/18)
157/12 157/16 159/16)
166/3 166/4 166/6
173/7 173/19 181/4
181/6 181/7
ours [2] 73/17 91/22
out [40] 13/20 37/9
40/5 55/10 56/19
67/17 72/7 74/12 76/1
77/3 79/1 79/17 91/15
(68) noting - out
[e)
out... [27] 94/7 94/19
98/7 102/25 114/9
114/10 114/16 121/18)
125/21 131/12 131/19
132/23 137/16 142/11
146/25 151/20 152/7
152/12 154/24 156/8
159/3 160/10 161/1
163/19 165/17 180/14}
181/16
outages [1] 49/1
outcome [1] 138/17
outdated [1] 50/2
outlining [1] 84/25
outs [1] 166/14
outside [4] 16/23
37/22 168/9 189/5
over [35] 3/9 7/17
11/19 16/7 21/7 30/18}
36/11 43/11 49/21
52/13 53/5 61/15
75/20 81/18 87/7
94/22 94/24 99/16
109/15 112/13 113/25)
119/9 132/24 136/9
136/11 140/2 148/4
151/6 154/3 155/12
160/13 161/12 162/25
164/18 167/24
overall [5] 94/5 94/7
104/8 137/5 157/14
overly [1] 77/16
overplay [1] 75/25
overreaction [1]
113/3
oversee [4] 22/22
23/5 23/6 37/17
overseeing [3] 11/10
12/24 25/14
oversight [38] 2/15
4/14 8/9 9/2 9/4 9/6
9/10 9/16 10/5 10/8
12/8 18/19 18/22 20/2
22/16 22/17 29/5 29/8
30/10 30/25 31/24
33/15 33/25 34/15
34/23 34/24 35/10
35/17 35/19 41/3
44/14 45/7 46/5 46/11
46/20 48/3 48/4 72/3
overview [1] 8/4
own [5] 34/9 63/3
112/15 129/17 168/3
owned [1] 37/8
Pp
P5 [1] 56/5
pack [4] 23/23 23/25
24/2 118/6
packages [1] 188/9
packed [1] 181/23
page [121] 2/5 2/7
2/8 2/9 2/9 2/11 2/11
2/17 2/17 3/13 3/13
3/14 4/16 4/17 4/17
5/12 5/13 6/20 7/19
7/20 8/12 8/13 10/7
11/6 16/3 16/7 16/10
17/2 20/21 21/7 23/16
25/5 25/6 26/16 32/7
33/4 33/5 35/14 35/23
35/24 36/1 36/2 36/3
36/11 42/21 43/11
45/5 47/5 50/11 52/7
52/14 52/21 53/4 53/5)
53/12 65/10 65/11
65/25 68/9 68/21 69/5)
78/22 81/13 84/11
85/20 87/7 90/19
90/20 95/2 95/3 95/24)
97/19 98/5 99/16
100/3 105/1 105/4
109/6 113/24 113/25
113/25 114/1 118/19
119/20 120/5 120/17
120/18 123/16 123/17)
126/11 130/4 130/15
130/16 136/9 136/11
136/11 137/11 137/13}
137/17 139/25 140/2
140/6 142/16 145/5
145/13 152/24 154/3
154/6 155/12 155/15
157/19 162/8 163/9
163/17 163/18 165/3
181/1 184/24 185/1
185/13 185/17
page 1 [3] 95/24
184/24 185/13
page 10 [1] 47/5
page 11 [1] 68/9
page 126 [2] 2/9 33/5
page 13 [1] 17/2
page 138 [1] 2/11
page 14 [3] 23/16
35/14 78/22
page 140 [1] 36/3
page 152 [1] 3/14
page 159 [1] 4/17
page 163 [1] 5/13
page 164 [1] 6/20
page 165 [1] 7/20
page 18 [2] 45/5
139/25
page 2 [8] 26/16 53/4
53/12 97/19 120/18
126/11 130/4 163/9
page 22 [2] 32/7
68/21
page 23 [1] 11/6
page 27 [1] 35/23
page 3 [8] 50/11
90/20 113/24 113/25
114/1 136/11 154/6
162/8
page 32 [2] 2/8 33/4
page 35 [1] 36/1
page 38 [1] 3/13
page 4 [2] 157/19
181/1
page 40 [1] 4/16
Page 41 [1] 5/12
page 44 [2] 69/5
140/6
page 45 [1] 65/11
page 5 [4] 52/21
145/5 185/1 185/17
page 54 [1] 142/16
page 6 [2] 20/21 25/5
page 7 [1] 52/14
page 73 [1] 8/13
page 8 [3] 16/3 52/7
65/25
pages [1] 2/4
panic [1] 183/3
paper [8] 16/4 68/17
136/10 136/23 136/25)
143/21 161/2 166/8
papers [8] 46/19 58/7]
165/14 165/21 166/5
166/7 166/13 166/13
para [2] 126/17
129/13
paragraph [40] 10/7
11/7 22/5 32/7 33/12
35/14 45/6 48/15
49/10 49/25 50/11
65/21 65/25 67/16
67/18 68/8 68/21 69/5)
75/14 86/8 94/21
107/19 108/19 127/12,
129/9 140/3 140/8
142/17 147/4 153/15
154/20 154/23 155/15}
156/9 162/4 174/2
179/18 185/14 185/18
186/16
paragraph 13 [2]
174/2 186/16
paragraph 142 [1]
140/8
paragraph 173 [2]
142/17 179/18
paragraph 2 [1]
50/11
paragraph 23 [1]
65/21
paragraph 3 [1]
49/25
paragraph 30 [1]
185/18
paragraph 31 [1]
68/8
paragraph 32 [1]
22/5
paragraph 35 [1]
45/6
paragraph 36 [1]
48/15
paragraph 4 [3]
67/16 67/18 155/15
paragraph 41.1 [1]
35/14
paragraph 44 [1]
10/7
paragraph 45 [1]
11/7
paragraph 50 [2]
68/21 140/3
Paragraph 51 [1]
49/10
Paragraph 56 [1]
32/7
paragraph 8 [1]
185/14
paragraph 99 [1]
69/5
paragraphs [1] 182/4
Parcelforce [1] 38/10
Parcels [1] 9/5
Parliament [3] 73/10
7AI5 163/13
Parliamentary [3]
74/8 74/9 77/3
Parsons [3] 146/25
162/3 181/16
part [44] 2/18 3/21
5/22 8/12 15/13 23/22,
34/2 37/7 38/17 44/2
57/24 67/20 68/10
69/23 72/18 74/1 74/3
79/21 79/21 81/8
105/10 111/8 112/7
118/1 121/12 121/13
121/19 139/19 145/11
145/11 145/14 147/24}
148/2 148/25 151/22
154/7 155/5 166/3
167/22 168/7 170/2
170/6 171/5 189/3
Participants [1]
169/1
particular [26] 13/15
31/8 43/20 47/8 53/23)
57/15 57/16 63/23
69/8 74/5 79/15 96/25
97/10 101/4 101/7
107/19 122/23 126/17
129/23 142/19 145/23
146/16 148/8 154/20
154/23 167/9
particularly [19] 71/3
75/3 79/18 97/15
102/12 102/13 112/5
117/21 121/23 127/11
128/3 139/19 144/6
150/12 166/3 168/2
168/20 172/5 190/3
Partington's [1]
52/22
partly [1] 71/8
party [1] 177/25
passage [4] 99/4
126/20 157/17 157/22
passages [3] 74/11
77/24 98/7
passed [6] 49/18
51/6 51/7 160/20
161/7 182/24
past [26] 14/24 43/20
51/19 86/9 87/8 92/17)
102/14 105/17 105/25)
106/8 106/17 107/13
107/17 107/25 108/23)
140/25 141/18 151/16)
156/20 157/15 159/14
159/18 167/25 172/16)
172/22 173/21
paste [1] 88/24
Patrick [1] 67/7
Paula [91] 67/13
67/22 68/10 69/3
69/20 72/18 73/1
73/11 73/17 73/18
73/24 74/13 75/8 76/8I
78/1 79/23 80/10 81/9I
81/19 82/12 88/9 90/1
97/21 98/9 100/4
100/15 101/14 103/11
103/14 105/1 105/11
106/22 114/5 114/21
114/22 115/4 115/6
119/20 120/4 120/11
126/8 131/5 137/13
138/1 138/22 139/2
139/5 139/10 140/24
141/23 141/24 143/3
143/6 144/9 144/20
144/24 145/9 148/4
149/3 150/20 150/24
151/14 152/17 152/22)
155/7 158/13 158/17
160/9 160/14 161/9
170/18 171/25 172/24)
173/21 174/8 174/16
176/20 177/21 178/2
178/18 178/23 178/25)
179/4 179/8 179/10
181/20 182/12 184/17)
185/24 187/20 188/17
Paula's [5] 114/8
114/9 127/22 141/6
152/7
pausing [8] 11/12
42/22 47/7 51/25 86/5)
100/12 146/2 159/20
PDF [1] 98/1
pen [3] 104/8 116/13
119/12
pending [2] 153/17
156/4
penny [1] 162/20
penultimate [2]
107/9 162/4
people [34] 3/24
13/25 15/14 15/19
19/7 22/24 23/1 30/13)
37/23 39/1 40/3 40/5
(69) out... - people
Pp
people... [22] 40/11
49/19 50/22 50/24
51/2 51/4 51/8 63/3
64/8 79/8 94/17
102/23 108/2 110/18
121/15 141/11 141/13}
142/10 172/11 175/5
181/21 187/23
per [6] 6/11 8/17
63/20 132/9 134/3
135/10
per se [3] 132/9
134/3 135/10
perceive [1] 129/5
perceptions [1] 76/6
perfect [1] 23/17
performing [1]
175/19
perhaps [11] 65/22
7AI5 106/21 139/23
140/6 140/8 154/20
157/18 169/2 169/16
184/25
period [13] 30/18
36/18 36/21 36/22
40/7 48/2 48/9 49/21
51/2 94/24 115/20
139/1 140/13
Perkins [11] 81/9
131/6 137/14 141/24
143/3 144/25 172/1
176/21 187/4 187/6
187/10
permitting [1] 165/19
perpetrated [1] 17/10)
persistent [1] 55/3
person [5] 59/16
99/12 141/25 182/6
183/17
personal [6] 50/12
T7I17 86/19 112/16
128/14 135/2
personally [3] 89/12
164/1 168/2
persons [1] 25/2
perspective [5] 13/8
56/23 120/10 123/22
135/2
perspectives [2]
164/11 168/23
persuasive [1] 73/6
Peter [2] 21/4 24/7
phase [1] 118/2
phone [4] 53/6 96/3
121/17 163/7
phrase [1] 107/5
pick [5] 121/17 125/7
126/5 144/16 163/7
picked [5] 10/3 19/22
62/15 99/23 165/4
picking [2] 144/6
144/23
piece [9] 12/12 40/4
43/25 58/7 58/8 58/19
63/23 109/11 166/10
pieces [4] 4/2 29/24
51/21 109/20
pilot [1] 47/21
pin [1] 96/4
place [31] 3/1 3/19
4/10 11/18 11/23 15/4
15/4 19/2 19/4 19/6
19/11 19/13 20/10
22/8 22/16 22/17
22/20 29/25 60/20
62/20 63/19 71/6 75/2
107/3 121/18 128/12
133/11 135/15 160/41
182/2 188/10
placed [2] 134/3
155/18
places [1] 119/5
Plan [1] 75/17
planned [1] 45/19
planning [2] 71/22
82/1
play [3] 47/24 72/2
123/7
played [2] 67/17
168/4
playing [1] 73/23
plays [2] 57/24 76/5
please [114] 2/2 2/8
2/10 2/17 3/13 3/14
4/16 5/12 6/19 7/19
8/12 10/6 11/6 15/23
16/3 16/10 16/17 17/2
19/14 20/17 20/21
21/7 22/14 23/13
23/15 23/16 24/4 25/5)
26/11 26/16 32/4 32/7
33/1 34/4 35/1 35/13
35/14 35/23 35/24
35/24 36/1 42/18
42/22 45/5 47/3 47/4
47/6 49/8 51/15 52/6
52/7 52/14 52/21 53/4
54/18 56/3 56/3 64/24
65/2 65/11 66/1 67/16
70/14 72/21 74/17
78/15 80/12 81/7
90/15 90/19 95/24
97/13 100/3 100/4
101/15 104/23 104/24)
107/8 109/6 113/23
113/24 113/25 116/22)
118/18 119/18 120/16)
120/17 123/16 123/21
125/8 126/9 126/11
130/13 132/12 137/10)
137/11 143/1 145/4
145/6 147/5 147/8
149/4 149/14 151/1
152/24 155/12 158/4
161/25 163/2 164/23
165/9 181/1 185/13
185/17
pleased [1] 53/9
plethora [1] 47/14
pm [5] 116/25 117/2
169/19 169/21 190/25}
point [72] 19/7 21/23
24/13 25/18 34/17
40/2 43/17 43/17
43/20 44/5 45/9 49/2
56/2 57/16 59/4 63/16
75/20 79/2 80/9 82/16)
85/23 88/9 88/10
88/20 91/9 91/12
91/13 92/8 92/10
92/12 93/5 94/19
94/20 96/4 99/7 99/22
105/23 107/9 107/15
117/15 118/15 123/23
124/13 127/17 127/20
130/17 130/19 134/23}
138/25 139/4 139/7
142/19 144/6 144/17
144/23 145/19 150/21
151/25 155/4 156/16
159/12 163/8 165/23
166/15 168/8 168/13
174/18 177/5 177/15
177/17 184/11 190/4
points [9] 103/13
103/18 103/24 105/17
122/13 143/14 147/8
158/21 165/17
POL [14] 3/5 9/5
11/25 12/3 12/11
12/11 19/13 38/25
39/1 40/8 42/15 42/15)
42/16 44/7
POL's [1] 66/1
POL00006590 [1]
117/9
POL00006803 [1]
139/24
POL00021418 [1]
24/4
POL00021483 [1]
15/24
POL00021485 [1]
16/17
POL00021486 [1]
20/17
POL00021487 [1]
42/18
POL00021490 [1]
23/13
POL00029707 [1]
161/25
POL00032210 [2]
26/11 47/3
POL00060587 [1]
