ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
Monday, 29 July 2024
(9.45 am)
(Proceedings delayed)
(9.47 am)
MR STEVENS: Good morning, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR STEVENS: We're hearing from Mr McCausland this morning.
SIR WYN WILLIAMS: Yes.
NEIL WILLIAM MCCAUSLAND (sworn)
Questioned by MR STEVENS
MR STEVENS: Please could you state your full name?
A. Neil William McCausland.
Q. Mr McCausland, thank you very much for firstly providing
a detailed written statement and, secondly, for
attending the Inquiry to give oral evidence today.
I want to turn to that witness statement; do you have it
in front of you?
A. Ido.
Q. For the record, that is WITN10290100. Can I ask you,
please, to turn to page 76 of that statement. Do you
see paragraph 203 and then beneath that a statement of
truth?
A. Yes.
Q. Then on the other side there's a signature; is it your
signature?
Limited as Senior Independent Director?
A. Correct.
Q. Did you know Alice Perkins before you were recruited to
Post Office Limited?
A. No, I had no knowledge of her at all.
Q. What was the time commitment for the role of Senior
Independent Director at Post Office?
A. I cannot quite remember. I have thought about that and
it isn't on my terms of reference. I think that it
is -- that it was three or maybe three to four days
amonth. I think it was three days a month but it might
have been three to four days a month but I haven't got
a piece of paper that confirms it.
Q. Whilst you were a Senior Independent Director at Post
Office, did any other representative from Post Office
ask you questions about how much time you were spending
on Post Office matters?
A. Would you mind repeating that?
Q. Yes, of course. Whilst you were Senior Independent
Director at Post Office, did anyone else within the Post
Office discuss the amount of hours or days you were
spending at Post Office Limited?
A. Yes, it was a fairly frequent topic of conversation for
me and all of the NEDs, including Alice, in that all of
us were spending maybe double the amount of time that
3
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
prop
29 July 2024
Yes.
Are the facts stated in that statement true to the best
of your knowledge and belief?
Yes.
Thank you, Mr McCausland, that stands as your evidence
in the Inquiry. It will be published shortly on the
Inquiry's website and I am going to ask you some
questions about parts of it. I'll start very briefly
with your background. Following various roles with
Marks & Spencer you became Managing Director of C&A in
1999?
Yes.
You then became CEO of a government-owned business
called Navy, Army and Air Force Institutes between 2001
and 2002?
Yes.
Was that your last executive role?
Yes, it was.
Can I ask you to move slightly closer to the
microphones, please, so they pick you up. Thank you.
You've then held a number of Non-Executive Chair
roles between 2000 and when you joined Post Office in
September 2011.
That's correct.
A pointer to 2011, at that point you joined Post Office
2
we, in theory, should have been. Post Office was a very
time-intensive job. So I and all of the other NEDs were
spending more time and we did talk about that.
So you rightly say your terms of reference don't refer
to time commitment. I think was it you said three to
four days a month was your expectation?
It was either three days a month or three to four days
a month.
Does that mean, in practice, you were working between
six and eight days a month on Post Office matters during
interesting your time as Senior Independent Director?
That is about right. I would say two days a week.
We don't need to turn this up on the screen but you give
a description of your role as Senior Independent
Director at page 3, paragraph 7 of your statement, and
I want to just raise some of them with you. The first
is that you say you were to assist with the development
10f Post Office Limited strategy --
Yes.
That effectively means analysing and considering the
future direction of the Post Office?
Absolutely. Post Office -- do you want me to expand?
Well, you don't need to but if you've got something to
add, then please do?
Well, the Post Office that I went into was a very badly
4
(1) Pages 1-4
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
run, very messy business. For the 10 years previous it
had had a very sharp decline in profitability. It was
losing -- the year before I joined it lost 120 million
in a year and that had been getting steadily worse. The
network had been shrinking, the infrastructure was old
and creaky and it was separating out from Royal Mail
Group. So it didn't have its own infrastructure and it
was about to get its own infrastructure -- it needed to
have its own infrastructure to stand alone and,
therefore, it needed to have a strategy to basically get
it back to profitability and make it a sustainable
business because it was not sustainable to keep going as.
itwas. So absolutely, developing strategy was
an important part of the job.
When you say "creaky" infrastructure, what
infrastructure are you referring to?
Basically everything. The IT infrastructure, we knew,
was old and underinvested and creaky; the physical post
offices were under-invested. They were dark, barred,
fairly dingy places. So --
To cut across you, when you said the IT infrastructure,
are you including Horizon system within that?
Absolutely. The Horizon system we knew was near end of
life. I think it was 15 years old by that stage. Most
IT systems don't last more than 10 years. So we knew
5
of how it responded to complaints against the Horizon IT
system; would you agree with that?
Yes.
Back to paragraph 7 -- as I say, we don't need to bring
it up -- another point you make is that you needed to
monitor performance and hold the Executive to account?
Yes.
So when doing that, does that mean probing and
challenging the Executive on the work that they carry
out?
Yes.
You also say ensuring the risk management system is
robust?
Yes.
Does that mean, in effect, ensuring that or overseeing
the Executive in their identification, analysis and
mitigation of risk?
Yes.
That would include risks arising from the integrity of
the Horizon IT system?
Yes.
We're to look at that aspect in some detail this morning
but, before I do, could we have your witness statement
on the screen, please, at page 4, paragraph 9. At
paragraph 9 you set out some of your non-executive
7
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
29 July 2024
that we had a clunky underinvested IT infrastructure,
which is why an awful lot of work went on during my
tenure to develop a new IT strategy which would end up
replacing Horizon and Fujitsu.
You joined the Post Office in September 2011, yes?
Yes.
So a year after Post Office and Fujitsu had rolled out
the Horizon Online system?
So a year after Horizon Online had been rolled out, yes.
So, in those circumstances, why did you think that
system was creaky?
Because Horizon Online wasn't a rewrite -- wasn't
a whole rewrite of Horizon. Horizon was still Horizon.
It was basically a modified version of Horizon. It's
more like having an iPhone 15/iPhone 16 release. It's
not necessarily a whole new system. So Horizon was
still a clunky, not a particularly intuitive, not
particularly easy to use system.
When you are using the word "creaky", are you using that
in a user interface way, rather than a technical way of
the integrity of the system itself?
Absolutely, yes. It wasn't easy to use. It wasn't
intuitive.
One other aspect of strategy, presumably, would have
been to developing the Post Office's strategy in respect
6
roles. Can I just first clarify, does this list capture
all of the non-executive roles you held whilst at the
Post Office?
1am not 100 per cent sure that it does. That's saying
the companies I've worked for since leaving POL.
Yes, if we look at Skin Clinics, for example, Joules,
Create Fertility?
Yes.
Those at least have some overlap with your time as
Senior Independent Director. Let me ask it another way:
during your time as Senior Independent Director, did you
work at any other companies as a non-executive, other
than those listed here?
Again, I cannot remember the dates, so I certainly have
worked with companies which are not listed there before.
I cannot remember the dates of leaving some of those
companies as to whether they overlapped September '11 or
didn't.
Well, let's just look at the ones we have here. Skin
Clinics, Joules and Create Fertility. Can you summarise
the time commitment that you had to give for each of
those companies as a Non-Executive Director?
Joules was three days a month; create Fertility, at that
stage, was very small, it was literally one clinic, so
it was probably two days a month; and Skin Clinics was
8
(2) Pages 5-8
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
also three days a month.
So did you feel that you were able to dedicate
sufficient time to the Post Office as Senior Independent
Director?
Absolutely. I mean, as I said earlier, I gave at least
double, you know, maybe more, the amount of time that,
in theory, I was meant to, but I never felt constrained
for time for Post Office.
I'll move to my first topic I want to look at and that's
some of the assurances in respect of IT that you refer
to in your witness statement. Please can we go to
page 8 of the statement, paragraph 17. You say:
"I recall being assured by Ernst & Young's Audit
Partner (Angus Grant), the CFO (Chris Day), the COO
(Mike Young) and the Chief Information Officer (Lesley
Sewell), that the integrity of the accounting systems
was sound, albeit slow and clunky. Given that I am not
an expert in either IT or accountancy, I deferred to
their expertise on these issues."
When you said "the integrity of the accounting
systems", presumably there you're including the Horizon
IT system within it?
Yes.
When you say "albeit slow and clunky", is that the same.
as we discussed before: more of a user interface matter,
9
General Counsel, and there was a very clear, very robust
answer from Susan Crichton that the system was sound.
So that was probably the first time that Horizon issues
really came into my mind. But after that exchange I had
the impression that they were strong. As ~
Yes, please, go on.
As we then became independent and had our first Audit
Committee meeting with Angus Young from EY, Ernst &
Young, and also there was an RMG internal audit report
that we looked at, then those documents made it clear
that they weren't questioning the data integrity at all
and they weren't even questioning the controls, but they
were questioning the documentation of controls. They
were basically saying that the documentation of the
controls was not as strong as it's needed to be.
There was a discussion with EY that it had taken
them longer to actually do the audit and that they had
not been able to rely on the documentation which existed
copied and, therefore, they had had to create some of
that documentation themselves, which had led to
an overrun in time and cost.
So data integrity wasn't an issue in my mind. The
controls had a small issue but the documentation of
controls had a large issue.
Could we please just bring up page 68, paragraph 181 of
1
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
rather than a data integrity issue?
Yes. I was not of the understanding then that data
integrity was at issue.
Can you recall the first time that -- I want to start
internally with the Executive -- that the CFO, Chris
Day, Mike Young or Lesley Sewell discussed with you the
Horizon IT system?
I think, if I go to the very first time that it was
discussed, it was probably actually Susan Crichton who
was doing the discussing, and that took place at a Board
before independence, so before I had even met Angus, and
at that Board, Les Owen, if I remember rightly, who was
still a Director of the Post Office Board at that stage,
had asked Susan Crichton about the Access
Legal/Shoosmiths letters, and had asked about the
strength of the legal claims, and Susan at that stage
reassured Les that their legal claims were weak and that
the -- there had been an audit done, which had been very
positive, and that that had been reviewed by an external
party, Deloitte, and also that there were no -- that in
all previous prosecutions where Horizon data had been
used, we had been successful.
So at the time, that was probably my first induction
into the integrity of Horizon data and, yeah, I was
listening to an experienced RMG Director talking to our
10
your statement -- just go down the page, please. You
can see it says:
"The Board were consistently provided reassurance by
a multitude of individuals -- many of whom had either
specialist IT or accountancy expertise -- that Horizon
was robust and fit for purpose. Examples of this
include ..."
Then if we turn the page, so I think you've
effectively, in your evidence, just summarised those
bits.
The first bullet point is the Board meeting on
12 January; the second is what you say are RMG/Post
Office's internal audit with the results reviewed by
Deloitte; then we have (3), the ISAE IT annual audit,
jointly commissioned by Post Office and Fujitsu; and
then (4):
"Ermst & Young (the auditors for [Post Office]),
regularly audited Fujitsu IT", and you go on to refer to
a discussion at the ARC audit, risk and compliance,
meeting on 15 May 2014.
Just so we're clear, are those the four matters you
were referring to in your evidence then?
Not quite. So I was referring to the first one, which
was Susan Crichton's assurances, which at the time
I believed. With hindsight, it becomes clear that
12
(3) Pages 9 - 12
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
rPOoOPrO
2
The Post Office Horizon IT Inquiry
pretty much all of --
We are just going to come to those in a moment.
-- they were wrong.
Just take us through --
Yeah, okay, the second one I was referring to, the
internal audit, I wasn't referring to the ISAE 3402.
That came later. So, by this time, ISAE 3402 was not in
existence. However, as a consequence of those meetings,
we did force Fujitsu to introduce the ISAE 3402 which,
the followed year, did come into existence.
Pausing there then, when you say you referred in your
evidence to Deloitte -- the audit taking longer, needing
to create your own paperwork, were you referring to what
we've heard as the SAS70 issue?
No.
No.
So the -- in the first year that I saw the audit reports
and my first audit committee meeting with Angus Young
(sic) from EY, that audit had run for longer than it was.
expected to run and had cost more and that was partly
because Horizon Online was new, it was partly because EY
had a new team who were doing the auditing but it was
significantly because the controls were not in place.
As a result of all of that -- as a result of all of
that, then that was one of the reasons why we were
13
quality/assurance."
Was that something you were aware of at the time?
I was not aware of that at the time. I subsequently
became aware, not of an issue relating to data
integrity, but of an -- there was an issue where we
had -- I'm trying to remember now. So later than this,
there were some customer incidents which affected
customers, where basically Fujitsu -- Horizon dropped
out and, when Lesley Sewell investigated that and
reported to the Board, the reason for that was because
the data -- we used to have two back-up data centres and
we'd moved to one, which I think had been a cost-saving
exercise in the migration to Horizon Online. So that
subsequently, I learnt, which was probably -- this might
have been what I was talking about: quality. But at the
time, I certainly had no knowledge that when Horizon
Online had been commissioned, we had -- RMG had driven
a hard bargain and there had been a reduction in quality
or assurance.
Further down, it says:
"Horizon -- is a real risk for us.
"Does it capture data accurately.
"Cases of fraud -- suspects suggest it's a system
problem.
Alice Perkins’ evidence was that this is something
15
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
saying it can't be right that this is the case, yeah, EY
shouldn't be needing to work that hard to do that. We
should be able to rely on our supplier to have a suite
of documentation that our auditor can simply look at and
test, rather than needing to construct it themselves.
And that is what led to the request to do SAS70 and
SAS70 then morphed into ISAE 3402. So, effectively,
they are one and the same thing.
Did Mr Grant, the Ernst & Young Audit Partner, say
anything to you about the integrity of the Horizon IT
system in recording transactions at a branch level?
There was absolutely no comment from Mr Grant that the
data integrity was in any way compromised or poor.
Alice Perkins gave evidence to the Inquiry on 5 and
6 June 2024 and her evidence was that she had
a conversation with Angus Grant during her induction, of
which she says she made a note. I want to bring that
note up, please. It's WITN00740122.
We see a Post Office notepad. Presumably you didn't
see this note until the Inquiry sent it to you?
Correct.
If we can look halfway down, please, and it says, right
in the middle almost:
"With Fujitsu, [Post Office] drove a [very] hard
bargain on price but they took back on
14
Mr Grant had said, who raised a question as to the
accuracy of data being captured by Horizon, and then the
second point being referring to the claims of which you
became aware.
Did Mr Grant say anything along those lines to you,
around the time you joined Post Office?
No. I don't recall meeting Mr Grant before the Audit
Committee meeting, which was in 2012. So I don't
believe that I saw him in 2011, and when I did meet him
I had the EY report, and neither in his conversation nor
in the EY report does he say that he is worried about
data integrity.
Did Alice Perkins raise or pass on any of this
information to you in the early days of being a Senior
Independent Director?
I have no recollection of her -- of her talking about
that.
That can come down. Thank you.
Can we now look at -- I was going to go through the
sources of assurance that you referred to, and we'll
start with the Board meeting, I think you are referring
to the 12 January one. It's POL00021503. So we see
it's a meeting of the Board of Directors on 12 January,
and you are listed as present as the Senior Independent
Director. Please could we turn to page 6 of that
16
(4) Pages 13 - 16
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
document and to the bottom, please.
So, as you said:
"Les Owen asked for assurance that there was no
substance to the claims brought by subpostmasters which
had featured in Private Eye."
Now, just pausing there, I understand it's your
evidence that, at this point, you were aware of the
claims through the Significant Litigation Report; is
that right?
Yes, the Significant Litigation Report had just been
published for the first time.
But your evidence is you hadn't seen the Letter of Claim
by Shoosmiths Access Legal?
That is correct. The first time I saw those was in the
Inquiry.
Again, your evidence is, at this point, you weren't
aware that one of the allegations was that Fujitsu could
access remotely branch accounts and either insert, edit
or delete transactions?
That is correct.
I'm going to refer to that in shorthand as "remote
access" from now on.
Okay.
It says:
"Susan Crichton explained that the subpostmasters
17
I did not. At this stage, this was -- I was very new,
I was still absorbing and this was a conversation
between Les Owen, who had been on the RMG Board and
had -- they were the ones who had commissioned this
internal audit and this had been going on for some
months. So Les was asking Susan about it and the
interchange was between Les and Susan.
I was listening at this stage, absorbing,
assimilating, and, as I say, I came out of that
reassured -- wrongly, with hindsight, but at the time,
reassured -- that the Horizon system was good, good
integrity, and that the claims against us were weak.
Finally, the comment:
"The Business has also won every criminal
prosecution in which it has used evidence based on the
Horizon system's integrity."
You may have said this in your evidence earlier but,
just so we're clear, who said that?
So Susan said, in answer to Les’ challenge/question,
that -- she said exactly that, which again, with
hindsight I now know is wrong but at the time I didn't
know it was wrong, at the time I didn't question it. If
the General Counsel is talking to an existing RMG and
now POL Director in a Board meeting and says something,
I believe her.
19
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
were challenging the integrity of the Horizon system.
However the system had been audited by RMG Internal
Audit with the reports reviewed by Deloittes. The audit
report was very positive."
Then at the bottom it says:
"Susan Crichton suggested that she clear the audit
report with the external lawyers and if it is possible
to give the report privileged status it would be
circulate it [sic] to the Board."
Did you ever see an audit report by Deloitte on
these internal audits?
No, I don't believe -- I didn't. I don't believe there
was an audit report by Deloitte, with hindsight. At the
time, clearly I didn't know that. But! don't believe
that there was one.
Had you seen the RMG internal audit itself at that
point?
No, I hadn't, although I did see it subsequently.
The RMG internal audit, is that -- a document we may
come to it -- but what's been described as an assurance
review and a series of slides showing an assurance
review?
Yes.
Did you ask any questions at this stage about what the
internal audit investigated or its detailed findings?
18
In terms of what you can recall now about her answer,
did she provide any other detail or any other context
around what we see recorded here?
I'm sure she did but I cannot remember it. This was
13/14 years ago and, inevitably, the minutes of a Board
meeting -- the Board meeting will last all day, and the
minutes are maybe eight or ten pages long, so the
minutes do not capture all of the conversation. So I'm
sure that there was a fairly large conversation around
that but I do not know any more than I can see from the
minutes. I cannot remember.
Could we turn, please, to POL00021430. So this
a meeting of the Audit, Risk and Compliance Subcommittee
‘on 13 November 2012 and, again, we can see you are in
attendance and, at the bottom, we can see that Angus
Grant, the Audit Partner of Ernst & Young, is there,
along with another representative of Ernst & Young.
Can we please turn to page 4. If we can just scroll
down, please. So (e) refers to "AG". So it's Mr Grant
setting out matters about the audit. It says:
"He expected that 2012/13 would be a challenging
year for the Business in several areas because of
separation and major change, and that the audit would
need to focus on separation, pensions and taxation with
an overlay of IT."
20
(5) Pages 17 - 20
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
He set out the method of doing it -- the focus,
sorry. Then (f):
"The ARC was comfortable with the approach,
alongside the separate ISAE 3402 IT audit [which we
referred to earlier in your statement] which had been
jointly commissioned by the Post Office and Fujitsu.”
It says:
"The Chairman asked at what level of materiality the
E&Y team would report. [Mr Grant] explained this would
be similar to previous years. Although E&Y did put
a figure on [profit and loss] materiality, they would
propose to report any identified audit adjustments above
£600,000 to the Committee and, as a general rule, insist
on changes to the accounts for any single item or
accumulation of items with an effect of over
£5-6 million. This was accepted."
When you say you took assurance from the IT audits,
did that give you any assurance as to the integrity of
the Horizon IT system in recording data at a branch
level?
There wasn't a specific -- I cannot recall a specific
comment about that. However, EY would have spent a lot
of time at the -- Chesterfield, I think it was --
accounting centre and, in order to sign off the
accounts, EY would have needed to ensure that they were
21
will take place subsequently. So here they're talking
about how they're going to plan it, then they will have
done the audit and then they will report on the audit.
And there is a detailed document for each, so after
it is document here, there will be a document which came
to the Board, not in the minutes, which will have spelt
‘out exactly how the audit was going to take place, which
we will have looked at and said okay, and that will have
included a large amount of work in -- at the
Chesterfield -- and forgive me if Chesterfield is the
wrong place -- but at the Chesterfield data centre. And
then the report will have come through and we will have
looked at that probably May time the following year,
once the audit had been done, and they will have
reported on all of their findings.
And all of their findings, the ARC, would then have
pored over and understood where there were problems and
then also made sure there was an action plan in place to
clear up those problems. And my name from the —-
throughout all of the years was that the issue was not
about data integrity; the issue was about controls and
specifically the documentation of controls, and the
first audit from '10/'11, they had quite a few findings;
the second one, in '11/'12, they had materially fewer
findings; and then by '13/'14 and '14/'15, they were
23
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
happy with the integrity of the accounting system,
including the branch accounting system and, if they
weren't, there would have been a discussion and there
would have been a matter of emphasis in the accounts.
Now, I cannot remember that happening, so I cannot
remember a specific discussion about branch accounting
but, inevitably, they will have done that in their
audit, and the fact that I can't remember it is probably
saying that it wasn't there as an issue. The issues
were the things that we primarily concentrated on.
So I don't want to put words in your mouth; I'm just
trying to summarise what I think you've said. You can't
remember if there was a conversation on integrity of
branch accounts in respect of the audit?
I think that's a yes?
Yes.
But it would have been your assumption that EY would
have satisfied themselves as to the integrity of the
accounting system, yes?
Absolutely, so --
But you can't help us with knowing what you may have or
may not have said or asked to satisfy yourself that that
was actually happening?
That is correct. So, at this stage, this is an audit
planning meeting, and then the audit results meeting
22
actually very complimentary about the controls and
documentation of controls, and the audit reports
specifically articulate that the level of controls has
improved very significantly over the period of time.
Thank you. I want to move on, please, to look at the
appointment of Second Sight -- and we don't need to turn
this up -- but in your statement at paragraph 36,
paragraphs 98 to 100, I think you make the following
points, I just want to confirm them with you:
The first is that you say you were not involved in
the decision to instruct forensic accountant or the
selection of Second Sight itself?
Correct.
You also say in your statement, paragraph 100 that:
"I was not involved in any discussion and/or
overseeing the drafting of the terms of reference for
Second Sight's investigation"?
Correct.
Alice Perkins gave evidence to the Inquiry that she
spoke to you at some point -- she couldn't be clear when
but at some point -- about the appointment of Second
Sight. We're going to come to the Board meeting shortly
but can you recall any conversation outside of the Board
meeting with Alice Perkins concerning the appointment of
Second Sight?
24
(6) Pages 21 - 24
1
2
3
4
5
6
7
8
9
10
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A
The Post Office Horizon IT Inquiry
Ihave no recollection of that. However, it is quite
possible that Alice did. I listened to Alice and
I think she was referring to her finding it difficult
within the business, in that she was getting pushback
from Mike Young and Susan Crichton, and so it is --
I cannot remember it but it is perfectly possible that
Alice had a conversation with me that said "James
Arbuthnot is suggesting this, I think it's a really good
idea, I'm getting pushback in the business, what do you
think, Neil?" That would have been the sort of
conversation that we would have had and I would have
said, "100 per cent right, Alice, go for it. If you
upset Mike and Susan, so be it".
But I have no recollection of that, but it's
a perfectly feasible conversation. Alice spoke to me
about those things regularly.
Let's look at one of the Board meetings where I think
you say it was the first time you can recollect Second
Sight or a forensic accountant being instructed? Please
can we bring up POLO0021507.
Before we go there, we see 23 May 2012 and you're
present on the second line. Can we turn to page 8,
please.
So this is under AOB. It refers to Paula Vennells
and Alice Perkins updating the Board on the meeting with
25
to be a two-man band and it was very unusual for Post
Office to appoint a two-man band to do anything.
Normally, we would apply -- we would appoint people with
large resource.
And the -- again, my memory is vague, but I think
that I was reassured that they were going to do
areview. They were not going to do a fully code-based
review, looking at all of the documentation and all of
the system. What they instead were going to do was to
take the cases that the MPs had given to them and
forensically understand what had happened to the money,
and follow -- find system faults through that way. So
if I have lost £5,000 -- if there is a loss of £5,000,
go through the forensic accounts and understand where
that has happened and, from that, identify problems with
Horizon.
So, rather than going bottom-up, looking at all of
the code, they would basically find the root cause of
those problems. So I think that was the discussion at
the time and I was reassured. I remember challenging it
but I remember also being reassured that Second Sight
had the capability and the capacity to do that job well.
Could we look, please, at POL00096642. If we can go to
the bottom of that at page, please, we see there's
an email from Paula Vennells on 14 June 2012 to you. So
27
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
James Arbuthnot and Oliver Letwin. At the end it says:
"The business had also agreed to use a forensic
accountant to investigate the system and give further
comfort to those concerned about these cases", referring
to the MPs' cases that they were championing.
We don't need to turn it up but in your statement,
page 36, paragraph 99, you say you do recall querying
whether they -- "they" being Second Sight -- had
sufficient manpower and sufficient expertise in IT to be
competent in undertaking a comprehensive review of
Horizon. The Board were assured that they were
sufficiently competent and that Susan Crichton had
worked with them previously and held them in high
regard.
At this stage, what type of investigation into the
Horizon IT system was being proposed by Paula Vennells
and the Chairman?
I think there was a degree of uncertainty at this stage
about what the scope of it would be and I have a vague
recollection of that, and it is only vague, but I came
back to it mentally several times in subsequent years,
which is why I do have a vague memory of it. So my
questioning at that Board was what are Second Sight
going to do, and are they good enough to do it? Have
they got enough resource to do it? Because they seemed
26
we've moved forwards a little bit in the chronology. It
says:
"Neil, good to see you earlier.”
Then further down:
"The meeting with James Arbuthnot went completely to
plan. So well worth insisting on it, and making the
effort to go across.
"He has agreed to our TOR [I take it that's Terms of
Reference] and an individual rather than a blanket
approach."
Pausing there, when it's referring to an individual
rather than blanket approach, is that going to the
evidence you just gave: that it's looking at individual
cases rather than a code-up review?
Yes.
Then, if we go up, please, to see your response, you
say:
"Paula it's always a pleasure to see you ...”
Further down:
"Well done with James."
That's presumably referring to Lord Arbuthnot?
Yes.
So you agreed, presumably, at this point with the
individual approach rather than the overall code review
approach?
28
(7) Pages 25 - 28
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
Yes. I did, Again, my memory is slightly vague but
I think that it was explained to me that because the
code -- the original code was so old and because it was
so different across the estate, that it would be almost
impossible and very expensive to do a proper code review
but that what Second Sight were recommending, ie take
the individual cases, follow the money forensically,
understand where the root cause of that loss had come
from, and my belief, then, was very clear that that
would be visible, as you went through the audit store,
so they would be able to track that down, they were
bright people, and from that, if then there were ten
instances where there'd been a problem with ATMs had
caused a £5,000 loss, that would then say, okay, there's
a problem with the system. So yes, I was happy with
that approach.
Would you agree that, at most, what that would show was,
in an individual case, a loss may have been caused by
the Horizon IT system but it wouldn't show you if the
Horizon IT system as a whole had difficulties or
problems?
Not necessarily. If we were looking at 47 cases, then
if there is a reason behind them, I think you're
probably as likely to find it by following the money,
and really getting to the root cause of each of those
29
around in all sorts of ways: in revenue, in profit, in
cost control, in everything.
So Alice and I thought that the CEO and CFO that we
had, Paula and Chris, were okay but, actually, Post
Office, in the mess that it was, needed somebody that
was great. So pretty much every email I wrote to Paula
at that stage was encouraging her to grip things, get
traction, keep control, make progress. So that isn't
an unusual statement. It's basically saying, "You are
the CEO, yeah, get control, drive things, manage things,
lead things, get traction, make progress".
Well, the process here that's being referred to isn't
anything to do with profitability, is it?
No, it's not.
It's nothing to do with the matters that you referred to
about the dip in profitability. This is to do with the
process of the review of cases by Second Sight?
Sure.
In fact, is what you were doing here encouraging
Ms Vennells to take control of the process to gain
a favourable outcome for the Post Office?
Absolutely not. So Alice and I are encouraging Second
Sight. We want Second Sight. I think Lord Arbuthnot
and the MPs had been trying to get traction with Royal
Mail Group for some time. Alice is there going "Yeah,
31
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
47, as opposed to doing a code-based review. So I'm not
sure that a code-based review would actually come up
with a problem either. So actually, it did seem
a reasonable way of understanding what that was. If
there was one, I'd absolutely agree with you but, if
you're looking at 47, then you should be able to
determine where there are themes which actually are
a common theme which are a problem/a flaw in Horizon.
So was it your view, then, that if the 47 cases came
back and no problem was found on those 47 cases alone,
then that would have given the Horizon IT system
effectively a clean bill of health?
I think that's what I thought and I think that's what
Second Sight were telling us.
You say in the email:
"Definitely good to keep control of that process.”
What do you mean by “control of that process"?
So this -- again, I cannot remember exactly what I meant
when I wrote that 12 years ago. If I tell you what
I think I meant, it was less about that process and more
about how Alice and I were trying to manage Paula.
Paula was new in position. Paula was the Managing
Director who had effectively presided over the very
sharp deterioration in profitability, so she was the MD
of POL in RMG Group, and we needed to turn the business
30
I'm listening to you. Yeah, I believe you, I want to
find something, so we will appoint somebody”. I am
there absolutely supporting the appointment of somebody
and actually in my mind going, “Should it be Second
Sight or should it be somebody better". So in no way
shape or form were we not trying to find things. We
were trying to find things. We were trying to
understand and to fix things.
However, in any process, be it about profit or cost
or -- it’s just leadership of the business. So I want
the CEO to lead properly and that means taking control
of things.
Let's jump forward to when the Interim Report is about
to be announced. Can we have POL00021515, please. That
is a Board meeting on 1 July 2013. You're in
attendance -- sorry, you're present. If we can scroll
down, please, we see it's about Horizon and Paula
Vennells is giving an update on the Horizon review. Do
you have any, now, positive recollection of this
meeting?
So from the minutes is my only recollection of it.
I think actually it wasn't a meeting about Horizon.
I think it was a meeting regarding network subsidy onto
which Horizon was tacked on at short notice with no
warning.
32
(8) Pages 29 - 32
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
It says:
"_. gave an update on the Horizon review which was
being undertaken by Second Sight and their Interim
Report which was due to be presented at a meeting of MPs
‘on 8 July. The investigation to date has found no
systemic issues with the Horizon computer system but had
highlighted areas for improvement in support areas such
as training.”
What did you understand "systemic issues" to mean?
I think I believed systemic issues to refer to the code,
the software. So was there a problem with the software,
which would be a flaw in Horizon?
Were you told how many cases that Second Sight had
looked at, at this stage?
At this stage, I don't think I was told. My
understanding will have been that they had 47 cases that
were in their remit. But I don't think, on this call,
there was a conversation about cases.
It goes on to say:
"The CEO explained that the Horizon, like any large
computer system, would occasionally have anomalies, and
two were known of over recent years. The Business had
dealt with these anomalies to ensure no subpostmaster
was out of pocket and these anomalies had not affected
any of the cases which Second Sight had reviewed."
33
expected and could lead to loose language at the MP.
meeting.
"The Board asked the Business to challenge Second
Sight to ensure changes were made to the report where
possible and asked the Business to prepare their
communication to combat any inaccuracies."
Do you recall if any examples were given of the type
of inaccuracy that the CEO was referring to?
I do not recall that, I would doubt if that was the
case. So again, I'm sure that there were no written
papers for this. This is Paula doing a short, verbal
briefing over a phone call.
What was your view on that the way it was presented to
the Board at this time, on what is clearly a significant
issue?
I was upset. So I was upset that we were being told
a week before the report was going to come out that the
report was going to come out. So I would have wanted to
understand. We had -- the Board had asked several
times, many times over the year, "How are Second Sight
getting on?" So to have it dropped on us not in
a proper, written communication, not at a proper Board
meeting with proper papers, but just to have it thrown
in as an AOB to say, "Actually Second Sight Report is
coming out next week, and we're not happy with it
35
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
What did you understand or take from the word
"anomaly"?
Again, memory vague but I think that I will have taken
that as being —- I guess, in my mind, I will have
likened it again to an iPhone release. If there is
an iPhone release and then some part of that doesn't
link with some other part of the system, then that's
a problem, a flaw. So I think a flaw.
Were you told anything about when the anomalies were
discovered?
I cannot recall if that was conversed on this call. So
again, just to stress, this phone call, I believe it was
a Board phone call.
Yes, we don't need to go to it but it says at the top
"Held by conference call".
Yes, and it was about a totally different issue. So
Horizon was just dumped on us in this phone call at
short notice. So no papers and squidged on as an extra
little piece. So my memory is that it was a very short
update about Horizon on this call because the majority
of it was about, I think, network subsidy. I might be
wrong on that.
If we turn over the page, please, it says:
"The CEO was concerned that the report from the
independent forensic accountants was not as factual as,
34
because it's inaccurate and, by the way, there are these
bugs/flaws", I wasn't happy with that and I don't think
the rest of the NEDs were happy with that. It's not
a good way to run the business of the Board.
Did you discuss with Alice Perkins or -- sorry, I'll
start again.
Did you discuss with Alice Perkins your concerns as
to how it was handled at this point?
I cannot remember if, on that phone call, I had that
conversation. I am sure that -- the NEDs spoke a lot
with each other, so I am sure that I and others did talk
to Alice and talk to each other to say that we were
unhappy with this process.
Can we look, please, at the Interim Report, when it came
out. It's POLO0130412. I think your evidence is that
you think you read this at some point between 8 July and
16 July; is that correct?
Correct.
If you turn to page 5, please, and go a bit further down
to the bottom. Thank you. It says:
"Did defects in Horizon cause some of the losses for
which [subpostmasters] or their staff were blamed?"
Paragraph 6.4:
"In the cause of our extensive discussions with
[Post Office] over the last 12 months, [Post Office] has
36
(9) Pages 33 - 36
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
disclosed to Second Sight that, in 2011 and 2012, it had
discovered ‘defects’ in Horizon Online that had impacted
76 branches."
Then, over the page, we see at 6.5 and 6.6 there are
references to the number of branches affected and the
quantum of the shortfalls and surpluses.
At 6.7 it says:
"[Post Office] was unaware of this second defect
until, a year after its first occurrence in 2011, it
reoccurred and an unexplained shortfall was reported by
[a subpostmaster].”
Now, what were your views when you saw this
information as to two defects that had caused shortfalls
and gains in branch accounts?
Again, I'll tell you what I think I remembered but my
memory is inevitably a little bit vague -- more than
10 years ago. I was not as worried as, with hindsight,
I should have been when I read this. So we had been
told by Paula that these anomalies/bugs were not in any
way linked with the cases that Second Sight were
reviewing. Second Sight themselves -- if you go to the
conclusion of this paper, Second Sight say there are no
systemic problems with Horizon, and then they -- in
fact, is it possible to scroll down to the conclusion
here?
37
assured by various members of the business that data
integrity wasn't an issue, you agree?
Yes.
Did it not concern you that, during that time, members
of the Executive hadn't raised the fact that there were
two bugs that affected 76 branches in circumstances
where there were allegations of a lack of integrity in
the system?
Yes, it did. So just to be clear on that answer, so
I was not overly worried about the bugs. With,
hindsight, I should have been more worried but the way
this was written and the way that it had been explained
to us by Paula, on the 1st and subsequently, it did not
make me overly worried. What did make me worried is
that we were only finding out about it at this stage.
So I thought that the way that it was being communicated
to the Board was poor. The way it was launched on the
Board on that 1 July phone call was, I think, was
unacceptable and I wanted to -- I wanted us to have
a different relationship with the Board, so that we were
told -- I wanted information to come to the Board freely
and quickly, and clearly it wasn't.
So the way it was communicated did worry me. The
actual fact that we had two bugs did not worry me as
much as it should have.
39
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
po
29 July 2024
Yes. It's page -- I think it's page 8.
So:
"We have so far found no evidence of system-wide
(systemic) problems [that's the same] with the Horizon
software.
"We are aware of 2 incidents where defects or 'bugs'
in the Horizon software gave rise to 76 branches ...
which took some time to identify and correct.”
So I am reading that but it's not actually raising
a huge red flag to me. So it is saying that there are
bugs but it's also saying to me that -- but it is --
it's underneath the main point, which is there are no
systemic problems with Horizon.
So I'm getting the impression from this -- wrongly,
with hindsight, but I'm getting the impression that "We
have found the bugs, okay, one of them took time", they
are not related to the 47 cases that Second Sight are
reviewing and, in their report, they also say, "Every
system has bugs, it's inevitable". So it was probably
an amber flag but it wasn't a red flag to me.
You had been dealing or were aware of -- I should say
aware of -- challenges to the integrity of Horizon since
at least 12 January 2012; do you agree?
Yes.
As you say in your statement, you say you've been
38
Was it not beyond that and do you think it should have
caused you to be more questioning or distrustful of the
information that was being provided to you by your
Executive?
So Second Sight are not saying that this is a big
problem. I'm reading the Second Sight Report and the
thing that I'm getting from Second Sight Report is that
there are no systemic, system-wide issues with Horizon
but there are significant issues with training, support,
call centre, et cetera, and that was the main message
that I got from Second Sight. It wasn't bugs are the
issue. What I read Second Sight and understood was the
issue is around not the code, not the software, but the
support package around Horizon, which was inadequate and
needed to be fixed.
And I believed that. I mean, intuitively, that is
also what I believed. As I had gone around to post
offices, lots of subpostmasters would say "It's not easy
to use, it's clunky, it's not intuitive, your helpline
isn't helpful". So as I read Second Sight's Report, it
resonated with me and I thought "Yeah, okay, I agree",
and I agreed with their broadening definition of the
Horizon system. So they were at pains to point out
that, in their view, Horizon wasn't just about the code,
the software, which I thought, yes, I agree. The
40
(10) Pages 37 - 40
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
22
23
25
The Post Office Horizon IT Inquiry
horizon system should be a wider thing. It's about the
user experience.
So as I read the Second Sight Report, which, you
know, this document is about, my takeaway wasn't "We
have had two bugs that have been found and weren't
responsible for the subpostmaster losses", my takeaway
from it was that the Horizon system, our old definition
has been overly narrow, we need to broaden that
definition and we need to fix those things.
MR STEVENS: Sir, that's probably a good time to take our
first break, as we are moving on to a different topic.
I know it's slightly early --
SIR WYN WILLIAMS: No, that's fine, Mr Stevens. What time
shall we resume?
MR STEVENS: 11.05, please, sir.
‘SIR WYN WILLIAMS: Fine.
MR STEVENS: § Thank you.
(10.54 am)
(A short break)
(11.06 am)
MR STEVENS: Good morning, sir. Can you still see and hear
us?
SIR WYN WILLIAMS: Yes, thank you.
MR STEVENS: I I'll carry on.
Mr McCausland, we were looking at assurance and we
41
assurance over whether there were, in fact, weaknesses
or points of malfunction in the system.
A. So, personally, I actually felt, after the Second Sight
Interim Report, I was pleased with it. I thought that
we had found what the problem was. So there were -- as
we went into the Mediation Scheme and 150 people came
into the Mediation Scheme, I thought to myself, "Okay,
that's good". I mean, Second Sight have identified that
there is a problem with Horizon system, not the code,
but the wider system, and 150 people have come into the
Mediation Scheme to say, "We have been affected by this,
training, ATMs, support, helpline", whatever, and
therefore I was actually feeling quite good that we had
identified what the issue was.
Q. Pausing there, you were presumably aware that people
coming into the scheme included people alleging that the
system had flaws?
A. Yes, alleging that, yes.
Q. Just taking what you say at 166 at --
A. Sorry. So I wasn't -- all of the cases were individual
and were confidential, so I wasn't aware of the
individual cases, but my feeling was that the -- and, as
we went through this, again, we were getting reports.
So, before we got to the March '14 date that you're
talking about, the Board would have had an update,
43
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
got up to the Interim Report. I now want to look at the
assurance after that, so we'll take the chronology
a little bit out of order but stay on this same theme.
I'm going to jump to March 2014, so at this point, for
context, the Mediation Scheme is in full swing. Post
Office Limited are conducting investigations into that
and there's the query of compensation. We then have the
Linklaters advice in March, and I want to explore that
and what came afterwards.
Can we look, please, at your statement, page 62,
paragraph 166. So 166, you're talking after the
Linklaters advice itself but what you say is:
"The Linklaters advice appeared to share the Board's
view that Second Sight's Interim Report did not
adequately address this ..."
There you're referring to getting to the bottom of
whether there was any evidence to suggest that Horizon
was not working as it should be:
particularly where any weaknesses or points of
malfunction had been identified."
So, in terms of your thinking, following the Interim
Report, is your position that the Interim Report hadn't
disclosed anything -- I think earlier you said it might
have been an orange flag, nothing particularly
concerning, in terms of bugs, but it hadn't given you
42
probably a couple of months before that saying, "We have
now investigated 74 [I think it was] of the cases and
not found anything in Horizon", but they are about the
wider issue, so I wasn't aware of the individual
specifics --
If I could just be clear here what you're saying.
You're not aware of the specifics but between the start
of the Mediation Scheme and to March 2014, were you
aware, as a matter of generality, that some of the
applicants to the Mediation Scheme were alleging that
discrepancies had been caused by problems in the Horizon
IT system?
Inevitably, yes. But my understanding of that is the
broader IT system. So I'm not -- I wasn't aware of any
of the specifics and my understanding was that, as we
were going through, we had a team of 20 people, yeah,
trying to work their way through the individual case
reports, and the message that we were getting back was
that, as they were being worked through, it was
consistent with the Second Sight Interim Report, ie that
we could explain those things. Nowhere in those,
I think, 74 reports was there an indication that there
was a software or a bug problem.
When you were referring to the 74 reports were you
referring to the investigations conducted by Post Office
44
(11) Pages 41 - 44
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
The Post Office Horizon IT Inquiry
Limited?
Yes.
I think it's simplest just to go to the advice at this
point. If we go to POLO0107317, please. So this is the
Linklaters Advice, 20 March 2014. Now, before moving on
to the substance, can we just turn to page 2, please,
and paragraph 1.4. It says:
"Absent such proof that Horizon is not working as it
should, the Post Office should be able to recover losses
which the Horizon records indicate are owing on
an individual SPMR's account. If the Post Office is
entitled to recover losses, then there can be no
question of a consequential loss claim on the part of
the [subpostmaster] relating to their recovery ..."
Alwen Lyons gave evidence to the Inquiry on 21 May
2024, to the effect that she thought you would have
thought this paragraph was good because the Post Office
could put a lid back on the can of worms and pay very
little. Does that fairly summarise what your views were
of the Mediation Scheme at this point?
Absolutely not. So I think Alwen was -- Alwen's words
were basically that I was the pragmatic one on the
Board, and I think --
Sorry, when you say Alwen's words, when are you
referring ~
45
1.5 billion that it's tying to go through. If you spend
15 million, which was my suggestion, as goodwill
payments, it's chicken feed. It's not an existential
crisis. So I'm actually the one -- I think I was the
‘only one -- who was saying "We should pay something if
it will solve it".
So you disagree with the point I just put to you?
Yes.
Weill just move on.
We could turn, please, to page 3 paragraph 2.3:
"Importantly, Jo Swinson, Parliamentary
Under-Secretary of State for Employment Relations and
Consumer Affairs, noted that there was no evidence of
a systemic problem with Horizon. This has also been the
Post Office's conclusion on the information so far
available to it. We note that there is, so far as we
understand it, no objective report which describes and
addresses the use and reliability of Horizon. We do
think that such a report would be helpful, though there
is a decision to be made about how broad and/or thorough
it needs to be."
So, at this point, you've referred to past sources
of assurance you'd had but you have Linklaters now
saying there is no objective report which describes and
addresses the use and reliability of Horizon; was that
47
1
2
3
4
5
6
7
8
9
10
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A
a
A.
29 July 2024
You just quoted Alwen's evidence --
Yes.
-- and Alwen's evidence was -- she wasn't saying that's
what I had said; she was saying that was her view of
what I might have been thinking but she was doing that
‘on the basis that I was the pragmatic person on the
Board. I think, actually, exactly around that time, you
have already disclosed to me an email from me to Paula,
where I was the one actually suggesting that we should
pay significant amounts of goodwill compensation. So
I said to -- I put an email to Paula in advance of
a Board discussion that says, "This is growing, and the
potential bill to the Post Office is huge. We are at
the moment saying that we are not going to pay
consequential or goodwill payments of any scale but,
actually, why don't we? Why don't we just say that the
worst cases get 75K, medium 50K, 25K, doesn't matter how
you do it" -- I think in the Board meeting I actually
doubled those figures -- "if you did that and paid
a significant amount of compensation, then you might
actually get out of this".
So Alwen, I think, is right in saying that I was the
pragmatic one, but I'm not the one -- this isn't
EBITDAS. So this is not sustainable profit. This is
an exceptional cost. The Post Office has got
46
a surprise to you?
So when we were having the original Second Sight -- "Are
Second Sight the right people" discussion, at that stage
there was a discussion about could you actually -- can
you do a system review? Does the code exist? Is it
possible to do that? I think, you know, Second Sight
had said to us that actually it would be a very
difficult, almost impossible, thing to do and, when we
subsequently had Deloitte do it they also said, broadly,
the same thing. So a proper code-based review was
almost impossible and, therefore, I don't think it was
a total surprise --
Just pausing there, it doesn't say that there needs to
be a code-based review, does it? It says that there
isn't an objective bespoke report that describes and
addresses the use and reliability of Horizon. Did you
think that there was such a report, an objective report,
describing and addressing the use and reliability of
Horizon before then?
Probably not. I don't think it was a surprise, no.
So did that strike you as troubling, given it's a few
years down the line of dealing with these claims and
there's no such report available to the Post Office?
Well, the whole point of appointing Second Sight was to
find the issues and find flaws. So if you go back to
48
(12) Pages 45 - 48
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
The Post Office Horizon IT Inquiry
Second Sight's remit, they were there to actually go
through the cases and find a flaw in Horizon, and their
advice was, and we believed it, we agreed, that that was
the best way to do it. And Second Sight were doing
a number of reports about the reliability of Horizon.
So Second Sight were, right then, working on
an Interim Report -- so it wasn't a -- they called it
a Part One report, I think -- which did describe Horizon
and the way it was being worked. So my understanding
was that that was what we were using Second Sight to do.
Let's look onwards please, page 9, paragraph 5.30. It
says:
"It is the reliability of the Horizon system as.
a matter of principle which important. If there are
doubts about the reliability of the system then this
could obviously impact on the Post Office's ability to
claim losses since it calls into question whether such
losses exist at all. This is the fundamental question
and one which has not yet been satisfactorily addressed.
"Second Sight have not done what we would have
expected them to in terms of an investigation into
Horizon. The logical and obvious start for their work
would have been a thorough review and description of how
Horizon is supposed to work, its day-to-day use by the
[subpostmasters] and an in principle identification of
49
Can we look at the Board meeting where that was
discussed, please. It's POL00021523.
Sorry, can I make one comment about the Linklaters
report?
Yes.
So it does also say in the Linklaters report that, even
absent such a report that Deloitte then turned out to
be, Post Office still had good reasons to believe that
the losses -- that they should not be paying
consequential losses, due to the level of assurances
that existed, such as ISAE 3402, such as Fujitsu, such
as Gareth Jenkins and Anne Chambers. So they don't say
“Huge red flag you shouldn't be doing this"; they say,
"Actually, you've got a lot of good evidence but, in
addition, it would be really helpful to have Deloitte",
and I absolutely agreed with that.
We've got the Board minute here it's 26 March 2014.
You're present and we also see in attendance, five down,
Christa Band from Linklaters. If we go to page 2,
please, we don't need to go through it but Ms Band makes.
various criticisms of the Second Sight work.
At (f) we see that, at that point:
"The Board thanked Christa for her report ...
Christa Band left the meeting.”
So, presumably, in terms of reading these minutes,
51
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
any weaknesses and likely points of malfunction."
Pausing there, what Second Sight had been asked to
do was look at individual cases, I think, to use your
words, trace the money; is that right?
Originally but then that morphed. So then the -- now,
at this stage, Second Sight were doing their Part One
and Part Two thematic reviews, which were, to some
extent, explaining how Horizon worked and where the
points of weakness were.
Pausing there, by this stage, the reports, you hadn't
seen them or they hadn't been released?
Correct, yeah, we knew they were working on them but
they were taking a long time because Second Sight were
trying to do a lot of things at the same time.
We see at paragraph 5.32 it refers to Second Sight being
due to produce the generic report in due course.
Yeah.
At this point, having read this, did you think it was
important to follow Linklaters' advice and get
an objective report that looked at the use and
reliability of the Horizon IT system?
Yes, I did.
That's why, presumably, Deloitte were subsequently
commissioned?
Yes.
50
just to confirm, everything from (f) down is without
Christa Band being present?
assume so.
We go to (k), it says:
"The Board agreed that they needed to commission
a piece of work, to complement that undertaken by
Linklaters, to give them and those concerned outside the
Business, comfort about the Horizon system."
Why did the Board wish to obtain a piece of work to
give it comfort about the Horizon IT system?
I think we -- so, back in February, there had been
a very large difference in the potential bill that the
Post Office would be paying, ranging from 6 million to
100 million and we, internally, on the Board had had
some discussions. I was suggesting significant goodwill
payments. Others were saying no, the Linklaters work
basically said that the key determinant of that was
going to be how robust we were with our belief that
Horizon was not malfunctioning and, therefore, in the
absence of Second Sight's work that they were still
doing, it was going to be very sensible for us to
actually have another piece of work.
So is that another piece of work to shore up the Board's
position or an objective review to understand whether or
not Horizon's data integrity is satisfactory?
52
(13) Pages 49 - 52
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
The Post Office Horizon IT Inquiry
I mean, the Board didn't really have a position. The
Board just wanted to get to the truth.
Well, if the Board wanted to get to the truth, would it
not say at (k) "The Board decided to commission a piece
of work which would be an objective investigation into
the Horizon IT system and its integrity", rather than
saying that it wanted “comfort about the Horizon IT
system"?
So that's a fine point of wording and Alwen wrote the
words but I can tell you that the people on the Board,
the NEDs on the Board, always just wanted to know the
truth.
There is absolutely no benefit for a NED in trying
to hide the truth.
So did that mean, for you, a report that described the
Horizon IT system and commented on how it worked in
practice?
Yes, and identified potential flaws.
It refers to the terms of reference. The first bullet
point says:
"The work undertaken by Angela van den Bogerd
explaining how the system works."
Can you help us with what that’s supposed to mean or
why Angela van den Bogerd is referred to in respect of
these terms of reference?
53
final is:
"A response to the most significant thematic issues
raised by Second Sight."
