INQ00001184 - Transcript (30/07/2024): Post Office Horizon IT Inquiry - Susannah Storey [WITN0092]

Evidence on official site

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The Post Office Horizon IT Inquiry

Tuesday, 30 July 2024

(10.00 am)
SIR WYN WILLIAMS: = Morning, everyone.
Mr Blake?
MR BLAKE: Morning, sir. This morning we're going to hear
from Ms Storey.
SUSANNAH JEMIMA STOREY (affirmed)
Questioned by MR BLAKE

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

please.

A. Susannah Jemima story.

Q. Ms Storey, you should have in front of you a witness
statement dated 23 May this year?

A. Yes.

Q. Can! ask you to turn to the final substantive page,
that's page 102. Can you confirm that that is your
signature?

A. That is my signature.

Q. Thank you, is that statement true to the best of your
knowledge and belief?

A. Itis, although, as we discussed, there are some small
changes I wanted to make.

Q. Thank you very much. Perhaps we could bring the
statement on to screen. It's WITN00920100.

‘SIR WYN WILLIAMS: Can everyone hear because I'm actually
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"substantial" after the "only" so it would read "the
only substantial item of business".

Q. Thank you very much.

A. And, sorry, lastly, paragraph 201 I realised was missing
a word.

Q. That's page 90.

A. Page 90, yes. In the final sentence of the paragraph,
it says, "I obtained significant relating". I think it
needs to read "I obtained significant information
relating".

Q. Thank you. Subject to those changes, is the statement
true to the best of your knowledge and belief?

A. Itis.

Q. Thank you very much. That witness statement will be
uploaded onto the Inquiry's website in due course.

Ms Storey, you're currently Permanent Secretary of
the Department for Culture, Media and Sport; is that
correct?

A. Thatis correct.

Q. You started life as an investment banker between 1995
and 2006?

A. That's right.

Q. Relevant for today’s purpose, you worked at ShEx between
2006 and 2013, initially on a secondment; is that
correct?

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slightly struggling, whether it's just me, I don't know.
But is the system working properly? Fine it's just me,
obviously.

MR BLAKE: Perhaps if you could sit slightly further
forward, it would assist.

FROM THE FLOOR: It's not just you.

SIR WYN WILLIAMS: = Right. Good.

THE WITNESS: Let me know, is that better? Maybe I was
a bit too far from the microphone, my apologies.

MR BLAKE: There are a few changes you would like to make.
Can we start with the first. Which paragraph?

A. Paragraph 21.

Paragraph 21 is page 10.

A. Page 10, yes. In the sentence "! do not recall any
significant concerns", which is about halfway down that
paragraph, two lines down, it says, "My tenure as
Director" I would like to insert "RMPS" before
"Director" to make clear I wasn't a director of the Post
Office at that time. That was a title in my Civil
Service role.

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Q. Thank you very much.
A. The next one is paragraph 110, page 49. In the first
line, I would like to delete "single issue".
Q. Thank you.
A. Then over the page in paragraph 111, I'd like to insert
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A. That's correct.

Q. Between March 2011 and March 2012, you were Director of
ShEx's Royal Mail and Postal Services team --

A. Yes.

Q. --and I think that's the correction you just made in
that paragraph?

A. (The witness nodded)

Q. You were then the first Shareholder Non-Executive of the
Post Office between April 2012 and March 2014; is that
correct?

A. That is correct.

Q. That was upon separation from Royal Mail Group?

A. Yes.

Q. Can you assist us with how you were selected for that

role as Non-Executive Director?

A. So the Shareholder Executive looked after a number of
different government-owned entities and, in some
instances, there would be a Board member from the
relevant team. I was most recently, as you were just
saying, from March 2011 the Director of the Royal Mail
and Postal Services team, and once the Government
decided it wanted to have a representative on the Board
of the Post Office on separation, it was the working
assumption, I think, that, as the Director, that would
be me.

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I've set out in my statement some of the further
background in case helpful, so I obviously knew the
Postal Services space well, having worked for a number
of years on the Royal Mail side as a civil servant and
I'd also experience working with boards when I was
an investment banker.

Did you have any prior experience of being on a board?
No, I hadn't been on a board before.

Were you provided with any training before you took up
the post, specific to that role of Non-Executive

Director?

No.

I want to ask you about your location and also the
support that was provided to you during your time as
Non-Executive Director. You became a Non-Executive
Director when on maternity leave, which was between
March 2012 and March 2013. When you came back, you were
based at the Department for Energy and Climate Change,
at that time an entirely separate department; is that
correct?

That's correct. So when -- could I give a couple of
moments for context is that's okay?

Absolutely.

So during 2011 the Government had a hugely ambitious

agenda for these two companies, which including the
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I also was required by the Department to hand back all
of my IT, so my phone and my computer, which is why, in
a lot of the disclosed documents, you'll see me using

a personal email address.

Thank you. The role itself wasn't a paid role or
separately paid role in any way; is that correct?

No, I received no remuneration for being the shareholder
representative Board member, although of course I was
getting a salary and, during maternity leave, you're

paid for some months. And then when I was at the
Department of Energy and Climate Change from March 2013,
I was being paid a salary by them to do that job. So in

a sense, as a civil servant, I was getting remuneration.
There was no additional remuneration, nor would I have
expected it.

When you were at the Department for Energy and Climate
Change, you were managing an entirely different
portfolio?

That's right. I was Strategy Director there, thinking

about the Climate Change Act and all of the things we
needed to do to decarbonise the country.

Were those logistical issues discussed with you before
you took on the position?

Not particularly. I mean, I think, as I was saying, the

sort of set of things we were doing through 2011 to
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separation, the Postal Services Act 2011 was passed to
enable all of that, we were tying to help stabilise the
pension scheme, change the regulation, and so on. And
so I -- during the course of that process, as I was just
saying, it became clear that we wanted a shareholder
representative.

I was pregnant during that year and, by the time
I started on the Board, which was the April Board
meeting, 2012, I had started my maternity leave, which
began on 14 March 2012. When you go on maternity leave,
you don't generally know how long you're going to go
for, and my expectation at that time was that I would
have come back to the Shareholder Executive but, during
the course of the year, I ended up getting a different
role at the Department of Energy and Climate Change.

So I just want to be clear, for the record, I don't
think it was envisaged in 2012 that this was exactly how
it would play out. In the end, it was how it played
out.
Absolutely. So throughout that period, from really the
beginning to the end, you weren't physically present at
what we know as ShEx; is that correct?
My last day in the office was 14 March 2012, and I was
never sitting at desks with those people, I was never in

that team again. And as I've said in my statement,
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March 2012 -- I mean, in the course of my career,

I think that's one of the single-most complex set of
transactions that I've ever done, and I had a career as
an investment banker doing transactions, so the critical
path to March 2012 was highly complex and I don't think
we were getting into the weeds of my personal logistics
at that time.

Not just personal logistics but in fact, actually,

physical location and relationship with the Shareholder
Executive team, for example?

The relationship with the Shareholder Executive team we
did discuss because, obviously, before I joined the
Board, I was getting up to speed on aspects of the Post
Office with the Post Office team within the shareholder
team. So we absolutely discussed that. Sorry, I had
thought you meant physical logistics.

In terms of the role of Non-Executive Director, it has
been described by some witnesses as having a dual
function: one of those functions being exercising
governance over the assets, so the normal Non-Executive
Director role; but also communicating the day-to-day
Government perspective. I think that's how Patrick
O'Sullivan has described it. Is that a description that
you would agree with?

I didn't particularly think of it as an asset. My view
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The Post Office Horizon IT Inquiry

of the Non-Executive Director role is as set out in the
Companies Act 2006. As a shareholder representative,
I had some additional things I needed to do, which the
others didn't need to do. That was the way I thought
about it.

Was that additional role communicating the day-to-day
Government perspective or some other witnesses have said
that it involved communicating the Post Office's
perspective to Government, so the other way round.
Which, if either of those, did you see it as?

My view was that the Secretary of State, in his letter

to the Chairman in January 2012, set out very clearly
what he thought the objectives for the Post Office were,
on separation, and I thought it was my role to make
sure, on top of the ordinary Non-Executive Director
responsibilities, that whenever the appropriate moment
arose at the Board table, you know, I could help make
sure those things were happening.

And that was my real priority when I went on to that
Board: to really focus on areas like the financial
stability, the mutualisation, the pension separation and
the sustainability of that company because, as I think
many people have said, at the time that was far from
certain.

So you have the letter from the Secretary of State that
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dialogue all the way through.
Paragraph 50 of your witness statement, you say:

"I was also conscious of the fact that my position
as a newly appointed Shareholder NED was a novel one,
and there was some uncertainty as to the nature and
extent of my remit at the outset."

Can you assist us with what you mean by that?
Yes, so as I said, there hadn't been a Shareholder
Non-Executive Director, shareholder representative on
the Board of either of these companies and, from April
2012 when they were separated, you had two sister
companies, the Royal Mail Group and the Post Office: one
had a shareholder representative and one didn't. There
was no blueprint for that, these companies had never had
a shareholder representative before, so what I was
trying to do was kind of get my foot in the door, start
this process but, also, critically, really critically,
build trust with that Board of Directors. So they were
all new, relatively new, at the non-executive level.

I didn't know any of them. I felt they didn't trust
me, so part of what I was doing at that May 2012 Board
meeting was explaining my role as a Shareholder
Non-Executive Director.
So we'll get to the May Board meeting but I'm going to

take you back in time and the first document I'd like to
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sets out an annual objective?

The letter to the Chairman.

The letter to the Chairman.

Yeah.

Outside of pursuing that, did you see your role as in
any way involving liaison with the Civil Service, with
ShEx, with Government?

Absolutely, absolutely, yes. So I saw my role at the
Board table in the way I've just described it, and
perhaps we'll come on to it, but I was always clear
which hat I was wearing, in terms of being the
shareholder representative or the Post Office
Non-Executive Director. But, in addition, there'd been
quite a complicated history with these companies with
the Government and I think there was a strong sense that
we wanted a reset at separation.

So part of what I was there for was to get in that
room and understand what they were actually doing. We'd
found it very difficult to get information from them
before, and so, as you'll see in my witness statement
and from many of the disclosed documents, a lot of the
time I was then, before and after Board meetings,
liaising with the shareholder team to say, "Well this is
my take on what happened, what's your sense of where

things are?" So it was a really, really strong two-way
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take you to is actually a 2010 document. That is
UKGI00000062. This is a ministerial submission from
Mike Whitehead. It's before your time. Was Mike
Whitehead somebody who you worked with?

Yes, absolutely. He was in the Shareholder Post Office
Team for a long time.

The purpose is set out there. It's a:

"... meeting with Alan Bates on Thursday, 7 October
at his request to discuss the Justice for Subpostmasters
claims that endemic flaws in [the Post Office] Horizon
system have resulted in a number of subpostmasters
having their contracts wrongly terminated by [the Post
Office] and in many cases prosecuted for false
accounting.”

Were these kinds of concerns matters that you were
aware of when you became Non-Executive Director, or
prior to becoming Non-Executive Director?

So in October 2010, I was in the Royal Mail team, and

I wasn't doing anything to do with Post Office. So I'm
not sure I would have known about this at that time. By
the time I became a Director in April 2012, I did have

a kind of background awareness, I would call it, and

I had been, for example, copied, in later 2011, on

a document in relation to the BBC's Inside Out

programme. But! don't recall -- if you had asked me in
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April 2012, "What are the top ten issues on your mind?",
unfortunately, I don't think this would have been one of
them at the time.
Broadly speaking, you were aware of the issues raised by
the Justice for Subpostmasters Alliance?
Not in October 2010, I don't recall that, but yes,
broadly speaking, broadly speaking.
By April 2012?
I'm not sure if I would have, at the time, have thought
of it as Sir Alan Bates and the JFSA, per se. I think
I would have had a general awareness.
Thank you could we turn now to UKGI00048174. This is
a document that's been prepared by UKGI, it's a "looking
back" exercise. I'm just going to read to you a few
passages. The "Purpose" is described there at 1.1, it
says:

"The purpose of this document is to provide
a preliminary view of the key facts relating to the
involvement of the Shareholder Executive and UK
Government Investments Limited in matters relating to
the Post Office Limited's Horizon IT system, and in
particular the events leading to the commencement of the
subpostmasters' litigation which was settled in
December 2019."

There's a passage, it's at page 7, that addresses
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the whole Shareholder Team was refilled. So my role was
backfilled by Roger Lowe and the team beneath were
there. So in a way, I was kind of bonus person on that
Board. The team existed as a whole without me.

So the essence, I think, of what I was saying,
I would agree with. I don't particularly recall it
being deliberately designed that way.

So the suggestion here, as we'll read on, is not that it

was anything personal to you and your circumstances but,
in fact, they intentionally wanted somebody who wasn't
part of the Shareholder Team. It continues there:

"_. at the time of the appointment in 2012, the
Shareholder Team was in the process of negotiating the
Funding Agreement with [Post Office] and we understand
that there was, therefore, resistance from [the Post
Office] to having a member of the Shareholder Team also.
sitting on the [Post Office] Board (where [the Post
Office's] approach to those negotiations would be
discussed). This meant that the Shareholder
[Non-Executive Director], while a representative of ShEx
and performing a key role in terms of bringing
Government experience and perspective to the [Post
Office] Board, was purposely detached from the
Shareholder Team; a clear illustration of this being the

fact that Board papers received by the Shareholder
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your role, paragraph 2.16. It describes it as follows:

"In April 2012, the first Shareholder [Non-Executive
Director], Susannah Storey, was appointed to the [Post
Office] Board (and in contrast to the position today,
was not on the Audit and Risk or Remuneration
Committees)."

Is that right?

That's incorrect.

Because I think you were I think on the Audit and Risk
Committee initially?

I was, I had never seen this document until a couple of
weeks ago.

It then says:

"Unlike the subsequent Shareholder [Non-Executives]
(from 2014 onwards), Susannah was, by design, not part
of the Shareholder Team ..."

Can you assist us with that? Is that correct, that
there was an intentional design that you weren't part of
the Shareholder Team?

I'm not sure I would phrase it like that but I'm

assuming it's getting at the point that you were making
earlier: that, structurally, I was separate, initially

because I was on maternity leave and then because I was
undertaking the role from a different Department, and

when I did -- when I went on the Board from April 2012,
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[Non-Executive Director] were not shared with the
Shareholder Team."

We will come on to look at what was and wasn't
shared but certainly from this document -- and you can
assist us whether that's right or wrong -- it seems to
suggest that, in fact, the very role was designed so
that it was separate from those people who were, for
example, carrying out funding negotiations?

There was a real nervousness on the part of the company
and the Chair, which I think you're saying we're going

to come on to, about having a Shareholder Non-Executive
Director and the kind of concern area, in particular,

was the funding because, whilst the Government had put
in £1.34 billion in 2010, plus the debt agreement, at

the time I arrived on the Board, the Post Office was

trying to agree a new funding agreement with the
shareholder.

So that certainly is true that there was concern
about that and the kind of conflict of interest concern
‘was, to my recollection, one of the reasons why I didn't
share the Board papers.

So I think paragraph 2.16 here is broadly correct.

Of course, when it concerns you, you often want to make
fine detail changes.

Who did the Shareholder Team report to within the
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Department?
Within the Department, the Shareholder Team was led at
Director, so after I'd gone on maternity leave, that was
Roger Lowe, he reported in to Mark Russell, the Director
General -- well, Stephen Lovegrove, actually, in 2012

and then Mark Russell, and they reported -- that role
reported into the Permanent Secretary of the Department
for -- what's now the Department for Business, it's had

a number of names.

How about yourself?

I reported into the DG of ShEx, so Stephen Lovegrove and
then Mark Russell in terms of this role. Obviously,

when I was at the Energy and Climate Change Department
I had a separate line for my day job.

So you had two lines of reporting?

Absolutely.

Can I take you to paragraph 54 of your witness

statement, please. Perhaps we could bring it up on to
screen it's WITN00920100., it's paragraph 54. Just

whilst we wait for that to come up, did the reporting

lines change when Richard Callard took over from you as
Non-Executive Director?

Richard Callard was -- my recollection is -- obviously

I wasn't in the team, but my recollection is that

Richard replaced Will Gibson, so he would have been
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was Clear that I would be taking this role on my
maternity leave, then I was in a separate system, as it
were, and my role was backfilled. So that was the team
in the Shareholder Executive advising ministers, and

I was in a separate swim lane, if I could put it like

that.

I want to move on to your initial period as
Non-Executive Director, and could we please turn to
POL00046944. This is a letter you didn't see at the
time. Again, this is going back in time to August 2011,
but it may assist in matters that we will be shortly
turning to. This is one of the letters from Shoosmiths
on behalf of Julian Wilson that was sent to the Post
Office. If we scroll down, we can see the way that his
claim has been described, about halfway down that large
paragraph, it says:

"However, like other [subpostmasters] he found the
Horizon system extremely difficult in operation. He had
no effective way of monitoring or correcting
transactions that were input ed incorrectly. He
observed regularly discrepancies in the reports which he
considered were caused by the system itself. He kept
records of the discrepancies. He noted a number of
‘occasions when the extent of discrepancies would

actually change whilst the store was closed."
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reporting into Anthony Odgers, who was then the Director
of the Royal Mail and Postal Services team, and then
into Mark Russell because that was later in 2013.

Thank you. Paragraph 54, it says as follows:

"As I was not part of the Shareholder Team directly
and was not involved in the day-to-day interaction
between Shareholder Team and ministers in this period,
I did not routinely take part in the drafting of
submissions to ministers on [Post Office] related issues
or their sign-off; nor did I assist with the preparation
of ministerial statements or answers to Parliamentary
questions."

We will see here a number of ministerial
submissions. Am I right in saying that they weren't
shared with you?

No, my recollection is I wasn't on the IT system. Had

I been on the IT system, I'm sure I would have been cc'd
on a lot of things. But because I was separate outside
the building, outside the office, I didn't routinely see

any of these interactions with ministers, nor was I part
of them.

So, in your view, it was intended that you would see
them but, as it happened, due to the technical issues
and your location, et cetera, it didn't happen or --

No, I wouldn't put it like that. I think that once it
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It follows on to refer to a concern about remote
access.

If we scroll over the page, please, we see there
that they say that it is denied, at (c), that the Post
Office had grounds to prosecute Mr Wilson.

It goes on to describe various breaches of
obligations, if we scroll over the page, please, the
letter explains, over the page again. So there:

"The Horizon system suffers with inherent defects
and/or an unfair system of operation", and it goes on to
set that out.

I'm drawing that to your attention because we'll
move on shortly to the way the Shoosmiths litigation was
brought to the attention of the Board. Can we turn
first to your first Board meeting, and that is
POL00021506. Your first Board meeting was 18 April
2012. We see there that you are listed. At that time
there are only two Non-Executive Directors; is that
correct?

That's not correct. There was also Neil McCausland,
who'd already joined but Virginia and I were, in effect,
getting appointed at roughly the same time. So, by
then, you had three Non-Executive Directors and

a Non-Executive Chairman.

Thank you very much. If we scroll down, we can see
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there at POLB12/44 the Chairman welcomed Virginia Holmes
and you to the Board.

If we scroll over the page, please, to page 4,
halfway down page 4, it there notes your appointment.
Slightly up, sorry. Thank you very much.

Then over the page, we can see a number of noting
papers and one of them is the Significant Litigation
Report.

A. Yes.

Q. Does anything stand out for you in terms of this initial
meeting? I mean, it looks from the papers to be
relatively brief, quite straightforward; is that a fair
summary or is it more complicated?

A. I've got quite clear memories of this meeting because it
was my first one. So we were obviously in the Post
Office offices. It was the first meeting after
separation, which was a fairly significant moment in the
company’s history. In terms of the Board itself, no,
I think it was orderly. Obviously, I was both trying to
contribute but also trying to navigate the environment.
I wanted to see how Alice chaired it. I'd never met
these other Non-Executive Directors before, I wanted to
see how the Executive performed. So no, to my
recollection, it was fairly orderly.

Q._ Let's have a look at that Significant Litigation Report.
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papers were right at the back. We obviously would have
read them all before but, to my memory at this meeting,
this paper was in amongst some others around health and
safety at work, those kinds of issues. I don't recall

it being discussed at that meeting, I'm sorry to say.

Q. Having noted that it was at the back, is that -- are we
to understand that it was quite low down the list of
priorities?

A. I think noting papers by their nature come after the
papers that are for discussion.

Q. Being at the back of the noting papers, is there
anything we can read into that or is that just how it
occurred?

A. I---I mean, I didn't mean it like that per se. I think
the Chairman and the Company Secretary would have
ordered the papers. I'm simply saying that was how
I received it.

Q. Thank you. Can we please turn to POLOOO --

SIR WYN WILLIAMS: Before we do, is that it, one page, or
can I just see the whole document?

MR BLAKE: Absolutely. If we scroll over the page, there is
one other entry that is redacted and, if we scroll over,
we can see there's nothing else.

SIR WYN WILLIAMS: = Right. Okay, thank you. Yeah.

MR BLAKE: If we turn to POL00021507, this is a 23 May 2012
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That can be found at UKGI00018251.

This is the first Significant Litigation Report that
you will have received. There's a section there for
claims over £500,000 or those of a sensitive nature.
It's here that it addresses the Shoosmiths claim. It
says:

"The Post Office has received notification of
a total of five claims from former subpostmasters.

"Each alleges wrongful termination of contract
(based on (a) alleged defects in Post Office's internal
processes and (b) alleged defects with Horizon). Each
are seeking damages in the sum of circa £150,000.

"Four of the five claims remain at the pre-action
stage ..."

A fifth has been struck the out. It says:

"Shoosmiths assert that they have consulted on
a further 85 cases, which are likely to raise similar
legal issues."

We saw that was a noting paper. Was there any
discussion whatsoever about that at that stage?
I don't recall any discussion of this paper at that
meeting and just, if it's helpful to give colour, Board
papers in those days were hard copy so we would have
a lever arch file with all of them in and they'd follow

the chronological order of the meeting and these noting
22

Board meeting. By now, Alasdair Marnoch is actually
named there as present and I know that you said that at
the earlier meeting, he had already been appointed,
or

I was referring to Neil McCausland.

Ah, sorry.

Yeah, who actually joined, I think in Q4-2011, alongside
Alice. I think perhaps you didn't pick him up because
he's down as Senior Independent Director but, obviously,
he's a Non-Executive Director.

Yes, well, now we have another Non-Executive Director,
Alasdair Marnoch. If we scroll down, we can see the
Chairman welcomed Alasdair Marnoch to the Board as
Non-Executive Director and the Chairman of the Audit,
Risk and Compliance Subcommittee.

Could we please turn to page 4, and I think this is
the section that you referred to earlier about concerns
about the role of the ShEx Non-Executive Director. It
says there:

"Susannah Storey outlined the reasons for
representation of ShEx on the Board of [the Post
Office]. She confirmed that ShEx representatives would
have exactly the same legal responsibilities as other
directors and, like all members of the Board, would be

acting to promote the success of [the Post Office]. She
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clarified that she would not be sharing the Board papers
with colleagues in ShEx."

Whose decision was that, not to share Board papers;
was that yours or somebody else's?
I covered this in my witness statement and I tried to be
as fulsome there as I could recollect. The documents
unfortunately don't really help me with exactly when
this was discussed and how it was decided but my sort of
reflection now, I guess, is that, given the nervousness
of the Chairman about having a shareholder
representative at all and about the conflict of interest
around the funding review, I would have been mindful of
that, and I think I was -- and again, I'm overlaying
this now, I can't recall exactly how it happened but
I think I would have been very keen to ensure that we
didn't end up with a sort of two-tier Board.

‘So my worry was that, because they were so nervous
about documents and interfaces with the shareholder, the
worst of all worlds for this new April 2012 moment would
have been if the Board had sort of had two rooms, one
where they discussed all the contentious things and then
a very vanilla Board that I was, such that they felt the
papers could be shared.

So I think it must have been an agreement between

Alice and I that I wouldn't share and I guess I was also
25

conversation of a subcommittee of the Board that
I wouldn't be on, and I pushed back on that. In
November 2012, she expressed discontent that I was
talking to Will Gibson about what was happening at the
Board meeting, and I note that, even when Richard
Callard became the shareholder representative in April
2014, the whole Shareholder Team, I understand, was
required to sign non-disclosure agreements to receive
those papers.

So there was a deep-seated concern from this company
about the shareholder and access to information.
You said "she, she, she" but then you said "the
company". Was it in particular the Chairman or was it
more broadly?
I think the reason I described it like that was because
my conversations would have been the Chairman at the
time, and all the way thorough on this issue. I don't
think it was only her but, if you were to ask me exactly
who else, I don't have particular basis to say a list of
people. I do know from my work with the Royal Mail
before that there was a sort of institutional concern
about the shareholder on some matters.
It then says:

"The Board discussed possible conflicts. Susannah

Storey believed that the areas of possible conflict
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mindful of the fact, in practical terms, I wasn't quite
sure how I would share those hard copy papers at that
time.
Thank you. You've said concerns from the Chairman. Was
it just Alice Perkins that had a concern about the role
of the Non-Executive Director representing ShEx, or were
there others?
There are papers noting a meeting between Alice Perkins
and Martin Donnelly, who was the Permanent Secretary at
the Department for Business in the autumn of 2011, where
she is reported to have set out her concerns, and, in
those papers, she says that one of the other
non-executives wouldn't serve on a Board with
a shareholder representative. I knew that, I knew that
had been reported, because there was a bit of a debate
with the ministers and, obviously, Vince Cable ended up
sending his Chairman's letters to her in January 2012 to
make clear that the Government would require
a shareholder representative.

But I didn't know whether those concerns were more
widely held or exactly who held them. I did discuss it
with Alice and, actually, you know, going forward in the
chronology, even after I'd said this, there was still
some serious concern that carried on for a long time.

In May 2012, she proposes a separate funding
26

should be easy to anticipate, funding being a good
example.

"The Chairman thanked Susannah Storey for clarifying
the role of the Director appointed to represent ShEx and
asked members of the Board to flag up any concerns,
either at the time of the meeting or to her separately
if they were more comfortable."

Could we now turn to the bottom of page 7 and into
page 8. I think this is the first mention in the
substantive Board minutes, at the bottom of this page
and over to the next, of matters relating to the Horizon
issues, as we know them, and it's a section there under
"Any Other Business" and it says:

"Paula Vennells and the Chairman updated the Board
‘on the meeting with James Arbuthnot MP and Oliver Letwin
MP, taking them through their constituency cases which,
they believed, that challenged the integrity of the
Horizon system. The meeting had been a success and
James Arbuthnot had now agreed to facilitate another
meeting with the other MPs who also had cases in their
constituencies. The business had also agreed to use
forensic accountant to investigate the system and give
further comfort to those concerned about these cases."

This is under "Any Other Business". Was it a matter

of discussion, do you recall?
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It's obviously very difficult to separate out hindsight
and all the other documents that I've now read and, you
know, all of the awful things that have happened when

I look back at this but I do reflect that there was

a conversation about this, even though it was under "Any
Other Business". It was quite unusual for -- well, it

was only the second Board, so -- but it was, I guess,
interesting that the Chairman and Paula were updating us
together. So I would have noted it, yeah, and I think
there was a bit of a discussion but I can't recall all

of the ins and outs of what were debated.

What did you mean by "interesting"?

Interesting in relation to the Chairman and the Chief
Executive?

Yes.

Well, because mostly papers were presented by Executive
Directors or members of the Executive Team and, in this
instance, it is both the Chairman and the Chief

Executive who had met these two MPs and then were
proposing the forensic accountant to be brought in to
investigate the system.

Is it something that you would have expected a paper to
have been produced beforehand, or is it appropriate, in
your view, for that to have been raised under "Any Other

Business"?
29

This submission details the various background to
the meeting. If we scroll down, we can see the
penultimate paragraph:

“A further development of which we have become aware
since this meeting was fixed is that Shoosmiths, the
solicitors acting for a number of JFSA ex-subpostmaster
members in current legal action against [the Post
Office] submitted written evidence to the BIS Select
Committee purportedly in the context of Network
Transformation, but which is solely focused on Horizon
and related contractual and training issues."

It then says:

“Following previous lobbying of BERR/BIS ministers
over an extended period, Alan Bates met with Ed Davey in
autumn 2010 [and that was the letter that we saw]. This
was in the context of reports that Channel 4 were
planning to run a news item ... The JFSA had also
mounted a substantial lobbying campaign with MPs,
several of whom ... wrote ... on behalf of constituents

Then if we scroll over to page 7, we have the letter
from Sir Alan Bates. Were you aware of these issues at
this time being raised within the Department in which
you were formerly based?

I wouldn't routinely have known about the meeting
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Well, clearly now I would have a very strong preference
for a whole set of different events on this issue.
I think at the time, as my second Board meeting, I was
still navigating this company and this environment.
I don't particularly recall thinking that at that time.
But it obviously is, as we all know now, a very
significant thing that they were telling us about. So,
yes, perhaps not best placed in "Any Other Business".
Could we please turn to UKGI00000065. This is another
ministerial submission, new minister, from Mr Whitehead.
It says as follows:

“Meeting with Alan Bates [so this is another meeting
with Mr Bates, Sir Alan now] at his request to discuss
the JFSA's claims its members are victims of endemic
flaws in Post Office's Horizon system which, over the
last 10 years or so have resulted in a number of
subpostmasters having their contracts wrongly terminated
by [the Post Office], with many also prosecuted for
false accounting.”

Then it lists the attendees. We have Sir Alan
Bates, and then we have Issy Hogg:

"... a partner at Coomber Rich (Basingstoke based
solicitors who have defended a number of subpostmasters
who have been prosecuted by [the Post Office] in recent

years)."
30

between whatever meeting Norman Lamb -- whatever
meetings he was doing nor particularly about this one.
But it is possible it would have come up in my
conversations with Will Gibson, either before and (sic)
after the May meeting. The reason why I say that also
is because this submission references, I think, the
Select Committee -

Yes.

-- that had happened in May 2012, which was also
referenced in those Board minutes because -- I think the
chairman drew to our attention because Paula herself --
Paula Vennells had given evidence at that. So

I wouldn't routinely have known but I can't rule out the
fact Will would have mentioned this to me.

We discussed earlier the issue of ministerial
submissions and I think it was your evidence that you
didn't see them --

No.

-- $0 you wouldn't have seen this particular document?
No, sorry, I more meant would I have been aware that the
Minister for Postal Services was meeting Sir Alan Bates,
possibly. I certainly wouldn't have seen this
submission.

So you had side conversations with, or meetings with,

was it the head of the relevant team in ShEx --
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The Post Office Horizon IT Inquiry

That's right.
- prior to Board meetings, regularly, occasionally?

All of the above. So I would have reached out to him
before and after Board meetings. If there was anything
ad hoc that occurred to him or occurred to me that we
thought was relevant to the other, we would have
absolutely passed it on. We had a very regular dialogue
and, in a way, that was the corollary of the fact that

I was out of the office. So it was to seek to ensure

that what I understood to be happening at the Board and
what he understood to be going on in the Government's
mind about Post Office we could, to the best extent
possible, noting the structural obstacles, we could

share that information.

Were there any formal chance set up or any formal
processes set up for the sharing of information with
you?

Do you mean formally from the Shareholder Team or the
Government to --

From -- exactly, both. Either.

No, not formal per se, in the way of saying right on

a Monday this will happen but it was regular, the
conversations between us. So I didn't feel at the
beginning that I wasn't clear about what was going on.

I think it's fair to say that, over time, that did
33

Chief Executive would be telling us. So I would have,

I think, been reassured that this was being taken
seriously and the Chairman herself was engaging in the
meetings with Mr Arbuthnot.

If we turn, please, over the page, we can see that
there's another Significant Litigation Report being
noted and we can see, again, that Significant Litigation
Report at POL00096747. Similar information to that
first report but now updated. I think it says:

"A third party fraud investigator is to be appointed
(following consultation with various MPs) to review up
to 10 cases where Horizon is alleged to have caused the
losses. It is anticipated that no further court action
will be taken, pending the outcome of that
investigation."

Then there is one other matter noted on that
Significant Litigation Report. Am I to take it again
that that was simply noted, rather than something that
was discussed?

That's my recollection, yes.

Could we please turn to POL00295498. Moving now to
August 2012. This is a meeting between Paula Vennells
and Will Gibson, who was the ShEx Royal Mail Postal
Services team lead. There's a number of matters being

discussed and, over the page, please, the bottom of
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become more difficult, not least because obviously I was
less current in terms of the information and obviously,

by this stage, the Postal Services Minister was Norman
Lamb, then when it changed to Jo Swinson, I didn't know
her and I hadn't worked with her.

Thank you. Can we please turn to POL0002158, taking you
to another Board meeting, this time 4 July 2012. We can
see that you were present at that meeting. If we turn,
please, to page 6, we can see there reference to James
Arbuthnot and it says:

"The Chairman updated the Board on the meeting
taking place on 4 July between James Arbuthnot and
Second Sight, Forensic Accountants. She promised to
keep them informed."

Do you recall at this Board meeting there being any
significant discussion of that issue?
I recall this Board meeting because it was at the
Gatwick Mail Centre, which was unusual. So that was
one -- we used to try to go to different places to do
the Board meeting. I don't recall this particularly.
I note now, of course, that it was the Chairman updating
it - us, as a Board.

What's the significance of it being from the Chairman?
It's the point I was making that, if you look through

the papers, the way it would normally work would be the
34

page 2, there's a section on what's described as
“Arbuthnot activity":

"... arrangements have been made with James
Arbuthnot's office to refer through cases suggested by
MPs for review to him -- which would then be sent to
Second Sight. It is not yet clear how many cases will
be involved but we believe that it currently remains in
single figures (although it may yet grow).”

Do you recall having any discussions with Mr Gibson
or either before or after this meeting?
I don't particularly recall exactly when I would have
spoken to him but, as I was saying, I would have spoken
to him regularly. If he had meetings with Paula, that
might have been the sort of thing he would update me on
and this -- based on this note of the meeting, it
obviously covers a wide range of areas. I'm not quite
sure why the “Arbuthnot activity", as described here, is
under the Select Committee heading, but no.

So I don't particularly recall this but I think it
is interesting, for me reading this now, that Paula was
giving presumably fairly regular updates to the
Shareholder Team.

Yes. But there was no formal structure for you, for
example, to have a prior meeting with Mr Gibson before

he met with Ms Vennells or afterwards?
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A. No, not necessarily. I mean, the Shareholder Team would
be meeting the Post Office team all the time, very, very
regularly. Sometimes they'd be going to their offices,
they'd be meeting on a whole range of things. So that
in itself wouldn't have triggered a specific meeting but
the way I tried to manage my time was to meet him before
or after Boards, or before or after some committee or
other meeting I was having with the Post Office. He
would have been in a very regular interaction, I would
have thought, with the Post Office.

Q. Was it always verbal briefings between himself and
yourself or did they produce, for example, packs of
information for you, updating you, from time to time?

A. No, I don't remember any packs of information coming
from them. I think it was -- it would always have been
us speaking on the telephone or meeting to discuss. We
did have some emails but often that was logistics,
setting up a meeting.

Q. Could we please turn to POL00103348. Moving on to the
19 September 2012 Board meeting. Can we please turn to
page 90. This is a whole pack. This is something that
you've addressed in your witness statement. It's the
Significant Litigation Report, as at September 2012. So
this is now separated out between Part (A), which is

“Civil Claims", and Part (B), which is on page 93, which
37

recall it particularly being an issue from the
separation work because my team had led a lot of that.
So no, at this stage, I didn't read it like that.