183/25
POL00097786 [1]
72/21
POL00098777 [1]
74/16
POL00098778 [2]
78/15 183/5
POL00098806 [1]
80/12
POL00099021 [1]
104/23
POL00106867 [1]
54/18
POL00107538 [1]
49/8
POL00112856 [1]
136/7
POL00113367 [2]
184/23 185/7
POL00118229 [1]
61/6
POL00120833 [1]
56/4
POL00145089 [2]
97/13 97/18
POL00146462 [1]
126/10
POL00161769 [2]
51/15 52/6
POL00190092 [2]
81/7 184/3
POL00190132 [1]
84/7
POL00196705 [1]
158/4
POL00196706 [1]
156/12
POL00196707 [2]
145/5 157/19
POL00196708 [1]
153/22
POL00196709 [1]
155/9
POL00196710 [1]
156/7
POL00295635 [2]
174/14 186/22
POL00297040 [2]
90/16 90/20
POL00297915 [1]
113/24
POL00299534 [1]
120/16
POL00299535 [1]
132/12
POL00372558 [1]
178/9
POL00373845 [1]
164/23
POL00380018 [1]
70/15
POL00380985 [1]
97/2
POL00381077 [1]
109/4
POL00381531 [1]
119/19
POL00382001 [1]
137/10
POL00407608 [1]
143/1
POLBO3 [1] 16/3
POLB03/69 [1] 16/3
POLB04 [2] 16/20
17/2
POLB04/108 [1] 17/2
POLB04/86 [1] 16/20
policies [3] 15/3
29/25 60/2
policy [3] 59/25
59/25 159/10
politically [3] 129/15
129/19 176/5
poor [1] 50/3
poorly [1] 119/5
portrayed [1] 76/4
posed [2] 163/16
1711/4
position [21] 33/23
43/10 45/17 50/7 70/1
82/13 82/14 90/8 91/7
94/16 100/10 100/12
100/14 101/6 101/7
101/7 110/9 113/2
136/22 165/25 166/6
positioning [1]
133/14
positive [1] 133/4
possibility [2] 80/16
123/1
possible [7] 82/3
107/13 107/25 140/7
157/20 158/20 180/24
possibly [4] 80/20
95/9 106/2 111/1
post [159] 2/12 9/12
10/5 10/12 10/14
10/21 10/25 11/13
11/18 11/20 11/23
12/14 13/21 13/24
15/22 15/24 16/11
17/19 19/7 19/16
20/18 21/22 22/18
23/4 23/10 23/11
23/13 24/8 25/1 25/7
26/7 26/12 26/18 28/6I
28/22 29/4 29/6 29/8
29/13 30/24 31/10
31/14 32/13 32/15
33/25 34/9 34/19
35/18 35/19 36/6
36/16 37/4 37/4 37/8
37/12 37/20 37/21
38/5 38/9 38/18 38/19
39/8 42/12 42/19 43/5I
44/10 44/17 45/3 45/9)
45/15 45/16 48/17
49/6 49/17 50/5 50/9
50/13 50/23 51/14
52/4 53/18 53/20 54/1
54/8 56/7 56/13 56/14
57/6 57/7 59/12 59/16)
59/18 60/3 60/9 60/12
(70) people... - post
P
post... [64] 67/2 67/5
67/12 67/24 68/22
69/16 70/5 70/6 70/13
73/8 78/21 78/24 79/3
80/20 83/21 94/16
109/14 113/2 118/16
120/8 120/22 120/25
121/16 122/19 122/21
122/25 123/20 124/5
124/7 124/18 126/23
127/2 127/8 129/7
132/17 133/5 133/18
133/19 134/5 134/7
134/12 134/13 134/19}
135/3 135/8 135/11
136/12 136/18 137/7
147/15 147/22 149/21
162/12 163/24 164/22
164/25 167/11 167/21
174/7 174/24 182/24
183/9 187/19 188/7
post-separation [2]
124/7 164/22
post-this [1] 52/4
posted [1] 125/7
postmaster [3]
110/23 113/6 127/19
postmasters [3]
110/12 188/11 189/8
potential [12] 12/18
12/22 13/9 14/22
56/13 57/6 57/12
84/17 106/11 113/8
157/11 166/10
potentially [8] 82/9
102/2 107/11 107/23
129/15 129/18 152/2
179/21
pounds [1] 50/8
PR [3] 53/2 120/9
122/14
practical [1] 178/22
practice [3] 9/15
142/3 177/16
practices [1] 15/3
pre [1] 181/23
pre-packed [1]
181/23
preceded [1] 88/7
preceding [3] 90/12
90/12 152/5
precisely [2] 39/6
170/8
prefer [1] 96/12
preferred [1] 83/10
preliminary [2] 82/17
86/18
preparation [2] 68/22
117/13
preparations [1]
144/18
prepare [5] 44/19
44/24 67/22 68/16
158/15
prepared [5] 98/16
100/19 116/3 149/20
167/11
preparing [1] 66/3
presence [1] 129/14
present [7] 16/1 16/2
16/19 16/20 16/22
26/13 152/19
presented [1] 16/4
presenting [2]
110/19 180/16
press [7] 60/9 111/9
124/23 127/8 128/15
129/18 130/6
pressed [3] 89/1
95/12 96/5
pressure [1] 77/2
presumably [12]
15/13 38/3 53/20
55/24 70/19 72/18
82/22 83/2 105/5
150/15 156/13 177/21
pretty [6] 6/16 27/25
62/25 63/1 91/5
150/19
previous [14] 67/11
82/2 82/5 82/10 82/12
82/20 84/18 87/2
87/25 95/2 106/5
108/6 138/10 160/11
previously [7] 67/8
80/21 81/3 106/22
107/22 162/13 166/7
primarily [1] 68/25
primary [3] 21/11
75/8 121/22
principally [2] 69/11
124/13
principle [2] 25/7
50/6
priority [1] 19/24
privatisation [1]
133/20
proactive [3] 14/25
20/3 30/25
proactively [2] 29/14
29/16
probable [1] 49/17
probably [30] 24/3
41/11 46/21 50/18
53/11 57/17 57/17
60/8 62/21 63/12
63/18 74/7 105/19
107/21 109/16 111/20)
117/19 133/5 138/25
139/6 150/8 150/24
151/11 154/24 155/4
164/8 167/3 169/13
178/15 180/4
probing [1] 11/16
problem [9] 29/12
presentation [1] 21/4
34/7 39/4 50/17 78/22
132/6 164/21 179/16
183/14
problematic [3]
102/4 119/1 120/8
problems [11] 33/9
46/18 50/14 59/11
59/17 110/11 126/23
127/1 162/9 162/13
179/25
procedures [4] 15/3
17/15 20/9 29/25
proceed [1] 169/1
proceedings [9]
17/12 32/11 33/3
35/18 36/8 36/16 59/8
59/9 98/14
process [47] 8/7 15/1
15/7 15/10 18/3 18/9
18/10 18/14 20/2
29/14 30/7 51/18
51/19 51/20 52/1 52/3)
52/5 57/25 62/1 66/1
66/7 82/4 89/4 95/15
98/19 99/9 102/22
127/21 133/17 133/19}
135/20 136/2 137/8
138/12 139/2 143/19
146/24 148/3 157/14
158/22 159/3 159/11
161/9 161/13 167/24
174/17 174/22
processes [7] 3/19
3/25 40/20 56/20 62/3
99/23 127/3
produced [5] 45/2
146/22 155/10 156/13
185/8
product [2] 48/17
68/6
production [1]
145/15
products [1] 22/10
professional [1]
178/4
profile [6] 129/16
129/19 131/20 137/23
173/12 179/21
Programme [2]
146/23 161/12
progress [8] 47/20
53/9 53/16 75/11
100/23 121/6 125/15
125/16
progression [1] 22/9
project [8] 45/8
45/11 46/1 46/21
46/21 46/22 189/16
189/21
projects [1] 45/18
prominent [1] 70/20
proper [2] 151/23
161/5
properly [6] 21/13
45/20 102/21 152/10
168/8 168/15
proposal [1] 43/7
proposing [2] 59/19
87/16
prosecute [4] 5/1
6/23 8/20 63/3
prosecuted [4] 4/20
108/2 108/10 108/12
prosecuting [1] 19/8
prosecution [20] 5/6
9/2 9/11 16/12 25/23
32/19 39/7 59/2 60/20)
61/22 66/1 66/7 81/24,
83/18 85/6 145/22
156/5 156/20 157/8
185/21
prosecution’ [1]
153/17
prosecution's [1]
149/9
prosecutions [94]
2/15 2/16 5/14 5/15
7/4 8/10 9/16 10/6
10/12 10/22 11/3 18/3}
18/9 18/10 18/13
18/14 18/16 18/19
18/22 18/24 19/1 19/4]
19/5 19/11 19/13
19/15 19/17 20/2 20/4}
22/17 22/18 22/22
23/5 25/8 25/14 26/8
27/12 29/6 29/14
30/16 30/21 31/1 31/4
31/24 32/10 33/9
35/10 35/17 35/20
36/14 36/15 36/15
38/6 40/6 41/3 61/25
62/9 63/15 63/15 82/5)
82/10 83/1 83/9 85/11
85/24 92/5 95/9 95/10
96/4 98/6 98/10 98/25
102/14 105/18 106/1
106/8 106/17 107/13
107/25 108/6 108/17
138/10 138/17 141/18
143/21 146/12 148/17]
170/5 172/16 172/23
181/8 184/5 184/6
185/1
prosecutorial [4]
13/23 14/12 15/1
40/24
prospective [2]
120/15 123/6
prospectus [19]
118/11 118/17 118/21
120/7 120/13 120/24
122/9 123/5 123/10
123/21 124/14 126/17
126/21 128/18 129/24}
132/18 133/12 134/21
137/3
protect [4] 56/20
82/25 85/14 135/11
protesting [1] 125/5
provide [10] 47/14
98/17 107/18 115/22
155/14 159/14 168/17
177/7 179/12 181/16
provided [10] 21/4
45/13 68/11 88/14
1437/7 142/25 147/1
163/6 179/13 189/4
provides [1] 156/2
providing [4] 34/21
118/15 146/11 181/6
provision [2] 136/17
141/4
provoke [1] 106/23
provoked [1] 112/23
prudent [1] 148/19
précis [1] 181/2
public [18] 25/9
25/24 53/11 71/1 71/7I
82/25 85/14 85/15
94/20 98/24 109/7
110/23 112/21 112/23)
132/9 153/10 155/17
155/18
publication [1] 109/9
publicity [2] 84/17
87/1
published [8] 74/18
75/22 92/24 126/22
129/21 129/21 132/7
132/8
pull [1] 151/24
pulled [1] 81/17
pulling [2] 103/14
105/14
punishment [1]
188/20
purpose [7] 22/12
45/22 45/24 75/8
106/15 120/13 171/19}
purposes [3] 2/5
59/7 155/13
pursue [1] 26/8
pursued [2] 86/2
98/12
pursuing [2] 10/13
82/25
pursuit [1] 32/21
pushback [1] 124/8
pushed [2] 86/9
88/10
pushing [1] 123/24
put [12] 28/5 29/25
56/22 85/9 89/13
98/14 133/8 138/11
152/9 154/24 170/7
177/10
putting [5] 33/7 90/1
152/6 162/6 166/5
PV [1] 184/2
(71) post... - QC
Qu
qualify [1] 134/4
quantification [1]
57/23
quarterly [1] 21/16
quarters [1] 154/7
Queen's [1] 176/5
querying [1] 83/25
question [26] 2/12
9/8 13/19 18/12 18/18
28/3 28/19 36/3 39/9
54/1 54/11 54/13
54/14 68/5 82/4 82/9
82/11 87/18 92/16
92/17 117/25 141/14
180/3 187/6 189/1
189/9
questioned [16] 1/22
35/25 58/17 61/16
65/1 94/18 170/1
187/15 189/14 192/4
192/6 192/8 192/12
192/14 192/16 192/18
questions [37] 1/17
30/6 33/6 47/16 58/15)
61/13 61/14 64/11
74/25 90/23 102/15
106/7 106/15 106/19
106/23 107/7 118/5
136/21 146/24 150/6
150/11 150/15 150/25}
152/5 158/15 159/25
163/15 163/19 168/25
169/3 169/5 171/4
177/19 181/15 187/2
187/7 187/16
questions/comments
[1] 90/23
quick [3] 16/6 72/24
151/9
quicker [2] 124/11
133/7
quickly [8] 17/14
41/15 47/22 64/9
173/25 179/15 181/3
185/7
quite [34] 27/11
38/22 39/12 39/14
43/25 44/2 49/21 51/1
58/18 59/24 62/23
69/18 76/2 87/25 88/8
88/10 89/9 89/23
97/10 97/18 110/25
112/9 122/24 131/14
132/2 133/23 135/17
149/12 151/20 152/6
155/2 164/15 165/24
181/22
quotation [1] 146/10
quotations [1]
159/23
quote [2] 36/4 66/6
quoted [1] 176/19
quotes [2] 110/1
155/1
quoting [1] 88/22
raise [4] 29/12
150/25 184/25 185/1
raised [31] 3/2 11/15
17/21 19/2 19/21
19/23 30/3 30/17
39/18 39/25 56/23
58/9 58/11 60/16
75/17 75/23 82/8
82/12 88/20 92/17
118/5 130/17 135/12
136/21 146/24 150/11
152/5 161/3 174/3
174/12 174/19
raises [1] 52/15
raising [6] 57/11
92/22 106/1 123/1
123/2 130/1
Ran [1] 109/13
range [5] 16/23 75/23
77/13 135/11 188/5
rather [15] 12/20
16/11 20/2 37/4 42/24
46/10 60/13 70/20