Why did an objective report or investigation need to
include a response to the thematic issues raised by
Second Sight?
I don't know, to be honest. I don't remember reading
that or thinking about that last bullet point, and
I don't remember any discussion about that last bullet
point.
Just so we're clear, when you say you don't recall it,
are you suggesting in any way that this might be
inaccurate in terms of what was discussed or not?
No, no. I'm simply saying that I do not remember any
conversation that the -- at that meeting, after
Linklaters had gone, which was, "Yeah, and we need to
have a response to the significant thematic issues".
Could we look please at --
Ina way, it doesn't worry me. If you are getting
somebody else to actually do a piece of work, I think it
would be sensible for them to see the Second Sight work
and to consider that and either to validate or refute
those issues.
Could we look, please, at POL00148075.
This is a Project Sparrow subcommittee meeting. You
55
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
So after the Interim Report from Second Sight, there
were a number of workstreams which came out of that,
Working Party, Mediation Scheme, Lessons Learned but, to
me, probably one of the most important was the Business
Support Programme or the Business Improvement
Programme -- it's called both things -- which basically
took the Second Sight Interim Report findings and then
tried to wash those through the business and fix things
which were not correct. So it fixed the training, fixed
the cultural issues, fixed the helpline, fixed the way
we suspended subpostmasters. It did a lot of things.
So the non-IT issues is what that's referring to?
Yes, so it's not about -- I don't -- some of it,
I think, it does touch on IT but it's primarily the --
I say -- the word “cultural” is a bad word but, if you
understand what I mean by the cultural issues that are
identified in the Second Sight Interim Report, I think
that is what it means. And as a -- if you are going to
describe the use of Horizon and articulate that in
a document, then the work that that Business Support
Programme had done, I think, would be very useful as
a starter for ten in that. So that's as I understand
that.
So that's the Business Support Programme. We've then
got two bullet points on data integrity issues. The
weren't in attendance at this meeting and I understand
you didn't attend the subcommittee; is that right?
Correct.
In your statement, page 46, paragraph 125, you refer to
these minutes going to the Board. Would you have read
them?
Yes.
If we look, please, at page 4 and go down to the "Update
on Horizon Online HNG-X (‘Horizon’) Assurance Work", at
point (b) it refers to two parts. I'm not going to read
it out because it's known well to the Inquiry but,
effectively, Part 1 is a desktop-based review, and it
says, you see at the end:
"The assessment [of Part 1] will not consider the
integrity of the Horizon processing environment at
implementation. That would form Part 2 of the work."
It then goes on to say:
"although no system could be absolutely
‘bulletproof, no issues had yet been identified through
the cases being investigated or any other route that has
called into question the integrity of Horizon. Nor have
any widespread systemic faults been identified since
Horizon Online was implemented. These two points, along
with the Part 1 work (depending on the results) should
be sufficient to assure Post Office that Horizon is fit
56
(14) Pages 53 - 56
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
for purpose.”
Firstly, can you recall reading this document when
you received it?
I cannot recall reading it but I'm sure that I did read
it. The minutes of the subcommittees would have been in
the Board pack and I would have read the whole Board
pack.
Did you discuss this approach to the Deloitte work with
any of the Non-Executive Directors?
I cannot remember discussing that. I think it is
unlikely that I did. The way that the subcommittee
minutes worked was generally they were in the Board pack
and the chairman of the subcommittee would generally
give a very short -- of the relevant subcommittee --
would give a very short description of what happened and
take questions. But there was rarely a substantive
discussion regarding the minutes of the subcommittees,
of which there were many subcommittees. So I doubt that
there was a substantive discussion about that.
Did you see any problem at the time with the plan not to
commence or go forward with the Part 2 work?
No. I wasn't in the subcommittee. So I mean -- can
I just explain the way subcommittees work?
Well, we've --
You know that?
57
We already know that it is -- we've already had
conversations that Part 2 is going to be potentially
difficult because the data may not exist, its very old,
it's very disparate, and therefore Part 2 may not be
possible and, if it is possible, it may be very
difficult. So to have it in a bitesized chunk feels
sensible now, it felt sensible at the time.
So, in your view at this point, Part 2 hadn't been
written off, it was an open question to be assessed
after Part 1?
Absolutely, yeah, and I think that it says it very
clearly that the SSC have a task, which I think is in
the minutes here, in the action points, that the SSC
have a task to get the CIO to come along and talk about
when and how and if -- are we going to do Part 2. So
Part 2 is absolutely there as a scope but the scope has
been split into two parts.
I think I should just clarify one thing. When you say
"SSC", I assume you're referring to Sparrow
Subcommittee?
Yes.
There's another SSC in this Inquiry, that's why I just
wanted to double check that.
Apologies.
No, you don't need to apologise. Let's move on in the
59
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
We have that, how they work. But you would have read
this, yes?
I would have read it but --
You are there as a Senior Independent Director to assist
the Post Office with strategy, yes?
Yeah.
Part of that strategy is how the Post Office was to
respond to claims about the integrity of the Horizon IT
system, yes?
Yes.
That was important, not just for the applicants in the
scheme but for how the data that Post Office relied on
to produce its account was prepared?
Yes.
So when you have a suggestion from Linklaters that,
firstly, there's no objective review into the integrity
of the Horizon system, (2) that it would be a good idea
to get one and the Board has suggested getting one, why
did you not see the problem with stopping at a desktop
review?
I don't think it said "stopping". It said that it was
going to be a two-part exercise. It's quite sensible.
So -- it's quite sensible to break an exercise down into
two parts. The first part being Part 1, and see where
you get to at Part 1, and then take a view about Part 2.
58
chronology, POL00021524, please. It's a Board meeting
‘on 30 April 2014. You're present and, if we can scroll
down, we see at the bottom Gareth James of Deloitte is
also in attendance.
Can we turn, please, to page 6. If we go down,
please, so subparagraph (d), it says:
"Gareth James reported that all the work to date
showed that the system that strong areas of control and
that its testing and implementation were in line with
best practice. Work was still needed to assure the
controls and access at the Finance Service Centre."
Now, I think in your statement -- but do correct me
if I'm wrong -- you criticise that this oral briefing on
the work to date was incomplete or inaccurate?
Can I just ask, where are you taking that from?
Yes. If we could bring up the witness statement on the
screen at the same time, and page 75. If we could go to
the bottom, please, paragraph 200:
"I do not think that the Board received the full
Deloitte Project Zebra Report. I do not know if the
Sparrow subcommittee saw it.”
You then say:
"The Board was given a somewhat misleading verbal
briefing and an incomplete Board Summary, neither of
which clearly exposed the serious problems that Deloitte
60
(15) Pages 57 - 60
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
>
prop
The Post Office Horizon IT Inquiry
found."
Now, the incomplete Board Summary is a reference,
I'm sure, to 4 June.
Yes.
We're going to come to that in an email from Chris
Aujard and Rodric Williams. When you say "somewhat
misleading verbal briefing’, is that referring to --
Yes.
~ the 30 April Board meeting?
Yes.
Okay. So if we could bring that Board meeting back,
please. It's POL00021524, page 6, please. Just back
down to (d), please. So (d) is the paragraph I read out
before. Now, do you have any independent recollection
as to what was said at this meeting or are you reliant
‘on the minute?
I do not have any recollection of the meeting itself.
1am reliant on the minutes. But I -- so I probably
would have remembered it, had I come out of the meeting
with a big worry, and I do not remember coming out of
that session with a big worry and, therefore, I think
that I listened to Gareth James. He had the day before
given a small document but, basically, I came out of
that session thinking "Yeah, we're in pretty good
shape".
61
And specifically asking Deloitte in their investigation
to try to understand is there validity in that.
So it was an important matter, you thought?
Correct.
Then at (f) we see:
"The Board asked what assurance could be given
pre-2010 when the different Horizon system was in use.”
It said Gareth James would go on to cost that up,
effectively.
Why was the Board concerned to look pre-2010 as
well?
So the vast majority of the prosecutions took place
before 2010, under Royal Mail Group, under old Horizon.
We understood that it was going to be difficult to get
assurance because of the age and just -- mainly because
of the age but, if there was an opportunity to get
assurance on old Horizon as well as on online Horizon,
then that would be helpful and useful.
So you specifically mention there that, in the Board
processes of thinking when -- asking for the pre-2010
work, it was considering how that might affect past
prosecutions?
I'm not sure that it was yes, implicitly. We just
wanted -- at that stage, we weren't really thinking so
much about the prosecutions; we were thinking about the
63
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
So Alice Perkins gave evidence to the Inquiry saying
that she thought the Board had the impression that
Deloitte were going to able to write a report giving, if
you like, Horizon a clean bill of health; would you
effectively agree with that?
Yes.
“Work was still needed to assure the controls and access
at the Finance Service Centre."
You accept, presumably, at this point, that it was
an interim report, effectively?
Absolutely.
If we look down -- we may as well cover it while we're
here -- it says:
"Chris Aujard explained that several subpostmasters
who were challenging Horizon had made allegations about
‘phantom’ transactions which were non-traceable.
Assurance from Deloitte about the integrity of the
system records would be very valuable.”
That's presumably referring to the remote access
issue, is it?
It is and, actually, "phantom transactions" was probably
a phrase that was used more than "remote access" but,
yes, it means the same thing.
So, by this point at least, you were aware of the
allegations about remote access?
62
integrity of Horizon. So the linkage to past
prosecutions wasn't high in the mind. It was -- so
Deloitte were looking at what is the integrity of
Horizon Online like? We also would like to understand,
if we could, what was the Horizon -- the old Horizon
integrity like?
But it was in the background and so, presumably, made
this work all the more important?
Yes.
Could we look, please, at POL00304159. If we could go
down, please, to Larissa Wilson's email. We see it's
from Larissa Wilson, you are in the distribution list,
29 April 2014, so it's the day before the meeting we've
just been to:
"Please find attached the draft report for item 6
attached. This paper will also be available on BoardPad
and hard possibly will also be provided at tomorrow's
meeting.”
Could we then look at the attachment to that, which
is POLO0304160. I appreciate you've been given this
document we're going to now this morning.
So we see it's a Deloitte report, "Review of
Assurance Sources, Executive Summary". I think behind
"Draft", it will say, "Emerging findings at 29 April
2014". Do you remember having read this report or do
64
(16) Pages 61 - 64
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
you remember receiving it?
I don't remember receiving it, although I don't doubt
that I did.
If we turn the page, please, to page 2. I should make
it clear you didn't have this report when you drafted
your witness statement. You refer to a separate report
around this point --
(The witness nodded)
-- so that's why I'm taking you to it now.
Under "Overall comments" -- I'm not sure why the
"DRAFT" is appearing in front on this is screen but
there we are. It says:
"A significant amount of work has been performed
In fact, it may, sir, be better to come back to this
at a later stage. Actually, we don't need that part.
We can go and look at the bottom paragraph.
It refers to:
“Our main recommendation for improvement in the
assurance provision therefore would be for [Post Office]
to extend the formal risk and control framework, already
in place for general controls, to also embrace key risks
and controls holistically across the [Horizon Online]
processing environment. For example, to include
controls in specific risk and thus more operational
65
. Content and Key Extracts; DRAFT -- for validation in
advance of Board discussion on Wednesday 30 April".
Now, Gareth James will give evidence to this Inquiry in
written form that said that this formed the primary
basis of discussion for the meeting on 30 April.
As you say, you referred to it in your statement, do
you have any independent recollection of reviewing it
now or not?
Again, I do not have a recollection of reviewing it but,
if it were sent to me for a Board discussion, I will
have read it.
But, for example, you can't assist with, now, whether
this was in the Board room at the time when the
discussion was taking place?
I cannot but my instinct is that it was.
Could we look, please, at page 5. This is "Key Matters
for Consideration", and you see on the left there's
“Risk Area", in the middle the "Matters for
Consideration", and on the right the "Nature of Work
Done". If we could turn the page, please. We have "(4)
"Specific" on the left and, on the right, it says,
"Other work only, no assurance work noted". At (d), it
says:
"Audit Store: This records all transactional
activity and certain (key) system events. Work we have
67
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
areas of the business, such as the Finance Service
Centre."
So similar as to the minutes we just went to, yes?
A. Yes.
Q. If we go back, slightly up, please, we see under
"Overall comments" it does say in the first paragraph:
"This work is comparable to that typically see [it
will say] in other, similar organisations."
So you may not be able to recall reading it but, if
you had read this at the time, is that consistent with
the feeling you remember of being reassured?
A. Yes. I mean, I do not remember reading this at the
time. I'm sure I did read this at the time but the
combination of reading this and listening to Gareth
James the following day at the Board meeting will have
not made me feel rosy and warm, and clearly there are
things more to do, but not made me feel overly worried.
MR STEVENS: Thank you. That can come down.
Sir, just so you know, the version on the system has
the "DRAFT" behind the text, so when you come to read it
you won't have the same difficulties.
Q. Could we please bring up POLO00105635.
This is a document to which you refer in your
witness statement. If we go down slightly, please, we
can see it. It says, "Project Zebra -- Phase 1 Report
66
seen performed on this store has been performed by
Fujitsu and is not ‘evidence based’, as the
documentation provides a description of the process they
have performed only. It is also not clear from the
documentation that we have been provided whether:
"[Post Office] has agreed that the current capturing
of certain, key system events is complete and
appropriate for potential governance and investigation
needs; and
"Investigatory work on the Audit Store has all been
performed by Fujitsu who, whilst technically qualified,
do not constitute an independent nor experienced party
for risk driven assurance purposes, or what risk
analytic tools were used for these purposes."
If we go down to the "Key Potential Next Steps", we
have 2(b) "Audit Store Testing" for a key potential next
step:
“An independent party should review and test the
Audit Store functionality, as described within the
technical documentation provided by Fujitsu. This
should include certain data analytical tests or
underlying Audit Store data, to better understand,
profile and examine the operation of the store, and,
potentially use historic characteristics of incidents
and errors to analytically search for the
68
(17) Pages 65 - 68
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
characteristics and trends within the audit records."
Do you recall that being discussed at the meeting,
these key potential next steps and points raised about
the audit store?
I do not recall the conversation at that meeting.
Can you assist us with what your understanding would
have been of these issues, if you can put yourself in
the position of reading it at the time; so what would
that have told you?
I think that it's basically saying that a lot more work
needs to be done at Fujitsu and to just understand how
it works and get some independent -- or get them to
review it. So they're basically saying, you know, "We
need to look more at the audit store". I think --
Sorry.
Yeah, I mean, the -- at that meeting -- this is the
meeting, isn't it, where we're basically asking Deloitte
to widen their scope? So we'd set up part -- the
Sparrow Subcommittee had set up the terms of reference
for Deloitte, agreed it with Linklaters, agreed it with
the Sparrow subcommittee, got Deloitte started, got them
started on a Part 1., and then on the 30th, at the Board
meeting, that scope was broadened a bit, which included
phantom transactions, which undoubtedly would have been
in Deloitte -- in Fujitsu and I think this is also
69
evidence that on 30 April you came away feeling good
about Horizon or the work that was being done by
Deloitte.
So, I mean, I think I said I didn't feel warm and rosy
but I didn't have -- but I didn't have red flags.
I didn't feel overly worried. So there was clear -- so
I came away feeling -- this is an Interim Report, we
have already widened the scope --
Yes, I'm just trying to summarise where you are.
So I would have felt not warm and rosy but not overly
worried.
Let me just get to the question. That feeling you've
described, do you think you would have had that feeling
if these issues had been discussed on 30 April?
Yes, I don't think that those issues would have changed.
So again, I'm not reading that to say, "Oh my God, I'm
really worried", I'm reading that as to say more work
needs to be done and more investigation is required,
particularly in the audit store with Fujitsu.
Could we look to the product that was given to you,
please. It's POLO00029733. We see the email from Alwen
Lyons on 4 June, you're in the distribution list. It
says:
"Please [see] below a message from Chris Aujard and
Lesley Sewell ..."
ral
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
29 July 2024
saying that they should review and test the audit store
functionality.
Irrespective of whether -- well, you don't remember
reading it. Do you recall anyone from the Post Office
Executive either briefing you or informing you about
these suggestions in this document by Deloitte?
I don't but, to be honest, I wouldn't really have
expected them to, in that the Deloitte work was within
the Sparrow Subcommittee and, therefore, had I been on
the Sparrow Subcommittee, I might well have, but
I wasn't and, therefore, my -- the only notes that I saw
at the time and the only notes that the Inquiry have
given me, are the minutes of the Sparrow Subcommittee.
And, as we talked about before, in the reading of the
papers which would have gone to the Sparrow Subcommittee
and the hours that they spent to condense that down to
a few pages of minutes, inevitably means that I am far
less sighted on that than people who are on the Sparrow
Subcommittee.
In your statement, you refer to this Phase 1 report and
you say:
“It did not raise any particular red flags with me,
albeit I knew controls around the system needed
improving."
One thing I want to test is you earlier said in your
70
Sorry, I earlier said Rodric Williams; it was Lesley
Sewell who was joint on this.
If we could turn the page, please, so we see it
talks about the briefing, and it says:
"The briefing strives to be succinct and
intelligible. However, given the subject matter and
scope of the review, it remains somewhat technical.
Furthermore, it is based on a desktop review of
currently available information ... It is therefore
heavily caveated.
"In the briefing, Deloitte expressly identify
a number of limitations and assumptions which underpin
their findings ... The briefing must be read in this
context. That said, its key findings are ..."
I'm not going to read them out because I understand
you've read that summary.
Yes.
Can you just explain what your view was of the Deloitte
work or what you took from this summary?
From the summary or from the --
From the summary.
From the summary, I took, that -- well, I took this as
a good, affirmative report saying that Horizon was in
good shape. So I did not feel overly worried when
I read the summary.
72
(18) Pages 69 - 72
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
Did you acknowledge or understand from the summary what
the limitations were; what did you think they were?
Sorry, so when --
How much weight did you think you could place on this
report from the summary, based on the described
limitations?
Let me just be clear. So when I read this email -- so
there's an email from Chris and then there is the report
from Deloitte. When I read the email from Chris, I felt
good, in that the email was basically saying
Fujitsu/Horizon is in good shape. When I read the Board
summary, which was the condensed version on the full
report, I felt less good. It wasn't an easy read and
I don't have a vivid memory of this but my memory of it
is that I felt less good and I thought that there were
some questions which still needed to be answered in that
Board summary.
What were the questions that you thought still needed to
be answered from the Board summary?
So, again, my memory it's not complete. I'm trying to
remember back more than 10 years ago here. But I do
remember that, in one of their matters, which, with
hindsight, I can tell you is Matter 3, it basically says
that they have not found documented controls which, you
know, give Horizon the protection that it should have.
73
standards."
Then, when we go to (3), the "Limitations and
Assumptions", the desktop-based exercise:
"... significant gaps existing in the information
available ..."
The last bullet point:
"We have not validated or commented on the quality
of the documentation supplied to us.”
Then, over the page, the assumptions includes at the
bottom:
“Assertions made by [Post Office Limited] and
Fujitsu staff have been accepted as accurate without
corroboration or verification.”
So, taking that together, is this a fair summary of
the Deloitte work: they reviewed documents on how
Horizon worked and assumed they were accurate?
Yes.
Yes? They hadn't tested whether the processes described
within the documents had been implemented?
Yes.
Where there were gaps in documents, they may have spoken
to Fujitsu and Post Office staff and, where they have
spoken to Post Office and Fujitsu staff, they would have
accepted what they said as accurate without
corroboration or verification?
75
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
29 July 2024
So there were questions around that that definitely
needed to be answered. That wasn't how I read the email
and so there were two things in my mind: first of all
the email is over only positive; and, secondly, the
report itself still has some questions to answer.
I was going to turn to the report but let's just pick up
on that first. Did it concern you that the summary
email was positive in comparison to what you took from
the report itself?
Yes, again -- so I'm trying to remember back 10 years.
So I have not got a particularly clear memory of it but
I do remember feeling a disconnect between the email and
the report.
Did you do anything about that?
I cannot remember. I mean, if I felt a disconnect, it's
likely that I would have but I cannot remember what
\ did.
Well, let's look at the report, please. It's
POL00130618. If we could turn to page 3, now you've
clearly read this report, the Inquiry has seen it, so
I'm not going to go to it in any detail and try to
summarise it. At the start we see that Deloitte say
this:
did not constitute an audit or assurance
engagement in accordance with UK or international
74
Yes.
That didn't really meet the form of objective
independent review that Linklaters were suggesting:
would you agree with that?
Yes.
Did you acknowledge that at the time?
So, at the time, I felt that this was an unsatisfactory
piece of work, in that there were lots of limitations,
it wasn't a particularly easy or clear read, it was
giving us some assurance but there were a lot of areas
that still needed to be followed up.
Pausing there, when you say it's giving you some
assurance, this was doing no more than pulling together
and summarising other sources of documentation and
pre-existing assurance work; would you agree with that?
It was desktop exercise using existing documentation
but, yeah, we knew that's what Part 1 was going to be.
So what they were not going to do was to go through and
look at all the code in Horizon. So it was really all
that they could do.
So this hasn't really given any new or independent
assurance to the position before the Linklaters advice;
would you agree with that?
No. I --
If it's a desktop report that is looking at other
76
(19) Pages 73 - 76
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
assurance documentation, how does that give you --
Because I hadn't seen all the other assurance
documentation. So there were definitely things in this
report which had not previously been brought to my
attention. So I learnt things in reading this. So
I accept that the business may have had all of that
information but I'm not sure that it had been pulled
together, in a way. So if you go back to what
Linklaters were saying here, document the -- Linklaters
were suggesting that we had somebody actually go through
the design of Horizon and its use. So, inevitably, that
is going to be using existing documentation.
So is this coming back to the original point I put to
you earlier, that what was being sought here was
a document that collated existing assurance to use in
the Mediation Scheme, rather than a true independent
investigation itself?
I don't think this was to use in the Mediation Scheme.
I think this was to actually understand for ourselves
the integrity of new Horizon, Horizon Online.
If we go, please, to page 7, Matter 3:
“Baskets of transactions recorded to the Audit Store
are complete and ‘digitally sealed’, to protect their
integrity and make it evident if they have been tampered
with."
77
Yes.
Post Office said that that was visible to
subpostmasters?
Yes.
But, of course, Deloitte hadn't been able to test that,
just assumed it was true. Fujitsu claimed it had only
been used once but hadn't been tested, and there was no
knowledge of its use before 2008.
Now, we saw in the minutes of the Board on 30 April
that remote access, or 'phantom transactions’, as you
referred to it then, was a core issue. Surely this
would have set off alarm bells for you?
I think that -- so, even when I read thorough this, I'm
still of the impression that a change is visible. So if
a change is made that if I then follow the flow of
information, either through the central database or
through the audit store, that is a visible transaction.
The one issue that I think did worry me is the Matter 3
where it said "I haven't seen any documented controls
about this, and if, if, if, then there's a risk". So
absolutely it would say, okay, so what -- are there
documented controls that you just haven't found, are
there people who have all that relevant access? So
questions that need to be answered. But if they are
answered, I am still of the understanding that this
79
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
Then, just scrolling further down, it says:
"We have not identified any documented controls
designed to:
"Prevent a person with authorised privileged access
from deleting a digitally sealed group of data and
replacing it with a ‘fake’ group within the Audit Store
I think you say this was something you recall
earlier being concerned by; is that right?
Yes.
If we turn the page, please, to look at Matter 5,
Matter 5 is:
"Horizon provides visibility to subpostmasters of
all centrally generated transactions processed to their
branch ledgers."
We see (3), "Balancing transactions"; do you
remember if that caused you any concern at the time?
I honestly cannot remember if I, at the time, was
concerned by that. I do remember concern about the
document. I remember concerns that the email was too
positive and I remember the Matter 3. I may well, also
have been concerned about that but I honestly cannot
remember.
Looking at it, what it says is, firstly, Fujitsu can
create transactions in branch ledgers, yes?
78
needs to be visible.
I didn't say, "And, actually, previously Gareth
James said all transactions are visible", which is why
he thinks it would be easy to do the validation. That
is in the Board meeting. So the fact that it is
visible, I think, reassured me.
I can't see the [draft] transcript, when you said that
Gareth James said to you about transactions being
visible, what words did you use: ‘transaction’ and then
what was the one that followed?
So Chris Aujard, I think it's in the minutes --
Sorry, I asked you to clarify your evidence on what you
said Gareth James said about transactions.
So Gareth James -- it is recorded in the minutes that
Gareth James said to Chris Aujard, who reported it to.
the Board, that because transaction corrections are
visible, it would be easy for him to do his work.
So, at the time, did you have in your mind the
difference between transaction corrections and what
I just took you to in Matter 5, which was a balancing
transaction? Do you understand the difference between
them?
At the time, I don't think that I was probably
sufficiently aware of the difference between them but
I still had an underlying belief that a change, any
80
(20) Pages 77 - 80
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
change, would be visible.
So, based on this desktop report, I think did you accept
that it left a lot of questions unanswered?
Yes.
Why was this report not discussed at the Board?
So the Board meeting -- it was never due to be discussed
at the Board.
Well -- sorry can you explain why that was because --
Sorry, let me answer your question. So it wasn't ever
due to be discussed at the Board. It was due to be
discussed at the Sparrow Subcommittee meeting and,
actually, that's the right place for it. This is a very
detailed piece of work, the Sparrow Subcommittee had
commissioned it, they'd done the terms of reference for
it, they had been involved in it on their 9 April and
30 April meeting and we, the Board, had been told late
May that it was going to be considered at the Sparrow
Subcommittee meeting, and when the email came out, from
Chris on the fourth, it also said that it would be
considerate at the Sparrow Subcommittee meeting.
It wasn't due to be considered at the Board. It
would be a pointless thing to set up a Sparrow
Subcommittee, get them to be spending lots of time
understanding it, and then for the document to be
considered at the Board.
81
that should have been articulated to the Board, and I do
not think that either of those things happened with
hindsight.
Was it not brought back to the Board because the Board
didn't want to delve into the unanswered questions and
know the answers?
Absolutely not. The Board -- the NEDs, not once in all
my time there did the NEDs not want to get to the truth.
Not once did they avoid a difficult conversation or
an uncomfortable truth. There is no benefit fora NED
in doing that and there was no behaviour that I saw from
any of the NEDs that did that. So absolutely not.
I cannot explain to you why it was not considered at the
SSC, and I cannot explain to you why it was not brought
back to the Board.
Because what -- again, just looking here, we've had
a Magic Circle firm give written advice and a Magic
Circle partner go to the Board and talk on that advice,
a decision made to commission some work. The work is
commissioned by Deloitte, a Deloitte partner comes to
the Board and talks about it. This is then sent to the
Board and then it appears, from your evidence, that it
just drop off everyone's radar. Why didn't you ask in
any questions of or follow-up on this with, even outside
the Board, with Paula Vennells?
83,
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
>
a
A
prop
29 July 2024
Well --
The Sparrow Subcommittee is the right place for it to be
considered.
-- just pausing there. The Board had brought Gareth
James in for an interim presentation on where Deloitte
was. Correct?
Yes.
Yes?
Yes.
So the Board at that point obviously thought that it was
sufficiently serious or important to go over with
Mr James his findings to date, correct?
Yes.
The Subcommittee, as you say, can consider the report
but the fact that the Subcommittee considers it doesn't
stop the Board also considering it as well, does it?
But the Subcommittee should consider it first, in far
more detail than the Board would consider it.
But why, when we've discussed what your views were on
the report, why was this never brought back to the Board
for a discussion of what's happening next; what are we
doing next?
So it should have been. I cannot tell you exactly why
it wasn't. My view is that it should have been
considered by the SSC in detail and then a summary of
82
So it was clear from both the SSC on 31 May and also
from the email that we -- that came with the report on
4June, both of them were very clear that that is would
be considered by the next meeting of the Sparrow
Subcommittee. I 100 per cent think that is the right
place for it. The Sparrow Subcommittee has got the
Chairman, the Chairman of the Audit Committee, the
shareholder representative, at the CEO and the General
Counsel, so the five perfect people to do that. Two of
those are -- two of those are accountants, you've got
legal skills, you've got better IT skills than the rest
of the Board so the Sparrow Subcommittee have got the
expertise and the time to review, ideally not just the
Board summary but the full Deloitte report.
Can we --
So that is --
SIR WYN WILLIAMS: Sorry, stopping you there, Mr McCausland,
the obligation -- I'm calling it obligation because you
said that it should have been considered subsequent to
that Sparrow Subcommittee meeting -- who bore the
obligation to ensure that it was discussed? Tell me how
it would work in practice? Who should have, in effect,
insisted on a discussion by the subcommittee?
So the agenda for the subcommittee, I think, would have
been created by Alice, with help from Alwen, who, as
84
(21) Pages 81 - 84
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
Company Secretary, would determine all agenda.
‘SIR WYN WILLIAMS: Right.
A.
There are action points from the previous subcommittee
saying that the report would be considered at the next
meeting of the Sparrow Subcommittee. So that's how it
would have -- it should have been on the agenda for the
next meeting of the Sparrow Subcommittee.
‘SIR WYN WILLIAMS: So I'll summarise it, then you say
A
whether you agree.
As I see it, there's a failure in process in
ensuring that it's not on the agenda for the next
meeting but then there's a collective failure of the
five people who formed that subcommittee, nonetheless,
to ensure that they discuss it; is that fair?
That is fair.
‘SIR WYN WILLIAMS: Fine.
MR STEVENS: Thank you, sir, that actually was my next set
of questions, so it's probably a good time —
SIR WYN WILLIAMS: I'm very sorry, Mr Stevens, I just
thought I wanted it clear while it was in my head.
MR STEVENS: Yes, I'm always glad when you ask questions
2
before me.
Sir, on that basis, it's probably a good time for
the break because I'm going to move on to a different
topic.
85
I don't need to go through all the summary, if we
can turn the page, please, and go to the bottom of
page 2. It says:
“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. We had a stronger exchange on this point. It is
not clear that any new evidence has emerged. If it
does, then as pointed out to James, legal routes to
appeal already exist. 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."
Do you remember when the issue of past prosecutions,
to use Ms Vennells' words, being reopened, do you
remember when that was first drawn to your attention?
At this stage.
What did you make of that?
Interested to know more. I mean, to be honest, at that
stage, I knew very little about prosecutions. I didn't
know much about civil versus criminal, I didn't really
understand that we did our own prosecutions and I didn't
really understand what it was in the Second Sight review
87
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
SIR WYN WILLIAMS: Fine. All right, what time shall we
resume?
MR STEVENS: 12.25, please, sir.
SIR WYN WILLIAMS: Fine.
MR STEVENS: Thank you.
(12.16 pm)
(A short break)
(12.25 pm)
MR STEVENS: Sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR STEVENS: I'm going to go on to a different topic,
Mr McCausland.
Now, I'm going to ask now about both the Clarke
Advice and the review of disclosure to subpostmasters
who had been convicted. I'm later going to ask you
about the oversight of prosecutions and ongoing
prosecutions. At the minute, I'm just limiting to
convictions themselves.
Okay.
Can we please bring up POL00099026, and this is an email
from Paula Vennells to you on 6 July 2013. So we're
back in the chronology, after the Board meeting where
the upcoming Second Sight Report was discussed, which we
went to earlier, but before the report had actually been
received.
86
which would lead to past prosecutions being reopened,
and therefore read it and went "Interesting, keen to
know more".
That can come down. Thank you.
We're going to turn in a moment to the Board meeting
on 16 July 2013 at which you were not present. You
received the Interim Report on 8 July and read it at
some point before that Board meeting.
Yes.
Do you recall having a discussion with either a non-exec
or a member of the Executive about this issue of past
prosecutions, following receipt of that email but before
the 16 July Board meeting?
I don't -- so I don't think that that would have
prompted it. When the -- there was a paper which came
out on 12 July from Susan, which did talk about wrongful
prosecutions and I would have had a conversation with
Alice about the Board meeting. So I will have read the
Board papers cover to cover and I will have had
a conversation with Alice about anything which I wanted
to bring up at the Board meeting.
I honestly cannot remember if wrongful prosecutions
were there but I would guess that they were.
Was this, to that point of your career, a unique moment,
dealing with past prosecutions?
88
(22) Pages 85 - 88
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
o>
>
The Post Office Horizon IT Inquiry
Absolutely, yes.
But you can't assist us at all with what you might have
discussed with Alice Perkins?
I cannot. When I read the minutes of the Board meeting,
and when I spoke to -- well, I remember reading --
sorry. With hindsight, just to be clear, when I read
the minutes of the Board meeting, which I was not at,
I was not surprised by the questions and the discussion
about wrongful prosecutions, and was anybody implicated.
So I would not be at all surprised if I had had --
well, I know I would have had a conversation with Alice
and I would not have been surprised if, in that
conversation, I would have been worried about the
concept of wrongful prosecutions because it absolutely
would have been unique and I'd never been involved in
anything like that before, so I'd have gone "Oofl”
So the concept of who is responsible and is there
responsibility on the Board, absolutely that would have
been a concern for me.
1am going to turn to the minutes in a moment. The
Inquiry has heard evidence about that meeting and that
Susan Crichton was intended to speak to a paper that she
produced -- I think you referred to it already, the
12 July paper -- but was kept out of the meeting, sat on
the other side of the door, by Alice Perkins, and it was
89
have her excluded from the meeting?
I did not.
Can we look, please, at the minutes. It's POL00027514.
We see it's 16 July 2013. You're noted there as
"Apologies for Absence". If we go over the page,
please.
Sorry, if we could go -- oh no, apologies.
Could we go to page 6, please. It says:
"The CEO explained that although the Second Sight
Report had been challenging it had highlighted some
positive things as well as improvement opportunities.”
Then at (b), it says:
"The Board were concerned that the review opened the
Business up to claims of wrongful prosecution. The
Board asked Susan Crichton, as General Counsel, was in
any way implicated ..."
An explanation given is there.
Either before the meeting or shortly after it, were
you given any information about the number of wrongful
prosecutions that the Legal team thought there may or
may not have been?
I'll rephrase the question.
Yeah.
Did anyone explain to you the extent of the risk, in
terms of the numbers that they were fearing there may be
1
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
Paula Vennells who spoke to the paper.
Were you told about that after the meeting by any of
the Non-Executive Directors?
I cannot -- again, I cannot remember but I would guess
that Alice would have briefed me about the breakfast --
the pre-Board meeting that took place with the non-execs
and about the fact that Susan didn't come into the
meeting. So I would guess that Alice did talk to me
about that because we would have had a thorough pre and
post-brief but I honestly cannot remember the content of
that conversation.
So you cannot assist us with the reasons for why, at the
time, Alice Perkins made that decision to keep Susan
Crichton out of the room?
''m afraid that I can't, no.
From your experience of how these meetings were run, do
you consider that to be an unusual decision, to keep
Susan Crichton out of the meeting?
Yes. I do. It absolutely would have been usual and
normal for the people who were on the agenda to turn up.
I cannot remember another instance where -- no, maybe
I can -- but if timing -- if something really overran,
sometimes an agenda item would slip to the next Board
meeting but it would be very rare for that to happen.
Did you speak to Susan Crichton about the decision to
90
wrongful prosecutions for?
Yes. So I can't remember if it was -- in which piece of
paper but, around that time, I was informed by Susan
that, in her view or in the view of the external lawyers
assisting her, it would be maybe 5 per cent of the --
yeah, 5 per cent of cases. So in 5 per cent of the
cases, I think, was the figure that was used. Yeah.
What was your view of that risk; how serious did you
think it was?
Yeah, I mean, so it doesn't matter how many, what
percentage. I mean, if there's one, then that's
serious. So we -- I would have been worried about
wrongful prosecution.
So was this an important issue that the Board needed to
grapple and maintain oversight of?
Yes.
Just so we're clear, because at various points in the
chronology we see subcommittees being made, there was no
subcommittee created to look at the past prosecutions,
was there?
No.
Was this considered to be a matter for the full Board
itself?
Yes. At this stage, there was no Sparrow Subcommittee.
If we look down, just to cover one point before carrying
92
(23) Pages 89 - 92
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
The Post Office Horizon IT Inquiry
‘on with this theme, it says (c):
"The Board expressed strong views that the Business
had not managed the Second Sight review well and
stressed the need for better management and cost control
going forward."
Is that something you had discussed with Alice
Perkins before the meeting?
I'm not sure if I did specifically but I shared that
view: that the Second Sight review had taken too long,
was taking too long, and the way in which the Second
Sight review had been sprung upon the Board, partly with
Paula talking about it in the margins of another
meeting, on the 1st, and then a very short period of
time before it was launched, it just felt like it hadn't
been a well-managed process. It felt like we, Post
Office, were disconnected from what Second Sight were
doing.
That document can come down. Thank you.
The day before this meeting, we now know that the
Clarke Advice had been prepared, the 15 July 2013 Clarke
Advice. You've read that as part of the documents that
were provided to you by the Inquiry, haven't you?
have.
You say at paragraph 110 of your statement, that you:
"... were unaware of the existence and/or contents
93,
When you say "this time", sorry?
Summer of '13.
Summer of '13. So the Interim Report comes out on
8 July, there's the 16 July Board meeting, and you think
at some point in between there you have a conversation
with Alice Perkins. Do you think it's around then or
later?
Yeah, I don't think it will have been with -- the
conversation with Alice Perkins but it was around that
time that I learnt that we could no longer use the
expert witness who we had. I'm not sure that I was
aware that his name was Gareth Jenkins but I was told
that -- and I wasn't specifically told: I mean, it was
in a document that we needed a new expert witness.
Okay. We may come to a document like that in a second
but let me clarify this: you say it was in a document,
did anyone discuss with you the use of expert evidence
orally?
No. Not that I can recall.
That document can come down, thank you.
Following the 16 July 2013 Board meeting and this
discussion of a review of past prosecutions -- I'm using
a very loose term there on purpose -- what were you told
about the nature of that review or look-back at past
prosecutions?
95
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
29 July 2024
of Simon Clarke's Advice of 15 July 2013, prior to
receiving it as part of the disclosure pack provided by
the Inquiry in relation to my Rule 9 Request."
Elsewhere in your statement, paragraph 199, you say:
"I do not believe that I was told that the reason
that we could no longer use Gareth Jenkins was because
he had been discredited.”
Yes. Correct on both counts.
Can we look at your statement, please, at page 68,
paragraph 181. I've taken you here before, it's
referring to the sources of assurance or reassurance for
the Horizon IT system. If we could turn over the page,
please.
If you can take it a bit further down, please.
Thank you. So on the screen, the third bullet point
down, says:
“By Fujitsu and their expert witness who would
regularly give evidence in court under oath about
Horizon's reliability which resulted in convictions ..."
Presumably there you're referring to Gareth Jenkins?
Yes. I did not know Gareth Jenkins’ name for much of
the time but, yes, I was aware that Fujitsu put up
an expert witness who would defend the system.
When did you become aware of that?
I think probably around this time.
94
Sorry, so just to clarify, are you talking about the
Sift Review?
I want to know, from 16 July onwards, when you were told
about a review of past prosecutions, what you were told
that review would entail?
So around the -- I think it was mentioned in the 12 July
letter and then it was mentioned in subsequent letters,
in subsequent minutes that Susan Crichton had
commissioned an external firm, which I think she
specified as Cartwright King, to do a review of past
prosecutions and to ascertain what needed to be
disclosed to those past -- to understand if we needed to
disclose the Second Sight review to those past
prosecutions. At a consequent time, Brian Altman also
then got added into that as an independent review of
Cartwright King.
Can we look, please, at POL00145891, and can we turn to
page 3, please, right at the bottom.
Can we go further down, please. Sorry, if we scroll
up, please. Thank you. That's it. Sorry I disoriented
myself.
It's an email from Alasdair Marnoch to Alwen Lyons
‘on 27 July 2013. We see you're copied in. If you go
down, please, it says:
"For the benefit of other Board members I had a very
96
(24) Pages 93 - 96
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
good review with Susan and Alwen earlier this week
focused mainly on the history and immediate actions we
are taking to dealing with the urgent case review."
Then it says:
"In our discussion with Susan, Alwen explained why
the case review was any going back to 2010 and the
significance of a Horizon upgrade (full reconciliations
across every site etc). Could Alwen please elaborate on
this point as a critical issue will be determining how
far back we need to go."
Do you recall any discussion firstly on the choice
of start date for the review?
I do not, no. It is -- the choice of start date is
referred to in several emails, and I am conscious that
Alasdair -- so Alasdair had been asked by Alice to do
this, and I think that's in a previous minute. So
Alasdair is having a conversation, and Alasdair is
talking to Susan and Alwen about the choice of start
date but I don't remember being involved in any of those
conversations myself. I was aware of it.
Outside of this email did you discuss with either
Alasdair, Susan Crichton or Alwen Lyons any of the
issues raised in that email?
I don't believe that I did. I certainly had
a conversation with Alice regarding these issues but
97
"I think I am up to date, and understand the issues,
so probably no need for a special update."
Why did you feel at this point it was not important
to talk to Susan Crichton about the criminal case
review?
Because I believed that I was up to date. I would have
had a conversation with Alice, and so Susan isn't
saying, "Neil, I've got some really important
information I need to share with you". Susan is saying,
"Please let me know if you would like to discuss this
issue or want an update". So I didn't want update;
I was up to date.
Now, clearly, with hindsight, I would have loved to
go that Gareth Jenkins had been discredited, that we had
the Helen Rose Lepton report, that the Clarke Advice had
come out, which had put a fundamentally different spin
‘on things but that wasn't what she was saying. She was
saying do I want an update and would I like to discuss.
I believed I was up to date and I was very happy to wait
until the next Board meeting or the next time that she
was going to update the board.
Just so we're clear at this point, so your email is on
13 August, we've discussed the sources of your
information as being firstly the 12 July paper from
Susan Crichton.
99
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
oP
p>rore>
29 July 2024
I cannot remember having a conversation with Alasdair,
Alwen or Susan.
When was the conversation with Alice?
It will have been when I was back from France. I cannot
tell you the date. I mean, I'm guessing sometime after
16 July.
Do you recall what was discussed in that conversation
with Alice Perkins?
Really a summary of what happened at the Board meeting
and at the breakfast meeting. Again, I cannot recall
the content of it but it will have been going through
the Board meeting and her take on the various
discussions in it. So it won't have been very different
from the minutes.
If we can go up the page, please. We see there's
an email for Martin Edwards with a different note. If
you carry on going up, please. There's an email from
Alice Perkins there, which we will probably come back to
later on. If we can carry on going up.
Susan Crichton emails you on 7 August 2013 and says:
“Neil -- please let me know if you would like to
discuss this issue or want an update and I will put some
time in the diary when you are next in the building.”
Your reply is:
"Thanks very much Susan.
98
Yes.
One or two conversations with Alice Perkins?
Yes.
The email below from Alasdair Marnoch?
Yes.
There's a paper which was in your pack and Martin
Edwards refers to that paper?
Yes.
Were there any other sources of information you had at
that point on the status of the review?
Not that I can recall.
That can come down but can we go, please, to
POL00030900. This is a meeting of the Audit, Risk and
Compliance Subcommittee to be held on 11 February 2014.
We see these are the papers for that, it says, "Agenda"
in the top left. If we turn to the second page, please,
we see it's a Prosecution Policy paper, and we don't
need to go there but, take it from me, it was signed off
by Chris Aujard.
Could you turn to page 4, please. Paragraph 4.5
says:
"It should be noted that, although [Post Office] is
still able to bring cases where the evidence concerned
is extracted from the Horizon system, there is a such
risk that in such cases a defence will be mounted to the
100
(25) Pages 97 - 100
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
effect that the Horizon system cannot be relied upon.
We have been advised that in these cases there is
a strong likelihood that such a defence will be
successful, at least until such time as a new
independent expert is identified and has familiarised
himself with the system. This is likely to take around
12 weeks, and cost up to £200,000."
Was that the document you were referring to earlier
when you said that you learnt that the expert couldn't
be used in future or did you learn at an earlier point?
I think I learned at an earlier -- I can't quite
remember but I think that I knew it already by that
stage.
Admittedly it's in the context of whether prosecutions
are pursued full stop but it's saying, at the moment, we
need to find a new independent expert and that may cost
up to £200,000.
Did you ask, in February 2014 or before, why you
couldn't use the expert who had provided evidence in
past prosecutions?
So at that time I did not ask but my memory is that I'd
been told previously that the old Fujitsu expert had
moved on and, therefore couldn't be used.
Sorry, this is important, please. Who told you that?
I cannot remember. I'm guessing -- I cannot remember.
104
Could it have been around then?
Yes, absolutely. Yes. That was the precursor for this
conversation, so the first meeting of the ARC in
November deliberately didn't make a decision. We needed
more information, which came to this meeting of the ARC.
So I would have been very surprised if I didn't know
about it in the November '13 ARC meeting because it
would have been very relevant to that. But I have
a feeling I didn't learn about it in the ARC; I have
a feeling I learnt about it in some different way.
So you don't think it alerted in the ARC -- Audit, Risk
and Compliance meeting -- you think it was probably at
or before November 2013. What other way do you think
you may have been told of that information?
Either through Susan or Paula or Lesley, probably at
a Board meeting. That's probably the -- yeah, that's
the most likely way.
You say -- we don't need to bring it up -- at page 71,
paragraph 186 of your statement:
"It has subsequently become clear that I was not
provided with or made aware of Simon Clarke's
appointment or the reports he provided. That is wholly
unacceptable. However, I do not regard this as a lack
of oversight on my part. I cannot have oversight of
matters of which I have no knowledge."
103
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
But my mind has it that somebody told me that the old
Fujitsu expert had moved on but told me in such a way
that I didn't particularly think "Oh, my God, he's been
discredited". I thought he's retired, resigned, gone to
work somewhere else, we needed to find someone new.
So your evidence is it was more of a practical matter:
the old expert has gone, we need to find someone else?
Yes. There was certainly absolutely no hint that the
expert had been discredited. So that was 100 per cent
not known by me or the NEDs.
It's quite a significant point. Can you assist even
with when it's likely that that was said? Was this
February 2014 or the summer 2013, or in between,
I should say?
I'm pretty sure that I didn't know it when the Second
Sight Interim Report came out in the summer of '13 and
I'm pretty sure that I did know it when this paper was
reviewed by the ARC. As to when it was between summer
and February '14, I -- it's somewhere in that period but
I honestly cannot tell you when it was. Very happy
to-
As we'll turn to -- we'll come to this later on in your
evidence -- there was a discussion on the future
prosecutorial role of Post Office in November 2013.
Yes.
102
Can you assist us with what you would have done if
you read the report when you were Senior Independent
Director?
So, if I go back to the Interim Second Sight Report,
I was, as I've said before, pleased that we seemed to be
finding some reasons for the unexplained losses, and
that gave us something to do, frankly. So, yeah, we'd
gone into the Working Party, the Mediation Scheme, the
Business Support Programme. We then reviewed past
prosecutions but we reviewed them in the context of is
there something in the Second Sight Report which should
be disclosed to those past prosecutions?
Had, at that time, I been told Gareth Jenkins is
discredited as a witness and has been giving false
evidence, the Helen Rose Report and the Simon Clarke
really very clear report, basically saying serious risk
of wrongful prosecutions, then I think we would have
approached the subsequent period very differently. So
we went into that subsequent period thinking that there
was a -- that we needed to disclose information to
a small number of past prosecutions, and we were
disclosing the Second Sight evidence.
That was my understanding. That was what we were
told. So the reason for reviewing the past prosecutions
was the Second Sight Report.
104
(26) Pages 101 - 104
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
The real reason, as I understand it now, is that we
had been prosecuting -- we had been using a tainted
witness and we had had serious risk of wrongful
prosecutions and, therefore, the Simon Clarke Advice,
coupled with the Gareth Jenkins information, clearly
they're linked, I think would have absolutely made us
take a very different tack.
Q._ In terms of what actually happened, what recollection do
you have of how the Board oversaw the review and
conducted oversight of it from August onwards?
A. So we were clearly concerned, as the minutes from the
July board meeting show, we were concerned about
wrongful prosecution and we were concerned about that in
a number of different ways. We were concerned --
clearly, the very fact that we're doing wrongful
prosecution and the impact on those individuals; we were
concerned from the company’s point of view because that
exposed us to financial risk, reputational risk, legal
risk; we were concerned from an individual point of view
who was doing that. So we were concerned about a lot of
different aspects and, therefore, we wanted more than
just Susan, because Susan might be implicated, and
therefore we wanted a legal firm to do that.
And we also then wanted somebody else, which was
where Brian Altman came in, to review the fact that we
105
A. So with hindsight, I wish we had. At the time, if
I have the General Counsel of the company saying
something to me, backed up by an external law firm,
backed up by a KG, frankly, I'm not expecting the
General Counsel to be lying or misleading me.
MR STEVENS: Sir, I'm going to go to a different topic, so
it's probably a good time to stop there for lunch.
I don't have much more to go and there's a few questions
from Core Participants but I don't think it would merit
working through lunch at this stage.
SIR WYN WILLIAMS: That's fine, Mr Stevens.
Mr McCausland, I want you now just to answer this
question from your general experience as a Non-Executive
Director and, therefore, what you would expect to happen
as a Non-Executive Director of a company like the Post
Office. Can you think of any good reason why the
substance of Mr Clarke's Advice, even if not the actual
Advice itself, would not have been discussed at Board
level?
A. I cannot think of any good reason, sir. I think, under
any circumstance of any Board that I have served on,
I would have expected that information to have come to
the Board and to be, you know, rigorously and in a very
untainted way, laid out in front of the Board.
If am honest, sir, I think the bit about Susan
107
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
were reviewing it. So, effectively, we were trying to
get two layers of assurance.
Q. Were you aware —
General Counsel, Cartwright King —~
Q. Were you aware that Cartwright King had been involved in
conducting prosecutions for Post Office at the time when
they were instructed?
A. No, I wasn't. It -- I was not aware of that. That
linked hadn't been made. I don't know if I had ever
previously seen a piece of paper that said Cartwright
King were doing criminal prosecutions but I certainly
didn't put those two things together.
Q. In your statement, you refer to the Advices of Brian
Altman KC. Were you provided with any of those notes of
advice?
A. Sadly not. Again, with hindsight, I understand that
Brian Altman also referred to other things that weren't
brought to our attention. We were basically given
a very anodyne, positive report to say that Brian Altman
said that our approach was sound, which again, with
hindsight, is not correct.
Q. Without hindsight now, that's what I want to look at, do
you think the Board, when presented with such a serious
issue, should have requested to see the notes of advice
of Brian Altman, of which it was aware?
106
>
being left outside on a chair is a bit of a red herring.