Q. Again, am I right to say that this was simply a paper
for noting at the Board?

A. Yes.

Q. Yes. Looking at it now, do you think that there was
a lack of curiosity at Board level when it came to these
Significant Litigation Reports: the fact, for example,
that they are just noting papers?

A. Looking at all of this now, and I've tried to be very
reflective in my witness statement, I think there's lots
of things that could have been done differently and, of
course, you know, when you see these words on the page
now, and you know what happened, absolutely. I wish
they'd been the first item on the agenda. And I think,
when you go through chronology, once we had the Second
Sight Interim Report, every single Board after that,
there was a discussion of these issues. But at this
time, in the autumn of 2012, unfortunately that wasn't
the case.

Q. If we draw the threads together from all of the
documents that we've just been looking at this morning,
we started with the Shoosmiths Letter of Claim relating

to Horizon issues mentioning prosecutions. We then have
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is "Criminal Cases". Thank you. It says, "Criminal
Cases Brought by Post Office Limited”.

First of all, it looks as though these reports are
slightly more sophisticated than the earlier ones. Was
that your recollection?

They were getting slightly longer and more detailed,

yes.

Do you recall any discussion about the reasons for that?
No, I don't recall a discussion. I mean, obviously by
September 2012, the forensic accountants had been
appointed and were undertaking their work, so my
assumption was that was the vehicle through which we
would hopefully learn more about this.

Although Part (B) describes it as "Principal ... Cases
Brought by Post Office Limited", I think you've said in
your witness statement that you weren't aware that Post
Office Limited was itself bringing prosecutions?

That's right. I had a sort of layman's understanding,

I suppose. I didn't fully appreciate until the July

2013 conversations exactly what the Post Office was
doing. My experience, generally, is companies do things
sometimes with bespoke statutory obligations that enable
them to do these kinds of things. I didn't have any
recollection of this prosecution issue coming up when we

were doing the Postal Services 2011 Act work. I didn't
38

the Significant Litigation Reports that refer to the
Shoosmiths claim, although not in that level of detail,
and refer to, for example, 85 potential cases. You then
now have a litigation report that, in fact, mentions
criminal cases being brought by the Post Office. We
have reports of meetings with James Arbuthnot and we saw
a letter to the Minister that referred to the attendance
of a solicitor who represented people in Post Office
prosecutions.

Why do you think it is that nobody at Board level
was drawing those various dots together?
I think it is -- by way of explanation, I think it is
important to put yourselves in the shoes of us in April
2012 onwards. So the Shoosmiths letter of the autumn of
2011, presumably that came to somebody in the Executive
Team of the Post Office, the Board was not constituted
then, that I was on, we didn't see it. The meeting with
Norman Lamb and Sir Alan Bates, the Shareholder Team
would have seen it but we, the Board, didn't see it.
And I think the Board felt -- speaking for myself,
I felt that from May 2012, when we knew the Second Sight
work was happening, that was the kind of frontline of
this issue.

I think when you look at this issue now, with

everything we know, you can see these jigsaw pieces and
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wonder why you didn't see the picture on the front of
the box. But, at the time, from what we saw, we'd seen

a much smaller set of information than even the
documents you're just outlining.

Was it ever suggested to you that you should, for
example, meet with Second Sight or meet with James
Arbuthnot?

No, unfortunately not and, as I've set out in my
reflections to my statement, that is one of the things

that I regret. Sir Alan Bates and James Arbuthnot were
meeting really quite a few MPs, they were meeting our
ministers and they were meeting the Chairman and the
Chief Executive. We, the Board, didn't meet them and

I guess, as I was saying, because Alice Perkins and
Paula Vennells were giving us updates, we took some
comfort from that.

I think in your witness statement you've said that you
received an unequivocal message that the Executive had
complete confidence in the accuracy, integrity and
robustness of the Horizon system. Was that at this
stage?

That was really all the way thorough. I mean, I mention
in my statement that, even attached to the lines around
the BBC Inside Out programme in 2011, there was a kind

of press notice or public comments from the Post Office
41

Strategy Director at that Department.

Was it at that time that you stepped back from the Audit
and Risk Committee?

Yes, that's my recollection, yes. So in March 2013.
Looking back at it now, do you think that that was

a particularly important committee for somebody with
those Government links or ShEx links to have been
sitting on?

Well, the -- if we go back to that 2012 letter to the
Chairman, the pensions issue was really very front of
mind, so when we separated the company and the
Government had taken on these huge liabilities, we were
worried to ensure that the pension remained sustainable.
So I personally was quite worried about that issue
because I knew it was in the Government's mind. In

a general sense, yeah, I think Audit and Risk is

an important Board committee.

Did anybody step in to fill that role?

The Audit and Risk Committee was Chaired by Alasdair
Marnoch and had other non-executive members and
obviously the Finance Director. Nobody from the
Shareholder Team would have done that but,
constitutionally, I'm not sure how that could have
worked.

25 SIRWYN WILLIAMS: Before we move on, could we have that

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very unequivocal. My recollection of really all the
conversations at this stage were "robust system, nothing
to see here", that kind of sentiment. Yes, absolutely.

As the person on the Board who had a link to the
Government or a link to the Civil Service, do you think
that, at that point in time, you should have been

probing more on those issues?

I think -- I suspect all of the NEDs feel, whatever the
hats they were wearing, and I certainly feel now, on
reflection, of course, I wish that we had, from the
beginning, done a series of things in a different way.

I did expect, and I've now seen documents to illustrate,
that the Shareholder Team from 2010, when Ed Davey was
asking, 2011, they were going back and forth to the Post
Office on this issue, and they were continuing to get
those unequivocal messages and they were getting more
detail that the Post Office was saying supported those
things.

By March 2013, you had returned full time to your day
job at the Department for Energy and Climate Change,
your new role. I think you've described it in your

witness statement as a demanding role; is that fair?

I think anybody finishing maternity leave finds their

new jobs reasonably demanding but, yes, it was

a demanding job. I was doing a job share, we were
42

litigation report back on the screen, so that I can see
the next page.

MR BLAKE: Absolutely, sir. It's POL00103348, page 90. The

section with the criminal cases is page 93.

SIR WYN WILLIAMS: Yes, just the next page, please. So

we've got four criminal cases under Part (B) on that,
and then it goes on. That's what I wanted to see. Yes.

MR BLAKE: I think that's the final page of --
SIR WYN WILLIAMS: Yes. I understand that this paper was

for noting but, for the first time, as I understand it,

the Board is being given information about completed and
‘ongoing criminal cases, yes? Just glancing at them,
some of them are very significant. Someone has pleaded
guilty to stealing over £100,000 on the page we are
looking at; two brothers are accused of fraudulently
obtaining or stealing over £200,000.

Forgive me if I'm a little surprised that nobody
thought to discuss these things but that appears to be
the case.

Well, I agree with you and, you know, when you look at
this page now, absolutely. I can't recall the
discussion but it's actually hard for me to recall --

SIR WYN WILLIAMS: I'm not for a minute suggesting you

should remember the words spoken but the impression

I get from you -- so now is your chance to correct it --
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that because this paper was to be noted, there was
literally no discussion of it and, you know, I'm not
hiding it, I'm expressing my surprise that a Board, for
the first time confronted with this sort of detail,
doesn't discuss it at all.

A. Yeah, and I mean I agree with you and I don't recall
a discussion. I also don't recall anybody highlighting
it to us either. But I totally take your point.

SIR WYN WILLIAMS: Yes, sorry, Mr Blake.

MR BLAKE: Sir, that might be an appropriate moment to take
‘our first break of the morning.

‘SIR WYN WILLIAMS: Very good.

MR BLAKE: Can we come back at 11.15?

SIR WYN WILLIAMS: Yes.

MR BLAKE: Thank you.

(11.06 am)

(A short break)

(11.18 am)

SIR WYN WILLIAMS: Yes, Mr Blake?

MR BLAKE: Sticking with the agenda for 19 September 2012,
that's POL00103348, we see there, for example, item 11
is discussion of the British Postal Museum and archive
funding. Is it odd that something like the Postal
Museum might be an item for discussion but the

prosecution that led to, for example, imprisonment for
45

busy time for you in your ordinary day job; is that
correct?

A. Not June and July no, in my day job. That was only
a particular issue in October/November 2013. So this
period, it was just ordinary day job.

Q. Thank you. If we scroll down, we can see an email there
from Martin Edwards, the Chief of Staff to Paula
Vennells, emailing the ShEx team to arrange a meeting
for Alwen and I think either Martin Edwards or possibly
Paula Vennells, with Will, Mike and Peter, and the topic
being the "[Post Office]/BIS meeting on Second Sight
investigation".

Is that something you would have been updated on by
the ShEx team?

A. I don't recall being updated on this issue on 28 June
because on 1 July, when we did have that Board call,
that was a surprise to us as a Board. 1 July was
a Monday, so it's possible this was late the previous
week and, therefore, I hadn't had a chance to talk to
Will Gibson. Also this is setting up a meeting, isn't
it, rather than actually discussing the issue.

Q. And if we please turn to UKGI00001656, we see another
email from Mr Edwards in the middle of that page,
please, emailing, again, the ShEx team in relation to

the James Arbuthnot meeting:
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two years, sentencing to 20 months, et cetera, that's
outlined in the Significant Litigation Report, wasn't
more of a discussion at Board level.
Of course, and I think it would be impossible not to
take that few now, looking at this. At the time, as
I think I said in my witness statement and is normal
with all corporate governance, the agendas, the rhythm
of meetings would be set by the Chairman and we as the
Non-Executive Directors, would follow that.
Did you ever have the opportunity to input into what
would be on the agenda?
Not routinely. I think, if -- for example, I am
assuming if one of the committee chairs, say Alasdair
Marnoch, who Chaired the Audit and Risk Committee, or
Virginia Holmes, who chaired the Pension Committee, if
they felt there was an issue of sufficient materiality,
it would -- they could put it as an item on a future
meeting.

And we would look at the forward look, perhaps, for
a year ahead but not -- I don't remember shaping the
agenda myself.
Moving now to June 2013, could we please turn to
POL00167917. The June/July period 2013 was
a particularly busy time in matters relating to the

Horizon system, and I think that was also a particularly
46

"We thought it might be helpful for you to see this
brief which we prepared for the meeting with Arbuthnot

this morning, to give you a clearer picture of both the

facts and handling issues at play ...

"Obviously strictly [private and confidential] but
happy for you to share some or all of it with Jo
[I think that's Jo Swinson, the then Minister] if you
believe that would be helpful -- I'll let you judge
(useful to know ahead of Paula's call with her so she
knows what she's sighted on)."

If we scroll over the page, we can see a copy of the
briefing. Perhaps we could look at page 4 and 5
quickly. We have looked at this with other witnesses.

This is a briefing note on -- prior to the meeting with
now Lord Arbuthnot. We can see at the bottom of page 4,
"Additional point if needed":

"Depending on the note of the meeting, it may be
appropriate to address head on [James Arbuthnot's]
apparent annoyance at the issues around prosecutions and
systems ‘exceptions'."

Just pausing there on the word "exceptions"; were
you aware around this time of the use of terminology
within the Post Office referring to, for example, bugs
as "exceptions" or "anomalies"

No, I wasn't familiar with any of that and I don't
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think, as a Board, we had even particularly focused on
this issue of bugs that obviously came out in the Second
Sight Interim Report.

If we scroll down, there's a section there on "Current
prosecutions". If we scroll down, we can see a further
entry on "Historical convictions", and it is there we've
addressed with other witnesses. It says:

"Nothing has emerged from the interim findings given
to us by [Second Sight] which would point to specific
convictions being unsafe."

Then it addresses "System exceptions".

So we've seen that this briefing has been copied to
ShEx but was that the kind of thing that would be shared
with you?

No, and I mean this particular week from Monday, 1 July
2013, onwards, was obviously very intense in a number of
layers but, having now seen a lot more of the

information, my perspective is that the least informed
group at this point were the Board. So we had had

acall on 1 July. This is, I think, a briefing for

Paula Vennells to meet Lord Arbuthnot, which is then
being shared with the Shareholder Team, and the Post
Office team are sharing quite a lot of information with

the Shareholder Team that week.

We, the Board, at this stage, hadn't had this --
49

of systemic issues with the Horizon system (and it

should be noted that this is based on a detailed review

of the four ‘best cases in terms of compelling

evidence). However, as expected, they do intend to draw
attention to wider failings in the training and support
provided to subpostmasters, with the implication that

this was the root cause of some of the problems related
to Horizor

There's reference there to the "Monday Board call"
and also "on receipt of this". What was your
understanding at this point of the likely finding of the
Second Sight Report?

My recollection is, at this stage on 4 July, all I knew

was what we'd been told on 1 July. We hadn't seen any
draft document, we didn't actually see that until the
following week. So everything we knew was as reported
to us by Paula Vennells.

What was your understanding? We see there, for example,
reference to "no evidence yet of systemic issues"; were
you aware that the Second Sight Report was an interim
report, for example?

Yeah, I think we did know that from the Monday night
call, although, as I say, we hadn't actually seen the
document itself at that point. On the Monday night

call, we had been, my recollection is, really quite
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well, we never got this document, as far as I know.
Is this an example where it might have been better for
you in your role to have been based at the Department,
or within ShEx, or within the broader Department?
I have set out in my statement that one of the reasons,
when I decided to resign a year early from the Board, in
part it was because I thought it was actually difficult
to do the job of Shareholder Non-Executive Director and
not be in the team, and I thought it was better that my
successor, there was just one line, that individual was
in the Board and they were completely immersed in the
Shareholder Team, the advice to ministers, and all of
those things. And this is an example to where the
Shareholder Team knew more than the Board.
Thank you. Moving to the Second Sight Report and
receipt of the report, can we please turn to
POL00145185. We're now on 4 July. Paula Vennells does
send the Board an update, and I'm going to read to you
just a few passages from this update. It begins:
"I wanted to send you a brief email to update you on
where we are with the Second Sight investigation."
Second paragraph, around halfway through, it says as
follows:
"In line with our discussion on Monday's Board call,

we understand that they have not found any evidence yet
50

surprised that this forensic accountants’ work, that had
been going on for over a year, was suddenly coming and
we hadn't seen it. But, in terms of the findings of

that Interim Report, all we knew was these kinds of

lines, which were what Paula Vennells was also saying on
Monday, no evidence of systemic issues.

But I'm assuming on 3 July the Executive also
wouldn't have seen the final Interim Report.

If we look at the next paragraph, around halfway through
that paragraph, it says:

"They shared with us today the introductory sections
of the report, which gave some cause for concern in
relation to the overall professionalism of the drafting
and the widespread use of subjective (and at times
somewhat emotional) statements of opinion rather than
more neutral or evidence-based insights."

Second Sight had been appointed as independent
investigators. Did you have any view at this stage with
regard to the way that their report was being described?
No, we could only know what we were being told at that
point. They'd been doing this work, there'd obviously
been interfaces between them and the company and, on the
Monday night, Paula had updated us, and then here she's
sending us a further email. We didn't have any other

information and, as I'm sure we'll come on to, we were
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quite irritated.
We see in the next paragraph:

"We are focusing heavily on our media and
stakeholder handling strategy.”

Were you aware of a particular strategy in respect
of the media and stakeholders that was being pursued at
that time?

Not particularly in relation to this issue, I would have
expected, if there was any report, information, action

the company was taking that it was going to have

a public face, somebody in the company would have been
thinking about this but I wouldn't have read this in

this email as particularly unusual.

Can we please turn to POL00099121. If we start on the
second page, please, moving now to 6 July. The Board
are emailed again by Paula Vennells, "A quick further
update”. She says:

"I have had two further very constructive telephone
conversations with Alan Bates of the JFSA, which
confirmed his willingness to work collaboratively with
us in taking forward our response to the review."

Second paragraph:

"It is worth emphasising that Alan Bates' main issue
is not 'the computer’ but the human aspect: how in his

view Post Office failed to support and help vulnerable
53

a number of people being sentenced to significant terms

of imprisonment, did this paragraph strike you at all?

I think the whole email struck me. So on the Monday

night, we'd had this Board call, which had been

difficult, and we were being told about this Interim

Report coming. Then we'd had an update on Thursday,

this is now the Saturday morning. There's a whole load

of information in here that I think I would have been

very uncomfortable about. This -- can I just check,

this was the Saturday morning, the 6th, was it

It was the 6th.

-- because I thought I saw at the top the 8th, but that

was -- it's just a forward document, was it?

Yes, we'll go to the email of the 8th as well.

Okay.

Perhaps let's turn to the first page and that is the

8th. I don't need to take anybody to it but we also

have a copy of this at POL00297468. But sticking with

this version, we then have an email from Sarah Paddison,

so presumably on behalf of Paula Vennells, which says:
"As promised in my previous email, here's a copy of

the final draft of the [Second Sight] Report ... They

took on board the majority of our comments over the

weekend, but not all of them. The second attachment is

an internal note detailing the remaining aspects of the
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and 'muddle headed’ [subpostmasters].”

Next paragraph:

“He also raised the idea of setting up a new
independent third party that [subpostmasters] can
approach if they are facing issues with Horizon ..."

If we scroll down, please, it says:

“Alwen and I then had a further meeting with James
Arbuthnot yesterday afternoon which was also positive.”
If we scroll over the page, please, I'm just going

to read to you those final two bullet points. 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. Ifit
does, then as I 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."

Now, having looked at all those documents that we
saw this morning, in particular the updated version of

the Significant Litigation Report, which identified
54

note which we believe are misleading or factually
inaccurate."

Is that something you recall receiving?

Yes, there was a whole series of emails, as I said,
through the previous week and then into this week and,
obviously, the Board was very keen to get its hands on
the Interim Report.

Can we please turn to POL00297469, and this is

an attached statement. So this is the media statement
that was attached in that -

Sorry, actually, if we go to the previous email
that's POL00099121. We see there, below that email that
I just took you to with the report, there is another
email from Paula Vennells of the same day and she
attaches a draft media statement.

This is Monday, the 8th?

Yes, sorry, if we turn back to POL00099121, so we see
below that, if we scroll down, we can see that is

another email from Paula Vennells saying, "I'm attaching
the latest draft of our media statement", and that's the
document that I'm just going to be taking you to.

Sticking with this email, though, if we look at the
final paragraph, it says about halfway down that final
paragraph:

"The most significant remaining concern relates to
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his continued determination for us to review past
prosecutions in light of the findings of the report ..."

That's a reference to James Arbuthnot being
concerned about those past prosecutions.

Did the issue of past prosecutions feature heavily
for you on 8 July?
As I say, I think, on 8 July, the first thing I would
have done when I received this email was read the Second
Sight Interim Report. So all of the issues I wanted to
try -- I would have wanted to try and understand and, in
the email that was sent to us the week before and also
in the call on 1 July, my recollection is it felt as if
we were being told a series of rather conflicting
things: there was this report coming, it was interim, it
had factual inaccuracies, the business was trying to
correct them, there were no systemic failures but there
were some very serious issues in it.

So this issue, they were all -- I think they would
all have been in my mind at the time and, obviously, as
we might come on to, the 16 July Board meeting attempted
to get the Board to draw together its sense of all of
these things and the very, very urgent actions it wanted
taken.
If we scroll up to the top email, that's your receipt of

the final draft of the Second Sight Report, and you have
57

"The Post Office is committed to supporting its
people and improving the way we do so. The interim
review makes clear that the Horizon computer system and
its supporting processes function effectively across our
network. As the review notes, it is used by around
68,000 people in more than 11,500 branches, successfully
processing more than six million transactions every day.
The review underlines our cause for confidence in the
overall system.

"It does however raise questions about the training
outputs we have offered to some subpostmasters and we
are determined to address these issues."

Having read the Second Sight Report, do you consider
that to have been an accurate reflection of the report?
I don't know, at the time on that Monday, how much
I would have been looking at this press statement.
I think I would have been more likely to be reading the
Second Sight Interim Report to try to understand what it
was saying and I do have a memory of being concerned by
what it was saying and, in particular, thinking about
this point on training and support, and helplines. So
I don't think I would have particularly been thinking
does this draft press notice exactly accurately reflect
what was in the report on that day, but these --

But having read the ultimate press reports in the press
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said you read that report. Can you recall when you read
that report?

I can't recall the time of day, if you mean that. But

I would have -- and I also can't tell from this redacted
document if that email address for me, it looks like it

was my Energy and Climate Change email address, so it
would have been coming to me at work. So I might have
read it really very quickly but I can't recall. The

other thing that would have been in my mind because, as
we have briefly discussed, the Shareholder Team was
getting information and, as we now know, the next day
the Minister ended up giving a statement in the House,
so I would have been very keen to understand what was
going on with Will Gibson, Roger Lowe and that team in
relation to the Minister.

So as at 8 July, you would have read the Second Sight
Report?

I can't think why I wouldn't have. As I say, it is

difficult, 12 years ago, or whatever it is, 11 years

ago, to say the time of day when I would have read it.

I would just like to take you to the attachments to

those emails. If we could first look at POL00297469.
This is the media statement that was attached to the
second email on that page. About halfway down, it says

there:
58

itself, did you have a view as to whether the Post

Office was being accurate in its summary of the Second
Sight Report?

I can't recall particularly thinking about the Post

Office's press reports at the time. I think the lines

we see here are reasonably consistent with what we had
often heard from the Post Office and then, even after

the Interim Report, what we continued to hear around,
you know, the sort of -- and I'm summarising -- but
broadly the system working, and then there being
questions and issues around training and support.

Can we turn to POL00297470. This is another attachment.
This is the "Post Office Horizon [Question and
Answers]". Would you have read this attachment at the
time? Sorry, it's not on screen yet. Do you recall

this document?

Well, I've seen now it was attached to an email.

I don't particularly recall this and I'm not sure at the

time that I would have been most focused on Q&A and
press releases. I would have been much more likely to
be worrying about how the Board had been blindsided and
what this report said and what we were going to do about
it, and what was the Minister going to say.

I'm just going to read to you a few passages from this

document. The second paragraph says:
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"We cannot comment on any individual cases but of
course all cases were fully tested in court and no
evidence found to suggest the Horizon system is at
fault."

Another question posed is:

"Are you saying you are going to review all these
cases?"

It says:

"The review has raised some concerns regarding or
training and support processes. Of course it is only
right that a review should be undertaken of any cases
where we feel the findings of this interim review might
have any bearing.”

If we scroll down, there's a question:

"I've heard there is evidence of faults with the
system?"

It says:

"As the review stresses, the Horizon system has
around 68,000 users and processes more than six million
transactions every day. While we take every case very
seriously, the total number of cases accepted by the
external reviewers for this review was 47, less than
0.1 per cent of the total number of users of the Horizon
system.

"With a system of this scale, of course there may be
61

police and Crown Prosecution Service?"

I know you said you don't recall paying much
attention to these particular attachments, rather than
the report itself but were you, at this time, aware of
public lines being taken by the Post Office that were
different to what you had read in the report?
I don't think I would have been on that day, Monday,
8 July, and I don't recall particularly seeing this Q&A
document. This looks like a draft but I'm assuming
there was a final one that was similar, so --
This was the attachment to --
To that email.
-- that email, the second email on that page, sent to
you by Sarah Paddison on behalf of Paula Vennells.
I think, if I -- I obviously appreciate why you're
asking it the way you're asking but, if you put yourself
in the shoes of an individual who has been, as a Board
member, waiting for this report, slightly surprised it's
coming in a rush, getting conflicting messages, I think
the thing that would have been on my mind would have
been what is in this report and what are we going to do
about it? I just don't think I would have been
comparing public lines and Q&A at that point.
Do you recall at that point having any discussions with

anybody at ShEx about the report?
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exceptions whether this is as a result of a power cut or
through operator error. We have systems in place to
identify and rectify these as quickly as possible (check
against findings in report)."

Then:

"Whenever reconciliation issues arise in the system,
we contact branches to inform them that reconciliation
is required, either by Post Office or branch.”

If we scroll over the page, there's a section there:

"Why have you destroyed documents relating to
criminal investigations?”

It says:

"In line with industry standards we operate
a seven-year document retention policy."

If we keep on turning over the page, please, to
page 7, penultimate page, "Why are you able to run your
own prosecutions? This can't be fair?"

It says:

“As with HMRC and other bodies which safeguard
public money (need to check the accuracy of this), the
Post Office has investigation and prosecuting
authorities in its own right."

Then there's a question:

"Will you reconsider investigating and prosecuting

cases yourself instead of handing these functions to the
62

I can't, in my memory, recall the to and fro with ShEx
but I know that I would have because this was such

a significant issue. On my time, on the Board, I think
I'm right that the Minister only gave two oral

statements, and one ended up being on Tuesday, 9 July
2013. So that would have been a significant thing for
them and, as I've now been able to see, there was a lot
of to and fro between them and the Post Office getting
ready to brief Jo Swinson, and she also has been to this
Inquiry.

Do you think that there was insufficient sharing of
information from the ShEx team to yourself on issues
relating to the Second Sight Report?

I mean, I haven't thought about it -- I didn't think

about it like that at the time. Now I've seen all of

the to and fro, I think one of my observations would be
that what was so unusual about this issue was that the
Chairman and Chief Executive were having the interface
with Sir Alan Bates and the JFSA and James Arbuthnot.
MPs were raising things with ministers through
Parliamentary Questions, correspondence. There was a to
and fro between the Post Office and the shareholder and
I think in this week, it seems to me now, with

everything I've seen, the Board were the least informed

of all.
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As the Government representative on the Board, was there
a problem there in the communication from those who were
working on behalf of the Government?

I didn't -- I wouldn't put if it like that but, and

I don't think there was a problem. I've described the
way in which we worked during this period. I think we
would have been very regularly discussing. I think, of
course, now when you look back, everybody would have
wished, and I certainly wished I had a whole load more
information at a number of points, and this one
included.

Was it lines of communication, was it individual
personalities: what was it that interrupted the flow of
information relating to the Second Sight Report?

I don't think I did say that the flow was interrupted.

It was more that there was a set of events playing out
very fast in realtime and so I imagine the Shareholder
Team's priority, rightly, was to brief the Minister. My
priority was to get the information as a Board member,
and we would have been communicating between us.
Let's turn to the Board meeting. Can we please look at
POL00021516. That's the 16 July 2013 Board meeting.
It's a meeting that the Inquiry has looked at on

a number of occasions.

We note there, in terms of those who are present,
65

the conversation but I think there was a kind of -- my
recollection is there was a sort of groundswell of
discontent.

Aimed simply at the Executive Team or at others?
When you're a Non-Executive Director, your role really
is to provide oversight, but the Executive Team and, in
particular, the Executive Directors, are the engine room
of the business. They are the people who are
responsible for running that business, for undertaking
with appropriate care and diligence all of their tasks,
and I think we felt frustrated that, after over a year

of work, there was suddenly this very rushed week, the
report had been published and, you know, I would have
felt that the Minister had been put in a difficult

position, having to make a statement to Parliament.
Were there any individuals specifically named during
those discussions that stand out?

I don't recall that. I think this was part of where

some of my concerns about the Chief Executive were
starting to crystallise.

What were those concerns?

It's really hard to talk about somebody's performance in
this context now, with everybody reflecting with such

a spotlight, and in my experience of Executive Teams,

performance can change, people can be stronger and
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that Susan Crichton was not present. Did you understand

why Susan Crichton wasn't present?

No, no. A lot of the issues around that that have been

brought out in this Inquiry, I was not aware of on that

day.

Did you attend a pre-meeting to the Board meeting in

a restaurant?

There was a breakfast that morning. In fact, when

I wrote my statement I couldn't identify if it

definitely was that morning, but I think now it was that

morning, and that, my recollection is, was with the

Chairman and those Non-Executive Directors who were

there; Neil McCausland had given apologies that day.
But yeah, I do have a recollection of a conversation

of just the non-executives and the Chairman with a lot

of discontent being expressed about the way this set of

events had unfolded.

Was that directed at a particular individual?

My own view was the Executive had mishandled the

interface between the Board and the whole of this Second

Sight Interim Report, and I held Paula Vennells

responsible for that, as the Chief Executive.

That was your own view. What were the views of others,

just as expressed at that breakfast meeting?

Again, it's -- I can't recall the ins and outs of all of
66

weaker on different things. I think I felt, though,
that this particular issue hadn't been well handled by
the Executive Team and, despite the rush of
communications, some late-night emails, some weekend
emails, it just didn't feel orderly and, as
a Non-Executive Director, the things that you take
comfort from are that the organisation is orderly,
thoughtful, no surprises.

No surprises is a really big thing. I still think
of that and use it a lot today. You know, I have 42
arm's-length bodies in the Department I'm responsible
for, you do not want to be surprised. And I think, at
that time I felt that it hadn't been well handled and
I think that comes out in the minutes for the subsequent
board that day, where we went on to say we didn't want
to be blindsided and a whole load of actions were put in
train.
We mentioned just before the absence of Susan Crichton.
That was explained by Alice Perkins in her evidence, if
Iam to summarise, that events overtook her, and I think
it was along the lines of the thought didn't come into
her head to invite her back in. Were you even aware of
Susan Crichton sitting outside that meeting?
I don't recall anything to do with her sitting outside.

Obviously because some of the papers we looked at that
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day -- there was a paper from Susan written on 12 July,
it was from her -- yeah, I suppose I might have thought
why was this being presented by Paula Vennells, but

I don't remember now a big focus on that. And I suppose

I also would have thought that, if the General Counsel
wanted or thought she should be in the room, she would
have been in the room. It wouldn't really have occurred

to me that somebody would stay outside a room.

Was the atmosphere in the room such that matters were
happening very quickly, it was a particularly rushed or
particularly packed Board meeting or not?

I don't recall that. I mean, as -- you know, the Board
agendas for this company through these years, when I was
a Non-Executive Director, were hugely full because there
‘was so much business to be done on very difficult and
important issues. I don't particularly recall this one

being more or less packed than any other.

Thank you. If we go through a few passages from the
minutes, we see at the bottom of this page:

"The Board discussed the papers received from the
Executive Committee members and agreed that in future
the content of the papers would not be presented at the
Board meeting so as to free up time for discussion. The
papers needed to be clear, not overly optimistic, and

commercially focused so questions of fact would not be
69

Board asked if Susan Crichton, as General Counsel, was
in any way implicated in the prosecutions."

At (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."

There's a reference there to “the business". Can
you recall specific names being mentioned?
I don't recall particular names but, you know, I think
the day-to-day interface would have been between Paula
Vennells and, as we've discussed, she gave a number of
the updates, and also Susan Crichton.

"The Board accepted this was an independent review and
therefore things could happen that were beyond the
control of the business.

"However, the things that could be managed by the
Business needed to be well managed with strong
leadership and the Board asked the CEO if she had
considered changing the person leading for the
Business."

What did that mean?
I think it was -- there was this sense, and it's quite
hard to disaggregate now specifically which meeting

different considerations came up and were then discussed
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necessary. They should also arrive in good time. The
Chairman asked the Board to contact the ExCo member
responsible for a paper before the meeting if they were
unclear or didn't have the necessary detail. The Board
also asked for earlier warning when risks and issues
arise to ensure they were not blindsided."

Can you assist us with that passage, please?
Well, I think we had been blindsided the week before,
and we were irritated, and my reflection is, in any
situation in any company, or if something starts to go
wrong, those are the times that you want to get into
more detail. I think we felt that we'd been bounced by
the Second Sight Interim Report and so I think that's
why we were saying, "Please give us early warning of
risks, please tell us about risks, please do not
blindside us".

The minutes, as you know, are quite mild in their
phrasing, quite anodyne. A word like "blindside"
I think was probably a direct quote.
If we could turn to page 6, there's a section on the
“Horizon Update". I won't spend much time on it because
this is something we've seen a lot of but at (b) it
says:

"The Board were concerned that the review opened the

business up to claims of wrongful prosecution. The
70

and acted on, but there had been a sense, increasingly,

I think, that the Second Sight Interim Report and Second
Sight, they were independent, the Board itself hadn't

had particular control of the terms of reference. If

you remember back to the May meeting, we were just told
in AOB that this was happening and we thought it was

a good thing to do.

But I'm assuming there was a sense at the time that
we wanted -- because now we'd seen the report, there
were a load of actions being discussed to be taken
forward, we wanted a kind of programme of work with
clear leadership and if you're a Board, a Non-Executive
Director, what you want is to be confident that they'll
be people leading that who have got the capacity and
capability to do it and will get whatever the work is
done.

If we scroll over the page, please, there's one final
passage that I'd like to take you to and that's:

"The CFO was asked what the insurance position was.
He promised the Board a note on this. He was also asked
to ensure that both [Royal Mail Group] and business
insurers were given notice of the review findings."

Do you recall the insurance position being raised at
that meeting?

I have a sort of vague recollection. I can't recall who
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it was. It may have been Alasdair Marnoch in his
position as Audit Committee Chair because, often in
businesses, if a risk profile changes, regardless of
whether or not it manifests, you need to notify the
insurers. So it may have been that. The other thing is
that the -- as part of the separation of the two
businesses, the Royal Mail Group, I think, had been the
named party on some of the insurance contracts, so --
and we were trying to finish the transitional services,
such that the Post Office stood on its own, so it could
have related to that. But I don't -- I can't -- I've

sort of wondered about this and I can't really recall
much more.

I'll take you to some of the insurance related emails
shortly. If that could come down, please. At
paragraph 127 of your witness statement you say that
this was the first time you became aware that the Post
Office was able to act and was acting as a prosecuting
authority, and you've described your feeling as being
uncomfortable by that. Now, what did you mean by
uncomfortable?

I think, as I said earlier, I'd obviously seen the SLRs
which had talked about legal situations. It just -

I don't recall it having occurred to me, before I read

the papers for this 16 July Board meeting, that ~
73

signs at the time did not point us to that place given
the assurances we were being given."

Looking at this moment in time, where you find out
that the Post Office itself prosecutes people, do you
think that you were sufficiently robust in scrutinising?
Would you mind if I just make a general comment about us
as a Board before I come on to that point?
Absolutely.
When I went onto the Board in April 2012, I was
pleasantly surprised by the calibre, to my mind, of
those Non-Executive Directors. They were extremely
robust, to the point that sometimes I used to feel in
meetings that it must have been quite difficult for the
executive members or people presenting. People did not
hold back in saying what they thought, what they were
worried about and in challenging. So, as a general
sense, I did think we were robust in our scrutiny and
not for this Inquiry but, as you know, there was
an array of things that we were trying to do with that
business, most of which were not easy.

I think the point here is -- and I wanted to reflect
at length in my statement, because the situation has
just been so catastrophic, you can't help feeling, as
a person I was responsible between April 2012 and March

2014 as the Shareholder Non-Executive Director, you
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specifically, what the Post Office itself was doing, and
that made me feel uncomfortable. I was surprised by it.
Did it suggest something quite fundamentally wrong with
the levels of information that was going to the Board?
I don't think I was necessarily thinking that because,
as a non-executive Board member, consistent with
governance codes and best practice, you do not expect to
see the vast majority of information. What you expect
is that the responsibilities are clearly defined, the
delegations are working, you've got first and second
line assurance to sort of double-check. So I don't
think I would have been thinking particularly that
point.

I just had a discomfort because a year into the
business and, having seen the Second Sight Interim
Report, it made me feel uncomfortable.
Can we turn back to your witness statement, please,
page 100. It's page 100, paragraph 218. If we scroll
down, you say in paragraph 218:

"I do continue to think we were robust in our
scrutiny and challenged the [Executive Team] when we had
the information to enable us to do so. And while there
were numerous proactive steps that I have detailed in
this document my view now is that it is impossible not

to feel now that more should have been done, even if the
74

can't help feeling that we should have done more. So
yes, now I think, on each of these areas, could we,
should we, what would have happened if we had done more?
I mean, I set out in paragraph 140 of my witness
statement all of the actions we did take, and I think at
the time, we thought we were being active and prudent.
That's how it felt. It was a very busy time after the
Interim Report, a whole load of things happened. It's

a reflection, though, that, of course, you wonder if you
could have/should have done more.