93/9 100/19 114/9
122/14 125/16 151/19)
183/15
re [14] 1/17 1/21
100/8 103/7 129/23
137/18 143/20 151/11
173/7 173/8 173/17
178/15 184/2 192/2
re-airing [1] 129/23
re-articulated [2]
151/11 178/15
re-attend [1] 1/17
re-read [2] 100/8
103/7
re-sworn [2] 1/21
192/2
reach [2] 139/5 139/8)
reached [2] 66/23
7917
reaching [2] 142/11
157/15
react [1] 20/16
reacting [3] 110/5
111/19 112/7
reaction [7] 106/11
111/13 112/9 112/12
112/14 112/16 112/16)
reactive [2] 20/1 20/5
read [56] 2/18 16/7
16/15 16/15 17/4
17/24 18/22 20/20
20/22 23/22 25/25
26/1 28/13 28/16
33/12 38/21 46/12
46/13 46/19 47/19
52/2 58/12 74/11 84/9)
91/2 98/7 100/8
101/17 101/24 103/7
103/9 128/13 131/13
134/11 146/2 146/19
153/2 154/11 154/12
154/14 162/18 165/18}
174/2 175/9 175/17
175/23 176/8 176/15
176/17 178/20 179/6
185/11 186/21 189/24
190/1 190/5
reading [10] 25/12
27/2 84/8 95/21
144/22 150/1 160/23
165/14 190/2 190/4
readouts [1] 72/16
reads [3] 83/7 85/6
173/5
ready [2] 48/10 69/23
real [8] 29/5 58/9
58/11 60/13 72/2
89/24 121/6 162/6
realise [1] 126/14
really [13] 2/25 9/25
10/3 25/17 54/22
91/13 95/6 135/8
137/8 142/8 166/20
182/4 182/4
reason [12] 34/24
38/3 39/24 84/19 87/2
88/1 100/1 138/24
144/16 157/9 159/18
162/7
reasonableness [1]
83/2
reasonably [1] 41/15
reasons [9] 43/8
43/22 43/23 53/17
54/8 54/15 134/14
139/6 141/9
reassurance [2]
98/17 155/2
reassured [1] 155/4
reassuring [5] 85/25
87/25 88/6 88/8
159/23
recall [80] 4/6 5/10
5/24 6/17 10/11 10/20}
10/24 11/5 16/14
16/24 17/20 17/21
17/24 19/12 21/24
22/2 24/14 24/17
24/20 25/12 26/2
26/25 27/16 28/7 28/8
28/14 28/20 28/24
32/1 32/2 32/12 32/18}
33/8 33/17 34/18
35/16 38/2 43/14
43/15 43/17 45/14
45/23 47/11 47/16
48/21 48/24 49/12
53/17 53/24 73/13
75/6 75/9 80/4 80/24
81/1 81/4 92/14 97/5
102/15 105/8 109/25
115/6 115/12 116/2
117/25 118/7 118/8
139/2 139/11 139/12
141/6 144/5 144/22
160/21 160/23 171/1
186/9 187/9 190/2
190/4
recapping [1] 1/25
receive [4] 33/8
49/15 53/2 109/18
received [4] 83/24
125/12 146/4 156/14
receiving [2] 49/12
165/16
recent [3] 112/22
120/23 172/7
recently [3] 161/18
162/20 180/13
recess [1] 77/4
recipient [1] 97/8
recipients [1] 105/2
recirculated [1]
131/18
recognise [3] 129/12
141/7 185/6
recognised [2] 112/5
123/4
recognising [2]
106/3 165/24
recollect [2] 138/1
172/4
recollected [1]
170/25
recollection [12] 6/7
16/13 26/6 45/7 138/3}
138/13 138/18 138/22
144/3 172/5 173/18
173/23
record [2] 53/11
126/24
recorded [2] 44/16
174/14
recover [1] 32/22
recovered [1] 142/24
recovery [7] 17/12
18/23 25/9 25/19
25/22 62/2 98/14
recruit [2] 26/22
53/10
redacted [2] 154/2
154/5
redraft [1] 165/20
redress [1] 50/9
reduced [1] 13/23
refer [4] 48/16 65/24
102/11 116/9
reference [16] 1/11
2/5 2/7 97/2 118/6
120/21 124/23 140/17
143/22 143/24 149/1
151/19 152/3 155/13
158/5 186/15
referenced [4] 46/23
80/18 132/4 136/23
references [6] 2/4
16/21 118/16 131/25
153/12 157/23
referred [8] 66/7 85/7I
86/16 121/13 126/9
139/15 155/11 156/23)
referring [17] 2/4
13/2 42/23 48/3 57/10}
61/7 66/9 100/17
101/9 106/11 111/7
112/1 112/4 117/10
167/4 167/7 184/12
refers [5] 16/4 89/6
149/21 156/9 173/16
reflect [5] 133/13
133/16 164/8 164/20
173/14
reflected [2] 46/1
133/15
reflecting [1] 181/20
reflects [4] 94/16
108/15 131/17 131/20)
regarding [6] 72/25
137/19 144/13 148/12)
148/14 156/8
regardless [1]
162/10
regional [1] 109/20
register [2] 56/7
105/19
regret [3] 112/13
168/9 189/6
regularly [1] 31/18
regulatory [8] 26/20
27/4 27/7 27/10 28/12I
28/14 28/15 28/17
reiterate [1] 90/9
reiterating [1] 89/11
reject [1] 43/7
relate [2] 60/2 116/5
related [6] 45/10 71/9)
125/13 127/13 165/11
188/17
relates [3] 74/17
107/12 164/23
relating [14] 10/14
16/11 33/9 46/10
56/15 57/8 58/1 69/17
97/3 99/10 124/14
127/25 128/16 131/15)
relation [18] 19/16
33/24 40/18 76/9 78/2
78/9 81/10 103/11
106/17 127/1 128/6
128/7 133/11 134/5
137/3 144/4 174/9
186/7
relations [2] 109/7
121/23
relationship [12]
43/11 122/2 122/21
122/25 123/2 124/6
124/17 133/5 163/2
(72) qualify - relationship
R
relationship... [3]
164/7 164/21 166/3
relationships [1]
188/25
relatively [4] 57/14
57/19 70/13 154/13
relayed [1] 61/18
release [6] 47/2 47/7
47/13 47/20 124/24
130/7
released [1] 94/16
releases [3] 46/15
46/16 46/23
relevant [12] 25/11
25/21 25/22 54/15
68/1 69/1 73/5 80/8
89/15 93/16 99/9
166/6
reliability [3] 56/15
57/8 58/2
reliance [1] 89/6
reliant [3] 161/22
177/16 177/18
relied [7] 5/15 69/11
87/14 89/4 95/15
161/7 161/9
relies [2] 29/22 98/12
relying [2] 66/5 90/6
remained [1] 34/2
remedial [1] 99/23
remember [13] 1/6
3/11 18/6 21/21 24/24
31/15 38/8 49/15
54/20 81/11 138/5
160/21 184/5
reminded [1] 46/20
remit [2] 15/20 21/22
remote [1] 189/19
remove [3] 91/20
130/25 131/3
removed [3] 123/25
129/9 134/15
removing [2] 151/19
167/1
rename [1] 93/23
reopen [4] 52/16
54/5 107/13 107/25
reopened [5] 52/18
54/12 92/9 92/12
170/5
reopening [2] 53/16
53/25
repeat [2] 7/10 180/3
repeated [4] 40/17
45/8 95/22 130/6
repeating [1] 128/20
repercussions [1]
122/20
rephrase [1] 18/15
replace [2] 66/2 76/3
report [142] 4/3 8/15
17/8 17/15 47/5 47/8
47/10 59/8 59/9 59/17
68/23 74/18 75/5
75/19 75/21 76/16
76/20 76/21 76/22
77/3 77/4 7718 77/18
78/10 79/13 79/22
82/17 89/2 92/24
93/15 93/16 93/17
94/10 94/15 95/13
98/15 104/22 105/25
107/17 108/23 109/3
112/16 117/21 126/22)
126/25 127/13 127/19)
127/24 128/16 129/21
129/22 131/15 131/23)
131/23 131/25 132/4
132/4 132/7 133/9
133/15 137/22 138/9
139/20 140/2 140/4
140/12 141/19 142/18)
142/20 142/23 142/23)
145/4 145/7 145/9
145/12 145/15 145/25)
146/3 146/5 146/5
146/20 147/10 147/25)
148/3 148/9 148/13
148/18 148/25 149/7
149/13 149/16 149/19)
149/20 150/14 150/16)
151/2 151/12 151/19
152/3 152/7 152/9
153/13 153/22 154/1
154/2 154/8 154/14
155/15 155/17 155/24)
156/9 156/10 156/11
156/22 156/23 157/4
158/11 160/11 160/25
161/17 161/18 162/4
162/7 162/17 162/21
173/11 175/11 175/16)
175/20 178/12 178/16)
179/14 179/24 180/5
180/6 182/1 182/2
189/16 189/21 189/24)
190/5 190/6
Report [1] 153/9
reported [8] 6/12
27/20 27/24 30/1
32/16 35/5 43/2
140/12
reporting [3] 4/10 6/3)
111/15
reports [11] 21/18
60/9 65/24 67/21
77/20 128/21 140/18
156/1 156/2 159/23
180/10
repositioned [1]
76/17
representation [1]
110/16
representative [5]
28/1 43/19 137/20
165/25 173/8
represented [5] 34/8
45/17 45/22 132/11
134/2
representing [1]
188/23
represents [1] 113/4
reproduced [1] 95/21
reputation [4] 56/13
57/1 57/6 135/11
reputational [6] 72/2
107/11 107/23 122/14
129/6 170/4
reputational/PR [1]
122/14
request [3] 1/16
130/25 171/5
requested [2] 62/8
164/10
requests [2] 47/14
164/14
require [4] 22/23
23/2 153/16 156/3
required [6] 18/23
30/10 44/19 101/20
146/15 149/14
research [2] 86/14
86/19
resiled [1] 176/12
Resilience [1] 48/6
resist [2] 146/11
181/7
resistance [1] 123/25
resolve [1] 12/6
resolved [6] 47/2
47/22 47/25 76/18
124/2 131/13
resonates [2] 140/23
140/24
Resources [2] 17/7
1717
respect [9] 3/17 9/11
27/17 7116 74/14
101/8 161/6 170/18
178/10
respond [4] 50/24
79/22 109/22 115/14
responded [5] 51/20
119/6 119/23 148/18
152/25
responds [2] 125/3
147/5
response [34] 51/23
52/14 68/23 75/13
78/22 81/22 85/20
92/1 96/14 97/4
101/16 104/23 111/4
114/6 114/7 114/12
114/13 114/17 114/20
119/22 120/4 120/11
122/7 124/19 125/23
129/22 130/5 130/13
132/8 148/23 149/5
151/7 165/9 180/18
responses [3] 38/21
49/20 71/7
responsibilities [2]
39/17 68/24
responsibility [15]
4/1 4/9 4/13 8/21
12/13 12/23 12/25
15/18 15/20 32/9 37/2}
37/5 37/15 40/21
40/25
responsible [15] 3/4
5/21 6/22 7/3 15/14
32/13 32/24 33/18
38/5 63/23 72/7
119/13 148/19 179/9
181/22
rest [1] 35/20
restricting [1] 117/16
result [5] 55/2 59/12
86/11 87/11 106/2
resulting [3] 53/2
84/17 86/25
resume [1] 41/25
return [1] 94/8
returned [1] 160/19
returning [1] 64/5
reveal [1] 179/15
revealed [1] 142/22
revenue [1] 13/7
review [49] 56/20
66/2 66/10 85/13 95/8
99/2 107/12 115/2
132/20 133/9 138/12
139/14 139/16 139/23}
143/17 143/19 143/23}
145/8 145/21 146/12
146/13 147/13 147/16}
147/20 148/14 148/15}
148/16 151/16 156/19)
157/12 157/14 157/15}
157/24 159/13 165/7
175/10 175/18 176/6
176/8 176/16 176/17
176/22 179/18 1814/5
181/7 181/9 181/10
181/11 186/5
reviewed [2] 85/19
99/15
reviewing [3] 145/22
166/13 173/20
reviews [2] 93/15
153/5
revised [1] 153/2
reviving [1] 184/25
rewording [1] 96/14
reworked [3] 90/24
101/17 103/8
reworking [1] 103/3
rewrite [3] 95/4 96/18)
103/16
rewriting [2] 96/7
96/21
Richard [2] 166/16
166/22
Richard's [1] 165/4
ridiculously [1]
126/14
right [70] 4/12 7/9
16/25 18/4 18/7 24/9
31/16 34/9 35/3 35/5
37/1 37/17 44/4 49/19)
59/5 60/21 61/15
62/14 63/7 63/14
63/25 66/15 66/21
67/3 70/2 71/25 73/2
73/12 75/22 83/24
85/17 93/25 94/6
96/11 96/18 99/13
102/7 103/6 109/1
121/18 123/7 123/14
123/15 124/16 127/22!
133/23 134/16 135/19)
135/21 136/5 156/24
160/14 161/10 161/23)
163/5 165/24 169/18
170/7 170/8 172/9
175/8 176/19 179/22
182/6 184/13 184/16
187/11 190/17 190/20)
190/24
right-hand [1] 49/19
rightly [1] 39/21
risk [82] 3/6 3/17
3/20 3/21 3/22 3/23
4/4 8/25 9/9 13/3 21/2!