It's clumsy, it shouldn't have happened but it is
Susan's job, as General Counsel, to inform the Board of
hugely relevant pieces of information, which, as I've
said, I fundamentally believe would have changed the way
that we operate, and for those pieces of information not
to have been disclosed -- and it's not a case of doing
it on a phone call. I mean, it's a very important piece
of paper which should either have been in her Board
report or sent around as a note or sent around on
a phone call. We arranged Board meetings and Board
information very regularly and, for those pieces of
information not to have been shared, I think it's wrong.
‘And subsequently, I don't think those pieces of
paper, that information was shared at all. So I don't
think it went to the CCRC. I think it was airbrushed
from history very consistently, which I have absolutely
no reason why that would be the case which is
acceptable.
SIR WYN WILLIAMS: All right. Thank you.
2.05 okay, Mr Stevens?
MR STEVENS: Yes, sir. Thank you.
SIR WYN WILLIAMS: Fine.
(1.04 pm)
(The Short Adjournment)
108
(27) Pages 105 - 108
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
(2.05 pm)
MR STEVENS: Good afternoon, sir. Can you see and hear us.
SIR WYN WILLIAMS: Yes, thank you very much.
MR STEVENS: I will continue.
Mr McCausland, I've got a few more, more discrete
smaller topics to cover this afternoon morning, and I
want to start with the resignation of Susan Crichton.
We don't need to turn it up but in your witness
statement at paragraph 146, you say you aren't aware of
the reasons as to why Susan Crichton resigned, correct?
Correct.
The Inquiry sent you or gave you this morning two
documents, so you didn't have those at the time you made
your witness statement. I want to look at them now and
explore them with you. Please could we bring up
POL00381628. It's an email from Paula Vennells on
2 September 2013 to you. That says:
"Neil, I have tried to help our discussion tomorrow
(today!) by providing a background brief. This is
a private note; and views in it may change as more
information comes to light. I'd be grateful if you
would treat it as such.
"Thank you for being available at such short
notice."
My reading of that is there's a note being sent to
109
chain of emails which follows.
Let's have look at the note that was attached, please.
It's POLO0381629. You see it says, "File notes SC/PV
[Susan Crichton/Paula Vennells], Friday 30/9". That's
been established should be 30 August, rather than
30 September.
I'm not going to read all through this but could we
please turn to page 3, first. It says.
“Neil, this the end of the brief for our discussion.
There are more notes below as context if you have time.
But not imperative."
So that's just to coordinate where we are in the
notes. So if you go back up, please, thank you.
Go back up to page 1, thank you. Further down,
please. So there's a note here of the conversation. In
the paragraph that says, "She again raised that Alice
had made mistakes’, it goes on to say:
“And I said that whilst I would be asking Alice
about a couple of challenges Susan raised (Alice
believing Donald and BIS [Department for Business,
Innovation and Skills] comments about a PO cover-up?)
Do you remember discussing that aspect of the note
with Paula Vennells?
I saw that this morning and was -- yeah, was interested
111
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
you for discussion in the future; is that your
understanding?
That is.
The subject says, "Our meeting -- P&C’
that means?
Jo you know what
Private and confidential, I guess.
I'll come to the note in a moment but do you recall
receiving this and the discussion which we're about to
turn to?
I didn't have any recollection of it before you showed
it to me this morning. Now that you have showed it to
me, I do have a vague recollection of it, yes.
That document can come down for the time being. Before
we turn to the note, can you recall what Paula Vennells
told you was the reason she wanted to speak, before that
email was sent?
I -- my memory, which is not perfect at this stage, but
my memory is that she was coming to me in my position as
SID because the Chair, Alice, and the General Counsel,
Susan, were having an issue and Paula probably felt
caught in the middle and Paula came to me, which is
appropriate in the case where there is some issue with
the Chair, and wanted my advice, wanted my guidance, my
opinion, my counsel. So I think Paula is trying to draw
me into the issue regarding Susan and Alice and the
110
in it but I do not have any recollection of that at the
time.
If we go back to page 3, please, we've got the
“Reflections” section. Now, just up slightly again,
please. Thank you. It says, as we've said here before:
"Neil ... There are more notes below as context if
you have time. But not imperative."
Would you have read the remainder of the document?
Yes.
Third paragraph down, it says:
"Susan had said to me prior to my leave, that she
would never have put a business she worked for in the
situation we found ourselves with the [Second Sight]
Interim Report, and she wished she had never allowed
Alice to persuade her to do the independent review."
Do you recall discussing that aspect with Paula
Vennells?
Well, this is fresh in my mind from this morning and my
mind hasn't had a long time to think about it, so
I really cannot remember the conversation I had with
Paula, you know, more than 10 years ago. I'm sorry,
I can't flesh that out. I'm sure I would have read the
note; I'm sure I spoke to her about everything in the
note but I cannot remember the details of that
conversation, I'm afraid.
112
(28) Pages 109 - 112
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
POoOPrOoP
The Post Office Horizon IT Inquiry
So if I asked you any more questions on this, you
wouldn't be able to assist us with what was said at the
conversation?
I can -- I won't -- I will not be able to remember the
actual conversation. I'm happy to reflect on what
I think I would have said but, as to what I actually did
say, I would struggle.
Do you have any recollection at all about how the
conversation went? If it's not precisely words that
were used but the overall tenor of the conversation?
Yes. So -- or do I? I'm not sure if it's an actual
recollection or what it's what I am imagining what was
said. But I think that I -- my reaction to Paula would
have been that Susan is being overemotional about it.
She should have resigned over the Second Sight Review
nonsense. You know, we were right to do the Second
Sight Review, there was nothing wrong with doing the
Second Sight Interim Report, that's no reason at alll to
resign. That's daft. And, being left in the corridor
outside the board meeting, yes, it's clumsy, but it's
not a resigning matter.
I mean, Post Office was in a real mess. We were
doing all sorts of things. There were lots of other
members of the Executive who would come in to the Board
meeting and frankly get a hard time. So Kevin would
113
Yes.
Just for context, the Lessons Learned Review is the
review the Board asked to be carried out into how the
Second Sight Review had been handled within the
business?
Yes.
As we see, we have an email there from Simon Richardson
and, if we turn, please, to page 2 at the bottom. We've
got one from Andrew Parsons, also of Bond Dickinson.
Would you have read these emails?
Yes.
Do you recall speaking about them with Paula Vennells?
Vaguely.
What is your vague recollection?
So Alice had asked for a Lessons Learned Review after
the Board meeting on the 16th, where the whole Board
were dissatisfied with the progress. Initially, that
was due to be done by Alasdair as Chairman of ARC. That
had then migrated, which I'm not sure I was aware of,
but it migrated to Richard Hatfield, and this email here
is basically then Susan arguing -- Susan getting
a lawyer's opinion to ask why we shouldn't be doing it.
So, at the time, I think I was frustrated and
I was -- I remember being frustrated by the whole of the
Lessons Learned Review because, actually, I wanted to do
115
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
come in and be, you know, talked about, about the
network. Martin, Nick -- it was a robust environment.
So for somebody to be upset about being left in
a corridor: get over it. It's not a resigning issue.
So I think I would have been relatively robust with
Paula that this Susan's job. Just, you know, tell her
to get on with her job and not be so sensitive. That's
probably what I would have said. That's my vague
recollection but I honestly cannot remember the
specifics of that conversation.
Can we look at an email sent around that time. It's
POL00146244. So the email I took you to earlier was on
2 September 2013 in the evening. This is an email from
Paula Vennells to you on 3 September in the morning.
"Neil, sorry to bombard you with emails but this is
useful; ideally you should read this after my briefing
note.
"I think indicates a way through."
This is also dealing with what you were discussing
at that conversation. If we look down, please, it's
Hugh Flemington, he sort of sets it out and says:
"[Please] see comments below from both Simon
Richardson and Andrew Parsons regarding risks of LL
review
That's the Lessons Learned Review, isn't it?
114
a Lessons Learned Review. I don't think the business
had handled it well and, therefore, you should
understand it and learn from it. And we were being
steered away from this Lessons Learned Review by lawyers
telling us it was a bad thing and we would put ourselves
at risk and, therefore, I think that I would have
accepted it because it was quite strong legal advice
saying, from a business point of view, we should not do
that but, at the time, I do remember being very
frustrated by the Lessons Learned Review.
With hindsight, I see it very differently and it
feels like Susan is -- one of the reasons that she's so
against it is because she's frightened that the Lessons
Learned Review is going to turn up some of the things
that, frankly, should have come to the Board and didn't.
Pausing there, we've seen a document by Belinda Crowe
setting out Lessons Learned and how to deal with things
like Second Sight Review going forward.
Yes.
In your evidence then you accepted it. Were you
referring to the legal advice here in these emails, that
you accepted this legal advice?
Yes.
So we know that there was a Lessons Learned Review that
was actually commissioned and finished by Belinda Crowe.
116
(29) Pages 113 - 116
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
Did this legal advice here change the scope of that
review?
Very much so, yes. So the original scope was going to
be done by Alasdair, understanding, talking to Susan,
then it went to Richard Hatfield and then I think
Susan -- we all hoped it would become a big review but
clearly Susan didn't hope that. And then, after this
legal advice, the scope changed and got downsized very
significantly into a fairly dull piece of work that then
did come out from Belinda as the Lessons Learned Review.
If we turn to page 3, please, one of the points made by
Mr Parsons refers to disclosure of the review. We see
something the Inquiry sees a lot, a point on privilege:
"This Review will not be legally privileged."
But then it says under "Criminal disclosure":
"Should the review reveal any concerns about Horizon
or branch accounting processes, then Post Office may be
obliged (under Criminal Procedure Rules) to proactively
pass this information to subpostmasters involved in
criminal prosecutions (both ongoing and historic). In
particular, recommendations for change could be
interpreted as highlighting historic problems that would
need to be disclosed.”
Are you saying you accepted that legal advice?
So there is quite a lot of argument here. I think there
117
the Lessons Learned Review?
No, I didn't and, frankly, even when Susan Crichton
resigned, I didn't suspect that she had bad motives in
doing that. As this Inquiry has peeled away the layers,
frankly, I have become appalled. At the time, I had no
feeling of that at all.
I want to move now to another topic, it's oversight of
prosecutions and future prosecution policy. In your
statement, we don't need to turn it up, but it's
paragraph 55, you say that, during the recruitment
process, you had no knowledge whatsoever with regards to
the investigation and prosecution of subpostmasters for
theft, fraud, or false accounting. That was September
2011. We saw the Board minute on September 2012, which
referred to prosecutions. So you were aware, in broad
terms, of the prosecutorial function by then?
Not really. So I was aware that prosecutions were
happening. I wasn't aware that we were bringing the
prosecutions.
If we just bring that note back up of the -- actually,
no, we don't need to.
So your evidence is January, you were aware that
prosecutions were happening?
Yeah.
But just explain what you mean by "not that we were
119
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
are two documents there, aren't there? There are two
different people?
Yes.
There's an email basically saying why we shouldn't do it
and then there's a report saying why we shouldn't do it.
So I don't think that would have gone into any of the
individual lines in that much detail but I would have
read it and thought we were being told very clearly by
two different external lawyers that it is a bad idea for
the business to do this and, therefore, I am not
a lawyer, I have no legal experience and to go against
my General Counsel, backed up by two external lawyers --
I mean, I wouldn't; I would take their advice.
Is it fair to summarise it this way: you and Alice
Perkins wanted more of a larger review than, in fact,
happened?
Yes.
Susan Crichton obtained this legal advice from Bond
Dickinson, you felt you needed to accept the advice from
the lawyers and that resulted in the Lessons Learned
Review being narrowed in scope?
Yes.
Thank you, that document can come down.
At the time, did you have any concerns as to Susan
Crichton's motives for seeking to narrow the scope of
118
bringing them"?
So when the November '13 report came out for the ARC,
explaining the prosecutorial functions, which you took
me to earlier this morning, that explained that Brian
Altman had done a review and that he explained that
Royal Mail Group and POL were virtually the only people
to bring their own prosecutions. And when -- if you go
back to '11/'12, I was aware that prosecutions were
happening but I assumed that they were happening through
the CPS or the police.
So the concept of a company itself bringing
a prosecution, I just had never heard of that, I didn't
know about it, I hadn't thought about it. So when I was
reading about these prosecutions have happened, in any
other world that I'd lived in, there would be
an internal investigation team, who would understand the
issue but then present evidence to the CPS, and they
would bring the prosecution. So that's how originally
assumed it had happened.
Would you agree that, if a company pursues prosecutions
as Post Office did, that is an unusual type of operation
for it to be involved with?
Absolutely.
Would you agree that -- and I'm not here pointing to
what you were or weren't aware of but, in terms of what
120
(30) Pages 117 - 120
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
the board should be doing, would you accept that the
Board should have oversight of how those prosecutions
are conducted?
A. Yes.
Q. Do you think you should have --
Sir, it sounds like we have a fire alarm.
Yes, so we have a fire alarm. We may have to break
for a moment.
SIR WYN WILLIAMS: Yes, by all means. I will remain nearby,
so to speak, and you can let me know when we're ready to
resume.
MR STEVENS: Yes, we will remain nearby, sir, but we'll come
back as soon as we can. Thank you.
(2.25 pm)
(A short break)
(2.50 pm)
MR STEVENS: Good afternoon, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes, I can, thank you.
MR STEVENS: Fortunately it wasn't a serious fire alarm so
we're back and I'll continue.
Mr McCausland, just before the fire alarm, I asked
you if the conduct of criminal prosecutions was
an unusual type of operation for a company, and you
agreed.
I then said, without exploring your actual knowledge
121
responsibility of informing the Board of the operation,
namely prosecutions, and then the Board would come to
its own view of what was appropriate oversight of the
executive in those circumstances?
A. Yes.
Q. I was going to ask you a series of questions about why
the Board did not oversee prosecutions until the Interim
Report, whilst you were there but your answer to that
would be you personally weren't aware of the
prosecutions; is that fair?
A. I certainly wasn't aware that we did our own
prosecutions. As I say, it was just -- I'd never
thought of that happening.
Q. Were you aware that Post Office -- and again, this is in
January 2012 -- had its own Investigation Department?
A. Nobody had explicitly said that but I had assumed that
was the case and by implicit, yes. So certainly other
companies I had worked with would have had their own
Investigation Team and I had assumed that there was
an Investigation Team in Post Office. I'm not sure that
I ever knew who it was or where it was but, yes, I would
have assumed it was there.
Q. Do you recall whether the Board conducted oversight of
the conduct of the Post Office Investigation Team
between you joining as a Senior Independent Director and
123
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
29 July 2024
of Post Office's role in prosecuting, would you accept
that the Board should have oversight of how those
investigations were conducted? Your answer was yes.
Yes.
Just before that, you, in your evidence, said you
weren't aware of Post Office's role as a prosecutor in
January 2012, that came later. At Post Office, whose
responsibility was it for informing Directors like you
of its role as a prosecutor?
I think the prime responsibility was probably with Susan
Crichton as GC who ran that area or, before her, I think
Mike Young ran the area, and probably Paula as a second.
What about the Chair? Does the Chair have any
responsibility for the induction of Non-Executive
Directors?
Yes, if the Chair knew.
In terms of the systems of oversight -- what I mean by
that is what systems should be in place for overseeing,
in this case, prosecutions -- who at the Board was
responsible for seeing that a system of oversight for
prosecution was in place?
The -- from an Executive point of view, Paula had the
prime responsibility for that, in that she ran the
company.
Would it be a case of Paula Vennells had the
122
the Interim Report?
I cannot remember that we did, no.
Why do you think that was?
I think probably just because of the weight of other
things which were going on and it just - past
prosecutions were not that big a feature for us.
Pausing there, I'm talking about ongoing prosecutions at
this point, so not things that have happened in the
past: prosecutions that Post Office are currently
pursuing or will pursue in future.
So prosecutions, not just past. Prosecutions, were not
as big a focus for us as they should have been or as,
with hindsight, I would have liked them to be. Our
focus was very much on trying to understand the
integrity of Horizon, that was the thing that I was
hearing from -- Lord Arbuthnot was talking to us about
that and that's what the Second Sight Review was about,
it was really trying to understand the integrity of
Horizon.
The conduct of prosecutions, past or present, was
not as big a feature and I don't think that we were
aware that there was as big a problem as clearly there
was. So I think it was a lack of awareness, coupled by
the weight of other things which were on our plate:
separation, costs, people, culture, revenue. It was
124
(31) Pages 121 - 124
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
a very, very busy Board and Horizon absolutely bubbled
up as -- the integrity of Horizon bubbled up as
something that the Board needed to spend time on. The
prosecution function didn't bubble up in the same way.
Last question I have on this and it may be this is
a very similar answer but the Inquiry has heard
evidence, as part of separation, at least one lawyer --
lawyers from Royal Mail Group transferred into Post
Office Limited, including a criminal lawyer called
Jarnail Singh, and so there was effectively a transfer
of part of the Criminal Law Team into Post Office
Limited as part of separation.
When you were dealing with separation and separation
issues, were you at all involved with looking at,
overseeing, new parts of the business that had come into
the Post Office, such as the Criminal Law Team?
No, I did have some involvement in the separation issues
but they tended to be where there was conflict between
Post Office and Royal Mail Group, and there were many
such issues, but the normal transfer of people across
I did not have sight of.
I want to look now briefly at the future prosecutions
policy following the Interim Report. Can we look,
please, at POLO00038678. So we see it's a minute of the
Audit, Risk and Compliance Subcommittee held on
125
make a decision at this meeting and it was very much
a questioning session. So particularly the three
members of the ARC, Alasdair, the Chair, Tim and myself,
were trying to understand how we did it, and so there
were lots of questions. Certainly one of those
questions was about recovery, and one was about -- the
two main areas were recovery and deterrence: how does it
work; what are the sums of money? And there weren't as
many answers as we wanted which is why we asked for
a far more detailed piece of work which subsequently
came to the February ARC.
You mentioned deterrence and, as we see in the last
line, it says:
"The Committee supported this but was nervous about
changing the approach to prosecutions as in their view
this acted as a deterrent."
Why was it thought necessary to have a deterrent in
the form of Post Office pursuing its own prosecutions?
It wasn't. So it was felt necessary to have a deterrent
but not necessarily for Post Office to bring its own,
ie perfectly happy for the CPS to bring prosecution or
for the Post Office to bring the prosecution, but to
have no prosecutions, that was what was making the ARC
nervous.
Do you have any recollection -- I should say at (d) it
127
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
19 November. You're present, second on the line there
and, further down, we see both Paula Vennells and Chris
Aujard in attendance as well. If we turn, please, to
page 3., and the bottom of that page.
Chris Aujard updated the Committee on the approach
to prosecutions bought by the Post Office and, as we go
‘on to see, it introduces a paper on the prosecutorial
role going forward. Was that the first time in your
career that you'd been involved in decisions as to
a future policy of prosecutions?
Yes.
Can we turn the page, please, to page 4, paragraph (c):
"Chris Aujard explained that one of the issues was
the perception that subpostmasters had of the Post
Office bringing prosecutions of false accounting rather
than theft, which was easier to establish. The
Committee asked whether the business would still be able
to recover branch losses through the Civil Courts.
Chris Aujard explained that this would still be open to
the Business but it would be slower and not recover as
much."
Pausing there, to what extent, at this stage, were
the Committee seeing that prosecutions was a method of
obtaining or recovering money from subpostmasters?
This -- so at this meeting, we were not being asked to
126
says:
"The CEO thanked the Committee for the helpful
challenge. She stressed that the Business was not
saying that it would never bring prosecutions, but that
it would be more circumspect in the cases it chose to
take."
You've mentioned before that minutes are obviously
not the full record. Do you have any other recollection
of what Paula Vennells said in respect of Post Office's
prosecutorial role at this meeting?
I don't, at this meeting. She subsequently sent around
some emails between this meeting and the next meeting
with some of her views. I guess that her views were the
same but I cannot remember her views at this meeting.
I'm not going to take you to the emails, they're
a matter of record. I do want to come to one matter
which was a potential conflict of evidence. Can we
look, please, at POLO0030900. I think we've been to
this document and we'll see at page 2 it's the report by
Chris Aujard. Could we turn, please, to page 3 and, if
we could just go down to "Options Considered”, please.
So the options put forward are (a):
"Preserving the status quo -- ie retaining
prosecutorial capability and continuing with
a prosecutions policy ...
128
(32) Pages 125 - 128
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
The Post Office Horizon IT Inquiry
"(b) Pursuing a prosecutions policy more focusing on
more egregious misconduct ..."
"(c) Ceasing all prosecutorial activities ..."
In your witness statement, at paragraph 157, which
is page 59 -- we don't need to bring that up -- you say:
"My recollection is that myself, Alice Perkins and
Susannah Storey were largely in support of Option 3,
whereas the Executive largely favour option 2."
That still accords with your recollection?
Itis.
Why did you favour Option 3?
So, in this meeting, I was trying to understand two
things: first of all, the recovery; and, secondly, the
deterrent. And if we look at the recovery -- so there
was a chain of emails before this where I was
questioning Chris on the amounts and, if I could ask you
just to scroll up a little bit to 3, just there is fine.
This document I then emailed Chris to say, "Help me
understand these figures a bit more", and it became
apparent from this that, in criminal prosecutions --
forgive me if I get those numbers slightly wrong -- in
criminal prosecutions we had losses of 1.6 million and
we recovered 740, however, it had cost us 500,000 to do
so, because we employed a small army of lawyers, and
each recovery cost about £7,500. So net, net, net, we
129
view -- understand that the two things are separate.
However, there was strong arguments put by Paula
that said we're in transition here, we've got the
Business Support Programme happening, we've got
Mediation Scheme happening, the CPS is overloaded and
our advice is that the CPS actually may not be able to
do anything, and therefore we should, whilst moving
towards Option (c), let's do it gradually, let's take
a step towards Option (b) and then maybe we'll review it
and go to Option (c).
And because all prosecutions were paused -- because
we had paused all prosecutions -- I thought that was
okay. So my instinct, and I think the NEDs' instinct
was Option (c) is better, because, you know, why do we
need to have an army of criminal lawyers ourselves do
the investigation and then hand it over to the CPS as
long as CPS would prosecute some, the worst but, as
a stepping stone, happy with Option (b) because,
frankly, it wasn't going to make much difference because
we weren't doing any prosecutions anyway.
That document can come down. Thank you.
Alice Perkins said in her evidence that she recalled
you being in favour of option 2. I assume, I take it,
that your position on that is that she's mistaken?
I ended up supporting the Option 2. So she may -- I'm
131
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
prparpe>ro
29 July 2024
were recovering 200,000 from 1.6; whereas civil, we were
1.9 and it was costing us about 100,000.
So, from a recovery point of view, we were actually
much better using civil, rather than criminal, which
wasn't clear and that wasn't evident from either of the
papers, which was why I was trying to unpack that and
understand it, and I was wise encouraging Chris to
actually unpack civil, because all of his paper and all
of the ARC policy was about criminal and civil was dealt
with very separately. So I'm saying should we not be
looking at civil as well because, actually, from
a recovery point of view, civil seems to be working much
better than criminal.
Separately, we were looking at a deterrent, and
I think that everybody in the ARC felt that there should
be some deterrent, ie there should -- we shouldn't just
stop all prosecutions. But I don't remember any of the
NEDs saying that we should be doing it ourselves. All
of the NEDs, from memory -- this is a long time ago, but
all of the NEDs, from memory, thought it was weird that
POL was bringing its own prosecutions and, therefore, we
were coming to this from an instinctive point of view to
say, yes, we should continue to do prosecutions, ideally
those are probably done by the CPS, and civil is
actually better than criminal from a recovery point of
130
not sure when in the debate she was talking about. So
my instinct -- and I think I started off going Option
(c) is better, but I was okay with Paula's arguments and
therefore I did support Option 2 as an interim step.
I mean, and the paperwork is quite clear that it's a,
you know, pro tem interim step.
As part of this conversation, this debate, did Chris
Aujard say anything about the future costs of bringing
prosecutions, namely the cost of a new expert?
So in the previous ARC, I think there was that reference
that you took me to earlier that said that, if we were
todoa--
This is in this paper. The paper is the February --
I don't recall that coming up in the February paper but,
certainly from the November paper and therefore in my
mind, will have been that we need to have a new
independent expert and there will be a cost to get that
person up to date.
Sorry, we can bring it back up so you can see it.
Is that in that paper as well?
Itis.
Okay, sorry.
Itis. Well, if you're happy to take it from me --
Yes, sure, yeah.
-- it's mentioning £200,000 as a likely cost.
132
(33) Pages 129 - 132
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
Apologies. I thought that was the November paper.
No need to apologise. But just with that clarified in
your mind, in February 2014, do you recall discussing
that issue on the cost of an expert witness with Chris
Aujard?
No. I don't believe that was a factor in the
conversation at all.
I want to look very briefly at the Mediation Scheme,
please. Can we turn to POL00145891.
So we went to this email earlier. It's between
Susan Crichton and you, you emailed each other in
August. But if we can go down please to Alice Perkins’
email on 31 July, one of the points she makes is:
"First, while it is clear that we are committed
using [Second Sight] for the 47 cases which are already
in the frame for their review, it is extremely important
that we cap their involvement at that. The moment they
are involved in additional cases beyond these, we will
have lost the ability to end the relationship with
them -- an outcome which I do not want to have to
contemplate."
Did you discuss that issue with Alice Perkins in
July or August 2013?
I cannot remember specifically discussing that aspect
with her.
133
that. There were differences of opinion.
So with Alice Perkins who is taking a stronger view to
you on the use of Second Sight going forward, do you
recall any other Board members who shared her view?
I don't. She was working more closely with Second Sight
than any of the others at that stage. So when the
Sparrow Subcommittee came into existence, Richard and
Alasdair shared that work with her, and I think actually
they probably came over more to her point of view, but
I don't remember any of the others sharing her view.
Do you have any concern as to Alice Perkins losing her
independence in respect of Second Sight by being
involved more in the -- being more involved with them?
I didn't. Alice was -- yeah, she had bags of integrity.
So I never doubted her integrity or her honesty or her
straightforwardness or her desire to do the right thing.
Can we look, please, at POL00101325, and if we could
look to the bottom of that page, please, we see an email
from Mark Davies to a number of people on the Board.
You're in the distribution list, I think it's third line
down. It's S September 2014 and it refers to a BBC
North reporter who has clearly seen a copy of the
reports being the Part Two report.
If we go to the next email up, another email from
Mark Davies on 9 September, and it says:
135
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
29 July 2024
Well, were the Board or the NEDs at this point looking
for ways, as a strategy, to have Second Sight removed or
their involvement limited in the cases going forward?
I think the NEDs had -- and the Board, had different
views on the involvement of Second Sight. Personally,
I didn't believe that we could get rid of Second Sight.
Actually, I didn't want to, either. I think there was
a shared concern about the resource of Second Sight. So
Second Sight at this stage were going to -- work with
the Working Party to do a detailed case review for each
of the cases going into mediation, we didn't know how
many there were going to be and, at the same time, they
were going to continue their own report on the thematics
that they'd started from the interim.
So for two people, that was an unbelievable amount
of work. They'd already taken a year, which was a lot
longer than had been expected and, therefore, trying to
limit the amount of work that Second Sight did
absolutely was probably a shared objective.
I think Alice probably felt more strongly that she
would like the ability to end the relationship, as she
says. I don't think that was a shared Board view and,
in fact, if you come to some of the later conversations
in the summer of next year, again, it was -- it's clear
that it wasn't. The Board did not have one view on
134
a report on the leak has been broadcast within
the last few minutes within BBC Radio 4."
Then your reply is shortly afterwards on the same
day.
"As you run through this through, I wonder if you
could also see if there is any way that we could use
this leak (seriously damaging our reputation etc) to
stop/alter the process that we are involved in."
Pausing there, why was the leak seriously damaging
to the Post Office reputation?
Because it was incorrect.
So are you saying the content of the Second Sight Report
was incorrect --
No, sorry, so the leak. So what was reported was
absolutely incorrect.
Right. So it's the -- you're referring there to what's
reported on Radio 4 --
Yeah.
~ rather than to the report itself?
Yeah, this isn't about the report; this is about the
leak. So the leak was reported on the radio on Radio 4,
and the report is inaccurate. It was just wrong. We
took it up with the journalist but it was damaging. So
the fact that we had an incorrect leak, I was, yeah via
annoyed by it. I didn't like that.
136
(34) Pages 133 - 136
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
At that point, can you recall what you thought was
incorrect about the report?
I cannot recall. I'm sure it's in the documents and it
says it just at the bottom of the screen there.
Why did you want to stop/alter the process at that
point?
I think if you read the whole of it, it says it would be
great to find a faster, better way out of Sparrow. So
where are we now? September '14. At this stage, my
thinking had moved on and, if you go back a few months
to June, I think it was, the Sparrow Subcommittee had
come to the Board with a recommendation that, actually,
we bring the Mediation Scheme in-house and the Board --
and let's face it, there are only three of us, me,
Virginia and Tim, who are not on the subcommittee --
have rejected that and said no, actually, we should
continue with it.
So we did continue with it but, by the time we get
to the autumn, the Mediation Scheme was still incredibly
slow, we'd had very, very few cases go through to
mediation, very few cases mediated and very, very, very
few cases successfully mediated.
So clearly it wasn't working and I think everyone
was saying that. It wasn't just us. So Sir Alan Bates
was saying that, the MPs were saying that, JFSA was
137
Deloitte to do Part 2 of the work or is that still on
the backburner?
There wasn't any discussion about that. There was --
the discussion here was about the Mediation Scheme,
really. So this conversation here and getting out of
Sparrow, it's about Mediation Scheme. So we had
a working party, lots of people working, individual case
reports. We had a mediation scheme, CEDR, but it just
didn't appear to me, in September ‘14, that the
Mediation Scheme was effective and, therefore, I was
looking for a better or faster way to get out of that
current -- the current way that we were doing things.
Open to any ideas, kicking ideas around, but just
keeping doing what we were doing didn't seem like
a sensible thing.
Can we look, please, at POL00102370. So the email at
the top there is from Alwen Lyons on 10 March to you and
others on the Board and it's effectively setting out
what had happened that day from Jane MacLeod and Mark
Davies, and that was the day on which the Working Group
was terminated. You have emailed in response:
"That feels very well handled.
I'm sure it will ignite some more, but so far so
good."
If we look down at the email itself, the update, we
139
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
saying that and Sir Anthony Hooper was saying that. So
I'm trying to find a better, faster way out of Sparrow.
So I'd already talked about a number of things. I had
suggested and was trying to get Second Sight put on
piece rate, rather than a day rate, we were
incentivising them to go slowly the way we were paying
them, incentivising them to get more people. They had
more than two people at this stage but two people
against 20 is daft. Maybe paying more. I mean, let's
look again at paying people more and looking to settle
because, clearly, the amount we your paying in mediation
wasn't working.
So we needed to find a faster, better way of
Sparrow. So the leak was, if we could use the leak,
which did annoy me. So the fact that there is a leak
says that the process isn't working. If the process is
working you wouldn't get a leak so can we use the leak
to find a faster, better way out of Sparrow? That's
what I was asking.
So, at this point, you refer to June 2014, where you say
there was a proposal brought forward to -- questioning
whether ending the scheme. Obviously June 2014 is when
the Board Briefing for Deloitte is presented as well.
At this point, was there any discussion for the
potential faster or better way out to be to commission
138
see the explanation of what happened and then "There has
been a very low-key response". Over the page, setting
‘out some response back to it including from journalists
and on Twitter.
So we can go back to page 1, please. Further up
please. Thank you.
When you say "I'm sure it will ignite some more but
so far so good", are you there referring to -- “ignite
some more" -- you're referring to press reaction?
Yes.
In your witness statement -- we don't need to bring it
up but it's page 67, paragraph 178 -- you respond to
a question on the use of the words "very well handled",
and you say:
"The closure of the Working Group was a very
sensitive issue and needed to be handled carefully and
effectively so that the subpostmasters did not disengage
from the Mediation Scheme. It was common for me to give
praise to members of the Post Office who had executed
a task well, to say thank you and well done."
Were you, in fact, here congratulating Jane MacLeod
and Mark because you thought they had done a good job of
keeping pressure off Post Office to reverse the
decision?
To reverse the decision that we had made to terminate --
140
(35) Pages 137 - 140
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
po
The Post Office Horizon IT Inquiry
To terminate the Working Party?
-- the Working Party? Not at all. So most of the
people involved in this, Sir Alan Bates -- maybe not
Sir Alan Bates. Certainly JFSA, MPs, Lord Arbuthnot,
were basically saying "All cases should go to
mediation". So, for some months, we had been told, the
Post Office had been told, all cases should go to
mediation.
Pausing there, they weren't saying all cases should go
to mediation and the Working Group as the independent
‘oversight should be discharged, were they?
So the Working Group had -- if all cases went to
mediation, there is no purpose for the Working Group.
So we still funded Second Sight to do the independent
report which would go along with the case review but the
Working Group had ended up being a weird thing where
Post Office were saying yes or no, JFSA were saying yes
or no, Sir Anthony Hooper was sometimes making a casting
vote, and people were arguing about should something go
into the Mediation Scheme or not, which was just a waste
of time and energy.
So you're much better off just binning the Working
Party and putting all cases into mediation. So I don't
think -- I mean, I don't know why anybody would want to
reverse that decision because actually we the Post
141
of the Shareholder Executive Non-Executive Director.
Can we bring up, please, POL00021507. This is a meeting
‘of 23 May 2012, which we've been to already today but
could we look at page 4 this time.
It's Susannah Storey outlining the reasons for
representation of the Shareholder Executive on the
Board, and the last part, she says:
"She clarified that she would not be sharing the
Board papers with her colleagues in Shareholder
Executive."
Are you aware as to if anyone from Post Office had
asked her not to share her papers with her Shareholder
Executive colleagues?
‘Am not aware if anyone had asked her not to. I do
recall that there was a difference between Susannah
Storey and Richard Callard's time, in that -- and
I might have this slightly wrong, but Richard did share
and had a fully integrated function as being -- running
that department in ShEx and also being a Non-Executive
Director. Susannah -- and I can't remember the reason
for it -- there was a view that there may be a conflict
of interest and there Susannah was NED on the Board but
I'm not sure that she ran the team in ShEx, and there
was like a Chinese wall between them.
I've got to say I think that Richard -- the
143
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
prpo>r
29 July 2024
Office had been asked to do that for some months
beforehand by pretty much all the people involved.
It's right, isn't it, that the Post Office had also been
asked to mediate cases in which there was a criminal
conviction --
Yes.
-- and Post Office's decision was not to do so --
Yes.
Do you not think the Working Group had a role in
overseeing those cases where there was a conviction that
had entered into the Mediation Scheme?
I'm not sure that I see the link. So we, the Post
Office, was under the impression that -- and we were
advised -- that the mediation process is not appropriate
for a criminal conviction and only the Court of Appeal
can actually overturn that. So, whilst we would go
through the collecting of evidence and the case review,
putting it into a mediation scheme wasn't advised to be
a sensible thing because it needed to go back to the
Court of Appeal in order to overturn a criminal
conviction and the mediation process, even under CEDR,
has got absolutely no authority to change a criminal
conviction.
I want to briefly look at two very discrete topics in
respect of Shareholder Executive. The first is the role
142
situation with Richard is far better than the situation
with Susannah.
Better for who?
Just better all round. Better for the shareholder,
better for POL.
So where it says she clarified that she would not be
sharing the Board papers, you can't assist us with the
origin of that came from, why she felt she didn't need
to share her Board papers with colleagues at ShEx.
I'm guessing it's something with Alice and -- I mean,
I'm guessing it's coming from Alice.
Was there any resistance on the Board to a Shareholder
Executive Non-Executive Director being appointed?
I do recall an early conversation with Alice where she
had some nervousness about it.
Do you remember what she said about her nervousness?
I honestly cannot remember. So, in my life, I have
always got a shareholder on the Board and I always find
it useful to have a shareholder on -- so every other
Board I've sat on, I've got a shareholder there, and
I find it really useful for the shareholder to be there.
Every now and again, there's a conflict of interest,
and somebody recuses themselves but that's very, very
rare. 99 times out of 100, it's helpful to have the
shareholder represented on the board, and I do remember
144
(36) Pages 141 - 144
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
having that conversation with Alice, where I think Alice
was okay with it.
Just going to your experience of sitting on Boards with
other shareholder representatives, the way in which
Susannah Storey and Richard Callard fulfilled that role,
was that consistent with how you'd seen the shareholder
role fulfilled in other Boards you'd sat on?
Yes, yes. I think, inevitably, they have quite
a difficult tightrope to walk because the aims are
sometimes different. So, at the end of the day, they
are there looking after the shareholder interests but
they're also there as a director of the Board and
sometimes those two will diverge, but I think they both
perform that role reasonably well.
I want to look at another matter, again relating to
a Shareholder Executive issue. In Richard Callard's
witness statement to the Inquiry, he referred to an away
day in June 2014, which he said that many members of the
Board felt at that away day that Paula Vennells was
acting more like a Non-Executive Director than a case.
Did you share that view and do you recall that away day?
I did share that view. I do vaguely recall the away
day. There is a fairly long history to Paula, which is
not desperately satisfactory, and Paula's performance,
which I touched on this morning -- her performance
145
the strategy aspects.
I want to briefly deal with one matter which is way, way
ahead in the chronology. In fact, it's after the
Horizon Issues trial, and it's communications you had
with Paula Vennells in 2020. Please can we bring up
PVENO00000362. If we could go to the second page,
please. You see these are text messages provided by
Paula Vennells, they're marked as being an exchange with
you on 3 March. Do you recognise these as being texts
that you sent to her and received from her.
Yes.
You say -- did you say something, sorry? No.
You say:
"Good morning Paula.
"Just to let you know I am a tad early and in
Paddington ..."
So you're referring to a meeting you're about to
have with her. Do you remember the purpose of meeting
with her on 3 March 2020?
Yes, so this is an extract from a slightly longer chain
of text messages, which I'm not sure if you have or not.
The earlier ones I looked at on my phone, whilst I'd got
these, I'd forgotten these. Basically Paula texted me
to say she'd just had a coffee with Alice, she's trying
to remember and catch up on things regarding Post
147
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
29 July 2024
changed over time and our view of her performance
changed over time. But, certainly, in 2014, her
performance was not great. In fact, probably towards
the end of '13 and '14 her performance was not great
and, as you will be aware, we did conduct an exercise
with a firm of headhunters to market, map and understand
alternatives.
Your concerns, to what extent -- sorry, I'll repeat
that.
Your concerns with Paula Vennells, to what extent
did they relate to her handling of matters such as the
Second Sight Review and complaints as to Horizon's
integrity?
They were not the main area of concern.
Was it an area of concern?
Not that I can recall. I don't recall her handling of
Horizon being an issue. She was very heavily involved
in Horizon. She and Alice spent a lot of time, a lot of
energy involved in Horizon. Arguably, you know, Paula
didn't spend enough time on other things. Now, clearly
with hindsight, that's wrong, and she didn't spent even
enough time with Horizon or do the right things. But
the criticism of her wasn't specifically about Horizon;
it was really about the leadership of her team, the
management of the business, the lack of commerciality,
146
Office. Would I have a cup of coffee with her, please.
So I said "Yeah, I left Post Office a long time ago. My
memory of Post Office is poor, I haven't got paperwork.
So I'm really not going to be much use to you, but I'm
happy to have a coffee". So we had a coffee.
We see the text there around 11.13/11.15, later on in
the evening, it says from Paula:
"Lovely to see you -- thanks for your wisdom,
memory, time and coffee! Will keep you posted.”
Do you remember what topics you discussed with Paula
Vennells at that meeting?
So Paula was asking me for my recollections of Post
Office and, honestly, I had very few recollections of
Post Office and I don't think that I told her anything
that she didn't already know way more than I did, and
that lasted maybe ten minutes, and then it morphed into
a conversation about her because she was not in good
form.
Just pausing there, I'm only going to explore with you
matters that are relevant to the evidence of the
Inquiry. I don't want to pry into anything further. In
that ten-minute conversation can you recall any specific
topics that she asked you about in particular, regarding
Post Office?
The Second Sight investigation, the Mediation Scheme,
148
(37) Pages 145 - 148
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
The Post Office Horizon IT Inquiry 29 July 2024
Business Improvement Programme, Working Party. I think
the only thing I can remember is Second Sight and the
spin-offs from that. I don't think there was
a conversation about prosecutions. So I think it was
Second Sight, mediation, Working Party.
Can we look, please, at PVEN00000015. So if we go to
the bottom of that page, please, we've got an email
about a week later on 15 March. It says:
"Hi Paula,
"Forgive me for being paranoid with the email
address!
"All very well here thank you ...”
"I had looked before and found nothing. I stumbled
across these two bits that I just seem to have neglected
to throw out. They may be of some small use -- if only
to jog your memory of the players involved."
What request were you responding to here?
Paula had asked if I had any paperwork regarding, say,
the things that she had been asking about: Second Sight,
Mediation Scheme, Working Party.
Thank you. That can come down.
I have two final broad questions on reflections.
We've gone in detail about the Board oversight of IT and
prosecutions from 2012 onwards, really. To what extent
do you think the Board would have been assisted if it
149
and there was some very important pieces of information
which were just missing and totally airbrushed, and
there were other pieces of information which were
massaged in a way that we didn't pick up on.
The absence of IT and legal expertise on the Board --
I say that in particular for non-execs -- was that
something you considered at the time as being something
that was absent?
We did, when we were thinking about the Nominations
Committee, we did -- and I think it's there in one of
the Nominations Committee reports -- we did say that
when the Board was refreshed, we should try to refresh
it with somebody with IT skills. So I don't think we
thought of it a screaming need but we did think of it as.
it would be helpful to have somebody with good IT
skills. Again, the benefit of hindsight is probably --
that would have been much more helpful at the time.
I think at the time we thought that we had found
what needed to be found and needed to be fixed, and we
were not as aware of the prosecutorial misfunction as
maybe we should have been.
MR STEVENS: Sir, those are the questions I have. Unless
you have any questions, I know there are some from Core
Participants.
I think is it ten minutes? 15?
151
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
had a Non-Executive Director with a specialist expertise
in IT?
A. I think that it would have been very useful to have
somebody with IT expertise on the Board and I also think
it would have been very useful for us to have --
arguably more useful for us to have somebody with legal
experience on the Board.
I have heard a lot of my peers, colleagues,
ex-colleagues, say that they thought the Board -- or
agree that the Board wasn't curious enough and,
actually, I personally don't agree with that. So if
I think about the Board, the Board was very curious. It
was quite combative, it was quite challenging.
Horizon issues aside, we were a very, very busy
Board dealing with some very difficult problems and we
made very good headway on many of those things and we
did that in quite a challenging environment. So the
whole environment was quite challenging.
With Horizon issues, I think partly because nobody
‘on the Board had good IT or good legal skills -- and
I'll perfectly happily admit I don't have good IT or
good legal skills, that wasn't why I was recruited --
I think the level of challenge probably wasn't good
enough. But, to me, the much bigger issue is that the
flow of information which came to the Board was flawed,
150
Sorry, sir, I'm just taking time -- oh.
You're on mute, sir, sorry. We'll take a break --
‘SIR WYN WILLIAMS: I've been unmuted but, for the last
30 seconds to a minute I've heard everything but I've
lost the video, if you see what I mean.
MR STEVENS: I see, sir.
SIR WYN WILLIAMS: So yes, if we take ten minutes and then
that can be put right.
MR STEVENS: Of course, yes.
We can hear you now, sir, sorry if I was speaking
over to you and noticing.
‘SIR WYN WILLIAMS: "No, it's fine, I wasn't able to unmute
myself but I had some remote assistance for that so I'd
now like some remote assistance to resume looking at you
all.
MR STEVENS: Thank you, sir. We'll arrange that, sir. So
if we come back at, shall we say, 3.55, sir.
‘SIR WYN WILLIAMS: Mm-hm.
MR STEVENS: § Thank you.
(3.43 pm)
(A short break)
(3.55 pm)
MR STEVENS: Sir, this usually a formality but hopefully you
can hear and see us this time?
SIR WYN WILLIAMS: Yes, I can, thank you.
152
(38) Pages 149 - 152
1
2
3
4
5
6
7
8
9
10
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
MR STEVENS: Only one set of questions from Mr Jacobs who
has ten to 15 minutes, I think.
SIR WYN WILLIAMS: Right, fine.
Questioned by MR JACOBS
MR JACOBS: Mr McCausland, good afternoon, I represent
a large number of subpostmasters and subpostmistresses
who are affected by this scandal and are Core
Participants in this Inquiry and I'm instructed by
Howe+Co.
I want to ask you about two things, hopefully quite
briefly: the first topic is bugs in the Horizon system
and the second topic is the Post Office Advisory
Council.
In relation to bugs in the system you gave evidence
this morning and you referred to a discussion with Susan
Crichton that you were present at, and you said -- and
I'm just reading from the [draft] transcript, so correct
me if I'm wrong -- Susan Crichton informed you that in
all previous prosecutions where Horizon data had been
used we -- that's the Post Office -- had been
successful. You said:
“I was talking to an experienced RMG director", who
I think its Les Owen, is that right?
A. Yes.
Q. He was talking to your General Counsel and there was
153
took comfort from that exchange, where Susan was very
clear we had won on previous prosecutions, the audit
report was very positive, it had been reviewed by
Deloitte, and the legal claims which I had not seen,
from Access Legal, were weak. So, yes, I took strong
comfort from that.
Q. That was the message you were getting from Post Office,
wasn't it?
A. Yes.
Q. So if we can move forward in time a little bit to 8 July
2013, which was the release of the Second Sight Interim
Report.
A. Yes.
Q. Again, taking you back to your evidence this morning,
you said that you were unhappy that you were not kept
properly informed about the progress of the Interim
Report.
A. Yes.
Q. You said:
"We had asked the Board several times over the year
how are Second Sight getting on. So to have it dropped
‘on us, not in a written communication, not at a proper
Board meeting, with proper papers, but just to have it
thrown in as an AOB to say [and I'm quoting you]
actually, Second Sight Report is coming out next week
155
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
a very clear and a very robust answer from Susan
Crichton that the system was sound. That was your
understanding, yes?
Yes.
Had you been told, at that stage, that there were no
bugs in the Horizon system?
I had not been explicitly told anything about bugs at
that stage, so this was very early in 2012, the January
Board meeting, I think, in 2012 and nowhere in my
induction or in the Royal Mail Group handover had there
been a conversation about bugs.
Right. Would it be fair to say that, as a result of
your conversation or the conversation that you were
involved in with Ms Crichton and Mr Owen, that it was
your understanding or it was the general understanding
of you and others on the Board that the Horizon system
was working perfectly and that there were no bugs in the
system?
Yes. I took comfort from the fact that the General
Counsel was being very clear and very unequivocal with
an experienced Royal Mail Group, as Les was Royal Mail
Group and had been on the RMG Board for some time, and
I took comfort from that.
I wasn't really involved in the discussion at that
stage, if I'm honest, I was listening but I definitely
154
and we're not happy with it because it's inaccurate and,
by the way, there are bugs and flaws."
That's how it landed on you, effectively?
Yes.
So we've gone, haven't we, from you having
an understanding that there are no bugs in the system,
everything is working perfectly, to a report from
forensic experts which said that there are defects in
Horizon Online, that it impacted 76 branches. The
receipts and payments mismatch problem affected 62
branches and the local suspense account problem affected
14 branches. So we've gone from one quite extreme
position to another quite worrying position, haven't we?
We've gone from a very confident position to a less
confident position but, at that stage, it wasn't
a particularly worrying --
Yes, and I remember you said that it should have been
a red flag but it was probably an amber flag, is I think
what you said this morning?
That probably is right.
Yes. So do you think that the Board, when presented
with a serious change of information about the Horizon
system, should have requested more information from IT
managers in POL, or even from Fujitsu, at that point
when you got that report?
156
(39) Pages 153 - 156
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
So when -- if I try to remember back to that time, when
I got the report and read the report from Second Sight,
and coupled with that had Paula's briefings verbally and
in writing, the two were -- the two issues were somewhat
separated in my mind. So neither Second Sight nor Paula
were saying that the bugs and the issues that we were
trying to find through Second Sight, ie the
subpostmaster losses, how have they arisen, what is
happening to them, follow the money.
Those two issues were separate and they were
separate when Paula was describing them. She was very
clearly articulating it verbally and in writing that
these bugs were not linked to the Second Sight cases.
And, in the Second Sight report, they were also
separate. Second Sight were clearly saying there are no
systemic problems with Horizon and there are two bugs
that have been found but they weren't saying these bugs
have caused this problem.
So, with hindsight, wrongly, but at the time, both
Second Sight and Paula led me to believe that the bugs
were actually not the issue that we were grappling with
here.
I think the essence of the question that I ask you on
behalf of our clients is: was this not is an opportunity
for the Board to get more information about why Post
157
Sight's Report or Second Sight had come to the Board and
said that but that -- I read Second Sight's report and
I didn't -- and even if I read it now, I still -- it
doesn't come out at me as saying these bugs are the
problem --
All right.
-- which is I think why we didn't take the action that
I wish we had taken.
So just -- and I'll move on after this, I think I have
your answer but I think that your answer is the fact
that Post Office were originally telling you there are
no bugs, and that Second Sight, in an Interim Report,
said there are bugs that affected 76 branches, you
didn't think at that point that someone in Post Office
was misleading the Board, which, of course, now we know
to be the case?
Correct.
I'll move on, and I'm going to ask you about
paragraph 34 of your statement, and if we could just
maybe call that up, it's WITN10290100. It's page 14 of
83. Weill just wait for that to load on the screen. So
paragraph 34, please. Thank you.
We can't see a paragraph 33, but the headline is
"Post Office Advisory Counsel (POAC’)". What you say
at the bottom, so we can see about eight lines down,
159
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
Office had been saying one thing and Second Sight were
saying something slightly different? Wasn't there
a case to consider whether the Board were being misled
by Post Office at this time?
I don't think Second Sight were saying something
different to the Post Office. So Second Sight and the
Post Office were both saying the same thing, which was
that they had found these bugs but they weren't -- they
weren't the same bugs or they weren't the problem which
we were looking for in the Second Sight Report. So the
Second Sight Report I read as saying there are definite
problems here, you need to fix these things -- I've been
through them again -- before, I won't repeat them -- and
that is what they were saying.
They weren't saying, "You've got two bugs here,
that's what you need to be looking for, boys". The
Second Sight Report -- I wish with hindsight that the
Second Sight Report had said, "First of all you've got
big prosecutorial problems", which I watched the
evidence from lan and Ron and they say they said that to
Susan, nothing about that in the report, and I wish that
they'd said, "You've got bugs here", and also, you know,
"I have been speaking to Gareth Jenkins and he tells me
this".
So all of that stuff, I wish that had been in Second
158
"I was a member of this committee", five lines from the
bottom:
"I was a member of this committee alongside Tim
Franklin, who acted as Chairman."