Given the terms that were used at that Board meeting,
"plindsided", et cetera, do you think you took

sufficient steps at Board level to scrutinise the whole
way that the company was being run at that stage?
Yes, I mean, I think generally we had been and were at
that stage, and continued to be for the period that

I was on the Board, diligent in trying to ensure that

the company was running with an appropriate control
environment and in an appropriate way.

In relation to this issue, after and at that 16th
Board meeting and in the following -- 16 July Board
meeting and in the following weeks and months, there
were a range of things that happened and, yeah, at the
time that did feel very active. As I have also put in

my reflections, you know, whilst we had actions in terms
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of the Mediation Scheme, the various pieces of work and
the follow-on with Second Sight, and later set up the
Board committee, specifically on this, I do reflect now
that we should have done more at that point and onwards
‘on past prosecutions.

MRBLAKE: Thank you, sir. That might be an appropriate
moment to take our second morning break.

SIR WYN WILLIAMS: Yes.

MR BLAKE: If we could come back just after 12.15.

(12.06 pm)

(A short break)
(12.18 pm)
MR BLAKE: Thank you.
Ms Storey, I said that we would address the issue of
insurance and insurance notification, and that's the
issue that I'd like to address now. Could we please
start by looking at POL00099330. So we've had the Board
meeting of 16 July and there was that slightly ambiguous
wording in the minutes that we looked at, relating to
the insurance position. This is an email from Alwen
Lyons to the Board, including you, we can see there --
thank you very much -- and Alwen Lyons says:
"On Tuesday the Board asked for information on three

things this week:

“[First] A paper on Transitional Support Services
77

three days after the Board meeting.

Q. Thank you. If we please turn to page 3 -- bottom of
page 2, and the top of page 3 -- we see, if we scroll
down slightly, Alasdair Marnoch responding to Chris Day,
whose name is at the bottom of that previous email.

Slightly further down, sorry. Thank you very much.

He says:

"On the insurance [question] we were keen to know if
we have currently got insurance cover for any claim
arising? Don't think your answer deals with this
point -- I'm sure Susan will know though."

You're not on this email chain. I'm just going to
go through it just to provide some background and some
context. If we scroll up, it seems as though this is
an email from Mr Marnoch to Paula Vennells, and he says:

"No need to broadcast loudly but I don't think C
[I think that's Chris Day] has understood the question
‘on insurance (or I've misunderstood the answer). Either
way a quick clarification will hopefully avoid more
mails."

If we scroll up, Mr Day responds internally and he
says:

"Sorry if not clear; there are two points -- firstly
the D+O appears to be the policy which would cover this

eventuality, and our understanding is the first 25,000
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"[Second] The impact of the Financial Services
Junction insurance changes ...

"[Third] The impact on Horizon/Second Sight on our
insurance cover."

Then there is a section/paragraph at the bottom. It
says, "Insurance":

"We discussed what impact the current Horizon issues
might have on our insurance on which we are advised by
our insurance broker Miller. Their view is that whilst
other insurance policies may be impacted the most likely
one is [Directors and Officers] -- this has the added
complication as it is the only policy we share with
[Royal Mail] and was placed by their broker, JLT. The
excess on this policy varies under different criteria
but the main one is £25,000 on each and every claim.

A meeting is being set up with JLT and Miller to ensure
they are fully briefed on the issues before JLT engage
with the insurers".

Moving on to POL00099331.

Do you recall receiving that email?

The email that you've just been reading from?
Yes.
Yes, I would have. I think, as it says, we had asked

for things obviously very quickly. So that was coming
78

of any claim is not covered (this is being verified).

"Secondly, our broker (Miller) will meet with [Royal
Mail's] (JLT) to determine the best way to engage with
D+O insurer/s which will enable us to understand the
possible impact on this (and possibly other) policy
premia going forward.

"The subtlety theory is that we need to inform
existing insurers of a potential new risk (in hand)
without ‘scaring the horses’ into immediately increasing
future costs, and this process is made more complex by
being a joint policy with [Royal Mail] (the only one
that is configured in this way).

“Will provide a fuller update when we have
established all the facts, next week.

"Charles -- please confirm my understanding is
correct."

If we scroll up there is an email from Paula
Vennells, forwarding that response to Alasdair Marnoch.
She says:

"Hi Alasdair, did you get the clarification you
asked for?

"lalso left a message with Chris as his note on
insurance cover raised two questions for me. Firstly,
that there could be an impact re future costs across

several policies. I understand D&O but which others --
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may be obvious to the experts but it isn't to me. And
secondly, his note seemed to imply we were going to
check if we are covered -- does that mean we may not
be/we don't know?

"Chris' reply to my question is below. The line
which bothers me slightly is 'D&O appears to be the
policy which would cover ..."

“Am I being too hawkish? I would have preferred to
read 'D&O is the policy which (if needed) will cover

"Does Chris' reply to you give more comfort?
I don't want to pile the pressure on Chris by going
again unnecessarily."

If we scroll up to the top, we have the response
from Mr Marnoch. He says that he's afraid Chris' answer
does not address the key question as to whether or not
the Post Office have got cover:

"He dropped me a note which suggested we do but
seems to suggest it would be under D&O cover. Like you
I'm concerned that we believe this policy would cover us
for this sort of issue -- rather I'm sure we will have a
PI policy which will cover us for this and any other
like issue.

"The follow-on issue is that to avoid the

underwriters rejecting our claim, we need to keep them
81

from the Horizon report. That can be found at
POL00298004. There were two versions of this report
that were sent to Board members; do you recall, in broad
terms, this document?

I do recall it in broad terms.

The document says:

“Further to the Board discussion on 16 July, this
note provides an update on how we're taking forward the
programme of work ..."

So this is essentially how we are taking forward the
matters raised at that Board meeting.

We see, if we scroll down, there's a section on
completing the Second Sight reviews.

Over the page and on to page 3, the bottom of
page 3, where we see there's "Prosecution Case Review",
and it outlines that:

"Through our criminal law solicitors, Cartwright
King, we are complying with this duty by reviewing past
and present prosecutions to identify any cases where
Second Sight Report ought to be disclosed."

Scrolling over the page to paragraph 17, there's
reference there to Brian Altman's review.

Can we go to paragraph 30, on page 7, please.
Paragraph 30 says:

"The Board requested further information on the
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abreast of developments and any possible claims (on this.
and any other issues). Experience tells me that keeping
underwriters updated on this sort of developing issue
can be very tricky getting the balance right in levels
of disclosure. Normally I would have expected Chris to
have been involved in discussions with Susan testing the
thinking at each stage of the process.

"I've gone back to Chris for further clarification
but I suggest it's handled in a face-to-face
conversation ...

"The issues about any disclosure is that it will
affect our premiums even if the underwriters don't pay
‘out. It's a bit like having to report near misses when
you're driving as well as crashes. The result will be
higher premiums, etc, etc. But turn the issue,
hassle/cost) on its head and we can reverse this problem
into a cost saving/process improvement opportunity by
combining necessary reporting to underwriters with
improvements on our own processes identifying mistakes
and a tracking mechanisms to their resolution.”

I'm afraid I'm going through the chain of events so
I. am going to have to read a fair amount from this
chain.

Almost a week goes by after that and then the Board

is provided with an update on the work programme arising
82

insurance position: a separate note is attached on this.
Annexe A also provides further information Directors’
duties as they relate to this review.”

I'm going to just now take you to the covering email
to that. That can be found at POL00145882. If we start
‘on the bottom of page 3, we see Alwen Lyons emails and
we'll scroll up in a bit to see the group, but you are
‘one of the recipients.

"Dear All

"Please find attached a detailed note from Paula
providing an update on our programme of work in response
to the Horizon investigation."

If we scroll up, we can see copied to you a response
from Alasdair Marnoch, at the bottom of that email. He
says:

"Finally I seem to be missing the insurance
update -- could you please resend."

That's a reference to the insurance update that's
promised at page 30 of that document that I have just
taken you to.

If we keep on scrolling up, please, Martin Edwards
then responds and says:

“Apologies all, it should have been this version of
the note attached to yesterday's email, which

incorporates the insurance information (at paragraph 31)
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rather than leave that in a standalone note."

I'm going to take you to that updated version very
shortly but, before I do that, if we could just have
a look at the email from Alice Perkins. She emails,
again, the Board, including yourself. She says:

"I had some thoughts which I want to put on record
about the way ahead.

"First, while it is clear that we are committed to
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."

This is a separate issue but I'd just like to pause
there and ask you about that. Do you recall a movement
towards capping Second Sight's involvement at that
stage?
I mean, I can obviously read the words on this page.
I don't recall thinking of it in that way at that time.
I thought that, after the 16 July Board meeting, there
were a whole load of actions and that included work for
Second Sight.

Because it follows in the next sentence:

"The moment they are involved in additional cases
beyond these, we will have lost the ability to end the
relationship with them

Were you aware of a desire to end the relationship
85

"Second, we need to pin down and cap [Second
Sight's] costs ...

"Third, we need a proper process of appointing the
independent Chair of the Working Party."

Then, "Finally", she says:
... [have asked Susan to keep the Board fully
informed of future developments and to alert me of
anything which she is unable to resolve which could get
in the way of getting the job done in the way it needs
to be done. She will be seeking conversations about all
of this with all the [Non-Executive Directors] on
an individual basis and will be in touch with you to
arrange these.”

Moving on, please, to POL00006590, this is the
updated version of the report that was circulated to the
Board.

Sorry, is this -- just to clarify, is this the one that
you're saying that Martin Edwards sent us —

Exactly.

Okay.

So Martin Edwards sent an email on Saturday, 27 July
that said, "Apologies all, It should have been this
version of the note".

Okay.

This is the updated version of that note. If we could
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with Second Sight at that stage?
I mean, this and all the other things you have just

shown me are a series of emails that were coming in
after the Board meeting. I would have read these words,
noted that they're from the Chair. I don't particularly
remember that issue to a greater extent than any of the
others at this point.

It being, I think, on your own evidence, quite

a significant Board meeting of all the Board meetings
that we've seen, would you have paid quite a lot of care
and attention to the emails you were receiving at that
stage?

You mean 16 July?

Yes.

Yeah, absolutely. I mean, I think that, even in the

‘ones you were just showing, I'm sure we'll come back to
the insurance question, but you can see emails coming
out on 19 July which is after we would even have
received the minutes, then emails to and fro, some of
which I was not copied on through the weekend. But
yeah, there was a whole series of actions and I would
have been very focused on it because, going back to our
conversation earlier, I was irritated about the

handling.

Reading on, she says:
86

turn, please, to paragraph 30 and 31, this is the
insurance section. It's page 8. Thank you very much.

‘So we see there a changed form of words. It's
an expanded form of words at paragraph 31, addressing
the insurance position, and it says:

"The Board requested further clarification on their
exposure as directors in relation to the review. As set
out in more detail at Annexe A, it is highly unlikely
that any individual director would have any personal
liability in connection with this review ..."

Then it refers to insurance being in place to cover
their liabilities, and it gives the amount, and then at
paragraph 32:

"In response to the Board's request for a post
mortem, internal audit has now been tasked with carrying
out a review", et cetera.

So there's just a slight addition on paragraph 31 to
what was previously in paragraph 30.

If we scroll down, we can see Annexe A, it sets out
there the Directors’ duties, the focus being very much
on individual liability of directors.

Could we please now turn to POL00193010, which is
another exchange from Alasdair Marnoch at the bottom of
the first page. Thank you. If we scroll down slightly,

he says:
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"I'm afraid the para on insurance does not answer
the question which was about PI cover for the [Post
Office] not D&O cover for the Directors.

"The key question is does the [Post Office] have
insurance cover in the event of a material claim (or
perhaps a ‘class action’ type claim)? Probably easiest
if I pick it up directly with Chris."

Irrespective of this particular email chain and
whether you focused on this particular issue at this
time or not, looking at it, is that a big issue for the
Post Office, whether it has insurance cover in the event
of, for example, a class action claim?

My recollection of the 16 July Board meeting was we
wanted to make sure we were prudent in taking all the
steps we thought needed to be taken, in light of our
understanding at that time of what the Second Sight
Interim Report was saying. So there was a whole raft of
things. I took some personal comfort from the fact
Alasdair Marnoch, as Chair of ARC, and who I found to be
a very diligent individual, was going to take the lead

on behalf of the Non-Executive Directors, I think in his
capacity as Audit and Risk Committee Chair, for kind of
leading some of these areas of work.

This issue and all the to and fro you've just shown

me on insurance, some of which I wasn't copied on,
89

problems with helplines, or the way kind of interface
with the system worked, that was a big issue and, of
course, getting a more clear view of what the actual
situation was.

If we scroll up we can see a response from Chris Day
internally to Charles Colquhoun. He says:

"Charles, please see if there's a straightforward
paragraph we can write on this (should go in my name)
rather than giving them the whole insurance paper."

If we scroll up, there's again an internal
discussion about this, and Charles Colquhoun says:

"Chris -- I don't think Alasdair saw the insurance
paper and maybe the 2 points below (and in particular
the second) covers his point? I'll be in first thing
tomorrow to discuss."

Again, addressing Directors and Officers liability
and professional indemnity, which refers to the limit of
indemnity:

"This covers a breach of duty by [the Post Office]
resulting in a third party loss", et cetera.

Could we please turn now to POL00428835. There was
reference before in one of the email chains we saw to
Susan Crichton following up with all Non-Executive
Directors at this time personally, and it is at this

document, so it's POL00428835. We're now at the
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I don't remember that being high in my list of worry
areas. I wonder if it's simply that Alasdair Marnoch
being diligent, wanted to make sure if the risk profile
of this set of issues -- particularly I think we were
worrying then about disclosure and some of the things
that had been in Susan Crichton's paper of 12 July, he
may simply have felt they needed to be notified.

But I don't remember particularly focusing on this
issue, I'm afraid.
We saw this morning the references to, for example, the
Shoosmiths case and potentially 85 claimants. We're now
at a stage where we have the Second Sight Interim
Report, potential class actions on the horizon. The
notification to the insurers was presumably quite
an important issue for Non-Executive Directors as
a whole, wasn't it?
All 'm saying is I personally don't particularly
remember that being high on my list. Alasdair perhaps
had had experience of some other business where they had
needed to notify the insurers. I also don't remember
particularly focusing on material claims. I think I was
more focused on what are the steps we are taking around
what became the Mediation Scheme, trying to improve the
business processes because that was the single biggest

kind of issue I had in front of mind, that if there were
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7 August, and she is contacting you directly. If we
scroll down, we can see that's in response to the email
that was in this chain, the Alice Perkins email. If we
scroll up, we can see she says:

"Susannah -- hope you are having a good break,
please let me know if you would like to have
a discussion as per Alice's email, and I will organise
a time to meet/talk."

Did you speak to Susan Crichton at this point in
time?

No, I don't think I did because I've now seen an email
or note later in September, I think, where Susan
Crichton says she had spoken or exchanged emails with
the other NEDs and not me. So, from that record, I'm
inferring that I didn’t. I don't know if, when we see

here, it's saying, "hope you are having a good break",

it is likely that, at that time, I was perhaps on

a holiday from work, I don't know.

But my -- I drew real comfort from the fact Alasdair
Marnoch was taking an active role in this work, as set
‘out in 16 July.

You were also at this time a Non-Executive Director at
the Post Office.
(The witness nodded)

Looking at it now, do you think that's an email that you
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should have followed up on?

I don't know if we know that I didn't follow up.

I know, based on the information that I've seen, that

I didn't meet her, so I don't know if it was

a logistical thing and, by the time she was updating in
the autumn it hadn't happened. Of course, I think now,
when you look at it, it would have been good to speak to
her, not least because I now know all of the things
you've said about her not being in the room, and so on.

But, at the time, I felt there was a clear set of
actions, the Non-Executive Director, Alasdair, was
taking a lead. So I'm not sure, in my shoes at the
time, I did feel strongly and, obviously, if I had,
I would have done something different.

We have seen all of those emails from Alasdair Marnoch
about the insurance position and the lack of clarity on
the issue that he is chasing down.

Did you have any discussion with Susan Crichton or
anybody else at this time about the notification to the
Post Office's insurers?

No, not about the insurers. As I say, I'm pretty sure

it wasn't me who raised it at 16 July. I also wasn't

the person charged with following up. So I wouldn't
particularly -- I would have seen some of these emails

coming in and the next opportunity to discuss any of the
93

prepared by Bond Dickinson and we've addressed this with
witnesses from Bond Dickinson. It's over the page,
please, there's a section on "Prosecutions &

Convictions". Again, in similar words in relation to

Mr Jenkins, it says:

"As noted above, where circumstances warrant, Post
Office prosecutes subpostmasters ... Post Office is
reviewing prosecutions ...

"Post Office has an obligation to consider whether
further disclosure should be made to defendants. It is
of concern to Post Office that the expert evidence of
‘one prosecution witness, Dr Gareth Jenkins of Fujitsu,
may have failed to disclose certain problems in the
Horizon system potentially relevant to a case.”

What were you aware of in respect of Gareth Jenkins
at this time?
I wasn't aware, I don't recall being aware of Gareth
Jenkins until a long, long time later.

Looking at this now, does this look to you to be a fair

and accurate notification of the position?

I thought you showed on the emails earlier, Alasdair
saying that there'd been a misunderstanding with Chris
about whether it was D&O or which insurance. It feels

as if somewhere underneath in the business, some people

are instructing Bond Dickinson to write a note. They're
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actions from the 16 July Board meeting would have been
at the September Board meeting as a group.

Let's have a quick look at the insurance notification

itself. That's at POL00112856. This is an email that

we've seen a few times before:

"Please find attached details received of a new D&O
matter for your consideration. The notice concerns
challenges which have been made to the accounting system
used in the Post Office Network ..."

It says about halfway down that covering email:

"A review of the Horizon system was undertaken and
whilst recommendations were made for improvements no
systemic problems were revealed which would call into
question the charges previously made against
subpostmasters. It is of concern to Post Office that
the expert of one prosecution witness, Dr Gareth Jenkins
of Fujitsu, may have failed to disclose certain problems
in the Horizon system potentially relevant to a case.

In the event it is discovered that improper prosecution
was undertaken, the risk exists of a claim being made
against the Post Office and Directors and Officers for
malicious prosecution [et cetera]. It is unclear at

this time the extent of possible exposure ... A copy of
your slip is also attached ..

If we go over the page, we can see the note that was
94

obviously making some assertions.

None of this, I think, came to us and it wasn't
something that we knew at the time, and I think you also
showed an email where Chris Day is saying, "Don't send
the Board the whole note, just do a paragraph”.
Is this note or is the information contained in this
note the kind of information that you would expect to
have been shared at Board level?
I can't really comment on this note per se because I've
only seen it for the first time a few days ago. I think
the point I was trying to make before about not being
blindsided, giving us early warning of risks and all of
the areas that we discussed and are minuted in the
16 July Board meeting, to my mind, were the strongest
signal we, as a group of Non-Executive Directors, could
have sent at that time that this was now, we understood,
to be a much more complicated issue, having received the
Second Sight Interim Report, we wanted to see a series
of actions and we wanted to be aware of what was going
on.

So, of course, now that I see all of this other
information that we didn't see, I can't understand why
that wasn't shared with the Board, having given such
a strong signal at that time on this specific issue.

This was not a general signal; this was specifically
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about all of the things that flowed from the Second

Sight Interim Report.

Aconcern that an expert witness had given unreliable
evidence, whether it was in a case or many cases, would
you have expected that to have been brought to your
attention?

Yeah, I mean, I think, as I was saying, there was a lot

of new news, certainly to me and I think to the other
Non-Executive Directors, at that 16 July Board meeting.
After that, if there's any material risk, issue,

concern, worry, in my experience of Boards, when you're
in a difficult phase, that's when you want and expect
people to be at their most open.

In your view, why did that information not reach you,
looking at what you know now?

I don't know. I don't know.

Can we have look at the October Board meeting. That's
at POL00158089.

Thank you. It has you down as being present but
only at items 13/97 to 13/99. If we scroll down, we see
13/97 is the "Introduction". You then have a section on
"Government Funding and Strategic Plan". Over the page,
please, “Role of the Board" -- if we scroll down -- "and
Relationship with ShEx Post-Funding". It says there:

"The Board noted that Will Gibson would soon be
97

that right?

That was an exceptionally busy period in that role.

I've had many busy periods in my career.

If we scroll down, we can see that, if we go over the
page and over to another page, if we keep on scrolling
down over to the next page, we have the "Chief
Executives Report" and then we have at F, a section on
"Project Sparrow":

"Sir Anthony Hooper has now been appointed as
Chairman of the Horizon Working Group. The business was
working to prepare the team of people to work on the
mediation and case information necessary, as there were
likely to be up to 150 cases put to the Working Party
for a decision on whether they progressed to the
mediation process.”

You weren't present at the Board during that
discussion of Project Sparrow; is that right?

Yeah, the -- I think -- the minutes will be correct in

terms of the chronology of when I left. I obviously

would have read the papers, including the Chief
Executive's update and including this update.

But there was no Government representative on the Board
whilst this item was being discussed?

Well, I was on the Board. I wasn't at the Board at this

point. I think this is the meeting, as well, in October
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leaving ShEx and the Chairman agreed to discuss his
replacement and the ShEx representative on the Board
with Mark Russell, Chief Executive, ShEx."

Then it says:

"Susannah Storey left the meeting."

Can you recall why you were only present for those
first few items at that particular meeting?
Yes, this is the issue that I mentioned in my witness
statement, that in the autumn of 2013, the then
Government decided it wanted to take £50 off everybody's
energy bill in the country, and the people tasked by the
Cabinet Secretary to do that, lead that work, was my
jobshare partner and I. So just at this precise time,
it was very intense kind of conflict of roles, which
meant I had to leave that meeting early.
We see there at (b) it’s also a period of transition
within ShEx itself; is that right?
My recollection is that Will Gibson was taking paternity
leave and so would be leaving the Shareholder Executive
team.
So there are changes taking place in the Shareholder
Executive team?
(The witness nodded)
You yourself have described it as an exceptionally busy

period of your career, outside of Post Office work; is
98

2013 that Mark Russell, who was the Director General by
then of the Shareholder Executive, I think he came but
the written information doesn't help me now work out
whether he -- which bits he came for.
I think if we turn to the second page, there's a mention
of Mark Russell in relation to the changes that are
taking place. If we scroll down, at (b) there's
a reference to Mark Russell but I don't think he's
actually mentioned on the first page as being present or
in attendance.

So you can't say whether he was there for the
discussion of Project Sparrow --
I can't, I can't.
But what we can be sure of is that there was no
Non-Executive Director who was representing the
Government's interests on that Board during that
discussion at the Board?
That's right.
And if we turn to POL00027136, we see there this is the
"Chief Executive's Report". If we turn to page 5, we
can see there's the section on Project Sparrow that's
then discussed at that Board meeting.

Isn't this exactly the period of time when it was
important to have a ShEx representative sitting at the

Board and discussing Project Sparrow with the Board?
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A. I mean, I think the reason why we put a shareholder
representative on the Board after separation was because
we felt all the issues that the Post Office were dealing
with were difficult and important and, therefore, we
generally wanted to increase visibility. Of course,

I take your point, at this point, and at every Board

after 16 July, there was a discussion about the issues

that became known as Project Sparrow. Would it have

been better if I was there? Yes. Did I have

an irreconcilable conflict on that day? Yes. Was this

part of the reason why I concluded I simply couldn't

keep doing this role in the way that I wanted to? Yes.
And that is why, at this point, I started my

conversations with the Shareholder Executive to say that

I wanted to resign a year early.

Q. Was there any discussion prior to that point when things
started to become particularly busy in your other role,
as to somebody to replace you or step in for you?

A. I have been clear that I -- my other role was a job
share, so I was working three days a week, and my
jobshare partner was working three days a week, so in
every week, there would be two days where I wasn't
working in the office, doing meetings for that employer,
and, therefore, generally in that year, I felt I could

give sufficient time to the Post Office, and in a way,
101

difficult. I haven't had any period of my career as
a civil servant when I've seen ministers less on
an issue than I did at this time. As I said in my
statement, I only saw Jo Swinson once, in February 2013.
So yes, I didn't think it was completely
satisfactory. Was it still better having me than no
one? Yes, I'm sure it was. But, you know, we could
debate counterfactuals.
MR BLAKE: Sir, that might be an appropriate moment to take
our lunch break.
SIR WYN WILLIAMS: All right. What time shall we resume?
MR BLAKE: We can come back at 2.00.
SIR WYN WILLIAMS: 2.00. Fine.
(12.58 pm)
(The Short Adjournment)
(2.02 pm)

‘SIR WYN WILLIAMS: I see you've demoted Mr Beer, Mr Blake.

Very good. Off you go.
MR BLAKE: Thank you very much.
Before the break, we were looking at the 31 October
2013 Board meeting. I am now going to turn to the
November Board meeting, and that can be found at
POL00021520.
Thank you. These are the minutes and we can see

there that you are not in attendance on that day and
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the sort of variable of whether or not things happened
was my time. So I would do the work as needed.

But I had a sort of growing feeling through this
autumn that this was continuing to be a very complicated
Board with a lot of difficult issues, not only this one
because, in another swim lane, as it were, we were just
about to announce the new funding, which was the thing
we'd been working on to make the business sustainable
for the last year and a half. That was announced
I think, in November 2013.

So there was a lot going on, and yeah, that's why
I started my conversations with the Shareholder
Executive.

To summarise where we're at: busy Board, dealing not
just with Sparrow issues and Horizon issues but other
issues; you personally had a lot going on in your other
role; we've also discussed that you weren't physically
present at ShEx any more, not part of ShEx any more. Is
that a combination of factors that caused real issues?
I have said in my witness statement that I thought the
model that was adopted after I left was better. There
were structural obstacles, as we've discussed, in
relation to information sharing. I think, over time,

I felt that I was simply getting more distant from the

Government, and that ~ I found that personally
102

have provided your apologies. Again, is that because
the work at the new department was very busy on that
particular occasion?

Yes, it's the same issue that was in those few weeks,
yeah.

On this occasion, if we scroll down, we can see there is
a significant update on Horizon, the Board has noted the
progress on Project Sparrow, there's discussion of the
Working Group.

If we go over the page, we see there at (c) past
prosecutions being discussed; at (d) future prosecutions
being discussed; there's a request for a note from the
General Counsel explaining who was named in past
prosecutions and the liability for the business. If we
go over to page 3, please, towards the bottom of page 3,
we can see there at (g):

"The Board noted the update on Risk Management and
the actions being taken as set out in [that] paper."

I'd like to take you to the paper. It's at
POL00027483. It's a paper prepared by Chris Aujard. If
we have a look at 2.2, "Allegations relating to the
integrity of the Horizon system":

"There is a risk that the allegations relating to
the integrity of the Horizon system, if not contained,

could raise wider questions over the robustness of our
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core systems and our ability to operate, damaging
(amongst other matters) current partnerships, new areas
of expansion and public and government confidence.”
This meeting, would you accept, was an important
Board meeting in the context of Horizon issues?
I think all the Boards, as I've said, after July, were
important on this issue because each one took an update,
yeah.
Here we have the risk management update referring there
to potential issues to do with Government confidence
arising from Horizon. Wasn't that an important moment
to have the Government representative on the Board
present at the Board meeting?
I'm not sure the paper and the moment, if you see what
I mean, are the key thing. The bigger point you're
making is that I wasn't present at that Board, which, as
I've described, was because of my other role. I would
have read the papers I would have been doing the
follow-up around the edges, including with the
Shareholder Team. It's not totally clear to me whether
that point on Government confidence is actually about
the revenue lines from Government or more widely but,
absolutely, I mean, this issue was extremely
significant. We'd put in train all of these actions.

It was high now on the Post Office's risk register.
105

that I had these concerns.

I don't think it would have been very easy just to
sub-in a person who wasn't a Board member, as a sort of
observer, if that's what you mean. But I did feel --
and that's why I took the steps to step down from this
Board because I felt whoever did it needed to be there
and, as you know and as I've said in my statement, I was
very clear to my successor, which in the end ended up
being Richard Callard, that he needed, in my view, to be
‘on both the Sparrow Subcommittee, which was the place
where these issues were being principally addressed, and
‘on the Audit and Risk Committee.
Looking back at those two meetings that we've just been
looking at, do you think there were missed opportunities
there, where --
Um, I've -- I've set out in my statement a series of
reflections and missed opportunities. I didn't
particularly think these -- this meeting and the one
before fell into that but it's obviously hard to say
when I wasn't at the meeting.
Moving on to discussions regarding the Post Office's
prosecution role. You were party to some of those
discussions in February 2014. By that stage, had
matters moved on in your other role? Was it less work

taking place on the £50 --
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So --

If we can turn back to the minutes themselves it's
POL00021520. I mean, there was discussion at this
meeting. This was the meeting where past prosecutions
were discussed, future prosecutions were discussed.
Well, the Audit and Risk Committee had taken

a discussion on the future prosecutions paper and hadn't
reached a decision, and then decided to come back in
February, as we then see, including with the discussion
at the full Board but yes, I mean, a whole series of
important issues were being discussed at this and the
other Board meetings.

At this time, you also weren't sitting on the Audit and
Risk Committee any more?

I was not.

Why not put in place an immediate replacement at this
stage?

Well, when you're appointed to a Board, there's a whole
series of things happen and, in order to be replaced,

the Shareholder Team needed to find a replacement, the
Post Office would have to accept that replacement and
the steps would have to be taken. So I think I was
flagging, at this stage, as I already said, to Mark
Russell, who was my line manager and the Director

General and responsible for the Shareholder Executive,
106

It was completed. It had been implemented and the
customers who were getting that discount had got it. So
yes, it was a short, intense period that just happened

to coincide with this November Board meeting.

Thank you. If that could come down, please.

By February 2014, there seemed to be three options
on the table, Options A, B and C: Option A being
preservation of the status quo; Option B focusing more
‘on egregious conduct; and Option C being ceasing all
prosecution conduct.

I'm going to turn to a few documents where those
options are discussed, where you have contributed. Can
we please start at POL00167751. It's page 4, 7 February
2013.

Thank you. If we turn to page 4, we can see there
is an email chain. Can you assist us, this is referring
to an Audit and Risk Committee teleconference on the
11 February. You're copied into or you're a recipient
of that email: can you assist us with why that would
have been sent to you at that time?

So my understanding is that in November 2013, the Audit
and Risk Committee had taken a paper on future
prosecutions, which at the time had Options A to D.

They asked for more information and, therefore, it was

coming back to the following Audit and Risk Committee,
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which was in February 2014.

Although I wasn't on the Audit and Risk Committee,
I think the decision had been taken at the previous
Audit and Risk Committee that the full Board should at
least be able to provide their input on the options set
out in the paper but the actual decision was going to be
taken by the Audit and Risk Committee. So my
understanding of this Friday, 7 February 2014 email is
that that is that Audit and Risk Committee paper being
sent to us.

Thank you. At this period, if your diary had fewer
commitments, was that an opportunity where you could
have rejoined the Audit and Risk Committee?

When I took the decision at the beginning of March 2013
about the following year and which committees to sit on,
I felt that was for the year. It was quite difficult,

I think, to chop and change, in terms of committee
membership.

At this point, there was still not a Government
representative on the Audit and Risk Committee?

No, nothing had changed in the sense that, from April
2013 until April 2014, there wasn't a Government
representative. At April 2014, when, in the end,
Richard Callard took over from me, he was on the Audit

and Risk Committee.
109

I am particularly grateful to our [Non-Executive
Directors] for your attention. We will do what we can
to facilitate a good debate.”

At that point in time, can you recall what the
different positions were amongst the Board?

You mean at 22.57 on Sunday night?

Exactly. That weekend, over the course of that weekend.
Well, I think it's, as just shown, the paper had come
round, Alice had set out her position, Paula has just
disclosed. There was actually a chain, I think, where
everybody was replying and I replied on the Monday
morning, just after 7.00 am.

We have your reply at POL00138141. It's the bottom of
the first page, and you say:

"Thanks for copying me on these papers and given
I am not on the [Audit and Risk Committee Audit], I am
just passing my thoughts for information. But my read
of the paper was similar to Alice's. It doesn't seem we
had sufficient reasons for discard Option C and I think
it would be interesting to explore further. It seems
hard to imagine in 2014 [the Post Office] is so
different from other organisations to necessitate this
approach.

"As an aside, I also find the statistics for [the

Post Office] surprising and I can't help wondering if
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Thank you. If we scroll up, please, to page 3. We see
there Alice Perkins has contributed her view, that
Option C has been dismissed "too summarily". She says:

"I do of course understand that we couldn't just
throw our cases at the CPS and walk away at a moment's
notice. And I appreciate that we might find the CPS
route less satisfactory in cases where we were convinced
we should be prosecuting. But if it is the case that
the banks and other financial institutions are content
to live with this, why are we different?"

Could I please turn to UKGI00043711. We then have
Paula Vennells' contribution to this discussion, and she
says:

"I thought it would be worth sharing my thoughts on
why we are different; in my mind it relates to the
operational nature of [Post Office] rather than product
or services, where there is more commonality:

"The difference and perhaps not immediately obvious
to our leading Counsel is scale. None of the businesses
Brian Altman compared us to has a network the size of
ours ..."

If we scroll down, she says:

"We are more complex and operate without the ability
to monitor our agents easily

"This is an important area for the business and so
110

any other organisation, to the extent we could get
comparable data, would have anything like this level of
situations that need investigation. Either way, I would
have thought any next steps must be accompanied by more
focus on training and better support. But sure that's
ongoing anyway."

Can you assist us with why you took the view you
did, as opposed to the view that Paula Vennells has
expressed in that previous email?
I mean, I think the -- what I wrote here speaks for
itself. I hadn't been in the November 2013 ARC.
discussion nor would I therefore have seen the ARC paper
which came in November 2013. So, notwithstanding the
trail in on this issue, this was the first time that I'd
seen it, and I think I would have had in my mind all of
the things that we had set in train as actions, and the
papers we'd read from the 12 July paper onwards, the
year before, and I felt instinctively uncomfortable with
prosecutions and I didn't think the data was there in
the paper to back it up.
Had you discussed it with ShEx at all?
I don't remember having discussed this ARC paper,
bearing in mind we got it a few days before, at the time
of my reply. This would be the sort of thing I was

doing as a Board member with my Board hat on, so
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I wouldn't routinely check with them before.

I certainly would have been discussing it with them,
though, because Richard Callard obviously was getting up
to speed. He was the new Will Gibson, in my mind, and

I certainly would have told him what I thought about

this and, as you know, he came also to the February and
to the March Board.

Absolutely. Let's have a look at those Board minutes,
please. Can we please turn to POL00021522. This is the
26 February Board meeting. It lists you as being

present and Mr Callard as being in attendance.

If we scroll down, we can see:

... the Chairman opened the meeting and welcomed
Richard Callard, Non-Executive Director designate,
Shareholder Executive, who would be attending this and
the March Board before taking over from Susannah
Storey."

Can we scroll down, please, to the bottom of page 2,
“Review of the Current Prosecution Policy", and then
‘over the page we see that:

"The Board approved the implementation of Option B
as a new prosecutions policy ..."

Do you recall speaking up in favour of your
preferred option, Option C?