21/5 21/22 21/25 22/6
22/10 22/12 22/15
23/4 23/10 23/11
23/18 23/20 24/5 25/1
30/21 56/5 56/7 56/22
56/24 57/1 57/11
57/13 57/17 57/19
57/23 57/24 57/25
72/2 73/20 77/1 77/13}
84/18 85/1 87/1
118/25 119/17 119/18)
120/8 122/23 122/25
123/10 123/14 127/10)
127/16 128/12 128/23)
128/24 128/25 129/14)
130/6 130/12 131/1
133/24 134/2 134/6
134/7 134/12 134/13
134/14 134/15 134/18}
134/19 134/24 134/25)
135/3 135/5 135/8
136/12 170/4 172/11
185/16
Risk/Opps [1] 56/5
risks [20] 32/18
100/17 107/12 107/24)
119/1 119/3 123/2
123/6 123/11 123/24
127/11 128/11 128/22)
129/3 129/6 129/25
132/20 133/22 134/23)
134/23
RMG [2] 120/7
124/21
(73) relationship... - RMG
R
Rob [2] 54/19 54/20
rock [1] 94/9
Rod [1] 24/14
Rod's [1] 101/19
Rodric [22] 139/18
139/20 142/12 145/7
145/17 148/24 150/23)
152/24 159/14 159/22)
159/24 160/12 161/8
161/22 161/23 163/10}
163/23 177/11 178/11
180/9 181/18 187/21
Rodric's [2] 152/4
154/25
role [46] 2/25 3/17
11/8 11/16 15/2 15/6
31/18 41/2 67/12
67/17 67/20 68/5
68/10 68/25 68/25
69/10 70/8 73/23 74/2
74/3 74/13 80/5
103/10 105/10 106/20)
117/19 118/4 121/12
121/19 121/20 121/21
121/23 159/1 161/11
167/6 167/9 167/10
168/4 175/19 176/4
176/10 179/10 180/22)
188/5 188/16 188/24
roles [5] 40/18 70/4
167/11 167/21 168/20)
rolled [1] 52/12
rolling [1] 13/19
Rose [35] 140/2
140/5 142/18 142/23
145/3 148/13 148/24
149/7 149/13 149/18
149/20 150/13 151/12)
152/3 153/9 153/13
153/21 154/1 154/2
154/7 155/15 155/17
156/10 156/23 160/25)
161/16 162/3 162/17
162/21 178/16 179/14}
179/24 180/5 180/6
180/10
Rosie [2] 114/1
114/19
route [1] 133/7
row [1] 56/11
Royal [102] 3/6 4/2
4/21 5/2 5/7 6/14 9/1
9/2 9/4 9/5 9/15 9/25
10/15 11/9 11/11 12/1
12/4 12/9 12/9 12/10
13/24 19/10 19/23
23/12 26/23 27/15
28/21 31/10 31/13
34/5 34/16 36/9 37/3
37/17 37/20 37/22
37/25 38/8 38/10
38/10 38/12 38/16
53/22 54/20 56/18
56/24 57/16 59/15
59/16 113/11 118/13
118/22 119/9 119/11
122/9 122/18 122/22
123/1 124/6 124/18
38/22 38/24 39/5 39/6
39/10 39/16 40/5 40/8)
41/2 42/17 42/25 44/7
44/11 45/3 45/15 49/6
119/12 120/14 120/23)
124/22 126/3 127/10
127/17 128/11 128/21
128/25 129/3 129/24
129/25 131/1 132/17
132/25 133/5 133/6
134/2 134/13 134/19
134/21 135/5 135/10
136/3 157/8
Rule [4] 171/5
Rule 9 [1] 171/5
rules [3] 43/13 43/25
155/19
run [3] 64/15 131/12
182/18
running [8] 7/22 49/1
105/18 105/22 106/6
106/17 107/1 107/20
Ruth [1] 132/15
s
$90 [3] 47/2 47/6
47/13
Sadly [1] 164/3
safeguard [2] 85/15
98/24
safety [3] 82/19
108/17 111/18
said [42] 8/18 8/19
20/20 22/5 26/2 28/13
30/20 32/2 40/17
40/23 48/4 51/8 62/21
73/3 73/14 83/14
87/13 88/16 88/25
92/4 100/16 113/17
115/21 118/12 119/13)
119/23 121/3 123/22
124/8 124/10 126/5
140/9 142/17 145/3
151/3 154/18 161/15
163/4 163/18 163/21
173/17 174/16
said/agreed [1]
121/3
same [7] 9/10 9/22
14/16 32/25 51/8 62/5)
80/12
sampled [1] 140/16
sat [7] 6/3 10/18
23/11 35/18 35/21
40/8 142/10
satisfied [1] 94/15
satisfy [2] 14/25
15/18
satisfying [1] 20/3
saw [23] 9/23 25/16
80/5 96/15 98/20
102/8 102/12 103/23
111/22 127/7 131/22
146/5 160/25 163/12
184/20 185/9 185/10
186/10 188/18
say [95] 1/18 2/3 3/10)
4/16 4/22 5/25 6/25
TIT 7/14 8/2 8/4 8/14
10/10 11/7 12/14
12/16 13/2 13/9 16/15
18/25 22/17 29/1 29/4
32/17 36/11 42/1
44/15 45/6 48/18
49/23 49/24 50/11
50/21 51/17 58/10
58/19 64/16 67/18
73/15 75/14 77/18
81/16 81/23 82/1
85/21 86/9 86/13
87/10 88/2 88/16
88/19 91/19 92/21
93/21 95/25 96/10
100/5 101/13 102/5
105/16 107/21 108/14
109/22 112/7 112/17
114/18 115/11 121/22)
124/25 125/6 132/14
137/3 138/2 141/22
145/16 146/7 148/14
148/23 150/22 151/8
152/5 158/8 165/9
166/11 167/23 169/12
172/21 178/2 179/8
181/21 187/18
saying [18] 8/3 40/9
52/3 57/19 63/4 83/4
84/2 92/14 106/18
108/7 110/18 120/25
130/19 135/21 144/25]
164/2 177/9 183/6
says [75] 3/18 4/24
7/20 16/20 17/7 21/3
21/10 22/11 23/19
24/1 25/6 26/17 32/8
33/6 33/14 35/15 36/5
42/22 47/6 47/7 47/9
49/11 49/25 54/25
56/5 57/5 58/1 70/24
72/4 74/19 78/19
80/14 81/15 82/21
84/12 86/8 86/24
86/24 91/4 91/23 92/2
92/10 93/7 95/5 99/5
101/16 107/10 111/2
114/3 118/20 119/7
120/6 120/19 125/10
125/20 126/13 127/9
129/8 130/10 130/24
131/2 137/17 140/2
33/19 49/23 58/7 80/5)
143/5 147/6 147/11
149/6 149/19 154/8
155/16 155/23 160/3
162/5 165/3 179/19
scale [2] 14/19 46/5
scandal [1] 50/16
scenario [1] 52/20
scenarios [1] 166/24
scheme [1] 188/10
scope [3] 14/16 21/8
scot [2] 83/4 188/20
scot-free [2] 83/4
68/9 68/21 72/8 72/23
Scottish [1] 66/20
screen [8] 32/25 61/6
65/22 67/15 117/8
157/19 173/6 174/1
scroll [56] 23/16
35/24 75/13 78/17
79/5 81/22 83/23 84/2,
84/9 85/5 86/23 87/8
87/19 88/18 91/4 95/2
95/22 96/8 96/9 97/25)
98/4 100/4 105/6
107/8 110/3 111/2
113/25 119/6 119/16
119/21 120/3 122/7
125/8 125/23 130/4
130/10 130/14 136/8
136/10 139/25 142/14)
143/4 144/9 144/10
147/5 148/23 149/5
151/3 154/3 155/12
155/23 157/21 162/4
163/21 165/9 185/13
scrolling [2] 130/13
143/12
scrutinise [1] 106/16
scrutinised [1]
168/16
scrutiny [2] 168/18
175/25
se [3] 132/9 134/3
135/10
seat [1] 122/3
second [83] 26/13
68/23 69/21 70/16
74/18 75/5 75/12
75/14 76/1 76/15
76/19 76/23 77/12
78/2 78/10 79/13
79/22 82/8 83/10
83/13 83/18 85/7
85/10 86/8 94/12 95/3)
98/11 99/7 104/22
104/25 105/3 105/25
108/19 109/3 109/8
117/16 117/18 117/24}
118/2 118/19 119/20
120/17 123/23 124/14}
127/18 127/24 128/16}
128/21 128/25 129/20}
129/22 131/15 131/25]
132/4 132/7 132/19
133/9 133/14 137/22
138/9 140/11 141/18
142/23 145/24 148/12)
148/18 155/9 156/8
156/9 156/21 157/22
158/25 159/7 166/24
167/1 167/5 168/12
173/10 174/9 182/20
183/16 183/18 183/22)
secondhand [1] 66/5
secondly [3] 15/10
25/18 40/7
seconds [1] 109/12
secretary [11] 6/8
6/12 6/13 8/15 24/17
27/22 37/19 43/4
55/20 55/21 126/3
section [30] 17/17
47/6 81/24 83/6 85/6
90/25 98/6 99/3
118/25 119/17 119/18)
120/8 123/10 123/24
127/12 128/9 128/10
128/18 128/18 128/21
129/14 129/24 130/12)
130/21 132/20 133/22!
136/12 140/12 143/12)
147/20
section 6 [1] 140/12
sections [1] 142/14
secured [2] 17/14
174/24
security [6] 5/25 6/2
6/3 16/4 16/11 149/21
Security/Legal [1]
5/25
see [114] 1/3 2/9 4/2
4/9 4/13 8/25 9/10
10/9 12/13 15/10
15/25 16/18 16/25
19/22 20/19 23/15
23/17 24/4 26/13 33/3}
33/20 35/14 35/24
36/3 39/4 41/17 42/7
42/20 43/15 47/6
47/23 47/24 49/18
49/25 50/21 51/12
51/20 52/2 52/7 52/14
53/4 53/9 54/19 56/22I
57/5 57/23 61/5 63/21
64/22 75/13 78/17
79/5 81/14 81/22
81/25 84/2 84/6 84/16)
85/5 85/20 86/24
88/18 89/22 92/19
92/20 94/4 96/8 97/19
97/25 98/4 98/5 99/18}
114/24 117/3 119/17
119/22 120/3 121/9
125/12 125/23 126/7
127/16 127/20 130/4
133/2 133/15 136/9
136/11 142/14 143/4
(74) Rob - see
Ss
144/11 148/23 149/5
153/20 154/3 154/6
157/21 163/9 168/8
176/2 176/9 176/17
176/19 178/14 182/4
185/13 185/17
seeing [4] 26/2 81/4
160/21 166/8
seek [4] 11/15 111/8
132/24 164/4
seeking [3] 53/7
71/12 163/14
seem [5] 33/20 38/21
73/23 89/7 96/11
Seema [7] 78/19
185/3 186/1 186/8
seemed [1] 131/10
seems [17] 9/24 50/1
53/24 69/10 74/3 76/8
77/6 80/19 84/25
88/25 96/20 97/14
117/15 131/14 142/18
148/21 157/24
seen [44] 6/6 19/18
20/8 29/17 46/22
51/13 51/17 55/23
56/6 56/8 58/5 58/8
66/4 66/8 76/22 80/19
82/16 92/19 94/22
95/4 97/1 97/7 103/4
109/23 115/12 126/15)
136/8 137/12 137/21
139/13 139/14 139/15
139/16 141/2 151/18
159/21 161/17 164/4
164/12 173/10 178/1
180/13 184/1 184/24
seismic [1] 133/18
sell [1] 136/2
selling [1] 22/10
send [10] 68/17
81/18 94/2 97/19
101/13 101/19 115/9
123/19 151/1 160/8
sends [1] 165/1
senior [4] 31/10
31/12 59/16 188/4
sense [5] 13/7 28/17
44/5 74/24 184/14
sensible [2] 73/4
153/12
sensitive [4] 129/15
129/18 133/20 138/15)
sensitivities [5]
137/6 165/15 165/22
166/10 166/11
sent [25] 61/5 72/16
72/18 81/15 83/7
see... [24] 144/9
149/15 151/10 153/14}
154/15 155/12 155/16)
182/14 183/13 184/19)
105/5 114/6 114/9
114/9 114/16 119/9
119/9 139/20 141/24
144/10 153/20 156/8
157/3 160/22 161/20
181/17
sentence [10] 65/24
81/25 82/23 83/25
149/2 149/11 181/17
sentences [2] 14/1
132/19
separate [11] 36/7
159/6 165/11 182/8
separated [1] 135/18
separately [1] 153/1
separation [11]
122/18 123/9 124/7
135/25 164/22
September [8] 20/18
23/21 24/6 67/2
132/13 136/7 143/8
144/1
September 2013 [1]
144/1
sequence [1] 102/16
series [2] 50/23
163/15
serious [3] 14/5 14/8
175/17
seriously [2] 59/20
73/7
serve [2] 151/13
178/17
served [1] 45/24
service [6] 21/11
66/15 66/24 66/25
67/9 74/4
services [3] 27/8
34/22 56/18
set [16] 3/25 15/6
19/9 22/25 38/14
40/20 41/12 44/19
62/24 67/16 74/12
102/25 105/18 105/22)
107/1 187/2
set-up [1] 38/14
sets [1] 72/7
setting [3] 94/7
106/16 107/20
settle [1] 59/19
settled [1] 59/12
settlement [2] 56/19
159/10
several [2] 137/12
146/14
Sewell [6] 75/7 77/23
78/18 79/6 80/2
184/20
96/21 98/1 98/8 102/2
108/19 114/24 123/23)