Then you say:
"POAC was established in 2014
Well:
"The idea behind POAC was to enable the Company to
better hear the views of SPMs and customers and to try
and improve engagement and workplace culture. I was
a member of this alongside Tim Franklin who acted as
chairman. POAC was established in 2014 and was set up
to help create a pathway to mutualisation, where all the
stakeholders -- [Post Office] employees,
[subpostmasters], customers and wider stakeholders --
worked collaboratively to improve the company for the
good of all."
Yes?
You've relied in your statement on the POAC terms of
reference. If we could maybe move to that document,
which is POL00228475.
We'll just wait for that to come up on the screen.
So we can see the purpose of the committee was to:
provide a forum for Post Office stakeholders
and other experts [this is reading from the top] to
160
(40) Pages 157 - 160
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
discuss issues of interest and importance that impact on
customers, stakeholders and their communities."
Now, a stakeholder is an SPM, that's right, isn't
it?
Yes, amongst others.
The role of the Council, and you can see the bullet
points under "Role", was to:
provide a two-way channel of communications
between Post Office and its stakeholders [so
subpostmasters in the post office would be included in
that]
“provide a mechanism for stakeholders and experts to
offer views and advice to Post Office Board and the
Group Executive on subjects brought to it
“increase understanding and strengthen relationships
between Post Office, its stakeholders and wider interest
groups
"provide a community for advocacy and communication
of Post Office issues."
Do you think that this is a potential vehicle that
could have dealt with subpostmaster issues with the
Horizon system? It certainly sounds that way.
I'm not sure that it could, to be honest. So the
culture of the Post Office was not good, particularly at
the beginning. It was very "Head Office is God and
161
debating, having different views.
I think to grapple with the Horizon issues, Horizon
issues inevitably are very technical, and I think you
really needed a group of specialists with a lot of time
to do that. And the people on the POAC were giving
their time but they were giving limited amounts of time
because they all have jobs elsewhere. So to expect them
to really, you know, dive into something which wasn't
their specialist subject, I'm not sure that the POAC
would have been a great vehicle to tackle the Horizon
issues.
In light of what you say in your statement, though,
where you say that it was to help stakeholders, which
include subpostmasters, to work collaboratively to
improve the company for the good of all, you've said
that there were subpostmasters who were members of the
POAG:; is that right?
I believe so.
Were they subpostmasters who had knowledge of the
Horizon issue, do you recall?
So I don't recall -- knowledge of Horizon, absolutely,
users of Horizon. Of the Horizon issue, I don't
remember any conversation at a POAC regarding the issues
that are being talked about in this Inquiry.
There was a provision to invite people to the meetings?
163
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
29 July 2024
everyone else is not good". It didn’t talk about
a customer at all. It was arrogant. There was a blame
and defensive culture. So, throughout my time there, we
tried hard to shift the culture into something frankly
more normal. There was, again, throughout my time,
a plan -- I wouldn't call it any more than that but
a plan -- to prepare the company to one day become
a mutual.
It was totally impossible at the beginning because
there were conditions -- yeah, you would need to be
financially sustainable to become a mutual and that was
nowhere near. But the Government quite liked the idea
of a mutual. Tim and I very much liked the idea of it
being a mutual and, therefore, we took number of steps
to try to change the culture, to try to engage more with
the subpostmasters, so we forced part of Paula's bonus
to be on subpostmaster engagement. We developed a lot
‘of engagement mechanisms, just communication. So lots
more communication with the subpostmasters, and huge
amounts more listening from them.
So the POAC was designed, really, just as one of the
strands in that, where we would get together a group of
people, subpostmasters, but a lot of customers as well,
industry people -- so people like Google were on it --
just as a way of opening up the culture, listening,
162
Yes.
And also the Committee fed back to the Board and the
Board fed back to the Committee; that's right, isn't it?
Yes.
Because Post Office knew what the issues were with the
subpostmasters and Horizon issues, did anyone ever
suggest inviting people like Lord Arbuthnot or
individual subpostmasters who had grievances to talk to
the Committee to try to resolve the issues at that
level? If someone had said, for example -- doesn't have
to be a technical point -- but "I can see the cursor is
moving on the screen, someone is in my system. I think
there have been miscarriages of justice, all my uncles
and aunts have been prosecuted, they've done nothing
wrong", that sort of thing might have been able to cut
through the culture of the Post Office; do you agree?
I understand what you're saying but I'm not sure that
lagree. So the agenda for the POAC was formed by the
members. So the members of the POAC would say what they
wanted to talk about and Tim, as Chair, would basically
agree. So, I mean, Tim is the nicest, most
collaborative man in the world and Tim would broadly
shape the agenda based on what the members wanted to
talk about. And those things tended to be more the
strategy for the Post Office, where we were going with
164
(41) Pages 161 - 164
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry 29 July 2024
Financial Services, why don't we do more for an energy
and telecom offer? How can we get better at listening?
Network Transformation was an issue.
So the agenda came from the members, which is what
we were trying to do. I wish that we had had more
direct contact as a Board so, again, I'm not sure the
Post Office Advisory Committee is the right place for
that but, as a Board, I absolutely wish that Lord
Arbuthnot and Second Sight and subpostmasters had come
to the Board and, you know, we had had more direct
contact in that way because, I mean, I have said it
several times but I'll stress it again: the NEDs on the
Board were not trying to cover up, were not trying to
shy away from problems. We were actively tying to find
problems and we thought we had found some of the
problems, and we thought we tried to fix some of those
problem.
We clearly didn't and, actually, the one thing that
I think might have helped to unlock that and to change
what we were doing, was direct contact with JFSA,
Sir Alan Bates, Lord Arbuthnot, subpostmasters, and
I regret that that didn't happen.
MR JACOBS: I think I have probably asked all my questions.
I'm just going to see if there is anything else that
Howe+Co and Mr Stein would like me to ask you?
165
INDEX
NEIL WILLIAM MCCAUSLAND (sworn) ....
Questioned by MR STEVENS .
Questioned by MR JACOBS ....
167
ONOaARWN
©
1
12
13
14
15
16
17
18
20
21
22
23
24
25
No, that's all. That's been helpful. I'm grateful,
thank you.
SIR WYN WILLIAMS: So that's it, is it, Mr Stevens?
MR STEVENS: Yes, sir.
SIR WYN WILLIAMS: = Well, thank you very much, Mr McCausland,
for making your witness statement, answering very many
questions during the course of the day, being
interrupted by a fire alarm and momentarily going off my
screen. But, nonetheless, we got through the day, and
I'm very grateful for your evidence.
THE WITNESS: Thank you, sir.
SIR WYN WILLIAMS: = Right. Tomorrow morning, can we make it
10.00, Mr Stevens, so that my train doesn't maroon me
and make you all late?
MR STEVENS: Yes, of course, sir.
‘SIR WYN WILLIAMS: Fine.
MR STEVENS: Thank you, sir.
(4.15 pm)
(The hearing adjourned until 10.00 am the following day)
166
(42) Pages 165 - 167
MR JACOBS: [2]
153/5 165/23
MR STEVENS: [32]
115 117 1/14 41/10
A115 41/17 41/21
41/24 66/18 85/17
85/21 86/3 86/5 86/9
86/11 107/6 108/22
109/2 109/4 121/12
124/17 121/19 151/22
152/6 152/9 152/16
152/19 152/23 153/1
166/4 166/15 166/17
SIR WYN WILLIAMS:
[29] 1/6 1/8 41/13,
41/16 41/23 84/17
85/2 85/8 85/16 85/19
86/1 86/4 86/10
107/11 108/20 108/23
109/3 121/9 124/18
152/3 152/7 152/12
152/18 152/25 153/3
166/3 166/5 166/12
166/16
THE WITNESS: [1]
166/11
"10 [1] 23/23
10/11 [1] 23/23
"41 [4] 8/17 23/23
23/24 120/8
"41/12 [2] 23/24
120/8
"42 [2] 23/24 120/8
"13 [7] 23/25 95/2
95/3 102/16 103/7
120/2 146/4
"43/'14 [4] 23/25
"14 [7] 23/25 23/25
43/24 102/19 137/9
139/9 146/4
"44/'15 [4] 23/25
"15 [1] 23/25
‘bugs’ [1] 38/6
"bulletproof" [1]
56/19
‘defects' [1] 37/2
‘digitally [1] 77/23
"evidence [1] 68/2
‘fake’ [1] 78/6
‘Horizon’ [1] 56/9
"phantom [1] 79/10
‘phantom’ [1] 62/16
"POAC' [1] 159/24
‘transaction’ [1] 80/9
-- they [1] 13/3
1
1 July [2] 32/15
39/18
1.04 [1] 108/24
1.4 [1] 45/7
1.5 billion [1] 47/1
1.6 [1] 130/1
1.6 million [1] 129/22
1.9 [1] 130/2
10 [3] 5/1 73/21
112/21
10 March [1] 139/17
10 years [3] 5/25
37/17 74/10
10.00 [1] 166/13
10.00 am [1] 166/19
10.54 [1] 41/18
100 [6] 8/4 24/8
24/14 25/12 84/5
144/24
100 million [1] 52/14
100 per cent [1]
102/9
100,000 [1] 130/2
11 February [1]
100/14
11.05 [1] 41/15
11.06 [1] 41/20
11.13/11.15 [1] 148/6
11.15 [1] 148/6
110 [4] 93/24
12 [3] 30/19 36/25
101/7
12 January [4] 12/12
16/22 16/23 38/23
12 July [4] 88/16
89/24 96/6 99/24
12.16 [1] 86/6
12.25 [2] 86/3 86/8
120 million [4] 5/3
125 [1] 56/4
13 [1] 20/21
13 August [1] 99/23
13 November [1]
20/14
13/14 [1] 20/5
14 [3] 20/5 156/12
159/20
14 June [4] 27/25
146 [1] 109/9
15 [2] 151/25 153/2
15 July [2] 93/20
94/1
15 March [1] 149/8
15 May [1] 12/20
15 million [1] 47/2
15 years [1] 5/24
15/iPhone [1] 6/15
150 [2] 43/6 43/10
157 [1] 129/4
16 [1] 6/15
16 July [8] 36/17
88/6 88/13 91/4 95/4
95/21 96/3 98/6
166 [3] 42/11 42/11
43/19
46th [4] 115/16
47 [1] 9/12
178 [1] 140/12
181 [2] 11/25 94/10
186 [1] 103/19
19 November [1]
126/1
199 [1] 94/4
1999 [1] 2/11
Aof [4] 4/18
1st [2] 39/13 93/13
2
2 September [2]
109/17 114/13
2.05 [2] 108/21 109/1
2.25 [1] 121/14
2.3 [1] 47/10
2.50 [1] 121/16
20 [2] 44/16 138/9
20 March [1] 45/5
200 [1] 60/18
200,000 [4] 101/7
101/17 130/1 132/25
2000 [1] 2/22
2001 [1] 2/14
2002 [1] 2/15
2008 [1] 79/8
2010 [5] 63/7 63/10
63/13 63/20 97/6
2011 [7] 2/23 2/25
6/5 16/9 37/1 37/9
119/14
2012 [13] 16/8 20/14
25/21 27/25 37/1
38/23 119/14 122/7
123/15 143/3 149/24
154/8 154/9
2012/13 [1] 20/21
2013 [16] 32/15
86/21 88/6 91/4 93/20
94/1 95/21 96/23
98/20 102/13 102/24
103/13 109/17 114/13
133/23 155/11
2014 [19] 12/20 42/4
44/8 45/5 51/17 60/2
64/13 64/25 100/14
101/18 102/13 133/3
135/21 138/20 138/22
145/18 146/2 160/6
160/12
2020 [2] 147/5
147/19
2024 [3] 1/1 14/15
45/16
203 [1] 1/21
21 May [1] 45/15
23 May [2] 25/21
143/3
25K [1] 46/17
26 March [4] 51/17
27 July [1] 96/23
29 [1] 64/24
29 April [1] 64/13
29 July 2024 [4] 1/1
67 [1] 140/12
68 [2] 11/25 94/9
3
7
3 March [2] 147/9
147/19
3 September [1]
114/14
3.43 [1] 152/20
3.55 [2] 152/17
152/22
30 [1] 71/14
30 April [7] 60/2 61/9
67/2 67/5 71/1 79/9
81/16
30 August [1] 111/5
30 seconds [1] 152/4
30 September [1]
111/16
30/9 [1] 111/4
30th [1] 69/22
31 July [1] 133/13
31 May [1] 84/1
33 [4] 159/23
34 [2] 159/19 159/22
3402 [6] 13/6 13/7
13/9 14/7 21/4 51/11
36 [2] 24/7 26/7
4
4 June [2] 61/3 71/22
4.15 pm [1] 166/18
4.5 [1] 100/20
46 [1] 56/4
47 [8] 29/22 30/1
30/6 30/9 30/10 33/16
38/17 133/15
4June [1] 84/3
5
5 per cent [3] 92/5
92/6 92/6
5 September [1]
135/21
5,000 [3] 27/13 27/13
29/14
5-6 million [1] 21/16
5.30 [1] 49/11
5.32 [1] 50/15
500,000 [1] 129/23
50K [1] 46/17
55 [1] 119/10
59 [1] 129/5
6
6 July [1] 86/21
6 June [1] 14/15
6 million [1] 52/13
6.4 [1] 36/23
6.5 [1] 37/4
6.6 [1] 37/4
6.7 [1] 37/7
600,000 [1] 21/13
62 [2] 42/10 156/10
7 August [1] 98/20
7,500 [1] 129/25
71 [1] 103/18
74 [2] 44/2 44/22
74 reports [1] 44/24
740 [1] 129/23
75 [1] 60/17
75K [1] 46/17
76 [6] 1/20 37/3 38/7
39/6 156/9 159/13
8
8 July [5] 33/5 36/16
88/7 95/4 155/10
83 [1] 159/21
9
9 April [1] 81/15
9 September [1]
135/25
9.45 [4] 1/2
9.47 [4] 1/4
98 [1] 24/8
99 [2] 26/7 144/24
A
ability [3] 49/16
133/19 134/21
able [16] 9/2 11/18
14/3 29/11 30/6 45/9
62/3 66/9 79/5 100/23}
113/2 113/4 126/17
131/6 152/12 164/15
about [172]
above [1] 21/12
absence [3] 52/20
91/5 151/5
absent [3] 45/8 51/7
151/8
absolutely [35] 4/22
5/13 5/23 6/22 9/5
14/12 22/20 30/5
31/22 32/3 45/21
51/16 53/13 56/18
59/11 59/16 62/11
79/21 83/7 83/12 89/1
89/14 89/18 90/19
102/8 103/2 105/6
108/17 120/23 125/1
134/19 136/15 142/22)
163/21 165/8
absorbing [2] 19/2
19/8
accept [6] 62/9 77/6
81/2 118/19 121/1
122/1
acceptable [1]
108/19
accepted [7] 21/16
75/12 75/24 116/7
(43) MR JACOBS: - accepted
A
access [13] 10/14
17/13 17/18 17/22
60/11 62/7 62/19
62/22 62/25 78/4
79/10 79/23 155/5
accordance [1]
74/25
accords [1] 129/9
account [4] 7/6 45/11
58/13 156/11
12/5
accountant [3] 24/11
25/19 26/3
accountants [2]
34/25 84/10
accounting [10] 9/16
9/20 21/24 22/1 22/2
22/6 22/19 117/17
119/13 126/15
accounts [7] 17/18
21/14 21/25 22/4
22/14 27/14 37/14
accumulation [1]
21/15
accuracy [1] 16/2
accurate [3] 75/12
75/16 75/24
accurately [1] 15/22
acknowledge [2]
73/1 76/6
across [7] 5/21 28/7
29/4 65/23 97/8
125/20 149/14
acted [3] 127/16
160/4 160/11
acting [1] 145/20
action [4] 23/18
59/13 85/3 159/7
actions [1] 97/2
actively [1] 165/14
activities [1] 129/3
activity [4] 67/25
actual [5] 39/24
107/17 113/5 113/11
121/25
actually [54] 10/9
11/17 22/23 24/1 30/2)
30/3 30/7 31/4 32/4
32/22 35/24 38/9 43/3
43/13 46/7 46/9 46/16)
46/18 46/21 47/4 48/4
48/7 49/1 51/14 52/22)
55/20 62/21 65/16
77/10 77/19 80/2
81/12 85/17 86/24
105/8 113/6 115/25
116/25 119/20 130/3
130/8 130/11 130/25
131/6 134/7 135/8
accepted... [3]
116/20 116/22 117/24}
accountancy [2] 9/18)
157/21 165/18
add [1] 4/24
added [1] 96/15
addition [1] 51/15
additional [1] 133/18
address [2] 42/15
149/11
addressed [1] 49/19
addresses [3] 47/18
47/25 48/16
addressing [1] 48/18
adequately [1] 42/15
adjourned [1] 166/19
Adjournment [1]
108/25
adjustments [1]
21/12
admit [1] 150/21
Admittedly [1]
101/14
advance [2] 46/11
67/2
advice [32] 42/8
49/3 50/19 76/22
83/17 83/18 86/14
93/20 93/21 94/1
99/15 105/4 106/15
106/24 107/17 107/18)
110/23 116/7 116/21
116/22 117/1 117/8
117/24 118/13 118/18)
118/19 131/6 161/13
Advices [1] 106/13
advised [3] 101/2
142/14 142/18
Advisory [3] 153/12
159/24 165/7
advocacy [1] 161/18
Affairs [1] 47/13
affect [1] 63/21
affected [9] 15/7
33/24 37/5 39/6 43/11
153/7 156/10 156/11
159/13
affirmative [1] 72/23
afraid [2] 90/15
112/25
after [21] 6/7 6/9 11/4
23/4 37/9 42/2 42/11
43/3 54/1 55/15 59/10
86/22 90/2 91/18 98/5)
114/16 115/15 117/7
145/11 147/3 159/9
afternoon [4] 109/2
109/6 121/17 153/5
afterwards [2] 42/9
136/3
AG [1] 20/19
again [36] 8/14 17/16
19/20 20/14 27/5 29/1
30/18 34/3 34/5 34/12
137/12 137/16 141/25)
142/16 150/11 155/25)
42/12 42/13 45/3 45/5
35/10 36/6 37/15
43/23 67/9 71/16
73/20 74/10 83/16
90/4 98/10 106/16
106/20 111/16 112/4
155/14 158/13 162/5
165/6 165/12
against [5] 7/1 19/12
116/13 118/11 138/9
age [2] 63/15 63/16
agenda [10] 84/24
90/23 100/15 164/18
164/23 165/4
ago [7] 20/5 30/19
37/17 73/21 112/21
130/19 148/2
agree [19] 7/2 29/17
30/5 38/23 39/2 40/21
76/23 85/9 120/20
120/24 150/10 150/11
164/16 164/18 164/21
28/23 40/22 49/3
51/16 52/5 68/6 69/20
69/20 121/24
ahead [1] 147/3
aims [1] 145/9
Air [1] 2/14
airbrushed [2]
108/16 151/2
141/4 165/21
alarm [6] 79/12 121/6I
121/7 121/19 121/21
166/8
Alasdair [12] 96/22
97/15 97/15 97/17
97/17 97/22 98/1
100/4 115/18 117/4
127/3 135/8
albeit [3] 9/17 9/24
70/23
alerted [1] 103/11
Alice [63] 3/3 3/24
14/14 15/25 16/13
24/19 24/24 25/2 25/2
25/7 25/12 25/15
25/25 30/21 31/3
31/22 31/25 36/5 36/7
36/12 62/1 84/25
88/18 88/20 89/3
89/11 89/25 90/5 90/8
90/13 93/6 95/6 95/9
97/15 97/25 98/3 98/8
98/18 99/7 100/2
110/19 110/25 111/16}
111/18 111/19 112/15
115/15 118/14 129/6
131/22 133/12 133/22
134/20 135/2 135/11
123/14 134/24 138/10
144/22 145/15 151/16
85/1 85/6 85/11 90/20
40/25 62/5 76/4 76/15)
agreed [11] 26/2 28/8)
Alan [4] 137/24 141/3I
135/14 144/10 144/11
144/14 145/1 145/1
146/18 147/24
all [82] 3/5 3/24 3/24
4/2 8/2 10/21 11/11
20/8 23/15 23/16
85/1 86/1 87/1 89/2
89/10 108/15 108/20
111/7 113/8 113/18
113/23 117/6 119/6
121/9 125/14 129/3
129/13 130/8 130/8
130/17 130/18 130/20)
131/11 131/12 133/7
141/2 141/5 141/7
141/9 141/12 141/23
142/2 144/4 149/12
152/15 153/19 158/18}
158/25 159/6 160/13
160/17 162/2 163/7
163/15 164/13 165/23
166/1 166/14
allegations [4] 17/17
39/7 62/15 62/25
alleging [3] 43/16
43/18 44/10
allowed [4] 112/14
almost [4] 14/23 29/4
48/8 48/11
alone [2] 5/9 30/10
along [5] 16/5 20/17
56/23 59/14 141/15
alongside [3] 21/4
160/3 160/11
already [13] 46/8
59/1 59/1 65/21 71/8
87/11 89/23 101/12
133/15 134/16 138/3
143/3 148/15
also [40] 7/12 9/1
10/20 11/9 19/14
23/18 24/14 26/2
27/21 38/11 38/18
40/17 47/14 48/9 51/6
51/18 60/4 64/4 64/16)
64/17 65/22 68/4
69/25 78/21 81/19
82/16 84/1 96/14
105/24 106/17 114/19}
115/9 136/6 142/3
143/19 145/12 150/4
157/14 158/22 164/2
alter [2] 136/8 137/5
alternatives [1]
146/7
although [6] 18/18
21/10 56/18 65/2 91/9
100/22
13/1 13/24 13/24 20/6)
23/20 27/8 27/8 27/17,
31/1 43/20 49/18 60/7,
64/8 67/24 68/10 74/3,
76/19 76/19 77/2 77/6
78/14 79/23 80/3 83/7,
Altman [7] 96/14
105/25 106/14 106/17)
106/19 106/25 120/5
always [5] 28/18
53/11 85/21 144/18
144/18
Alwen [14] 45/15
45/21 46/22 53/9
71/21 84/25 96/22
97/1 97/5 97/8 97/18
97/22 98/2 139/17
Alwen's [4] 45/21
45/24 46/1 46/3
am [23] 1/2 1/4 2/7
8/4 9/17 32/2 36/10
36/11 38/9 41/18
41/20 61/18 70/17
79/25 89/20 97/14
99/1 107/25 113/12
118/10 143/14 147/15}
166/19
amber [2] 38/20
156/18
amongst [1] 161/5
amount [9] 3/21 3/25
9/6 23/9 46/20 65/13
134/15 134/18 138/11
amounts [4] 46/10
129/16 162/20 163/6
analysing [1] 4/20
analysis [1] 7/16
analytic [1] 68/14
analytical [1] 68/21
analytically [1] 68/25
Andrew [2] 114/23
115/9
Angela [2] 53/21
53/24
Angus [6] 9/14 10/11
11/8 13/18 14/16
20/15
Anne [1] 51/12
announced [1] 32/14
annoy [1] 138/15
annoyed [1] 136/25
annual [1] 12/14
anodyne [1] 106/19
anomalies [5] 33/21
33/23 33/24 34/9
37/19
anomalies/bugs [1]
37/19
anomaly [1] 34/2
another [12] 7/5 8/10
20/17 52/22 52/23
59/22 90/21 93/12
119/7 135/24 145/15
156/13
answer [13] 11/2
19/19 20/1 39/9 74/5
81/9 107/12 122/3
123/8 125/6 154/1
159/10 159/10
answered [5] 73/16
(44) accepted... - answered
A
answered... [4] 73/19
74/2 79/24 79/25
answering [1] 166/6
answers [2] 83/6
127/9
Anthony [2] 138/1
141/18
any [86] 3/15 8/12
14/13 16/13 18/24
20/2 20/2 20/10 21/12
21/14 21/18 24/15
24/23 32/9 32/19
33/20 33/25 35/6 35/7,
37/19 42/17 42/19
44/14 46/15 50/1 55/9)
55/12 55/14 56/20
56/22 57/9 57/20
61/14 61/17 67/7
70/22 74/21 76/21
78/2 78/17 79/19
80/25 83/12 83/24
87/9 87/13 90/2 91/16
91/19 97/6 97/11
97/19 97/22 100/9
106/14 107/16 107/20
107/21 107/21 110/10
112/1 113/1 113/8
117/16 118/6 118/24
120/14 122/13 127/25
128/8 130/17 131/20
135/4 135/6 135/10
135/11 136/6 138/24
139/3 139/13 144/12
148/22 149/18 151/23}
162/6 163/23
anybody [2] 89/9
141/24
anyone [7] 3/20 70/4
91/24 95/17 143/11
143/14 164/6
anything [16] 14/10
16/5 27/2 31/13 34/9
42/23 44/3 74/14
88/20 89/16 131/7
132/8 148/14 148/21
154/7 165/24
anyway [1] 131/20
AOB [3] 25/24 35/24
155/24
apologies [4] 59/24
91/5 91/7 133/1
apologise [2] 59/25
133/2
appalled [1] 119/5
apparent [1] 129/20
appeal [3] 87/11
142/15 142/20
appear [1] 139/9
appeared [1] 42/13
appearing [1] 65/11
appears [1] 83/22
applicants [2] 44/10
58/11
apply [1] 27/3
appoint [3] 27/2 27/3
32/2
appointed [1] 144/13
appointing [1] 48/24
appointment [5] 24/6
24/21 24/24 32/3
103/22
appreciate [1] 64/20
approach [10] 21/3
28/10 28/12 28/24
28/25 29/16 57/8
106/20 126/5 127/15
approached [1]
104/18
appropriate [4] 68/8
110/22 123/3 142/14
April [11] 60/2 61/9
64/13 64/24 67/2 67/5)
71/1 71/14 79/9 81/15)
81/16
Arbuthnot [11] 25/8
26/1 28/5 28/21 31/23
87/7 124/16 141/4
164/7 165/9 165/21
ARC [17] 12/19 21/3
23/16 102/18 103/3
103/5 103/7 103/9
103/11 115/18 120/2
127/3 127/11 127/23
130/9 130/15 132/10
are [118] 2/2 5/16
5/22 6/19 6/19 8/15
12/12 12/21 13/2 14/8)
16/21 16/24 20/7
20/14 26/23 26/24
30/7 30/7 30/8 31/9
31/22 35/20 36/1 37/4
37/22 38/6 38/10
38/12 38/17 38/17
40/5 40/8 40/9 40/11
41/11 42/6 44/3 45/10
45/24 46/13 46/14
48/2 49/14 54/16
54/18 55/12 55/19
58/4 59/15 60/15
61/15 64/12 65/12
66/16 70/13 70/18
71/9 72/14 77/23
79/21 79/22 79/24
80/3 80/16 82/21
84/10 84/10 85/3
87/11 87/13 96/1 97/3)
98/23 100/15 101/15
111/10 111/12 112/6
117/24 118/1 118/1
121/3 124/9 127/8
128/7 128/22 130/24
1314/1 133/14 133/15
133/18 136/8 136/12
137/9 137/14 137/15
140/8 143/11 145/9
145/11 147/7 148/20
151/22 151/23 153/7
153/7 155/21 156/2
156/6 156/8 157/15
157/16 158/11 159/4
159/11 159/13 163/3
163/24
area [5] 67/18 122/11
122/12 146/14 146/15]
areas [7] 20/22 33/7
33/7 60/8 66/1 76/10
127/7
aren't [2] 109/9 118/1
arguably [2] 146/19
150/6
arguing [2] 115/21
141/19
argument [1] 117/25
arguments [2] 131/2
132/3
arisen [1] 157/8
arising [3] 7/19 87/5
87/13
army [3] 2/14 129/24
131/15
around [24] 16/6
20/3 20/9 31/1 40/13
40/14 40/17 46/7 65/7
70/23 74/1 92/3 94/25)
95/6 95/9 96/6 101/6
103/1 108/10 108/10
114/11 128/11 139/13}
148/6
arrange [1] 152/16
arranged [1] 108/11
arrogant [1] 162/2
articulate [2] 24/3
54/19
articulated [1] 83/1
articulating [1]
157/12
as [199]
ascertain [1] 96/11
aside [1] 150/14
ask [20] 1/19 2/7
2/19 3/16 8/10 18/24
60/15 83/23 85/21
86/13 86/15 101/18
101/21 115/22 123/6
129/16 153/10 157/23}
159/18 165/25
asked [28] 10/14
10/15 17/3 21/8 22/22
35/3 35/5 35/19 50/2
63/6 80/12 91/15
97/15 113/1 115/3
115/15 121/21 126/17!
126/25 127/9 142/1
142/4 143/12 143/14
148/23 149/18 155/20
165/23
asking [8] 19/6 63/1
63/20 69/17 111/18
138/19 148/12 149/19)
aspect [5] 6/24 7/22
111/23 112/16 133/24,
aspects [2] 105/21
147/1
Assertions [1] 75/11
assessed [1] 59/9
assessment [1]
56/14
ssimilating [1] 19/9
assist [10] 4/17 58/4
67/12 69/6 89/2 90/12,
102/11 104/1 113/2
144/7
assistance [2]
152/13 152/14
assisted [1] 149/25
assisting [1] 92/5
assume [3] 52/3
59/19 131/23
assumed [7] 75/16
79/6 120/9 120/19
123/16 123/19 123/22}
assumption [1]
22/17
assumptions [3]
72/12 75/3 75/9
assurance [31] 15/1
15/19 16/20 17/3
18/20 18/21 21/17
21/18 41/25 42/2 43/1
47/23 56/9 62/17 63/6)
63/15 63/17 64/23
65/20 67/22 68/13
74/24 76/10 76/13
76/15 76/22 77/1 77/2
77/15 94/11 106/2
assurances [3] 9/10
12/24 51/10
assure [3] 56/25
60/10 62/7
assured [3] 9/13
26/11 39/1
at [318]
ATMs [2] 29/13 43/12!
attached [3] 64/15
64/16 111/2
attachment [1] 64/19
attempts [1] 87/6
attend [1] 56/2
attendance [6] 20/15
32/16 51/18 56/1 60/4)
126/3
attending [1] 1/15
attention [3] 77/5
87/18 106/18
audit [60] 9/13 10/18
11/7 11/9 11/17 12/13}
12/14 12/19 13/6
13/12 13/17 13/18
13/19 14/9 16/7 18/3
18/3 18/6 18/10 18/13}
18/16 18/19 18/25
19/5 20/13 20/16
20/20 20/23 21/4
21/12 22/8 22/14
o
22/24 22/25 23/3 23/3
23/7 23/14 23/23 24/2I
29/10 67/24 68/10
68/16 68/19 68/22
69/1 69/4 69/14 70/1
71/19 74/24 77/22
78/6 79/17 84/7
100/13 103/11 125/25}
155/2
audited [2] 12/18
18/2
auditing [1] 13/22
auditor [1] 14/4
auditors [1] 12/17
audits [2] 18/11
21/17
August [6] 98/20
99/23 105/10 111/5
133/12 133/23
Aujard [13] 61/6
62/14 71/24 80/11
80/15 100/19 126/3
126/5 126/13 126/19
128/20 132/8 133/5
aunts [1] 164/14
authorised [1] 78/4
authority [1] 142/22
autumn [1] 137/19
available [6] 47/16
48/23 64/16 72/9 75/5)
109/23
avoid [1] 83/9
aware [43] 15/2 15/3
15/4 16/4 17/7 17/17
38/6 38/21 38/22
43/15 43/21 44/4 44/7)
44/9 44/14 62/24
80/24 94/22 94/24
95/12 97/20 103/21
106/3 106/5 106/8
106/25 109/9 115/19
119/15 119/17 119/18}
119/22 120/8 120/25
122/6 123/9 123/11
123/14 124/22 143/11
143/14 146/5 151/20
awareness [1]
124/23
away [9] 71/1 71/7
116/4 119/4 145/17
145/19 145/21 145/22)
165/14
awful [1] 6/2
back [45] 5/11 7/4
14/25 15/11 26/21
30/10 44/18 45/18
48/25 52/11 61/11
61/12 65/15 66/5
73/21 74/10 77/8
77/13 82/20 83/4
83/15 86/22 95/24
97/6 97/10 98/4 98/18)
(45) answered... - back
B
back... [18] 104/4
111/13 111/14 112/3
119/20 120/8 121/13
121/20 132/19 137/10
140/3 140/5 142/19
152/17 155/14 157/1
164/2 164/3
back-up [1] 15/11
backburner [1] 139/2
backed [3] 107/3
107/4 118/12
background [3] 2/9
64/7 109/19
bad [4] 54/15 116/5
118/9 119/3
badly [1] 4/25
bags [1] 135/14
balancing [2] 78/16
80/20
band [6] 27/1 27/2
51/19 51/20 51/24
52/2
bargain [2] 14/25
15/18
barred [1] 5/19
based [13] 19/15
27/7 30/1 30/2 48/10
48/14 56/12 72/8 73/5
75/3 81/2 87/6 164/23
based' [1] 68/2
basically [23] 5/10
5/17 6/14 11/14 15/8
27/18 31/9 45/22
52/17 54/6 61/23
69/10 69/13 69/17
73/10 73/23 104/16
106/18 115/21 118/4
141/5 147/23 164/20
basis [3] 46/6 67/5
85/23
Baskets [1] 77/22
Bates [4] 137/24
141/3 141/4 165/21
BBC [2] 135/21 136/2)
be [180]
became [6] 2/10 2/13
11/7 15/4 16/4 129/19}
because [60] 5/12
6/12 13/21 13/21
13/23 15/10 20/22
26/25 29/2 29/3 34/20
36/1 45/17 50/13
56/11 59/3 63/15
63/15 72/15 77/2
80/16 81/8 83/4 83/16
84/18 85/24 89/14
90/9 92/17 94/6 99/6
103/7 105/17 105/22
110/19 115/25 116/7
116/13 124/4 129/24
130/8 130/11 131/11
131/11 131/14 131/18}
131/19 136/11 138/11
145/9 148/17 150/19
156/1 162/9 163/7
164/5 165/11
become [6] 94/24
103/20 117/6 119/5
162/7 162/11
becomes [1] 12/25
been [162] 3/12 4/1
5/4 5/5 6/9 6/25 10/18)
10/18 10/19 10/21
10/22 11/18 15/12
15/15 15/17 15/18
17/10 18/2 18/20 19/3
19/5 21/5 22/3 22/4
22/17 23/14 25/10
29/13 29/18 31/24
33/16 37/18 37/18
38/21 38/25 39/11
39/12 41/5 41/8 42/20
42/24 43/11 44/11
46/5 47/14 49/19
49/23 50/2 50/11
52/11 56/19 56/22
57/5 59/8 59/17 64/14)
64/20 65/13 68/1 68/5
68/10 69/7 69/24 70/9
71/14 75/12 75/19
77/4 77/7 77/24 78/22
79/5 79/7 79/7 81/15
81/16 82/23 82/24
83/1 84/19 84/25 85/6
86/15 86/24 89/12
89/13 89/15 89/15
89/19 90/19 91/10
91/21 92/12 93/11
93/15 93/20 94/7 95/8)
97/15 98/4 98/11
98/13 99/14 101/2
101/22 102/3 102/9
103/1 103/6 103/8
103/14 104/13 104/14)
105/2 105/2 106/5
106/9 107/18 108/7
108/9 108/13 111/5
113/14 114/5 115/4
124/12 126/9 128/18
132/16 134/17 136/1
140/2 141/6 141/7
142/1 142/3 143/3
149/19 149/25 150/3
150/5 151/17 151/21
152/3 153/19 153/20
154/5 154/7 154/11
154/22 155/3 156/17
157/17 158/1 158/12
158/23 158/25 163/10)
164/13 164/14 164/15)
166/1
before [46] 3/3 5/3
7/23 8/15 9/25 10/11
10/11 16/7 25/21
35/17 43/24 44/1 45/5)
140/22 141/25 142/19)
48/19 61/14 61/22
63/13 64/13 70/14
76/22 79/8 85/22
86/24 88/8 88/12
89/16 91/18 92/25
93/7 93/14 93/19
94/10 101/18 103/13
104/5 110/10 110/13
110/15 112/5 121/21
122/5 122/11 128/7
129/15 149/13 158/13
beforehand [1] 142/2
beginning [2] 161/25
162/9
behalf [1] 157/24
behaviour [1] 83/11
behind [4] 29/23
64/23 66/20 160/8
being [62] 9/13 16/2
16/3 16/14 25/19 26/8}
26/16 27/21 31/12
33/3 34/4 35/16 39/16
40/3 44/19 49/9 50/15}
52/2 56/20 58/24
66/11 69/2 71/2 77/14
78/9 80/8 87/17 88/1
92/18 97/19 99/24
108/1 109/23 109/25
110/13 113/14 113/19]
114/3 115/24 116/3
116/9 118/8 118/21
126/25 131/23 135/12
135/13 135/23 141/16
143/18 143/19 144/13
146/17 147/8 147/9
149/10 151/7 154/20
158/3 162/14 163/24
166/7
belief [4] 2/3 29/9
52/18 80/25
believe [15] 16/9
18/12 18/12 18/14
19/25 32/1 34/12 51/8
94/5 97/24 108/5
133/6 134/6 157/20
163/18
believed [7] 12/25
33/10 40/16 40/17
49/3 99/6 99/19
believing [1] 111/20
Belinda [3] 116/16
116/25 117/10
bells [1] 79/12
below [5] 71/24
100/4 111/10 112/6
114/22
beneath [1] 1/21
benefit [4] 53/13
83/10 96/25 151/16
bespoke [1] 48/15
best [3] 2/2 49/4
60/10
better [24] 32/5
65/15 68/22 84/11
93/4 130/4 130/13
130/25 131/14 132/3
137/8 138/2 138/13
138/18 138/25 139/11
141/22 144/1 144/3
144/4 144/4 144/5
160/9 165/2
between [22] 2/14
2/22 4/9 19/3 19/7
36/16 44/7 74/12
80/19 80/21 80/24
95/5 102/13 102/18
123/25 125/18 128/12}
133/10 143/15 143/24}
161/9 161/16
beyond [2] 40/1
133/18
big [9] 40/5 61/20
61/21 117/6 124/6
124/12 124/21 124/22,
158/19
bigger [1] 150/24
bill [4] 30/12 46/13
52/12 62/4
ion [1] 47/1
inning [1] 141/22
BIS [1] 111/20
bit [11] 28/1 36/19
37/16 42/3 69/23
94/14 107/25 108/1
129/17 129/19 155/10
bitesized [1] 59/6
bits [2] 12/10 149/14
blame [1] 162/2
blamed [1] 36/22
blanket [2] 28/9
28/12
board [203]
Board's [2] 42/13
52/23
BoardPad [1] 64/16
Boards [2] 145/3
145/7
Bogerd [2] 53/21
53/24
bombard [1] 114/15
Bond [2] 115/9
118/18
bonus [1] 162/16
bore [1] 84/20
both [11] 54/6 84/1
84/3 86/13 94/8
114/22 117/20 126/2
145/13 157/19 158/7
bottom [20] 17/1
18/5 20/15 27/17
27/24 36/20 42/16
60/3 60/18 65/17
75/10 87/2 96/18
115/8 126/4 135/18
137/4 149/7 159/25
160/2
bottom-up [1] 27/17
bought [1] 126/6
boys [1] 158/16
branch [11] 14/11
17/18 21/19 22/2 22/6)
22/14 37/14 78/15
78/25 117/17 126/18
branches [8] 37/3
37/5 38/7 39/6 156/9
156/11 156/12 159/13
break [9] 41/11 41/19
58/23 85/24 86/7
121/7 121/15 152/2
152/21
breakfast [2] 90/5
98/10
Brian [7] 96/14
105/25 106/13 106/17I
106/19 106/25 120/4
brief [3] 90/10 109/19)
111/9
briefed [1] 90/5
briefing [11] 35/12
60/13 60/24 61/7 70/5I
72/4 72/5 72/11 72/13}
114/16 138/23
briefings [1] 157/3
briefly [6] 2/8 125/22
133/8 142/24 147/2
153/11
bright [1] 29/12
bring [25] 7/4 11/25
14/17 25/20 60/16
61/11 66/22 86/20
88/21 100/23 103/18
109/15 119/20 120/7
120/18 127/20 127/21
127/22 128/4 129/5
132/19 137/13 140/11
143/2 147/5
bringing [6] 119/18
120/1 120/11 126/15
130/21 132/8
broad [3] 47/20
119/15 149/22
broadcast [1] 136/1
broaden [1] 41/8
broadened [1] 69/23
broadening [1] 40/22)
broader [1] 44/14
broadly [2] 48/9
164/22
brought [9] 17/4 77/4
82/4 82/20 83/4 83/14)
106/18 138/21 161/14I
bubble [1] 125/4
bubbled [2] 125/1
125/2
bug [1] 44/23
bugs [31] 36/2 37/19
38/11 38/16 38/19
39/6 39/10 39/24
40/11 41/5 42/25
153/11 153/14 154/6
154/7 154/11 154/17
156/2 156/6 157/6
(46) back... - bugs
B
bugs... [11] 157/13
157/16 157/17 157/20)
158/8 158/9 158/15
158/22 159/4 159/12
159/13
bugs/flaws [1] 36/2
building [1] 98/23
bullet [8] 12/11 53/19
54/25 55/8 55/9 75/6
94/15 161/6
business [39] 2/13
5/1 5/12 19/14 20/22
25/4 25/9 26/2 30/25
32/10 33/22 35/3 35/5
36/4 39/1 52/8 54/4
54/5 54/8 54/20 54/24
66/1 77/6 91/14 93/2
104/9 111/20 112/12
115/5 116/1 116/8
118/10 125/15 126/17)
126/20 128/3 131/4
146/25 149/1
busy [2] 125/1
150/14
but [237]
Cc
call [15] 33/17 34/11
34/12 34/13 34/15
34/17 34/20 35/12
36/9 39/18 40/10
108/8 108/11 159/20
162/6
Callard [1] 145/5
Callard's [2] 143/16
145/16
called [5] 2/14 49/7
54/6 56/21 125/9
calling [1] 84/18
calls [1] 49/17
came [28] 11/4 13/7
19/9 23/5 26/20 30/9
36/14 42/9 43/6 54/2
61/23 71/1 71/7 81/18
84/2 88/15 102/16
103/5 105/25 110/21
120/2 122/7 127/11
135/7 135/9 144/8
150/25 165/4
can [117] 1/5 1/19
2/19 8/1 8/20 9/11
10/4 12/2 14/4 14/22
16/18 16/19 20/1
20/10 20/14 20/15
20/18 20/18 24/23
25/18 25/20 25/22
27/23 32/14 32/16
36/14 41/21 42/10
45/6 45/12 45/18 48/4
51/1 51/3 53/10 53/23)
57/2 57/22 60/2 60/5
60/15 65/17 66/18
66/25 69/6 69/7 72/18
73/23 78/24 81/8
82/14 84/15 86/9
86/20 87/2 87/14 88/4
90/22 91/3 93/18 94/9
94/14 95/19 95/20
96/17 96/17 96/19
98/15 98/19 100/11
100/12 100/12 102/11
104/1 107/16 109/2
110/13 110/14 113/4
114/11 118/23 121/10)
121/13 121/17 121/18)
125/23 126/12 128/17)
131/21 132/19 132/19)
133/9 133/12 135/17
137/1 138/17 139/16
140/5 142/16 143/2
146/16 147/5 148/22
149/2 149/6 149/21
152/8 152/10 152/24
152/25 155/10 159/25)
160/23 161/6 164/11
165/2 166/12
can't [14] 14/1 22/8
22/12 22/21 67/12
80/7 89/2 90/15 92/2
101/11 112/22 143/20)
144/7 159/23
cannot [46] 3/8 8/14
8/16 20/4 20/11 21/21
22/5 22/5 25/6 30/18
34/11 36/9 57/4 57/10
67/15 74/15 74/16
78/18 78/22 82/23
83/13 83/14 88/22
89/4 90/4 90/4 90/10
90/12 90/21 98/1 98/4
98/10 101/1 101/25
101/25 102/20 103/24)
107/20 112/20 112/24)
114/9 124/2 128/14
133/24 137/3 144/17
cap [1] 133/17
capability [2] 27/22
128/24
capacity [1] 27/22
capture [3] 8/1 15/22
20/8
captured [1] 16/2
capturing [1] 68/6
career [2] 88/24
126/9
carefully [1] 140/16
carried [1] 115/3
carry [4] 7/9 41/24
98/17 98/19
carrying [1] 92/25
Cartwright [5] 96/10
96/16 106/4 106/5
106/10
case [20] 14/1 29/18
35/10 44/17 97/3 97/6
99/4 108/7 108/18
110/22 122/19 122/25}
123/17 134/10 139/7
141/15 142/17 145/20
158/3 159/16
cases [45] 15/23
26/4 26/5 27/10 28/14
29/7 29/22 30/9 30/10)
31/17 33/13 33/16
33/18 33/25 37/20
38/17 43/20 43/22
44/2 46/17 49/2 50/3
56/20 87/14 92/6 92/7
100/23 100/25 101/2
128/5 133/15 133/18
134/3 134/11 137/20
137/21 137/22 141/5
141/7 141/9 141/12
141/23 142/4 142/10
157/13
casting [1] 141/18
catch [1] 147/25
caught [1] 110/21
cause [5] 27/18 29/8
29/25 36/21 36/24
caused [7] 29/14
29/18 37/13 40/2
44/11 78/17 157/18
caveated [1] 72/10
CCRC [1] 108/16
Ceasing [1] 129/3
CEDR [2] 139/8
142/21
cent [7] 8/4 25/12
84/5 92/5 92/6 92/6
102/9
central [1] 79/16
centrally [1] 78/14
centre [6] 21/24
23/11 40/10 60/11
62/8 66/2
centres [1] 15/11
CEO [10] 2/13 31/3
31/10 32/11 33/20
34/24 35/8 84/8 91/9
128/2
certain [3] 67/25 68/7
68/21
certainly [13] 8/14
15/16 87/7 97/24
102/8 106/11 123/11
123/17 127/5 132/15
141/4 146/2 161/22
cetera [1] 40/10
CFO [3] 9/14 10/5
31/3
chain [3] 1141/4
129/15 147/20
chair [9] 2/21 108/41
110/19 110/23 122/13
122/13 122/16 127/3
164/20
chairman [8] 21/8
26/17 57/13 84/7 84/7
115/18 160/4 160/12
challenge [4] 19/19
35/3 128/3 150/23
challenge/question
[1] 19/19
challenges [2] 38/22
111/19
challenging [9] 7/9
18/1 20/21 27/20
62/15 91/10 150/13
150/17 150/18
Chambers [1] 51/12
championing [1]
26/5
change [12] 20/23
79/14 79/15 80/25
81/1 109/20 117/1
117/21 142/22 156/22}
162/15 165/19
changed [5] 71/15
108/5 117/8 146/1
146/2
changes [2] 21/14
35/4
changing [1] 127/15
channel [1] 161/8
characteristics [2]
68/24 69/1
check [1] 59/23
Chesterfield [4]
21/23 23/10 23/10
23/11
chicken [1] 47/3
Chief [1] 9/15
Chinese [1] 143/24
choice [3] 97/11
97/13 97/18
chose [1] 128/5
Chris [22] 9/14 10/5
31/4 61/5 62/14 71/24,
73/8 73/9 80/11 80/15)
81/19 100/19 126/2
126/5 126/13 126/19
128/20 129/16 129/18}
130/7 132/7 133/4
Christa [4] 51/19
51/23 51/24 52/2
chronology [6] 28/1
42/2 60/1 86/22 92/18
147/13
chunk [1] 59/6
CIO [1] 59/14
Circle [2] 83/17
83/18
circulate [1] 18/9
circumspect [1]
128/5
circumstance [1]
107/21
circumstances [3]
6/10 39/6 123/4
civil [9] 87/23 126/18
130/1 130/4 130/8
130/9 130/11 130/12
130/24
claim [3] 17/12 45/13
49/17
claimed [1] 79/6
claims [10] 10/16
10/17 16/3 17/4 17/8
19/12 48/22 58/8
91/14 155/4
clarified [3] 133/2
143/8 144/6
clarify [5] 8/1 59/18
80/12 95/16 96/1
Clarke [6] 86/13
93/20 93/20 99/15
104/15 105/4
Clarke's [3] 94/1
103/21 107/17
clean [2] 30/12 62/4
clear [34] 11/1 11/10
12/21 12/25 18/6
19/18 23/19 24/20
29/9 39/9 44/6 55/11
65/5 68/4 71/6 73/7
74/11 76/9 84/1 84/3
85/20 87/9 89/6 92/17
99/22 103/20 104/16
130/5 132/5 133/14
134/24 154/1 154/20
155/2
clearly [21] 18/14
35/14 39/22 59/12
60/25 66/16 74/20
99/13 105/5 105/11
105/15 117/7 118/8
124/22 135/22 137/23)
138/11 146/20 157/12!