I'd already expressed my views in the email chain and
113

raised, so that is a moment at which you're not present
at this particular Board. It says:

"The Board discussed the Professional Indemnity
insurance and the Sparrow compensation risks. The CFO
explained that [Professional Indemnity] insurance could
only cover incidents for which the Business was legally
responsible. Therefore any combination paid outside
that legal requirement could not be covered by
[Professional Indemnity] insurance.

"The Board asked the Business to consider enhancing
its insurance expertise and to reconsider how it tracks
events and near misses which should be reported to the
insurers. The CFO was asked to provide an update for
the next ARC on his proposal for [Professional
Indemnity] insurance."

So you can't recall why it was that you weren't
present at this meeting for this discussion?

No.

Again, looking at this now, does that seem like

a relatively significant moment, the discussion of the
insurance position relating to Project Sparrow?

No. My view on the insurance issue is as we'd already
discussed earlier today. I think this would probably be
the follow-up from all of the actions initiated in July,

which Alasdair had been taking forward.
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then this was being considered by the ARC. I can't
remember if, in the room, those of us who had

a different view expressed it again but when you don't
chair a subcommittee, no one Board member has a veto.
It's -- I'm not sure at this point I would have changed

it but I can't remember if I said anything in

particular.

Can we please turn to POL00021523, and this is the March
meeting. This was your final Board meeting, was it?

It was.

We have you down for items 14/31 to 14/38. Richard
Callard present. Was there a particular reason why you
were only present for part of that meeting?

I can't recall now why that was.

If we scroll down, we can see Project Sparrow is
addressed:

"The CEO reminded the Board of the background to
Sparrow and the Initial Complaint Review and Mediation
Scheme, and introduced the work which Linklaters had
been asked to undertake to clarify the Company's legal
position."

So you were present for the discussion regarding
Project Sparrow and Linklaters.

If we scroll down to page 8, please. At 14/43 we

have the "Project Sparrow -- Insurance" issue being
114

Having looked at the way that the notification took
place and the information that was in that notification,
do you think it would have been helpful to have
scrutinised the insurance notification more, at Board
level?

I think the point you're making is about information

that was coming to the Board, which could have helped
overall in this situation and, obviously, as I said

before, if we had seen some of those papers, if the
Executive had provided some of that information after we
asked them not to blindside us and to be open with us,
then of course that would have helped. Sorry, I wasn't
seeing it as a sort of insurance issue, per se.

You're making the point if I had seen the Bond
Dickinson note that mentioned Gareth Jenkins in the
summer of 2013, would that have made the difference? My
answer is yes.

There's reference in these Board minutes to the
Linklaters advice. II'd very briefly like to take you to

that. That's at POL00030724. The Linklaters advice can
be found at page 4. Do you recall that advice going to
the Board.

Yes, I do, and the partner came to the Board.

Was it unusual, in your experience, for legal advice of

this nature to be shared at Board level?
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As a general rule in all the Board conversations and
situations I've seen, and, you know, even now, thinking
about me as an executive with a Board of Non-Executive
Directors, you don't always share all of the underlying
information but what you do expect is, if the underlying
information is material, that it's being accurately
summarised and, if there's something particular that
would benefit the reader from seeing the whole paper,
that you share the whole paper.

So I think me as the Board wanted that Linklaters
advice. It was something we commissioned ourselves. So
I think I found it helpful to see both the paper and the
partner, as it were.

If we scroll over the page, please, we can see the
"Executive Summary". The Linklaters advice, it says
summarises:

"... our key conclusions on the legal analysis of
the complaints made by [postmasters] about Horizon.”

At 1.3 it says:

"The key factual issue is whether and to what extent
Horizon might be said to be reliable, what defects there
may be in it and how any such defects might manifest
themselves and translate into errors in the state of the
account between an individual [subpostmaster] and the

Post Office. Such relevant legal risks as exist arise
117

something more complicated, and I think we felt that, as
well as all of the work described in paragraph 140 of my
statement, we wanted then to have this Deloitte piece of
work, which was a way of looking at the IT problems.
This Linklaters piece of work was a question of legal
issues and compensation, and so on.

Wasn't the functioning of the system quite an obvious
and large stone to unturn, though?

Well, the Second Sight work had been looking at the
system and related issues. The 8 July report, the
Interim Report, as we've discussed, had a series of
complicated and difficult messages: on the one hand the
words “no systemic issues" but, on the other hand, it
was very clear through the spot reviews that

a combination of factors could create problems.

So, at the time, I think we felt taking the actions,
including with the Mediation Scheme and the other steps,
was a way to try and be prudent about this set of issues
but we also, as a Board, hadn't commissioned anything
other than the Second Sight Interim Report. So I think
this was -- it felt at the time another important step.

I'm going to turn to one final issue very briefly, and
that's risk reporting. Prior to becoming
a Non-Executive Director, was there a system for

reporting Post Office risks within ShEx that you were
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only in the event that there are provable malfunctions
in the Horizon system which are causative of losses on
the part of the [subpostmaster]."

From your perspective, was it not important at this
time to grapple urgently with whether the system was in
fact reliable, which is something that wasn't addressed
by this advice?

Yeah, and I think that's why, at this Board, and then
afterwards, the Deloitte work was commissioned because
the premise of this advice as set out was -- and I'm
summarising, these might not be the right words -- but
the system works. So I think what Linklaters were
saying, which we agreed with, was you need to get some
basis check that point.

We're now in March 2014,

(The witness nodded)

Why, in your view, are things moving so slowly in that
respect?

I think if you look at the long arc of this issue where,
unfortunately, problems have been arising for over

a decade, this to us at the time, to us as a Board,

who'd had the Second Sight Interim Report in July 2013,
actually felt that we'd taken a lot of actions, we were
trying to uncover things, and move at pace. Of course,

often with complex issues, each stone you lift, you find
118

aware of?
So during my time in the Shareholder Executive, I joined
in 2006, I worked on a few different situations and, in
simple terms, I think the role of that team looking
after a series of different situations, evolved and
matured, including in relation to risk reporting.

So we used to have quarterly meetings in relation to
the individual companies or projects, if it wasn't
a company, and the risk reporting was on a journey of
improvement. I don't remember thinking -- it's hard to
think back now to all of the different iterations.
I think it was broadly in line with best practice at the
time, for example, when the Department or in the private
sector. If you looked at it now, with a 2024 hat on,
I think you'd think it was quite unsophisticated. But
I don't think we were particularly out of line.
Did the system change while you were a Non-Executive
Director in respect of your ability to report risks to
ShEx?
When I was a Non-Executive Director, I would have been
primarily interfacing with the Post Office's risk
practices and what we did as that Board through the
Audit and Risk Committee to improve our risk management
and to look at different areas of what I would call the

control environment. As we've discussed, I would be
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giving reflection, views, commentary to the Shareholder
Team. They were then responsible for what was in the
risk registers that they were managing. So I wouldn't
have seen those risk registers that they had after the
14 March 2012, when I left the building.

MR BLAKE: Thank you, sir, those are all the questions
have.

Questioned by SIR WYN WILLIAMS

SIR WYN WILLIAMS: Before CPs ask any questions, I have been
musing about this debate that the Board had about
Options B or C, in terms of Prosecution Policy, all
right, and clearly there was a difference of view about
it. But in the discussions which did take place, was
there any acknowledgement or discussion that, in
Scotland and Northern Ireland, nobody but for the CPS
could prosecute and was that not considered as
a material factor in terms of England and Wales?

A. I do have a background recollection of that but, now
that you say it, I don't know why it wasn't in that
paper. So I can't recall -- I can't recall why. I just
remember feeling myself uncomfortable.

SIR WYN WILLIAMS: Yes, and I understand there was
a difference of view, and I'm not necessarily expecting
that you would have known personally --

A. No, no, I get your point.
121

didn't feel able to say whether the Board was
deliberately being kept in the dark by the Executive.
That's how you put it in your statement, not exactly
those words, but broadly. What I'd like to do is show
an email that the Inquiry has seen a few times to see if
we can get any closer to an answer on that. So if we
could look, please, at POL00382001, and this is the
email which has come up a few times. It's between
Ms Vennells and Ms Perkins about an unsafe witness. It
dates from November 2013, and hopefully you've seen it
before.

A. Yeah, I've seen that one.

Q. But I'd like to just zoom in on the important words. If
we could scroll down a little to "My concern", the email
begins between Ms Vennells and Ms Perkins -- or rather
the paragraph within it. Yes.

So there we are at the bottom.

"My concern re Sparrow currently is our obligations
of disclosure re an unsafe witness (the representative
from Fujitsu made no statements about no bugs, which
later could be seen to have been undermined by the SS
report). We do not think it material but it could be
high profile.”

So that actually very succinctly encapsulates what

Mr Clarke enunciated much more fully in his Advice.
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‘SIR WYN WILLIAMS: = -- but someone in that Board would have

known --

A. Yeah.

SIR WYN WILLIAMS: I -- that in Scotland and Northern
Ireland --

A. Yeah, it was a different --

SIR WYN WILLIAMS: I -- it had to be the Procurator Fiscal or
the CPS version in Belfast --

A. Yeah.

SIR WYN WILLIAMS: = -- so to speak.

A. Yeah.

SIR WYN WILLIAMS: = Okay.

MR BLAKE: Thank you, sir. It's Ms Page and then Mr Stein.

Questioned by MS PAGE
MS PAGE: Thank you.
In your statement, Ms Storey, you describe

a critical moment in the summer of 2013 when the Board
was deprived of the information it needed, and you say
“at precisely the time when the Executive should have
been at their most open with us". The information you
were talking about was the information that was within
the Clarke Advice, that Gareth Jenkins had been acting
as an expert witness and that he was "tainted".

A. Yes.

Q. On that issue, in your statement, you said that you
122

Would you have wanted to know about this unsafe witness
and the obligation to disclose the fact that he had made
statements about there being no bugs; would you have
wanted to know about that?

A. Ofcourse. Of course.

Q. Do you think that the Board's discussions, in the months
leading up to November, would have made it clear to
Ms Vennells and Ms Perkins that the Board would want to
know about that unsafe witness?

A. Ido. I've hopefully tried to give a general sense that
we were quite a difficult set of Non-Executive Directors
and we wanted to know things and, when something goes
wrong, yeah, I think those are the times when you need
to be absolutely as open as you can. And in my
preparation for this Inquiry, I've now seen a lot of
documents that I didn't see at the time, and I would say
even since I wrote my witness statement my position on
this issue has hardened.

Q. When you say "hardened", can you tell us exactly what
you mean by that?

A. I mean that I've seen a number of things that I think
were relative, contextual information that add to the
weight of the issues being significant, which were then
not reported to us as significant. So an example that

I was reading about last week was that Shoosmiths did
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put written evidence to the 15 May Department of

Business Select Committee. They didn't appear at the

hearing. Paula Vennells and George Thomson appeared.

That's an example of something. We then met as a Board

the week later, that Select Committee is referenced.

The Select Committee itself didn't pick up that issue in

its own response, but it makes me think there was quite

a lot of information which was important and relevant.
Obviously, I'm applying hindsight, you know, I can't

put myself in the shoes of those people, which is why

I phrased it in the way I did in my statement.

Mr McCausland told us yesterday, and obviously on the

same page as you in this respect, that the Board did not

know about the contents of the Clarke Advice, but he

also said that he was told that there was a Fujitsu

expert witness that could not be used any more but that

person could not be used any more because they had moved

on or they had retired or some such. He wasn't given

aname. The important point, perhaps, is that he was

given the impression that there was an innocuous reason

for that witness not to be used any more and therefore

the taint was hidden. And he thought that that was

perhaps some time in the latter half of 2013. Do you

remember being told anything like that?

Ido not. I heard what he said yesterday when I watched
125

properly tomorrow. I thought the Board were generous in
their patience tonight over the SS discussion. It is

helpful to know that they are supportive of the need to

be robust. That said, I thought Alasdair's intervention

was good ~- it is why we haven't been completely
heavy-handed yet. We can discuss nuances and next steps
tomorrow."

Now, what do you recall of the meeting that would
have led her to say that the Board were supportive of
the need to be robust?
I can't be sure because this is an email exchange
between her and Alice. I am assuming -- I'm just,
assuming -- it could have related to the point she was
making on that call about the need for factual accuracy
and, obviously, we were being told that day that this
report was going to go into the public domain, the
executive were not happy with it, they were concerned
about accuracy and they then went on to tell us about
that. So it may be that she's referencing the need to
be robust with Second Sight about the need to be
accurate and factual. But I can't be sure.

Do you think that the Board was supportive of her view
on that?
I think, yeah, I think the Board heard what Paula said

on that call. We absolutely wouldn't have wanted
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it last night. I don't recall that.

Q. No.

A. Bear in mind that Neil, as a Senior Independent
Non-Executive Director, would have been in and around
the business perhaps a bit more, so perhaps he had some
other conversations.

Q. And possibly also went to those Board meetings which you
didn't, in the latter half of 2013?

A. That's true. That's true.

Q. That was, of course, at the same time or around the same
time as the insurers were being informed and given the
name Gareth Jenkins. So, again, coming back to this
point, does this show that the Board was actually being
kept in the dark, as it were? You were not being told
about Gareth Jenkins but insurers were?

A. There was obviously a significant asymmetry of
information between what we were getting, which you've
seen -- both the papers and the minutes -- and what some
other parties were aware of and were getting.

Q. Allright. Can we look, please, at another email.
POL00296944. This is just going back a little bit to
the 1 July telephone Board meeting and the reaction
afterwards. This is Paula Vennells to Alice Perkins at
9.07 pm, so on the day but afterwards:

“Hi Alice, I'm looking forward to catching up
126

a document to go into the public domain that wasn't
factually accurate and we did trust the Executive. We
had no reason not to. So yeah, there's no reason,
I think, that this would be incorrect. What she's
reporting is her view of what we thought, having been --
sorry, that's not a great sentence.
Q. No, understood.
Then sort of counterposed with that, she says:
"That said [so, in other words ‘on the other hand]
I thought Alasdair's intervention was good -- it is why
we haven't been completely heavy-handed yet."
Can you decode that for us at all; does that make
any sense?
A. I don't recall what specifically Alasdair said.
I wonder if it's to do with the interface with Second
Sight and, you know, it's plausible, isn't it, because
it was a debate later, that there was a concern about
the scope and time their work was taking and the cost,
the sort of desire to have some fixed parameters around
it. So it may be that it was a reference to that and so
Paula sort of implying that she might in due course
need, in her words, to be heavy-handed with Second
Sight. But I can't be sure.
Q. Allright, well, it carries on:

"I caught up with Susan this evening after we
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finished. She had finished her meeting with [Second
Sight] and [presumably this is ‘and was of the view]

that they do now understand the risk of being caught up
in something bigger and more sensitive. She is hoping
their report should be more balanced, should say they
have found no evidence of systemic Horizon (computer)
issues but will confirm shortcomings in support
processes and systems, and that Post Office has already
identified and corrected number of these. I hope when
they speak to James tomorrow that they will confirm all
this. They will also want to say their work is not

finished and therefore still not conclusive."

Then she says this:

"Not a final position by any means nor one that
controls what they might say rather than write but
sounding slightly better."

Do you know that the business were making efforts to
control what was written by Second Sight?

Not in that way as described there and it was

an independent report, so no.

Then particularly she seems to be pleased, shall we
say -- or perhaps that's inferring too much, but in any
event she reports that Susan Crichton had told them
about the risks of being "caught up in something bigger

and more sensitive". Again, I hope I'm not reading too
129

point says:

"She does remember it becoming an increasing thing
after joining. Remembers Paula indicating that there
was nothing much to see here, it was a small number of
subpostmasters, long time ago, the business was getting
assurance etc..."

But then in the next bullet:

"NEDs and Alice increasingly worried at the
seemingly slow pace of the execs’ response and Arbuthnot
had started to fan the flames. The Board felt this was
mischief making that was fanning the flames and was
becoming a populist cause."

If that's the correct reporting of your
conversation, where is this idea of mischief making,
fanning the flames, a populist cause, coming from?
Yeah, I only saw this email very recently. I didn't
know -- I did meet Richard Callard from time to time,
I wanted to make sure he was getting the support he
needed. I do recall having various conversations with
him, including presumably one in March or April 2020.
I didn't know he was taking notes, I didn't know he was
recording it and I can't say exactly where all of these
things have come from. Obviously, what I've tried to do
in a very open way is set out my recollections and my

reflections in my witness statement, and that is after
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much, but it's sort of an implied threat, isn't it? Did

you know that the business was involved in sort of
warning Second Sight of risks?

No, I don't really know what that sentence means.

I have to say, the end of it, the "something bigger and
more sensitive". I've obviously read this before today
because I've seen it in the disclosure documents but

I don't know what that's referring to.

No. So, again, perhaps some issues going on behind the
scenes that the Board were being kept in the dark about.
You're nodding --

Yes.

-- just for the transcript.

Sorry, yes. I am nodding. I agree.

Can list just have a look at this email, UKGI00045624.

If we scroll down a bit, the email that we can perhaps
look at is between Richard Callard and Tom Cooper in
2020, so considerably after the events we're looking at.
And, obviously, he's reporting back on a conversation he
had with you, and people no doubt have their own
slightly different recollections of conversations. So

you may wish to comment on various parts of this email.
But there are couple of these bullet points that

I wanted to focus upon. It's about the "whole Sparrow

thing", as Richard Callard puts it. The second bullet
130

I've read all the documents. So, at this point in 2020,
which would have been six years after I left, I'm not
sure how much reliance can be put on this.

In other words, are you saying that you don't believe
that you said that there was mischief making or

a populist cause?

I don't remember those words. So, honestly, it's hard

to say.

Do you think that there was any propensity on the Board
to be predisposed in that direction or was that
something the Board was being steered towards by the
Executive?

I think, from the beginning of our conversations as

a Board about what became the Second Sight Interim
Report, Alice was keenly aware, in the way she portrayed
it to us, that there was a whole series of issues that

had been going on for a long time, that understandably
James Arbuthnot was very worried about, as was Sir Alan
Bates. She wanted to get the work done, to look at it,
and that's what's happened. That's my recollection.
Well, can we look at the Second Sight relationship over
a slightly longer time frame and, in broad terms, in

2020 -- sorry, the email can come down unless there's
anything else you want to tell us about it while it's up

there?
132

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No.

No. In 2012, the CEO announced the Second Sight Review
to the Board as just a little bit of AOB, right; that is

the first the Board gets to hear about it?

Yeah, it was in the AOB part of the discussion, I don't
think it was just a little bit, I wouldn't use exactly

those words but I understand of course the point you're
making. It didn't come as a paper nor as a main agenda
item.

No history, nothing about past prosecutions. The
reasons that lay behind why Second Sight had been called
in, in effect, the fact that over many, many years,

people had been being prosecuted on the back of the
Horizon evidence and that, therefore, there were

multiple complaints to MPs about those prosecutions.
That wasn't part of the history that you heard about?

At that May 2012 Board meeting, no, it was nothing like
the horrific extent of what I now understand. It was --

Or even what was understood at the time, in the sense
that a number of MPs had made complaints, a number of
newspaper articles had been written. There was

a growing groundswell of people complaining about
Horizon that required this to happen. That wasn't made
clear, was it?

No, not in the May 2012 "Any Other Business" discussion,
133

We did not, and the next sort of thing we got, which is
why, as I've discussed, there was irritation, there was
this 1 July -

Exactly, when you were blindsided?

Yeah.

So then even though you had asked in May for a proper
update, you then get nothing until you're blindsided and
told there is an urgent need to deal with the report
that's about to be presented to Parliament. So, in
effect, over that whole first year, the Board is not
substantively updated on the work of Second Sight and,
indeed, the agenda is managed in a way that everything
about it is put sort of below the line, everything in

the papers at least is put below the line just for

noting, nothing for a proper discussion?

Yeah, that's right. I mean, I know now from the papers.
I've read that there was quite a lot of to and fro

between the company and Second Sight in the months that
led up to the publication of the Interim Report but we
were really getting very little colour on that, and as

you say, the written papers that we were receiving were
more as a sort of risk update, they're positioned as
there are these situations but not presented to us in

the way that we then came to understand them.

Then we get to the July 2013 Board and, in the
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no.
No. So then, following that, each month the Chair draws
up the agenda and she puts the Significant Litigation
Report below the line just for noting, not for

discussion, month after month and, at the point where
there's Second Sight included as part of that, there's

kind of a couple of lines on Second Sight in those
Significant Litigation Reports but not for discussion?

The -- yes, I mean, you're right. The May 2012 Board
meeting was when Alice and Paula reported their meetings
to us with James Arbuthnot and then the Second Sight
work started, as well as the Significant Litigation

Reports, which were in the papers every month and
expanded over time in terms of their content.

There were, from time to time, updates, for example
if one of Alice Perkins or Paula Vennells had met Lord
Arbuthnot or Sir Alan Bates, they might update on that,
and I think, from time to time, the Board said, "What
happened on that work?" So there was a bit of to and
fro but nothing like the volume and focus, as you'll see
from the 1 July 2013 until I left the Board in 2014.
Indeed, in May 2013, the Board did actually ask for
a formal update --

That's right.

~- which you did not receive?
134

background to just a few more questions -- and I don't
have many more -- it's just worth bearing in mind this:
that they are -- the July Board is a missed opportunity
arising from the fact that Ms Crichton was not
presenting her own paper, because she had received the
Clarke Advice.
(The witness nodded)
She knew much more than the Board did about past and
present prosecutions.
(The witness nodded)
The fact that she did not present her paper and become
subject to questions from the Board means that her
knowledge of the Clarke Advice stood no chance of being
revealed to the Board?
(The witness nodded)
Ms Perkins gave an account to this Inquiry about why
Ms Crichton didn't come in to Board to present her
paper. At the end of that, Mr Beer asked her “Why is
none of that reflected in the Board minutes?", and after
a few false starts, her answer was, "I don't know the
answer to that question".

Was it your experience of the minute taking at POL
that important discussions were not reflected in the
minutes?

My recollection was that Alwen Lyons was a diligent
136

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company secretary. The nature of minutes from any Board
meeting, and frankly any other meeting, often doesn't
give the reader all of the to and fro and who said what,
and might not include somebody having been expected to
present a paper and then not. So I don't think that in
itself was unusual. I obviously appreciate how
frustrating it is now and, you know, for me now as
a reader, trying to jog my memory, of course I think we
all wish there was a lot more colour on this issue
but --

Q. No, of course minutes don't reflect everything but would
you have experienced a case where there's a discussion
about something significant and it just doesn't appear
in the minutes?

A. Um... I mean, I can't think of examples of that now,
looking back. If we were contemporaneous, I'm sure it
would be much easier to give you an example about that.

SIR WYN WILLIAMS: Nothing about it sticks in your mind?

A. No, no.

‘SIR WYN WILLIAMS: All right. Is that it Ms Page?

MS PAGE: Just very briefly -- if I may, sir -- in your time
on the Board, was Ms Perkins somebody you would have
found or did you find her to be capable of leading and
controlling Board discussions?

A. Alice had a lot of experience of Board interfaces
137

Ms Perkins actually lose control of what was being said
in the meeting?

A. I don't recall that. She is quite a calm person.
I don't recall that.

MS PAGE: No. Thank you, sir.

SIR WYN WILLIAMS: = Mr Stein?

Questioned by MR STEIN

MR STEIN: Sir, tempted as I am to say I've got a clear
hour, I'll be about 15 minutes --

SIR WYN WILLIAMS: Tempted as I would have to say: no, you
haven't.

MR STEIN: I think about 15 minutes, if that suits both the
panel and -- yes, it does, I'm very grateful. Thank
you.

SIR WYN WILLIAMS: Well, I'll be rigorous, Ms Page, and hold
Mr Stein to 15 minutes, so I'll look at Mr Page's watch
now.

MR STEIN: The time is on, Ms Storey.

Ms Storey, I represent a large group of
subpostmasters, also people working in branches at the
small branches that you're familiar with right up and
down the country.

Can I just take you to two passages in your
statement to start off with, please. They're parts of

the statement whereby you refer to being reassured about
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because part of her day job was coaching people and
coaching boards and my experience was she took this role
really very seriously, she was very committed to it and,

I think, wanted to make sure there was a good discussion
of all of the issues across these difficult areas.

I think, if people felt strongly about things, they

would say them anyway. She probably was quite good at
sometimes drawing a conversation to a close or asking us
to pick it up offline. So I think she was rigorous.

Would you have said that the July board "kicked off" in
any way?

“Kicked off" is not a sort of expression I would

particularly use but, I mean, as we've discussed today
and as I think the minutes reflect, it was

an uncomfortable Board and we had a difficult discussion
before the Board, just the NEDs who were there -- Neil
was not there that day, but for the NEDs and the

Chair -- the board meeting was difficult. "Kicked off"
slightly implies uncontrollable. I wouldn't say that.

It wasn't uncontrollable; it was controlled, in effect?
Controlled in the sense of orderly. I don't mean

controlled to my memory in the sense of --

Steered? No --

Yeah.

-- not steered but, in the sense that at no stage did
138

the system, the Horizon system. So paragraph page 17,
and I'm going to go page 8 of your statement, so I'd

like it on the screen, please. So paragraph 17 but it's
actually page 8 of the statement and it's the last,

I suppose, few lines of that paragraph.

So if we go to page 8, and we look at that top
paragraph, I'm very grateful. That's ideal, thank you
very much. So if you look above paragraph 18, the bit
I'm after is just above there.

What you're talking about there is that -- you're
talking about POL had full confidence in the Horizon
system, the system had been vigorously tested, full
confidence in the accuracy and robustness of the system
was shared by the NFSP:

"As I explain below, this was the consistent
position adopted by the company in relation to Horizon
throughout my tenure on the Board.”

Paragraph 21, at page 10 now, please, and the last
few lines of paragraph 21. So very similar there.

"I referred above to the POL statement circulated
November 2011 [then a Relatively reference] expressing
full confidence in the accuracy and robustness of the
system and I do not recall hearing or reading anything
that was inconsistent with those assertions."

So we can see from your statement that on two.
140

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‘occasions you were referring to what you understood the
position to be, having been informed by the Post Office
that the system works fine.

Yes.

Now, we then get, in terms of the order of things, we

get a reference within your statement to another
document I'd like to refer to, please, which is an SLR.

I'll ask this to go on the screen, please, UKGI00018251.
Now, this may appear as a slightly faded document on the
copy we're about to look at but we'll make our way
through it.

Yes. On my screen it's quite small, if that could
be expanded slightly I would be very grateful, if that’s
possible. If we work our way down, so if we hold it
there for a second. So the SLR is referring, as you can
see there, to the right-hand side as "Privileged and
Confidential -- claims over 500,000 or those of
a sensitive nature".

If we look at file name "Horizon claims", and then
reference to case holder, we then see a name that is
very familiar to this Inquiry, Rod Ismay of POL. Now
the significance of Mr Ismay to the Inquiry, you've been
following the Inquiry clearly --

'have.

-- he wrote what within the Inquiry is called the
144

Shoosmiths, and then an update as to the position.
Okay.

So we see that there are Shoosmiths setting out the
fact that they've got 85 clients, plus the then five
that are here, all setting out -- this is the summary of
the situation which is they're all saying there are
problems within the system.

Now, you referred to this document at paragraph 66
of your statement. That's at page 32, paragraph 66.
I want you to help us with what you mean by some of the
terms that you're using. So if we can now go to
paragraph 66, page 32 of your statement.

So this is sent to you, this document. You refer to
this as being part of the Board pack for your first
Board meeting. Now, it might be said that, as it's your
first Board meeting, you may have read the lot, rather
than having the ability to sift, but let's see how we
go:

"The SLR [the one we've just referred to] appears to
have been included with the Board papers but 'below the
line’ and for noting (ie not for discussion by or at the
Board). As I have explained, the Board papers would
include papers that were intended to form the basis of
discussion by the Board and papers which we were

requested to note for information but not usually
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whitewash report 2010 --

Yeah.

-- saying essentially "No bugs here", okay?

Yeah, the Ismay Report that I think David Smith had
asked him to produce.

Yes. If we then have a look at what is going on, we see
a reference -- I know it's very faded and slightly hard
to see.

It's okay, I can read it.

Okay great. Look at the middle column under
"Description", we've got a reference to Shoosmiths,
under the fourth paragraph:

"Shoosmiths assert that they have consulted on
a further 85 cases which are all likely to raise similar
legal issues."

If you go up above that one, the third one, if you
can do the yellow line trick above to the:

"Each alleges wrongful termination of contract
(based upon (a) alleged defects in POL's internal
processes and (b) alleged defects with Horizon) ..."

Okay? Then we'll move across and again, names that
are familiar to this Inquiry. Mr Darlington, it's
talking about his position, the claim rejected "on the
basis that the SPMR admitted to and was convicted of

false accounting". Then “Response”, in relation to
142

discussed."

Help us translate the corporate speak here, if you
don't mind. When you're saying, "Appears to have been
included within the Board papers but below the line and
for noting only, ie not for discussion by or at the
Board", what does that mean: "below the line", nobody
reads it at all or people are expected to read and raise
something if they think about it? Help us.

Yes, so what I mean by that is that the Board agenda
would set out each of the items that were going to be
discussed at the Board, each one would have a timetable
committed to it. That would basically take up the bulk

of the day, if a Board meeting went from 9.00 until

4,00. And then, just at the end of the day, in my
experience of the Post Office with these matters, there
were items that were not being raised to the Board for
discussion, but only to note, which means you needed to
read it and agree that you had noted it, and that was

the nature of these Significant Litigation Reports.
Shoosmiths is saying they've got 90 people all saying
that there are problems with the Horizon system. Was
that something that came to your attention in terms of
you thinking about it and saying, "Hang on, that's

a heck of a lot of people"? Did it come to your

attention in that way.
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I don't recall it coming to my attention in that way at

that Board meeting and, you know, that's one of the
things obviously that I've said I regret. My reflection

is - and I understand why, you know, from your position
this will sound odd but, in the shoes that I was in and

as a Non-Executive Director Board member, we were
getting quite strong assurances that the system is
robust, nothing to see here. So I think I was trusting
what the execs were saying. But I take your point.

All right well let's keep on going, you're talking about
shoes, I'm going to talk about Shoosmiths a bit more.
Yes.

POL00141382. Now, you go away on maternity leave --
I have this from your statement -- is it March 2012 to
March 2013?

No, I had the baby in March 2013, and I started on the
Board in April -- sorry, in March 2012, and I started on
the Board in April 2012.

Right. Okay, maybe I've misnoted it from your.
statement. So I'm not sure whether you're around at the
time of this particular document. We go to the end of
the document, I think it's July 2012. But let's have

look through. I want to go to particular paragraphs,
paragraphs 2 to start off with, it's a very good summary

of the situation.
145

ever gone missing. Then 12, again I will summarise:

If the loss not repaid, POL will prosecute the SPM.
for false accounting and then people are being advised
to plead guilty to false accounting. In the
circumstances, many were charged with theft or fraud but
these charges are typically dropped and SPMs have been
imprisoned for false accounting.

These are serious and quite complex issues that are
being raised. Lastly 14 and 16.

14: the contract is old, this is what it is saying.

It goes back to 1994. It was designed for a paper
system, no good for a digital system. That's what 14 is
saying.

Then 16, just finishing. Faults with Horizon, loads
of ways, this is saying, there could have been problems
with Horizon: system errors, human errors, faults with
cross-system communications, electrical faults. It
doesn't matter, it goes on to say, how they're
‘occurring, it's happening.

So you've got complicated detailed submissions being
made by Shoosmiths in relation to the Network
Transformation consultation. That's what's going on
here --

Yes.

-- saying look there are real problems, lots of people
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Paragraph 2. I'm going to summarise this because
I've got a clock ticking. Access Legal from Shoosmiths,
national firm, contacted by 100 SPMs. So you see the
same numbers. The numbers, in fact, are going up by
this point. They suffered losses, those losses can't be
explained. They had been subject to disciplinary
measures, all adamant that they or their staff have not
stolen any money. Horizon system is at fault, they say,
the Post Office requires them to use it. The last three
lines:

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

Can we go back to paragraphs 11 and 12 together.
They appear, I think, close to each other.

Paragraph 11:

"POL will ask an SPM to repay all losses ..."

I've used this document before in another context so
I'm just going to go to a slightly different part to
assist the Inquiry. Last line of paragraph 11 says:

“It is far from clear whether there is a loss in
a sub post office that POL have actually lost any
money."

So it's far from clear as to whether any money has
146

we've got all having difficulties in the same way.

Now, first question, it relates to this: if I'm
right in thinking about the timing of when you were
away, was this brought to your attention, if I've got
the timing right, when you came back from maternity
leave or at you in any way familiar with this document
at the time -- at the time?
So just firstly, I never was away on my maternity leave.
So I had the baby and then started on the Board. So
I was on the Board when I was on my maternity leave --
(unclear -- simultaneous speakers) -- doesn't matter.
Are you familiar with this document?
This document I am now, it's a written submission, as
you're saying, to the Department of Business Select
Committee.
Correct.
The hearing was in May 2012 and it was on Network
Transformation. Shoosmiths made the submission, it was
a written submission, it’s in the papers, and Paula
Vennells appeared at that hearing, it's the one that
I was referring to earlier. She appeared on 15 May
and --
At the time of these sorts of matters, around this
period of time, forgive me for summarising your

position --
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The Post Office Horizon IT Inquiry 30 July 2024

Yes, sorry ~
-- were you familiar with what was going long in these
submissions? Was it --

I had not seen this submission, no, no. But the point

I was making before was, when we were given the update,
for example, at the Board on the BEIS Select Committee
that the Chief Executive had just appeared at, this
particular submission wasn't referenced and it actually
would have been extremely important to see it at the
time.

Because one of the simple ways through this would have
been for somebody on the Board, or Ms Vennells,
somebody, to start speaking to the subpostmasters
because rapidly what would have happened is that would
have resulted in being told "Look every time we phone up
the damn helpline they just tell us to pay because of

the contracts".

I appreciate that --

That's masking people masking complaints about the
system, "they keep on telling us to pay and I'm trying

to say look there's a problem".

I appreciate that and --

If that had been looked into?

Yes, and also the Parliamentary Committee didn't pick up

this issue -- I think in the hearing Caroline Dinenage
149

You're being told: system robust, no bugs, no problems
with it. Then later on, 2.13, you're told that there
are bugs.
(The witness nodded)
Right. Did Ms Vennells, at this juncture, when you get
the Second Sight Report and the discussions at the Board
about it, did she say to the Board, or you individually,
"One of the things that's really peculiar about this is
that I've been reassured, reassured and reassured there
are no bugs in the system, and then, quite surprisingly,
or perhaps using other words, I've now learnt through
Second Sight and details before that there are bugs in
the system, and we really ought to look into this as to
why we weren't told about this before".

Did she ever say something like that because I might
feel a bit misled in that situation, if I were in her
shoes.
No, she --
Right.
Not in --
What about you and the other people on the Board?
You're in a similar position. You agreed with Ms Page
and Mr Blake that you feel as though the Board was left
in a bit of a vacuum on information. But the one thing

that you've been told at the beginning is no bugs in the
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Q. No, we have a slight problem with Parliamentary
privilege, so therefore —-

SIR WYN WILLIAMS: = Anyway, just on this, can I just be
clear, there was no attempt by the Post Office
Executives to bring this sort of detail -- however it
came into being, there'd been no attempt to bring this
sort of detail to the Board?

A. No.

‘SIR WYN WILLIAMS: Right.

MR STEIN: We then get through -- and you have been asked
a lot of questions about it by Mr Blake and some of them
have been looked at them afterwards. So just to finish,
you get to the stage whereby you read and you're aware
of the contents of the Second Sight Interim Report.