41/12 63/5 73/4 90/14
135/15 158/11 158/18)
133/17 133/20 135/12)
135/15 135/17 135/22)
shall [1] 41/25
shape [2] 39/3 40/10
share [3] 91/21
118/25 119/8
164/10
shareholder [3]
shares [2] 120/15
136/3
sharing [3] 100/6
147/16 176/2
she [59] 73/6 74/19
76/11 79/17 82/13
84/11 84/12 84/25
87/25 88/14 94/6
101/16 103/7 105/5
113/17 114/2 115/11
126/13 134/12 138/2
138/6 139/3 139/4
139/5 139/7 139/8
141/9 141/25 142/3
142/4 142/5 142/6
142/10 143/5 148/4
152/8 152/13 152/17
161/12 161/21 161/21
163/12 165/3 176/21
177/5 177/22 178/3
178/6 179/11 182/13
182/14 187/4
she'd [3] 115/14
138/4 152/10
she'll [1] 177/10
She's [2] 113/16
119/23
ShEx [15] 118/20
120/19 121/14 121/25)
122/2 125/10 163/1
164/12 165/7 165/15
165/21 165/25 166/3
166/4 166/8
short [15] 21/4 42/5
52/24 64/20 72/16
117/1 147/1 147/4
155/14 157/2 158/18
164/15 169/2 169/20
182/4
shortcut [1] 39/20
shortfalls [2] 32/11
32/22
shorthand [1] 169/14
shortly [2] 30/20 84/5]
should [45] 2/14 4/16
14/12 14/14 14/15
20/9 26/23 30/24
39/14 43/4 43/18
55/13 55/13 55/16
56/23 59/20 60/3
60/15 61/4 61/17
61/23 65/4 73/2 82/22
91/9 91/12 91/13
91/20 96/18 108/4
shared [3] 75/6 79/14I
100/13 163/16 164/22
85/5 86/24 86/24 87/6
115/12 115/12 119/20
115/9 119/3 127/3
130/20 131/3 134/22
147/14 155/18 159/3
182/9 188/21 188/24
shouldn't [5] 73/11
93/18 101/19 107/2
169/4
63/22 119/25 147/14
showed [1] 80/20
shown [1] 133/23
sic [1] 86/21
side [14] 14/21 16/1
74/8 74/9 116/14
116/15 120/24 157/21
164/13 167/15
sides [1] 164/16
sifts [1] 146/14
Sight [62] 68/23
69/21 70/17 74/18
76/19 76/23 77/12
78/3 78/10 79/13
79/22 83/10 83/13
83/18 85/7 85/10
98/11 99/7 104/22
105/3 105/25 109/3
117/17 117/24 118/2
123/23 124/15 127/18
127/24 128/16 128/21
128/25 129/21 129/22)
131/15 131/25 132/4
132/7 132/19 133/9
133/14 137/22 138/9
140/11 141/18 142/23}
145/24 148/12 148/18
156/9 156/21 166/24
167/1 173/11 174/9
182/20 183/18 183/22
Sight's [6] 82/8 109/8}
117/18 158/25 159/8
167/6
sights [1] 164/19
sign [1] 143/19
signature [1] 65/12
signed [3] 102/21
103/21 120/25
significance [10]
171/9 171/15 171/16
172/6 172/8 172/20
180/10 180/11 180/12
186/6
significant [29] 12/5
20/15 20/16 29/10
30/8 30/11 44/2 44/8
44/12 45/2 45/17
45/25 46/22 48/12
49/5 59/4 84/22 85/24)
89/9 89/14 103/3
103/16 133/8 133/24
134/6 162/21 170/21
1714/7 188/22
108/12 114/20 114/23)
show [5] 62/24 63/18
16/25 29/2 73/19 74/7I
75/5 75/12 76/1 76/15)
significantly [5] 31/6
42/11 45/19 96/19
96/21
signing [1] 137/16
similar [8] 27/16
52/20 56/21 68/9
78/16 88/20 131/24
138/6
similarly [1] 69/6
Simon [2] 77/22
113/14
simplest [1] 13/24
simply [4] 112/10
127/25 180/23 189/15)
since [8] 11/17 11/22
41/15 55/10 70/4
83/12 98/11 171/12
sincere [1] 126/15
sing [1] 125/14
Singh [1] 179/3
sir [50] 1/3 1/5 1/18
22/3 22/11 24/7 31/12I
31/25 32/4 33/1 34/17
34/19 34/23 40/2
41/11 41/20 42/1 42/7)
42/23 49/9 50/25
58/15 58/17 58/21
60/18 60/25 61/3
61/12 64/3 64/13
64/18 64/22 116/19
117/3 134/17 144/20
168/25 169/14 169/22)
174/19 184/16 186/12)
186/19 186/23 186/25]
187/9 187/14 190/12
190/23 192/6
Sir Alan [3] 49/9
50/25 174/19
Sir Anthony [1]
144/20
Sir Michael [9] 22/3
22/11 24/7 31/12
31/25 34/17 34/19
34/23 42/23
Sir Michael's [2] 32/4I
33/1
sit [4] 6/10 21/25
28/22 29/3
situation [5] 61/20
62/25 63/2 129/16
129/19
situations [1] 17/9
six [2] 49/22 94/12
skill [1] 170/3
skim [3] 16/6 154/12
154/14
Slaughters [5]
119/12 122/11 123/19)
124/12 124/20
sleep [1] 97/14
slightly [18] 23/17
28/3 40/10 63/8 87/8
88/20 95/23 96/10
119/21 125/9 136/6
(75) see... - slightly
Ss
slightly... [7] 143/2
144/10 149/25 157/21
157/23 163/21 165/2
slow [1] 49/1
small [9] 60/10 79/8
80/14 141/11 141/13
165/17 166/11 169/3
170/25
smaller [1] 48/10
SMEs [2] 68/2 69/2
so [274]
softer [1] 76/13
software [3] 48/8
50/14 127/2
sole [1] 100/13
solely [1] 98/13
sol [1] 114/1
solicitors [2] 146/14
156/18
solution [1] 48/9
some [60] 1/25 3/25
7/16 9/23 14/19 29/17
31/9 34/2 40/3 40/20
47/12 48/19 49/1 55/9)
63/10 63/16 71/20
74/25 75/16 77/15
83/1 83/2 87/6 91/12
101/23 104/5 106/4
107/1 111/23 118/8
118/15 119/21 119/25}
121/7 122/4 123/8
123/25 124/10 130/3
133/4 136/21 139/20
140/23 144/18 146/24}
147/1 149/4 154/25
157/25 159/22 159/24)
162/19 167/5 168/25
180/16 180/25 181/14}
181/15 181/19 188/18)
somebody [4] 29/16
51/20 53/25 104/13
someone [8] 5/1
27/17 28/5 33/23
119/25 120/24 142/4
163/8
something [23] 8/5
25/24 34/12 40/16
53/21 59/19 86/1
86/13 89/14 96/5
106/8 112/9 112/15
115/21 142/15 144/12)
144/15 150/20 152/9
154/22 159/6 162/15
172/23
sometimes [2] 76/11
166/2
somewhat [1] 41/9
somewhere [3] 61/22)
62/12 63/9
soon [2] 69/19 81/6
sorry [29] 2/23 7/10
18/5 21/1 22/15 24/6
24/19 28/10 31/21
31/22 36/4 36/20
37/14 47/7 50/25
51/25 57/21 58/22
61/1 69/25 87/22 96/9
96/15 108/20 113/25
129/12 180/3 185/4
185/6
sort [7] 5/25 60/15
62/22 63/19 107/1
111/23 122/4
sorts [1] 150/25
sound [5] 31/16 35/2
55/2 66/6 93/24
sound’ [4] 146/9
147/9 157/16 181/6
sounds [2] 91/15
141/1
South [1] 109/21
space [1] 71/4
span [1] 122/6
Sparrow [7] 137/18
146/23 158/9 161/13
165/4 166/15 173/7
speak [2] 31/21
140/18
speaking [4] 73/18
91/6 97/25 98/4
Special [1] 67/9
specific [19] 31/16
57/3 78/5 80/24 99/7
100/17 102/9 104/9
110/5 112/8 118/16
132/6 144/23 165/15
165/21 171/6 184/11
186/8 186/9
specifically [12] 22/9
66/9 91/9 92/14 101/9)
111/10 119/5 121/11
121/21 151/12 176/24)
178/16
speculating [1] 26/3
speed [3] 69/24
158/14 166/17
spell [1] 180/14
spent [2] 31/7 167/15
spoke [3] 87/14
123/21 125/20
spoken [2] 167/9
183/17
spot [3] 93/15 95/8
96/2
spread [1] 180/22
spreadsheet [1] 56/4
square [2] 46/24
149/1
squarely [1] 167/16
stab [1] 181/2
staff [13] 48/20 67/12
68/25 70/1 89/9
121/12 167/10 167/14)
175/9 177/21 178/7
180/17 180/22
stage [18] 9/25 49/2
51/22 55/22 76/22
81/8 82/7 82/19
105/20 113/20 129/6
146/2 151/21 157/9
159/17 170/7 170/16
176/11
stake [3] 13/3 13/4
82/24
stakeholder [2] 71/1
72/14
stakeholders [2]
67/24 77/3
stand [1] 175/13
standard [1] 132/21
start [16] 1/25 15/23
31/11 53/8 67/16
74/16 81/7 83/13 86/1
95/3 98/11 109/5
120/17 126/10 145/5
190/21
started [2] 33/19
142/8
starting [1] 190/17
starts [1] 36/3
state [7] 44/20 47/24
65/2 82/23 161/19
185/24 185/24
stated [1] 162/13
statement [44] 1/10
1/11 1/12 10/6 11/6
22/4 32/4 33/13 35/13
44/15 45/5 49/10 65/5
65/7 65/14 65/18 66/4
66/11 66/12 67/15
69/10 74/11 77/24
78/19 89/6 91/21
93/11 102/24 103/9
110/6 121/13 122/24
127/5 127/6 162/10
170/16 170/17 170/20
171/2 174/1 183/7
184/20 186/17 190/14]
statements [10] 77/1
91/18 113/1 113/5
133/4 137/20 140/16
171/4 171/11 173/9
states [2] 112/10
127/12
status [4] 76/17
120/22 155/14 156/1
statutory [1] 44/17
steer [2] 114/23
115/15
steering [2] 77/15
158/17
Stein [5] 61/12 61/13
61/15 61/16 192/8
step [5] 72/11 116/1
116/7 178/22 189/5
stepping [1] 168/8
steps [5] 14/25 48/12
101/11 153/6 161/4
STEVENS [5] 1/22
59/23 61/1 64/2 192/4
sticking [1] 123/22
still [22] 42/7 52/10
52/12 52/15 70/5 73/1
79/4 83/1 112/22
121/9 123/24 125/19
132/20 151/14 151/17]
151/18 155/6 178/18
178/25 179/4 189/7
190/21
stonewalling [1]
181/11
stories [1] 50/13
story [2] 73/19
111/17
strange [1] 60/19
strangely [1] 149/25
strapline [1] 184/2
strategic [9] 11/10
12/18 12/22 13/9
13/12 13/13 13/18
13/22 29/22
strategy [6] 70/2 70/9
167/15 167/18 168/22
187/24
strengthening [2]
103/25 104/2
stress [1] 1/15
strong [8] 88/8 112/2
112/9 112/12 146/11
159/2 172/5 181/7
strongly [2] 91/15
91/16
struck [2] 25/25
165/11
structure [8] 38/15
39/2 39/12 40/7 40/9
40/12 41/7 41/10
structured [3] 37/25
103/17 164/18
structures [4] 3/1 3/5
4/10 33/17
stuck [1] 76/13
style [1] 109/20
sub [3] 16/11 50/5
188/7
subcommittees [3]
3/7 10/17 15/23
subject [32] 1/10
68/3 68/18 69/7 69/11
73/22 77/25 78/4 78/6
78/8 85/8 87/14 87/15)
87/15 89/7 89/12
89/15 89/20 90/3
96/22 101/22 101/24
103/5 103/22 104/11
104/20 145/7 145/22
155/19 156/20 175/22,
179/11
subjective [1] 83/11
submitted [1] 118/1
submitting [1] 98/18
subpostmaster [16]
5/1 6/23 14/6 14/9
43/19 50/4 50/8 52/10)
52/15 83/3 83/13
83/16 127/13 128/1
188/1 188/22
subpostmasters [40]
2/15 2/16 4/20 5/15
5/23 9/16 10/13 11/3
11/25 12/6 19/17
20/14 22/18 30/17
31/25 32/11 32/20
32/21 35/11 39/8
42/10 44/6 44/11
50/17 61/22 63/3
70/10 83/12 86/3
98/18 99/25 109/13
112/10 127/4 174/6
174/20 175/5 188/6
188/8 188/19
subsequent [3]
49/20 167/11 167/21
subsequently [1]
157/10
subset [1] 34/5
subsidiary [1] 34/22
substance [3] 67/25
103/20 147/3
substantial [2] 60/1
104/5
substantive [6] 65/10)
69/8 84/11 114/12
114/13 114/20
succeed [1] 59/2
successful [6] 84/20
85/2 87/4 88/2 88/5
92/21
succinct [2] 68/7
68/15
such [20] 10/24
22/22 37/5 47/11
48/24 50/10 67/23
69/2 71/7 71/23 72/16I
85/15 102/8 104/15