157/15 165/18
clients [1] 157/24
clinic [1] 8/24
Clinics [3] 8/6 8/20
8/25
closely [1] 135/5
closer [1] 2/19
closure [1] 140/15
clumsy [2] 108/2
113/20
clunky [5] 6/1 6/17
9/17 9/24 40/19
Co [2] 153/9 165/25
code [17] 27/7 27/18
28/14 28/24 29/3 29/3I
29/5 30/1 30/2 33/10
40/13 40/24 43/9 48/5)
48/10 48/14 76/19
code-based [2] 27/7
48/10
coffee [5] 147/24
148/1 148/5 148/5
148/9
collaborative [1]
164/22
collaboratively [2]
160/16 163/14
collated [1] 77/15
colleagues [5] 143/9
(47) bugs... - colleagues
Cc
colleagues... [4]
143/13 144/9 150/8
150/9
collecting [1] 142/17
collective [1] 85/12
combat [1] 35/6
combative [1] 150/13
combination [1]
66/14
come [48] 13/2 13/10
16/18 18/20 23/12
24/22 29/8 30/2 35/17,
35/18 39/21 43/10
59/14 61/5 61/19
65/15 66/18 66/20
88/4 90/7 93/18 95/15)
95/20 98/18 99/16
100/12 102/22 107/22
110/7 110/13 113/24
114/1 116/15 117/10
118/23 121/12 123/2
125/15 128/16 131/21
134/23 137/12 149/21
152/17 159/1 159/4
160/22 165/9
comes [3] 83/20 95/3
109/21
comfort [8] 26/4 52/8
52/10 53/7 154/19
154/23 155/1 155/6
comfortable [1] 21/3
coming [9] 35/25
43/16 61/20 77/13
110/18 130/22 132/14}
144/11 155/25
commence [1] 57/21
comment [4] 14/12
19/13 21/22 51/3
commented [2]
53/16 75/7
comments [4] 65/10
66/6 111/21 114/22
commerciality [1]
146/25
commission [4] 52/5
53/4 83/19 138/25
commissioned [9]
12/15 15/17 19/4 21/6
50/24 81/14 83/20
96/9 116/25
commitment [3] 3/6
4/5 8/21
committed [1]
133/14
committee [19] 11/8
13/18 16/8 21/13 84/7I
126/5 126/17 126/23
127/14 128/2 151/10
151/11 160/1 160/3
160/23 164/2 164/3
164/9 165/7
common [2] 30/8
140/18
communicated [2]
39/16 39/23
communication [6]
35/6 35/22 155/22
161/18 162/18 162/19)
communications [2]
147/4 161/8
communities [1]
161/2
community [1]
161/18
companies [6] 8/5
8/12 8/15 8/17 8/22
123/18
company [11] 85/1
107/2 107/15 120/11
120/20 121/23 122/24)
160/8 160/16 162/7
163/15
company's [1]
105/17
comparable [1] 66/7
comparison [1] 74/8
compensation [3]
42/7 46/10 46/20
competent [2] 26/10
26/12
complaints [2] 7/1
146/12
complement [1] 52/6
complete [3] 68/7
73/20 77/23
completely [1] 28/5
compliance [5] 12/19
20/13 100/14 103/12
125/25
complimentary [1]
24/1
comprehensive [1]
26/10
compromised [1]
14/13
computer [2] 33/6
33/21
concentrated [1]
22/10
concept [3] 89/14
89/17 120/11
concern [9] 39/4
TAIT 78/17 78/19
89/19 134/8 135/11
146/14 146/15
concerned [16] 26/4
34/24 52/7 63/10 78/9)
78/19 78/22 91/13
100/23 105/11 105/12)
105/13 105/14 105/17)
105/19 105/20
concerning [2] 24/24
42/25
concerns [6] 36/7
78/20 117/16 118/24
146/8 146/10
conclusion [3] 37/22
37/24 47/15
condense [1] 70/16
condensed [1] 73/12
conditions [1]
162/10
conduct [4] 121/22
123/24 124/20 146/5
conducted [5] 44/25
105/10 121/3 122/3
123/23
conducting [2] 42/6
106/6
conference [1] 34/15
confident [2] 156/14
156/15
confidential [2]
43/21 110/6
confirm [2] 24/9 52/1
confirms [1] 3/13
conflict [4] 125/18
128/17 143/21 144/22
congratulating [1]
140/21
conscious [1] 97/14
consequence [1]
13/8
consequent [1]
96/14
consequential [3]
45/13 46/15 51/10
consider [8] 55/22
56/14 82/14 82/17
82/18 87/12 90/17
158/3
considerate [1]
81/20
Consideration [2]
67/17 67/19
considered [12]
81/17 81/21 81/25
82/3 82/25 83/13 84/4
84/19 85/4 92/22
128/21 151/7
considering [3] 4/20
63/21 82/16
considers [1] 82/15
consistent [3] 44/20
66/10 145/6
consistently [2] 12/3
108/17
constitute [2] 68/12
74124
constrained [1] 9/7
construct [1] 14/5
Consumer [1] 47/13
contact [3] 165/6
165/11 165/20
contemplate [1]
133/21
content [4] 67/1
90/10 98/11 136/12
contents [1] 93/25
context [8] 20/2 42/5
72/14 101/14 104/10
111/10 112/6 115/2
continue [6] 109/4
121/20 130/23 134/13
137/17 137/18
continuing [1]
128/24
control [10] 30/16
30/17 31/2 31/8 31/10
31/20 32/11 60/8
65/21 93/4
controls [21] 11/12
11/13 11/15 11/23
11/24 13/23 23/21
23/22 24/1 24/2 24/3
60/11 62/7 65/22
65/23 65/25 70/23
73/24 78/2 79/19
79/22
conversation [51]
3/23 14/16 16/10 19/2,
20/8 20/9 22/13 24/23)
25/7 25/11 25/15
33/18 36/10 55/15
69/5 83/9 88/17 88/20)
89/11 89/13 90/11
95/5 95/9 97/17 97/25
98/1 98/3 98/7 99/7
103/3 111/15 112/20
112/25 113/3 113/5
113/9 113/10 114/10
114/20 132/7 133/7
139/5 144/14 145/1
148/17 148/22 149/4
154/11 154/13 154/13
163/23
conversations [4]
59/2 97/20 100/2
134/23
conversed [1] 34/11
convicted [1] 86/15
conviction [5] 142/5
142/10 142/15 142/21
142/23
convictions [2] 86/18)
94/19
COO [1] 9/14
coordinate [1]
111/12
copied [2] 11/19
96/23
copy [1] 135/22
core [4] 79/11 107/9
151/23 153/7
correct [24] 2/24 3/2
14/21 17/14 17/20
22/24 24/13 24/18
36/17 36/18 38/8
50/12 54/9 56/3 60/12,
63/4 82/6 82/12 94/8
106/21 109/10 109/11
153/17 159/17
corrections [2] 80/16)
80/19
corridor [2] 113/19
114/4
corroboration [2]
75/13 75/25
cost [16] 11/21 13/20
15/12 31/2 32/9 46/25)
63/8 93/4 101/7
101/16 129/23 129/25)
132/9 132/17 132/25
133/4
costing [1] 130/2
costs [2] 124/25
132/8
could [58] 1/11 7/23
11/25 16/25 17/17
20/12 27/23 35/1 44/6
44/21 45/18 47/10
48/4 49/16 55/18
55/24 56/18 60/16
60/17 61/11 63/6 64/5
64/10 64/10 64/19
66/22 67/16 67/20
71/20 72/3 73/4 74/19I
76/20 91/7 91/8 94/6
94/12 95/10 97/8
100/20 103/1 109/15
1411/7 117/21 128/20
128/21 129/16 134/6
135/17 136/6 136/6
138/14 143/4 147/6
159/19 160/20 161/21
161/23
couldn't [4] 24/20
101/9 101/19 101/23
Council [2] 153/13
161/6
counsel [14] 11/1
19/23 84/9 91/15
106/4 107/2 107/5
108/3 110/19 110/24
118/12 153/25 154/20)
159/24
counts [1] 94/8
couple [2] 44/1
111/19
coupled [3] 105/5
124/23 157/3
course [7] 3/19 50/16)
79/5 152/9 159/15
166/7 166/15
court [3] 94/18
142/15 142/20
Courts [1] 126/18
cover [7] 62/12 88/19)
88/19 92/25 109/6
111/21 165/13
cover-up [1] 111/21
CPS [8] 120/10
120/17 127/21 130/24)
131/5 131/6 131/16
131/17
creaky [5] 5/6 5/15
5/18 6/11 6/19
create [7] 8/7 8/20
(48) colleagues... - create
Cc
create... [5] 8/23
11/19 13/13 78/25
160/13
created [2] 84/25
92/19
Crichton [28] 10/9
10/14 11/2 17/25 18/6
25/5 26/12 89/22
90/14 90/18 90/25
91/15 96/8 97/22
98/20 99/4 99/25
109/7 109/10 111/4
118/18 119/2 122/11
133/11 153/16 153/18
154/2 154/14
Crichton's [2] 12/24
118/25
Crichton/Paula [1]
111/4
criminal [22] 19/14
87/23 99/4 106/11
117/15 117/18 117/20
121/22 125/9 125/11
125/16 129/20 129/22)
130/4 130/9 130/13
130/25 131/15 142/4
142/15 142/20 142/22)
crisis [1] 47/4
critical [1] 97/9
criticise [1] 60/13
c m [1] 146/23
criticisms [1] 51/21
Crowe [2] 116/16
116/25
cultural [3] 54/10
54/15 54/16
culture [8] 124/25
160/10 161/24 162/3
162/4 162/15 162/25
164/16
cup [1] 148/1
curious [2] 150/10
150/12
current [3] 68/6
139/12 139/12
currently [2] 72/9
124/9
cursor [1] 164/11
customer [2] 15/7
162/2
customers [5] 15/8
160/9 160/15 161/2
162/23
cut [2] 5/21 164/15
D
daft [2] 113/19 138/9
damaging [3] 136/7
136/9 136/23
dark [1] 5/19
data [25] 10/1 10/2
10/21 10/24 11/11
11/22 14/13 15/4
15/11 15/11 15/22
16/2 16/12 21/19
23/11 23/21 39/1
52/25 54/25 58/12
59/3 68/21 68/22 78/5)
153/19
database [1] 79/16
date [14] 33/5 43/24
60/7 60/14 82/12
97/12 97/13 97/19
98/5 99/1 99/6 99/12
99/19 132/18
dates [2] 8/14 8/16
Davies [3] 135/19
135/25 139/20
day [22] 9/14 10/6
20/6 49/24 49/24
61/22 64/13 66/15
93/19 136/4 138/5
139/19 139/20 145/10)
145/18 145/19 145/21
145/23 162/7 166/7
166/9 166/19
days [13] 3/10 3/11
3/12 3/21 4/6 4/7 4/7
4/10 4/12 8/23 8/25
9/1 16/14
deal [2] 116/17 147/2
dealing [7] 38/21
48/22 88/25 97/3
114/19 125/13 150/15)
dealt [3] 33/23 130/9
161/21
debate [2] 132/1
132/7
debating [1] 163/1
decided [1] 53/4
decision [12] 24/11
47/20 83/19 90/13
90/17 90/25 103/4
127/1 140/24 140/25
141/25 142/7
decisions [1] 126/9
decline [1] 5/2
dedicate [1] 9/2
defect [1] 37/8
defects [4] 36/21
37/13 38/6 156/8
defence [2] 100/25
101/3
defend [1] 94/23
defensive [1] 162/3
deferred [1] 9/18
definite [1] 158/11
definitely [4] 30/16
TAN 77/3 154/25
definition [3] 40/22
41/7 4119
degree [1] 26/18
delayed [1] 1/3
delete [4] 17/19
deleting [1] 78/5
deliberately [1] 103/4I
Deloitte [38] 10/20
12/14 13/12 18/10
18/13 48/9 50/23 51/7
51/15 57/8 60/3 60/20
60/25 62/3 62/17 63/1
64/3 64/22 69/17
69/20 69/21 69/25
70/6 70/8 71/3 72/11
72/18 73/9 74/22
75/15 79/5 82/5 83/20
83/20 84/14 138/23
139/1 155/4
Deloittes [1] 18/3
delve [1] 83/5
den [2] 53/21 53/24
department [3]
111/20 123/15 143/19}
depending [1] 56/24
describe [2] 49/8
54/19
described [6] 18/20
53/15 68/19 71/13
73/5 75/18
describes [3] 47/17
47/24 48/15
describing [2] 48/18
157/11
description [4] 4/14
49/23 57/15 68/3
design [1] 77/11
designed [2] 78/3
162/21
desire [1] 135/16
desktop [7] 56/12
58/19 72/8 75/3 76/16
76/25 81/2
desktop-based [1]
75/3
desperately [1]
145/24
detail [7] 7/22 20/2
74/21 82/18 82/25
118/7 149/23
detailed [6] 1/14
18/25 23/4 81/13
127/10 134/10
details [1] 112/24
deterioration [1]
30/24
determinant [1]
52/17
determine [2] 30/7
85/1
determining [1] 97/9
deterrence [2] 127/7
127/12
deterrent [6] 127/16
127/17 127/19 129/14
130/14 130/16
develop [1] 6/3
developed [1] 162/17
developing [2] 5/13
6/25
development [1]
4I17
diary [1] 98/23
Dickinson [2] 115/9
118/19
did [124] 3/3 3/15
3/20 4/3 6/10 8/11 9/2,
13/9 13/10 14/9 16/5
16/9 16/13 18/10
18/18 18/24 19/1 20/2
20/4 21/10 21/18 25/2,
29/1 30/3 33/9 34/1
36/5 36/7 36/11 36/21
39/4 39/9 39/13 39/14)
39/23 39/24 42/14
46/19 48/16 48/21
49/8 50/18 50/22 52/9)
53/15 54/11 55/4 57/4)
57/8 57/11 57/20
58/19 65/3 66/13
70/22 72/24 73/1 73/2
73/4 TAIT 74/14 74/17,
74/24 76/6 79/18 80/9)
80/18 81/2 83/8 83/9
83/12 87/20 87/24
88/16 90/8 90/25 91/2,
91/24 92/8 93/8 94/21
94/24 95/17 97/21
97/24 99/3 101/10
101/18 101/21 102/17
113/6 117/1 117/10
118/24 120/21 123/7
123/11 124/2 125/17
125/21 127/4 129/11
132/4 132/7 133/22
134/18 134/25 137/5
137/18 138/15 140/17
143/17 145/21 145/22)
146/5 146/11 147/12
148/15 150/17 151/9
151/10 151/11 151/14}
164/6
didn't [55] 5/7 8/18
14/19 18/12 18/14
19/21 19/22 53/1 56/2)
65/5 71/4 71/5 71/5
71/6 76/2 80/2 83/5
83/23 87/22 87/23
87/24 90/7 99/11
102/3 102/15 103/4
103/6 103/9 106/12
109/13 110/10 116/15)
117/7 119/2 119/3
120/12 125/4 134/6
134/7 134/11 135/14
136/25 139/9 139/14
144/8 146/20 146/21
148/15 151/4 159/3
159/7 159/14 162/1
165/18 165/22
difference [6] 52/12
80/19 80/21 80/24
131/19 143/15
differences [1] 135/1
different [22] 29/4
34/16 39/20 41/11
63/7 85/24 86/11
98/13 98/16 99/16
103/10 105/7 105/14
105/21 107/6 118/2
118/9 134/4 145/10
158/2 158/6 163/1
differently [2] 104/18
116/11
difficult [8] 25/3 48/8
59/3 59/6 63/14 83/9
145/9 150/15
difficulties [2] 29/20
66/21
digitally [1] 78/5
dingy [1] 5/20
dip [1] 31/16
direct [3] 165/6
165/10 165/20
direction [1] 4/21
director [29] 2/10 3/1
3/7 3/14 3/20 4/11
4/15 8/10 8/11 8/22
9/4 10/13 10/25 16/15}
16/25 19/24 30/23
58/4 104/3 107/14
107/15 123/25 143/1
143/20 144/13 145/12)
145/20 150/1 153/22
Directors [5] 16/23
57/9 90/3 122/8
122/15
disagree [1] 47/7
discharged [1]
141/11
disclose [2] 96/13
104/20
disclosed [7] 37/1
42/23 46/8 96/12
104/12 108/7 117/23
disclosing [1] 104/22)
disclosure [4] 86/14
94/2 117/12 117/15
disconnect [2] 74/12
7415
disconnected [1]
93/16
discovered [2] 34/10
37/2
discredited [5] 94/7
99/14 102/4 102/9
104/14
discrepancies [1]
44/11
discrete [2] 109/5
142/24
discuss [12] 3/21
36/5 36/7 57/8 85/14
95/17 97/21 98/22
99/10 99/18 133/22
161/1
discussed [20] 9/25
10/6 10/9 51/2 55/13
69/2 71/14 81/5 81/6
(49) create... - discussed
D
discussed... [11]
81/10 81/11 82/19
84/21 86/23 89/3 93/6
98/7 99/23 107/18
148/10
discussing [7] 10/10
57/10 111/23 112/16
114/19 133/3 133/24
discussion [33]
11/16 12/19 22/3 22/6)
24/15 27/19 46/12
48/3 48/4 55/9 57/17
57/19 67/2 67/5 67/10
67/14 82/21 84/23
88/10 89/8 95/22 97/5
97/11 102/23 109/18
110/1 110/8 111/9
138/24 139/3 139/4
153/15 154/24
discussions [3]
36/24 52/15 98/13
disengage [1] 140/17I
disoriented [1] 96/20
disparate [1] 59/4
dissatisfied [1]
115/17
distribution [3] 64/12)
71/22 135/20
distrustful [1] 40/2
dive [1] 163/8
diverge [1] 145/13
do [152] 1/16 1/18
1/20 4/22 4/24 7/23
11/17 14/2 14/6 20/8
20/10 25/9 26/7 26/22
26/24 26/24 26/25
27/2 27/6 27/7 27/9
27/22 29/5 30/17
31/13 31/15 31/16
32/18 35/7 35/9 38/23
40/1 46/18 47/18 48/5
48/6 48/8 48/9 49/4
49/10 50/3 50/14
55/14 55/20 59/15
60/12 60/19 60/20
61/14 61/17 61/20
64/25 64/25 66/12
66/17 67/6 67/9 68/12
69/2 69/5 70/4 71/13
73/21 74/12 74/14
76/18 76/20 78/16
78/19 80/4 80/17
80/21 83/1 84/9 87/16
87/17 88/10 90/16
90/19 94/5 95/6 96/10
97/11 97/13 97/15
98/7 99/18 103/13
103/23 104/7 105/8
105/23 106/22 110/4
110/7 110/12 111/23
112/1 112/15 112/16
113/8 113/11 113/16
115/12 115/25 116/8
116/9 118/4 118/5
118/10 121/5 123/23
124/3 127/25 128/8
128/16 129/23 130/23}
131/7 131/8 131/14
131/15 132/12 133/3
133/20 134/10 135/3
135/11 135/16 139/41
141/14 142/1 142/7
142/9 143/14 144/14
144/16 144/25 145/21
145/22 146/22 147/9
147/18 148/10 149/25)
156/21 161/20 163/5
163/20 164/16 165/1
165/5
document [30] 17/1
18/19 23/4 23/5 23/5
41/4 54/20 57/2 61/23
64/21 66/23 70/6 77/9
77/15 78/20 81/24
93/18 95/14 95/15
95/16 95/20 101/8
110/13 112/8 116/16
118/23 128/19 129/18)
131/21 160/20
documentation [18]
11/13 11/14 11/18
11/20 11/23 14/4
23/22 24/2 27/8 68/3
68/5 68/20 75/8 76/14
76/16 77/1 77/3 77/12
documented [4]
73/24 78/2 79/19
79/22
documents [8] 11/10
75/15 75/19 75/21
93/21 109/13 118/1
137/3
does [18] 4/9 7/8
7/15 8/1 8/4 15/22
16/11 45/19 48/5
48/14 51/6 54/14 66/6
77/1 82/16 87/10
122/13 127/7
doesn't [9] 34/6
46/17 48/13 55/19
82/15 92/10 159/4
164/10 166/13
doing [31] 7/8 10/10
13/22 21/1 30/1 31/19
35/11 46/5 49/4 50/6
51/13 52/21 76/13
82/22 83/11 93/17
105/15 105/20 106/11
108/7 113/17 113/23
115/22 119/4 121/1
130/18 131/20 139/12)
139/14 139/14 165/20}
don't [81] 4/4 4/13
4/23 5/25 7/4 16/7
16/8 18/12 18/12
18/14 22/11 24/6 26/6
33/15 33/17 34/14
36/2 46/16 46/16
48/11 48/20 51/12
51/20 54/13 55/7 55/7
55/9 55/11 58/21
59/25 65/2 65/2 65/16
70/3 70/7 71/15 73/14
77/18 80/23 87/1
88/14 88/14 95/8
97/19 97/24 100/17
103/11 103/18 106/9
107/8 107/9 108/14
108/15 109/8 116/1
118/6 119/9 119/21
124/21 128/11 129/5
130/17 132/14 133/6
134/22 135/5 135/10
140/11 141/23 141/24
146/16 148/14 148/21
149/3 150/11 150/21
151/13 158/5 163/21
163/22 165/1
Donald [1] 111/20
done [20] 10/18 22/7
23/3 23/14 28/20
49/20 54/21 67/20
69/11 71/2 71/18
81/14 104/1 115/18
117/4 120/5 130/24
140/20 140/22 164/14
door [1] 89/25
double [3] 3/25 9/6
59/23
doubled [1] 46/19
doubt [3] 35/9 57/18
65/2
doubted [1] 135/15
doubts [1] 49/15
down [48] 12/1 14/22
15/20 16/18 20/19
28/4 28/19 29/11
32/17 36/19 37/24
48/22 51/18 52/1 56/8
58/23 60/3 60/5 61/13)
62/12 64/11 66/18
66/24 68/15 70/16
78/1 88/4 92/25 93/18
94/14 94/16 95/20
96/19 96/24 100/12
110/13 111/14 112/10
114/20 118/23 126/2
128/21 131/21 133/12
135/21 139/25 149/21
159/25
downsized [1] 117/8
draft [7] 64/15 64/24
65/11 66/20 67/1 80/7
153/17
drafted [1] 65/5
drafting [1] 24/16
draw [1] 110/24
drawn [1] 87/18
drive [1] 31/10
driven [2] 15/17
68/13
drop [1] 83/23
dropped [3] 15/8
35/21 155/21
drove [1] 14/24
due [9] 33/4 50/16
50/16 51/10 81/6
81/10 81/10 81/21
115/18
dull [1] 117/9
dumped [1] 34/17
during [7] 4/10 6/2
8/11 14/16 39/4
119/10 166/7
E
each [8] 8/21 23/4
29/25 36/11 36/12
129/25 133/11 134/10
earlier [19] 9/5 19/17
21/5 28/3 42/23 70/25)
72/1 77/14 78/9 86/24,
97/1 101/8 101/10
101/11 114/12 120/4
132/11 133/10 147/22}
early [5] 16/14 41/12
144/14 147/15 154/8
easier [1] 126/16
easy [7] 6/18 6/22
40/18 73/13 76/9 80/4)
80/17
EBITDAS [1] 46/24
edit [1] 17/18
Edwards [2] 98/16
100/7
effect [5] 7/15 21/15
45/16 84/22 101/1
effective [1] 139/10
effectively [14] 4/20
12/9 14/7 30/12 30/23
56/12 62/5 62/10 63/9
106/1 125/10 139/18
140/17 156/3
effort [1] 28/7
egregious [1] 129/2
eight [3] 4/10 20/7
159/25
either [16] 4/7 9/18
12/4 17/18 30/3 55/22}
70/5 79/16 83/2 88/10)
91/18 97/21 103/15
108/9 130/5 134/7
elaborate [1] 97/8
else [7] 3/20 55/20
102/5 102/7 105/24
162/1 165/24
elsewhere [2] 94/4
163/7
email [45] 27/25
30/15 31/6 46/8 46/11
61/5 64/11 71/21 73/7,
73/8 73/9 73/10 74/2
74/4 74/8 74/12 78/20
81/18 84/2 86/20
88/12 96/22 97/21
97/23 98/16 98/17
99/22 100/4 109/16
110/16 114/11 114/12)
114/13 115/7 115/20
118/4 133/10 133/13
135/18 135/24 135/24)
139/16 139/25 149/7
149/10
emailed [3] 129/18
133/11 139/21
emails [9] 97/14
98/20 111/1 114/15
115/10 116/21 128/12)
128/15 129/15
embrace [1] 65/22
emerged [1] 87/9
Emerging [1] 64/24
emphasis [1] 22/4
employed [1] 129/24
employees [1]
160/14
Employment [1]
47/12
enable [1] 160/8
encouraging [4] 31/7
31/19 31/22 130/7
end [9] 5/23 6/3 26/1
56/13 111/9 133/19
134/21 145/10 146/4
ended [2] 131/25
141/16
ending [1] 138/22
energy [3] 141/21
146/19 165/1
engage [1] 162/15
engagement [4]
74/25 160/10 162/17
162/18
enough [6] 26/24
26/25 146/20 146/22
150/10 150/24
ensure [5] 21/25
33/23 35/4 84/21
85/14
ensuring [3] 7/12
7/15 85/11
entail [1] 96/5
entered [1] 142/11
entitled [1] 45/12
environment [5]
56/15 65/24 114/2
150/17 150/18
Ernst [6] 9/13 11/8
12/17 14/9 20/16
20/17
errors [1] 68/25
essence [1] 157/23
establish [1] 126/16
established [3] 1117/5)
160/6 160/12
estate [1] 29/4
et [1] 40/10
et cetera [1] 40/10
(50) discussed... - et cetera
E
etc [2] 97/8 136/7
even [12] 10/11
11/12 51/6 79/13
83/24 102/11 107/17
119/2 142/21 146/21
156/24 159/3
evening [2] 114/13
148/7
events [2] 67/25 68/7
ever [5] 18/10 81/9
106/9 123/21 164/6
every [6] 19/14 31/6
38/18 97/8 144/19
144/22
everybody [1] 130/15]
everyone [2] 137/23
162/1
everyone's [1] 83/23
everything [6] 5/17
31/2 52/1 112/23
152/4 156/7
evidence [51] 1/15
2/5 12/9 12/22 13/12
14/14 14/15 15/25
17/7 17/12 17/16
19/15 19/17 24/19
28/13 36/15 38/3
42/17 45/15 46/1 46/3
47/13 51/14 62/1 67/3)
71/1 80/12 83/22 87/9
89/21 94/18 95/17
100/23 101/19 102/6
102/23 104/15 104/22
116/20 119/22 120/17)
122/5 125/7 128/17
131/22 142/17 148/20)
153/14 155/14 158/20
166/10
evident [2] 77/24
130/5
ex [4] 150/9
ex-colleagues [1]
150/9
exactly [5] 19/20
23/7 30/18 46/7 82/23
examine [1] 68/23
example [4] 8/6
65/24 67/12 164/10
examples [2] 12/6
35/7
exceptional [1] 46/25]
exchange [4] 11/4
87/8 147/8 155/1
excluded [1] 91/1
exec [1] 88/10
execs [2] 90/6 151/6
executed [1] 140/19
executive [37] 2/17
2/21 7/6 7/9 7/16 7/25
8/2 8/12 8/22 10/5
39/5 40/4 57/9 64/23
70/5 88/11 90/3
107/13 107/15 113/24)
122/14 122/22 123/4
129/8 142/25 143/1
143/1 143/6 143/10
143/13 143/19 144/13)
144/13 145/16 145/20)
150/1 161/14
exercise [6] 15/13
58/22 58/23 75/3
76/16 146/5
exist [4] 48/5 49/18
59/3 87/11
existed [2] 11/18
51/11
existence [4] 13/8
13/10 93/25 135/7
existential [1] 47/3
existing [6] 19/23
75/4 76/15 76/16
7712 77/15
expand [1] 4/22
expect [2] 107/14
163/7
expectation [1] 4/6
expected [7] 13/20
20/21 35/1 49/21 70/8
107/22 134/17
expecting [1] 107/4
expensive [1] 29/5
experience [6] 41/2
90/16 107/13 118/11
145/3 150/7
experienced [4]
10/25 68/12 153/22
154/21
expert [17] 9/18
94/17 94/23 95/11
95/14 95/17 101/5
101/9 101/16 101/19
101/22 102/2 102/7
102/9 132/9 132/17
133/4
expertise [7] 9/19
12/5 26/9 84/13 150/1
150/4 151/5
experts [3] 156/8
160/25 161/12
explain [8] 44/21
57/23 72/18 81/8
83/13 83/14 91/24
119/25
explained [12] 17/25
21/9 29/2 33/20 39/12
62/14 91/9 97/5 120/4
120/5 126/13 126/19
explaining [3] 50/8
53/22 120/3
explanation [2] 91/17I
140/1
explicitly [2] 123/16
154/7
explore [3] 42/8
109/15 148/19
exploring [1] 121/25
exposed [2] 60/25
105/18
expressed [1] 93/2
expressly [1] 72/11
extend [1] 65/21
extensive [1] 36/24
extent [6] 50/8 91/24
126/22 146/8 146/10
149/24
external [8] 10/19
18/7 87/12 92/4 96/9
107/3 118/9 118/12
extra [1] 34/18
extract [1] 147/20
extracted [1] 100/24
Extracts [1] 67/1
extreme [1] 156/12
extremely [1] 133/16
EY [10] 11/8 11/16
13/19 13/21 14/1
16/10 16/11 21/22
21/25 22/17
Eye [1] 17/5
F
face [1] 137/14
fact [21] 22/8 31/19
37/24 39/5 39/24 43/1
65/15 80/5 82/15 90/7
105/15 105/25 118/15}
134/23 136/24 138/15}
140/21 146/3 147/3
154/19 159/10
factor [1] 133/6
facts [1] 2/2
factual [1] 34/25
failure [2] 85/10
85/12
fair [6] 75/14 85/14
85/15 118/14 123/10
154/12
fairly [6] 3/23 5/20
20/9 45/19 117/9
145/23
false [3] 104/14
119/13 126/15
familiarised [1]
101/5
far [10] 38/3 47/15
47/16 70/17 82/17
97/10 127/10 139/23
140/8 144/1
faster [6] 137/8 138/2I
138/13 138/18 138/25]
139/11
faults [2] 27/12 56/22}
favour [3] 129/8
129/11 131/23
favourable [1] 31/21
fearing [1] 91/25
feasible [1] 25/15
feature [2] 124/6
124/21
featured [1] 17/5
February [9] 52/11
100/14 101/18 102/13}
102/19 127/11 132/13}
132/14 133/3
fed [2] 164/2 164/3
feed [1] 47/3
feel [7] 9/2 66/16
66/17 71/4 71/6 72/24,
99/3
feeling [11] 43/13
43/22 66/11 71/1 71/7)
71/12 71/13 74/12
103/9 103/10 119/6
feels [3] 59/6 116/12
139/22
felt [18] 9/7 43/3 59/7
71/10 73/9 73/13
73/15 74/15 76/7
93/14 93/15 110/20
118/19 127/19 130/15}
134/20 144/8 145/19
Fertility [3] 8/7 8/20
8/23
few [11] 23/23 48/21
70/17 107/8 109/5
136/2 137/10 137/20
137/21 137/22 148/13
fewer [1] 23/24
figure [2] 21/11 92/7
figures [2] 46/19
129/19
File [1] 111/3
final [2] 55/1 149/22
Finally [1] 19/13
Finance [3] 60/11
62/8 66/1
financial [3] 87/5
105/18 165/1
financially [1] 162/11
find [21] 27/12 27/18
29/24 32/2 32/6 32/7
48/25 48/25 49/2
64/15 101/16 102/5
102/7 137/8 138/2
138/13 138/18 144/18
144/21 157/7 165/14
finding [3] 25/3 39/15}
104/6
findings [11] 18/25
23/15 23/16 23/23
23/25 54/7 64/24
72/13 72/14 82/12
87/7
fine [12] 41/13 41/16
53/9 85/16 86/1 86/4
107/11 108/23 129/17]
152/12 153/3 166/16
finished [1] 116/25
fire [5] 121/6 121/7
121/19 121/21 166/8
firm [5] 83/17 96/9
105/23 107/3 146/6
first [34] 4/16 8/1 9/9
10/4 10/8 10/23 11/3
41/7 12/11 12/23
13/17 13/18 17/11
17/14 23/23 24/10
25/18 37/9 41/11
53/19 58/24 66/6 74/3
TAIT 82/17 87/18
103/3 111/8 126/8
129/13 133/14 142/25)
153/11 158/18
firstly [6] 1/13 57/2
58/16 78/24 97/11
99/24
fit [2] 12/6 56/25
five [4] 51/18 84/9
85/13 160/1
fix [5] 32/8 41/9 54/8
158/12 165/16
fixed [6] 40/15 54/9
54/9 54/10 54/10
151/19
flag [7] 38/10 38/20
38/20 42/24 51/13
156/18 156/18
flags [2] 70/22 71/5
flaw [5] 30/8 33/12
34/8 34/8 49/2
flawed [1] 150/25
flaws [5] 36/2 43/17
48/25 53/18 156/2
Flemington [1]
114/21
flesh [1] 112/22
flow [2] 79/15 150/25
focus [4] 20/24 21/1
124/12 124/14
focused [2] 87/7 97/2
focusing [1] 129/1
follow [6] 27/12 29/7
50/19 79/15 83/24
157/9
follow-up [1] 83/24
followed [3] 13/10
76/11 80/10
following [10] 2/9
23/13 24/8 29/24
42/21 66/15 88/12
95/21 125/23 166/19
follows [1] 111/1
force [2] 2/14 13/9
forced [1] 162/16
forensic [6] 24/11
25/19 26/2 27/14
34/25 156/8
forensically [2] 27/11
29/7
forgive [3] 23/10
129/21 149/10
forgotten [1] 147/23
form [6] 32/6 56/16
67/4 76/2 127/18
148/18
formal [1] 65/21
formality [1] 152/23
formed [3] 67/4
(61) etc - formed
F
formed... [2] 85/13
164/18
Fortunately [1]
121/19
forum [1] 160/24
forward [10] 32/13
57/21 93/5 116/18
126/8 128/22 134/3
135/3 138/21 155/10
forwards [1] 28/1
38/3 38/16 41/5 43/5
44/3 61/1 73/24 79/22)
112/13 149/13 151/18}
151/19 157/17 158/8
165/15
four [5] 3/10 3/12 4/6
AIT 12/21
fourth [4] 81/19
frame [1] 133/16
framework [1] 65/21
France [1] 98/4
Franklin [2] 160/4
160/11
frankly [8] 104/7
107/4 113/25 116/15
119/2 119/5 131/19
162/4
fraud [2] 15/23
119/13
freely [1] 39/21
frequent [1] 3/23
fresh [1] 112/18
Friday [1] 111/4
frightened [1] 116/13
front [3] 1/17 65/11
107/24
frustrated [3] 115/23
115/24 116/10
Fujitsu [27] 6/4 6/7
12/15 12/18 13/9
14/24 15/8 17/17 21/6)
51/11 68/2 68/11
68/20 69/11 69/25
71/19 73/11 75/12
75/22 75/23 78/24
79/6 94/17 94/22
101/22 102/2 156/24
Fujitsu/Horizon [1]
73/11
fulfilled [2] 145/5
145/7
full [9] 1/11 42/5
60/19 73/12 84/14
92/22 97/7 101/15
128/8
fully [2] 27/7 143/18
function [3] 119/16
125/4 143/18
functionality [2]
68/19 70/2
functions [1] 120/3
found [17] 30/10 33/5]
fundamental [1]
49/18
fundamentally [2]
99/16 108/5
funded [1] 141/14
further [13] 15/20
26/3 28/4 28/19 36/19)
78/1 87/14 94/14
96/19 111/14 126/2
140/5 148/21
Furthermore [1] 72/8
future [9] 4/21
101/10 102/23 110/1
119/8 124/10 125/22
126/10 132/8
Go
gain [1] 31/20
gains [1] 37/14
gaps [2] 75/4 75/21
Gareth [21] 51/12
60/3 60/7 61/22 63/8
66/14 67/3 80/2 80/8
80/13 80/14 80/15
82/4 94/6 94/20 94/21
95/12 99/14 104/13
105/5 158/23
gave [11] 9/5 14/14
24/19 28/13 33/2 38/7
45/15 62/1 104/7
109/12 153/14
GC [1] 122/11
general [16] 11/1
19/23 21/13 65/22
84/8 91/15 106/4
107/2 107/5 107/13
108/3 110/19 118/12
153/25 154/15 154/19)
generality [1] 44/9
generally [2] 57/12
57/13
generated [1] 78/14
generic [1] 50/16
get [36] 5/8 5/10 31/7
31/10 31/11 31/24
46/17 46/21 50/19
53/2 53/3 58/18 58/25
59/14 63/14 63/16
69/12 69/12 71/12
81/23 83/8 106/2
113/25 114/4 114/7
129/21 132/17 134/6
137/18 138/4 138/7
138/17 139/11 157/25)
162/22 165/2
getting [17] 5/4 25/4
25/9 29/25 35/21
38/14 38/15 40/7
42/16 43/23 44/18
55/19 58/18 115/21
139/5 155/7 155/21
give [16] 1/15 4/13
8/21 18/8 21/18 26/3
52/7 52/10 57/14
57/15 67/3 73/25 77/1
83/17 94/18 140/18
given [17] 9/17 27/10
30/11 35/7 42/25
48/21 60/23 61/23
63/6 64/20 70/13
71/20 72/6 76/21
91/17 91/19 106/18
giving [7] 32/18 62/3
76/10 76/12 104/14
163/5 163/6
glad [1] 85/21
go [80] 9/11 10/8
11/6 12/1 12/18 16/19
25/12 25/21 27/14
27/23 28/7 28/16
34/14 36/19 37/21
45/3 45/4 47/1 48/25
49/1 51/19 51/20 52/4
56/8 57/21 60/5 60/17
63/8 64/10 65/17 66/5
66/24 68/15 74/21
75/2 76/18 77/8 77/10
77/21 82/11 83/18
86/11 87/1 87/2 91/5
91/7 91/8 96/19 96/23
97/10 98/15 99/14
100/12 100/18 104/4
107/6 107/8 111/13
111/14 112/3 118/11
120/7 126/6 128/21
131/10 133/12 135/24
137/10 137/20 138/6
140/5 141/5 141/7
141/9 141/15 141/19
142/16 142/19 147/6
149/6
God [3] 71/16 102/3
161/25
goes [3] 33/19 56/17
111/17
going [77] 2/7 5/12
13/2 16/19 17/21 19/5
23/2 23/7 24/22 26/24
27/6 27/7 27/9 27/17
28/12 31/25 32/4
35/17 35/18 42/4
44/16 46/14 52/18
52/21 54/18 56/5
56/10 58/22 59/2
59/15 61/5 62/3 63/14,
64/21 72/15 74/6
74/21 76/17 76/18
77/12 81/17 85/24
86/11 86/13 86/15
88/5 89/20 93/5 97/6
98/11 98/17 98/19
99/21 107/6 111/7
116/14 116/18 117/3
123/6 124/5 126/8
128/15 131/19 132/2
134/3 134/9 134/11
134/12 134/13 135/3
145/3 148/4 148/19
166/8
gone [12] 40/17
55/16 70/15 89/16
102/4 102/7 104/8
118/6 149/23 156/5
156/12 156/14
good [49] 1/5 19/11
30/16 36/4 41/10
41/21 43/8 43/13
45/17 51/8 51/14
58/17 61/24 71/1
72/23 72/24 73/10
73/11 73/13 73/15
85/18 85/23 97/1
107/7 107/16 107/20
109/2 121/17 139/24
140/8 140/22 147/14
148/17 150/16 150/20)
150/20 150/21 150/22}
150/23 151/15 153/5
160/17 161/24 162/1
163/15
goodwill [4] 46/10
46/15 47/2 52/15
Google [1] 162/24
got [38] 3/12 4/23
26/25 40/11 42/1
43/24 46/25 51/14
51/17 54/25 69/21
69/21 74/11 84/6
84/10 84/11 84/12
96/15 99/8 109/5
112/3 115/9 117/8
131/3 131/4 142/22
143/25 144/18 144/20}
147/22 148/3 149/7
156/25 157/2 158/15
158/18 158/22 166/9
governance [1] 68/8
government [2] 2/13
162/12
gradually [1] 131/8
Grant [10] 9/14 14/9
14/12 14/16 16/1 16/5)
16/7 20/16 20/19 21/9}
grapple [2] 92/15
163/2
grappling [1] 157/21
grateful [3] 109/21
166/1 166/10
great [5] 31/6 137/8
146/3 146/4 163/10
grievances [1] 164/8
grip [1] 31/7
group [22] 5/7 30/25
31/25 63/13 78/5 78/6
120/6 125/8 125/19
139/20 140/15 141/10
141/12 141/13 141/16}
142/9 154/10 154/21
154/22 161/14 162/22}
163/4
159/18 164/25 165/24)
19/11 25/8 26/24 28/3)
groups [1] 161/17
growing [1] 46/12
guess [6] 34/4 88/23
90/4 90/8 110/6
128/13
guessing [4] 98/5
101/25 144/10 144/11
guidance [1] 110/23
H
had [259]
hadn't [15] 17/12
18/18 39/5 42/22
42/25 50/10 50/11
59/8 75/18 77/2 79/5
79/7 93/14 106/9
120/13
halfway [1] 14/22
hand [1] 131/16
handled [6] 36/8
115/4 116/2 139/22
140/13 140/16
handling [2] 146/11
146/16
handover [1] 154/10
happen [3] 90/24
107/14 165/22
happened [13] 27/11
27/15 57/15 83/2 98/9
105/8 108/2 118/16
120/14 120/19 124/8
139/19 140/1
happening [11] 22/5
22/23 82/21 119/18
119/23 120/9 120/9
123/13 131/4 1314/5
157/9
happily [1] 150/21
happy [13] 22/1
29/15 35/25 36/2 36/3
99/19 102/20 113/5
127/21 131/18 132/23)
148/5 156/1
hard [6] 14/2 14/24
15/18 64/17 113/25
162/4
has [37] 19/14 19/15
24/3 27/15 28/8 33/5
36/25 38/19 41/8
46/25 47/14 49/19
56/20 58/18 59/16
65/13 66/19 68/1 68/6
68/10 74/5 74/20 84/6I
87/9 89/21 101/5
102/1 102/7 103/20
104/14 119/4 125/6
135/22 136/1 140/1
142/22 153/2
hasn't [2] 76/21
112/19
Hatfield [2] 115/20
117/5
have [298]
haven't [7] 3/12
(62) formed... - haven't
H
haven't... [6] 79/19
79/22 93/22 148/3
156/5 156/13
having [11] 6/15 48/2
50/18 64/25 88/10
97/17 98/1 110/20
145/1 156/5 163/1
he [15] 16/11 16/11
20/21 21/1 28/8 61/22
80/4 94/7 103/22
114/21 120/5 145/17
145/18 153/25 158/23}
he's [2] 102/3 102/4
head [2] 85/20
161/25
headhunters [1]
146/6
headline [1] 159/23
headway [1] 150/16
health [2] 30/12 62/4
hear [8] 1/5 41/21
86/9 109/2 121/17
152/10 152/24 160/9
heard [6] 13/14 89/21
120/12 125/6 150/8
152/4
hearing [3] 1/7
124/16 166/19
heavily [2] 72/10
146/17
held [6] 2/21 8/2
26/13 34/15 100/14
125/25
Helen [2] 99/15
104/15
help [7] 22/21 53/23
84/25 109/18 129/18
160/13 163/13
helped [1] 165/19
helpful [9] 40/20
47/19 51/15 63/18
128/2 144/24 151/15
151/17 166/1
helpline [3] 40/19
43/12 54/10
her [57] 3/5 14/15
14/16 16/16 16/16
19/25 20/1 25/3 31/7
46/4 51/23 91/1 92/4
92/5 98/12 108/9
112/15 112/23 114/6
114/7 122/11 128/13
128/13 128/14 131/22)
133/25 135/4 135/8
135/9 135/10 135/11
135/15 135/15 135/15}
135/16 143/9 143/12
143/12 143/12 143/14}
144/9 144/16 145/25
146/1 146/2 146/4
146/11 146/16 146/23)
146/24 147/10 147/10)
147/18 147/19 148/41
148/14 148/17
here [34] 8/13 8/19
20/3 23/1 23/5 31/12
31/19 37/25 44/6
51/17 59/13 62/13
73/21 77/9 77/14
83/16 94/10 111/15
112/5 115/20 116/21
117/14 117/25 120/24
131/3 139/4 139/5
140/21 149/12 149/17)
157/22 158/12 158/15)
158/22
herring [1] 108/1
Hi [1] 149/9
hide [1] 53/14
high [2] 26/13 64/2
highlighted [2] 33/7
91/10
highlighting [1]
117/22
him [3] 16/9 16/9
80/17
himself [1] 101/6
hindsight [21] 12/25
18/13 19/10 19/21
37/17 38/15 39/11
73/23 83/3 89/6 99/13)
106/16 106/21 106/22!