A. Yes.

Q. Okay. Now, we don't need to go to it but one of the
most significant things about that report is saying that
there's bugs in the system, a couple of bugs --

A. (The witness nodded)

Q._ -- one which is the mismatch bug --

A. (The witness nodded)

Q. -- could really cause problems to people. Okay? So

let's go back to where I started with my questions.
150

system and yet, in 2013, you're told about bugs that

well affect branch accounts. Did you ever get or was
there any discussion at the Board "Why on earth are we
being told that there were no bugs in the system? Who's
been making this up? What's going on?" Did you ever
get to that because, as an example, Mr Ismay, who

I referred to right at the beginning, he learnt in 2011
about the mismatch bug.

So it's been going on for years, the Post Office has
known about these things.

A. Yeah, I can't speak to the sort of pre-2012 period,
although obviously I know that when I started on that
Board we had none of the long history from the Royal
Mail Group, we were not getting any concerns flagged by
internal -- or any material concerns from internal or
external audit.

To your point, when it came to the Second Sight
Interim Report, it did flag those issues from the spot
reviews very clearly. It also said there were no
systemic issues. It also flagged some serious concerns
that we needed to look at and, at the time in 2013,
those were the steps that we thought we were taking.

Q. Forgive me for interrupting, as again I'm slightly
thinking about the seconds ticking --

SIR WYN WILLIAMS: They've ticked but carry on, yes.
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MR STEIN: They've well ticked but did you think to yourself
or did the Board think to itself, "Well, hang on we
‘ought to look into why we've been reassured about
something that ain't true’
A. Well, I think at the time, we did have various elements
of discontent that we expressed to the Executive and
then we set about a series of actions that we felt we

could control, to try to get to the bottom of these

things.
Q. And that one?
‘SIR WYN WILLIAMS: Well, I think the answer to the question

is that you didn't enquire, as Mr Stein suggested you
should. What you did, by the look of it, is to accept
the explanation you were given, namely there had been
two bugs but they'd been cured. That's what happened,
isn't it?

A. Yeah, I think we took what the -- the Executive were
clear about their view. At that point in July 2013, we
had no particular basis to think anything different and
then we started to take a series of steps and then, as
I said earlier to Mr Blake, part of the point from my
perspective of the Deloitte report was to try to get
under the skin of the IT --

MR STEIN: Outward facing from this, going into then the

question of -- it doesn't matter who is prosecuting,
153

disappear, as you prefer.
But for certain, I'd like to thank you for making
your witness statement, which is a very detailed one and
for answering questions for the greater part of today,
so thank you very much.
If you'd like to leave, now is your chance,
‘otherwise Mr Beer is going to start.

MR BEER: I won't take offence at all.

THE WITNESS: No, it's fine.

Announcements by MR BEER

MR BEER: Sir, as we've come to the end of phases 5 and 6 --

SIR WYN WILLIAMS: Well, is that true?

MR BEER: -- at least the principal part of the evidence
taking of Phases 5 and 6, I thought it might assist to
firstly draw the threads together in terms of the nature
and extent of the evidence that you've heard, secondly
to read some statements into the record, in fact, those
statements received in the course of these phases but
which relate to other phases of the Inquiry, Phases 2, 3
and 4, and then thirdly to say something quite short
about the independent surveys that are being conducted
for the purposes of Phase 7 of the Inquiry.

So, firstly, the evidence heard in Phases 5 and 6.
Over the course of 16 weeks, sir, you've heard

evidence from people at the highest level within the
155

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whether it's the CPS in Northern Ireland, whether it's

the Procurator Fiscal in Scotland, whether it's Post

Office in England. We know that prosecutions continued.
I've referred to Ms Falcon who was prosecuted at the

beginning of 2015, using data from the Horizon system.

The prosecutions continued using Horizon data. Didn't

the Board say to itself, "Well, hang on, haven't we got

to make sure what on earth is going on with this. If

there are bugs in the system, like are being set out in

the report, we, the Board, have to be responsible for

making sure we stop it right now"?

A. Well, I can only speak to the Board until I stepped down
in 2014.

SIR WYN WILLIAMS: Well, I think that's really a speech, not
a question. So I think we'll call it a day there,

Mr Stein.

MR STEIN: Thank you, sir.

SIR WYN WILLIAMS: = Thank you.

MR BLAKE: Thank you, sir. Those are all the questions for
Ms Storey.

‘SIR WYN WILLIAMS: Right, we're not quite at the end of the
session because Mr Beer wants to make one or two
announcements but that does conclude your evidence,
Ms Storey. So you're very welcome to sit there and

listen to Mr Beer for a couple of minutes, or you can
154

Post Office and Government paying careful attention to
the three questions which run through every stage of
this Inquiry: who knew what and when, about the issues
with Horizon. Since April of this year, you have heard
oral evidence from 66 witnesses. You will hear evidence
from a small number of witnesses on Phase 5 and 6 issues
in the course of Phase 7. Their evidence could not be
taken during the course of the last 16 weeks, for one
reason or another.

As in other phases of the Inquiry, the oral evidence
that you have heard is not the entirety of the evidence
that you will be considering. Aside from the huge
volume of documentary evidence, there are the statements
of witnesses who will be read into the record. I'm not
going to do that now for Phases 5 and 6, ie Phase 5 and
6 witnesses, and, instead, I'll do that in the course of
Phase 7, when all or nearly all of the Phase 5 and 6
written evidence is available to the Inquiry.

Owing to the scale of Phases 5 and 6, your Inquiry
Team will continue to seek evidence and issue Rule 9
requests throughout August, and further evidence will be
disclosed to Core Participants and then to the public in
due course.

Reading in of statements from Phases 2, 3 and 4.

Today the Inquiry will be publishing statements from
156

(39) Pages 153 - 156
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The Post Office Horizon IT Inquiry

witnesses about Phase 2, 3 and 4 issues. Those
statements will be admitted into evidence and treated as
having been read into the record. The witness
statements will be uploaded shortly to the Inquiry's
website.

The witnesses who fall into those categories are
described in a PowerPoint presentation that I'd ask to
be displayed. INQ00002022. If we look at page 2,
please. The names of the witnesses that are going to be
read into the record by the act of displaying this
document are listed on the left-hand side for Phase 2.
There are seven witnesses and eight statements because
Mr Folkes has got two statements relating to Phase 2
issues, and the URNs are displayed in the right-hand
column.

Over the page, please, to Phase 3. On this page and
the next, there are 11 witnesses -- Mr Folkes being the
first of them, his fourth witness statement -- who give
evidence in relation to Phase 3 issues: names listed on
the left; URNs, which I'm not going to read out, on the
right.

Over the page, please, that's the balance of the
Phase 3 witnesses.

Then the last page, please, there are four witnesses

who give evidence about Phase 4 issues, names on the
157

Inquiry will be aware that you have commissioned
independent research and data analytics from a firm
called YouGov, in particular to conduct two surveys to
gather views from all current subpostmasters and all
applicants to the Horizon Shortfall Scheme.

Those two surveys are ongoing. They're live at the
moment. By way of update to you and for others,
I understand that, so far, over 2,000 recipients have
either started to complete or have completed and
returned the survey. We're surveying 16,000 people, so
that is a response rate of around 12.5 per cent, which
1am told is a promising start at this point of
a research project.

So, sir, that's all from me today. I would like to
end by encouraging those, everyone who has received
a link to the surveys, to complete them. It's vital
from the Inquiry's perspective that we enter Phase 7
with as full a body of evidence about the current
position as is possible.

Thank you, sir.

‘Statement by SIR WYN WILLIAMS.
SIR WYN WILLIAMS: = Thank you, Mr Beer.

Well, those who have had the grave misfortune of

following what I do will know that I am not very keen on

repetition but, on this occasion, I do wish to repeat
159

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left, URNs on the right.

That can come down.

The work of your Inquiry so far has covered a period
of over 20 years. It has heard evidence through oral
witnesses from 267 individuals. We had published the
written evidence from a further 229, including those
listed on that PowerPoint presentation. Your Inquiry
has disclosed to Core Participants almost 250,000
documents totalling just under 2 million pages of
documents. I'm told, for those wishing to visualise
that number, if stacked up it would be the length of two
football pitches.

Can we turn, lastly, then to Phase 7 of the Inquiry.

As we move on to the final phase of oral evidence,
the Inquiry will turn its focus to the current practice
and the current procedures within the Post Office and
within Government, in relation to the Post Office.
Phase 7 will include evidence from current and former
senior officials and executives within the Post Office
and Government. We will also return to looking at the
effectiveness of the compensation schemes and the
redress schemes, building on your Interim Report
published last year.

Work on this phase has been going on in the

background for many months now. Those following the
158

the appeal which Mr Beer has made for continued
participation in the two surveys. I am obviously
heartened by what he has had to say about the numbers of
participants to date but it is crucial that I get as
full a response as possible to these surveys because we
have looked long at the past, but now I'm coming up to
date, so to speak, and I want to know about the present,
both in terms of subpostmasters' reactions to the
present regime -- survey number 1 -- and postmasters'
reactions to the compensation scheme HSS in particular.

I think I am now brave enough to say that I have
stretched my terms of reference on compensation to, and
perhaps beyond, breaking point. It's something I am
very keen to say as much about as I reasonably can. So
I need as much help as possible from those who are
claiming compensation in order to make proper
conclusions about what has happened and whether it lives
up to the mantra of being full and fair.

I want to stress that the surveys are not connected
to the Post Office. I said that, I think, some weeks
ago when they were first introduced but I want to stress
that, because I can't help but think that there will be
lurking in some people's minds "Do we really want to get
involved with this? Is the Post Office somehow behind
it?"

160

(40) Pages 157 - 160
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The Post Office is not, this is for the benefit of
the Inquiry. So if you find it difficult to speak about
challenges which you still face, you people out there
whom I am addressing, please be assured that these
surveys are for the benefit of the Inquiry and therefore
ultimately for the benefit of me writing a sensible
report about the information they will contain.

Let me just say something about Phase 7. I think —-
in fact, I'm 95 per cent sure -- that this will begin in
the week commencing 23 September. There are significant
issues to examine. I don't want to rush it. So what
I expect is that hearings will run into November. Quite
how far into November we'll have to see because I have
decided that you all deserve a break in the middle of
this Phase 7, so that there won't be sittings in the
last week of October and the first week in November,
ie the potential half term weeks when people may want to
take a break.

Awitness timetable for these sessions will be
published as soon as we can reasonably do that.

All that will be left after the Phase 7 evidence is
closing submissions and I want to tell you what I have
in mind, and I'm telling you this now so that if anybody
violently objects, they'll have a chance to register

their objection. What I want is that the substance of
161

You've heard me praise my team up to the sky is the
limit, but all you -- and I'm looking past Mr Beer
because Mr Chapman hides in the corner there and I can
never see him -- but every CP in this room deserves
credit, together with their legal teams, for
facilitating my work.

So thank you all very much. I am going to retreat
back to Wales shortly and escape the heat of London but
I'll see you again in the autumn.

MR BEER: Thank you, sir.
SIR WYN WILLIAMS: Right. There we are.
(3.29 pm)

(The hearing adjourned until September 2024)

163

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closing submissions are in writing. I do not want
anyone to get the impression that I am going to sit
here, or on screen, for a number of weeks listening to
oral submissions because I'm not.

What I will allow are reasonably short oral
submissions so that the advocates can demonstrate their
oratorical skills and treat me as I'm a jury in the Old
Bailey, even though I'm not, but it will allow there to
be some human impact to those oral submissions. So
I would expect that oral submissions will last for, say,
up to two days but the bulk of it has to be done in
writing, not least because that's the best way that
I can ultimately digest what is being said.

With a fair wind, all that will be completed for all
you to go off and enjoy your Christmas holidays, and for
me to think "Oh, my goodness, what comes next?”

Can I thank you all for participating as you have
done in this phase of the Inquiry.

Mr Beer, with his usual understatement, has reduced
66 witnesses and goodness knows how many documents he
mentioned, as if it was an everyday occurrence. With
the cooperation of all of you, we have got through
an enormous amount of work in a very short period of
time and, for that, I am eternally grateful for every
single person who participates in this Inquiry.

162

INDEX
SUSANNAH JEMIMA STOREY (affirmed) 1
Questioned by MR BLAKE .... 1
Questioned by SIR WYN WILLIAMS .... 121
Questioned by MS PAGE . 122
Questioned by MR STEIN 139
Announcements by MR BEER ... 155,
Statement by SIR WYN WILLIAMS .. 159

164

(41) Pages 161 - 164
FROM THE FLOOR:
[1] 2/6

MR BEER: [4] 155/8
155/11 155/13 163/10}
MR BLAKE: [21] 1/5
1/9 2/4 2/10 23/21
23/25 44/3 44/8 45/10
45/13 45/15 45/20
77/6 77/9 77/13 103/9
103/12 103/19 121/6
122/13 154/19

MR STEIN: [7] 139/8
139/12 139/18 150/12}
153/1 153/24 154/17
MS PAGE: [3]
122/15 137/21 139/5
SIR WYN WILLIAMS:
[39] 1/3 1/25 2/7
23/19 23/24 43/25
44/5 44/9 44/23 45/9
45/12 45/14 45/19
77/8 103/11 103/13
103/17 1241/9 121/22
122/1 122/4 122/7
122/10 122/12 137/18
137/20 139/6 139/10
139/15 150/5 150/11
152/25 153/11 154/14]
154/18 154/21 155/12}
159/22 163/11

THE WITNESS: [2]
2/8 155/9

‘and [1] 129/2
"below [1] 143/20
‘best’ [1] 51/3
"class [1] 89/6
"D [2] 81/6 81/9
‘exceptions’ [1]
48/20

"muddle [1] 54/1
‘on [1] 128/9
"scaring [1] 80/9
"the [1] 53/24

[2] 81/7 81/10

I
IBIS [1] 47/11

0

0.1 per cent [1]
61/23

1

1 July [9] 47/16
47/17 49/15 49/20
51/14 57/12 126/22
134/21 135/3

1.4 [1] 13/15

1.3 [1] 117/19

1.34 billion [4] 16/14
10 [5] 2/13 2/14
30/16 35/12 140/18
10.00 [4] 1/2

100 [3] 74/18 74/18
146/3

100,000 [1] 44/14
102 [1] 1/16

11 [5] 45/21 146/15
146/17 146/21 157/17)
11 February [1]
108/18

11 years [1] 58/19
11,500 [1] 59/6
11.06 [1] 45/16
11.15 [4] 45/13
11.18 [1] 45/18
110 [1] 2/22

414 [1] 2/25

12 [2] 146/15 147/1
12 July [3] 69/1 90/6
112/17

12 years [1] 58/19
12.06 [1] 77/10
12.15 [1] 77/9
12.18 [1] 77/12
12.5 per cent [1]
159/11

12.58 [1] 103/14
127 [1] 73/16
13/97 [2] 97/20 97/21
13/99 [1] 97/20

14 [3] 147/9 147/10
147/12

14 March [3] 6/10
6/23 121/5

14/38 [1] 114/11
14/43 [4] 114/24
140 [2] 76/4 119/2
15 [3] 139/9 139/12
139/16

15 May [2] 125/1
148/21

150 [1] 99/13
150,000 [1] 22/12
16 [5] 92/21 147/9
147/14 155/24 156/8
16 July [14] 57/20
65/22 73/25 76/21
77/18 83/7 85/18
86/13 89/13 93/22
94/1 96/14 97/9 101/7
16,000 [1] 159/10
16th [1] 76/20

17 [3] 83/21 140/1
140/3

18 [1] 140/8

18 April [1] 20/16
19 July [1] 86/18
19 September [2]
37/20 45/20

1994 [1] 147/11
1995 [1] 3/20

2
2 million [1] 158/9
2,000 [1] 159/8
2.00 [2] 103/12
103/13
2.02 [1] 103/16
2.13 [1] 151/2
2.16 [2] 14/4 16/22
2.2 [1] 104/21
20 [2] 46/1 158/4
200,000 [1] 44/16
2006 [4] 3/21 3/24
9/2 120/3
201 [1] 3/4
2010 [7] 12/4 12/18
13/6 16/14 31/15
42/13 142/1
2011 [15] 4/2 4/20
5/24 6/1 7/25 12/23
19/10 24/7 26/10
38/25 40/15 41/24
42/14 140/21 152/7
2012 [49] 4/2 4/9
5/17 6/9 6/10 6/17
6/23 8/1 8/5 9/12
44/41 11/21 12/21
13/4 13/8 14/2 14/25
15/12 17/5 20/17
23/25 25/19 26/17
26/25 27/3 32/9 34/7
35/22 37/20 37/23
38/10 39/20 40/14
40/21 43/9 45/20 75/9
75/24 121/5 133/2
133/17 133/25 134/9
145/14 145/17 145/18I
145/22 148/17 152/11
2013 [38] 3/24 5/17
7/11 18/3 38/20 42/19
43/4 46/22 46/23 47/4
49/16 64/6 65/22 98/9
4100/1 102/10 103/4
103/21 108/14 108/21
109/14 109/22 112/11
112/13 116/16 118/22
122/17 123/10 125/23
126/8 134/21 134/22
135/25 145/15 145/16
152/1 152/21 153/18
2014 [14] 4/9 14/15
27/7 75/25 107/23
108/6 109/1 109/8
109/22 109/23 111/21
118/15 134/21 154/13
2015 [1] 154/5
2019 [1] 13/24
2020 [4] 130/18
131/20 132/1 132/23
2024 [3] 1/1 120/14
163/13
24 [4] 2/12 2/13
140/18 140/19
218 [2] 74/18 74/19

22.57 [1] 111/6
229 [1] 158/6

23 May [1] 1/13
23 September [1]
161/10

25,000 [2] 78/16
79/25

250,000 [1] 158/8
26 February [1]
113/10

267 [1] 158/5

27 July [1] 87/21

28 June [1] 47/15

3

3 July [1] 52/7

3.29 pm [1] 163/12
30 [5] 83/23 83/24
84/19 88/1 88/18
30 July 2024 [4] 1/1
31 [5] 84/25 88/1
88/4 88/17 114/11
31 October [1]
103/20

32 [3] 88/13 143/9
143/12

38 [1] 114/11

4

4 July [4] 34/7 34/12

50/17 51/13
4.00 [1] 144/14
42 [1] 68/10

43 [4] 114/24
44 [1] 21/1

47 [2] 61/22 85/9
49 [1] 2/22

5

50 [3] 11/2 98/10

107/25

500,000 [2] 22/4
141/17

54 [3] 17/17 17/19
18/4

6

6 July [1] 53/15

66 [5] 143/8 143/9
143/12 156/5 162/20
68,000 [2] 59/6 61/19
6th [2] 55/10 55/11

7
7 August [1] 92/1

7 February [2]
108/13 109/8

7 October [1] 12/8
7.00 am [1] 111/12

8

8 July [5] 57/6 57/7
58/16 63/8 119/10
85 [4] 22/17 90/11

142/14 143/4

85 potential [1] 40/3
8th [4] 55/12 55/14
55/17 56/16

9
9 July [1] 64/5

9.00 [1] 144/13

9.07 pm [1] 126/24
90 [5] 3/6 3/7 37/21
44/3 144/20

93 [2] 37/25 44/4

95 per cent [1] 161/9
97 [2] 97/20 97/21
99 [1] 97/20

A

ability [5] 85/23
105/1 110/23 120/18
143/17

able [5] 62/16 64/7
73/18 109/5 123/1
about [155] 2/15 5/13
7/20 9/5 12/20 16/11
16/19 17/10 19/15
20/1 22/20 24/17
24/18 25/10 25/11
25/18 26/5 27/4 27/11
27/22 28/23 29/5 30/7I
31/25 32/2 33/12
33/24 38/8 38/13
43/14 44/11 53/12
55/5 55/9 56/23 57/4
58/24 59/10 59/20
60/4 60/21 60/22
63/22 63/25 64/14
64/15 64/17 66/16
67/19 67/22 70/15
73/12 73/23 75/6
75/16 82/11 85/7
85/13 86/23 87/10
89/2 90/5 91/11 93/9
93/16 93/19 93/21
94/10 95/23 96/11
97/1 101/7 102/7
105/21 109/15 113/5
116/6 117/3 117/48
119/48 121/10 121/10]
121/12 122/21 123/9
123/20 124/1 124/3
124/4 124/9 124/25
125/14 126/15 127/14I
127/18 127/18 127/20
128/17 129/24 130/10I
130/24 132/14 132/18I
132/24 133/4 133/10
133/15 133/16 133/22I
135/9 135/13 136/8
136/16 137/13 137/17I
137/18 138/6 139/9
139/12 139/25 140/10I
140/11 141/10 142/23I
144/8 144/23 145/10
145/11 148/3 149/19

(42) FROM THE FLOOR: - about
A

about... [25] 150/13
150/19 151/7 151/8
151/14 151/21 152/1
152/8 152/10 152/24
153/3 153/7 153/18
155/21 156/3 157/1
157/25 159/18 160/3
160/7 160/14 160/17
161/2 161/7 161/8
above [7] 33/3 95/6
140/8 140/9 140/20
142/16 142/17
abreast [1] 82/1
absence [1] 68/18
absolutely [19] 5/23
6/20 8/15 10/8 10/8
12/5 17/16 23/21 33/7
39/15 42/3 44/3 44/21
75/8 86/15 105/23
113/8 124/14 127/25
accept [3] 105/4
106/21 153/13
accepted [2] 61/21
71114
access [3] 20/2
27/11 146/2
accompanied [1]
112/4
account [2] 117/24
136/16
accountant [2] 28/22
29/20
accountants [2]
34/13 38/10
accountants’ [1]
52/1
accounting [7] 12/14
30/19 94/8 142/25
147/3 147/4 147/7
accounts [1] 152/2
accuracy [6] 41/19
62/20 127/14 127/18
140/13 140/22
accurate [5] 59/14
60/2 95/20 127/21
128/2
accurately [2] 59/23
117/16
accused [1] 44/15
acknowledgement
[4] 121/14
across [4] 59/4 80/24
138/5 142/21
act [6] 6/1 7/20 9/2
38/25 73/18 157/10
acted [1] 72/1
acting [4] 24/25 31/6
73/18 122/22
action [5] 22/13 31/7
35/13 53/9 89/12
action’ [1] 89/6
actions [18] 57/22

68/16 72/10 76/5
76/25 85/19 86/21
90/13 93/11 94/1
96/19 104/18 105/24
112/16 115/24 118/23}
119/16 153/7

active [3] 76/6 76/24
92/20

activity [2] 36/2
36/17

actual [2] 91/3 109/6
actually [26] 1/25 8/8
10/18 12/1 17/5 19/25
24/1 24/7 26/22 44/22
47/21 50/7 51/15
51/23 56/11 100/9
105/21 111/10 118/23)
123/24 126/13 134/22)
139/1 140/4 146/23
149/8

ad [1] 33/5

ad hoc [1] 33/5
adamant [1] 146/7
add [1] 124/22
added [1] 78/12
addition [2] 10/13
88/17

additional [5] 7/14
9/3 9/6 48/16 85/22
address [8] 7/4 48/18)
58/5 58/6 59/12 77/14
77/16 81/16
addressed [6] 37/22
49/7 95/1 107/11
114/16 118/6
addresses [3] 13/25
22/5 49/11
addressing [3] 88/4
91/16 161/4
adjourned [1] 163/13
Adjournment [1]
103/15

admitted [2] 142/24
157/2

adopted [2] 102/21
140/16

advice [14] 50/12
116/19 116/20 116/21
116/24 117/11 117/15)
118/7 118/10 122/22
123/25 125/14 136/6
136/13

advised [2] 78/9
147/3
advising [1] 19/4
advocates [1] 162/6
affect [2] 82/12 152/2
affirmed [2] 1/7
164/3
afraid [4] 81/15 82/21
89/1 90/9
after [41] 3/1 4/16
10/22 17/3 21/16 23/9)
26/23 32/5 33/4 36/10

37/7 37/7 39/18 60/7
67/11 76/7 76/20 77/9
79/1 82/24 85/18 86/4
86/18 97/10 101/2
101/7 102/21 105/6
111/12 116/10 120/5
121/4 128/25 130/18
131/3 131/25 132/2
134/5 136/19 140/9
161/21
afternoon [1] 54/8
afterwards [5] 36/25
118/9 126/23 126/24
150/14
again [25] 6/25 19/10
20/8 25/13 35/7 35/17
39/4 47/24 53/16
66/25 81/13 85/5
91/10 91/16 95/4
104/1 114/3 115/19
126/12 129/25 130/9
142/21 147/1 152/23
163/9
against [4] 31/7 62/4
94/14 94/21
agenda [9] 5/25
39/16 45/20 46/11
46/21 133/8 134/3
135/12 144/9
agendas [2] 46/7
69/13
agents [1] 110/24
ago [6] 14/12 58/19
58/20 96/10 131/5
160/21
agree [7] 8/24 15/6
16/16 44/20 45/6
130/14 144/18
agreed [6] 28/19
28/21 69/21 98/1
118/13 151/22
agreement [4] 15/14
16/14 16/16 25/24
agreements [1] 27/8
Ah [1] 24/6
ahead [3] 46/20 48/9
85/7
Aimed [1] 67/4
ain't [4] 153/4
Alan [15] 12/8 13/10
30/12 30/13 30/20
31/14 31/22 32/21
40/18 41/10 53/19
53/23 64/19 132/18
134/17
Alasdair [21] 24/1
24/12 24/13 43/19
46/13 73/1 79/4 80/18
80/20 84/14 88/23
89/19 90/2 90/18
91/12 92/19 93/11
93/15 95/21 115/25
128/14
Alasdair's [2] 127/4

128/10
alert [1] 87/7
Alice [20] 21/21 24/8
25/25 26/5 26/8 26/22
41/14 68/19 85/4 92/3)
110/2 111/9 126/23
126/25 127/12 131/8
132/15 134/10 134/16
137/25
Alice's [2] 92/7
111/18
all [109] 6/2 7/1 7/20
11/1 11/19 22/24 23/2}
24/24 25/11 25/19
25/21 27/17 29/2 29/3)
29/10 30/6 33/3 37/2
38/3 39/11 39/22
41/22 42/1 42/8 45/5
46/7 48/6 50/12 51/13)
52/4 54/23 55/2 55/24
57/9 57/18 57/19
57/21 61/2 61/6 64/15)
64/25 66/25 67/10
76/5 80/14 84/9 84/23,
86/2 86/9 87/10 87/11
87/22 89/14 89/24
90/17 91/23 93/8
93/15 96/12 96/21
97/1 101/3 103/11
105/6 105/24 108/9
112/15 112/21 115/24
4117/1 117/4 119/2
120/11 121/6 121/11
126/20 128/12 128/24}
129/10 131/22 132/1
137/3 137/9 137/20
138/5 142/14 143/5
143/6 144/7 144/20
145/10 146/7 146/18
148/1 154/19 155/8
156/17 156/17 159/4
159/4 159/14 161/14
161/21 162/14 162/14}
162/17 162/22 163/2
163/7
allegations [2]
104/21 104/23
alleged [5] 22/10
22/11 35/12 142/19
142/20
alleges [2] 22/9
142/18
Alliance [1] 13/5
allow [2] 162/5 162/8
almost [2] 82/24
158/8
along [1] 68/21
alongside [1] 24/7
already [8] 20/21
24/3 54/18 85/9
106/23 113/25 115/22}
129/8
also [55] 5/5 5/13 7/1
8/21 11/3 11/17 15/16

20/20 21/20 25/25
28/20 28/21 30/18
31/17 32/5 32/9 45/7
46/25 47/20 51/10
52/5 52/7 54/3 54/8
55/17 57/11 58/4 64/9I
69/5 70/1 70/5 71/13
72/20 76/24 80/22
84/2 90/20 92/22
93/22 94/24 96/3
98/16 102/17 106/13
111/24 113/6 119/19
125/15 126/7 129/11
139/20 149/24 152/19)
152/20 158/20
although [8] 1/21 7/8
36/8 38/14 40/2 51/23}
109/2 152/12
Altman [4] 110/20
Altman's [1] 83/22
always [4] 10/10
37/11 37/15 117/4
Alwen [6] 47/9 54/7
77/20 77/22 84/6
136/25
am [28] 1/2 18/14
35/17 39/4 45/16
45/18 46/12 68/20
81/8 82/22 103/21
4111/1 111/12 111/16
111/16 127/12 130/14I
139/8 148/13 159/12
159/24 160/2 160/11
160/13 161/4 162/2
162/24 163/7
ambiguous [1] 77/18
ambitious [1] 5/24
amongst [3] 23/3
105/2 111/5
amount [3] 82/22
88/12 162/23
analysis [1] 117/17
analytics [1] 159/2
Annexe [3] 84/2 88/8
88/19
announce [1] 102/7
announced [2] 102/9
133/2
announcements [3]
154/23 155/10 164/13)
annoyance [1] 48/19
annual [1] 10/1
anodyne [1] 70/18
anomalies [1] 48/24
another [19] 24/11
28/19 30/9 30/12 34/7
35/6 47/22 56/13
56/19 60/12 61/5
88/23 99/5 102/6
119/21 126/20 141/6
146/19 156/9
answer [9] 79/10
79/18 81/15 89/1
116/17 123/6 136/20

(43) about... - answer
A

answer... [2] 136/21
153/11
answering [1] 155/4
answers [2] 18/11
60/14
Anthony [2] 18/1
99/9
anticipate [1] 28/1
anticipated [1] 35/13
any [82] 2/14 5/7 5/9
7/6 10/6 11/20 18/20
22/19 22/21 28/5
28/13 28/24 29/5
29/24 30/8 33/15
33/15 34/15 36/9
37/14 38/8 38/23
48/25 50/25 51/14
52/18 52/24 53/9
54/16 54/20 61/1
61/11 61/13 63/24
67/16 69/17 70/9
70/10 71/2 79/9 80/1
81/22 82/1 82/2 82/11
83/19 86/6 88/9 88/9
93/18 93/25 97/10
101/16 102/18 102/18
103/1 106/14 112/1
112/4 115/7 117/22
121/9 121/14 123/6
125/16 125/17 125/21
128/13 129/14 129/22)
132/9 133/25 137/1
137/2 138/11 146/8
146/23 146/25 148/6
152/3 152/14 152/15
anybody [7] 42/23
43/18 45/7 55/17
63/25 93/19 161/23
anyone [1] 162/2
anything [14] 12/19
15/9 21/10 23/12 33/4}
68/24 87/8 112/2
114/6 119/19 125/24
132/24 140/23 153/19
anyway [3] 112/6
138/7 150/5
AOB [3] 72/6 133/3
133/5
apologies [5] 2/9
66/13 84/23 87/22
104/1
apparent [1] 48/19
appeal [2] 54/18
160/1
appear [4] 125/2
137/13 141/9 146/16
appeared [5] 125/3
146/12 148/20 148/21
149/7
appears [5] 44/18
79/24 81/6 143/19
144/3

applicants [1] 159/5
applying [1] 125/9
appointed [10] 11/4
14/3 20/22 24/3 28/4
35/10 38/11 52/17
99/9 106/18
appointing [1] 87/3
appointment [2]
15/12 21/4
appreciate [6] 38/19
63/15 110/6 137/6
149/18 149/22
approach [3] 15/18
54/5 111/23
appropriate [9] 9/16
29/23 45/10 48/18
67/10 76/18 76/19
77/6 103/9
approved [1] 113/21
April [21] 4/9 6/8

11/10 12/21 13/1 13/8)

14/2 14/25 20/16

25/19 27/6 40/13 75/9

75/24 109/21 109/22

109/23 131/20 145/17)

145/18 156/4

April 2012 [1] 75/9
April 2014 [1] 109/22
Arbuthnot [22] 28/15
28/19 34/10 34/12
35/4 36/2 36/17 40/6
41/7 41/10 47/25 48/2
48/15 49/21 54/8
54/14 57/3 64/19
131/9 132/18 134/11
134/17
Arbuthnot's [2] 36/4
48/18

arc [7] 89/19 112/11
112/12 112/22 114/1
115/14 118/19
arch [1] 22/24
archive [1] 45/22
are [117] 1/21 2/10
10/25 13/1 20/17
20/18 22/12 22/17
23/6 23/10 26/8 30/14
38/3 39/10 44/13
44/14 44/15 49/23
50/21 53/3 53/16 54/5)
54/18 54/20 56/1
59/12 60/6 61/6 61/6
62/16 63/21 65/25
67/7 67/8 67/8 68/7
70/11 70/17 74/9
74/10 78/9 78/18
79/23 81/3 83/10
83/18 84/7 85/8 85/9
85/22 86/3 90/22
90/22 92/5 92/16
95/25 96/13 98/21
100/6 103/24 103/25
105/15 108/12 110/9
110/10 110/15 110/23}

118/1 118/2 118/17
121/6 123/17 124/13
127/3 130/23 132/4
135/23 136/3 142/14
142/22 143/3 143/5
143/6 144/7 144/21
146/4 146/13 147/3
147/6 147/8 147/8
147/25 148/12 151/3
151/10 151/12 152/3
154/9 154/9 154/19
155/21 156/13 157/6
157/9 157/11 157/12

159/6 160/15 160/19
161/5 161/10 162/1
162/5 163/11

area [2] 16/12 110/25
areas [10] 9/20 27/25

96/13 105/2 120/24
138/5

arise [3] 62/6 70/6
117/25

arising [7] 54/12
54/20 79/10 82/25
105/11 118/20 136/4
arm's [1] 68/11
arm's-length [1]
68/11

arose [1] 9/17
around [20] 23/3
25/12 41/23 48/19
48/22 50/22 52/9 59/5
60/8 60/11 61/19 66/3
90/22 105/19 126/4
126/10 128/19 145/20
148/23 159/11
arrange [2] 47/8
87/13
arrangements [1]
36/3
array [1] 75/19
arrive [1] 70/1
arrived [1] 16/15
articles [1] 133/21
as [248]
aside [2] 111/24
156/12

ask [9] 1/15 5/13
27/18 85/13 121/9
134/22 141/8 146/18
157/7
asked [22] 12/25
28/5 70/2 70/5 71/1
71/19 72/19 72/20
77/23 78/24 80/21
87/6 108/24 114/20
115/10 115/13 116/11
135/6 136/18 142/5
150/1 150/12
asking [4] 42/14
63/16 63/16 138/8
aspect [1] 53/24

157/14 157/17 157/24

36/16 76/2 89/23 90/2

aspects [2] 8/13
55/25

assert [2] 22/16
142/13

assertions [2] 96/1
140/24

asset [1] 8/25
assets [1] 8/20
assist [13] 2/5 4/14

19/11 70/7 108/16
108/19 112/7 146/21
155/14
assuming [7] 14/21
46/13 52/7 63/9 72/8
127/12 127/13
assumption [2] 4/24
38/12
assurance [2] 74/11
131/16
assurances [2] 75/2
145/7
assured [1] 161/4
asymmetry [1]
126/16
at [361]
atmosphere [1] 69/9
attached [10] 41/23
56/9 56/10 58/23
60/17 84/1 84/10
84/24 94/6 94/24
attaches [1] 56/15
attaching [1] 56/19
attachment [4] 55/24
60/12 60/14 63/11
attachments [2]
58/21 63/3
attempt [2] 150/6
150/8
attempted [1] 57/20
attempts [1] 54/13
attend [1] 66/6
attendance [4] 40/7
100/10 103/25 113/11
attendees [1] 30/20
attending [1] 113/15
attention [13] 20/12
20/14 32/11 51/5 63/3
86/11 97/6 111/2
144/22 144/25 145/1
148/4 156/1
audit [27] 14/5 14/9
24/14 43/2 43/16
43/19 46/14 73/2
88/15 89/22 106/6
106/13 107/12 108/17)
108/21 108/25 109/2
109/4 109/7 109/9
109/13 109/20 109/24}
111/16 111/16 120/23
152/16
August [4] 19/10
35/22 92/1 156/21
Aujard [1] 104/20