119/3 132/22 155/5
156/2 188/6 188/19
suchlike [1] 188/21
sued [1] 60/8
sufficiently [1] 142/2
suggest [17] 89/2
95/13 107/1 119/3
130/22 131/14 149/4
151/5 154/17 160/8
165/7 171/21 172/9
179/14 180/17 182/12)
183/20
suggested [7] 14/18
59/10 59/17 100/16
105/6 179/24 181/10
suggesting [4]
106/24 107/6 140/12
176/11
suggestion [9] 43/3
82/3 82/15 88/21
94/10 102/14 106/7
118/8 119/11
suggestions [1]
(76) slightly... - suggestions
Ss
suggestions... [1]
90/10
suggestive [4]
149/23 150/2 150/16
154/18
suggests [5] 92/8
92/11 127/2 154/20
162/8
suitable [2] 22/16
100/21
suitably [1] 68/6
suits [4] 169/6
sum [1] 60/10
summaries [1]
139/21
summarise [3] 9/14
43/9 160/13
summarised [2]
139/16 139/17
summarises [1]
50/16
summarising [1] 4/8
summary [13] 40/1
66/5 68/20 73/25 74/1
90/24 96/23 145/13
149/18 153/6 157/17
190/1 190/4
summer [1] 77/4
summing [1] 127/22
summing-up [1]
127/22
sunk [4] 144/12
supervision [2]
35/15 37/19
support [17] 44/10
62/9 91/8 93/22 94/10
127/3 127/14 127/19
127/21 128/1 128/4
128/5 128/6 149/24
150/3 150/4 166/25
support/cover [1]
166/25
supporting [2] 38/25
144/17
supports [2] 38/12
119/2
suppose [2] 28/19
63/1
suppress [1] 170/3
suppressing [2]
170/9 183/20
sure [39] 2/25 3/19
6/11 14/14 26/1 27/13
27/25 41/24 51/13
51/23 59/24 68/15
100/15 100/17 101/9
105/23 117/20 118/14}
121/16 123/15 125/4
131/7 132/2 134/1
134/3 135/17 144/3
150/5 150/19 153/24
154/12 154/23 161/5
166/12 170/11 179/10)
179/19 186/17 188/19)
surely [3] 54/7
133/22 172/12
surprised [1] 41/9
surprising [1] 40/11
survivors [1] 187/19
Susan [51] 77/22
81/14 81/16 81/17
82/17 83/25 84/2
84/10 86/7 86/17
86/23 87/15 88/7 90/3
90/12 96/3 97/22
101/16 102/17 107/15)
108/21 108/24 113/15)
114/10 114/20 114/23}
114/25 115/13 115/19)
115/24 116/5 116/8
116/14 118/22 119/10)
122/10 123/17 124/19)
125/1 125/3 138/5
139/1 139/6 142/5
142/10 143/5 163/18
163/23 177/23 177/24}
178/2
suspected [1] 5/22
Swinson [1] 163/12
sworn [3] 1/19 1/21
192/2
synthesis [3] 105/12
147/2 181/14
synthesise [1] 69/2
synthesising [1]
73/21
system [40] 2/6 5/16
5/19 13/20 33/10
45/21 46/4 46/5 46/16
ATINT 48/22 52/11
55/12 61/24 62/3
82/24 86/4 93/25
94/12 98/13 98/23
99/11 99/16 99/20
103/12 103/15 109/15)
110/6 110/12 110/24
112/21 126/24 126/25)
127/20 128/6 128/7
128/17 140/18 140/19)
182/22
systemic [10] 13/16
14/20 30/15 44/9 49/3
55/9 59/3 91/8 93/12
94/10
systems [3] 46/18
83/14 112/24
T
tab [1] 56/5
tabs [1] 160/16
tactics [1] 76/5
tailor [1] 151/7
take [41] 8/11 8/14
11/16 13/25 14/25
22/17 26/5 27/9 31/23
35/9 41/11 60/20
60/21 64/14 82/13
82/14 85/14 86/12
89/9 89/11 97/1 98/23)
100/25 116/19 120/5
126/8 132/23 146/17
151/5 152/11 152/18
153/7 156/11 157/6
161/4 163/25 169/2
169/16 174/13 184/23}
190/21
taken [18] 51/19 52/4
59/20 62/20 73/11
83/16 99/24 100/25
124/10 124/23 125/2
125/21 135/15 157/15}
161/12 167/22 168/13}
183/4
takes [1] 83/21
taking [25] 11/17
11/23 15/4 19/2 19/4
19/6 19/11 19/13
20/10 62/4 63/19
68/13 71/6 73/7 74/12
75/2 81/6 90/9 107/2
125/17 145/21 153/23
174/10 184/2 188/14
talk [2] 3/9 61/18
talked [2] 46/3
118/22
talking [6] 18/1 35/15)
37/15 117/9 128/12
129/25
talks [5] 18/13 91/17
162/3 173/4 173/16
target [2] 68/7 68/14
tasked [2] 79/16 81/2
taxpayer [1] 45/12
team [85] 3/4 5/21
6/2 6/3 6/9 6/10 6/25
10/21 12/21 24/12
28/22 32/23 33/17
35/19 35/21 36/7
36/10 37/2 37/8 37/21
37/22 38/5 38/16
38/17 38/18 38/19
38/25 39/2 39/6 40/8
42/15 42/15 54/20
71/20 72/12 72/19
75/6 76/22 76/25
77/12 77/12 77/19
77/21 77/22 78/11
79/15 81/2 82/18
88/12 90/2 92/18
100/16 101/3 105/13
107/15 108/21 120/9
121/22 122/10 126/6
126/16 130/7 130/8
130/18 132/15 138/5
138/23 139/12 141/9
145/25 147/2 149/21
151/24 152/17 155/7
164/12 170/2 170/6
176/1 176/8 177/19
178/23 182/8 182/24
183/4
teams [8] 6/7 20/10
29/23 37/24 121/15
121/25 157/3 177/7
technical [3] 46/11
67/25 154/14
teething [1] 164/20
telephone [1] 102/11
tell [2] 17/25 25/4
telling [4] 59/14
171/14 176/7 177/3
ten [2] 169/11 169/16
tend [3] 20/16 30/1
168/20
tended [4] 147/25
tends [1] 62/16
tensions [2] 166/2
177/24
term [8] 14/9 27/11
122/21 124/5 176/20
176/22 176/23 187/20}
terms [11] 3/20 14/22)
55/14 59/11 67/1 68/9)
85/8 113/13 135/17
143/22 171/18
territory [1] 150/7
Tessa [1] 73/16
test [2] 83/2 149/8
tested [1] 45/21
text [16] 88/23 145/7
145/17 145/19 147/1
148/9 151/10 151/16
152/5 153/2 154/25
158/9 158/10 178/14
181/13 181/22
than [27] 16/11 20/3
37/4 42/24 45/19
46/10 46/22 49/16
60/13 64/9 71/10 74/7,
93/9 94/13 100/19
106/4 106/21 107/22
112/15 122/14 125/16
132/18 142/19 142/25}
150/12 151/19 152/5
thank [63] 1/4 1/23
1/23 5/12 21/2 23/17
26/10 28/25 34/25
36/2 42/3 42/8 44/13
48/14 56/2 58/14
61/10 63/25 64/1 64/4,
64/12 64/13 64/18
64/23 65/4 66/11
69/15 69/25 70/12
78/15 81/13 84/8
90/21 114/1 116/18
116/24 117/4 117/5
118/10 119/22 119/24,
120/16 123/16 126/11
136/5 137/10 145/6
157/20 161/25 162/24,
167/8 168/24 169/22
169/25 186/13 186/25}
187/14 189/10 189/11
190/10 190/13 190/16
190/23
thanked [1] 100/5
thanks [13] 85/22
90/23 96/1 97/22
114/19 120/12 125/1
125/16 125/24 148/24)
150/23 153/1 187/11
that [1022]
that's [81] 1/20 2/3
2/9 2/23 4/12 8/15
8/17 9/8 9/17 9/20
11/24 13/4 16/15
16/16 16/17 21/14
22/25 23/17 28/8 29/7
29/20 36/1 39/9 41/11
41/21 42/23 46/4
47/23 49/16 49/19
53/11 54/6 54/23
57/19 61/13 64/3
65/11 68/21 69/5 74/1
77/8 85/24 90/25 91/3}
95/17 96/24 102/4
107/4 108/7 110/12
118/23 120/11 120/21
125/24 134/17 136/22)
138/18 139/24 144/12)
144/20 146/10 155/9
155/11 156/7 156/12
157/20 158/10 167/3
167/6 168/10 171/23
172/2 172/4 182/9
183/20 183/23 186/2
186/12 186/23 186/24)
190/19
theft [2] 5/22 32/20
their [23] 9/4 15/20
29/24 37/10 37/12
42/14 56/20 76/5
85/18 99/14 106/20
117/17 117/24 118/4
120/15 123/22 131/23)
131/25 147/3 157/4
163/25 167/2 188/24
them [45] 37/5 43/9
46/8 49/15 49/22
51/12 60/24 67/8
67/10 67/11 75/10
76/2 76/3 78/12 86/20)
87/4 89/20 94/8 96/4
99/21 101/5 102/11
106/19 109/15 109/24)
110/7 110/19 111/25
112/5 118/4 119/9
121/18 121/18 122/12)
124/14 129/2 129/5
134/11 140/13 140/17)
147/23 163/2 165/16
179/10 188/23
theme [1] 48/1
themselves [2] 81/1
141/17
then [95] 2/6 2/24 3/9)
3/13 3/14 4/17 5/5
6/19 7/19 8/9 13/14
(77) suggestions... - then
T
then... [84] 15/4
21/15 26/16 29/22
30/16 32/25 34/8
43/13 49/20 50/11
51/13 51/23 52/4
52/12 52/17 52/21
53/4 56/17 58/8 60/3
70/4 70/4 72/4 72/8
75/11 81/5 82/21 83/6
83/20 83/23 84/2
84/11 85/5 91/23
94/21 99/3 99/18
101/13 112/24 116/2
119/6 119/17 120/11
130/24 131/2 131/5
135/19 137/17 140/1
142/11 146/22 146/25)
147/3 147/11 148/1
151/8 152/13 152/16
158/21 159/9 160/2
160/8 160/24 161/13
163/21 164/2 165/8
167/4 169/2 171/12
177/10 181/15 181/15
183/24 184/1 185/7
there [201]
there'd [3] 59/9 80/25)
86/17
there's [30] 20/6
26/17 29/13 36/3 40/3
46/2 49/3 49/5 50/23
50/25 50/25 52/7 54/3,
58/23 65/17 78/3
90/14 95/22 96/8 98/5
99/3 106/18 118/6
143/12 145/6 155/13
163/15 168/5 173/5
183/24
thereafter [2] 41/13
43/17
therefore [13] 3/3
10/2 20/8 45/20 93/16
119/2 128/8 130/11
149/10 157/3 174/18
179/12 186/3
these [34] 7/21 9/23
32/24 38/21 39/22
39/24 40/5 41/7 43/23,
46/17 47/21 48/12
49/12 55/7 60/12 68/1
79/16 83/11 86/12
86/16 99/23 105/19
123/8 140/17 147/15
151/24 157/2 157/10
159/4 159/16 159/25
161/14 161/21 180/25)
they [64] 2/20 2/21
6/7 6/8 23/25 29/15
29/15 36/14 36/15
37/7 37/10 37/21
35/22 36/4 39/15 40/7
62/3 64/15 68/17 69/2
38/21 41/9 47/25
48/24 51/9 51/10
70/22 76/1 77/1 81/16
85/2 85/8 85/17 88/12
89/1 89/16 90/8 92/19
92/20 95/12 99/13
99/24 100/7 102/22
108/12 109/15 118/4
121/8 121/15 121/16
121/17 122/2 124/20
128/25 129/3 131/9
133/2 133/7 133/13
133/16 140/11 146/17)
157/6 159/3 163/7
163/8 163/13 164/3
164/13 168/17 175/6
175/24
they'd [1] 85/2
they'll [1] 164/5
they're [6] 12/1 90/10
90/11 123/15 123/24
163/18
thing [11] 3/25 9/22
39/14 40/20 45/25
48/5 48/6 61/4 109/16
148/5 152/15
thing's [1] 51/12
things [21] 7/17 7/18
8/1 19/20 20/7 27/10
29/16 30/1 49/1 63/1
90/10 90/11 103/1
107/2 107/3 151/13
160/8 166/18 178/17
188/6 188/18
think [288]
thinking [4] 98/18
135/4 154/15 188/14
third [4] 42/20 90/19
156/16 168/19
this [414]
those [69] 1/6 3/7 3/8
4/20 7/4 7/7 7/8 7/11
7/18 8/2 9/9 10/13
12/20 14/11 15/4
17/13 23/1 23/22 24/2
29/1 29/9 29/23 30/1
30/8 31/5 31/6 33/7
33/11 38/13 38/23
44/24 54/7 55/13
58/15 62/2 62/10
62/15 63/9 70/19
71/15 72/17 74/11
75/9 80/17 80/23
84/19 86/15 87/3 88/1
90/10 93/14 98/20
108/17 112/13 118/5
121/10 122/16 137/5
138/17 146/16 153/7
153/24 156/14 158/6
158/7 160/25 174/15
182/23 188/23
though [21] 18/2
23/23 33/20 62/25
63/2 73/23 76/8 77/6
77/6 84/25 86/22
88/25 89/7 91/15
96/20 97/14 102/23
134/5 153/25 154/6
157/24
thought [12] 8/6 8/19
18/12 37/21 47/1
54/15 57/25 73/1