107/1 116/11 124/13
146/21 151/16 157/19)
158/17
hint [1] 102/8
his [5] 16/10 80/17
82/12 95/12 130/8
historic [3] 68/24
117/20 117/22
history [3] 97/2
108/17 145/23
hm [1] 152/18
HNG [1] 56/9
HNG-X [1] 56/9
hold [1] 7/6
holistically [1] 65/23
honest [6] 55/7 70/7
87/21 107/25 154/25
161/23
honestly [8] 78/18
78/22 88/22 90/10
102/20 114/9 144/17
148/13
honesty [1] 135/15
Hooper [2] 138/1
141/18
hope [1] 117/7
hoped [1] 117/6
hopefully [2] 152/23
153/10
horizon [147] 5/22
5/23 6/4 6/8 6/9 6/12
6/13 6/13 6/13 6/14
6/16 7/1 7/20 9/21
10/7 10/21 10/24 11/3
12/5 13/21 14/10 15/8}
15/13 15/16 15/21
16/2 18/1 19/11 19/16
21/19 26/11 26/16
27/16 29/19 29/20
30/8 30/11 32/17
32/18 32/22 32/24
33/2 33/6 33/12 33/20
34/17 34/20 36/21
37/2 37/23 38/4 38/7
38/13 38/22 40/8
40/14 40/23 40/24
41/1 41/7 42/17 43/9
44/3 44/11 45/8 45/10
47/14 47/18 47/25
48/16 48/19 49/2 49/5
49/8 49/13 49/22
49/24 50/8 50/21 52/8
52/10 52/19 53/6 53/7
53/16 54/19 56/9
56/15 56/21 56/23
56/25 58/8 58/17 62/4
62/15 63/7 63/13
63/17 63/17 64/1 64/4
64/5 64/5 65/23 71/2
72/23 73/11 73/25
75/16 76/19 77/11
77/20 77/20 78/13
94/12 97/7 100/24
101/1 117/16 124/15
124/19 125/1 125/2
146/17 146/18 146/19}
146/22 146/23 147/4
150/14 150/19 153/11
153/19 154/6 154/16
156/9 156/22 157/16
161/22 163/2 163/2
163/10 163/20 163/21
163/22 163/22 164/6
Horizon's [3] 52/25
94/19 146/12
hours [2] 3/21 70/16
house [1] 137/13
how [46] 3/16 7/1
23/2 23/7 30/21 33/13
35/20 36/8 46/17
47/20 49/23 50/8
52/18 53/16 53/22
58/1 58/7 58/12 59/15
63/21 69/11 73/4 74/2
75/15 77/1 84/21 85/5)
90/16 92/8 92/10 97/9
105/9 113/8 115/3
116/17 120/18 121/2
122/2 127/4 127/7
134/11 145/6 155/21
156/3 157/8 165/2
Howe [2] 153/9
165/25
however [9] 13/8
18/2 21/22 25/1 32/9
72/6 103/23 129/23
131/2
huge [4] 38/10 46/13
51/13 162/19
hugely [1] 108/4
Hugh [1] 114/21
1100 [1] 84/5
l absolutely [2] 51/16
165/8
l accept [1] 77/6
l actually [3] 43/3
46/18 113/6
l agree [3] 40/21
40/25 164/18
l agreed [1] 40/22
lalso [1] 150/4
l always [1] 144/18
lam [17] 2/7 8/4 9/17
32/2 36/10 36/11 38/9
61/18 70/17 79/25
89/20 97/14 99/1
107/25 113/12 118/10}
147/15
land [2] 4/2 36/11
l appreciate [1]
64/20
lare [1] 31/22
lask [2] 1/19 157/23
lasked [2] 113/1
121/21
l assume [3] 52/3
59/19 131/23
lassumed [1] 120/9
I been [2] 70/9
104/13
I believe [4] 19/25
32/1 34/12 163/18
I believed [6] 12/25
33/10 40/16 40/17
99/6 99/19
I came [4] 19/9 26/20
61/23 71/7
lean [11] 20/10
53/10 73/23 90/22
95/19 113/4 121/18
146/16 149/2 152/25
164/11
I can't [7] 22/8 80/7
90/15 92/2 101/11
112/22 143/20
I cannot [36] 3/8 8/14
8/16 20/4 20/11 21/21
22/5 22/5 25/6 30/18
34/11 36/9 57/4 57/10)
67/15 74/15 74/16
82/23 83/13 83/14
89/4 90/4 90/4 90/21
98/1 98/4 98/10
101/25 101/25 103/24,
107/20 112/24 124/2
128/14 133/24 137/3
I certainly [5] 8/14
15/16 97/24 106/11
123/11
I come [1] 61/19
I could [2] 44/6
129/16
I deferred [1] 9/18
I definitely [1] 154/25)
I did [22] 16/9 18/18
19/1 29/1 50/22 57/4
57/11 65/3 66/13
72/24 74/17 91/2 93/8)
94/21 97/24 101/21
102/17 125/17 125/21
132/4 145/22 148/15
I didn't [26] 18/12
18/14 19/21 19/22
71/4 71/5 71/5 71/6
80/2 87/22 87/23
87/24 99/11 102/3
102/15 103/6 103/9
110/10 119/2 119/3
120/12 134/6 134/7
135/14 136/25 159/3
I disoriented [1]
96/20
Ido [30] 1/18 7/23
20/10 26/22 35/9
55/14 60/19 60/20
61/17 61/20 66/12
67/9 69/5 73/21 74/12
78/19 83/1 90/19 94/5I
97/13 103/23 110/12
112/1 116/9 128/16
133/20 143/14 144/14I
144/25 145/22
I don't [53] 16/7 16/8
18/12 18/12 18/14
22/11 33/15 33/17
36/2 48/11 48/20
54/13 55/7 55/7 55/9
65/2 65/2 70/7 71/15
73/14 77/18 80/23
87/1 88/14 88/14 95/8)
97/19 97/24 106/9
107/8 107/9 108/14
108/15 116/1 118/6
124/21 128/11 130/17)
132/14 133/6 134/22
135/5 135/10 141/23
146/16 148/14 148/21
149/3 150/21 151/13
158/5 163/21 163/22
I doubt [1] 57/18
learlier [1] 72/1
lended [1] 131/25
lever [1] 123/21
I felt [5] 73/9 73/13
73/15 74/15 76/7
I find [1] 144/21
I fundamentally [1]
108/5
I gave [1] 9/5
I get [1] 129/21
I go [2] 10/8 104/4
I got [2] 40/11 157/2
I guess [3] 34/4
110/6 128/13
(63) haven't... -I guess
I had [22] 3/5 10/11
11/4 16/10 36/9 40/17)
46/4 89/10 96/25
106/9 112/20 119/5
123/16 123/18 123/19)
138/3 148/13 149/13
149/18 152/13 154/7
155/4
I hadn't [3] 18/18
77/2 120/13
Ihave [27] 3/8 16/16
25/1 25/14 26/19
27/13 74/11 93/23
103/8 103/9 103/25
107/2 107/21 108/17
109/18 118/11 119/5
125/5 144/17 148/1
149/22 150/8 151/22
158/23 159/9 165/11
165/23
I haven't [3] 3/12
79/19 148/3
I honestly [7] 78/18
78/22 88/22 90/10
102/20 114/9 144/17
I joined [1] 5/3
I just [10] 8/1 24/9
ATIT 57/23 59/22
60/15 80/20 85/19
120/12 149/14
I knew [3] 70/23
87/22 101/12
I know [3] 41/12
89/11 151/23
learnt [4] 15/14 77/5)
95/10 103/10
Heft [1] 148/2
Hike [1] 99/18
I listened [2] 25/2
61/22
Ilooked [1] 147/22
I make [1] 51/3
I may [4] 78/21
I mean [26] 9/5 40/16
43/8 53/1 54/16 57/22
66/12 69/16 71/4
74/15 87/21 92/10
92/11 95/13 98/5
108/8 113/22 118/13
122/17 132/5 138/9
141/24 144/10 152/5
164/21 165/11
I meant [2] 30/18
30/20
I might [4] 34/21 46/5]
70/10 143/17
I need [1] 99/9
I never [2] 9/7 135/15
I now [2] 19/21 42/1
I personally [1]
150/11
I probably [1] 61/18
I put [2] 46/11 77/13
lread [15] 37/18
40/12 40/20 41/3
61/13 72/25 73/7 73/9
73/11 74/2 79/13 89/4
158/11 159/2 159/3
Ireally [4] 112/20
I recall [1] 9/13
lregret [1] 165/22
I remember [8] 10/12
27/20 27/21 78/20
78/21 89/5 115/24
156/17
I remembered [1]
37/15
lrepresent [1] 153/5
I said [5] 9/5 46/11
71/4 111/18 148/2
I saw [6] 13/17 16/9
17/14 70/11 83/11
111/25
I say [5] 7/4 19/9
54/15 123/12 151/6
Isee [4] 85/10
116/11 142/12 152/6
I shared [1] 93/8
I should [7] 37/18
38/21 39/11 59/18
65/4 102/14 127/25
I spoke [2] 89/5
112/23
I started [1] 132/2
I still [2] 80/25 159/3
I stumbled [1] 149/13}
I subsequently [1]
15/3
I take [2] 28/8 131/23
Itell [1] 30/19
I then [3] 79/15
121/25 129/18
I think [137] 3/9 3/11
4/5 5/24 10/8 12/8
15/12 16/21 21/23
22/12 22/15 24/8 25/3
25/8 25/17 26/18 27/5
27/19 29/2 29/23
30/13 30/13 30/20
31/23 32/22 32/23
33/10 34/3 34/8 34/21
36/15 37/15 38/1
39/18 42/23 44/2
44/22 45/3 45/21
45/23 46/7 46/18
46/22 47/4 48/6 49/8
50/3 52/11 54/14
54/17 54/21 55/20
57/10 59/11 59/12
59/18 60/12 61/21
64/23 69/10 69/14
69/25 71/4 77/19 78/8)
79/13 79/18 80/6
80/11 81/2 84/24
89/23 92/7 94/25 96/6
96/9 97/16 99/1
101/12 104/17 105/6
107/20 107/25 108/13
108/16 110/24 113/6
113/13 114/5 114/18
115/23 116/6 117/5
117/25 122/10 122/11
124/4 124/23 128/18
130/15 131/13 132/2
132/10 134/4 134/7
134/20 135/8 135/20
137/7 137/11 137/23
143/25 145/1 145/8
145/13 149/1 149/4
150/3 150/12 150/19
150/23 151/10 151/18
151/25 153/2 153/23
154/9 156/18 157/23
159/7 159/9 159/10
163/2 163/3 164/12
165/19 165/23
I thought [114] 30/13
31/3 39/16 40/21
40/25 43/4 43/7 73/15)
102/4 131/12 133/1
[told [1] 148/14
I took [6] 72/22 72/22
114/12 154/19 154/23
155/5
I touched [1] 145/25
Itry [1] 157/41
l understand [7] 17/6
54/22 56/1 72/15
105/1 106/16 164/17
I very [1] 162/13
I want [22] 1/16 4/16
9/9 10/4 14/17 24/5
32/1 32/10 42/8 70/25
96/3 99/18 106/22
107/12 109/14 119/7
125/22 133/8 142/24
145/15 147/2 153/10
I wanted [6] 39/19
39/19 39/21 85/20
88/20 115/25
I was [67] 9/7 10/2
10/24 12/23 13/5 15/3
15/15 16/19 19/1 19/2
19/8 24/15 27/6 27/20
29/15 33/15 35/16
35/16 37/17 39/10
43/4 43/13 45/22 46/6
46/9 46/22 47/4 52/15
74/6 89/7 89/8 92/3
94/5 94/22 95/11
95/12 97/20 98/4 99/6
99/12 99/19 99/19
103/20 104/5 106/8
115/19 115/23 115/24
119/17 120/8 120/13
123/6 124/15 129/12
129/15 130/6 132/3
136/24 138/19 139/10
150/22 152/10 153/22
154/25 160/1 160/3
160/10
I was probably [1]
80/23
I wasn't [13] 13/6
36/2 43/20 43/21 44/4
44/14 57/22 70/11
95/13 106/8 119/18
152/12 154/24
I watched [1] 158/19
I went [1] 4/25
I were [1] 30/21
Iwill [9] 34/3 34/4
67/10 88/18 88/19
98/22 109/4 113/4
121/9
I wish [6] 107/1
158/17 158/21 158/25}
159/8 165/5
I won't [2] 113/4
158/13
I wonder [1] 136/5
I would [31] 4/12
25/11 35/9 35/18 57/6
58/3 71/10 74/16
88/17 88/23 89/10
89/11 89/12 89/13
90/4 90/8 92/12 99/6
99/13 103/6 107/22
112/22 113/6 113/7
114/5 114/8 116/6
118/7 118/13 123/21
124/13
I wouldn't [3] 70/7
118/13 162/6
I wrote [2] 30/19 31/6
I'd [11] 30/5 89/15
89/16 101/21 109/21
120/15 123/12 138/3
147/22 147/23 152/13}
I'l [14] 2/8 9/9 36/5
37/15 41/24 85/8
91/22 110/7 121/20
146/8 150/21 159/9
159/18 165/12
I'm [94] 15/6 17/21
20/4 20/8 22/11 25/9
30/1 32/1 35/10 38/14)
38/15 40/6 40/7 42/4
44/14 46/23 47/4
55/14 56/10 57/4
60/13 61/3 63/23 65/9)
65/10 66/13 71/9
71/16 71/16 71/17
72/15 73/20 74/10
74/21 77/7 79/13
84/18 85/19 85/21
85/24 86/11 86/13
86/15 86/17 90/15
93/8 95/11 95/22 98/5)
101/25 102/15 102/17,
107/4 107/6 111/7
112/21 112/22 112/23}
112/25 113/5 113/11
115/19 120/24 123/20
124/7 128/15 130/10
131/25 137/3 138/2
139/23 140/7 142/12
143/23 144/10 144/11
147/21 148/4 148/4
148/19 152/1 153/8
153/17 153/18 154/25)
155/24 159/18 161/23
163/9 164/17 165/6
165/24 166/1 166/10
I've [13] 8/5 94/10
99/8 104/5 108/4
109/5 143/25 144/20
144/20 152/3 152/4
152/4 158/12
lan [1] 158/20
idea [6] 25/9 58/17
118/9 160/8 162/12
162/13
ideally [3] 84/13
114/16 130/23
ideas [2] 139/13
139/13
identification [2]
7/16 49/25
identified [10] 21/12
42/20 43/8 43/14
53/18 54/17 56/19
56/22 78/2 101/5
identify [3] 27/15
38/8 72/11
ie [6] 29/6 44/20
127/21 128/23 130/16)
1567/7
ie perfectly [1]
127/21
ie retaining [1]
128/23
ie take [1] 29/6
ie that [1] 44/20
ie the [1] 157/7
ie there [1] 130/16
if [175]
ignite [3] 139/23
140/7 140/8
imagining [1] 113/12
immediate [1] 97/2
impact [3] 49/16
105/16 161/41
impacted [2] 37/2
156/9
imperative [2]
411/11 112/7
implementation [2]
56/16 60/9
implemented [2]
56/23 75/19
implicated [3] 89/9
91/16 105/22
implications [1]
87/13
implicit [1] 123/17
implicitly [1] 63/23
importance [1] 161/1
(64) [had - importance
I
important [15] 5/14
49/14 50/19 54/4
58/11 63/3 64/8 82/11
92/14 99/3 99/8
101/24 108/8 133/16
151/1
Importantly [1] 47/11
impossible [4] 29/5
48/8 48/11 162/9
impression [6] 11/5
38/14 38/15 62/2
79/14 142/13
improve [3] 160/10
160/16 163/15
improved [1] 24/4
improvement [5]
33/7 54/5 65/19 91/11
149/1
improving [1] 70/24
inaccuracies [1] 35/6
inaccuracy [1] 35/8
inaccurate [5] 36/1
55/13 60/14 136/22
156/1
inadequate [1] 40/14
incentivising [2]
138/6 138/7
incidents [3] 15/7
38/6 68/24
include [6] 7/19 12/7
55/5 65/24 68/21
163/14
included [4] 23/9
43/16 69/23 161/10
includes [1] 75/9
including [6] 3/24
5/22 9/21 22/2 125/9
140/3
incomplete [3] 60/14
60/24 61/2
incorrect [5] 136/11
136/13 136/15 136/24}
137/2
increase [1] 161/15
incredibly [1] 137/19
independence [2]
10/11 135/12
independent [31] 3/1
3/7 3/14 3/19 4/11
4/14 8/10 8/11 9/3
11/7 16/15 16/24
34/25 58/4 61/14 67/7
68/12 68/18 69/12
76/3 76/21 77/16
96/15 101/5 101/16
104/2 112/15 123/25
132/17 141/10 141/14)
indicate [1] 45/10
indicates [1] 114/18
indication [1] 44/22
individual [16] 28/9
28/11 28/13 28/24
29/7 29/18 43/20
43/22 44/4 44/17
45/11 50/3 105/19
118/7 139/7 164/8
individuals [2] 12/4
105/16
induction [4] 10/23
14/16 122/14 154/10
industry [1] 162/24
inevitable [1] 38/19
inevitably [8] 20/5
22/7 37/16 44/13
70/17 77/11 145/8
163/3
inform [1] 108/3
information [32] 9/15
16/14 37/13 39/21
40/3 47/15 72/9 75/4
T77IT 79/16 91/19 99/9
99/24 100/9 103/5
103/14 104/20 105/5
107/22 108/4 108/6
108/12 108/13 108/15)
109/21 117/19 150/25)
151/1 151/3 156/22
156/23 157/25
informed [3] 92/3
153/18 155/16
informing [3] 70/5
122/8 123/1
infrastructure [9] 5/5
5/7 5/8 5/9 5/15 5/16
5/17 5/21 6/1
Initially [1] 115/17
Innovation [1]
111/21
Inquiry [24] 1/15 2/6
14/14 14/20 17/15
24/19 45/15 56/11
59/22 62/1 67/3 70/12
74/20 89/21 93/22
94/3 109/12 117/13
119/4 125/6 145/17
148/21 153/8 163/24
Inquiry's [1] 2/7
insert [1] 17/18
insist [1] 21/13
insisted [1] 84/23
insisting [1] 28/6
instance [1] 90/21
instances [1] 29/13
instead [1] 27/9
instinct [4] 67/15
131/13 131/13 132/2
instinctive [1] 130/22
Institutes [1] 2/14
instruct [1] 24/11
instructed [3] 25/19
106/7 153/8
integrated [1] 143/18
integrity [43] 6/21
7/19 9/16 9/20 10/1
10/3 10/24 11/11
11/22 14/10 14/13
15/5 16/12 18/1 19/12)
19/16 21/18 22/1
22/13 22/18 23/21
38/22 39/2 39/7 52/25
53/6 54/25 56/15
56/21 58/8 58/16
62/17 64/1 64/3 64/6
771/20 77/24 124/15
124/18 125/2 135/14
135/15 146/13
intelligible [1] 72/6
intended [1] 89/22
intensive [1] 4/2
interchange [1] 19/7
interest [4] 143/22
144/22 161/1 161/16
interested [2] 87/21
111/25
interesting [2] 4/11
88/2
interests [1] 145/11
interface [2] 6/20
9/25
interim [31] 32/13
33/3 36/14 42/1 42/14
42/21 42/22 43/4
44/20 49/7 54/1 54/7
54/17 62/10 71/7 82/5
88/7 95/3 102/16
104/4 112/14 113/18
123/7 124/1 125/23
132/4 132/6 134/14
155/11 155/16 159/12
internal [10] 11/9
12/13 13/6 18/2 18/11
18/16 18/19 18/25
19/5 120/16
internally [2] 10/5
52/14
international [1]
74/25
interpreted [1]
117/22
interrupted [1] 166/38
into [40] 4/25 10/24
11/4 13/10 14/7 26/15}
42/6 43/6 43/7 43/10
43/16 49/17 49/21
53/5 56/21 58/16
58/23 59/17 83/5 90/7
96/15 104/8 104/19
110/25 115/3 117/9
118/6 125/8 125/11
125/15 134/11 135/7
141/20 141/23 142/11
142/18 148/16 148/21
162/4 163/8
introduce [1] 13/9
introduces [1] 126/7
intuitive [3] 6/17 6/23
40/19
intuitively [1] 40/16
invested [1] 5/19
investigate [1] 26/3
investigated [4] 15/9
18/25 44/2 56/20
investigation [18]
24/17 26/15 33/5
49/21 53/5 55/4 63/1
68/8 71/18 77/17
119/12 120/16 123/15)
123/19 123/20 123/24}
131/16 148/25
investigations [3]
42/6 44/25 122/3
Investigatory [1]
68/10
invite [1] 163/25
inviting [1] 164/7
involved [21] 24/10
24/15 81/15 89/15
97/19 106/5 117/19
120/22 125/14 126/9
133/18 135/13 135/13
136/8 141/3 142/2
146/17 146/19 149/16)
154/14 154/24
involvement [4]
125/17 133/17 134/3
134/5
iPhone [4] 6/15 6/15
34/5 34/6
Irrespective [1] 70/3
is [304]
ISAE [7] 12/14 13/6
13/7 13/9 14/7 21/4
51/11
ISAE 3402 [4] 13/6
isn't [14] 3/9 31/8
31/12 40/20 46/23
48/15 69/17 99/7
114/25 136/20 138/16
142/3 161/3 164/3
issue [43] 10/1 10/3
11/22 11/23 11/24
13/14 15/4 15/5 22/9
23/20 23/21 34/16
35/15 39/2 40/12
40/13 43/14 44/4
62/20 79/11 79/18
87/16 88/11 92/14
97/9 98/22 99/11
106/24 110/20 110/22,
110/25 114/4 120/17
133/4 133/22 140/16
145/16 146/17 150/24}
157/21 163/20 163/22,
165/3
issues [44] 9/19 11/3
22/9 33/6 33/9 33/10
40/8 40/9 48/25 54/10)
54/12 54/16 54/25
55/2 55/5 55/17 55/23)
56/19 69/7 71/14
71/15 97/23 97/25
99/1 125/14 125/17
125/20 126/13 147/4
150/14 150/19 157/4
157/6 157/10 161/1
161/19 161/21 163/2
163/3 163/11 163/23
164/5 164/6 164/9
it [644]
it's [116] 6/14 6/15
11/15 14/18 15/23
16/22 16/23 17/6
20/19 25/8 25/14
28/11 28/13 28/18
31/9 31/14 31/15
32/10 32/17 36/1 36/3
36/15 38/1 38/1 38/9
38/11 38/12 38/19
40/18 40/19 40/19
41/1 41/12 45/3 47/1
47/3 47/3 48/21 51/2
51/17 54/6 54/13
54/14 56/11 58/22
58/23 59/4 60/1 61/12
64/11 64/13 64/22
69/10 71/21 73/20
74/15 74/18 76/12
76/25 80/11 85/11
85/18 85/23 91/3 91/4I
94/10 95/6 96/22
100/17 101/14 101/15}
102/11 102/12 102/19)
107/7 108/2 108/7
108/8 108/13 109/16
1411/3 113/9 113/11
113/12 113/20 113/20)
114/4 114/11 114/20
119/7 119/9 125/24
128/19 132/5 132/25
133/10 134/24 135/20)
135/21 136/16 137/3
139/6 139/18 140/12
142/3 143/5 144/10
144/11 144/24 147/3
147/4 151/10 152/12
156/1 159/20 159/20
item [3] 21/14 64/15
90/23
item 6 [1] 64/15
items [1] 21/15
its [22] 5/7 5/8 5/9
18/25 37/9 49/24 53/6I
58/13 59/3 60/9 72/14
77/11 79/8 122/9
123/3 123/15 127/18
127/20 130/21 153/23)
161/9 161/16
itself [13] 6/21 18/16
24/12 42/12 61/17
74/5 74/9 77/17 92/23}
107/18 120/11 136/19}
139/25
aq
Jacobs [3] 153/1
153/4 167/6
James [19] 25/7 26/1
28/5 28/20 60/3 60/7
(65) important - James
J
James... [13] 61/22
63/8 66/15 67/3 80/3
80/8 80/13 80/14
80/15 82/5 82/12 87/7
87/10
Jane [2] 139/19
140/21
January [8] 12/12
16/22 16/23 38/23
119/22 122/7 123/15
154/8
Jarnail [1] 125/10
Jenkins [8] 51/12
94/6 94/20 95/12
99/14 104/13 105/5
158/23
Jenkins’ [1] 94/21
JFSA [4] 137/25
141/4 141/17 165/20
Jo [1] 47/11
job [7] 4/2 5/14 27/22
108/3 114/6 114/7
140/22
jobs [1] 163/7
jog [1] 149/16
joined [5] 2/22 2/25
5/3 6/5 16/6
joining [1] 123/25
joint [1] 72/2
jointly [2] 12/15 21/6
Joules [3] 8/6 8/20
8/23
journalist [1] 136/23
journalists [1] 140/3
July [27] 1/1 32/15
33/5 36/16 36/17
39/18 86/21 88/6 88/7
88/13 88/16 89/24
91/4 93/20 94/1 95/4
95/4 95/21 96/3 96/6
96/23 98/6 99/24
105/12 133/13 133/23)
155/10
jump [2] 32/13 42/4
June [8] 14/15 27/25
61/3 71/22 137/11
138/20 138/22 145/18}
June 2014 [1] 138/22
just [113] 4/16 8/1
8/19 11/25 12/1 12/9
12/21 13/2 13/4 17/6
17/10 19/18 20/18
22/11 24/9 28/13
32/10 34/12 34/17
35/23 39/9 40/24
43/19 44/6 45/3 45/6
46/1 46/16 47/7 47/9
48/13 52/1 53/2 53/11
55/11 57/23 58/11
59/18 59/22 60/15
61/12 63/15 63/23
64/14 66/3 66/19
69/11 71/9 71/12
72/18 73/7 74/6 78/1
79/6 79/22 80/20 82/4
83/16 83/23 84/13
85/19 86/17 89/6
92/17 92/25 93/14
96/1 99/22 105/22
107/12 111/12 112/4
114/6 115/2 119/20
119/25 120/12 121/21
122/5 123/12 124/4
124/5 124/11 128/21
129/17 129/17 130/16)
133/2 136/22 137/4
137/24 139/8 139/13
141/20 141/22 144/4
145/3 147/15 147/24
148/19 149/14 151/2
152/1 153/17 155/23
159/9 159/19 159/21
160/22 162/18 162/21
162/25 165/24
justice [1] 164/13
KC [2] 106/14 107/4
keen [1] 88/2
keep [6] 5/12 30/16
31/8 90/13 90/17
148/9
keeping [2] 139/14
140/23
kept [2] 89/24 155/15
Kevin [1] 113/25
key [11] 52/17 65/22
67/1 67/16 67/25 68/7
68/15 68/16 69/3
72/14 140/2
kicking [4] 139/13
King [5] 96/10 96/16
106/4 106/5 106/11
knew [11] 5/17 5/23
5/25 50/12 70/23
76/17 87/22 101/12
122/16 123/21 164/5
know [52] 3/3 9/6
18/14 19/21 19/22
20/10 41/4 41/12 48/6
53/11 55/7 57/25 59/1
60/20 66/19 69/13
73/25 83/6 87/21
87/23 88/3 89/11
93/19 94/21 96/3
98/21 99/10 102/15
102/17 103/6 106/9
107/23 110/4 112/21
113/16 114/1 114/6
116/24 120/13 121/10)
131/14 132/6 134/11
141/24 146/19 147/15)
148/15 151/23 158/22)
159/15 163/8 165/10
knowing [1] 22/21
knowledge [9] 2/3
3/5 15/16 79/8 103/25
119/11 121/25 163/19}
163/21
known [3] 33/22
56/11 102/10
L
lack [4] 39/7 103/23
124/23 146/25
laid [1] 107/24
landed [1] 156/3
language [1] 35/1
large [7] 11/24 20/9
23/9 27/4 33/20 52/12}
153/6
largely [2] 129/7
129/8
larger [1] 118/15
Larissa [2] 64/11
64/12
last [12] 2/17 5/25
20/6 36/25 55/8 55/9
75/6 125/5 127/12
136/2 143/7 152/3
lasted [1] 148/16
late [2] 81/16 166/14
later [11] 13/7 15/6
65/16 86/15 95/7
98/19 102/22 122/7
134/23 148/6 149/8
launched [2] 39/17
93/14
law [3] 107/3 125/11
125/16
lawyer [3] 118/11
125/7 125/9
lawyer's [1] 115/22
lawyers [10] 18/7
87/12 92/4 116/4
118/9 118/12 118/20
125/8 129/24 131/15
layers [2] 106/2
119/4
lead [4] 31/11 32/11
35/1 88/1
leadership [2] 32/10
146/24
leak [12] 136/1 136/7
136/9 136/14 136/21
136/21 136/24 138/14
138/14 138/15 138/17I
138/17
learn [3] 101/10
103/9 116/3
learned [15] 54/3
101/11 114/25 115/2
115/15 115/25 116/1
116/4 116/10 116/14
116/17 116/24 117/10}
118/20 119/1
learnt [5] 15/14 77/5
95/10 101/9 103/10
least [6] 8/9 9/5
38/23 62/24 101/4
125/7
leave [1] 112/11
leaving [2] 8/5 8/16
led [3] 11/20 14/6
157/20
ledgers [2] 78/15
78/25
left [9] 51/24 67/17
67/21 81/3 100/16
108/1 113/19 114/3
148/2
legal [24] 10/15
10/16 10/17 17/13
84/11 87/10 87/11
91/20 105/18 105/23
116/7 116/21 116/22
4117/1 117/8 117/24
118/11 118/18 150/6
150/20 150/22 151/5
155/4 155/5
Legal/Shoosmiths [1]}
10/15
legally [1] 117/14
Lepton [1] 99/15
Les [8] 10/12 10/17
17/3 19/3 19/6 19/7
153/23 154/21
Les' [4] 19/19
Lesley [6] 9/15 10/6
15/9 71/25 72/1
103/15
less [5] 30/20 70/18
73/13 73/15 156/14
Lessons [14] 54/3
114/25 115/2 115/15
115/25 116/1 116/4
116/10 116/13 116/17}
116/24 117/10 118/20
119/1
let [9] 8/10 71/12
73/7 81/9 95/16 98/21
99/10 121/10 147/15
let's [12] 8/19 25/17
32/13 49/11 59/25
74/6 74/18 111/2
131/8 131/8 137/14
138/9
letter [2] 17/12 96/7
letters [2] 10/15 96/7
Letwin [1] 26/1
level [8] 14/11 21/8
21/20 24/3 51/10
107/19 150/23 164/10)
lid [1] 45/18
life [2] 5/24 144/17
light [2] 109/21
163/12
like [27] 6/15 33/20
62/4 64/4 64/4 64/6
89/16 93/14 93/15
95/15 98/21 99/10
99/18 107/15 116/12
116/18 121/6 122/8
134/21 136/25 139/14,
143/24 145/20 152/14I
162/24 164/7 165/25
liked [3] 124/13
162/12 162/13
likelihood [1] 1041/3
likely [7] 29/24 50/1
74/16 101/6 102/12
103/17 132/25
likened [1] 34/5
limit [1] 134/18
limitations [5] 72/12
73/2 73/6 75/2 76/8
limited [11] 3/1 3/4
3/22 4/18 42/6 45/1
75/11 125/9 125/12
134/3 163/6
limiting [1] 86/17
line [6] 25/22 48/22
60/9 126/1 127/13
135/20
lines [4] 16/5 118/7
159/25 160/1
link [2] 34/7 142/12
linkage [1] 64/1
linked [4] 37/20
105/6 106/9 157/13
Linklaters [17] 42/8
42/12 42/13 45/5
47/23 51/3 51/6 51/19)
52/7 52/16 55/16
58/15 69/20 76/3
76/22 77/9 77/9
Linklaters’ [1] 50/19
list [4] 8/1 64/12
71/22 135/20
listed [3] 8/13 8/15
16/24
listened [2] 25/2
61/22
listening [8] 10/25
19/8 32/1 66/14
154/25 162/20 162/25]
165/2
literally [4] 8/24
Litigation [2] 17/8
17/0
little [8] 28/1 34/19
37/16 42/3 45/19
87/22 129/17 155/10
lived [1] 120/15
LL [1] 114/23
load [1] 159/21
local [1] 156/11
logical [1] 49/22
long [9] 20/7 50/13
93/9 93/10 112/19
130/19 131/17 145/23}
148/2
longer [7] 11/17
13/12 13/19 94/6
95/10 134/17 147/20
look [55] 7/22 8/6
8/19 9/9 14/4 14/22
16/19 24/5 25/17
(56) James... - look
L
look... [46] 27/23
36/14 42/1 42/10
49/11 50/3 51/1 55/18)
55/24 56/8 62/12
63/10 64/10 64/19
65/17 67/16 69/14
71/20 74/18 76/19
78/11 91/3 92/19
92/25 94/9 95/24
96/17 106/22 109/14
111/2 114/11 114/20
125/22 125/23 128/18}
129/14 133/8 135/17
135/18 138/10 139/16
139/25 142/24 143/4
145/15 149/6
look-back [1] 95/24
looked [7] 11/10 23/8
23/13 33/14 50/20
147/22 149/13
looking [20] 27/8
27/17 28/13 29/22
30/6 41/25 64/3 76/25
78/24 83/16 125/14
130/11 130/14 134/1
138/10 139/11 145/11
152/14 158/10 158/16}
loose [2] 35/1 95/23
Lord [7] 28/21 31/23
124/16 141/4 164/7
165/8 165/21
Lord Arbuthnot [6]
28/21 31/23 124/16
141/4 164/7 165/21
losing [2] 5/3 135/11
loss [6] 21/11 27/13
29/8 29/14 29/18
45/13
losses [12] 36/21
41/6 45/9 45/12 49/17)
49/18 51/9 51/10
104/6 126/18 129/22
157/8
lost [4] 5/3 27/13
133/19 152/5
lot [19] 6/2 21/22
36/10 50/14 51/14
54/11 69/10 76/10
81/3 105/20 117/13
117/25 134/16 146/18)
146/18 150/8 162/17
162/23 163/4
lots [7] 40/18 76/8
81/23 113/23 127/5
139/7 162/18
loved [1] 99/13
Lovely [1] 148/8
low [1] 140/2
low-key [1] 140/2
lunch [2] 107/7
107/10
lying [1] 107/5
Lyons [5] 45/15
71/22 96/22 97/22
139/17
MacLeod [2] 139/19
140/21
made [22] 11/10
14/17 23/18 35/4
47/20 62/15 64/7
66/16 66/17 75/11
79/15 83/19 90/13
92/18 103/21 105/6
106/9 109/13 111/17
Magic [2] 83/17
83/17
Mail [9] 5/6 31/25
63/13 120/6 125/8
125/19 154/10 154/21
154/21
main [6] 38/12 40/10
65/19 87/4 127/7
146/14
mainly [2] 63/15 97/2
major [1] 20/23
majority [2] 34/20
63/12
make [16] 5/11 7/5
24/8 31/8 31/11 39/14
39/14 51/3 65/4 77/24)
87/20 103/4 127/1
131/19 166/12 166/14)
makes [2] 51/20
133/13
making [4] 28/6
127/23 141/18 166/6
malfunction [3]
42/20 43/2 50/1
malfunctioning [1]
52/19
man [3] 27/1 27/2
164/22
manage [2] 30/21
31/10
managed [2] 93/3
93/15
management [3]
7/12 93/4 146/25
managers [1] 156/24
Managing [2] 2/10
30/22
manpower [1] 26/9
many [11] 12/4 33/13
35/20 57/18 92/10
125/19 127/9 134/12
145/18 150/16 166/6
map [1] 146/6
March [10] 42/4 42/8
43/24 44/8 45/5 51/17
139/17 147/9 147/19
149/8
March '14 [1] 43/24
117/11 140/25 150/16)
margins [1] 93/12
Mark [4] 135/19
135/25 139/19 140/22
marked [1] 147/8
market [1] 146/6
Marks [1] 2/10
Marnoch [2] 96/22
100/4
maroon [1] 166/13
Martin [3] 98/16
100/6 114/2
massaged [1] 151/4
materiality [2] 21/8
21/11
materially [1] 23/24
matter [22] 9/25 22/4
44/9 46/17 49/14 63/3
72/6 73/23 77/21
78/11 78/12 78/21
79/18 80/20 92/10
92/22 102/6 113/21
128/16 128/16 145/15}
147/2
Matter 3 [3] 73/23
78/21 79/18
Matter 5 [2] 78/11
78/12
matters [11] 3/17
4/10 12/21 20/20
31/15 67/16 67/18
73/22 103/25 146/11
148/20
may [35] 12/20 18/19
19/17 22/21 22/22
23/13 25/21 29/18
45/15 59/3 59/4 59/5
62/12 65/15 66/9
75/21 77/6 78/21
81/17 84/1 91/20
91/21 91/25 95/15
101/16 103/14 109/20
117/17 121/7 125/5
131/6 131/25 143/3
143/21 149/15
maybe [13] 3/10 3/25
9/6 20/7 90/21 92/5
131/9 138/9 141/3
148/16 151/21 159/20
160/20
McCausland [14] 1/7
1/9 1/12 1/13 2/5
41/25 84/17 86/12
107/12 109/5 121/21
153/5 166/5 167/2
MD [1] 30/24
me [70] 3/24 4/22
8/10 23/10 25/7 25/15
29/2 38/10 38/11
38/20 39/14 39/14
39/23 39/24 40/21
46/8 46/8 54/4 55/19
60/12 66/16 66/17
67/10 70/13 70/22
71/12 73/7 79/18 80/6
81/9 84/21 85/22
98/21 99/10 100/18
102/1 102/2 102/10
107/3 107/5 110/11
110/12 110/18 110/21
110/25 112/11 120/4
121/10 129/18 129/21
138/15 139/9 140/18
158/23 159/4 165/25
166/13
mean [34] 4/9 7/8
7/15 9/5 30/17 33/9
53/23 54/16 57/22
66/12 69/16 71/4
74/15 87/21 92/10
92/11 95/13 98/5
108/8 113/22 118/13
119/25 122/17 132/5
138/9 141/24 144/10
152/5 164/21 165/11
means [7] 4/20 32/11
54/18 62/23 70/17
110/5 121/9
meant [3] 9/7 30/18
30/20
mechanism [1]
161/12
mechanisms [1]
162/18
mediate [1] 142/4
mediated [2] 137/21
137/22
mediation [36] 42/5
43/6 43/7 43/11 44/8
44/10 45/20 54/3
77/16 77/18 104/8
131/5 133/8 134/11
137/13 137/19 137/21
138/11 139/4 139/6
139/8 139/10 140/18
141/6 141/8 141/10
141/13 141/20 141/23}
142/11 142/14 142/18}
142/21 148/25 149/5
149/20
medium [1] 46/17
meet [2] 16/9 76/2
meeting [108] 11/8
12/11 12/20 13/18
16/7 16/8 16/21 16/23}
19/24 20/6 20/6 20/13}
22/25 22/25 24/22
24/24 25/25 28/5
32/15 32/20 32/22
32/23 33/4 35/2 35/23
46/18 51/1 51/24
55/15 55/25 56/1 60/1
61/9 61/11 61/15
61/17 61/19 64/13
89/19 90/5 90/8 95/16)
132/11 132/23 137/14)
147/23 148/12 149/10)
150/24 153/18 157/20}
40/16 43/8 53/1 53/15
64/18 66/15 67/5 69/2
69/5 69/16 69/17
69/23 80/5 81/6 81/11
81/16 81/18 81/20
84/4 84/20 85/5 85/7
85/12 86/22 88/5 88/8)
88/13 88/18 88/21
89/4 89/7 89/21 89/24
90/2 90/6 90/8 90/18
90/24 91/1 91/18 93/7I
93/13 93/19 95/4
95/21 98/9 98/10
98/12 99/20 100/13
103/3 103/5 103/7
103/12 103/16 105/12!
110/4 113/20 113/25
115/16 126/25 127/1
128/10 128/11 128/12)
128/12 128/14 129/12)
143/2 147/17 147/18
148/11 154/9 155/23
meetings [5] 13/8
25/17 90/16 108/11
163/25
member [4] 88/11
160/1 160/3 160/11
members [13] 39/1
39/4 96/25 113/24
127/3 135/4 140/19
145/18 163/16 164/19}
164/19 164/23 165/4
memory [18] 26/22
27/5 29/1 34/3 34/19
37/16 73/14 73/14
73/20 74/11 101/21
110/17 110/18 130/19)
130/20 148/3 148/9
149/16
mentally [1] 26/21
mention [1] 63/19
mentioned [4] 96/6
96/7 127/12 128/7
mentioning [1]
132/25
merit [1] 107/9
mess [2] 31/5 113/22
message [4] 40/10
44/18 71/24 155/7
messages [2] 147/7
147/21
messy [1] 5/1
met [1] 10/14
method [2] 21/1
126/23
microphones [1]
2/20
middle [3] 14/23
67/18 110/21
might [14] 3/11 15/14
34/21 42/23 46/5
46/20 55/12 63/21
70/10 89/2 105/22
143/17 164/15 165/19)
migrated [2] 115/19
(67) look... - migrated
migrated... [1]
115/20
migration [1] 15/13
Mike [5] 9/15 10/6
25/5 25/13 122/12
million [6] 5/3 21/16
47/2 52/13 52/14
129/22
mind [14] 3/18 11/4
11/22 32/4 34/4 64/2
74/3 80/18 102/1
112/18 112/19 132/16}
133/3 157/5
minute [8] 51/17
61/16 86/17 97/16
119/14 125/24 148/22)
152/4
minutes [32] 20/5
20/7 20/8 20/11 23/6
32/21 51/25 56/5 57/5)
57/12 57/17 59/13
61/18 66/3 70/13
70/17 79/9 80/11
80/14 89/4 89/7 89/20
91/3 96/8 98/14
105/11 128/7 136/2
148/16 151/25 152/7
153/2
miscarriages [1]
164/13
misconduct [1]
129/2
misfunction [1]
151/20
misleading [4] 60/23
61/7 107/5 159/15
misled [1] 158/3
mismatch [1] 156/10
missing [1] 151/2
mistaken [1] 131/24
mistakes [1] 111/17
mitigation [1] 7/17
Mm [1] 152/18
Mm-hm [1] 152/18
modified [1] 6/14
moment [9] 13/2
46/14 88/5 88/24
89/20 101/15 110/7
121/8 133/17
momentarily [1]
166/8
Monday [1] 1/1
money [7] 27/11 29/7
29/24 50/4 126/24
127/8 157/9
monitor [1] 7/6
month [10] 3/11 3/11
3/12 4/6 4/7 4/8 4/10
8/23 8/25 9/1
months [6] 19/6
36/25 44/1 137/10
141/6 142/1
more [68] 4/3 5/25
6/15 9/6 9/25 13/20
20/10 30/20 37/16
39/11 40/2 62/22 64/8
65/25 66/17 69/10
69/14 71/17 71/18
73/21 76/13 82/18
87/21 88/3 102/6
103/5 105/21 107/8
109/5 109/5 109/20
111/10 112/6 112/21
113/1 118/15 127/10
128/5 129/1 129/2
129/19 134/20 135/5
135/9 135/13 135/13
138/7 138/8 138/9
138/10 139/23 140/7
140/9 145/20 148/15
150/6 151/17 156/23
157/25 162/5 162/6
162/15 162/19 162/20)
164/24 165/1 165/5
165/10
morning [18] 1/5 1/7
7/22 41/21 64/21
109/6 109/12 110/11
111/25 112/18 114/14)
120/4 145/25 147/14
153/15 155/14 156/19)
166/12
morphed [3] 14/7
50/5 148/16
most [7] 5/24 29/17
54/4 55/2 103/17
141/2 164/21
motives [2] 118/25
119/3
mounted [1] 100/25
mouth [4] 22/11
move [11] 2/19 9/9
24/5 47/9 59/25 85/24
119/7 155/10 159/9
159/18 160/20
moved [5] 15/12 28/1
101/23 102/2 137/10
moving [4] 41/11
45/5 131/7 164/12
MP [1] 35/1
MPs [5] 27/10 31/24
33/4 137/25 141/4
MPs' [1] 26/5
Mr [34] 1/7 1/10 1/13
2/5 14/9 14/12 16/1
16/5 16/7 20/19 21/9
41/13 41/25 82/12
84/17 85/19 86/12
107/11 107/12 107/17,
108/21 109/5 117/12
121/21 153/1 153/4
153/5 154/14 165/25
166/3 166/5 166/13
167/4 167/6
Mr Clarke's [1]
107/17
Mr Grant [7] 14/9
14/12 16/1 16/5 16/7
20/19 21/9
Mr Jacobs [1] 153/1
Mr James [1] 82/12
Mr McCausland [11]
AIT 1113 2/5 41/25
84/17 86/12 107/12
109/5 121/21 153/5
166/5
Mr Owen [1] 154/14
Mr Parsons [1]
117/12
Mr Stein [1] 165/25
MR STEVENS [8]
1/10 41/13 85/19
107/11 108/21 166/3
166/13 167/4
Ms [4] 31/20 51/20
87/17 154/14
Ms Band [1] 51/20
Ms Crichton [1]
154/14
Ms Vennells [1]
31/20
Ms Vennells' [1]
87/17
much [27] 1/13 3/16
13/1 31/6 39/25 63/25
73/4 87/23 94/21
98/25 107/8 109/3
117/3 118/7 124/14
126/21 127/1 130/4
130/12 131/19 141/22
142/2 148/4 150/24
151/17 162/13 166/5
multitude [1] 12/4
must [1] 72/13
mute [1] 152/2
mutual [4] 162/8
162/11 162/13 162/14
mutualisation [1]
160/13
my [76] 3/9 6/2 9/9
10/23 11/4 11/22
13/18 23/19 26/22
27/5 29/1 29/9 32/4
32/21 33/15 34/4
34/19 37/15 41/4 41/6
43/22 44/13 44/15
47/2 49/9 67/15 70/11
71/16 73/14 73/20
74/3 77/4 82/24 83/8
85/17 85/20 94/3
101/21 102/1 102/3
103/24 104/23 109/25}
110/17 110/18 110/18}
110/23 110/23 110/23
110/24 112/11 112/18}
112/18 113/13 114/8
114/16 118/12 129/6
131/13 132/2 132/15
137/9 144/17 147/22
148/2 148/12 150/8
154/9 157/5 162/3
162/5 164/12 164/13
165/23 166/8 166/13
myself [6] 43/7 96/21
97/20 127/3 129/6
152/13
N
name [4] 1/11 23/19
94/21 95/12
namely [2] 123/2
132/9
narrow [2] 41/8
118/25
narrowed [1] 118/21
nature [2] 67/19
95/24
Navy [1] 2/14
near [2] 5/23 162/12
nearby [2] 121/9
121/12
necessarily [3] 6/16
29/22 127/20
necessary [2] 127/17
127/19
NED [3] 53/13 83/10
143/22
NEDs [15] 3/24 4/2
36/3 36/10 53/11 83/7
83/8 83/12 102/10
130/18 130/19 130/20}
134/1 134/4 165/12
NEDs' [4] 131/13
need [39] 4/13 4/23
7/4 20/24 24/6 26/6
34/14 41/8 41/9 51/20)
55/4 55/16 59/25
65/16 69/14 79/24
87/1 93/4 97/10 99/2
99/9 100/18 101/16
102/7 103/18 109/8
117/23 119/9 119/21
129/5 131/15 132/16
133/2 140/11 144/8
151/14 158/12 158/16
162/10
needed [31] 5/8 5/10
7/5 11/15 21/25 30/25
31/5 40/15 52/5 60/10)
62/7 70/23 73/16
73/18 74/2 76/11
92/14 95/14 96/11
96/12 102/5 103/4
104/20 118/19 125/3
138/13 140/16 142/19)
151/19 151/19 163/4
needing [3] 13/12
14/2 14/5
needs [6] 47/21
48/13 68/9 69/11
71/18 80/1
neglected [1] 149/14
NEIL [11] 1/9 1/12
25/10 28/3 98/21 99/8)
109/18 111/9 112/6
114/15 167/2
neither [3] 16/10
60/24 157/5
nervous [2] 127/14
127/24
nervousness [2]
144/15 144/16
net [3] 129/25 129/25
129/25
network [5] 5/5 32/23)
34/21 114/2 165/3
never [10] 9/7 81/6
82/20 89/15 112/12
112/14 120/12 123/12)
128/4 135/15
new [16] 6/3 6/16
13/21 13/22 19/1
30/22 76/21 77/20
87/9 95/14 101/4
101/16 102/5 125/15
132/9 132/16
next [20] 35/25 68/15
68/16 69/3 82/21
82/22 84/4 85/4 85/7
85/11 85/17 87/15
90/23 98/23 99/20
99/20 128/12 134/24
135/24 155/25
nicest [1] 164/21
Nick [1] 114/2
no [88] 3/5 3/5 10/20
13/15 13/16 14/12
15/16 16/7 16/16 17/3)
18/12 18/18 25/1
25/14 30/10 31/14
32/5 32/24 33/5 33/23
34/18 35/10 37/22
38/3 38/12 40/8 41/13}
45/12 47/13 47/17
47/24 48/20 48/23
52/16 53/13 55/14
55/14 56/18 56/19
57/22 58/16 59/25
67/22 76/13 76/24
79/7 83/10 83/11
90/15 90/21 91/7
92/18 92/21 92/24
94/6 95/10 95/19
97/13 99/2 102/8
103/25 106/8 108/18
113/18 118/11 119/2
119/5 119/11 119/21
124/2 125/17 127/23
133/2 133/6 136/14
137/16 141/13 141/17)
141/18 142/22 147/12!