11/7 14/17 16/5 18/10)

authorities [1] 62/22
authority [4] 73/19
autumn [8] 26/10
31/15 39/20 40/14
93/6 98/9 102/4 163/9
available [1] 156/18
avoid [2] 79/19 81/24
aware [23] 12/16
13/4 31/4 31/22 32/20}
38/16 48/22 51/20
53/5 63/4 66/4 68/22
73/17 85/25 95/15
95/17 95/17 96/19
120/1 126/19 132/15
150/15 159/1
awareness [2] 12/22
13/11

away [4] 110/5
145/13 148/4 148/8
awful [1] 29/3

baby [2] 145/16
148/9
back [45] 5/17 6/13
7/1 11/25 13/14 19/10}
23/1 23/6 23/11 27/2
29/4 42/14 43/2 43/5
43/9 44/1 45/13 56/17
65/8 68/22 72/5 74/17
75/15 77/9 82/8 86/16}
86/22 103/12 106/2
106/8 107/13 108/25
112/20 120/11 126/12)
126/21 130/19 133/13)
137/16 146/13 146/15)
147/11 148/5 150/25
163/8
backfilled [2] 15/2
19/3
background [8] 5/2
12/22 31/1 79/13
114/17 121/18 136/1
158/25
Bailey [1] 162/8
balance [2] 82/4
157/22
balanced [1] 129/5
banker [3] 3/20 5/6
8/4
banks [1] 110/9
based [11] 5/18
22/10 30/22 31/24
36/15 50/3 51/2 52/16)
54/13 93/3 142/19
basically [1] 144/12
Basingstoke [1]
30/22
basis [6] 27/19 87/12
118/14 142/24 143/23)
153/19
Bates [14] 12/8 13/10
30/12 30/13 30/21
31/14 31/22 32/21

(44) answer... - Bates
B

Bates... [6] 40/18

41/10 53/19 64/19
132/19 134/17
Bates' [1] 53/23
BBC [1] 41/24
BBC's [1] 12/24
be [176]
be/we [1] 81/4
Bear [1] 126/3
bearing [3] 61/13
112/23 136/2
became [9] 5/15 6/5
12/16 12/21 27/6
73/17 90/23 101/8
132/14
because [72] 1/25
8/12 9/22 14/9 14/23
14/23 16/13 18/3
18/18 20/12 21/14
24/8 25/17 26/15
27/15 29/16 32/6
32/10 32/11 34/1
34/17 39/2 41/14
43/15 45/1 47/16 50/7)
55/12 58/9 64/2 68/25)
69/14 70/21 72/9 73/2
74/5 74/14 75/22
85/21 86/22 90/24
92/11 93/8 96/9 101/2
102/6 104/1 105/7
105/17 107/6 113/3
118/9 125/17 127/11
128/16 130/7 136/5
138/1 146/1 149/11
149/14 149/16 151/15)
152/6 154/22 157/12
160/5 160/22 161/13
162/4 162/12 163/3
become [4] 31/4 34/1
101/17 136/11
becoming [4] 12/17
119/23 131/2 131/12
been [157] 5/8 8/18
10/13 11/8 12/23 13/2
13/13 17/25 18/17
18/17 19/15 22/15
24/3 25/12 25/15
25/20 25/24 26/15
27/16 28/18 29/23
29/24 30/24 32/20
35/2 36/3 36/14 37/9
37/15 38/10 39/13
39/16 39/23 42/6 43/7
47/13 49/12 50/2 50/3
51/14 51/25 52/2
52/17 52/21 52/22
53/11 55/4 55/8 57/19)
58/7 58/9 58/13 59/14
59/16 59/17 59/22
60/19 60/20 60/21
63/7 63/17 63/20
63/21 63/22 64/6 64/7;

64/9 65/7 65/20 66/3
67/13 67/14 68/2

71/11 72/1 73/1 73/5
73/7 74/12 74/25
75/13 75/23 76/15
78/22 82/6 84/23
86/22 87/22 88/15
90/6 93/7 94/1 94/8
95/22 96/8 97/5 99/9
101/9 101/19 102/8
105/18 107/2 107/13
108/1 108/20 109/3
110/3 112/11 113/2
114/20 115/25 116/3
118/20 119/9 120/20
121/9 122/20 122/22
123/21 126/4 127/5
128/5 128/11 132/2
132/17 133/11 133/13}
133/21 137/4 140/12
141/2 141/22 143/20
144/3 146/6 146/11
147/6 147/15 149/9
149/12 149/23 150/8
150/12 150/14 151/9
151/25 152/5 152/9
153/3 153/14 153/15
157/3 158/24
Beer [11] 103/17
136/18 154/22 154/25)
155/7 155/10 159/22
160/1 162/19 163/2
164/13
before [46] 2/17 5/8
5/9 7/22 8/12 10/20
10/22 11/15 12/3
21/22 23/2 23/19
27/21 32/4 33/4 36/10
36/24 37/6 37/7 43/25
57/11 68/18 70/3 70/8
73/24 75/7 78/18 85/3
91/22 94/5 96/11
103/20 107/19 112/18)
112/23 113/1 113/16
116/9 121/9 123/11
130/6 138/16 146/19
149/5 151/12 151/14
beforehand [1] 29/23
began [1] 6/10
begin [1] 161/9
beginning [8] 6/21
33/24 42/11 109/14
132/13 151/25 152/7
154/5,
begins [2] 50/19
123/15
behalf [6] 19/13
31/19 55/20 63/14
65/3 89/21
behind [3] 130/9
133/11 160/24
being [106] 5/7 7/7
7/12 8/19 10/11 15/7

68/13 69/7 70/8 70/12

15/24 23/5 23/11 28/1
31/23 34/15 34/23
35/2 35/6 35/24 39/1
40/5 44/11 47/11
47/15 49/10 49/22
52/19 52/20 53/6 55/1

60/2 60/10 63/5 64/5
72/10 72/23 73/19

80/1 80/11 81/8 86/8
88/11 88/20 90/1 90/3)
90/18 93/9 94/20
95/17 96/11 97/19
99/23 100/9 104/11
104/12 104/18 106/11
107/9 107/11 108/7
108/9 109/9 113/10
113/11 114/14 114/25
117/6 123/2 124/3
124/23 125/24 126/11
126/13 126/14 127/15)
129/3 129/24 130/10
132/11 133/13 136/13
139/1 139/25 143/14
144/16 147/3 147/9
147/20 149/15 150/8
151/1 152/4 154/9
155/21 157/17 160/18
162/13
BEIS [1] 149/6
Belfast [1] 122/8
belief [2] 1/20 3/12
believe [5] 36/7 48/8
56/1 81/20 132/4
believed [2] 27/25
28/17
below [10] 56/12
56/18 81/5 91/13
134/4 135/13 135/14
140/15 144/4 144/6
beneath [1] 15/2
benefit [4] 117/8
161/1 161/5 161/6
BERR [1] 31/13
BERRIBIS [1] 31/13
bespoke [1] 38/22
best [8] 1/19 3/12
30/8 33/12 74/7 80/3
120/12 162/12
better [9] 2/8 50/2
50/9 71/6 101/9
102/21 103/6 112/5
129/16
between [28] 3/20
3/23 4/2 4/9 5/16 18/7
25/24 26/8 32/1 33/23)
34/12 35/22 37/11
37/24 52/22 64/8
64/22 65/20 66/20
71/11 75/24 117/24
123/8 123/15 126/17
127/12 130/17 135/18}

55/5 57/3 57/13 59/19

66/16 69/3 69/17 71/9

75/2 76/6 76/14 78/17

beyond [3] 71/15
85/23 160/13
big [4] 68/9 69/4
89/10 91/2
bigger [4] 105/15
129/4 129/24 130/5
biggest [1] 90/24
[1] 98/11
billion [1] 16/14
BIS [3] 31/8 31/13
47/11
bit [15] 2/9 26/15
29/10 82/13 84/7
126/5 126/21 130/16
133/3 133/6 134/19
140/8 145/11 151/16
151/24
bits [1] 100/4
Blake [9] 1/4 1/8 45/9
45/19 103/17 150/13
151/23 153/21 164/5
blindside [2] 70/16
116/11
blindsided [9] 60/21
68/16 70/6 70/8 70/18)
76/12 96/12 135/4
135/7
blueprint [1] 11/14
board [284]
Board's [2] 88/14
124/6
boards [5] 5/5 37/7
97/11 105/6 138/2
bodies [2] 62/19
68/11
body [1] 159/18
Bond [4] 95/1 95/2
95/25 116/14
bonus [1] 15/3
both [10] 21/19 29/18)
33/20 48/3 72/21
107/10 117/12 126/18
139/12 160/8
bothers [1] 81/6
bottom [17] 28/8
28/10 35/25 48/15
69/19 78/6 79/2 79/5
83/14 84/6 84/14
88/23 104/15 111/13
113/18 123/17 153/8
bounced [1] 70/12
box [1] 41/2
branch [2] 62/8
152/2
branches [4] 59/6
62/7 139/20 139/21
brave [1] 160/11
breach [1] 91/19
breaches [1] 20/6
break [10] 45/11
45/17 77/7 77/11 92/5
92/16 103/10 103/20
161/14 161/18
breakfast [2] 66/8

66/24
breaking [1] 160/13
Brian [2] 83/22
110/20
brief [5] 21/12 48/2
50/20 64/9 65/18
briefed [1] 78/18
briefing [4] 48/12
48/14 49/12 49/20
briefings [1] 37/11
briefly [4] 58/10
116/19 119/22 137/21
bring [4] 1/23 17/18
150/7 150/8
bringing [2] 15/21
38/17
British [1] 45/22
broad [3] 83/3 83/5
132/22
broadcast [1] 79/16
broader [1] 50/4
broadly [8] 13/4 13/7
13/7 16/22 27/14
60/10 120/12 123/4
broker [3] 78/10
78/14 80/2
brothers [1] 44/15
brought [8] 20/14
29/20 38/2 38/15 40/5I
66/4 97/5 148/4
bug [2] 150/22 152/8
bugs [16] 48/23 49/2
123/20 124/3 142/3
150/20 150/20 151/1
151/3 151/10 151/12
151/25 152/1 152/4
153/15 154/9
build [1] 11/18
building [3] 18/19
121/5 158/22
bulk [2] 144/12
162/11
bullet [4] 54/10
130/23 130/25 131/7
business [38] 3/2
17/8 26/10 28/13
28/21 28/24 29/6
29/25 30/8 57/15 67/8)
67/9 69/15 70/25 71/4
71/8 71/16 71/18
71/21 72/21 74/15
75/20 90/19 90/24
95/24 99/10 102/8
104/14 110/25 115/6
115/10 125/2 126/5
129/17 130/2 1341/5
133/25 148/14
businesses [3] 73/3
73/7 110/19
busy [9] 46/24 47/1
76/7 98/24 99/2 99/3
101/17 102/14 104/2
but [188]

(45) Bates... - Cabinet
Cc

Cable [1] 26/16
calibre [1] 75/10
call [15] 12/22 47/16
48/9 49/20 50/24 51/9
51/23 51/25 55/4
57/12 94/13 120/24
127/14 127/25 154/15}
Callard [12] 17/21
17/23 27/6 107/9
109/24 113/3 113/11
113/14 114/12 130/17)
130/25 131/17
called [3] 133/11
141/25 159/3
calm [1] 139/3
came [16] 5/17 39/8
40/15 49/2 71/25 96/2
100/2 100/4 112/13
113/6 116/23 135/24
144/22 148/5 150/8
152/17
campaign [1] 31/18
can [118] 1/9 1/15
1/16 1/25 2/11 4/14
11/7 14/17 16/4 17/17)
19/14 20/14 20/25
21/6 22/1 23/12 23/18
23/20 23/23 24/12
31/2 34/6 34/7 34/9
35/5 35/7 37/20 40/25)
44/1 45/13 47/6 48/11
48/15 49/5 50/16
53/14 54/4 54/21 55/9
56/8 56/18 58/1 60/12
65/21 67/25 67/25
70/7 71/8 74/17 77/21
82/4 82/16 83/1 83/23
84/5 84/13 85/16
86/17 88/19 91/5 91/8
92/2 92/4 94/25 97/17,
98/6 99/4 100/14
100/21 103/12 103/22)
103/24 104/6 104/16
106/2 108/12 108/15
108/16 108/19 111/2
111/4 112/7 113/9
113/12 113/18 114/8
114/15 116/20 117/14}
123/6 124/14 124/19
126/20 127/6 128/12
130/15 130/16 132/3
132/21 132/23 139/23}
140/25 141/15 142/9
142/17 143/11 146/15)
150/5 154/12 154/25
158/2 158/13 160/14
161/20 162/6 162/13
162/17 163/3
can't [38] 25/14
29/10 32/13 44/21
58/3 58/4 58/8 58/18
60/4 62/17 64/1 66/25)

72/25 73/11 73/12
75/23 76/1 96/9 96/22
100/11 100/13 100/13)
111/25 114/1 114/6
114/14 115/16 121/20)
121/20 125/9 127/11
127/21 128/23 131/22)
137/15 146/5 152/11
160/22

cannot [1] 61/1

cap [2] 85/11 87/1
capability [1] 72/15
capable [1] 137/23
capacity [2] 72/14
89/22

capping [1] 85/14
care [2] 67/10 86/10
career [5] 8/1 8/3
98/25 99/3 103/1
careful [1] 156/1
Caroline [1] 149/25
carried [1] 26/24
carries [1] 128/24
carry [1] 152/25
carrying [2] 16/8
88/15

Cartwright [1] 83/17
case [13] 5/2 39/21
44/19 61/20 83/15
90/11 94/18 95/14
97/4 99/12 110/8
137/12 141/20

cases [32] 12/13
22/17 28/16 28/20
28/23 35/12 36/4 36/6
38/1 38/2 38/14 40/3
40/5 44/4 44/6 44/12
51/3 54/21 61/1 61/2
61/7 61/11 61/21
62/25 83/19 85/9
85/22 97/4 99/13
1410/5 110/7 142/14
catastrophic [1]
75/23

catching [1] 126/25
categories [1] 157/6
caught [3] 128/25
129/3 129/24
causative [1] 118/2
cause [7] 51/7 52/12
59/8 131/12 131/15
132/6 150/24

caused [4] 19/22
35/12 102/19 146/14
ce'd [1] 18/17
ceasing [1] 108/9
cent [3] 61/23 159/11
161/9

Centre [1] 34/18
CEO [3] 71/19 114/17
133/2

certain [4] 9/24 94/17
95/13 155/2
certainly [9] 16/4

16/18 32/22 42/9
54/14 65/9 97/8 113/2
113/5
cetera [6] 18/24 46/1
76/12 88/16 91/20
94/22
CFO [3] 72/19 115/4
115/13
chain [8] 79/12 82/21
82/23 89/8 92/3
108/16 111/10 113/25}
chains [1] 91/22
chair [9] 16/10 73/2
86/5 87/4 89/19 89/22
114/4 134/2 138/18
chaired [4] 21/21
43/19 46/14 46/15
chairman [32] 9/12
10/2 10/3 20/24 21/1
23/15 24/13 24/14
25/10 26/4 27/13
27/16 28/3 28/14 29/8
29/13 29/18 32/11
34/11 34/21 34/23
35/3 41/12 43/10 46/8
64/18 66/12 66/15
70/2 98/1 99/10
113/13
Chairman's [1] 26/17
chairs [1] 46/13
challenged [2] 28/17
74/21
challenges [2] 94/8
161/3
challenging [1] 75/16)
chance [6] 33/15
44/25 47/19 136/13
155/6 161/24
change [14] 5/18 6/3
6/15 7/11 7/17 7/20
17/13 17/21 19/25
42/20 58/6 67/25
109/17 120/17
changed [4] 34/4
88/3 109/21 114/5
changes [8] 1/22
2/10 3/11 16/24 73/3
78/3 98/21 100/6
changing [1] 71/20
Channel [1] 31/16
Channel 4 [1] 31/16
Chapman [1] 163/3
charged [2] 93/23
147/15
charges [2] 94/14
147/16
Charles [4] 80/15
91/6 91/7 91/11
chasing [1] 93/17
check [7] 55/9 62/3
62/20 74/11 81/3
113/1 118/14
Chief [13] 29/13
29/18 35/1 41/13 47/7

64/18 66/22 67/19
98/3 99/6 99/20
100/20 149/7

chop [1] 109/17
Chris [12] 79/4 79/17
80/22 81/12 82/5 82/8,
89/7 91/5 91/12 95/22,
96/4 104/20

Chris' [3] 81/5 81/11
81/15

Christmas [1] 162/15
chronological [1]
22/25

chronology [3] 26/23
39/17 99/19

circa [1] 22/12
circulated [2] 87/15
140/20
circumstances [3]
15/9 95/6 147/5

civil [7] 2/19 5/4 7/13
10/6 37/25 42/5 103/2}
claim [14] 19/15 22/5
39/24 40/2 78/16 79/9)
80/1 81/25 89/5 89/6
89/12 94/20 142/23
146/11

claimants [1] 90/11
claiming [1] 160/16
claims [11] 12/10
22/4 22/8 22/13 30/14
37/25 70/25 82/1
90/21 141/17 141/19
clarification [4]

79/19 80/20 82/8 88/6
clarified [1] 25/1
clarify [2] 87/17
114/20

clarifying [1] 28/3
clarity [1] 93/16
Clarke [5] 122/22
123/25 125/14 136/6
136/13

class [2] 89/12 90/13
clause [1] 146/12
clear [29] 2/18 6/5
6/16 10/10 15/24 19/1
21/14 26/18 33/24
36/6 54/16 59/3 69/24
72/12 79/23 85/8 91/3}
93/10 101/19 105/20
107/8 119/14 124/7
133/24 139/8 146/22
146/25 150/6 153/18
clearer [1] 48/3
clearly [6] 9/12 30/1
74/9 121/12 141/23
152/19
clients [1] 143/4
Climate [8] 5/18 6/15
7/11 7/16 7/20 17/13
42/20 58/6
clock [1] 146/2
close [2] 138/8

146/16
closed [1] 19/25
closer [1] 123/6
closing [2] 161/22
162/1
coaching [2] 138/1
138/2
codes [1] 74/7
coincide [1] 108/4
collaboratively [1]
53/20
colleagues [1] 25/2
colour [3] 22/22
135/20 137/9
Colquhoun [2] 91/6
91/11
column [2] 142/10
157/15
combination [3]
102/19 115/7 119/15
combining [1] 82/18
come [27] 6/13 10/10
16/3 16/11 17/20 23/9)
32/3 45/13 52/25
57/20 68/21 73/15
75/7 77/9 86/16
103/12 106/8 108/5
111/8 123/8 131/23
132/23 133/8 136/17
144/24 155/11 158/2
comes [2] 68/14
162/16
comfort [6] 28/23
41/16 68/7 81/11
89/18 92/19
comfortable [1] 28/7
coming [17] 37/14
38/24 52/2 55/6 57/14
58/7 63/19 78/25 86/3}
86/17 93/25 108/25
116/7 126/12 131/15
145/1 160/6
commencement [1]
13/22
commencing [1]
161/10
comment [4] 61/1
75/6 96/9 130/22
commentary [1]
121/1
comments [2] 41/25
55/23
commercially [1]
69/25
commissioned [4]
117/11 118/9 119/19
159/1
commitments [1]
109/12
committed [4] 59/1
85/8 138/3 144/12
committee [38]
14/10 31/9 32/7 36/18)
37/7 43/3 43/6 43/17

(46) Cable - committee
Cc

committee... [30]
43/19 46/13 46/14
46/15 69/21 73/2 77/3)
89/22 106/6 106/14
107/12 108/17 108/22)
108/25 109/2 109/4
109/7 109/9 109/13
109/17 109/20 109/25}
111/16 120/23 125/2
125/5 125/6 148/15
149/6 149/24
committee's [1]
150/2
committees [2] 14/6
109/15
commonality [1]
110/17
communicating [4]
8/21 9/6 9/8 65/20
communication [2]
65/2 65/12
communications [2]
68/4 147/17
companies [8] 5/25
9/2 10/14 11/10 11/12
11/14 38/21 120/8
company [18] 9/22
16/9 23/15 27/10
27/13 30/4 43/11
52/22 53/10 53/11
69/13 70/10 76/14
76/18 120/9 135/18
137/1 140/16
company's [2] 21/18
114/20
comparable [1]
112/2
compared [1] 110/20
comparing [1] 63/23
compelling [1] 51/3
compensation [6]
115/4 119/6 158/21
160/10 160/12 160/16
complaining [1]
133/22
Complaint [1] 114/18
complaints [4]
117/18 133/15 133/20
149/19
complete [3] 41/19
159/9 159/16
completed [4] 44/11
108/1 159/9 162/14
completely [4] 50/11
103/5 127/5 128/11
completing [1] 83/13
complex [6] 8/2 8/5
80/10 110/23 118/25
147/18
Compliance [1]
24/15
complicated [7]

10/14 21/13 96/17
102/4 119/1 119/12
147/20
complication [1]
78/13
complying [1] 83/18
computer [3] 7/2
59/3 129/6
computer’ [1] 53/24
concern [17] 16/12
16/18 16/19 20/1 26/5)
26/24 27/10 27/21
52/12 56/25 94/15
95/11 97/3 97/11
123/14 123/18 128/17)
concerned [6] 28/23
57/4 59/19 70/24
81/20 127/17
concerns [16] 2/15
12/15 16/23 24/17
26/4 26/11 26/20 28/5
61/9 67/19 67/21 94/7
107/1 152/14 152/15
152/20
conclude [1] 154/23
concluded [1] 101/11
conclusions [2]
117/17 160/17
conclusive [1]
129/12
conduct [3] 108/9
108/10 159/3
conducted [1]
155/21
confidence [8] 41/19
59/8 105/3 105/10
105/21 140/11 140/13)
140/22
confident [1] 72/13
confidential [2] 48/5
141/17
configured [1] 80/12
confirm [4] 1/16
80/15 129/7 129/10
confirmed [2] 24/22
53/20
conflict [5] 16/19
25/11 27/25 98/14
101/10
conflicting [2] 57/13
63/19
conflicts [1] 27/24
confronted [1] 45/4
connected [1]
160/19
connection [1] 88/10
conscious [1] 11/3
consider [4] 54/19
59/13 95/9 115/10
considerably [1]
130/18
consideration [1]
94/7
considerations [1]

71/25

considered [4] 19/22
71/20 114/1 121/16
considering [1]
156/12

consistent [3] 60/6
74/6 140/15
constituencies [1]
28/21

constituency [1]
28/16

constituents [1]
31/19

constituted [1] 40/16
constitutionally [1]
43/23

constructive [1]
53/18

consultation [2]
35/11 147/22
consulted [2] 22/16
142/13

contact [2] 62/7 70/2
contacted [1] 146/3
contacting [1] 92/1
contain [1] 161/7
contained [2] 96/6
104/24
contemporaneous
[1] 137/16

content [3] 69/22
110/9 134/14
contentious [1]
25/21

contents [2] 125/14
150/16

context [7] 5/22 31/9
31/16 67/23 79/14
105/5 146/19
contextual [1]
124/22
continue [2] 74/20
156/20
continued [6] 57/1
60/8 76/16 154/3
154/6 160/1
continues [1] 15/11
continuing [2] 42/15
102/4
contract [3] 22/9
142/18 147/10
contracts [4] 12/12
30/17 73/8 149/17
contractual [1] 31/11
contrast [1] 14/4
contribute [1] 21/20
contributed [2]
108/12 110/2
contribution [1]
110/12
control [8] 71/6
71/16 72/4 76/18
120/25 129/18 139/1
153/8

controlled [3] 138/20
138/21 138/22
controlling [1]
137/24
controls [1] 129/15
conversation [9]
27/1 29/5 66/14 67/1
82/10 86/23 130/19
131/14 138/8
conversations [15]
27/16 32/4 32/24
33/23 38/20 42/2
53/19 87/10 101/14
102/12 117/1 126/6
130/21 131/19 132/13
convicted [1] 142/24
convictions [3] 49/6
49/10 95/4
convinced [1] 110/7
Coomber [1] 30/22
Cooper [1] 130/17
cooperation [1]
162/22
copied [6] 12/23
49/12 84/13 86/20
89/25 108/18
copy [7] 22/23 26/2
48/11 55/18 55/21
94/23 141/10
copying [1] 111/15
core [3] 105/1 156/22
158/8
corner [1] 163/3
corollary [1] 33/8
corporate [2] 46/7
144/2
correct [21] 3/18
3/19 3/25 4/1 4/10
4/11 5/20 5/21 6/22
7/6 14/17 16/22 20/19)
20/20 44/25 47/2
57/16 80/16 99/18
131/13 148/16
corrected [1] 129/9
correcting [1] 19/19
correction [1] 4/5
correspondence [1]
64/21
cost [4] 71/6 82/16
82/17 128/18
costs [3] 80/10 80/24
87/2
could [66] 1/23 2/4
5/21 9/17 13/12 17/18
19/5 19/8 24/16 25/6
25/23 28/8 30/9 33/12
33/13 35/21 37/19
39/13 43/23 43/25
46/17 46/22 48/12
52/20 58/22 70/20
71/15 71/17 73/10
73/15 76/2 76/10 77/9)
77/16 80/24 84/17
85/3 87/8 87/25 88/22

91/21 96/15 101/24
103/7 104/25 108/5
109/12 110/11 112/1
115/5 115/8 116/7
119/15 121/16 123/7
123/14 123/21 123/22)
125/16 125/17 127/13)
141/12 147/15 150/24)
153/8 156/7
couldn't [3] 66/9
101/11 110/4
Counsel [4] 69/5
71/1 104/13 110/19
counterfactuals [1]
103/8
counterposed [1]
128/8
country [3] 7/21
98/11 139/22
couple [6] 5/21 14/11
130/23 134/7 150/20
154/25
course [36] 3/15 6/4
6/14 7/8 8/1 16/23
34/21 39/14 42/10
46/4 61/2 61/10 61/25
65/8 76/9 91/3 93/6
96/21 101/5 110/4
4111/7 116/12 118/24
124/5 124/5 126/10
128/21 133/7 137/8
137/11 155/18 155/24)
156/7 156/8 156/16
156/23
court [2] 35/13 61/2
cover [16] 78/5 79/9
79/24 80/23 81/7 81/9
81/17 81/19 81/20
81/22 88/11 89/2 89/3}
89/5 89/11 115/6
covered [5] 25/5 80/1
81/3 115/8 158/3
covering [2] 84/4
94/10
covers [3] 36/16
91/14 91/19
CP [1] 163/4
CPS [6] 110/5 110/6
121/9 121/15 122/8
154/1
crashes [1] 82/14
create [1] 119/15
credit [1] 163/5
Crichton [13] 66/1
66/2 68/18 68/23 71/1
71/13 91/23 92/9
92/13 93/18 129/23
136/4 136/17
Crichton's [1] 90/6
criminal [8] 38/1 38/1
40/5 44/4 44/6 44/12
62/11 83/17
criteria [1] 78/15
critical [2] 8/4 122/17)

(47) committee... - critical
Cc

critically [2] 11/17
11/17

cross [1] 147/17
cross-system [1]
147/17

Crown [1] 63/1
crucial [1] 160/4
crystallise [1] 67/20
Culture [1] 3/17
cured [1] 153/15
curiosity [1] 39/8
current [11] 31/7
34/2 49/4 78/8 105/2
113/19 158/15 158/16
158/18 159/4 159/18
currently [4] 3/16
36/7 79/9 123/18
customers [1] 108/2
cut [1] 62/1

D

damages [1] 22/12
damaging [1] 105/1
damn [1] 149/16
dark [3] 123/2 126/14)
130/10
Darlington [1] 142/22)
data [5] 112/2 112/19
154/5 154/6 159/2
date [2] 160/4 160/7
dated [1] 1/13
dates [1] 123/10
Davey [2] 31/14
42/13
David [1] 142/4
day [40] 6/23 8/21
8/21 9/6 9/6 17/14
18/6 18/6 42/19 47/1
47/3 47/5 56/14 58/3
58/11 58/20 59/7
59/24 61/20 63/7 66/5
66/13 68/15 69/1
71/11 71/11 79/4
79/17 79/21 91/5 96/4
101/10 103/25 126/24}
127/15 138/1 138/17
144/13 144/14 154/15
days [8] 22/23 79/1
96/10 101/20 101/21
101/22 112/23 162/11
deal [1] 135/8
dealing [2] 101/3
102/14
deals [1] 79/10
Dear [1] 84/9
debate [5] 26/15
103/8 111/3 121/10
128/17
debated [1] 29/11
debt [1] 16/14
decade [1] 118/21
decarbonise [1] 7/21

December [1] 13/24
December 2019 [1]
13/24
decided [6] 4/22 25/8
50/6 98/10 106/8
161/14
decision [6] 25/3
99/14 106/8 109/3
109/6 109/14
decode [1] 128/12
deep [1] 27/10
defects [7] 20/9
22/10 22/11 117/21
117/22 142/19 142/20)
defendants [1] 95/10
defended [1] 30/23
defined [1] 74/9
definitely [1] 66/10
delegations [1] 74/10)
delete [1] 2/23
deliberately [2] 15/7
123/2
Deloitte [3] 118/9
119/3 153/22
demanding [3] 42/22
42/24 42/25
demonstrate [1]
162/6
demoted [1] 103/17
denied [1] 20/4
department [24] 3/17
5/18 5/19 6/15 7/1
7/11 7/16 14/24 17/1
17/2 17/7 17/8 17/13
26/10 31/23 42/20
43/1 50/3 50/4 68/11
104/2 120/13 125/1
148/14
Depending [1] 48/17
deprived [1] 122/18
describe [2] 20/6
122/16
described [17] 8/18
8/23 10/9 13/15 19/15)
27/15 36/1 36/17
42/21 52/19 65/5
73/19 98/24 105/17
119/2 129/19 157/7
describes [2] 14/1
38/14
description [2] 8/23
142/11
deserve [1] 161/14
deserves [1] 163/4
design [2] 14/15
14/18
designate [1] 113/14
designed [3] 15/7
16/6 147/11
desire [2] 85/25
128/19
desks [1] 6/24
despite [1] 68/3
destroyed [1] 62/10

detached [1] 15/23
detail [9] 16/24 40/2
42/17 45/4 70/4 70/12
88/8 150/7 150/9
detailed [6] 38/6 51/2
74/23 84/10 147/20
155/3

detailing [1] 55/25
details [3] 31/1 94/6
151/12
determination [1]
57/1

determine [1] 80/3
determined [1] 59/12
developing [1] 82/3
development [1]

31/4

developments [2]
82/1 87/7

DG [4] 17/11
dialogue [2] 11/1
33/7

diary [4] 109/11
Dickinson [4] 95/1
95/2 95/25 116/15
did [73] 5/7 8/12 9/10
10/5 12/21 14/25
16/25 17/20 18/8
18/10 26/21 29/12
33/25 37/12 37/17
42/12 43/18 46/10
47/16 51/22 52/18
55/2 57/5 60/1 65/15
66/1 66/6 71/22 73/20
74/3 75/1 75/14 75/17
76/5 76/24 80/20 92/9
92/11 93/13 93/18
97/14 101/9 103/3
107/4 107/6 112/8
120/17 120/22 121/13
124/25 125/11 125/13
128/2 130/1 131/17
134/22 134/25 135/1
136/8 136/11 137/23
138/25 144/24 151/5
151/7 151/15 152/2
152/5 152/18 153/1
153/2 153/5 153/13
didn't [52] 8/25 9/4
11/13 11/20 11/20
16/20 18/19 18/24

38/25 39/3 40/17
40/19 41/1 41/13
51/15 52/24 64/14
65/4 68/5 68/15 68/21
70/4 92/15 93/2 93/4
96/22 103/5 107/17
112/19 123/1 124/16
125/2 125/6 126/8
131/16 131/21 131/21
133/8 136/17 149/24

19/9 23/14 24/8 25/16} 20/18 20/23 21/22
26/20 32/17 33/23 24/24 29/17 46/9
34/4 38/19 38/23 66/12 67/7 75/11

153/12 154/6
difference [4] 110/18
116/16 121/12 121/23}
different [25] 4/17
6/14 7/17 14/24 30/2
34/19 42/11 63/6 68/1
71/25 78/15 93/14
110/10 110/15 1141/5
111/22 114/3 120/3
120/5 120/11 120/24
122/6 130/21 146/20
153/19

differently [1] 39/13
difficult [21] 10/19
19/18 29/1 34/1 50/7
55/5 58/19 67/14
69/15 75/13 97/12
101/4 102/5 103/1
109/16 119/12 124/11
138/5 138/15 138/18
161/2
difficulties [1] 148/1
digest [1] 162/13
digital [1] 147/12
ence [1] 67/10
ent [4] 76/17
89/20 90/3 136/25
Dinenage [1] 149/25
direct [1] 70/19
directed [1] 66/18
direction [1] 132/10
directly [3] 18/5 89/7
92/1

director [57] 2/17
2/18 2/18 4/2 4/15
4/20 4/24 5/11 5/15
5/16 7/19 8/17 8/21
9/1 9/15 10/13 11/9
11/23 12/16 12/17
12/21 14/3 15/20 16/1
16/12 17/3 17/4 17/22}
18/1 19/8 24/9 24/10
24/11 24/14 24/18
26/6 28/4 43/1 43/21
50/8 67/5 68/6 69/14
72/13 75/25 88/9
92/22 93/11 100/1
100/15 106/24 113/14)
119/24 120/18 120/20
126/4 145/6
directors [25] 11/18

78/12 87/11 88/7
88/21 89/3 89/21
90/15 91/16 91/24
94/21 96/15 97/9
111/2 117/4 124/11
Directors’ [2] 84/2
88/20
disaggregate [1]
71/24

disappear [1] 155/1

discard [1] 111/19
disciplinary [1] 146/6I
disclose [3] 94/17
95/13 124/2
disclosed [6] 7/3
10/21 83/20 111/10
156/22 158/8
disclosure [7] 27/8
82/5 82/11 90/5 95/10
123/19 130/7
discomfort [1] 74/14
discontent [4] 27/3
66/16 67/3 153/6
discount [1] 108/2
discovered [1] 94/19
discrepancies [3]
19/21 19/23 19/24
discuss [11] 8/12
12/9 26/21 30/13
37/16 44/18 45/5
91/15 93/25 98/1
127/16
discussed [38] 1/21
7/22 8/15 15/19 23/5
25/8 25/21 27/24
32/15 35/19 35/25
58/10 69/20 71/12
71/25 72/10 78/8
96/13 99/23 100/22
102/17 102/22 104/11
104/12 106/5 106/5
106/11 108/12 112/21
112/22 115/3 115/23
119/11 120/25 135/2
138/13 144/1 144/11
discussing [4] 47/21
65/7 100/25 113/2
discussion [50]
22/20 22/21 23/10
28/25 29/10 34/16
38/8 38/9 39/19 44/22
45/2 45/7 45/22 45/24)
46/3 50/24 69/23 83/7
91/11 92/7 93/18
99/17 100/12 100/17
101/7 101/16 104/8
106/3 106/7 106/9
110/12 112/12 114/22)
115/17 115/20 121/14I
127/2 133/5 133/25
134/5 134/8 135/15
137/12 138/4 138/15
143/21 143/24 144/5
144/17 152/3
discussions [11]
36/9 63/24 67/17 82/6
107/21 107/23 121/13}
124/6 136/23 137/24
151/6
dismissed [1] 110/3
displayed [2] 157/8
157/14
displaying [1] 157/10
distant [1] 102/24