111/5 130/6 151/4
154/22
thoughtful [1] 74/23
thoughts [3] 74/21
88/19 117/23
thousands [1] 51/9
threaten [1] 76/2
three [7] 16/1 16/19
33/7 79/8 94/7 154/6
165/13
through [26] 1/15
3/22 7/12 8/5 8/11
12/10 15/11 46/8 62/2
62/3 65/25 89/3 94/3
95/14 97/19 99/8
131/8 131/10 134/10
158/2 165/18 167/24
181/2 183/1 184/14
185/23
throughout [4] 36/18
36/21 74/23 89/6
Thursday [1] 160/4
Tim [4] 120/19
121/11 122/8 125/24
time [137] 3/9 3/9
4/19 7/8 7/12 7/22
9/19 11/2 14/17 16/14
17/23 18/2 19/4 19/6
19/25 24/25 25/25
26/1 26/6 26/13 30/12
30/18 30/22 31/7 33/1
34/10 34/13 37/18
39/12 40/7 40/17 41/8
41/11 41/24 44/11
45/14 45/19 45/25
47/11 48/2 48/25
49/21 51/2 56/9 58/6
60/22 64/15 66/3
68/11 68/14 70/13
70/16 70/19 71/6
71/11 72/19 75/2 75/4
75/20 78/16 79/12
79/25 80/1 80/9 89/25)
92/15 92/18 94/3
96/19 100/23 103/13
106/2 108/5 108/15
110/8 110/15 111/14
111/24 112/3 112/4
112/17 112/18 112/21
113/12 114/22 115/5
115/17 117/15 117/22
117/25 120/22 121/6
122/18 129/2 131/11
131/12 135/3 136/6
136/19 137/9 139/19
141/3 143/2 144/1
144/24 146/5 147/15
154/11 154/22 155/4
171/25 172/8 172/10
172/21 173/24 176/3
177/15 180/15 182/11
182/23 182/25 184/11
186/4 189/5 190/9
time/status [1]
120/22
timeline [1] 45/10
times [2] 137/13
176/23
timing [3] 41/17
102/23 113/13
today [14] 1/5 1/17
9/21 30/14 33/19
41/17 125/21 160/6
167/9 187/19 188/11
188/15 188/23 190/15]
together [9] 21/13
33/7 71/3 81/17 96/14)
103/14 105/14 160/1
180/6
told [12] 18/8 45/23
48/23 126/18 131/12
170/23 171/17 172/24}
175/2 177/22 179/20
187/4
tomorrow [4] 114/7
151/5 151/9 160/5
tomorrow's [1]
158/17
tone [1] 132/21
tonight [1] 81/19
Tony [2] 16/4 158/23
too [8] 92/7 94/17
94/17 102/21 106/20
133/6 169/4 178/3
took [16] 45/18 59/24
77/24 78/24 80/7
87/24 133/11 152/11
157/22 158/10 160/17,
162/2 178/10 178/22
179/17 181/16
top [15] 26/16 30/4
49/19 50/23 79/5
80/13 90/17 101/15
105/6 108/4 112/13
131/5 165/3 172/18
176/4
topic [7] 42/9 68/5
68/16 80/8 118/11
165/11 171/6
topics [11] 41/13
102/8 102/9 152/17
161/21 162/24 175/21
180/20 180/23 180/25}
182/3
totally [2] 176/4
176/10
155/25 160/19 162/23}
164/18 167/14 168/25}
171/10 171/15 171/16)
172/15 172/17 172/20}
touch [2] 118/21
177/11
tourism [1] 54/4
tournament [1] 54/3
towards [2] 70/25
117/16
tragedy [2] 13/15
44/8
training [14] 92/6
93/8 93/9 127/3
127/13 127/19 127/21
128/1 128/3 128/5
128/5 149/23 150/3
150/4
transaction [1] 44/16
transactions [4]
46/17 94/13 94/25
126/24
transcriber [2] 41/22
169/7
transcript [6] 1/12
2/2 2/5 8/11 16/8 33/3}
Transformation [1]
165/5
tray [1] 137/16
Treasury [2] 66/19
114/15
treat [2] 85/11 98/25
trial [1] 184/1
trigger [1] 58/3
true [3] 44/20 50/15
65/14
truly [1] 94/16
truth [2] 172/3 177/3
try [3] 96/4 121/9
163/25
trying [7] 28/13 50/1
57/4 76/6 123/13
131/24 185/23
turn [55] 2/8 3/13
4/16 10/6 16/3 20/21
22/14 23/16 25/5 26/6
26/16 32/7 34/25
35/23 36/1 45/5 47/4
49/11 52/14 65/10
70/12 70/14 72/21
74/16 76/1 78/15
80/12 90/15 90/19
95/24 97/13 100/3
101/15 104/23 104/25)
105/4 109/4 118/18
119/18 120/16 123/16)
125/8 126/10 137/10
139/25 140/8 142/16
143/1 145/5 152/24
153/22 158/4 161/25
163/2 164/23
turned [3] 8/9 25/13
111/17
Turning [1] 68/21
TV [1] 109/20
two [28] 2/4 31/5
31/6 49/18 61/12
61/13 64/6 69/22
(78) then... - two
T
two... [20] 72/17 75/4
79/12 80/17 93/14
94/8 96/13 96/20
99/21 109/19 135/18
140/11 140/17 141/17)
143/2 143/9 147/8
162/24 164/11 190/17)
two pages [1] 2/4
type [7] 9/10 48/5
48/6 112/24 137/6
148/5 178/5
types [4] 22/22 62/15
100/22 118/5
typical [1] 164/7
typically [1] 68/1
U
UK [2] 45/11 66/19
UKGI [2] 164/7
164/10
UKGI00001852 [1]
163/3
UKGI00001916 [1]
118/18
UKGI00002065 [1]
125/8
UKLA [1] 126/18
ultimate [3] 148/9
156/12 157/17
ultimately [4] 33/18
144/19 160/16 189/9
unable [1] 131/9
unaware [1] 142/24
uncharacteristic [1]
111/20
unclear [3] 104/4
131/10 173/3
under [11] 16/3
17/17 37/19 99/20
128/9 128/18 130/18
130/20 130/21 134/23)
172/25
underline [1] 91/7
underlying [3] 80/23
149/16 161/19
undermine [3]
110/25 112/20 149/8
undermined [3]
112/23 137/21 173/10)
understand [17] 38/4
41/9 59/5 62/14 66/8
75/10 121/2 124/22
130/22 132/16 134/9
144/8 171/12 180/11
180/12 180/21 180/24}
understanding [16]
19/3 19/5 21/21 37/18
37/23 55/1 74/4 81/2
134/4 144/6 166/23
168/23 172/15 172/21
173/1 173/23
understands [1]
166/17
understood [7] 64/7
106/21 123/15 129/2
134/18 138/11 173/19)
undertaken [1] 86/14
undertaking [1] 25/7
underway [2] 71/11
80/25
undiscovered [1]
100/2
unearthed [1] 171/25
unfair [2] 78/24
111/1
unfairly [1] 94/18
unfairness [1]
174/20
unfolding [1] 89/23
unfortunately [2]
64/6 150/23
unfounded [1]
112/18
unhelpful [5] 100/9
100/12 100/14 101/6
141/15
unilaterally [3] 89/25
103/20 164/6
union [1] 43/10
unions [1] 132/24
unique [5] 1/10 62/23
62/24 62/25 63/1
university [1] 66/14
unknown [1] 157/7
unless [4] 1/18 19/21
53/23 100/10
unlikely [1] 156/3
unsafe [15] 99/8
137/19 159/19 170/13}
170/15 170/19 170/22)
172/12 173/8 175/2
175/4 179/21 182/10
182/13 186/6
unsound [1] 108/6
unstructured [1]
164/15
unsure [1] 73/20
until [8] 31/14 40/25
64/15 161/18 162/17
162/18 180/12 191/1
unusual [8] 38/8
38/11 38/15 38/17
39/2 40/10 46/4 63/2
Unusually [1] 131/9
unvarnished [1]
118/25
up [108] 2/2 2/3 3/2
4/4 10/1 10/3 11/20
12/15 15/7 16/1 16/25
19/2 19/19 19/22
20/11 20/13 20/15
22/4 22/25 30/1 30/4
30/19 31/21 32/4 32/5)
32/25 38/14 48/15
49/11 51/6 51/7 52/6
52/23 55/16 61/4
62/16 63/12 65/22
67/15 69/23 75/13
79/5 79/11 79/19 80/4
81/4 81/22 83/23 84/2
87/8 87/19 88/18 95/2
96/8 97/7 99/23
103/25 105/6 111/2
117/7 117/20 119/6
119/21 121/17 122/7
125/7 125/23 126/5
127/22 129/15 129/18
130/4 130/10 130/13
130/14 131/2 131/13
144/6 144/9 144/10
144/16 144/23 147/5
148/23 149/5 151/3
151/9 151/23 155/8
157/18 158/14 158/18!
160/18 161/18 163/7
163/21 165/4 165/9
166/17 168/7 170/12
173/6 174/1 179/20
182/18 185/13 187/9
189/3
update [11] 52/8
69/21 72/9 76/17
105/2 107/18 115/22
116/3 123/21 153/5
158/21
updated [2] 121/6
138/4
updates [2] 67/24
116/4
updating [1] 101/20
upfront [1] 92/3
uploaded [1] 66/12
us [33] 9/18 9/21
17/18 27/2 38/3 42/7
51/5 51/10 62/14
65/20 66/23 71/25
75/1 77/19 84/23 88/3
88/4 88/12 96/18 99/7
111/25 112/5 113/16
121/5 124/21 130/2
134/25 138/6 146/11
148/15 165/20 169/1
181/6
use [10] 2/4 50/1
59/10 84/16 95/20
97/4 115/17 121/8
128/7 163/8
used [10] 17/11
27/12 37/21 44/16
44/24 126/24 162/11
170/3 176/20 180/1
useful [3] 121/1
159/25 160/4
user [4] 93/18 93/18
93/20 93/22
uses [1] 147/9
using [1] 155/21
usually [2] 12/17
53/22
Vv
validity [2] 82/4
82/10
value [3] 45/11 45/22
168/14
variety [1] 47/15
various [5] 10/8 55/5
70/4 158/7 158/21
Vennells [59] 67/13
67/22 69/4 73/11
73/24 74/13 74/19
76/9 78/1 80/10 81/9
97/5 98/9 100/4
103/11 105/1 114/5
114/21 115/4 119/20
120/4 120/11 126/8
126/12 127/9 128/14
130/10 130/24 131/5
134/11 137/14 138/20
139/10 141/24 143/3
144/9 144/21 144/24
145/10 160/14 161/4
165/1 170/18 170/23
172/1 172/24 173/3
174/8 175/2 176/20
177/22 178/2 181/20
182/12 184/18 187/4
187/20 188/17 190/7
Vennells' [3] 68/10
72/19 185/24
verbal [3] 138/3
141/22 148/2
verbally [1] 139/12
verbatim [1] 174/2
verify [1] 17/15
version [8] 89/19
91/5 92/7 94/2 98/8
99/5 103/5 154/2
versions [1] 153/25
versus [2] 111/25
112/5
very [72] 14/4 14/8
26/3 32/6 38/22 41/6
41/6 44/12 46/4 46/19
51/16 59/20 60/1 63/2
64/10 64/23 66/11
69/19 75/25 76/17
78/16 89/24 92/6
101/25 102/6 102/25
103/4 110/15 110/21
110/22 111/11 116/24}
117/5 119/1 119/24
120/8 125/24 133/13
133/24 135/7 135/10
139/24 141/19 142/18}
147/25 149/11 150/23
153/18 155/3 158/12
161/18 162/16 162/20}
162/22 162/24 164/17]
167/16 168/6 169/3
170/21 1714/7 172/7
172/9 175/17 179/15
180/14 181/3 181/3
182/3 189/15 190/8
190/10
via [6] 55/16 61/19
62/1 83/11 85/8 136/9
victims [2] 25/10
25/20
view [24] 22/16 26/19)
33/24 44/20 58/3
60/15 77/6 77/9 77/10
82/17 91/7 108/5
115/1 118/25 127/24
128/15 141/9 143/10
147/12 152/18 153/18)
157/11 159/20 161/1
viewed [2] 138/16
173/22
views [3] 73/22 94/6
181/20
visit [1] 48/16
Vital [4] 21/17
voice [1] 148/4
volume [2] 26/20
27/4
volunteer [2] 171/8
172/2
WwW
wait [1] 125/14
waiting [2] 27/6
187/2
wall [1] 126/17
want [30] 1/25 15/22
16/6 31/9 40/16 44/14)
51/17 56/3 88/11 91/6I
100/20 121/7 125/14
129/10 131/7 137/24
143/18 151/20 169/10}
173/12 173/14 173/25)
177/1 178/9 178/9
181/2 182/10 186/19
189/15 190/21
wanted [8] 42/9 61/1
101/1 118/21 139/3
139/4 139/8 142/4
warranted [1] 182/7
was [540]
wasn't [49] 14/24
20/13 31/1 34/8 40/23
58/18 77/5 86/19
108/5 108/7 108/16
108/16 111/14 113/10)
113/10 113/12 113/22!
115/18 124/9 127/5
132/4 134/4 134/19
135/9 137/1 137/8
138/15 138/16 139/6
141/19 142/8 150/5
150/11 150/19 152/8
154/21 162/17 162/22!