152/12 154/5 154/17
156/6 157/15 159/12
166/1
nobody [2] 123/16
150/19
nodded [1] 65/8
Nominations [2]
(58)
migrated... - Nominations
N
Nominations... [2]
151/9 151/11
non [20] 2/21 7/25
8/2 8/12 8/22 54/12
57/9 62/16 88/10 90/3,
90/6 107/13 107/15
122/14 143/1 143/19
144/13 145/20 150/1
151/6
non-execs [2] 90/6
151/6
non-executive [8]
2/21 7/25 8/2 57/9
90/3 122/14 143/1
144/13
non-IT [1] 54/12
non-traceable [1]
62/16
nonetheless [2]
85/13 166/9
nonsense [1] 113/16
nor [4] 16/10 56/21
68/12 157/5
normal [3] 90/20
125/20 162/5
Normally [1] 27/3
North [1] 135/22
not [233]
note [17] 14/17 14/18
14/20 47/16 98/16
108/10 109/20 109/25)
110/7 110/14 111/2
111/15 111/23 112/23
112/24 114/17 119/20}
noted [4] 47/13 67/22
91/4 100/22
notepad [1] 14/19
notes [8] 70/11 70/12
106/14 106/24 111/3
111/10 111/13 112/6
nothing [6] 31/15
42/24 113/17 149/13
158/21 164/14
notice [3] 32/24
34/18 109/24
noticing [1] 152/11
November [9] 20/14
102/24 103/4 103/7
103/13 120/2 126/1
132/15 133/1
now [46] 15/6 16/19
17/6 17/22 19/21
19/24 20/1 22/5 32/19)
37/12 42/1 44/2 45/5
47/23 50/5 59/7 60/12)
61/2 61/14 64/21 65/9
67/3 67/8 67/12 74/19
79/9 86/13 86/13
93/19 99/13 105/1
106/22 107/12 109/14}
110/11 112/4 119/7
125/22 137/9 144/22
159/3 159/15 161/3
nowhere [3] 44/21
154/9 162/12
number [12] 2/21
37/5 49/5 54/2 72/12
91/19 104/21 105/14
135/19 138/3 153/6
162/14
numbers [2] 91/25
129/21
{e)
oath [1] 94/18
objective [11] 47/17
47/24 48/15 48/17
58/16 76/2 134/19
obligation [3] 84/18
84/18 84/21
obliged [1] 117/18
obtain [1] 52/9
obtained [1] 118/18
obtaining [1] 126/24
obvious [1] 49/22
obviously [4] 49/16
82/10 128/7 138/22
occasionally [1]
33/21
occurrence [1] 37/9
off [9] 21/24 59/9
79/12 83/23 100/18
132/2 140/23 141/22
166/8
offer [2] 161/13
165/2
office [115] 2/22 2/25
3/4 3/7 3/15 3/15 3/17
3/20 3/21 3/22 4/1
4/10 4/18 4/21 4/22
4/25 6/5 6/7 8/3 9/3
9/8 10/13 12/15 12/17)
14/19 14/24 16/6 21/6
27/2 31/5 31/21 36/25
36/25 37/8 42/6 44/25
45/9 45/11 45/17
46/13 46/25 48/23
51/8 52/13 56/25 58/5
58/7 58/12 65/20 68/6)
70/4 75/11 75/22
75/23 79/2 93/16
100/22 102/24 106/6
107/16 113/22 117/17)
120/21 122/7 123/14
123/20 123/24 124/9
125/9 125/11 125/16
125/19 126/6 126/15
127/18 127/20 127/22)
136/10 140/19 140/23)
141/7 141/17 142/1
142/3 142/13 143/11
148/1 148/2 148/3
148/13 148/14 148/24)
153/12 153/20 155/7
146/20 152/10 152/14,
50/20 52/24 53/5 55/4)
158/1 158/4 158/6
158/7 159/11 159/14
159/24 160/14 160/24
161/9 161/10 161/13
161/16 161/19 161/24]
161/25 164/5 164/16
164/25 165/7
Office's [8] 6/25
12/13 47/15 49/16
122/1 122/6 128/9
142/7
Officer [1] 9/15
offices [2] 5/19 40/18
offs [1] 149/3
oh [4] 71/16 91/7
102/3 152/1
okay [17] 13/5 17/23
23/8 29/14 31/4 38/16
40/21 43/7 61/11
79/21 86/19 95/15
108/21 131/13 132/3
132/22 145/2
old [12] 5/5 5/18 5/24
29/3 41/7 59/3 63/13
63/17 64/5 101/22
102/1 102/7
Oliver [1] 26/1
on [270]
once [4] 23/14 79/7
83/7 83/9
one [54] 6/24 8/24
12/23 13/5 13/25 14/8
15/12 16/22 17/17
18/15 23/24 25/17
30/5 38/16 45/22 46/9
46/23 46/23 47/4 47/5
49/8 49/19 50/6 51/3
54/4 58/18 58/18
59/18 70/25 73/22
79/18 80/10 87/4
92/11 92/25 100/2
115/9 116/12 117/11
125/7 126/13 127/5
127/6 128/16 133/13
134/25 147/2 151/10
153/1 156/12 158/1
162/7 162/21 165/18
ones [3] 8/19 19/4
147/22
ongoing [3] 86/16
117/20 124/7
online [14] 6/8 6/9
6/12 13/21 15/13
15/17 37/2 56/9 56/23)
63/17 64/4 65/23
77/20 156/9
only [17] 26/20 32/21
39/15 47/5 67/22 68/4
70/11 70/12 74/4 79/6
120/6 137/14 142/15
148/19 149/2 149/15
153/1
onto [1] 32/23
onwards [4] 49/11
96/3 105/10 149/24
Oof [1] 89/16
open [3] 59/9 126/19
139/13
opened [1] 91/13
opening [1] 162/25
operate [1] 108/6
operation [4] 68/23
120/21 121/23 123/1
operational [1] 65/25
opinion [3] 110/24
115/22 135/1
opportunities [1]
91/11
opportunity [2] 63/16)
157/24
opposed [1] 30/1
option [12] 129/7
129/8 129/11 131/8
131/9 131/10 131/14
131/18 131/23 131/25}
132/2 132/4
Option 2 [2] 131/25
132/4
Option 3 [1] 129/7
options [2] 128/21
128/22
or [137] 3/10 3/21 4/7
7/15 8/17 9/18 10/6
12/5 14/13 15/19
16/13 17/19 18/25
20/2 20/7 21/14 22/21
22/22 24/11 24/15
25/19 29/20 32/5 32/6
32/9 32/10 34/1 36/5
36/22 38/6 38/21 40/2,
42/19 43/2 44/23
46/15 47/20 50/11
52/24 52/24 53/23
54/5 55/4 55/8 55/13
55/22 56/20 57/21
60/14 61/15 64/25
67/8 68/13 68/21
69/12 70/5 71/2 72/19)
72/20 73/1 74/24
74/25 T5IT 75/13
75/25 76/9 76/21
79/10 79/16 82/11
83/9 83/24 88/11
91/18 91/20 92/4
93/25 94/11 95/6
95/24 97/22 98/2
98/22 99/11 99/20
100/2 101/10 101/18
102/10 102/13 102/13}
103/13 103/15 103/15}
103/21 103/22 107/5
108/10 108/10 109/12}
113/11 113/12 117/17)
119/13 120/10 120/25)
122/11 123/21 124/10}
124/12 124/20 126/24}
127/21 133/23 134/1
134/2 135/15 135/15
135/16 138/25 139/1
139/11 141/17 141/18)
141/20 146/22 147/21
150/9 150/20 150/21
154/10 154/13 154/15}
156/24 158/9 159/1
164/7
oral [2] 1/15 60/13
orally [1] 95/18
orange [1] 42/24
order [3] 21/24 42/3
142/20
organisations [1]
66/8
origin [1] 144/8
original [4] 29/3 48/2
77/13 117/3
originally [3] 50/5
120/18 159/11
other [36] 1/24 3/15
4/2 6/24 8/12 8/12
20/2 20/2 34/7 36/11
36/12 56/20 66/8
67/22 76/14 76/25
77/2 89/25 96/25
100/9 103/13 106/17
113/23 120/15 123/17
124/4 124/24 128/8
133/11 135/4 144/19
145/4 145/7 146/20
151/3 160/25
others [7] 36/11
52/16 135/6 135/10
139/18 154/16 161/5
our [25] 10/25 11/7
14/3 14/4 28/8 36/24
41/7 41/10 52/18
65/19 87/12 87/24
97/5 106/18 106/20
109/18 110/4 111/9
123/11 124/13 124/24)
131/6 136/7 146/1
157/24
ourselves [5] 77/19
112/13 116/5 130/18
131/15
out [55] 5/6 6/7 6/9
7/10 7/25 15/9 19/9
20/20 21/1 23/7 33/24
35/17 35/18 35/25
36/15 39/15 40/23
42/3 46/21 51/7 54/2
56/11 61/13 61/19
61/20 61/23 72/15
81/18 87/10 88/16
89/24 90/14 90/18
95/3 99/16 102/16
107/24 112/22 114/21
115/3 116/17 117/10
120/2 137/8 138/2
138/18 138/25 139/5
139/11 139/18 140/3
144/24 149/15 155/25)
159/4
(69) Nominations... - out
[e)
outcome [2] 31/21
133/20
outlining [1] 143/5
outside [6] 24/23
52/7 83/24 97/21
108/1 113/20
over [25] 21/15 23/17)
24/4 30/23 33/22
34/23 35/12 35/20
36/25 37/4 43/1 74/4
75/9 82/11 91/5 94/12
113/15 114/4 131/16
135/9 140/2 146/1
146/2 152/11 155/20
overall [4] 28/24
65/10 66/6 113/10
overemotional [1]
113/14
overlap [1] 8/9
overlapped [1] 8/17
overlay [1] 20/25
overloaded [1] 131/5
overly [7] 39/10
39/14 41/8 66/17 71/6
71/10 72/24
overran [1] 90/22
overrun [1] 11/21
oversaw [1] 105/9
oversee [1] 123/7
overseeing [5] 7/15
24/16 122/18 125/15
142/10
oversight [14] 86/16
92/15 103/24 103/24
105/10 119/7 121/2
122/2 122/17 122/20
123/3 123/23 141/11
149/23
overturn [2] 142/16
142/20
Owen [5] 10/12 17/3
19/3 153/23 154/14
owing [1] 45/10
own [14] 5/7 5/8 5/9
13/13 87/24 120/7
123/3 123/11 123/15
123/18 127/18 127/20}
130/21 134/13
owned [1] 2/13
Pp
pack [5] 57/6 57/7
57/12 94/2 100/6
package [1] 40/14
Paddington [1]
147/16
page [67] 1/20 4/15
7/24 9/12 11/25 12/1
12/8 16/25 20/18
25/22 26/7 27/24
34/23 36/19 37/4 38/1
38/1 42/10 45/6 47/10
49/11 51/19 56/4 56/8)
60/5 60/17 61/12 65/4
65/4 67/16 67/20 72/3
74/19 75/9 77/21
78/11 87/2 87/3 91/5
91/8 94/9 94/12 96/18)
98/15 100/16 100/20
103/18 111/8 111/14
112/3 115/8 117/11
126/4 126/4 126/12
126/12 128/19 128/20)
129/5 135/18 140/2
140/5 140/12 143/4
147/6 149/7 159/20
page 1 [2] 111/14
140/5
page 14 [1] 159/20
page 2 [6] 45/6 51/19
65/4 87/3 115/8
128/19
page 3 [9] 4/15 47/10
74/19 96/18 111/8
112/3 117/11 126/4
128/20
page 36 [1] 26/7
page 4 [6] 7/24 20/18
56/8 100/20 126/12
143/4
page 46 [1] 56/4
page 5 [2] 36/19
67/16
page 59 [1] 129/5
page 6 [4] 16/25 60/5
61/12 91/8
page 62 [1] 42/10
page 67 [1] 140/12
page 68 [2] 11/25
94/9
page 7 [1] 77/21
page 71 [1] 103/18
page 75 [1] 60/17
page 76 [1] 1/20
page 8 [3] 9/12 25/22
38/1
page 9 [1] 49/11
pages [2] 20/7 70/17
paid [1] 46/19
pains [1] 40/23
paper [24] 3/13 37/22
64/16 88/15 89/22
89/24 90/1 92/3 99/24)
100/6 100/7 100/17
102/17 106/10 108/9
108/15 126/7 130/8
132/13 132/13 132/14)
132/15 132/20 133/1
papers [12] 34/18
35/11 35/23 70/15
88/19 100/15 130/6
143/9 143/12 144/7
144/9 155/23
paperwork [4] 13/13
132/5 148/3 149/18
paragraph [37] 1/21
4/15 7/4 7/24 7/25
9/12 11/25 24/7 24/14
26/7 36/23 42/11 45/7
45/17 47/10 49/11
50/15 56/4 60/18
61/13 65/17 66/6
93/24 94/4 94/10
100/20 103/19 109/9
111/16 112/10 119/10}
126/12 129/4 140/12
159/19 159/22 159/23
paragraph 1.4 [1]
45/7
paragraph 100 [1]
24/14
paragraph 110 [1]
93/24
paragraph 125 [1]
56/4
paragraph 146 [1]
109/9
paragraph 157 [1]
129/4
paragraph 166 [1]
42/11
paragraph 17 [1]
9/12
paragraph 178 [1]
140/12
paragraph 181 [2]
11/25 94/10
paragraph 186 [1]
103/19
paragraph 199 [1]
94/4
paragraph 2.3 [1]
47/10
paragraph 200 [1]
60/18
paragraph 203 [1]
1/21
paragraph 34 [2]
159/19 159/22
paragraph 36 [1]
24/7
Paragraph 4.5 [1]
100/20
paragraph 5.30 [1]
49/11
paragraph 5.32 [1]
50/15
paragraph 55 [1]
119/10
Paragraph 6.4 [1]
36/23
paragraph 7 [2] 4/15
7/4
paragraph 9 [2] 7/24
7/25
paragraph 99 [1]
26/7
paragraphs [1] 24/8
paragraphs 98 [1]
24/8
paranoid [1] 149/10
Parliamentary [1]
47/11
Parsons [3] 114/23
115/9 117/12
part [39] 5/14 34/6
34/7 45/13 49/8 50/6
50/7 56/12 56/14
56/16 56/24 57/21
58/7 58/22 58/24
58/24 58/25 58/25
59/2 59/4 59/8 59/10
59/15 59/16 65/16
69/18 69/22 76/17
93/21 94/2 103/24
125/7 125/11 125/12
132/7 135/23 139/1
143/7 162/16
Part 1 [6] 56/14
56/24 58/24 58/25
59/10 76/17
Part 2 [9] 56/16
57/21 58/25 59/2 59/4)
59/8 59/15 59/16
139/1
Part Two [1] 135/23
Participants [3]
107/9 151/24 153/8
particular [4] 70/22
117/21 148/23 151/6
particularly [11] 6/17
6/18 42/19 42/24
71/19 74/11 76/9
102/3 127/2 156/16
161/24
partly [4] 13/20 13/21
93/11 150/19
partner [5] 9/14 14/9
20/16 83/18 83/20
parts [5] 2/8 56/10
58/24 59/17 125/15
party [13] 10/20 54/3
68/12 68/18 104/8
134/10 139/7 141/1
141/2 141/23 149/1
149/5 149/20
pass [2] 16/13
117/19
past [25] 47/22 63/21
64/1 87/6 87/14 87/16
88/1 88/11 88/25
92/19 95/22 95/24
96/4 96/10 96/12
96/13 101/20 104/9
104/12 104/21 104/24}
124/5 124/9 124/11
124/20
pathway [1] 160/13
Paula [55] 25/24
26/16 27/25 28/18
30/21 30/22 30/22
31/4 31/6 32/17 35/11
37/19 39/13 46/8
46/11 83/25 86/21
90/1 93/12 103/15
109/16 110/14 110/20)
110/21 110/24 111/4
111/24 112/16 112/21
113/13 114/6 114/14
115/12 122/12 122/22)
122/25 126/2 128/9
131/2 145/19 145/23
146/10 146/19 147/5
147/8 147/14 147/23
148/7 148/10 148/12
149/9 149/18 157/5
157/11 157/20
Paula's [4] 132/3
145/24 157/3 162/16
paused [2] 131/11
131/12
pausing [15] 13/11
17/6 28/11 43/15
48/13 50/2 50/10
76/12 82/4 116/16
124/7 126/22 136/9
141/9 148/19
pay [4] 45/18 46/10
46/14 47/5
paying [6] 51/9 52/13)
138/6 138/9 138/10
138/11
payments [4] 46/15
47/3 52/16 156/10
peeled [1] 119/4
peers [1] 150/8
pensions [1] 20/24
people [34] 27/3
29/12 43/6 43/10
43/15 43/16 44/16
48/3 53/10 70/18
79/23 84/9 85/13
90/20 118/2 120/6
124/25 125/20 134/15)
135/19 138/7 138/8
138/8 138/10 139/7
141/3 141/19 142/2
162/23 162/24 162/24)
163/5 163/25 164/7
per [7] 8/4 25/12 84/5
92/5 92/6 92/6 102/9
percentage [1] 92/11
perception [1]
126/14
perfect [2] 84/9
110/17
perfectly [6] 25/6
25/15 127/21 150/21
154/17 156/7
perform [1] 145/14
performance [6] 7/6
145/24 145/25 146/1
146/3 146/4
performed [5] 65/13
68/1 68/1 68/4 68/11
period [5] 24/4 93/13
102/19 104/18 104/19)
Perkins [24] 3/3
(60) outcome - Perkins
Pp
Perkins... [23] 14/14
16/13 24/19 24/24
25/25 36/5 36/7 62/1
89/3 89/25 90/13 93/7
95/6 95/9 98/8 98/18
100/2 118/15 129/6
131/22 133/22 135/2
135/11
Perkins’ [2] 15/25
133/12
person [3] 46/6 78/4
132/18
personally [4] 43/3
123/9 134/5 150/11
persuade [1] 112/15
phantom [2] 62/21
69/24
Phase [2] 66/25
70/20
Phase 1 [2] 66/25
70/20
phone [9] 34/12
34/13 34/17 35/12
36/9 39/18 108/8
108/11 147/22
phrase [1] 62/22
physical [1] 5/18
pick [3] 2/20 74/6
151/4
piece [16] 3/13 34/19
52/6 52/9 52/22 52/23
53/4 55/20 76/8 81/13
92/2 106/10 108/8
117/9 127/10 138/5
pieces [6] 108/4
108/6 108/12 108/14
151/14 151/3
place [17] 10/10
13/23 23/1 23/7 23/11
23/18 63/12 65/22
67/14 73/4 81/12 82/2
84/6 90/6 122/18
122/21 165/7
places [1] 5/20
plan [6] 23/2 23/18
28/6 57/20 162/6
162/7
planning [1] 22/25
plate [1] 124/24
players [1] 149/16
please [114] 1/11
1/20 2/20 4/24 7/24
9/11 11/6 11/25 12/1
14/18 14/22 16/25
17/1 20/12 20/18
20/19 24/5 25/19
25/23 27/23 27/24
28/16 32/14 32/17
34/23 36/14 36/19
41/15 42/10 45/4 45/6
47/10 49/11 51/2
51/20 55/18 55/24
56/8 60/1 60/5 60/6
60/18 61/12 61/12
61/13 64/10 64/11
64/15 65/4 66/5 66/22
66/24 67/16 67/20
71/21 71/24 72/3
74/18 77/21 78/11
86/3 86/20 87/2 91/3
91/6 91/8 94/9 94/13
94/14 96/17 96/18
96/19 96/20 96/24
97/8 98/15 98/17
98/21 99/10 100/12
100/16 100/20 101/24)
109/15 111/2 111/8
111/13 111/15 112/3
112/5 114/20 114/22
115/8 117/11 125/24
126/3 126/12 128/18
128/20 128/21 133/9
133/12 135/17 135/18)
139/16 140/5 140/6
143/2 147/5 147/7
148/1 149/6 149/7
159/22
pleased [2] 43/4
104/5
pleasure [1] 28/18
pm [9] 86/6 86/8
108/24 109/1 121/14
121/16 152/20 152/22)
166/18
PO [1] 111/21
POAC [11] 160/6
160/8 160/12 160/19
162/21 163/5 163/9
163/17 163/23 164/18
164/19
pocket [1] 33/24
point [65] 2/25 7/5
12/11 16/3 17/7 17/16
18/17 24/20 24/21
28/23 36/8 36/16
38/12 40/23 42/4 45/4
45/20 47/7 47/22
48/24 50/18 51/22
53/9 53/20 55/8 55/10)
56/10 59/8 62/9 62/24
65/7 75/6 77/13 82/10
87/8 88/8 88/24 92/25)
94/15 95/5 97/9 99/3
99/22 100/10 101/10
102/11 105/17 105/19)
116/8 117/13 122/22
124/8 130/3 130/12
130/22 130/25 134/1
135/9 137/1 137/6
138/20 138/24 156/24}
159/14 164/11
pointed [1] 87/10
pointer [1] 2/25
pointing [1] 120/24
pointless [1] 81/22
points [14] 24/9
42/19 43/2 50/1 50/9
54/25 56/23 59/13
69/3 85/3 92/17
117/11 133/13 161/7
POL [7] 8/5 19/24
30/25 120/6 130/21
144/5 156/24
POL00021430 [1]
20/12
POL00021503 [1]
16/22
POL00021507 [2]
25/20 143/2
POL00021515 [1]
32/14
POL00021523 [1]
51/2
POL00021524 [2]
60/1 61/12
POL00027514 [1]
91/3
POL00029733 [1]
71/21
POL00030900 [2]
100/13 128/18
POL00038678 [1]
125/24
POL00096642 [1]
27/23
POL00099026 [1]
86/20
POL00101325 [1]
135/17
POL00102370 [1]
139/16
POL00105635 [1]
66/22
POL00107317 [1]
45/4
POL00130412 [1]
36/15
POL00130618 [1]
7419
POL00145891 [2]
96/17 133/9
POL00146244 [1]
114/12
POL00148075 [1]
55/24
POL00228475 [1]
160/21
POL00304159 [1]
64/10
POL00304160 [1]
64/20
POL00381628 [1]
109/16
POL00381629 [1]
111/3
police [1] 120/10
policy [7] 100/17
119/8 125/23 126/10
128/25 129/1 130/9
poor [3] 14/13 39/17
148/3
pored [1] 23/17
position [12] 30/22
42/22 52/24 53/1 69/8
76/22 110/18 131/24
156/13 156/13 156/14}
156/15
positive [9] 10/19
18/4 32/19 74/4 74/8
78/21 91/11 106/19
155/3
possible [9] 18/7
25/2 25/6 35/5 37/24
48/6 59/5 59/5 87/6
possibly [1] 64/17
post [125] 2/22 2/25
3/4 3/7 3/14 3/15 3/17,
3/20 3/20 3/22 4/1
4/10 4/18 4/21 4/22
4/25 5/18 6/5 6/7 6/25)
8/3 9/3 9/8 10/13
12/12 12/15 12/17
14/19 14/24 16/6 21/6}
27/1 31/4 31/21 36/25)
36/25 37/8 40/17 42/5)
44/25 45/9 45/11
45/17 46/13 46/25
47/15 48/23 49/16
51/8 52/13 56/25 58/5)
58/7 58/12 65/20 68/6
70/4 75/11 75/22
75/23 79/2 90/10
93/15 100/22 102/24
106/6 107/15 113/22
417/17 120/21 122/1
122/6 122/7 123/14
123/20 123/24 124/9
125/8 125/11 125/16
125/19 126/6 126/14
127/18 127/20 127/22)
128/9 136/10 140/19
140/23 141/7 141/17
141/25 142/3 142/7
142/12 143/11 147/25)
148/2 148/3 148/12
148/14 148/24 153/12
153/20 155/7 157/25
158/4 158/6 158/7
159/11 159/14 159/24)
160/14 160/24 161/9
161/10 161/13 161/16)
161/19 161/24 164/5
164/16 164/25 165/7
post-brief [1] 90/10
posted [1] 148/9
potential [10] 46/13
52/12 53/18 68/8
68/15 68/16 69/3
128/17 138/25 161/20}
potentially [3] 59/2
68/24 87/4
practical [1] 102/6
practice [4] 4/9 53/17I
60/10 84/22
pragmatic [3] 45/22
46/6 46/23
praise [1] 140/19
pre [6] 63/7 63/10
63/20 76/15 90/6 90/9
pre-2010 [3] 63/7
63/10 63/20
pre-Board [1] 90/6
pre-existing [1]
76/15
precisely [1] 113/9
precursor [1] 103/2
prepare [2] 35/5
162/7
prepared [2] 58/13
93/20
present [11] 16/24
25/22 32/16 51/18
52/2 60/2 88/6 120/17
124/20 126/1 153/16
presentation [1] 82/5)
presented [5] 33/4
35/13 106/23 138/23
156/21
Preserving [1]
128/23
presided [1] 30/23
press [1] 140/9
pressure [1] 140/23
presumably [12]
6/24 9/21 14/19 28/21
28/23 43/15 50/23
51/25 62/9 62/19 64/7
94/20
pretty [6] 13/1 31/6
61/24 102/15 102/17
142/2
Prevent [1] 78/4
previous [8] 5/1
10/21 21/10 85/3
97/16 132/10 153/19
155/2
previously [5] 26/13
77/4 80/2 101/22
106/10
price [1] 14/25
primarily [2] 22/10
54/14
primary [1] 67/4
prime [2] 122/10
122/23
principle [2] 49/14
49/25
prior [2] 94/1 112/11
private [3] 17/5
109/20 110/6
privilege [1] 117/13
privileged [3] 18/8
78/4 117/14
pro [1] 132/6
pro tem [1] 132/6
proactively [1]
117/18
probably [40] 8/25
(61) Perkins... - probably
Pp
probably... [39] 10/9
10/23 11/3 15/14 22/8)
23/13 29/24 38/19
41/10 44/1 48/20 54/4
61/18 62/21 80/23
85/18 85/23 94/25
98/18 99/2 103/12
103/15 103/16 107/7
110/20 114/8 122/10
122/12 124/4 130/24
134/19 134/20 135/9
146/3 150/23 151/16
156/18 156/20 165/23}
probing [1] 7/8
problem [22] 15/24
29/13 29/15 30/3 30/8
30/10 33/11 34/8 40/6
43/5 43/9 44/23 47/14)
57/20 58/19 124/22
156/10 156/11 157/18)
158/9 159/5 165/17
problems [18] 23/17
23/19 27/15 27/19
29/21 37/23 38/4
38/13 44/11 60/25
117/22 150/15 157/16
158/12 158/19 165/14}
165/15 165/16
Procedure [1] 117/18
Proceedings [1] 1/3
process [18] 30/16
30/17 30/20 31/12
31/17 31/20 32/9
36/13 68/3 85/10
93/15 119/11 136/8
137/5 138/16 138/16
142/14 142/21
processed [1] 78/14
processes [3] 63/20
75/18 117/17
processing [2] 56/15
65/24
produce [2] 50/16
58/13
produced [1] 89/23
product [1] 71/20
profile [1] 68/23
profit [4] 21/11 31/1
32/9 46/24
profitability [5] 5/2
5/11 30/24 31/13
31/16
Programme [7] 54/5
54/6 54/21 54/24
104/9 131/4 149/1
progress [4] 31/8
31/11 115/17 155/16
Project [3] 55/25
60/20 66/25
prompted [1] 88/15
proof [1] 45/8
proper [7] 29/5 35/22
35/22 35/23 48/10
155/22 155/23
properly [2] 32/11
155/16
proposal [1] 138/21
propose [1] 21/12
proposed [1] 26/16
prosecute [1] 131/17
prosecuted [1]
164/14
prosecuting [2]
105/2 122/1
prosecution [14]
19/15 91/14 92/13
119/8 119/12 120/12
120/18 122/21 125/4
127/21 127/22
prosecutions [83]
10/21 63/12 63/22
63/25 64/2 86/16
86/17 87/6 87/16
87/22 87/24 88/1
88/12 88/17 88/22
88/25 89/9 89/14
91/20 92/1 92/19
95/22 95/25 96/4
96/11 96/14 101/14
101/20 104/10 104/12)
104/17 104/21 104/24)
105/4 106/6 106/11
117/20 119/8 119/15
119/17 119/19 119/23)
120/7 120/8 120/14
120/20 121/2 121/22
122/19 123/2 123/7
123/10 123/12 124/6
124/7 124/9 124/11
124/11 124/20 125/22)
126/6 126/10 126/15
126/23 127/15 127/18)
127/23 128/4 128/25
129/1 129/20 129/22
130/17 130/21 130/23)
131/11 131/12 131/20)
132/9 149/4 149/24
153/19 155/2
prosecutor [2] 122/6
122/9
prosecutorial [9]
102/24 119/16 120/3
126/7 128/10 128/24
129/3 151/20 158/19
protect [1] 77/23
protection [1] 73/25
provide [6] 20/2
87/14 160/24 161/8
161/12 161/18
provided [12] 12/3
40/3 64/17 68/5 68/20
93/22 94/2 101/19
103/21 103/22 106/14)
147/7
provides [2] 68/3
100/17 105/13 105/16)
78/13
providing [2] 1/13
109/19
provision [2] 65/20
163/25
pry [1] 148/21
published [2] 2/6
17/11
pulled [1] 77/7
pulling [1] 76/13
purpose [6] 12/6
57/1 95/23 141/13
147/18 160/23
purposes [2] 68/13
68/14
pursue [1] 124/10
pursued [1] 101/15
pursues [1] 120/20
pursuing [3] 124/10
127/18 129/1
pushback [2] 25/4
25/9
put [17] 21/10 22/41
45/18 46/11 47/7 69/7
77/13 94/22 98/22
99/16 106/12 112/12
116/5 128/22 131/2
138/4 152/8
putting [2] 141/23
142/18
PV [4] 111/3
PVEN00000015 [1]
149/6
PVEN00000362 [1]
147/16
Qo
qualified [1] 68/11
quality [4] 15/1 15/15
15/18 75/7
quality/assurance [1]
15/1
quantum [1] 37/6
query [1] 42/7
querying [1] 26/7
question [15] 16/1
19/19 19/22 45/13
49/17 49/18 56/21
59/9 71/12 81/9 91/22
107/13 125/5 140/13
157/23
Questioned [4] 1/10
153/4 167/4 167/6
questioning [8]
11/11 11/12 11/13
26/23 40/2 127/2
129/16 138/21
questions [26] 2/8
3/16 18/24 57/16
73/16 73/18 74/1 74/5
79/24 81/3 83/5 83/24
85/18 85/21 89/8
107/8 113/1 123/6
127/5 127/6 149/22
151/22 151/23 153/1
165/23 166/7
quickly [1] 39/22
quite [21] 3/8 12/23
23/23 25/1 43/13
58/22 58/23 101/11
102/11 116/7 117/25
132/5 145/8 150/13
150/13 150/17 150/18
153/10 156/12 156/13}
162/12
quo [1] 128/23
quoted [1] 46/1
quoting [1] 155/24
R
radar [1] 83/23
radio [4] 136/2
136/17 136/21 136/21
Radio 4 [3] 136/2
136/17 136/21
raise [3] 4/16 16/13
70/22
raised [8] 16/1 39/5
55/3 55/5 69/3 97/23
111/16 111/19
raising [1] 38/9
ran [4] 122/11 122/12
122/23 143/23
ranging [1] 52/13
rare [2] 90/24 144/24
rarely [1] 57/16
rate [2] 138/5 138/5
rather [15] 6/20 10/1
14/5 27/17 28/9 28/12)
28/14 28/24 53/6
77/16 111/5 126/15
130/4 136/19 138/5
reaction [2] 113/13
140/9
read [48] 36/16 37/18
40/12 40/20 41/3
50/18 56/5 56/10 57/4,
57/6 58/1 58/3 61/13
64/25 66/10 66/13
66/20 67/11 72/13
72/15 72/16 72/25
73/7 73/9 73/11 73/13
74/2 74/20 76/9 79/13,
88/2 88/7 88/18 89/4
89/6 93/21 104/2
4111/7 112/8 112/22
114/16 115/10 118/8
137/7 157/2 158/11
159/2 159/3
reading [20] 38/9
40/6 51/25 55/7 57/2
57/4 66/9 66/12 66/14
69/8 70/4 70/14 71/16
71/17 77/5 89/5
109/25 120/14 153/17}
160/25
ready [1] 121/10
real [3] 15/21 105/1
113/22
really [29] 11/4 25/8
29/25 51/15 53/1
63/24 70/7 71/17 76/2I
76/19 76/21 87/23
87/25 90/22 98/9 99/8)
104/16 112/20 119/17)
124/18 139/5 144/21
146/24 148/4 149/24
154/24 162/21 163/4
163/8
reason [11] 15/10
29/23 94/5 104/24
105/1 107/16 107/20
108/18 110/15 113/18}
143/20
reasonable [1] 30/4
reasonably [1]
145/14
reasons [7] 13/25
51/8 90/12 104/6
109/10 116/12 143/5
reassurance [2] 12/3
94/11
reassured [8] 10/17
19/10 19/11 27/6
27/20 27/21 66/11
80/6
recall [43] 9/13 10/4
16/7 20/1 21/21 24/23)
26/7 34/11 35/7 35/9
55/11 57/2 57/4 66/9
69/2 69/5 70/4 78/8
88/10 95/19 97/11
98/7 98/10 100/11
110/7 110/14 112/16
115/12 123/23 132/14)
133/3 135/4 137/1
137/3 143/15 144/14
145/21 145/22 146/16)
146/16 148/22 163/20)
163/21
recalled [1] 131/22
receipt [1] 88/12
receipts [1] 156/10
received [5] 57/3
60/19 86/25 88/7
147/10
receiving [4] 65/1
65/2 94/2 110/8
recent [1] 33/22
recognise [1] 147/9
recollect [1] 25/18
recollection [22]
16/16 25/1 25/14
26/20 32/19 32/21
61/14 61/17 67/7 67/9
105/8 110/10 110/12
112/1 113/8 113/12
114/9 115/14 127/25
128/8 129/6 129/9
recollections [2]
148/12 148/13
recommendation [2]
(62) probably... - recommendation
R
recommendation...
[2] 65/19 137/12
recommendations
[1] 117/21
recommending [1]
29/6
reconciliations [1]
97/7
record [3] 1/19 128/8
128/16
recorded [3] 20/3
77/22 80/14
recording [2] 14/11
21/19
records [4] 45/10
62/18 67/24 69/1
recover [4] 45/9
45/12 126/18 126/20
recovered [1] 129/23
recovering [2]
126/24 130/1
recovery [9] 45/14
127/6 127/7 129/13
129/14 129/25 130/3
130/12 130/25
recruited [2] 3/3
150/22
recruitment [1]
119/10
recuses [1] 144/23
red [7] 38/10 38/20
51/13 70/22 71/5
108/1 156/18
reduction [1] 15/18
refer [11] 4/4 9/10
12/18 17/21 33/10
56/4 65/6 66/23 70/20
106/13 138/20
reference [11] 3/9
4/4 24/16 28/9 53/19
53/25 61/2 69/19
81/14 132/10 160/20
references [1] 37/5
referred [15] 13/11
16/20 21/5 31/12
31/15 47/22 53/24
67/6 79/11 89/23
97/14 106/17 119/15
145/17 153/15
referring [29] 5/16
12/22 12/23 13/5 13/6)
13/13 16/3 16/21 25/3}
26/4 28/11 28/21 35/8
42/16 44/24 44/25
45/25 54/12 59/19
61/7 62/19 94/11
94/20 101/8 116/21
136/16 140/8 140/9
147/17
refers [9] 20/19
25/24 50/15 53/19
56/10 65/18 100/7
117/12 135/21
reflect [1] 113/5
reflections [2] 112/4
149/22
refresh [1] 151/12
refreshed [1] 151/12
refute [1] 55/22
regard [2] 26/14
103/23
regarding [9] 32/23
57/17 97/25 110/25
114/23 147/25 148/23)
149/18 163/23
regards [1] 119/11
regret [1] 165/22
regularly [4] 12/18
25/16 94/18 108/12
rejected [1] 137/16
relate [1] 146/11
related [1] 38/17
relates [1] 87/5
relating [3] 15/4
45/14 145/15
relation [2] 94/3
153/14
Relations [1] 47/12
relationship [3]
39/20 133/19 134/21
relationships [1]
161/15
relatively [1] 114/5
release [4] 6/15 34/5
34/6 155/11
released [1] 50/11
relevant [5] 57/14
79/23 103/8 108/4
148/20
reliability [9] 47/18
47/25 48/16 48/18
49/5 49/13 49/15
50/21 94/19
reliant [2] 61/15
61/18
relied [3] 58/12 101/1
160/19
rely [2] 11/18 14/3
remain [2] 121/9
121/12
remainder [1] 112/8
remains [1] 72/7
remember [75] 3/8
8/14 8/16 10/12 15/6
20/4 20/11 22/5 22/6
22/8 22/13 25/6 27/20
27/21 30/18 36/9 55/7
55/9 55/14 57/10
61/20 64/25 65/1 65/2
66/11 66/12 70/3
73/21 73/22 74/10
74/12 74/15 74/16
78/17 78/18 78/19
78/20 78/21 78/23
87/16 87/18 88/22
89/5 90/4 90/10 90/21
92/2 97/19 98/1
101/12 101/25 101/25)
111/23 112/20 112/24
113/4 114/9 115/24
116/9 124/2 128/14
130/17 133/24 135/10
143/20 144/16 144/17
144/25 147/18 147/25)
148/10 149/2 156/17
157/1 163/23
remembered [2]
37/15 61/19
remit [2] 33/17 49/1
remote [7] 17/21
62/19 62/22 62/25
79/10 152/13 152/14
remotely [1] 17/18
removed [1] 134/2
reoccurred [1] 37/10
reopen [1] 87/6
reopened [2] 87/17
88/1
repeat [2] 146/8
158/13
repeating [1] 3/18
rephrase [1] 91/22
replacing [2] 6/4 78/6}
reply [2] 98/24 136/3
report [133] 11/9
16/10 16/11 17/8
17/10 18/4 18/7 18/8
18/10 18/13 21/9
21/12 23/3 23/12
32/13 33/4 34/24 35/4
35/17 35/18 35/24
36/14 38/18 40/6 40/7
40/20 41/3 42/1 42/14
42/22 42/22 43/4
44/20 47/17 47/19
47/24 48/15 48/17
48/17 48/23 49/7 49/8
50/16 50/20 51/4 51/6
51/7 51/23 53/15 54/1
54/7 54/17 55/4 60/20
62/3 62/10 64/15
64/22 64/25 65/5 65/6
66/25 70/20 71/7
72/23 73/5 73/8 73/13
74/5 74/6 74/9 74/13
74/18 74/20 76/25
77/4 81/2 81/5 82/14
82/20 84/2 84/14 85/4
86/23 86/24 87/13
88/7 91/10 95/3 99/15)
102/16 104/2 104/4
104/11 104/15 104/16
104/25 106/19 108/10}
112/14 113/18 118/5
120/2 123/8 124/1
125/23 128/19 134/13}
135/23 136/1 136/12
136/19 136/20 136/22
137/2 141/15 155/3
155/12 155/17 155/25
156/7 156/25 157/2
157/2 157/14 158/10
158/11 158/17 158/18)
158/21 159/1 159/2
159/12
reported [8] 15/10
23/15 37/10 60/7
80/15 136/14 136/17
136/21
reporter [1] 135/22
reports [13] 13/17
18/3 24/2 43/23 44/18}
44/22 44/24 49/5
50/10 103/22 135/23
139/8 151/11
represent [1] 153/5
representation [1]
143/6
representative [3]
3/15 20/17 84/8
representatives [1]
145/4
represented [1]
144/25
reputation [2] 136/7
136/10
reputational [2] 87/4
105/18
request [3] 14/6 94/3
149/17
requested [2] 106/24
156/23
required [1] 71/18
resign [1] 113/19
resignation [1] 109/7
resigned [4] 102/4
109/10 113/15 119/3
resigning [2] 113/21
114/4
resistance [1] 144/12)
resolve [1] 164/9
resonated [1] 40/21
resource [3] 26/25
27/4 134/8
respect [7] 6/25 9/10
22/14 53/24 128/9
135/12 142/25
respond [2] 58/8
140/12
responded [1] 7/1
responding [1]
149/17
response [7] 28/16
55/2 55/5 55/17
139/21 140/2 140/3
responsibility [6]
89/18 122/8 122/10
122/14 122/23 123/1
responsible [3] 41/6
89/17 122/20
rest [2] 36/3 84/11
result [3] 13/24 13/24I
154/12
resulted [2] 94/19
118/20
results [3] 12/13
22/25 56/24
resume [4] 41/14
86/2 121/11 152/14
retaining [1] 128/23
retired [1] 102/4
reveal [1] 117/16
revenue [2] 31/1
124/25
reverse [3] 140/23
140/25 141/25
review [85] 18/21
18/22 26/10 27/7 27/8)
28/14 28/24 29/5 30/1
30/2 31/17 32/18 33/2
48/5 48/10 48/14
49/23 52/24 56/12
58/16 58/20 64/22
68/18 69/13 70/1 72/7
72/8 76/3 84/13 86/14I
87/5 87/25 91/13 93/3}
93/9 93/11 95/22
95/24 96/2 96/4 96/5
96/10 96/13 96/15
97/1 97/3 97/6 97/12
99/5 100/10 105/9
105/25 112/15 113/15)
113/17 114/24 114/25)
115/2 115/3 115/4
115/15 115/25 116/1
116/4 116/10 116/14
116/18 116/24 117/2
117/6 117/10 117/12
117/14 117/16 118/15}
118/21 119/1 120/5
124/17 131/9 133/16
134/10 141/15 142/17
146/12
reviewed [9] 10/19
12/13 18/3 33/25
75/15 102/18 104/9
104/10 155/3
reviewing [6] 37/21
38/18 67/7 67/9
104/24 106/1
reviews [1] 50/7
rewrite [2] 6/12 6/13
Richard [9] 115/20
117/5 135/7 143/16
143/17 143/25 144/1
145/5 145/16
Richardson [2]
114/23 115/7
rid [1] 134/6
right [36] 4/12 14/1
14/22 17/9 25/12
46/22 48/3 49/6 50/4
56/2 67/19 67/21 78/9I
81/12 82/2 84/5 85/2
86/1 96/18 108/20
113/16 135/16 136/16)
142/3 146/22 152/8
153/3 153/23 154/12
(63)
recommendation... - right
R
right... [7] 156/20
159/6 161/3 163/17
164/3 165/7 166/12
rightly [2] 4/4 10/12
rigorously [1] 107/23
rise [1] 38/7
risk [23] 7/12 7/17
12/19 15/21 20/13
65/21 65/25 67/18
68/13 68/13 79/20
91/24 92/8 100/13
100/25 103/11 104/16}
105/3 105/18 105/18
105/19 116/6 125/25
risks [4] 7/19 65/22
87/5 114/23
RMG [12] 10/25 11/9
12/12 15/17 18/2
18/16 18/19 19/3
19/23 30/25 153/22
154/22
RMG/Post [1] 12/12
robust [7] 7/13 11/1
12/6 52/18 114/2
114/5 154/1
Rodric [2] 61/6 72/1
role [16] 2/17 3/6
4/14 102/24 122/1
122/6 122/9 126/8
128/10 142/9 142/25
145/5 145/7 145/14
161/6 161/7
roles [4] 2/9 2/22 8/1
8/2
rolled [2] 6/7 6/9
Ron [1] 158/20
room [2] 67/13 90/14
root [3] 27/18 29/8
29/25
Rose [2] 99/15
104/15
rosy [3] 66/16 71/4
71/10
round [1] 144/4
route [1] 56/20
routes [1] 87/10
Royal [9] 5/6 31/24
63/13 120/6 125/8
125/19 154/10 154/21
154/21
rule [2] 21/13 94/3
Rule 9 [1] 94/3
Rules [1] 117/18
run [6] 5/1 13/19
13/20 36/4 90/16
136/5
running [1] 143/18
Ss
Sadly [1] 106/16
said [80] 4/5 5/21 9/5
9/20 16/1 17/2 19/17
19/18 19/19 19/20
22/12 22/22 23/8 25/7
25/12 42/23 46/4
46/11 48/7 48/9 52/17
58/21 58/21 61/15
63/8 67/4 70/25 71/4
72/1 72/14 75/24 79/2
79/19 80/3 80/7 80/8
80/13 80/13 80/15
81/19 84/19 101/9
102/12 104/5 106/10
106/20 108/5 111/18
112/5 112/11 113/2
113/6 113/13 114/8
121/25 122/5 123/16
128/9 131/3 131/22
132/11 137/16 144/16)
145/18 148/2 153/16
153/21 155/15 155/19
156/8 156/17 156/19
158/18 158/20 158/22)
159/2 159/13 163/15
164/10 165/11
same [15] 9/24 14/8
38/4 42/3 48/10 50/14
60/17 62/23 66/21
125/4 128/14 134/12
136/3 158/7 158/9
SAS70 [3] 13/14 14/6
14/7
sat [3] 89/24 144/20
145/7
satisfactorily [1]
49/19
satisfactory [2]
52/25 145/24
satisfied [1] 22/18
satisfy [1] 22/22
saving [1] 15/12
saw [10] 13/17 16/9
17/14 37/12 60/21
70/11 79/9 83/11
111/25 119/14
say [100] 4/4 4/12
AINT 5/15 7/4 7/12
9/12 9/24 12/12 13/11
14/9 16/5 16/11 19/9
21/17 24/10 24/14
25/18 26/7 28/17
29/14 30/15 33/19
35/24 36/12 37/22
38/18 38/21 38/25
38/25 40/18 42/12
43/11 43/19 45/24
46/16 48/13 51/6
51/12 51/13 53/4
54/15 55/11 56/17
59/18 60/22 61/6
64/24 66/6 66/8 67/6
70/21 71/16 71/17
74/22 76/12 78/8
79/21 80/2 82/14 85/8)
93/24 94/4 95/1 95/16
102/14 103/18 106/19)
109/9 111/17 113/7
119/10 123/12 127/25)
129/5 129/18 130/23
132/8 138/20 140/7
140/14 140/20 143/25}
147/12 147/12 147/13
147/24 149/18 150/9
151/6 151/11 152/17
154/12 155/24 158/20}
159/24 160/5 163/12
163/13 164/19
saying [63] 8/4 11/14
14/1 22/9 31/9 38/10
38/11 40/5 44/1 44/6
46/3 46/4 46/14 46/22
47/5 47/24 52/16 53/7
55/14 62/1 69/10
69/13 70/1 72/23
73/10 77/9 85/4 99/8
99/9 99/17 99/18
101/15 104/16 107/2
116/8 117/24 118/4
118/5 128/4 130/10
130/18 136/12 137/24
137/25 137/25 138/1
138/1 141/5 141/9
141/17 141/17 157/6
157/15 157/17 158/1
158/2 158/5 158/7
158/11 158/14 158/15}
159/4 164/17
says [65] 12/2 14/17
14/22 15/20 17/24
18/5 19/24 20/20 21/7
26/1 28/2 33/1 34/14
34/23 36/20 37/7 45/7
46/12 48/14 49/12
52/4 53/20 56/13
59/11 60/6 62/13
65/12 66/25 67/21
67/23 71/23 72/4
73/23 78/1 78/24 87/3
91/8 91/12 93/1 94/16
96/24 97/4 98/20
100/15 100/21 109/17]
110/4 111/3 111/8
111/16 112/5 112/10
114/21 117/15 127/13
128/1 134/22 135/25
137/4 137/7 138/16
143/7 144/6 148/7
149/8
SC [4] 111/3
SC/PV [1] 111/3
scale [1] 46/15
scandal [1] 153/7
scheme [28] 42/5
43/6 43/7 43/11 43/16
44/8 44/10 45/20 54/3,
58/12 77/16 77/18
104/8 131/5 133/8
137/13 137/19 138/22
139/4 139/6 139/8
139/10 140/18 141/20}
142/11 142/18 148/25)
149/20
scope [12] 26/19
59/16 59/16 69/18
69/23 71/8 72/7 117/1
117/3 117/8 118/21
118/25
screaming [1]
151/14
screen [10] 4/13 7/24
60/17 65/11 94/15
137/4 159/21 160/22
164/12 166/9
scroll [6] 20/18 32/16
37/24 60/2 96/19
129/17
scrolling [1] 78/1
sealed [1] 78/5
sealed’ [1] 77/23
search [1] 68/25
second [130] 12/12
13/5 16/3 23/24 24/6
24/12 24/17 24/21
24/25 25/18 25/22
26/8 26/23 27/21 29/6)
30/14 31/17 31/22
31/23 32/4 33/3 33/13
33/25 35/3 35/20
35/24 37/1 37/8 37/20)
37/21 37/22 38/17
40/5 40/6 40/7 40/11
40/12 40/20 41/3
42/14 43/3 43/8 44/20)
48/2 48/3 48/6 48/24
49/1 49/4 49/6 49/10
49/20 50/2 50/6 50/13;
50/15 51/21 52/20
54/1 54/7 54/17 55/3
55/6 55/21 86/23
87/25 91/9 93/3 93/9
93/10 93/16 95/15
96/13 100/16 102/15
104/4 104/11 104/22
104/25 112/13 113/15)
113/16 113/18 115/4
116/18 122/12 124/17
126/1 133/15 134/2
134/5 134/6 134/8
134/9 134/18 135/3
135/5 135/12 136/12
138/4 141/14 146/12
147/6 148/25 149/2
149/5 149/19 153/12
155/11 155/21 155/25}
157/2 157/5 157/7
157/13 157/14 157/15}
157/20 158/1 158/5
158/6 158/10 158/11
158/17 158/18 158/25}
159/1 159/2 159/12
165/9
secondly [3] 1/14
74/4 129/13
seconds [1] 152/4
Secretary [2] 47/12
85/1
section [1] 112/4
see [80] 1/5 1/21
12/2 14/19 14/20
16/22 18/10 18/18
20/3 20/10 20/14
20/15 25/21 27/24
28/3 28/16 28/18
32/17 37/4 41/21
50/15 51/18 51/22
55/21 56/13 57/20
58/19 58/24 60/3 63/5I
64/11 64/22 66/5 66/7I
66/25 67/17 71/21
71/24 72/3 74/22
78/16 80/7 85/10 86/9I
91/4 92/18 96/23
98/15 100/15 100/17
106/24 109/2 111/3
114/22 115/7 116/11
117/12 121/17 125/24)
126/2 126/7 127/12
128/19 132/19 135/18)
136/6 140/1 142/12
147/7 148/6 148/8
152/5 152/6 152/24
159/23 159/25 160/23)
161/6 164/11 165/24
seeing [2] 122/20
126/23
seeking [1] 118/25
seem [3] 30/3 139/14
149/14
seemed [2] 26/25
104/5
seems [1] 130/12
seen [12] 17/12
18/16 50/11 68/1
74/20 77/2 79/19
106/10 116/16 135/22
145/6 155/4
sees [1] 117/13
selection [1] 24/12
Senior [14] 3/1 3/6
3/14 3/19 4/11 4/14
8/10 8/11 9/3 16/14
16/24 58/4 104/2
123/25
sensible [8] 52/21
55/21 58/22 58/23
59/7 59/7 139/15
142/19
sensitive [2] 114/7
140/16
sent [11] 14/20 67/10
83/21 108/10 108/10
109/12 109/25 110/16)
114/11 128/11 147/10)
separate [6] 21/4
65/6 131/1 157/10
157/11 157/15
separated [1] 157/5
separately [2] 130/10
(64) right... - separately
Ss
separately... [1]
130/14
separating [1] 5/6
separation [8] 20/23
20/24 124/25 125/7
125/12 125/13 125/13}
125/17
September [13] 2/23
6/5 8/17 109/17 111/6
114/13 114/14 119/13}
119/14 135/21 135/25
137/9 139/9
September '11 [1]
8/17
series [2] 18/21
123/6
serious [9] 60/25
82/11 92/8 92/12
104/16 105/3 106/23
121/19 156/22
seriously [2] 136/7
136/9
served [1] 107/21
Service [3] 60/11
62/8 66/1
Services [1] 165/1
session [3] 61/21
61/24 127/2
set [9] 7/25 21/1
69/18 69/19 79/12
81/22 85/17 153/1
160/12
sets [1] 114/21
setting [4] 20/20
116/17 139/18 140/2
settle [1] 138/10
several [7] 20/22
26/21 35/19 62/14
97/14 155/20 165/12
Sewell [5] 9/16 10/6
15/9 71/25 72/2
shall [3] 41/14 86/1
152/17
shape [5] 32/6 61/25
72/24 73/11 164/23
share [7] 42/13 99/9
143/12 143/17 144/9
145/21 145/22
shared [8] 93/8
108/13 108/15 134/8
134/19 134/22 135/4
135/8
shareholder [17]
84/8 142/25 143/1
143/6 143/9 143/12
144/4 144/12 144/18
144/19 144/20 144/21
144/25 145/4 145/6
145/11 145/16
sharing [3] 135/10
143/8 144/7
sharp [2] 5/2 30/24
she [60] 14/15 14/17
46/4 46/5 62/2 89/22
96/9 99/17 99/17
99/20 110/15 110/18
119/3 122/23 128/3
132/1 133/13 134/20
134/21 135/5 135/14
143/7 143/8 143/8
143/23 144/6 144/6
144/8 144/8 144/14
148/23 149/19 157/11
she'd [1] 147/24
she's [4] 116/12
ShEx [3] 143/19
143/23 144/9
shift [1] 162/4
Shoosmiths [2]
10/15 17/13
shore [1] 52/23
short [13] 32/24
34/18 34/19 35/11
41/19 57/14 57/15
86/7 93/13 108/25
109/23 121/15 152/21
shortfall [1] 37/10
shortfalls [2] 37/6
37/13
shorthand [1] 17/21
shortly [4] 2/6 24/22
91/18 136/3
should [66] 4/1 14/3
30/6 32/4 32/5 37/18
38/21 39/11 39/25
40/1 41/1 42/18 45/9
45/9 46/9 47/5 51/9
56/24 59/18 65/4
68/18 68/21 70/1
73/25 82/17 82/23
82/24 83/1 84/19
84/22 85/6 100/22
102/14 104/11 106/24}
108/9 111/5 113/15
114/16 116/2 116/8
116/15 117/16 121/41
121/2 121/5 122/2
122/18 124/12 127/25)
130/10 130/15 130/16)
130/18 130/23 131/7
137/16 141/5 1414/7