(48) critically - distant
D

do [89] 2/14 7/12
7/21 9/3 9/4 11/16
12/19 23/19 27/20
28/25 29/4 33/18
34/15 34/19 36/9 38/8
38/21 38/23 39/7
40/10 42/5 43/5 50/8
51/4 59/2 59/13 59/19)
60/15 60/22 63/21
63/24 64/11 66/14
68/12 68/24 70/15
72/7 72/15 72/23 74/7
74/20 74/22 75/4
75/19 76/12 77/3
78/21 81/18 83/3 83/5
85/3 85/13 92/25 96/5)
98/12 102/2 105/10
107/14 110/4 111/2
113/23 116/3 116/21
116/23 117/5 121/18
123/4 123/22 124/6
124/10 125/23 125/25
127/8 127/22 128/15
129/3 129/17 131/19
131/23 132/9 140/23
142/17 156/15 156/16
159/24 159/25 160/23}
161/20 162/1
document [36] 11/25
12/1 12/24 13/13
13/17 14/11 16/4
23/20 32/19 50/1
51/15 51/24 55/13
56/21 58/5 60/16
60/25 62/14 63/9
74/24 83/4 83/6 84/19
91/25 128/1 141/7
141/9 143/8 143/13
145/21 145/22 146/19)
148/6 148/12 148/13
157/11
documentary [1]
156/13
documents [17] 7/3
10/21 25/6 25/18 29/2)
39/23 41/4 42/12
54/23 62/10 108/11
124/16 130/7 132/1
158/9 158/10 162/20
does [18] 21/10
50/17 54/17 59/10
59/23 81/3 81/11
81/16 89/1 89/4 95/19)
115/19 126/13 128/12)
131/2 139/13 144/6
154/23
doesn't [8] 45/5
100/3 111/18 137/2
137/13 147/18 148/11
153/25
doing [15] 7/25 8/4
10/18 11/21 12/19

32/2 38/21 38/25
42/25 52/21 74/1

101/12 101/23 105/18)

112/25

domain [2] 127/16
128/1

don't [91] 2/1 6/11
6/16 8/5 12/25 13/2
13/6 15/6 22/21 23/4

25/7 27/17 27/19 30/5

34/20 36/11 36/19
37/14 38/9 45/6 45/7
46/20 47/15 48/25
55/17 59/15 59/22
60/18 63/2 63/7 63/8
63/22 65/5 65/15
67/18 68/24 69/4
69/12 69/16 71/10
73/11 73/24 74/5
74/11 79/10 79/16
81/4 81/12 82/12
85/17 86/5 90/1 90/8
90/17 90/20 91/12
92/11 92/15 92/18
93/2 93/4 95/17 96/4
97/16 97/16 100/8
107/2 112/22 114/3
117/4 120/10 120/16
121/19 126/1 128/14
130/4 130/8 132/4
132/7 133/5 136/1
136/20 137/5 137/11
138/21 139/3 139/4
144/3 145/1 150/18
161/11
done [18] 8/3 39/13
42/11 43/22 57/8
69/15 72/16 74/25
76/1 76/3 76/10 77/4
87/9 87/10 93/14
132/19 162/11 162/18)
Donnelly [1] 26/9
door [1] 11/16
dots [1] 40/11
double [1] 74/11
double-check [1]
74/11
doubt [4] 130/20
down [51] 2/15 2/16
19/14 19/15 20/25
21/4 23/7 24/9 24/12
31/2 47/6 49/4 49/5
54/6 56/18 56/23
58/24 61/14 73/15
74/19 79/4 79/6 83/12
87/1 88/19 88/24 92/2
93/17 94/10 97/19
97/20 97/23 99/4 99/6)
100/7 104/6 107/5
108/5 110/22 113/12
113/18 114/11 114/15)
114/24 123/14 130/16)
132/23 139/22 141/14)
154/12 158/2

Dr [2] 94/16 95/12
Dr Gareth [2] 94/16
95/12

draft [7] 51/15 55/22
56/15 56/20 57/25
59/23 63/9

drafting [2] 18/8
52/13

draw [4] 39/22 51/4
57/21 155/15
drawing [3] 20/12
40/11 138/8

draws [1] 134/2
drew [2] 32/11 92/19
driving [1] 82/14
dropped [2] 81/18
147/16

dual [1] 8/18

due [4] 3/15 18/23
128/21 156/23
during [12] 5/14 5/24
6/4 6/7 6/13 7/9 65/6
67/16 99/16 100/16
120/2 156/8

duties [2] 84/3 88/20
duty [2] 83/18 91/19

E

each [12] 22/9 22/11
76/2 78/16 82/7 105/7
118/25 134/2 142/18
144/10 144/11 146/16
earlier [12] 14/22
24/3 24/17 32/15 38/4
70/5 73/22 86/23
95/21 115/23 148/21
153/21
early [5] 50/6 70/14
96/12 98/15 101/15
earth [2] 152/3 154/8
easier [1] 137/17
easiest [1] 89/6
easily [1] 110/24
easy [3] 28/1 75/20
107/2
ed [3] 19/20 31/14
42/13
edges [1] 105/19
Edwards [6] 47/7
47/9 47/23 84/21
87/18 87/21
effect [4] 20/21
133/12 135/10 138/20
effective [1] 19/19
effectively [1] 59/4
effectiveness [1]
158/21
efforts [1] 129/17
egregious [1] 108/9
eight [1] 157/12
either [12] 9/10 11/10}
28/6 32/4 33/20 36/10
45/8 47/9 62/8 79/18
112/3 159/9

electrical [1] 147/17
elements [1] 153/5
else [4] 23/23 27/19
93/19 132/24
else's [1] 25/4
email [62] 7/4 47/6
47/23 50/20 52/24
53/13 55/3 55/14
55/19 55/21 56/11
56/12 56/14 56/19
56/22 57/8 57/11
57/24 58/5 58/6 58/24
60/17 63/12 63/13
63/13 77/20 78/21
78/22 79/5 79/12
79/15 80/17 84/4
84/14 84/24 85/4
87/21 89/8 91/22 92/2
92/3 92/7 92/11 92/25
94/4 94/10 96/4
108/16 108/19 109/8
112/9 113/25 123/5
123/8 123/14 126/20
127/11 130/15 130/16}
130/22 131/16 132/23}
emailed [1] 53/16
emailing [2] 47/8
47/24
emails [16] 37/17
56/4 58/22 68/4 68/5
73/14 84/6 85/4 86/3
86/11 86/17 86/19
92/13 93/15 93/24
95/21
emerged [2] 49/8
54/16
emotional [1] 52/15
emphasising [1]
53/23
employer [1] 101/23
enable [4] 6/2 38/22
74/22 80/4
encapsulates [1]
123/24
encouraging [1]
159/15
end [14] 6/18 6/21
25/16 85/23 85/25
107/8 109/23 130/5
136/18 144/14 145/21
154/21 155/11 159/15)
ended [5] 6/14 26/16
58/12 64/5 107/8
endemic [2] 12/10
30/14
energy [8] 5/18 6/15
7/11 7/16 17/13 42/20
58/6 98/11
engage [2] 78/18
80/3
engaging [1] 35/3
engine [1] 67/7
England [2] 121/17
154/3

enhancing [1] 115/10)
enjoy [1] 162/15
enormous [1] 162/23
enough [1] 160/11
enquire [1] 153/12
ensure [7] 25/15 33/9I
43/13 70/6 72/21
76/17 78/17
enter [1] 159/17
entirely [2] 5/19 7/17
entirety [1] 156/11
entities [1] 4/17
entry [2] 23/22 49/6
enunciated [1]
123/25
environment [4]
21/20 30/4 76/19
120/25
envisaged [1] 6/17
error [1] 62/2
errors [3] 117/23
147/16 147/16
escape [1] 163/8
essence [1] 15/5
essentially [2] 83/10
142/3
established [1] 80/14
et [6] 18/24 46/1
76/12 88/16 91/20
94/22
et cetera [6] 18/24
46/1 76/12 88/16
91/20 94/22
etc [3] 82/15 82/15
131/16
eternally [1] 162/24
even [18] 26/23 27/5
29/5 41/3 41/23 49/1
60/7 68/22 74/25
82/12 86/15 86/18
117/2 124/17 133/19
135/6 150/2 162/8
evening [1] 128/25
event [5] 89/5 89/11
94/19 118/1 129/23
events [8] 13/22 30/2
65/16 66/17 68/20
82/21 115/12 130/18
eventuality [1] 79/25
ever [7] 8/3 41/5
46/10 147/1 151/15
152/2 152/5
every [12] 39/18 59/7
61/20 61/20 78/16
101/6 101/22 134/13
149/15 156/2 162/24
163/4
everybody [3] 65/8
67/23 111/11
everybody's [1]
98/10
everyday [1] 162/21
everyone [3] 1/3 1/25)
159/15

(49) do - everyone
E
everything [6] 40/25
51/16 64/24 135/12
135/13 137/11
evidence [41] 31/8
32/12 32/16 50/25
51/4 51/19 52/6 52/16
54/16 61/3 61/15
68/19 86/8 95/11 97/4
125/1 129/6 133/14
154/23 155/13 155/16
155/23 155/25 156/5
156/5 156/7 156/10
156/11 156/13 156/18)
156/20 156/21 157/2
157/19 157/25 158/4
158/6 158/14 158/18
159/18 161/21
evidence-based [1]
52/16
evolved [1] 120/5
ex [1] 31/6
ex-subpostmaster
[1] 31/6
exactly [18] 6/17
24/23 25/7 25/14
26/21 27/18 33/20
36/11 38/20 59/23
87/19 100/23 111/7
123/3 124/19 131/22
133/6 135/4
examine [1] 161/11
example [26] 8/10
12/23 16/8 28/2 36/24
37/12 39/9 40/3 41/6
45/21 45/25 46/12
48/23 50/2 50/13
51/18 51/21 89/12
90/10 120/13 124/24
125/4 134/15 137/17
149/6 152/6
examples [1] 137/15
exceptionally [2]
98/24 99/2
exceptions [4] 48/21
48/24 49/11 62/1
excess [1] 78/15
exchange [3] 54/15
88/23 127/11
exchanged [1] 92/13
ExCo [1] 70/2
execs [1] 145/9
execs' [1] 131/9
executive [107] 4/8
4/15 4/16 5/10 5/15
5/15 6/13 8/10 8/11
8/17 8/20 9/1 9/15
10/13 11/9 11/19
11/23 12/16 12/17
13/19 14/2 15/20 16/1
16/11 17/22 19/4 19/8)
20/18 20/23 20/24
21/22 21/23 24/10

24/11 24/14 24/18
26/6 29/14 29/16
29/17 29/19 35/1
40/15 41/13 41/18
43/20 46/9 50/8 52/7
64/18 66/12 66/19
66/22 67/4 67/5 67/6
67/7 67/19 67/24 68/3
68/6 69/14 69/21
72/12 74/6 74/21
75/11 75/14 75/25
87/11 89/21 90/15
91/23 92/22 93/11
96/15 97/9 98/3 98/19)
98/22 100/2 100/15
101/14 102/13 106/25)
111/1 113/14 113/15
116/10 117/3 117/3
117/15 119/24 120/2
120/17 120/20 122/19)
123/2 124/11 126/4
127/17 128/2 132/12
145/6 149/7 153/6
153/17
Executive's [2] 99/21
100/20
executives [6] 14/14
26/13 66/15 99/7
150/7 158/19
exercise [1] 13/14
exercising [1] 8/19
exist [2] 54/18
117/25
existed [1] 15/4
existing [1] 80/8
exists [1] 94/20
expanded [3] 88/4
134/14 141/13
expansion [1] 105/3
expect [8] 42/12 74/7
74/8 96/7 97/12 117/5)
161/12 162/10
expectation [1] 6/12
expected [9] 7/15
29/22 51/4 53/9 82/5
97/5 137/4 144/7
146/13
expecting [1] 121/23
experience [13] 5/5
5/7 15/22 38/21 67/24
82/2 90/19 97/11
116/24 136/22 137/25)
138/2 144/15
experienced [1]
137/12
expert [5] 94/16
95/11 97/3 122/23
125/16
expertise [1] 115/11
experts [1] 81/1
explain [1] 140/15
explained [4] 68/19
115/5 143/22 146/6
explaining [2] 11/22

104/13

explains [1] 20/8
explanation [2] 40/12
153/14

explore [1] 111/20
exposure [2] 88/7
94/23

expressed [8] 27/3
66/16 66/24 71/4
112/9 113/25 114/3
153/6

expressing [2] 45/3
140/21

expression [1]
138/12

extended [1] 31/14
extent [9] 11/6 19/24
33/12 86/6 94/23
112/1 117/20 133/18
155/16

external [3] 54/19
61/22 152/16
extremely [5] 19/18
75/11 85/10 105/23
149/9

F

face [4] 53/11 82/9
82/9 161/3

facilitate [2] 28/19
111/3

facilitating [1] 163/6
facing [2] 54/5
153/24

fact [23] 8/8 11/3
15/10 15/25 16/6 26/1
32/14 33/8 39/9 40/4
66/8 69/25 89/18
92/19 118/6 124/2
133/12 136/4 136/11
143/4 146/4 155/17
161/9

factor [1] 121/17
factors [2] 102/19
119/15

facts [3] 13/18 48/4
80/14

factual [4] 57/15
117/20 127/14 127/21
factually [2] 56/1
128/2

faded [2] 141/9 142/7
failed [3] 53/25 94/17
95/13

failings [1] 51/5

failures [1] 57/16

fair [8] 21/12 33/25
42/22 62/17 82/22
95/19 160/18 162/14

fairly [3] 21/17 21/24
36/21

Falcon [1] 154/4

fall [1] 157/6

false [7] 12/13 30/19

136/20 142/25 147/3
147/4 147/7
familiar [7] 48/25
139/21 141/21 142/22}
148/6 148/12 149/2
fan [1] 131/10
fanning [2] 131/11
131/15
far [8] 2/9 9/23 50/1
146/22 146/25 158/3
159/8 161/13
fast [1] 65/17
fault [2] 61/4 146/8
faults [4] 61/15
147/14 147/16 147/17I
favour [1] 113/23
feature [1] 57/5
February [10] 103/4
106/9 107/23 108/6
108/13 108/18 109/1
109/8 113/6 113/10
feel [15] 33/23 42/8
42/9 61/12 68/5 74/2
74/16 74/25 75/12
76/24 93/13 107/4
123/1 151/16 151/23
feeling [5] 73/19
75/23 76/1 102/3
121/21
feels [1] 95/23
fell [1] 107/19
felt [27] 11/20 25/22
40/20 40/21 46/16
57/12 67/11 67/14
68/1 68/13 70/12 76/7
90/7 93/10 101/3
101/24 102/24 107/6
109/16 112/18 118/23
119/1 119/16 119/21
131/10 138/6 153/7
few [20] 2/10 13/14
41/11 46/5 50/19
60/24 69/18 94/5
96/10 98/7 104/4
108/11 112/23 120/3
123/5 123/8 136/1
136/20 140/5 140/19
fewer [1] 109/11
fifth [1] 22/15
figures [1] 36/8
file [2] 22/24 141/19
fill [1] 43/18
final [15] 1/15 3/7
44/8 52/8 54/10 55/22
56/23 56/23 57/25
63/10 72/17 114/9
119/22 129/14 158/14
Finally [2] 84/16 87/5
Finance [1] 43/21
financial [4] 9/20
54/12 78/2 110/9
find [9] 75/3 84/10
94/6 106/20 110/6
111/24 118/25 137/23

161/2
finding [1] 51/11
findings [7] 49/8 52/3
54/14 57/2 61/12 62/4I
72/22
finds [1] 42/23
fine [5] 2/2 16/24
103/13 141/3 155/9
finish [2] 73/9 150/14
finished [3] 129/1
129/1 129/12
finishing [2] 42/23
147/14
firm [2] 146/3 159/2
first [41] 2/11 2/22
4/8 11/25 14/2 20/15
20/15 20/16 21/15
21/16 22/2 28/9 35/9
38/3 39/16 44/10 45/4
45/11 55/16 57/7
58/22 73/17 74/10
77/25 79/25 85/8
88/24 91/14 96/10
98/7 100/9 111/14
112/14 133/4 135/10
143/14 143/16 148/2
157/18 160/21 161/16
firstly [5] 79/23 80/23}
148/8 155/15 155/23
Fiscal [2] 122/7
154/2
five [3] 22/8 22/13
143/4
fixed [2] 31/5 128/19
flag [2] 28/5 152/18
flagged [2] 152/14
152/20
flagging [1] 106/23
flames [3] 131/10
131/11 131/15
flaws [2] 12/10 30/15
flow [2] 65/13 65/15
flowed [1] 97/1
focus [7] 9/20 69/4
88/20 112/5 130/24
134/20 158/15
focused [8] 31/10
49/1 54/14 60/19
69/25 86/22 89/9
90/22
focusing [4] 53/3
90/8 90/21 108/8
Folkes [2] 157/13
157/17
follow [7] 22/24 46/9
77/2 81/24 93/2
105/19 115/24
follow-on [2] 77/2
81/24
follow-up [2] 105/19
115/24
followed [1] 93/1
following [13] 31/13
35/11 51/16 76/21

(

50) everything - following
F

91/23 93/23 108/25
109/15 134/2 141/23
158/25 159/24
follows [6] 14/1 18/4
20/1 30/11 50/23
85/21
foot [1] 11/16
football [1] 158/12
forensic [5] 28/22
29/20 34/13 38/10
52/1
forgive [3] 44/17
148/24 152/23
form [3] 88/3 88/4
143/23
formal [5] 33/15
33/15 33/21 36/23
134/23
formally [1] 33/18
former [2] 22/8
158/18
formerly [1] 31/24
forth [1] 42/14
forward [12] 2/5
26/22 46/19 53/21
55/13 71/7 72/11 80/6
83/8 83/10 115/25
126/25
forwarding [1] 80/18
found [14] 10/19
19/17 22/1 50/25 61/3
83/1 84/5 89/19
102/25 103/22 116/21
117/12 129/6 137/23
four [4] 22/13 44/6
51/3 157/24
fourth [2] 142/12
157/18
frame [2] 85/10
132/22
frankly [1] 137/2
fraud [2] 35/10 147/5
fraudulently [1]
44/15
free [1] 69/23
Friday [1] 109/8
fro [9] 64/1 64/8
64/16 64/22 86/19
89/24 134/20 135/17
137/3
front [4] 1/12 41/1
43/10 90/25
frontline [1] 40/22
frustrated [1] 67/11
frustrating [1] 137/7
Fujitsu [4] 94/17
95/12 123/20 125/15
full [11] 1/9 42/19
69/14 106/10 109/4
140/11 140/12 140/22)
159/18 160/5 160/18

following... [9] 76/22

fuller [1] 80/13
fully [5] 38/19 61/2
78/18 87/6 123/25
fulsome [1] 25/6
function [2] 8/19
59/4

functions [2] 8/19
62/25
fundamentally [1]
74/3
funding [11] 15/14
16/8 16/13 16/16
25/12 26/25 28/1
45/23 97/22 97/24
102/7
further [23] 2/4 5/1
22/17 28/23 31/4
35/13 49/5 52/24
53/16 53/18 54/7
54/21 79/6 82/8 83/7
83/25 84/2 88/6 95/10
111/20 142/14 156/21
158/6
future [9] 46/17
69/21 80/10 80/24
87/7 104/11 106/5
106/7 108/22

G

Gareth [8] 94/16
95/12 95/15 95/17
116/15 122/22 126/12)
126/15
gather [1] 159/4
Gatwick [1] 34/18
gave [4] 52/12 64/4
71/12 136/16
general [13] 13/11
17/5 43/16 69/5 71/1
75/6 75/16 96/25
100/1 104/13 106/25
117/1 124/10
generally [5] 6/11
38/21 76/15 101/5
101/24
generous [1] 127/1
George [2] 125/3
150/1
get [32] 10/17 10/19
11/16 11/24 42/15
44/25 56/6 57/21
65/19 70/11 72/15
80/20 87/8 112/1
118/13 121/25 123/6
132/19 135/7 135/25
141/5 141/6 150/12
150/15 151/5 152/2
152/6 153/8 153/22
160/4 160/23 162/2
gets [1] 133/4
getting [25] 6/14 7/9
7/13 8/6 8/13 14/21
20/22 38/6 42/16

functioning [1] 119/7)

87/9 91/3 102/24
108/2 113/3 126/17
126/19 131/5 131/18
135/20 145/7 152/14
Gibson [11] 17/25
27/4 32/4 35/23 36/9
36/24 47/20 58/14
97/25 98/18 113/4
give [13] 1/9 5/21
22/22 28/22 48/3
70/14 81/11 101/25
124/10 137/3 137/17
157/18 157/25

given [17] 25/9 32/12
44/11 49/8 66/13
72/22 75/1 75/2 76/11
96/23 97/3 111/15
125/18 125/20 126/11
149/5 153/14

ives [1] 88/12
giving [6] 36/21
41/15 58/12 91/9
96/12 121/1

glancing [1] 44/12
go [33] 6/10 6/11
34/19 39/17 43/9
55/14 56/11 69/18
70/10 79/13 83/23
91/8 94/25 99/4
103/18 104/10 104/15}
127/16 128/1 140/2
140/6 141/8 142/16
143/11 143/18 145/13
145/21 145/23 146/15}
146/20 150/18 150/25}
162/15

goes [7] 20/6 20/10
44/7 82/24 124/12
147/11 147/18

going [67] 1/5 6/11
11/24 13/14 16/10
19/10 26/22 33/11
33/24 37/3 42/14
50/18 52/2 53/10 54/9
56/21 58/14 60/22
60/23 60/24 61/6
63/21 71/7 74/4 79/12
80/6 81/2 81/12 82/21
82/22 84/4 85/2 86/22
89/20 96/19 102/11
102/16 103/21 108/11
109/6 116/21 119/22
126/21 127/16 130/9
132/17 140/2 142/6
144/10 145/10 145/11
146/1 146/4 146/20
147/22 149/2 152/5
152/9 153/24 154/8
155/7 156/15 157/9
157/20 158/24 162/2
163/7

gone [3] 17/3 82/8
147/1

58/11 63/19 64/8 82/4

good [16] 2/7 28/1
45/12 70/1 72/7 92/5
92/16 93/7 103/18
111/3 127/5 128/10
138/4 138/7 145/24
147/12

goodness [2] 162/16
162/20

got [21] 21/14 44/6

81/17 108/2 112/23
135/1 139/8 142/11
143/4 144/20 146/2
147/20 148/1 148/4
154/7 157/13 162/22
governance [3] 8/20
46/7 74/7
government [32]
4/17 4/21 5/24 8/22
9/7 9/9 10/7 10/15
13/20 15/22 16/13
26/18 33/19 42/5 43/7,
43/12 65/1 65/3 97/22)
98/10 99/22 102/25
105/3 105/10 105/12
105/21 105/22 109/19)
109/22 156/1 158/17
158/20
Government's [3]
33/11 43/15 100/16
government-owned
[1] 4/17
grapple [1] 118/5
grateful [5] 111/1
139/13 140/7 141/13
162/24
grave [1] 159/23
great [2] 128/6
142/10
greater [2] 86/6
155/4
grounds [1] 20/5
groundswell [2] 67/2
133/22
group [12] 4/12
11/12 49/19 72/21
73/7 84/7 94/2 96/15
99/10 104/9 139/19
152/14
grow [1] 36/8
growing [2] 102/3
133/22
guess [4] 25/9 25/25
29/7 41/14
guilty [2] 44/14 147/4

H

had [164] 5/24 6/9
8/3 8/15 9/3 11/11
11/13 11/14 11/44
12/23 12/25 13/11
14/11 16/13 17/8
17/14 17/15 18/16
19/18 20/5 20/23 24/3

50/1 72/14 74/10 79/9)

25/20 25/20 26/5
26/15 28/18 28/19
28/20 28/21 29/19
31/17 32/9 32/12
32/24 33/7 36/13
38/10 38/18 39/2
39/17 41/18 42/4
42/10 42/19 43/12
43/20 47/19 49/1
49/19 49/19 49/25
51/25 52/1 52/17
52/23 53/18 54/7
54/15 55/4 55/4 55/6
57/15 60/6 60/21 63/6I
65/9 66/13 66/17
66/19 67/13 67/14
70/8 71/5 71/19 72/1
72/4 73/7 73/23 74/14I
74/21 76/3 76/15
76/25 77/17 78/24
85/6 90/6 90/19 90/19
90/19 90/25 92/13
93/13 97/3 98/15 99/3
102/3 102/16 103/1
106/6 107/1 107/23
108/1 108/2 108/22
108/23 109/3 109/11
109/21 111/8 111/9
111/19 112/15 112/16)
112/21 114/2 114/19
115/25 116/9 116/10
116/14 118/22 119/9
119/11 121/4 121/10
122/7 122/22 124/2
125/17 125/18 126/5
128/3 129/1 129/23
130/20 131/10 132/17)
133/11 133/13 133/20}
133/21 134/16 135/6
136/5 137/25 138/15
140/11 140/12 142/4
144/18 145/16 146/6
148/9 149/4 149/7
149/23 152/13 153/14)
153/19 158/5 159/23
160/3
hadn't [15] 5/8 11/8
34/5 47/19 49/25
51/14 51/23 52/3 68/2
68/13 72/3 93/6 106/7I
112/11 119/19
half [4] 102/9 125/23
126/8 161/17
halfway [8] 2/15
19/15 21/4 50/22 52/9)
56/23 58/24 94/10
hand [7] 7/1 80/8
119/12 119/13 141/16)
157/11 157/14
hand' [1] 128/9
handed [3] 127/6
128/11 128/22
handing [1] 62/25
handled [3] 68/2

(61) following... - handled
H

82/9

handling [3] 48/4
53/4 86/24

hands [1] 56/6

hang [3] 144/23
153/2 154/7

happen [5] 18/24
33/22 71/15 106/19
133/23

happened [17] 10/24

93/6 102/1 108/3

153/15 160/17
happening [7] 9/18
27/4 33/10 40/22
69/10 72/6 147/19
happy [2] 48/6
127/17

hard [10] 22/23 26/2
44/22 67/22 71/24

132/7 142/7
hardened [2] 124/18
124/19

has [48] 8/17 8/23
19/15 22/7 22/15
44/13 49/8 49/12
54/16 61/9 61/18
62/21 63/17 64/9
65/23 75/22 78/12
79/17 88/15 89/11
95/9 97/19 99/9 104/7,
110/2 110/3 110/20
111/9 112/8 114/4
123/5 123/8 124/18
129/8 146/11 146/25
152/9 157/13 158/3
158/4 158/8 158/24
159/15 160/1 160/3
160/17 162/11 162/19}
hassle [1] 82/16
hassle/cost [1] 82/16
hat [3] 10/11 112/25
120/14

hats [1] 42/9

have [307]
have/should [1]
76/10

haven't [6] 64/14
103/1 127/5 128/11
139/11 154/7

having [34] 5/3 8/18
12/12 15/16 16/11
23/6 25/10 30/17 36/9)
37/8 49/17 54/23
59/13 59/25 63/24
64/18 67/15 73/24
74/15 82/13 92/5
92/16 96/17 96/23

handled... [2] 68/13

18/23 25/14 29/3 32/9)
39/15 76/3 76/8 76/23,

132/20 134/19 149/14)

107/19 111/21 120/10}

103/6 112/22 116/1
128/5 131/19 137/4
141/2 143/17 148/1
157/3

hawkish [1] 81/8
he [56] 9/13 12/5
17/4 17/25 19/17
19/18 19/20 19/21

33/11 36/13 36/14

72/20 79/7 79/15
79/21 81/15 81/18

93/17 100/2 100/4
100/4 100/11 107/9
109/24 113/4 113/6
122/23 124/2 125/14

125/22 125/25 126/5

152/7 160/3 162/20
he's [5] 24/9 24/10
81/15 100/8 130/19
head [4] 32/25 48/18
68/22 82/16

headed’ [1] 54/1
heading [1] 36/18
health [1] 23/3

hear [5] 1/5 1/25 60/8)
133/4 156/5

125/25 127/24 133/16)
155/16 155/23 155/24)
156/4 156/11 158/4
163/1

hearing [6] 125/3
140/23 148/17 148/20)
149/25 163/13
hearings [1] 161/12
heartened [1] 160/3
heat [1] 163/8
heavily [2] 53/3 57/5
heavy [3] 127/6
128/11 128/22
heavy-handed [3]
127/6 128/11 128/22
heck [1] 144/24

held [3] 26/21 26/21
66/21

help [13] 6/2 9/17
25/7 53/25 75/23 76/1
100/3 111/25 143/10
144/2 144/8 160/15
160/22

helped [2] 116/7
116/12

helpful [7] 5/2 22/22
48/1 48/8 116/3
117/12 127/3
helpline [1] 149/16
helplines [2] 59/21
91/1

19/22 19/23 24/3 32/2

36/25 37/8 54/3 72/20

84/14 88/25 90/6 91/6)

125/15 125/18 125/19)

130/19 131/18 131/18)
131/21 131/21 141/25)

heard [12] 60/7 61/15)

her [33] 26/11 26/17
27/18 28/6 34/5 34/5
48/9 68/19 68/20
68/22 68/22 68/24
69/2 93/4 93/8 93/9
110/2 111/9 127/9
127/12 127/22 128/5
128/22 129/1 136/5

138/1 151/16
here [20] 15/8 16/22

92/16 105/9 112/10
131/4 142/3 143/5
144/2 145/8 147/23
162/3

here's [1] 55/21

Hi [2] 80/20 126/25
hidden [1] 125/22
les [1] 163/3

ing [1] 45/3
high [4] 90/1 90/18
105/25 123/23
higher [1] 82/15
highest [1] 155/25
highlighting [1] 45/7
ighly [2] 8/5 88/8
him [11] 24/8 33/3

37/6 113/5 131/20
142/5 163/4

himself [1] 37/11
hindsight [2] 29/1
125/9

his [19] 9/11 12/9
19/14 26/17 30/13
53/20 53/24 57/1 73/1
80/22 81/2 89/21
91/14 98/1 115/14

162/19

Historical [1] 49/6
history [5] 10/14
21/18 133/10 133/16
152/13

HMRC [1] 62/19
hoc [1] 33/5

Hogg [1] 30/21
hold [3] 75/15 139/15
141/14

holder [1] 141/20
holiday [1] 92/18
holidays [1] 162/15
Holmes [2] 21/1
46/15

honestly [1] 132/7
Hooper [1] 99/9
hope [4] 92/5 92/16
129/9 129/25
hopefully [4] 38/13
79/19 123/10 124/10

136/11 136/12 136/17]
136/18 136/20 137/23

18/13 22/5 36/17 42/3
52/23 55/8 60/6 75/21

herself [2] 32/11 35/3

33/5 36/5 36/12 36/13

123/25 142/23 157/18}

hoping [1] 129/4
horizon [56] 12/10
13/21 19/18 20/9
22/11 28/11 28/18
30/15 31/10 35/12
39/25 41/20 46/25
51/1 51/8 54/5 59/3
60/13 61/3 61/18

83/1 84/12 90/13
94/11 94/18 95/14
99/10 102/15 104/7
104/22 104/24 105/5
105/11 117/18 117/21
118/2 129/6 133/14
133/23 140/1 140/11
140/16 141/19 142/20}
144/21 146/8 147/14
147/16 154/5 154/6
156/4 159/5
Horizon/Second [1]
78/4

horrific [1] 133/18
horses’ [1] 80/9
hour [1] 139/9
House [1] 58/12
how [31] 4/14 6/11
6/17 6/18 8/22 17/10
21/21 21/23 23/12
23/16 25/8 25/14 26/2
36/6 43/23 53/24
59/15 60/21 76/7 83/8)
83/10 115/11 117/22
123/3 132/3 137/6
143/17 146/13 147/18
161/13 162/20
however [5] 19/17
51/4 59/10 71/17
150/7

HSS [1] 160/10
huge [2] 43/12
156/12
hugely [2] 5/24 69/14
human [3] 53/24
147/16 162/9

l agree [3] 44/20 45/6)
130/14

l already [1] 106/23
lalso [8] 7/1 45/7
58/4 69/5 80/22 90/20
93/22 111/24

lam [20] 46/12 68/20
82/22 103/21 111/1
111/16 111/16 127/12
130/14 139/8 148/13
159/12 159/24 160/2
160/11 160/13 161/4
162/2 162/24 163/7

I appreciate [3]

110/6 149/18 149/22
larrived [1] 16/15
lask [1] 1/15

61/23 70/21 78/4 78/8)

lassist [1] 18/10
I became [1] 12/21
I been [1] 18/17
Ican [6] 44/1 85/16
142/9 154/12 162/13
163/3
I can't [30] 25/14
29/10 32/13 44/21
58/3 58/8 58/18 60/4
64/1 66/25 72/25
73/11 73/12 96/9
96/22 100/13 100/13
114/1 114/6 114/14
121/20 121/20 125/9
127/11 127/21 128/23)
131/22 137/15 152/11
160/22
I caught [1] 128/25
I certainly [5] 32/22
42/9 65/9 113/2 113/5)
I come [1] 75/7
I concluded [1]
101/11
I could [4] 9/17 19/5
25/6 101/24
I couldn't [1] 66/9
I covered [1] 25/5
I decided [1] 50/6
I described [1] 27/15
I did [13] 12/21 14/25
18/8 26/21 42/12
65/15 75/17 92/11
93/13 103/3 107/4
125/11 131/17
I didn't [24] 8/25
11/20 16/20 18/19
23/14 26/20 33/23
34/4 38/19 38/23
38/25 39/3 64/14 65/4I
92/15 93/2 93/4 103/5I
107/17 112/19 124/16)
131/16 131/21 131/21
Ido [19] 2/14 27/20
29/4 59/19 66/14
74/20 77/3 83/5 85/3
110/4 116/23 121/18
124/10 125/25 131/19)
140/23 159/24 159/25}
162/1
I don't [73] 2/1 6/16
8/5 12/25 13/2 13/6
15/6 22/21 23/4 27/17)
27/19 30/5 34/20
36/11 36/19 37/14
38/9 45/6 46/20 47/15]
48/25 55/17 59/15
59/22 60/18 63/7 63/8
65/5 65/15 67/18
68/24 69/4 69/12
69/16 71/10 73/24
74/5 74/11 79/16
81/12 85/17 86/5 90/1
90/8 91/12 92/11
92/15 92/18 93/2 93/4

(52) handled... - I don't
I don't... [23] 95/17
97/16 97/16 100/8
107/2 112/22 120/10
120/16 121/19 126/1
128/14 130/4 130/8
132/7 133/5 136/1
136/20 137/5 138/21
139/3 139/4 145/1
161/11

I drew [4] 92/19
lended [1] 6/14
lexpect [1] 161/12

l explain [1] 140/15
I felt [9] 11/20 40/21
68/1 68/13 93/10
101/24 102/24 107/6
112/18

I found [3] 89/19
102/25 117/12

I get [3] 44/25 121/25
160/4

I give [1] 5/21

I guess [4] 25/9
25/25 29/7 41/14

I had [19] 6/9 8/3
8/15 9/3 12/23 14/11
17/14 38/18 65/9 85/6)
90/25 93/13 98/15
102/3 107/1 116/14
145/16 148/9 149/4

I hadn't [4] 5/8 34/5
47/19 112/11

Ihave [22] 7/14
32/20 50/5 53/18
68/10 72/25 74/23
76/24 84/19 87/6
101/9 101/19 102/20
121/7 121/9 130/5
141/24 143/22 145/14)
160/11 161/13 161/22
I haven't [2] 64/14
103/1

I heard [1] 125/25
Iheld [1] 66/21

I hope [2] 129/9
129/25

limagine [1] 65/17

I joined [2] 8/12
120/2

I just [10] 6/16 23/20
55/9 56/13 63/22
74/14 75/6 121/20
139/23 150/5

I knew [4] 26/14
26/14 43/15 51/13

I know [8] 24/2 50/1
63/2 64/2 93/3 135/16)
142/7 152/12

I left [5] 99/19 102/21
121/5 132/2 134/21

Hook [1] 29/4

I may [1] 137/21

I mean [29] 7/24 8/1
21/11 23/14 37/1 38/9
41/22 45/6 49/15
64/14 69/12 76/4
76/15 85/16 86/2
86/15 97/7 101/1
105/15 105/23 106/3
106/10 112/10 124/21
134/9 135/16 137/15
138/13 144/9

I mention [1] 41/22

I mentioned [1] 98/8
I might [3] 58/7 69/2
151/15

I more [1] 32/20
Ineed [1] 160/15

I needed [1] 9/3
Inever [1] 148/8

I note [2] 27/5 34/21
I now [2] 93/8 133/18
I obtained [2] 3/8 3/9
l obviously [4] 5/2
63/15 99/19 137/6

J only [2] 103/4
131/16

I part [1] 18/20

I personally [2] 43/14!
90/17

I phrased [1] 125/11
I pick [1] 89/7

I please [1] 110/11

I pointed [1] 54/17

I pushed [1] 27/2
lread [1] 73/24
Irealised [1] 3/4

I reasonably [1]
160/14

Irecall [1] 34/17

I received [3] 7/7
23/17 57/8

lI referred [2] 140/20
152/7

I regret [2] 41/10
145/3

Ireplied [1] 111/11

I reported [1] 17/11

I represent [1]

139/19

Iright [2] 18/14 39/4

I said [10] 11/8 46/6
56/4 73/22 77/14
103/3 114/6 116/8
153/21 160/20

I saw [2] 10/8 55/12

I say [5] 32/5 51/23
57/7 58/18 93/21

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103/17

Iseem [1] 84/16

Iset [1] 76/4

I simply [1] 101/11

I started [7] 6/8
101/13 102/12 145/16)
145/17 150/25 152/12!