164/17 170/14 173/22)
176/1 177/25 180/24
182/5 182/6 186/17
190/2 190/8
watch [2] 165/17
(79) two... - watch
Ww
watch... [1] 166/14
watching [1] 1/7
watered [1] 148/20
Watt [6] 169/4 169/23
187/13 187/15 189/11
192/16
way [19] 13/17 16/14
22/25 39/2 40/10
46/18 60/19 62/1
63/12 66/14 84/9
102/7 102/20 111/1
132/5 154/7 162/22
164/9 164/15
we [468]
we'd [7] 34/24 39/18
47/23 47/23 129/20
159/21 178/5
we'll [13] 33/3 41/12
61/18 91/2 109/17
118/14 148/8 149/1
149/2 151/22 152/16
152/23 169/11
we're [21] 60/7 62/22
62/23 73/7 76/6 76/13,
86/10 87/10 89/11
90/9 91/1 92/22 95/4
104/25 108/24 110/21
123/13 142/15 159/11
164/25 187/2
we've [17] 7/12 24/15]
67/7 92/19 94/22
119/8 134/10 138/14
144/5 158/7 164/12
167/9 169/7 176/1
183/1 184/1 188/15
weak [2] 91/5 103/24
weakening [1] 85/24
weapons [1] 121/7
website [3] 1/13
66/13 109/24
Wednesday [1] 160/5I
week [8] 53/3 94/14
107/18 114/16 115/22)
163/22 186/5 190/17
week's [1] 165/6
weekend [1] 129/11
Weekly [1] 69/17
weeks [5] 69/22
117/19 122/12 146/6
174/7
weigh [2] 31/6 52/23
weight [1] 154/25
welded [1] 180/6
well [43] 2/7 4/19
6/19 13/11 16/14 26/1
29/20 30/12 37/10
37/23 39/9 40/13
50/22 57/5 57/13
57/20 58/7 62/10
62/20 62/25 63/18
81/15 87/18 102/24
105/10 106/23 134/3
153/2 164/17 165/8
167/3 167/13 169/6
173/25 176/5 176/19
178/22 183/1 183/17
183/22 184/13 184/22)
190/13
well-connected [1]
176/5
went [5] 49/21
103/14 148/7 158/11
161/2
were [191] 4/3 4/10
4/19 4/20 4/25 5/6
5/14 5/14 7/7 7/9 7/12
7/15 7/21 7/22 7/25
8/1 8/2 8/6 9/23 11/12
11/15 12/2 12/4 12/7
13/16 13/19 14/4 15/3
15/4 15/17 17/14
18/15 18/20 18/24
19/2 19/4 19/9 19/20
19/23 20/4 20/8 20/9
20/10 21/12 23/25
30/8 34/12 34/20 36/6)
36/8 37/3 37/25 37/25)
38/14 39/1 39/25
42/15 47/16 47/17
47/18 48/20 48/21
48/23 48/23 48/24
48/25 50/17 51/21
52/1 53/17 55/6 55/7
55/10 59/18 60/11
61/6 67/12 70/20
70/22 71/5 71/10 74/6)
74123 74/24 75/5
75/23 76/23 76/23
77/12 77/13 77/19
78/11 79/12 81/2
81/25 82/7 86/16
89/16 92/18 97/17
100/13 100/22 101/12)
102/25 103/18 103/25)
107/19 108/24 110/16)
112/25 113/20 115/16)
115/19 117/9 117/10
117/12 118/5 121/15
121/20 122/16 122/23)
122/24 123/6 128/24
128/25 130/7 131/9
131/11 135/3 135/4
135/10 136/15 136/17)
137/3 137/5 138/8
141/3 141/25 142/1
143/19 144/1 144/25
150/6 152/19 161/18
162/9 162/13 162/15
163/4 163/13 164/11
164/16 166/1 166/9
170/2 170/9 170/12
170/13 170/23 171/2
171/16 171/21 172/1
172/24 173/20 174/12)
175/2 175/8 175/24
176/11 176/12 176/13}
176/23 177/8 177/9
177/21 178/3 178/7
178/20 179/6 179/19
179/19 179/25 180/20
181/21 182/22 183/22)
186/3 186/6 187/4
189/18
weren't [11] 1/14
7/15 18/2 18/7 67/9
104/1 118/12 121/16
170/5 170/10 171/3
West [2] 78/21 183/9
what [171] 3/16 7/14
8/2 8/3 8/4 8/17 11/22
13/10 15/15 15/22
16/16 18/23 18/24
19/3 21/21 22/11
22/22 27/2 28/13 29/7
30/25 31/3 31/4 33/20
34/7 39/6 40/9 41/7
41/17 41/24 43/15
A7I17 47/23 48/23
48/24 49/17 50/1 52/2
53/17 53/23 53/24
54/6 57/24 58/6 58/12
58/22 58/23 59/25
60/16 62/16 62/17
62/18 62/18 63/20
63/21 63/21 65/20
66/23 66/25 70/8
71/24 75/1 76/20
77/15 77/17 77/17
77/19 79/8 79/13
79/25 80/22 81/3
81/25 82/2 86/14
86/24 88/16 89/25
91/12 92/1 92/12
92/22 93/6 94/4 94/24
94/25 99/5 100/13
101/3 101/6 101/9
101/11 101/11 102/8
103/20 105/5 105/22
105/23 106/1 106/14
106/16 107/5 108/7
109/25 110/1 110/22
111/20 112/19 113/1
113/4 113/5 115/3
115/11 115/23 119/17]
120/13 121/2 122/16
122/20 123/8 123/13
124/3 128/14 128/15
130/22 131/18 135/14
136/25 137/1 138/2
138/6 138/14 139/21
141/4 141/6 141/6
142/3 144/7 144/19
146/17 146/23 147/2
149/3 151/6 152/2
152/13 154/6 154/13
154/16 155/6 157/5
159/15 160/16 161/11
161/13 164/8 164/11
166/19 167/3 167/7
167/16 168/2 172/10
173/16 177/22 182/9
182/23 185/23 186/22}
187/19 188/11
what's [8] 13/3 28/8
47/24 47/24 80/2
110/3 145/12 182/24
whatever [1] 169/6
whatsoever [1]
113/11
when [61] 2/4 4/19
4/23 7/14 7/15 7/18
7/22 8/6 13/2 13/9
14/4 14/21 16/6 16/15}
16/22 18/19 18/22
18/23 20/22 22/17
25/25 28/16 33/19
37/25 38/21 45/24
48/3 52/18 54/4 54/12)
58/10 59/23 61/6 62/8
62/15 67/5 68/15
70/19 71/25 72/3 72/9)
74/11 94/15 108/12
135/14 135/18 137/6
146/5 147/15 152/8
161/19 163/4 164/4
170/21 171/10 171/16}
172/21 176/10 176/21
179/8 187/3
where [57] 4/1 6/2
6/9 11/15 11/24 15/5
16/21 17/9 19/23 25/8
32/9 34/19 38/12 40/8)
40/21 46/3 47/8 48/16)
49/7 57/19 63/19
66/17 74/12 77/8
82/23 83/10 83/12
83/21 85/7 86/3 86/5
86/10 87/13 87/17
91/17 92/4 97/2 98/22,
105/3 111/12 116/5
117/15 121/9 121/16
139/1 145/25 146/15
149/10 151/6 153/7
154/4 154/8 155/1
156/2 162/3 173/1
183/5
whereby [2] 59/25
61/17
wherever [1] 13/13
whether [27] 4/25
6/22 17/18 18/12
25/12 25/13 25/23
31/7 39/13 43/18
47/16 49/15 53/20
59/24 73/1 75/21 96/9)
107/16 108/22 124/9
134/1 134/22 145/23
153/9 156/20 162/10
186/17
which [134] 5/20
6/13 7/11 11/10 12/17,
14/16 19/25 20/6 26/7}
28/4 30/7 33/13 40/6
40/17 40/18 44/2
45/21 46/17 48/10
48/16 48/21 49/21
50/7 51/1 51/19 51/20I
54/3 56/25 57/1 59/10
59/11 59/17 59/20
60/1 60/15 61/18 62/1
62/2 66/5 68/8 70/12
75/4 76/23 78/25
79/12 79/23 82/11
84/10 85/9 88/4 88/6
88/7 90/10 90/11 92/8)
92/11 94/12 94/19
96/2 98/12 99/7 100/9I
100/18 100/22 101/5
103/14 109/12 110/7
411/17 111/22 116/4
116/12 118/1 118/21
119/1 121/1 123/24
125/21 126/24 128/16)
133/3 133/17 134/14
134/20 135/22 136/23)
137/21 138/8 138/8
138/15 140/11 140/15)
140/23 140/23 140/25)
141/17 142/22 144/15)
145/12 147/3 148/5
148/7 150/7 150/16
150/20 152/15 153/2
158/11 158/13 159/11
159/14 159/24 166/5
166/24 168/12 168/20)
168/20 169/4 170/6
172/18 173/9 174/15
174/18 178/1 179/18
179/20 180/14 180/20}
181/14 184/11 184/20)
186/5 186/10 186/16
while [4] 2/3 60/7
98/15 187/2
whilst [6] 50/5
103/15 123/4 132/21
139/5 165/24
Whitehead [1] 164/2
who [48] 3/4 5/20
6/21 7/3 12/1 15/14
16/4 18/1 24/11 27/19)
28/14 32/12 32/15
37/3 37/8 39/1 42/14
50/20 50/24 55/13
55/21 72/7 77/21 78/8I
78/11 78/13 78/24
80/2 81/8 101/23
111/6 115/9 116/11
122/10 137/25 139/17)
141/21 141/25 142/10)
143/16 146/22 146/25)
148/1 174/24 177/11
181/10 183/17 184/8
who's [1] 187/12
whole [13] 2/18
36/18 36/21 46/6 96/7I
101/10 102/5 103/7
133/17 133/19 134/2
167/19 167/23
(80) watch... - whole
Ww
wholly [1] 77/19
whom [2] 11/19
155/20
why [36] 7/24 9/8
9/18 10/3 13/19 19/15)
22/25 23/8 34/22
39/15 41/5 43/21
43/23 51/5 54/8 54/10
54/12 54/15 62/14
76/14 79/7 79/20 83/1
101/6 106/13 106/14
106/14 121/11 134/20}
141/9 144/20 162/21
165/20 166/17 177/20)
178/10
wide [2] 127/1 188/5
widely [2] 162/9
179/24
wider [9] 72/10 75/11
94/2 112/15 112/20
113/2 113/6 133/3
135/5
will [54] 1/6 2/3 2/4
24/12 24/23 50/3 53/2
53/8 54/1 54/5 54/12
54/12 66/12 71/25
72/9 84/4 91/15 91/16
94/3 96/1 114/15
118/20 121/1 121/1
121/6 123/21 124/22
125/5 125/7 125/11
125/21 130/9 131/4
133/3 151/12 151/14
153/14 153/16 156/4
157/10 158/13 158/19)
159/2 159/18 165/5
165/8 165/16 178/16
178/18 178/25 179/2
179/4 179/8 179/9
WILLIAMS [16] 58/17
139/18 142/12 145/7
147/5 147/19 152/25
153/20 154/17 160/12)
163/10 177/11 178/11
179/2 187/21 192/6
Williams’ [1] 149/5
Williams's [1] 155/11
Wilson [2] 54/19
54/21
win [1] 71/12
wiser [1] 180/9
wish [1] 1/18
withholding [1]
171/13
within [30] 6/4 6/25
7/1 11/18 11/23 12/23,
13/22 21/22 28/11
29/23 31/10 32/13
34/21 36/9 36/13
36/15 37/3 38/24 39/6
45/9 46/6 52/18 56/7
61/21 61/22 62/7 63/9
63/16 69/22 91/4
without [12] 50/9
73/19 89/14 91/21
103/21 104/20 119/4
123/7 164/5 166/8
175/17 181/25
WITN04380100 [1]
1/11
WITN04390100 [1]
35/14
WITN09760100 [1]
65/23
WITN10660100 [1]
32/5
witness [45] 1/9 22/4
35/13 44/15 65/5 65/7
66/3 67/15 77/24
78/18 89/6 102/24
103/9 108/11 121/13
137/19 138/7 140/16
143/20 143/25 144/2
144/13 144/14 170/13)
170/15 170/16 170/17)
170/19 170/20 170/23)
171/2 171/4 171/11
172/12 173/8 175/3
175/4 179/21 182/10
183/7 184/20 186/7
186/17 190/14 190/20;
witnesses [1] 136/13
won [1] 79/4
won't [4] 46/8 52/12
149/3 158/17
wondered [2] 73/17
74/21
Woollard [1] 24/24
word [2] 72/24 98/1
worded [1] 149/25
wording [17] 84/16
87/6 87/7 87/16 90/10
91/10 96/21 102/13
104/1 104/6 104/9
148/7 148/8 148/9
148/13 149/4 150/5
words [8] 60/12 63/3
63/14 88/1 91/12
119/21 154/17 188/20)
work [12] 21/5 21/19
37/16 71/2 81/18
83/13 107/18 115/22
120/10 132/25 160/10;
174/5
worked [14] 6/7 6/8
8/7 11/19 31/18 35/7
38/24 40/12 51/4
66/17 66/19 67/8 70/4
167/16
workforce [3] 14/23
14/24 17/19
working [25] 12/1
20/10 21/12 24/17
24/20 41/8 45/14
76/23 77/12 105/14
107/15 108/21 108/25)
120/7 135/7 144/19
158/22 158/23 163/20
164/17 168/21 168/21
188/1 188/16 188/24
works [1] 151/17
workstream [2]
116/15 116/16
workstreams [2]
116/5 161/14
worry [1] 137/15
worrying [1] 166/38
worth [4] 38/7 73/18
94/7 133/6
would [220]
wouldn't [20] 17/3
19/21 24/3 25/15
25/15 27/12 37/5 51/6
51/12 54/11 54/14
58/3 75/18 85/2 89/12
89/13 104/18 112/6
151/20 178/5
write [1] 90/21
writer [1] 169/14
writes [2] 115/3
183/5
writing [3] 49/20
155/25 176/21
written [2] 53/7
186/22
wrong [6] 106/16
106/18 110/4 130/2
132/11 182/2
wrongdoing [1]
174/23
wrongful [2] 89/3
95/14
wrongly [3] 39/22
108/2 154/24
WYN [2] 58/17 192/6
Y
yeah [24] 5/4 6/16
16/24 17/1 31/22 32/3
33/22 43/16 44/18
54/6 54/24 55/19 56/1
63/12 63/18 73/13
108/14 122/5 123/13
147/24 150/18 163/6
187/1 189/21
year [9] 1/8 16/17
52/18 65/8 72/22
110/7 110/13 110/19
135/16
year’ [1] 109/16
years [5] 11/19 60/8
66/17 94/23 167/25
yes [213]
yesterday [2] 153/4
166/16
yet [10] 92/24 109/19
140/16 165/4 170/21
175/9 176/6 176/25
178/7 180/16
you [737]
you'd [1] 122/23
you'll [7] 10/9 64/7
101/13 150/8 151/10
177/10 178/14
you're [32] 8/3 10/7
16/1 16/22 20/19
26/14 27/5 42/20 54/4,
57/14 73/21 73/21
87/16 88/14 88/18
90/6 90/7 93/23 96/9
96/17 119/7 132/13
136/1 162/1 163/11
175/15 177/9 177/9
177/14 180/16 180/16}
187/24
you've [15] 3/3 3/5
20/20 46/2 46/23
51/17 67/16 70/16
80/17 88/16 102/24
109/23 173/14 176/12)
184/24
your [143] 1/24 1/25
2/10 2/10 2/18 3/10
3/18 4/8 7/8 7/11 7/21
8/9 9/14 10/6 11/2
11/6 15/6 16/13 18/6
18/25 19/3 21/21
22/16 23/15 25/13
26/5 26/6 27/22 28/7
28/10 29/11 29/12
31/18 31/23 33/13
33/24 34/10 35/9
36/21 37/1 40/17
44/15 45/5 49/10
49/14 50/20 51/25
55/6 56/23 58/3 59/15)
60/4 60/15 60/21 64/6)
65/2 65/12 65/15
67/12 67/15 67/17
69/10 69/10 69/16
70/1 70/13 72/12
72/12 74/3 74/11
74/12 75/13 77/17
77/24 79/10 81/18
81/22 84/14 85/20
87/7 88/17 89/6 91/3
91/10 92/1 92/8 92/10)
92/12 96/1 96/14
100/13 100/14 101/7
101/21 102/24 103/9
103/10 111/4 111/8
112/15 113/15 114/10)
118/6 119/8 120/17
125/23 127/12 127/24}
128/14 129/17 130/7
131/22 133/6 135/2
139/10 140/20 143/15}
148/23 150/1 153/1
161/1 163/1 164/7
165/9 166/15 166/17
167/11 168/3 170/16
171/2 172/21 172/24
174/1 174/13 176/4
176/10 176/11 176/25}
180/17 181/2 185/24
188/16 190/14
yourself [12] 72/22
80/23 84/3 95/4 102/1
103/2 104/7 122/7
125/10 132/13 138/19)
180/16
z
Zebra [2] 189/16
189/21
(81) wholly - Zebra