141/9 141/11 141/19
151/12 151/21 156/17,
156/23
shouldn't [7] 14/2
51/13 108/2 115/22
118/4 118/5 130/16
14/17 18/6 19/20 20/2
20/4 24/19 24/20 25/3
25/4 30/24 45/16 46/3
111/16 112/11 112/12)
112/14 112/14 113/15)
128/11 131/22 131/25)
144/16 146/17 146/18,
146/21 148/15 148/17)
116/13 131/24 147/24)
show [3] 29/17 29/19
105/12
showed [3] 60/8
110/10 110/11
showing [1] 18/21
shrinking [1] 5/5
shy [1] 165/14
sic [2] 13/19 18/9
SID [1] 110/19
side [2] 1/24 89/25
Sift [1] 96/2
sight [112] 24/6
24/12 24/22 24/25
25/19 26/8 26/23
27/21 29/6 30/14
31/17 31/23 31/23
32/5 33/3 33/13 33/25
35/4 35/20 35/24 37/1
37/20 37/21 37/22
38/17 40/5 40/6 40/7
40/11 40/12 41/3 43/3
43/8 44/20 48/2 48/3
48/6 48/24 49/4 49/6
49/10 49/20 50/2 50/6
50/13 50/15 51/21
54/1 54/7 54/17 55/3
55/6 55/21 86/23
87/25 91/9 93/3 93/9
93/11 93/16 96/13
102/16 104/4 104/11
104/22 104/25 112/13}
113/15 113/17 113/18}
115/4 116/18 124/17
125/21 133/15 134/2
134/5 134/6 134/8
134/9 134/18 135/3
135/5 135/12 136/12
138/4 141/14 146/12
148/25 149/2 149/5
149/19 155/11 155/21
155/25 157/2 157/5
157/7 157/13 157/14
157/15 157/20 158/1
158/5 158/6 158/10
158/11 158/17 158/18
159/1 159/12 165/9
Sight's [7] 24/17
40/20 42/14 49/1
52/20 159/1 159/2
sighted [1] 70/18
sign [1] 21/24
signature [2] 1/24
1/25
igned [1] 100/18
icance [1] 97/7
significant [12] 17/8
17/10 35/14 40/9
46/10 46/20 52/15
55/2 55/17 65/13 75/4
102/11
significantly [3]
13/23 24/4 117/9
similar [4] 21/10 66/3)
66/8 125/6
Simon [6] 94/1
103/21 104/15 105/4
114/22 115/7
simplest [1] 45/3
simply [2] 14/4 55/14
since [4] 8/5 38/22
49/17 56/22
Singh [1] 125/10
single [1] 21/14
sir [37] 1/5 41/10
41/15 41/21 65/15
66/19 85/17 85/23
86/3 86/9 107/6
107/20 107/25 108/22)
109/2 121/6 121/12
121/17 137/24 138/1
141/3 141/4 141/18
151/22 152/1 152/2
152/6 152/10 152/16
152/16 152/17 152/23
165/21 166/4 166/11
166/15 166/17
Sir Alan [4] 137/24
141/3 141/4 165/21
Sir Anthony [2]
138/1 141/18
site [1] 97/8
sitting [1] 145/3
situation [3] 112/13
144/1 144/1
six [1] 4/10
skills [7] 84/11 84/11
111/21 150/20 150/22)
151/13 151/16
Skin [3] 8/6 8/19 8/25)
slides [1] 18/21
slightly [10] 2/19
29/1 41/12 66/5 66/24
112/4 129/21 143/17
147/20 158/2
slip [1] 90/23
slow [3] 9/17 9/24
137/20
slower [1] 126/20
slowly [1] 138/6
small [6] 8/24 11/23
61/23 104/21 129/24
149/15
smaller [1] 109/6
so [411]
software [7] 33/11
33/11 38/5 38/7 40/13
40/25 44/23
solve [1] 47/6
some [59] 2/7 4/16
7/22 7/25 8/9 8/16
9/10 11/19 15/7 19/5
24/20 24/21 31/25
34/6 34/7 36/16 36/21
38/8 44/9 50/7 52/15
54/13 69/12 73/16
74/5 76/10 76/12
83/19 88/8 91/10 95/5
98/22 99/8 103/10
104/6 110/22 116/14
125/17 128/12 128/13}
130/16 131/17 134/23)
139/23 140/3 140/7
140/9 141/6 142/1
144/15 149/15 150/15)
151/1 151/23 152/13
152/14 154/22 165/15)
165/16
somebody [14] 31/5
32/2 32/3 32/5 55/20
77/10 102/1 105/24
114/3 144/23 150/4
150/6 151/13 151/15
someone [5] 102/5
102/7 159/14 164/10
164/12
something [23] 4/23
15/2 15/25 19/24 32/2)
47/5 78/8 90/22 93/6
104/7 104/11 107/3
117/13 125/3 141/19
144/10 147/12 151/7
151/7 158/2 158/5
162/4 163/8
sometime [1] 98/5
sometimes [4] 90/23
141/18 145/10 145/13)
somewhat [4] 60/23
61/6 72/7 157/4
somewhere [2] 102/5}
102/19
soon [1] 121/13
sorry [31] 21/2 32/16
36/5 43/20 45/24 51/3
69/15 72/1 73/3 80/12)
81/8 81/9 84/17 85/19
89/6 91/7 95/1 96/1
96/19 96/20 101/24
112/21 114/15 132/19)
132/22 136/14 146/8
147/12 152/1 152/2
152/10
sort [3] 25/10 114/21
164/15
sorts [2] 31/1 113/23
sought [1] 77/14
sound [4] 9/17 11/2
106/20 154/2
sounds [2] 121/6
161/22
sources [7] 16/20
47/22 64/23 76/14
94/11 99/23 100/9
Sparrow [30] 55/25
59/19 60/21 69/19
69/21 70/9 70/10
70/13 70/15 70/18
81/11 81/13 81/17
81/20 81/22 82/2 84/4
84/6 84/12 84/20 85/5I
85/7 92/24 135/7
137/8 137/11 138/2
138/14 138/18 139/6
(65) separately... - Sparrow
s
speak [4] 89/22
90/25 110/15 121/10
speaking [3] 115/12
152/10 158/23
special [1] 99/2
specialist [3] 12/5
150/1 163/9
specific [6] 21/21
21/21 22/6 65/25
67/21 148/22
specifically [8] 23/22
24/3 63/1 63/19 93/8
95/13 133/24 146/23
specifics [4] 44/5
44/7 44/15 114/10
specified [1] 96/10
spelt [1] 23/6
Spencer [1] 2/10
spend [3] 47/1 125/3
146/20
spending [5] 3/16
3/22 3/25 4/3 81/23
spent [4] 21/22 70/16
146/18 146/21
spin [2] 99/16 149/3
spin-offs [1] 149/3
split [1] 59/17
SPM [1] 161/3
SPMR's [1] 45/11
SPMs [1] 160/9
spoke [6] 24/20
25/15 36/10 89/5 90/1
112/23
spoken [2] 75/21
75/23
sprung [1] 93/11
squidged [1] 34/18
SSC [7] 59/12 59/13
59/19 59/22 82/25
83/14 84/1
staff [4] 36/22 75/12
75/22 75/23
stage [34] 5/24 8/24
10/13 10/16 18/24
19/1 19/8 22/24 26/15)
26/18 31/7 33/14
33/15 39/15 48/3 50/6
50/10 63/24 65/16
87/19 87/22 92/24
101/13 107/10 110/17)
126/22 134/9 135/6
137/9 138/8 154/5
154/8 154/25 156/15
stakeholder [1]
161/3
stakeholders [8]
160/14 160/15 160/24
161/2 161/9 161/12
161/16 163/13
stand [1] 5/9
standards [1] 75/1
stands [1] 2/5
start [14] 2/8 10/4
16/21 36/6 44/7 49/22
74/22 97/12 97/13
97/18 109/7
started [4] 69/21
69/22 132/2 134/14
starter [1] 54/22
state [2] 1/11 47/12
stated [1] 2/2
statement [39] 1/14
1/16 1/20 1/21 2/2
4/15 7/23 9/11 9/12
12/1 21/5 24/7 24/14
26/6 31/9 38/25 42/10
56/4 60/12 60/16 65/6
66/24 67/6 70/20
93/24 94/4 94/9
103/19 106/13 109/9
109/14 119/9 129/4
140/11 145/17 159/19)
160/19 163/12 166/6
status [3] 18/8
100/10 128/23
stay [1] 42/3
steadily [1] 5/4
steered [1] 116/4
Stein [1] 165/25
step [4] 68/17 131/9
132/4 132/6
stepping [1] 131/18
steps [3] 68/15 69/3
162/14
STEVENS [8] 1/10
41/13 85/19 107/11
108/21 166/3 166/13
167/4
still [24] 6/13 6/17
10/13 19/2 41/21 51/8)
52/20 60/10 62/7
73/16 73/18 74/5
76/11 79/14 79/25
80/25 100/23 126/17
126/19 129/9 137/19
139/1 141/14 159/3
stone [1] 131/18
stop [6] 82/16 101/15
107/7 130/17 136/8
137/5
stop/alter [2] 136/8
137/5
stopping [3] 58/19
58/21 84/17
store [15] 29/10
67/24 68/1 68/10
68/16 68/19 68/22
68/23 69/4 69/14 70/1
71/19 77/22 78/6
79/17
Storey [4] 129/7
143/5 143/16 145/5
straightforwardness
[1] 135/16
strands [1] 162/22
strategy [11] 4/18
5/10 5/13 6/3 6/24
6/25 58/5 58/7 134/2
147/1 164/25
strength [1] 10/16
strengthen [1]
161/15
stress [2] 34/12
165/12
stressed [2] 93/4
128/3
strike [1] 48/21
strives [1] 72/5
strong [8] 11/5 11/15
60/8 93/2 101/3 116/7I
131/2 155/5
stronger [2] 87/8
135/2
strongly [1] 134/20
struggle [1] 113/7
stuff [1] 158/25
stumbled [1] 149/13
subcommittee [42]
20/13 55/25 56/2
57/11 57/13 57/14
57/22 59/20 60/21
69/19 69/21 70/9
70/10 70/13 70/15
70/19 81/11 81/13
81/18 81/20 81/23
82/2 82/14 82/15
82/17 84/5 84/6 84/12
84/20 84/23 84/24
85/3 85/5 85/7 85/13
92/19 92/24 100/14
125/25 135/7 137/11
137/15
subcommittees [5]
57/5 57/17 57/18
57/23 92/18
subject [3] 72/6
110/4 163/9
subjects [1] 161/14
subparagraph [1]
60/6
subpostmaster [7]
33/23 37/11 41/6
45/14 157/8 161/21
162/17
subpostmasters [28]
17/4 17/25 36/22
40/18 49/25 54/11
62/14 78/13 79/3
86/14 117/19 119/12
126/14 126/24 140/17
153/6 160/15 161/10
162/16 162/19 162/23}
163/14 163/16 163/19}
164/6 164/8 165/9
165/21
subpostmistresses
[1] 153/6
subsequent [6]
26/21 84/19 96/7 96/8
104/18 104/19
subsequently [11]
15/3 15/14 18/18 23/1
39/13 48/9 50/23
103/20 108/14 127/10
128/11
subsidy [2] 32/23
34/21
substance [3] 17/4
45/6 107/17
substantive [2] 57/16
57/19
successful [3] 10/22
101/4 153/21
successfully [1]
137/22
succinct [1] 72/5
such [22] 33/7 45/8
47/19 48/17 48/23
49/17 51/7 51/11
51/11 51/11 66/1
100/24 100/25 101/3
101/4 102/2 106/23
109/22 109/23 125/16}
125/20 146/11
sufficient [4] 9/3 26/9}
26/9 56/25
sufficiently [3] 26/12
80/24 82/11
suggest [3] 15/23
42/17 164/7
suggested [3] 18/6
58/18 138/4
suggesting [6] 25/8
46/9 52/15 55/12 76/3)
77/10
suggestion [2] 47/2
58/15
suggestions [1] 70/6
suite [1] 14/3
summarise [7] 8/20
22/12 45/19 71/9
74/22 85/8 118/14
summarised [1] 12/9
summarising [1]
76/14
summary [20] 60/24
61/2 64/23 72/16
72/19 72/20 72/21
72/22 72/25 73/1 73/5)
73/12 73/17 73/19
TAIT 75/14 82/25
84/14 87/1 98/9
summer [6] 95/2
95/3 102/13 102/16
102/18 134/24
sums [1] 127/8
supplied [1] 75/8
supplier [1] 14/3
support [11] 33/7
40/9 40/14 43/12 54/5
54/20 54/24 104/9
129/7 131/4 132/4
supported [1] 127/14
supporting [2] 32/3
131/25
supposed [2] 49/24
53/23
sure [36] 8/4 20/4
20/9 23/18 30/2 31/18}
35/10 36/10 36/11
57/4 61/3 63/23 65/10
66/13 77/7 93/8 95/11
102/15 102/17 112/22)
112/23 113/11 115/19)
123/20 132/1 132/24
137/3 139/23 140/7
142/12 143/23 147/21
161/23 163/9 164/17
165/6
Surely [1] 79/11
surpluses [1] 37/6
surprise [3] 48/1
48/12 48/20
surprised [4] 89/8
89/10 89/12 103/6
Susan [62] 10/9
10/14 10/16 11/2
12/24 17/25 18/6 19/6)
19/7 19/19 25/5 25/13}
26/12 87/11 88/16
89/22 90/7 90/13
90/18 90/25 91/15
92/3 96/8 97/1 97/5
97/18 97/22 98/2
98/20 98/25 99/4 99/7
99/9 99/25 103/15
105/22 105/22 107/25)
109/7 109/10 110/20
110/25 111/4 111/19
112/11 113/14 115/21
115/21 116/12 117/4
117/6 117/7 118/18
118/24 119/2 122/10
133/11 153/15 153/18}
154/1 155/1 158/21
Susan's [2] 108/3
114/6
Susannah [7] 129/7
143/5 143/15 143/20
143/22 144/2 145/5
suspect [1] 119/3
suspects [1] 15/23
suspended [1] 54/11
suspense [1] 156/11
sustainable [4] 5/11
5/12 46/24 162/11
swing [1] 42/5
Swinson [1] 47/11
sworn [2] 1/9 167/2
system [82] 5/22
5/23 6/8 6/11 6/16
6/18 6/21 7/2 7/12
7/20 9/22 10/7 11/2
14/11 15/23 18/1 18/2)
19/11 21/19 22/1 22/2)
22/19 26/3 26/16 27/9I
27/12 29/15 29/19
(66) speak - system
Ss
system... [54] 29/20
30/11 33/6 33/21 34/7
38/3 38/19 39/8 40/8
40/23 41/1 41/7 43/2
43/9 43/10 43/17
44/12 44/14 48/5
49/13 49/15 50/21
52/8 52/10 53/6 53/8
53/16 53/22 56/18
58/9 58/17 60/8 62/18
63/7 66/19 67/25 68/7
70/23 94/12 94/23
100/24 101/1 101/6
122/20 153/11 153/14}
154/2 154/6 154/16
154/18 156/6 156/23
161/22 164/12
system's [1] 19/16
system-wide [2] 38/3
40/8
systemic [10] 33/6
33/9 33/10 37/23 38/4
38/13 40/8 47/14
56/22 157/16
systems [5] 5/25
9/16 9/21 122/17
122/18
T
tack [1] 105/7
tacked [1] 32/24
tackle [1] 163/10
tad [4] 147/15
tainted [1] 105/2
take [26] 13/4 23/1
23/7 27/10 28/8 29/6
31/20 34/1 41/10 42/2
57/16 58/25 94/14
98/12 100/18 101/6
105/7 118/13 128/6
128/15 131/8 131/23
132/23 152/2 152/7
159/7
takeaway [2] 41/4
41/6
taken [6] 11/16 34/3
93/9 94/10 134/16
159/8
taking [13] 13/12
32/11 43/19 50/13
60/15 65/9 67/14
75/14 93/10 97/3
135/2 152/1 155/14
talk [12] 4/3 36/11
36/12 59/14 83/18
88/16 90/8 99/4 162/1
164/8 164/20 164/24
talked [4] 70/14
114/1 138/3 163/24
talking [16] 10/25
15/15 16/16 19/23
23/1 42/11 43/25
93/12 96/1 97/18
117/4 124/7 124/16
132/1 153/22 153/25
talks [2] 72/4 83/21
tampered [1] 77/24
task [3] 59/12 59/14
140/20
taxation [1] 20/24
team [13] 13/22 21/9
44/16 87/11 91/20
120/16 123/19 123/20)
123/24 125/11 125/16)
143/23 146/24
technical [5] 6/20
68/20 72/7 163/3
164/11
technically [1] 68/11
telecom [1] 165/2
tell [9] 30/19 37/15
53/10 73/23 82/23
84/21 98/5 102/20
114/6
telling [3] 30/14
116/5 159/11
tells [1] 158/23
tem [1] 132/6
ten [8] 20/7 29/12
54/22 148/16 148/22
151/25 152/7 153/2
ten-minute [1]
148/22
tended [2] 125/18
164/24
tenor [1] 113/10
tenure [1] 6/3
term [1] 95/23
terminate [2] 140/25
141/1
terminated [1]
139/21
terms [20] 3/9 4/4
20/1 24/16 28/8 42/21
42/25 49/21 51/25
53/19 53/25 55/13
69/19 81/14 91/25
105/8 119/16 120/25
122/17 160/19
test [5] 14/5 68/18
70/1 70/25 79/5
tested [2] 75/18 79/7
testing [2] 60/9 68/16
tests [1] 68/21
text [4] 66/20 147/7
147/21 148/6
texted [1] 147/23
texts [1] 147/9
than [39] 5/25 6/20
8/13 10/1 13/19 14/5
15/6 20/10 27/17 28/9)
28/12 28/14 28/24
37/16 53/6 62/22
70/18 73/21 76/13
77/16 82/18 84/11
105/21 111/5 112/21
118/15 126/16 130/4
130/13 130/25 134/17I
135/6 136/19 138/5
138/8 144/1 145/20
148/15 162/6
thank [41] 1/6 1/13
2/5 2/20 16/18 24/5
36/20 41/17 41/23
66/18 85/17 86/5
86/10 88/4 93/18
94/15 95/20 96/20
108/20 108/22 109/3
109/23 111/13 111/14
112/5 118/23 121/13
121/18 131/21 140/6
140/20 149/12 149/21
152/16 152/19 152/25I
159/22 166/2 16/5
166/11 166/17
thanked [2] 51/23
128/2
thanks [2] 98/25
148/8
that [1014]
that's [54] 2/24 8/4
9/9 22/15 28/8 28/21
30/13 30/13 31/12
34/7 38/4 41/10 41/13
43/8 46/3 50/23 53/9
53/23 54/12 54/22
54/24 59/22 62/19
65/9 76/17 81/12 85/5
92/11 96/20 97/16
103/16 103/16 106/22
107/11 1141/4 114/12
113/18 113/19 114/7
114/8 114/25 120/18
124/17 138/18 144/23
146/21 153/20 156/3
158/16 1641/3 164/3
166/1 16/1 16/3
theft [2] 119/13
126/16
their [37] 7/16 9/19
10/17 22/7 23/15
23/16 33/3 33/17 35/5
36/22 38/18 40/22
40/24 44/17 45/14
49/2 49/22 50/6 63/1
69/18 72/13 73/22
77/23 78/14 81/15
94/17 118/13 120/7
123/18 127/15 133/16
133/17 134/3 134/13
161/2 163/6 163/9
them [40] 4/16 11/17
24/9 26/13 26/13
27/10 29/23 38/16
49/21 50/11 50/12
52/7 55/21 56/6 69/12
69/21 70/8 72/15
80/22 80/24 81/23
84/3 104/10 109/14
109/15 115/12 120/1
124/13 133/20 135/13
138/6 138/7 138/7
143/24 157/9 157/11
158/13 158/13 162/20
163/7
thematic [4] 50/7
55/2 55/5 55/17
thematics [1] 134/13
theme [3] 30/8 42/3
93/1
themes [1] 30/7
themselves [6] 11/20}
14/5 22/18 37/21
86/18 144/23
then [105] 1/21 1/24
2/13 2/21 4/24 10/2
11/7 11/10 12/8 12/14}
12/16 12/22 13/11
13/25 14/7 16/2 18/5
21/2 22/25 23/2 23/3
23/12 23/16 23/18
23/25 28/4 28/16 29/9)
29/12 29/14 29/22
30/6 30/9 30/11 34/6
34/7 37/4 37/23 42/7
45/12 46/20 48/19
49/6 49/15 50/5 50/5
51/7 54/7 54/20 54/24)
56/17 58/25 60/22
63/5 63/18 64/19
69/22 73/8 75/2 75/9
78/1 79/11 79/15
79/20 80/9 81/24
82/25 83/21 83/22
85/8 85/12 87/10
91/12 92/11 93/13
95/6 96/7 96/15 97/4
103/1 104/9 104/17
105/24 115/19 115/21
116/20 117/5 117/5
117/7 117/9 117/15
417/17 118/5 119/16
120/17 121/25 123/2
129/18 131/9 131/16
136/3 140/1 148/16
152/7 160/5
theory [2] 4/1 9/7
there [221]
there'd [1] 29/13
there's [23] 1/24
27/24 29/14 42/7
48/23 58/16 59/22
67/17 73/8 79/20
85/10 85/12 92/11
95/4 98/15 98/17
100/6 107/8 109/25
111/15 118/4 118/5
144/22
therefore [27] 5/10
11/19 43/13 48/11
52/19 59/4 61/21
65/20 70/9 70/11 72/9)
88/2 101/23 105/4
105/21 105/23 107/14
116/2 116/6 118/10
130/21 131/7 132/4
132/15 134/17 139/10
162/14
these [36] 9/19 18/11
26/4 33/23 33/24 36/1
37/19 48/22 51/25
53/25 56/5 56/23
68/14 69/3 69/7 70/6
71/14 90/16 97/25
100/15 101/2 115/10
116/21 120/14 129/19]
133/18 147/7 147/9
147/23 147/23 149/14
157/13 157/17 158/8
158/12 159/4
they [114] 2/20 5/19
7/9 8/17 11/5 11/11
11/12. 11/12 11/13
14/17 11/19 13/3 14/8
14/25 19/4 21/11
21/25 22/2 22/7 23/2
23/3 23/14 23/23
23/24 23/25 26/5 26/8
26/8 26/11 26/24
26/25 26/25 27/6 27/7I
27/9 27/18 29/11
29/11 33/16 37/23
38/16 38/18 40/23
44/3 44/19 48/9 49/1
49/7 50/11 50/12
50/13 51/9 51/12
51/13 52/5 52/20
57/12 58/1 68/3 70/1
70/16 73/2 73/24
75/15 75/16 75/18
75/21 75/22 75/23
75/24 76/18 76/20
77124 79124 81/15
83/9 85/14 88/23
91/25 106/7 120/9
120/17 124/12 125/18
133/17 134/12 135/9
138/7 140/22 141/9
141/11 145/8 145/10
145/13 146/11 146/14
149/15 150/9 157/8
157/10 157/14 157/17I
158/8 158/8 158/8
158/9 158/14 158/15
158/20 158/20 163/6
163/7 163/19 164/19
they'd [4] 81/14
134/14 134/16 158/22
they're [7] 23/1 23/2
69/13 105/6 128/15
145/12 147/8
they've [1] 164/14
thing [20] 14/8 40/7
41/1 48/8 48/10 59/18I
62/23 70/25 81/22
116/5 124/15 135/16
139/15 141/16 142/19I
149/2 158/1 158/7
(67) system... - thing
T
165/18
things [43] 22/10
25/16 31/7 31/10
32/8 32/12 41/9 44/21
50/14 54/6 54/8 54/11
66/17 74/3 77/3 77/5
83/2 91/11 99/17
116/14 116/17 124/5
124/8 124/24 129/13
131/1 138/3 139/12
158/12 164/24
think [194]
thinking [10] 42/21
63/24 63/25 104/19
137/10 151/9
thinks [1] 80/4
third [3] 94/15
112/10 135/20
this [278]
thorough [4] 47/20
49/23 79/13 90/9
those [53] 6/10 8/9
8/13 8/16 8/22 11/10
12/9 12/21 13/2 13/8
16/5 17/14 23/19
25/16 26/4 27/19
29/25 30/10 41/9
44/21 44/21 46/19
52/7 54/8 55/23 71/15)
83/2 84/10 84/10
96/12 96/13 97/19
104/12 105/16 106/12)
106/14 108/6 108/12
108/14 109/13 121/2
122/2 123/4 127/5
129/21 130/24 142/10)
145/13 150/16 151/22)
157/10 164/24 165/16
though [2] 47/19
163/12
thought [32] 3/8
30/13 31/3 39/16
40/21 40/25 43/4 43/7
45/16 45/17 62/2 63/3)
73/15 73/18 82/10
85/20 91/20 102/4
118/8 120/13 123/13
127/17 130/20 131/12)
133/1 137/1 140/22
150/9 151/14 151/18
165/15 165/16
three [11] 3/10 3/10
3/11 3/12 4/5 4/7 4/7
8/23 9/1 127/2 137/14
through [36] 13/4
16/19 17/8 23/12
thing... [2] 164/15
31/10 31/11 32/6 32/7
106/12 106/17 113/23}
146/20 146/22 147/25)
149/19 150/16 153/10)
46/5 55/8 61/24 63/20
27/12 27/14 29/10
43/23 44/16 44/17
54/8 56/19 76/18
77/10 79/16 79/17
87/1 98/11 103/15
107/10 111/7 114/18
120/9 126/18 136/5
136/5 137/20 142/17
157/7 158/13 164/16
166/9
throughout [3] 23/20
162/3 162/5
throw [1] 149/15
thrown [2] 35/23
155/24
thus [1] 65/25
tightrope [1] 145/9
Tim [8] 127/3 137/15
160/3 160/11 162/13
time [124] 3/6 3/16
3/25 4/2 4/3 4/5 4/11
8/9 8/11 8/21 9/3 9/6
9/8 10/4 10/8 10/23
15/2 15/3 15/16 16/6
17/11 17/14 18/14
19/10 19/21 19/22
21/23 23/13 24/4
25/18 27/20 31/25
35/14 38/8 38/16 39/4
41/10 41/13 46/7
50/13 50/14 57/20
59/7 60/17 66/10
66/13 66/13 67/13
69/8 70/12 76/6 76/7
78/17 78/18 80/18
80/23 81/23 83/8
84/13 85/18 85/23
86/1 90/13 92/3 93/14)
94/22 94/25 95/1
95/10 96/14 98/23
99/20 101/4 101/21
104/13 106/6 107/1
107/7 109/13 110/13
111/10 112/2 112/7
112/19 113/25 114/11
115/23 116/9 118/24
119/5 125/3 126/8
130/19 134/12 137/18)
141/21 143/4 143/16
146/1 146/2 146/18
146/20 146/22 148/2
148/9 151/7 151/17
151/18 152/1 152/24
154/22 155/10 157/1
157/19 158/4 162/3
162/5 163/4 163/6
163/6
time-intensive [1]
4/2
times [6] 26/21 35/20
35/20 144/24 155/20
44/19 47/1 49/2 51/20
164/20 164/21 164/22
11/3 11/21 12/24 13/7)
165/12
timing [1] 90/22
143/3
together [5] 75/14
76/13 77/8 106/12
162/22
told [29] 33/13 33/15
34/9 35/16 37/19
94/5 95/12 95/13
95/23 96/3 96/4
101/22 101/24 102/1
102/2 103/14 104/13
104/24 110/15 118/8
141/6 141/7 148/14
154/5 154/7
tomorrow [2] 109/18
166/12
too [3] 78/20 93/9
93/10
took [22] 10/10 14/25
21/17 38/8 38/16 54/7
63/12 72/19 72/22
72/22 74/8 80/20 90/6
114/12 120/3 132/11
136/23 154/19 154/23
155/1 155/5 162/14
tools [1] 68/14
top [4] 34/14 100/16
139/17 160/25
topic [9] 3/23 9/9
41/11 85/25 86/11
107/6 119/7 153/11
153/12
topics [4] 109/6
142/24 148/10 148/23}
TOR [1] 28/8
total [1] 48/12
totally [3] 34/16
151/2 162/9
touch [1] 54/14
touched [1] 145/25
towards [3] 131/8
131/9 146/3
trace [1] 50/4
traceable [1] 62/16
track [1] 29/11
traction [3] 31/8
31/11 31/24
train [1] 166/13
training [4] 33/8 40/9
43/12 54/9
transaction [4] 79/17
80/16 80/19 80/21
transactional [1]
67/24
transactions [12]
14/11 17/19 62/16
62/21 69/24 77/22
78/14 78/16 78/25
80/3 80/8 80/13
transactions’ [1]
today [3] 1/15 109/19
39/21 69/9 81/16 90/2
tomorrow's [1] 64/17
79/10
transcript [2] 80/7
153/17
transfer [2] 125/10
125/20
transferred [1] 125/8
Transformation [1]
165/3
transition [1] 131/3
treat [1] 109/22
trends [1] 69/1
trial [1] 147/4
tried [4] 54/8 109/18
162/4 165/16
troubling [1] 48/21
true [3] 2/2 77/16
79/6
truth [7] 1/22 53/2
83/10
try [8] 63/2 74/21
151/12 157/1 160/9
162/15 162/15 164/9
30/21 31/24 32/6 32/7,
32/7 44/17 50/14
53/13 71/9 73/20
74/10 106/1 110/24
124/14 124/18 127/4
129/12 130/6 134/17
138/2 138/4 147/24
157/7 165/5 165/13
165/13
turn [43] 1/16 1/20
4/13 12/8 16/25 20/12
20/18 24/6 25/22 26/6)
30/25 34/23 36/19
45/6 47/10 60/5 65/4
67/20 72/3 74/6 74/19)
78/11 87/2 88/5 89/20)
90/20 94/12 96/17
100/16 100/20 102/22}
109/8 110/9 110/14
111/8 115/8 116/14
117/11 119/9 126/3
126/12 128/20 133/9
turned [1] 51/7
Twitter [1] 140/4
two [46] 4/12 8/25
15/11 27/1 27/2 33/22}
37/13 39/6 39/24 41/5)
50/7 54/25 56/10
56/23 58/22 58/24
59/17 74/3 84/9 84/10)
100/2 106/2 106/12
109/12 118/1 118/1
118/9 118/12 127/7
129/12 131/1 134/15
135/23 138/8 138/8
142/24 145/13 149/14}
149/22 153/10 157/4
157/4 157/10 157/16
158/15 161/8
tying [2] 47/1 165/14
53/3 53/12 53/14 83/8)
trying [28] 15/6 22/12
type [4] 26/15 35/7
120/21 121/23
U
UK [4] 74/25
unacceptable [2]
39/19 103/23
unanswered [2] 81/3
83/5
unaware [2] 37/8
93/25
unbelievable [1]
134/15
uncertainty [1] 26/18
uncles [1] 164/13
uncomfortable [1]
83/10
under [14] 5/19
25/24 47/12 63/13
63/13 65/10 66/5
94/18 107/20 117/15
117/18 142/13 142/21
161/7
under-invested [1]
5/19
Under-Secretary [1]
47/12
underinvested [2]
5/18 6/1
underlying [2] 68/22
80/25
underneath [1] 38/12)
underpin [1] 72/12
understand [38] 17/6)
27/11 27/14 29/8 32/8I
33/9 34/1 35/19 47/17
52/24 54/16 54/22
56/1 63/2 64/4 68/22
69/11 72/15 73/1
77/19 80/21 87/24
87/25 96/12 99/1
105/1 106/16 116/3
120/16 124/14 124/18)
127/4 129/12 129/19
130/7 131/1 146/6
164/17
understanding [17]
10/2 30/4 33/16 44/13)
44/15 49/9 69/6 79/25)
81/24 104/23 110/2
117/4 154/3 154/15
154/15 156/6 161/15
understood [3] 23/17I
40/12 63/14
undertaken [3] 33/3
52/6 53/21
undertaking [1]
26/10
undoubtedly [1]
69/24
unequivocal [1]
154/20
unexplained [2]
(68) thing... - unexplained
U
unexplained... [2]
37/10 104/6
unhappy [2] 36/13
155/15
unique [2] 88/24
89/15
Unless [1] 151/22
unlikely [1] 57/11
unlock [1] 165/19
unmute [1] 152/12
unmuted [1] 152/3
unpack [2] 130/6
130/8
unsatisfactory [1]
76/7
untainted [1] 107/24
until [6] 14/20 37/9
99/20 101/4 123/7
166/19
unusual [5] 27/1 31/9)
90/17 120/21 121/23
up [78] 2/20 4/13 6/3
7/5 11/25 14/18 15/11
23/19 24/7 25/20 26/6
27/17 28/14 28/16
30/2 42/1 52/23 60/16
63/8 66/5 66/22 69/18
69/19 74/6 76/11
81/22 83/24 86/20
88/21 90/20 91/14
94/22 96/20 98/15
98/17 98/19 99/1 99/6
99/12 99/19 101/7
101/17 103/18 107/3
107/4 109/8 109/15
111/13 111/14 111/21
112/4 116/14 118/12
119/9 119/20 125/2
125/2 125/4 129/5
129/17 131/25 132/14
132/18 132/19 135/24}
136/23 140/5 140/12
141/16 143/2 147/5
147/25 151/4 159/20
160/12 160/22 162/25}
165/13
upcoming [1] 86/23
update [13] 32/18
33/2 34/20 43/25 56/8
87/14 98/22 99/2
99/11 99/11 99/18
99/21 139/25
updated [1] 126/5
updating [1] 25/25
upgrade [1] 97/7
upon [2] 93/11 101/4
upset [4] 25/13 35/16
35/16 114/3
urgent [1] 97/3
us [41] 1/5 3/25 13/4
15/21 19/12 22/21
30/14 34/17 35/21
39/13 39/19 41/22
75/8 76/10 86/9 89/2
90/12 104/1 104/7
105/6 105/18 109/2
113/2 116/5 121/17
124/6 124/12 124/16
129/23 130/2 137/14
137/24 144/7 150/5
150/6 152/24 155/22
use [31] 6/18 6/22
26/2 40/19 47/18
47/25 48/16 48/18
49/24 50/3 50/20
54/19 63/7 68/24
77/N14 77/15 77/18
79/8 80/9 87/17 94/6
95/10 95/17 101/19
135/3 136/6 138/14
138/17 140/13 148/4
149/15
used [11] 10/22
15/11 19/15 62/22
68/14 79/7 92/7
153/20
useful [8] 54/21
63/18 114/16 144/19
144/21 150/3 150/5
150/6
user [3] 6/20 9/25
41/2
users [1] 163/22
using [9] 6/19 6/19
49/10 76/16 77/12
95/22 105/2 130/4
133/15
usual [1] 90/19
usually [1] 152/23
Vv
vague [10] 26/19
26/20 26/22 27/5 29/1
34/3 37/16 110/12
114/8 115/14
vaguely [2] 115/13
145/22
validate [1] 55/22
validated [1] 75/7
validation [2] 67/1
80/4
validity [1] 63/2
valuable [1] 62/18
van [2] 53/21 53/24
various [5] 2/9 39/1
51/21 92/17 98/12
vast [1] 63/12
vehicle [2] 161/20
163/10
Vennells [23] 25/24
26/16 27/25 31/20
32/18 83/25 86/21
90/1 109/16 110/14
111/4 111/24 112/17
48/7 52/21 53/23 69/6
101/10 101/23 113/10)
126/2 128/9 145/19
146/10 147/5 147/8
148/11
Vennells' [1] 87/17
verbal [3] 35/11
60/23 61/7
verbally [2] 157/3
157/12
verification [2] 75/13
75/25
version [3] 6/14
66/19 73/12
versus [1] 87/23
very [108] 1/13 2/8
4/1 4/25 5/1 5/2 8/24
10/8 10/18 11/1 11/1
14/24 18/4 19/1 24/1
24/4 27/1 29/5 29/9
30/23 34/19 45/18
48/7 52/12 52/21
54/21 57/14 57/15
59/3 59/4 59/5 59/11
62/18 81/12 84/3
85/19 87/22 90/24
93/13 95/23 96/25
98/13 98/25 99/19
102/20 103/6 103/8
104/16 104/18 105/7
105/15 106/19 107/23}
108/8 108/12 108/17
109/3 116/9 116/11
117/3 117/8 118/8
124/14 125/1 125/1
125/6 127/1 130/10
133/8 137/20 137/20
137/21 137/21 137/21
137/21 139/22 140/2
140/13 140/15 142/24
144/23 144/23 146/17
148/13 149/12 150/3
150/5 150/12 150/14
150/14 150/15 150/16
151/1 154/1 154/1
154/8 154/20 154/20
155/1 155/3 156/14
157/11 161/25 162/13
163/3 166/5 166/6
166/10
via [4] 136/24
video [1] 152/5
view [33] 30/9 35/13
40/24 42/14 46/4
58/25 59/8 72/18
82/24 92/4 92/4 92/8
93/9 105/17 105/19
116/8 122/22 123/3
127/15 130/3 130/12
130/22 131/1 134/22
134/25 135/2 135/4
135/9 135/10 143/21
145/21 145/22 146/1
views [12] 37/12
45/19 82/19 93/2
114/14 115/12 122/25)
128/14 134/5 160/9
161/13 163/1
Virginia [1] 137/15
virtually [1] 120/6
visibility [1] 78/13
visible [10] 29/10
79/2 79/14 79/17 80/1
80/3 80/6 80/9 80/17
81/1
vivid [1] 73/14
vote [1] 141/19
Ww
wait [3] 99/19 159/21
160/22
walk [4] 145/9
wall [1] 143/24
want [39] 1/16 4/16
4/22 9/9 10/4 14/17
22/11 24/5 24/9 31/23)
32/1 32/10 42/1 42/8
70/25 83/5 83/8 96/3
98/22 99/11 99/11
99/18 106/22 107/12
109/7 109/14 119/7
125/22 128/16 133/8
133/20 134/7 137/5
141/24 142/24 145/15}
147/2 148/21 153/10
wanted [23] 35/18
39/19 39/19 39/21
53/2 53/3 53/7 53/11
59/23 63/24 85/20
88/20 105/21 105/23
105/24 110/15 110/23}
110/23 115/25 118/15)
127/9 164/20 164/23
warm [3] 66/16 71/4
71/10
warning [1] 32/25
was [575]
wash [1] 54/8
wasn't [57] 6/12 6/12
6/22 6/22 11/22 13/6
21/21 22/9 32/22 36/2
38/20 39/2 39/22
40/11 40/24 41/4
43/20 43/21 44/4
44/14 46/3 49/7 57/22)
64/2 70/11 73/13 74/2
76/9 81/9 81/21 82/24
95/13 99/17 106/8
119/18 121/19 123/11
127/19 130/5 130/5
131/19 134/25 137/23
137/24 138/12 139/3
142/18 146/23 150/10
150/22 150/23 152/12
154/24 155/8 156/15
158/2 163/8
waste [1] 141/20
watched [1] 158/19
way [55] 6/20 6/20
109/20 128/13 128/13)
8/10 14/13 27/12 30/4I
32/5 35/13 36/1 36/4
37/20 39/11 39/12
39/16 39/17 39/23
44/17 49/4 49/9 54/10
55/12 55/19 57/11
57/23 77/8 91/16
93/10 102/2 103/10
103/13 103/17 107/24}
108/5 114/18 118/14
125/4 136/6 137/8
138/2 138/6 138/13
138/18 138/25 139/11
139/12 145/4 147/2
147/2 148/15 151/4
156/2 161/8 161/22
162/25 165/11
ways [3] 31/1 105/14
134/2
we [456]
we'd [4] 15/12 69/18
104/7 137/20
we'll [12] 16/20 42/2
47/9 102/22 102/22
121/12 128/19 131/9
152/2 152/16 159/21
160/22
we're [22] 1/7 7/22
12/21 19/18 24/22
35/25 55/11 61/5
61/24 62/12 64/21
69/17 86/21 88/5
92/17 99/22 105/15
110/8 121/10 121/20
131/3 156/1
we've [23] 13/14 28/1
51/17 54/24 57/24
59/1 64/13 82/19
83/16 99/23 112/3
112/5 115/8 116/16
128/18 131/3 131/4
143/3 149/7 149/23
156/5 156/12 156/14
weak [3] 10/17 19/12
155/5
weakness [1] 50/9
weaknesses [3]
42/19 43/1 50/1
website [1] 2/7
Wednesday [1] 67/2
week [7] 4/12 35/17
35/25 87/15 97/1
149/8 155/25
weeks [1] 101/7
weight [3] 73/4 124/4
124/24
weird [2] 130/20
141/16
well [44] 4/23 4/25
8/19 27/22 28/6 28/20)
31/12 48/24 53/3
56/11 57/24 62/12
63/11 63/17 70/3
70/10 72/22 74/18
(69) unexplained... - well
Ww
well... [26] 78/21 81/8)
82/1 82/16 89/5 89/11
91/11 93/3 93/15
112/18 116/2 126/3
130/11 132/20 132/23)
134/1 138/23 139/22
140/13 140/20 140/20
145/14 149/12 160/7
162/23 166/5
went [15] 4/25 6/2
28/5 29/10 43/6 43/23
66/3 86/24 88/2
104/19 108/16 113/9
117/5 133/10 141/12
were [280]
weren't [19] 11/11
11/12 17/16 22/3 41/5)
56/1 63/24 106/17
120/25 122/6 123/9
127/8 131/20 141/9
157/17 158/8 158/9
158/9 158/15
what [152] 3/6 5/15,
12/12 13/13 14/6
15/15 18/24 20/1 20/3
21/8 22/12 22/21 25/9
26/15 26/19 26/23
27/9 27/11 29/6 29/17,
30/4 30/13 30/13
30/17 30/18 30/19
31/19 33/9 34/1 35/13)
35/14 37/12 37/15
39/14 40/12 40/17
41/13 42/9 42/12 43/5
43/14 43/19 44/6
45/19 46/4 46/5 49/10)
49/20 50/2 53/23
54/12 54/16 54/18
55/13 57/15 61/15
63/6 64/3 64/5 68/13
69/6 69/8 72/18 72/19
73/1 73/2 73/18 74/8
74/16 75/24 76/17
76/18 77/8 77/14
78/24 79/21 80/9
80/10 80/12 80/19
82/19 82/21 83/16
86/1 87/20 87/25 89/2
92/8 92/10 93/16
95/23 96/4 96/11 98/7,
98/9 99/17 103/13
104/1 104/23 105/8
105/8 106/22 107/14
110/4 110/14 113/2
113/5 113/6 113/12
113/12 113/12 114/8
114/19 115/14 119/25)
120/25 120/25 122/13}
122/17 122/18 123/3
124/17 126/22 127/8
127/23 128/9 136/14
137/1 138/19 139/14
139/19 140/1 144/16
146/8 146/10 148/10
149/17 149/24 151/19)
152/5 156/19 157/8
158/14 158/16 159/24)
163/12 164/5 164/17
164/19 164/23 165/4
165/20
what's [3] 18/20
82/21 136/16
whatever [1] 43/12
whatsoever [1]
119/11
when [86] 2/22 5/15
5/21 6/19 7/8 9/20
9/24 13/11 15/9 15/16
16/9 21/17 24/20
28/11 30/19 32/13
34/9 36/14 37/12
37/18 44/24 45/24
45/24 48/2 48/8 55/11
57/2 58/15 59/15
59/18 61/6 63/7 63/20
65/5 66/20 67/13
72/24 73/3 73/7 73/9
73/11 75/2 76/12
79/13 80/7 81/18
82/19 85/21 87/16
87/18 88/15 89/4 89/5)
89/6 94/24 95/1 96/3
98/3 98/4 98/23 101/9
102/12 102/15 102/17)
102/18 102/20 104/2
106/6 106/23 119/2
120/2 120/7 120/13
121/10 125/13 132/1
135/6 138/22 140/7
151/9 151/12 156/21
156/25 157/1 157/1
157/11
when I [1] 89/6
where [47] 10/21
15/5 15/8 23/17 25/17)
27/14 29/8 29/13 30/7
35/4 38/6 39/7 42/19
46/9 50/8 51/1 58/24
60/15 69/17 71/9
75/21 75/22 79/19
82/5 86/22 90/21
100/23 105/25 110/22)
111/12 115/16 123/21
125/18 129/15 137/9
138/20 141/16 142/10)
144/6 144/14 145/1
153/19 155/1 160/13
162/22 163/13 164/25)
whereas [2] 129/8
130/1
whether [17] 8/17
26/8 42/17 43/1 49/17
52/24 67/12 68/5 70/3)
75/18 85/9 87/12
101/14 123/23 126/17)
138/22 158/3
which [137] 6/2 6/3
8/15 10/18 11/18
11/20 12/23 12/24
13/9 14/17 15/7 15/12
15/14 16/3 16/8 17/4
19/15 19/20 21/4 21/5
23/5 23/6 23/7 26/22
30/7 30/8 32/24 33/2
33/4 33/12 33/25
36/22 38/8 38/12
40/14 40/25 41/3
45/10 47/2 47/17
47/24 49/8 49/14
49/19 50/7 53/5 54/2
54/6 54/9 55/16 57/18
59/12 60/25 62/16
64/19 66/23 69/23
69/24 70/15 72/12
73/12 73/16 73/22
73/24 77/4 80/3 80/20
86/23 88/1 88/6 88/15
88/16 88/20 89/7 92/2
93/10 94/19 96/9
98/18 99/16 100/6
103/5 103/25 104/11
105/24 106/20 106/25I
108/4 108/9 108/17
108/18 110/8 110/17
110/21 1141/1 115/19
119/14 120/3 124/5
124/24 126/16 127/9
127/10 128/17 129/4
130/4 130/6 133/15
133/20 134/16 138/15I
139/20 141/15 141/20
142/4 143/3 145/4
145/18 145/23 145/25I
147/2 147/21 150/25
151/2 151/3 155/4
155/11 156/8 158/7
158/9 158/19 159/7
159/15 160/21 163/8
163/13 165/4
while [3] 62/12 85/20
133/14
whilst [9] 3/14 3/19
8/2 68/11 111/18
123/8 131/7 142/16
147/22
who [48] 10/9 10/12
13/22 16/1 19/3 19/4
19/18 30/23 47/5
62/15 68/11 70/18
7212 79/23 80/15
84/20 84/22 84/25
85/13 86/15 89/17
90/1 90/20 94/17
94/23 95/11 101/19
101/24 105/20 113/24]
120/16 122/11 122/19]
123/21 135/2 135/4
135/22 137/15 140/19I
144/3 153/1 153/7
153/22 160/4 160/11
163/16 163/19 164/8
whole [9] 6/13 6/16
29/20 48/24 57/6
115/16 115/24 137/7
150/18
wholly [4] 103/22
whom [1] 12/4
whose [1] 122/7
why [49] 6/2 6/10
13/25 26/22 46/16
46/16 50/23 52/9
53/24 55/4 58/18
59/22 63/10 65/9
65/10 80/3 81/5 81/8
82/19 82/20 82/23
83/13 83/14 83/23
90/12 97/5 99/3
101/18 107/16 108/18}
109/10 115/22 118/4
118/5 123/6 124/3
127/9 127/17 129/11
130/6 131/14 136/9
137/5 141/24 144/8
150/22 157/25 159/7
165/1
wide [2] 38/3 40/8
widen [1] 69/18
widened [1] 71/8
wider [5] 41/1 43/10
44/4 160/15 161/16
widespread [1] 56/22!
will [50] 2/6 20/6 22/7I
23/1 23/2 23/3 23/5
23/6 23/8 23/8 23/12
23/12 23/14 32/2
33/16 34/3 34/4 47/6
56/14 64/16 64/17
64/24 66/8 66/15 67/3
67/10 88/18 88/19
95/8 97/9 98/4 98/11
98/18 98/22 100/25
101/3 109/4 113/4
117/14 121/9 121/12
124/10 132/16 132/17}
133/18 139/23 140/7
145/13 146/5 148/9
WILLIAM [3] 1/9 1/12
167/2
Williams [2] 61/6
72/1
Wilson [1] 64/12
Wilson's [1] 64/11
wisdom [1] 148/8
wise [1] 130/7
wish [8] 52/9 107/1
158/17 158/21 158/25]
159/8 165/5 165/8
wished [1] 112/14
within [12] 3/20 5/22
9/22 25/4 68/19 69/1
70/8 75/19 78/6 115/4I
136/1 136/2
without [5] 52/1
75/12 75/24 106/22
121/25
WITN00740122 [1]
14/18
WITN10290100 [2]
1/19 159/20
witness [20] 1/16
7/23 9/11 60/16 65/6
65/8 66/24 94/17
94/23 95/11 95/14
104/14 105/3 109/8
109/14 129/4 133/4
140/11 145/17 166/6
won [2] 19/14 155/2
won't [4] 66/21 98/13
113/4 158/13
wonder [1] 136/5
word [4] 6/19 34/1
54/15 54/15
wording [1] 53/9
words [9] 22/11
45/21 45/24 50/4
53/10 80/9 87/17
113/9 140/13
work [64] 6/2 7/9
8/12 14/2 23/9 44/17
49/22 49/24 51/21
52/6 52/9 52/16 52/20
52/22 52/23 53/5
53/21 54/20 55/20
55/21 56/9 56/16
56/24 57/8 57/21
57/23 58/1 60/7 60/10}
60/14 62/7 63/21 64/8)
65/13 66/7 67/19
67/22 67/22 67/25
68/10 69/10 70/8 71/2I
TANT 72/19 75/15
76/8 76/15 80/17
81/13 83/19 83/19
84/22 87/15 102/5
117/9 127/8 127/10
134/9 134/16 134/18
135/8 139/1 163/14
worked [12] 8/5 8/15
26/13 44/19 49/9 50/8
53/16 57/12 75/16
112/12 123/18 160/16)
working [33] 4/9
42/18 45/8 49/6 50/12
54/3 87/12 104/8
107/10 130/12 134/10)
135/5 137/23 138/12
138/16 138/17 139/7
139/7 139/20 140/15
141/1 141/2 141/10
141/12 141/13 141/16)
141/22 142/9 149/1
149/5 149/20 154/17
156/7
workplace [1] 160/10
works [2] 53/22
69/12
workstreams [1]
54/2
(70) well... - workstreams
Ww
world [2] 120/15
164/22
worms [1] 45/18
worried [13] 16/11
37/17 39/10 39/11
39/14 39/14 66/17
7116 71/11 71/17
72/24 89/13 92/12
worry [6] 39/23 39/24]
55/19 61/20 61/21
79/18
worrying [2] 156/13
156/16
worse [1] 5/4
worst [2] 46/17
131/17
worth [1] 28/6
would [192]
wouldn't [6] 29/19
70/7 113/2 118/13
138/17 162/6
write [1] 62/3
writing [2] 157/4
157/12
written [8] 1/14 35/10)
35/22 39/12 59/9 67/4
83/17 155/22
wrong [14] 13/3
19/21 19/22 23/11
34/22 60/13 108/13
113/17 129/21 136/22)
143/17 146/21 153/18}
164/15
wrongful [12] 88/16
88/22 89/9 89/14
91/14 91/19 92/1
92/13 104/17 105/3
105/13 105/15
wrongly [3] 19/10
38/14 157/19
wrote [3] 30/19 31/6
53/9
Y
yeah [32] 10/24 13/5
14/1 31/10 31/25 32/1
40/21 44/16 50/12
50/17 55/16 58/6
59/11 61/24 69/16
76/17 91/23 92/6 92/7
92/10 95/8 103/16
104/7 111/25 119/24
132/24 135/14 136/18
136/20 136/24 148/2
162/10
year [13] 5/3 5/4 6/7
6/9 13/10 13/17 20/22
23/13 35/20 37/9
134/16 134/24 155/20}
years [14] 5/1 5/24
5/25 20/5 21/10 23/20
26/21 30/19 33/22
37/17 48/22 73/21
74/10 112/21
yes [167] 1/6 1/8 1/23
2/1 2/4 2/12 2/16 2/18
3/19 3/23 4/19 6/5 6/6)
6/9 6/22 7/3 7/7 7/11
7/14 7/18 7/21 8/6 8/8
9/23 10/2 11/6 17/10
18/23 22/15 22/16
22/19 28/15 28/22
29/1 29/15 34/14
34/16 38/1 38/24 39/3)
39/9 40/25 41/23
43/18 43/18 44/13
45/2 46/2 47/8 50/22
50/25 51/5 53/18
54/13 56/7 58/2 58/5
58/9 58/10 58/14
59/21 60/16 61/4 61/8)
61/10 62/6 62/23
63/23 64/9 66/3 66/4
66/12 71/9 71/15
72/17 74/10 75/17
75/18 75/20 76/1 76/5)
78/10 78/25 79/1 79/4
81/4 82/7 82/8 82/9
82/13 85/21 86/10
88/9 89/1 90/19 92/2
92/16 92/24 94/8
94/21 94/22 100/1
100/3 100/5 100/8
102/8 102/25 103/2
103/2 108/22 109/3
110/12 112/9 113/11
113/20 115/1 115/6
115/11 116/19 116/23)
117/3 118/3 118/17
118/22 121/4 121/7
121/9 121/12 121/18
122/3 122/4 122/16
123/5 123/17 123/21
126/11 130/23 132/24}
140/10 141/17 141/17)
142/6 142/8 145/8
145/8 147/11 147/20
152/7 152/9 152/25
153/24 154/3 154/4
154/19 155/5 155/9
155/13 155/18 156/4
156/17 156/21 160/18)
161/5 164/1 164/4
166/4 166/15
yet [2] 49/19 56/19
you [618]
you'd [4] 47/23 126/9
145/6 145/7
you're [28] 9/21
25/21 29/23 30/6
32/15 32/16 42/11
42/16 43/24 44/6 44/7
51/18 59/19 60/2
71/22 91/4 94/20
96/23 126/1 132/23
135/20 136/16 140/9
141/22 147/17 147/17I
152/2 164/17
you've [20] 2/21 4/23
12/8 22/12 38/25
47/22 51/14 64/20
71/12 72/16 74/19
84/10 84/11 93/21
128/7 158/15 158/18
158/22 160/19 163/15}
Young [11] 9/15 10/6
11/8 11/9 12/17 13/18
14/9 20/16 20/17 25/5
122/12
Young's [1] 9/13
your [112] 1/11 1/24
2/3 2/5 2/9 2/17 4/4
4/6 4/11 4/14 4/15
7/23 7/25 8/9 8/11
9/11 12/1 12/9 12/22
13/11 13/13 17/6
17/12 17/16 19/17
21/5 22/11 22/17 24/7
24/14 26/6 28/16 30/9}
35/13 36/7 36/15
37/12 38/25 40/3
40/19 42/10 42/21
42/22 45/19 50/3 56/4
59/8 60/12 65/6 66/23
67/6 69/6 70/20 70/25
72/18 80/12 80/18
81/9 82/19 83/22
87/18 88/24 90/16
92/8 93/24 94/4 94/9
98/24 99/22 99/23
100/6 102/6 102/22
103/19 106/13 107/13
109/8 109/14 110/1
115/14 116/20 119/8
119/22 121/25 122/3
122/5 123/8 126/8
129/4 129/9 131/24
133/3 136/3 138/11
140/11 145/3 146/8
146/10 148/8 149/16
153/25 154/2 154/13
154/15 155/14 159/10}
159/10 159/19 160/19}
163/12 166/6 166/10
yourself [2] 22/22
69/7
Zz
Zebra [2] 60/20 66/25
(71) world - Zebra