I stepped [1] 154/12
I still [1] 68/9
I suggest [1] 82/9
I suppose [4] 38/19
69/2 69/4 140/5
I suspect [1] 42/8
I take [3] 17/17 101/6
145/9
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I that [1] 25/25
I then [1] 54/7
I therefore [1] 112/12
I think [159] 3/8 4/5
4/24 7/24 8/2 8/22
9/22 10/15 13/10 14/9
14/9 15/5 16/10 16/22}
18/25 21/19 23/9
23/14 24/7 24/8 24/16)
25/13 25/15 25/24
27/15 28/9 29/9 30/3
32/6 32/10 32/16
33/25 35/2 35/9 36/19)
37/15 38/15 39/12
39/16 40/12 40/12
40/20 40/24 41/17
42/8 42/21 42/23
43/16 44/8 46/4 46/6
46/12 46/25 47/9 48/7
49/20 51/22 55/3 55/8
57/7 57/18 59/17 60/5
63/15 63/19 64/3
64/16 64/23 65/6 65/7
66/10 67/1 67/11
67/18 68/1 68/12
68/14 68/20 70/8
70/12 70/13 70/19
71/10 71/23 72/2 73/7
73/22 75/21 76/2 76/5
76/15 78/24 79/17
86/8 86/15 89/21 90/4
90/21 92/12 93/6 96/2
96/3 96/10 97/7 97/8
99/18 99/25 100/2
100/5 101/1 102/10
102/23 105/6 106/22
109/3 109/17 111/8
111/19 112/10 112/15}
115/23 116/6 117/10
117/12 118/8 118/12
118/19 119/1 119/16
119/20 120/4 120/12
120/15 124/13 124/21
127/24 127/24 128/4
132/13 134/18 137/8
138/4 138/6 138/9
138/14 139/12 142/4
145/8 145/22 146/16
149/25 153/5 153/11
153/17 154/14 154/15}
160/11 160/20 161/8
I thought [14] 9/4
9/14 50/7 50/9 55/12
85/18 95/21 102/20
110/14 113/5 127/1

127/4 128/10 155/14
Ito [1] 35/17

I took [3] 89/18 107/5)
109/14

I totally [1] 45/8

I tried [2] 25/5 37/6
I understand [8] 27/7
44/9 44/10 80/25
121/22 133/7 145/4
159/8

I understood [1]
33/10

lused [1] 75/12

I want [10] 5/13 19/7
85/6 143/10 145/23
160/7 160/19 160/21
161/22 161/25

I wanted [11] 1/22
21/21 21/22 44/7
50/20 57/9 75/21
101/12 101/15 130/24}
131/18

I was [77] 2/8 4/19
5/5 6/4 6/7 6/23 6/24
7/8 7/10 7/12 7/13
7/19 7/24 8/13 10/10
10/11 10/17 10/22
11/3 11/15 11/21
12/18 14/11 14/22
14/23 14/23 15/3 15/5)
17/13 18/5 18/18 19/2
19/5 21/19 24/5 25/13}
25/22 25/25 27/3 30/3)
33/9 34/1 34/24 36/12
37/8 40/17 41/14
42/25 66/4 69/13 74/2)
74/5 75/9 75/24 76/17,
86/20 86/23 90/21
92/17 96/11 97/7
99/24 101/9 101/20
102/24 106/15 106/22
107/7 112/24 120/20
124/25 145/5 145/8
148/10 148/10 148/21
149/5

I wasn't [14] 2/18
12/19 17/24 18/16
26/1 33/24 48/25
89/25 95/17 99/24
101/22 105/16 107/20}
109/2

I watched [1] 125/25

I went [3] 9/19 14/25
75/9

I were [2] 20/21
151/16

I will [3] 92/7 147/1
162/5

I wish [2] 39/15
42/10

I won't [2] 70/21
155/8

I wonder [2] 90/2
128/15

I worked [1] 120/3
I would [59] 2/17
2/23 6/12 12/20 12/22I
13/9 13/11 14/20 15/6)
18/17 19/1 25/12
25/15 26/2 29/9 30/1
33/3 35/1 36/11 36/12I
37/9 53/8 55/8 57/7
57/10 58/4 58/20
58/21 59/16 59/17
59/22 60/19 60/20
63/7 63/22 64/2 67/13
74/12 78/24 82/5 86/4I
86/21 93/14 93/24
102/2 105/17 105/18
1412/3 112/15 114/5
120/20 120/24 120/25)
124/16 138/12 139/10)
141/13 159/14 162/10)
I wouldn't [13] 18/25
25/25 27/2 31/25
32/13 53/12 58/18
65/4 93/23 113/1
121/3 133/6 138/19
I wrote [3] 66/9
112/10 124/17
I'd [20] 2/25 5/5
11/25 17/3 21/21
26/23 72/18 73/22
77/16 85/12 104/19
112/14 113/25 116/19}
123/4 123/13 140/2
141/7 155/2 157/7
lll [9] 48/8 73/14
91/14 139/9 139/15
139/16 141/8 156/16
163/9
I'm [80] 1/25 11/24
12/19 13/9 13/14
14/20 14/20 18/17
20/12 23/5 23/16
25/13 36/16 43/23
44/17 44/23 45/2 45/3
50/18 52/7 52/25 54/9I
56/19 56/21 60/9
60/18 60/24 63/9 64/4
68/11 72/8 79/11
79/12 81/20 81/21
82/21 82/21 84/4 85/2
86/16 89/1 90/9 90/17
92/14 93/12 93/21
103/7 105/14 108/11
114/5 118/10 119/22
121/23 125/9 126/25
127/12 129/25 132/2
137/16 139/13 140/2
140/7 140/9 145/11
145/20 146/1 146/20
148/2 149/20 152/23
156/14 157/20 158/10}
160/6 161/9 161/23
162/4 162/7 162/8
163/2
I've [48] 5/1 6/25 8/3

(63) I don't... - I've
I've... [45] 10/9 21/14
29/2 39/11 41/8 42/12
60/17 61/15 64/7
64/15 64/24 65/5
73/11 79/18 82/8
92/11 93/3 96/9 99/3
103/2 105/6 105/17
107/7 107/16 107/16
117/2 123/12 124/10
124/15 124/21 130/6
130/7 131/23 132/1
135/2 135/17 139/8
145/3 145/19 146/2
146/19 148/4 151/9
151/11 154/4
idea [2] 54/3 131/14
ideal [1] 140/7
identified [2] 54/25
129/9
identify [3] 62/3 66/9
83/19
identifying [1] 82/19
ie [4] 143/21 144/5
156/15 161/17
ie not [2] 143/21
144/5
ie Phase 5 [1] 156/15)
ie the [1] 161/17
if [192]
illustrate [1] 42/12
illustration [1] 15/24
imagine [2] 65/17
111/21
immediate [1] 106/16
immediately [2] 80/9
110/18
immersed [1] 50/11
impact [6] 78/2 78/4
78/8 80/5 80/24 162/9
impacted [1] 78/11
implementation [1]
113/21
implemented [1]
108/1
implicated [1] 71/2
implication [1] 51/6
implications [1]
54/20
implied [1] 130/1
implies [1] 138/19
imply [1] 81/2
implying [1] 128/21
important [20] 40/13
43/6 43/17 69/16
85/10 90/15 100/24
101/4 105/4 105/7
105/11 106/11 110/25)
118/4 119/21 123/13
125/8 125/19 136/23
149/9
impossible [2] 46/4
74124

impression [3] 44/24
125/20 162/2
imprisoned [1] 147/7
imprisonment [2]
45/25 55/2
improper [1] 94/19
improve [2] 90/23
120/23
improvement [2]
82/17 120/10
improvements [2]
82/19 94/12
improving [1] 59/2
inaccuracies [1]
57/15
inaccurate [1] 56/2
incidents [1] 115/6
include [3] 137/4
143/23 158/18
included [5] 65/11
85/19 134/6 143/20
144/4
including [11] 5/25
77/21 85/5 99/20
99/21 105/19 106/9
119/17 120/6 131/20
158/6
inconsistent [1]
140/24
incorporates [1]
84/25
incorrect [2] 14/8
128/4
incorrectly [1] 19/20
increase [1] 101/5
increasing [2] 80/9
131/2
increasingly [2] 72/1
131/8
indeed [2] 134/22
135/12
indemnity [6] 91/17
91/18 115/3 115/5
115/9 115/15
independent [10]
24/9 52/17 54/4 71/14
72/3 87/4 126/3
129/20 155/21 159/2
indicating [1] 131/3
individual [11] 50/10
61/1 63/17 65/12
66/18 87/12 88/9
88/21 89/20 117/24
120/8
individually [4] 151/7
individuals [2] 67/16
158/5
industry [1] 62/13
inferring [2] 92/15
129/22
inform [2] 62/7 80/7
information [52] 3/9
10/19 27/11 33/14
33/16 34/2 35/8 37/13

37/14 41/3 44/11
49/18 49/23 52/25
53/9 55/8 58/11 64/12,
65/10 65/14 65/19
74/4 74/8 74/22 77/23
83/25 84/2 84/25 93/3
96/6 96/7 96/22 97/14
99/12 100/3 102/23
108/24 111/17 116/2
116/6 116/10 117/5
117/6 122/18 122/20
122/21 124/22 125/8
126/17 143/25 151/24
161/7
informed [6] 34/14
49/18 64/24 87/7
126/11 141/2
inherent [1] 20/9
initial [3] 19/7 21/10
114/18
initially [3] 3/24
14/10 14/22
initiated [1] 115/24
innocuous [1]
125/20
input [3] 19/20 46/10
109/5
INQ00002022 [1]
157/8
Inquiry [29] 64/10
65/23 66/4 75/18
123/5 124/15 136/16
141/21 141/22 141/23
141/25 142/22 146/21
155/19 155/22 156/3
156/10 156/18 156/19!
156/25 158/3 158/7
158/13 158/15 159/1
161/2 161/5 162/18
162/25
Inquiry's [3] 3/15
157/4 159/17
ins [2] 29/11 66/25
insert [2] 2/17 2/25
Inside [2] 12/24
41/24
insights [1] 52/16
instance [1] 29/18
instances [1] 4/18
instead [2] 62/25
156/16
instinctively [1]
112/18
institutional [1]
27/21
institutions [1] 110/9
instructing [1] 95/25
insufficient [1] 64/11
insurance [44] 72/19
72/23 73/8 73/14
77/15 77/15 77/20
78/3 78/5 78/7 78/9
78/10 78/11 79/8 79/9
79/18 80/23 84/1

84/16 84/18 84/25
86/17 88/2 88/5 88/11
89/1 89/5 89/11 89/25)
91/9 91/12 93/16 94/3
95/23 114/25 115/4
115/5 115/9 115/11
115/15 115/21 115/22)
116/4 116/13
insurer [1] 80/4
insurer/s [1] 80/4
insurers [11] 72/22
73/5 78/19 80/8 90/14
90/20 93/20 93/21
115/13 126/11 126/15)
integrity [4] 28/17
41/19 104/22 104/24
intend [1] 51/4
intended [2] 18/22
143/23
intense [3] 49/16
98/14 108/3
intentional [1] 14/18
intentionally [1]
15/10
interaction [2] 18/6
37/9
interactions [1]
18/20
interest [2] 16/19
25/11
interesting [5] 29/8
29/12 29/13 36/20
111/20
interests [1] 100/16
interface [5] 64/18
66/20 71/11 91/1
128/15
interfaces [3] 25/18
52/22 137/25
interfacing [1]
120/21
interim [31] 39/18
49/3 49/8 51/20 52/4
52/8 55/5 56/7 57/9
57/14 59/2 59/18 60/8
61/12 66/21 70/13
72/2 74/15 76/8 89/17,
90/12 96/18 97/2
118/22 119/11 119/20
132/14 135/19 150/16}
152/18 158/22
internal [7] 22/10
55/25 88/15 91/10
142/19 152/15 152/15}
internally [2] 79/21
91/6
interrupted [2] 65/13
65/15
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152/23
intervention [2]
127/4 128/10
into [33] 8/6 17/7
17/11 18/1 18/3 23/12,

28/8 46/10 56/5 68/21
70/11 74/14 80/9
82/17 94/13 107/19
108/18 117/23 127/16)
128/1 149/23 150/8
151/13 153/3 153/24
155/17 156/14 157/2
157/3 157/6 157/10
161/12 161/13
introduced [2]
114/19 160/21
Introduction [1]
97/21
introductory [1]
52/11
investigate [2] 28/22
29/21
investigating [1]
62/24
investigation [7]
35/15 47/12 50/21
62/21 84/12 112/3
146/11
investigations [1]
62/11
investigator [1]
35/10
investigators [1]
52/18
investment [3] 3/20
5/6 8/4
Investments [1]
13/20
invite [1] 68/22
involved [7] 9/8 18/6
36/7 82/6 85/22 130/2I
160/24
involvement [3]
13/19 85/11 85/14
involving [1] 10/6
Ireland [3] 121/15
122/5 154/1
irreconcilable [1]
101/10
Irrespective [1] 89/8
irritated [3] 53/1 70/9
86/23
irritation [1] 135/2
is [328]
Ismay [4] 141/21
141/22 142/4 152/6
isn't [6] 47/20 81/1
100/23 128/16 130/1
153/16
issue [63] 2/23 27/17
30/2 32/15 34/16
38/24 39/1 40/23
40/24 42/15 43/10
43/14 46/16 47/4
47/15 47/21 49/2 53/8)
53/23 57/5 57/18 64/3I
64/17 68/2 76/20
77/14 77/16 81/21
81/23 81/24 82/3

(64) I've... - issue
I
issue... [32] 82/15

85/12 86/6 89/9 89/10)

89/24 90/9 90/15
90/25 91/2 93/17
96/17 96/24 97/10
98/8 103/3 104/4
105/7 105/23 112/14

114/25 115/22 116/13)
117/20 118/19 119/22)

122/25 124/18 125/6
137/9 149/25 156/20
issues [65] 7/22 13/1

13/4 18/9 18/23 22/18}

23/4 28/12 31/11
31/22 39/19 39/25
42/7 48/4 48/19 51/1
51/19 52/6 54/5 57/9
57/17 59/12 60/11
62/6 64/12 66/3 69/16
70/5 78/8 78/18 82/2
82/11 90/4 101/3
1041/7 102/5 102/15
102/15 102/16 102/19
105/5 105/10 106/11
107/11 118/25 119/6
119/10 119/13 119/18
124/23 129/7 130/9
132/16 138/5 142/15
147/8 152/18 152/20
156/3 156/6 157/1
157/14 157/19 157/25
161/11
Issy [1] 30/21
it [469]
it's [82] 1/24 2/1 2/2
2/6 12/3 12/7 13/13
13/25 14/21 17/8
17/19 17/19 22/5
22/22 28/12 29/1
33/25 34/24 37/22
44/3 44/22 47/18
55/13 60/15 63/18
65/23 66/25 67/22
71123 74/18 76/8 82/9
82/13 88/2 88/3 90/2
91/25 92/16 95/2
98/16 104/4 104/19
104/20 105/20 106/2
107/19 108/13 111/8
111/13 114/5 117/6
120/10 122/13 123/8
128/15 128/16 130/1
130/24 132/7 132/24
136/2 140/3 140/4
141/12 142/7 142/9
142/22 143/15 145/22
145/24 146/25 147/19
148/13 148/19 148/20
152/9 154/1 154/1
154/2 155/9 159/16
160/13

item [8] 3/2 31/17

39/16 45/21 45/24
46/17 99/23 133/9
item 11 [1] 45/21
items [5] 97/20 98/7
114/11 144/10 144/16)
items 14/31 [1]
114/11

iterations [1] 120/11
its [12] 30/14 56/6
57/21 59/1 59/4 60/2
62/22 73/10 82/16
115/11 125/7 158/15
itself [18] 7/5 19/22
21/18 37/5 38/17
51/24 60/1 63/4 72/3
74/1 75/4 94/4 98/17
112/11 125/6 137/6
153/2 154/7

James [18] 28/15
28/19 34/9 34/12 36/3
40/6 41/6 41/10 47/25
48/18 54/7 54/14
54/17 57/3 64/19
129/10 132/18 134/11

January [2] 9/12
26/17

JEMIMA [3] 1/7 1/11
164/3

Jenkins [9] 94/16
95/5 95/12 95/15
95/18 116/15 122/22
126/12 126/15

JFSA [5] 13/10 31/6
31/17 53/19 64/19

JFSA's [1] 30/14

jigsaw [1] 40/25

JLT [4] 78/14 78/17
78/18 80/3

Jo [5] 34/4 48/6 48/7
64/9 103/4

job [12] 7/12 17/14

42/20 42/25 42/25

47/1 47/3 47/5 50/8

87/9 101/19 138/1

jobs [1] 42/24

jobshare [2] 98/13

101/21

jog [1] 137/8

joined [4] 8/12 20/21

24/7 120/2

joining [1] 131/3

joint [1] 80/11

journey [1] 120/9

judge [1] 48/8

Julian [1] 19/13

July [53] 1/1 34/7

34/12 38/19 46/23

47/3 47/16 47/17

49/15 49/20 50/17

51/13 51/14 52/7

53/15 57/6 57/7 57/12

57/20 58/16 63/8 64/5)

65/22 69/1 73/25
76/21 77/18 83/7
85/18 86/13 86/18
87/21 89/13 90/6
92/21 93/22 94/1
96/14 97/9 101/7
105/6 112/17 115/24
118/22 119/10 126/22
134/21 135/3 135/25
136/3 138/10 145/22
153/18
Junction [1] 78/3
juncture [1] 151/5
June [4] 46/22 46/23
47/3 47/15
June/July [1] 46/23
jury [4] 162/7
just [95] 2/1 2/2 2/6
4/5 4/19 6/4 6/16 8/8
10/9 13/14 17/19
22/22 23/12 23/20
26/5 39/10 39/23 41/4
44/5 44/12 47/5 48/21
50/10 50/19 54/9 55/9
55/13 56/13 56/21
58/21 60/24 63/22
66/15 66/24 68/5
68/18 72/5 73/23
74/14 75/6 75/23 77/9
78/22 79/12 79/13
84/4 84/19 85/3 85/12
86/2 86/16 87/17
88/17 89/24 96/5
98/13 102/6 102/15
107/2 107/13 108/3
110/4 111/8 111/9
111/12 111/17 121/20
123/13 126/21 127/12]
130/13 130/15 133/3
133/6 134/4 135/14
136/1 136/2 137/13
137/21 138/16 139/23}
140/9 143/19 144/14
146/20 147/14 148/8
149/7 149/16 150/5
150/5 150/14 158/9
161/8
Justice [2] 12/9 13/5

K

keen [6] 25/15 56/6
58/13 79/8 159/24
160/14

keenly [1] 132/15
keep [9] 34/14 62/15
81/25 84/21 87/6 99/5
101/12 145/10 149/20
keeping [1] 82/2
kept [4] 19/22 123/2
126/14 130/10

key [7] 13/18 15/21
81/16 89/4 105/15
117/17 117/20
kicked [3] 138/10

138/12 138/18
kind [17] 11/16 12/22
15/3 16/12 16/19
40/22 41/24 42/3
49/13 67/1 72/11
89/22 90/25 91/1 96/7,
98/14 134/7

kinds [4] 12/15 23/4
38/23 52/4

King [1] 83/18
knew [12] 5/2 26/14
26/14 40/21 43/15
50/14 51/13 51/16
52/4 96/3 136/8 156/3)
know [79] 2/1 2/8
6/11 6/22 9/17 11/20
24/2 26/20 26/22
27/20 28/12 29/3 30/6)
34/4 39/14 39/15
40/25 44/20 45/2 48/9)
50/1 51/22 52/20
58/11 59/15 60/9 63/2,
64/2 67/13 68/10
69/12 70/17 71/10
75/18 76/25 79/8
79/11 81/4 92/6 92/15)
92/18 93/2 93/2 93/3
93/4 93/8 97/15 97/16
97/16 103/7 107/7
113/6 117/2 121/19
124/1 124/4 124/9
124/12 125/9 125/14
127/3 128/16 129/17
130/2 130/4 130/8
131/17 131/21 131/21
135/16 136/20 137/7
142/7 145/2 145/4
152/12 154/3 159/24
160/7

knowledge [3] 1/20
3/12 136/13
known [7] 12/20
31/25 32/13 101/8
121/24 122/2 152/10
knows [2] 48/10
162/20

L

lack [2] 39/8 93/16
Lamb [3] 32/1 34/4
40/18

lane [2] 19/5 102/6
large [3] 19/15 119/8
139/19

last [14] 6/23 30/16
102/9 124/25 126/1
140/4 140/18 146/9
146/21 156/8 157/24
158/23 161/16 162/10}
lastly [3] 3/4 147/9
158/13

late [2] 47/18 68/4
late-night [1] 68/4
later [9] 12/23 18/3

77/2 92/12 95/18
123/21 125/5 128/17
151/2
latest [1] 56/20
latter [2] 125/23
126/8
law [1] 83/17
lawyers [1] 54/19
lay [1] 133/11
layers [1] 49/17
layman's [1] 38/18
lead [4] 35/24 89/20
93/12 98/12
leadership [2] 71/19
72/112
leading [7] 13/22
71/20 72/14 89/23
110/19 124/7 137/23
learn [1] 38/13
learnt [2] 151/11
152/7
least [8] 34/1 49/18
64/24 93/8 109/5
135/14 155/13 162/12)
leave [16] 5/16 6/9
6/10 7/9 14/23 17/3
19/2 42/23 85/1 98/15
98/19 145/13 148/6
148/8 148/10 155/6
leaving [2] 98/1
98/19
led [5] 17/2 39/2
45/25 127/9 135/19
left [12] 80/22 98/5
99/19 102/21 121/5
132/2 134/21 151/23
157/11 157/20 158/1
161/21
left-hand [1] 157/11
legal [15] 22/18
24/23 31/7 54/17
54/18 73/23 114/20
115/8 116/24 117/17
117/25 119/5 142/15
146/2 163/5
legally [1] 115/6
length [3] 68/11
75/22 158/11
less [6] 34/2 61/22
69/17 103/2 107/24
110/7
let [4] 2/8 48/8 92/6
161/8
let's [9] 21/25 55/16
65/21 94/3 113/8
143/17 145/10 145/22)
150/25
letter [12] 9/11 9/25
10/2 10/3 19/9 20/8
31/15 31/21 39/24
40/7 40/14 43/9
letters [2] 19/12
26/17
Letwin [1] 28/15

(65) issue... - Letwin
L

96/8 112/2 116/5
116/25 155/25
levels [2] 74/4 82/4
lever [1] 22/24
liabilities [2] 43/12
88/12

liability [4] 88/10
88/21 91/16 104/14
liaising [1] 10/23
liaison [1] 10/6

[1] 3/20

lift [1] 118/25

light [2] 57/2 89/15
like [44] 2/10 2/17
2/23 2/25 9/20 11/25
14/20 18/25 19/5
19/17 23/14 24/24

70/18 72/18 77/16
81/19 81/23 82/13
85/12 92/6 104/19
112/2 115/19 116/19
123/4 123/13 125/24
133/17 134/20 140/3
141/7 151/15 154/9
155/2 155/6 159/14
likely [8] 22/17 51/11
59/17 60/20 78/11
92/17 99/13 142/14
limit [2] 91/17 163/2
Limited [4] 13/20
38/2 38/15 38/17
Limited's [1] 13/21
line [17] 2/23 17/14
50/10 50/24 62/13
74/11 81/5 106/24
120/12 120/16 134/4
135/13 135/14 142/17)
144/4 144/6 146/21
line’ [1] 143/21

lines [15] 2/16 17/15
17/21 41/23 52/5 60/5)
63/5 63/23 65/12
68/21 105/22 134/7
140/5 140/19 146/10
link [3] 42/4 42/5
159/16

Linklaters [8] 114/19
114/23 116/19 116/20}
117/10 117/15 118/12)
119/5

links [2] 43/7 43/7
list [5] 23/7 27/19
90/1 90/18 130/15
listed [4] 20/17
157/11 157/19 158/7
listen [1] 154/25
listening [1] 162/3
lists [2] 30/20 113/10

level [14] 11/19 39/8
40/2 40/10 46/3 76/13!

27/15 39/3 45/23 58/5
58/21 63/9 64/15 65/4

literally [1] 45/2
litigation [19] 13/23

39/9 40/1 40/4 44/1
46/2 54/25 134/3
134/8 134/12 144/19

126/21 133/3 133/6
135/20

live [2] 110/10 159/6
lives [1] 160/17
load [6] 55/7 65/9
68/16 72/10 76/8
85/19

loads [1] 147/14
lobbying [2] 31/13
31/18

location [3] 5/13 8/9
18/24
logistical [2] 7/22
93/5
logistics [4] 8/6 8/8
8/16 37/17

London [1] 163/8
long [11] 6/11 12/6
26/24 95/18 95/18
118/19 131/5 132/17
149/2 152/13 160/6
longer [2] 38/6
132/22
look [45] 16/3 21/25
29/4 34/24 40/24
44/20 46/19 46/19
48/12 52/9 56/22
58/22 65/8 65/21 85/4

104/21 113/8 118/19
120/24 123/7 126/20
130/15 130/17 132/19)
132/21 139/16 140/6
140/8 141/10 141/19
142/6 142/10 145/23
147/25 149/15 149/21
151/13 152/21 153/3
153/13 157/8

looked [11] 4/16
48/13 54/23 65/23
68/25 77/19 116/1
120/14 149/23 150/14)
160/6

looking [26] 13/13
39/7 39/11 39/23 43/5
44/15 46/5 59/16 75/3
77/17 89/10 92/25
95/19 97/15 103/20
107/13 107/14 115/19)
119/4 119/9 120/4
126/25 130/18 137/16)
158/20 163/2

looks [4] 21/11 38/3
58/5 63/9

Lord [3] 48/15 49/21
134/16

20/13 21/7 21/25 22/2
35/6 35/7 35/17 37/23)

little [6] 44/17 123/14

93/7 94/3 95/19 97/17)

Lord Arbuthnot [1]
49/21

lose [1] 139/1
loss [3] 91/20 146/22
147/2

losses [6] 35/13
118/2 146/5 146/5
146/12 146/18

lost [2] 85/23 146/23
lot [25] 7/3 10/21
18/18 39/2 49/17

68/10 70/22 86/10
97/7 102/5 102/11

125/8 135/17 137/9

150/13

lots [2] 39/12 147/25
loudly [1] 79/16
Lovegrove [2] 17/5
17/11

low [1] 23/7

Lowe [3] 15/2 17/4
58/14

lunch [1] 103/10
lurking [1] 160/23
Lyons [4] 77/21
77/22 84/6 136/25

made [20] 4/5 36/3
74/2 74/16 80/10 94/8
94/12 94/14 94/20
95/10 116/16 117/18
123/20 124/2 124/7
133/20 133/23 147/21
148/18 160/1

Mail [15] 4/3 4/12
4/20 5/4 11/12 12/18
18/2 27/20 34/18
35/23 72/21 73/7
78/14 80/11 152/14
Mail's [1] 80/3

mails [1] 79/20
main [4] 53/23 54/11
78/16 133/8

majority [2] 55/23
7AI8

make [20] 1/22 2/10
2/18 9/14 9/17 16/23
26/18 67/15 75/6
89/14 90/3 96/11
102/8 128/12 131/18
138/4 141/10 154/8
154/22 160/16
makes [2] 59/3 125/7
making [16] 14/21
34/24 96/1 105/16
116/6 116/14 127/14
129/17 131/11 131/14
132/5 133/8 149/5
152/5 154/11 155/2
malfunctions [1]

49/23 64/7 66/3 66/15)

102/16 118/23 124/15}

137/25 143/16 144/24

118/41

malicious [1] 94/22
manage [1] 37/6
managed [4] 71/5
TANT 71/18 135/12
management [4]
71/6 104/17 105/9
120/23

manager [1] 106/24
managing [2] 7/17
121/3

manifest [1] 117/22
manifests [1] 73/4
mantra [1] 160/18
many [13] 9/23 10/21

99/3 133/12 133/12
136/2 147/5 158/25
162/20

March [25] 4/2 4/2
4/9 4/20 5/17 5/17

42/19 43/4 75/24
109/14 113/7 113/16
114/8 118/15 121/5
131/20 145/14 145/15}
145/16 145/17

Mark [9] 17/4 17/6
17/12 18/3 98/3 100/1
100/6 100/8 106/23
Marnoch [16] 24/1
24/12 24/13 43/20
46/14 73/1 79/4 79/15)
80/18 81/15 84/14
88/23 89/19 90/2
92/20 93/15

Martin [6] 26/9 47/7
47/9 84/21 87/18
87/21

masking [2] 149/19
149/19
material [7] 89/5
90/21 97/10 117/6
121/17 123/22 152/15)
materiality [1] 46/16
maternity [12] 5/16
6/9 6/10 7/9 14/23
17/3 19/2 42/23
145/13 148/5 148/8
148/10
matter [6] 28/24
35/16 94/7 147/18
148/11 153/25
matters [13] 12/15
13/20 19/11 27/22
28/11 35/24 46/24
69/9 83/11 105/2
107/24 144/15 148/23}
matured [1] 120/6
may [37] 1/13 11/21
11/24 19/11 23/25
26/25 32/5 32/9 36/8
40/21 48/17 61/25
72/5 73/1 73/5 78/11

12/13 30/18 36/6 97/4)

6/10 6/23 7/11 8/1 8/5)

81/1 81/3 90/7 94/17
95/13 117/22 125/1
127/19 128/20 130/22)
133/17 133/25 134/9
134/22 135/6 137/21
141/9 143/16 148/17
148/21 161/17
May 2012 [1] 40/21
maybe [3] 2/8 91/13
145/19
McCausland [4]
20/20 24/5 66/13
125/12
me [53] 2/1 2/2 2/8
4/25 7/3 11/21 12/25
15/4 25/7 27/18 32/14I
33/5 36/14 36/20
44/17 44/22 55/3 58/5)
58/7 64/23 69/8 73/24
74/2 74/16 80/23 81/1
81/6 81/18 82/2 86/3
87/7 89/25 92/6 92/14
93/22 97/8 100/3
103/6 105/20 109/24
111/15 117/3 117/10
125/7 137/7 148/24
152/23 159/14 161/6
161/8 162/7 162/16
163/1
mean [44] 7/24 8/1
41/7 21/11 23/14
23/14 29/12 33/18
37/1 38/9 41/22 45/6
49/15 58/3 64/14
69/12 71/22 73/20
76/4 76/15 81/3 85/16I
86/2 86/13 86/15 97/7
101/1 105/15 105/23
106/3 106/10 107/4
111/6 112/10 124/20
124/21 134/9 135/16
137/15 138/13 138/21
143/10 144/6 144/9
means [4] 129/14
130/4 136/12 144/17
meant [4] 8/16 15/19
32/20 98/15
measures [1] 146/7
mechanisms [1]
82/20
media [7] 3/17 53/3
53/6 56/9 56/15 56/20
58/23
mediation [6] 77/1
90/23 99/12 99/15
114/18 119/17
meet [9] 37/6 41/6
41/6 41/13 49/21 80/2
92/8 93/4 131/17
meetitalk [1] 92/8
meeting [125] 6/9
11/22 11/24 12/8
20/15 20/16 21/11
21/14 21/16 22/22

(56) level - meeting
Mo
meeting... [115]
22/25 23/2 23/5 24/1
24/3 26/8 27/5 28/6
28/15 28/18 28/20

30/3 30/12 30/12 31/2

31/5 31/25 32/1 32/5
32/21 34/7 34/8 34/11
34/15 34/17 34/20
35/22 36/10 36/15
36/24 37/2 37/4 37/5
37/8 37/16 37/18
37/20 40/17 41/11
41/11 41/12 46/18
47/8 47/11 47/20
47/25 48/2 48/14
48/17 54/7 57/20
65/21 65/22 65/23
66/6 66/6 66/24 68/23
69/11 69/23 70/3
71/24 72/5 72/24
73/25 76/11 76/21
76/22 77/18 78/17
79/1 83/11 85/18 86/4
86/9 89/13 94/1 94/2
96/14 97/9 97/17 98/5
98/7 98/15 99/25
100/22 103/21 103/22)
105/4 105/5 105/13
106/4 106/4 107/18
107/20 108/4 113/10
113/13 114/9 114/9
114/13 115/17 126/22)
127/8 129/1 133/17
134/10 137/2 137/2
138/18 139/2 143/15
143/16 144/13 145/2
meetings [17] 10/22
32/2 32/24 33/2 33/4
35/4 36/13 40/6 46/8
75/13 86/9 101/23
106/12 107/13 120/7
126/7 134/10
member [11] 4/18
7/8 15/16 63/18 65/19
70/2 74/6 107/3
112/25 114/4 145/6
members [9] 24/24
28/5 29/17 30/14 31/7
43/20 69/21 75/14
83/3
membership [1]
109/18
memories [1] 21/14
memory [5] 23/2
59/19 64/1 137/8
138/22
mention [3] 28/9
41/22 100/5
mentioned [7] 32/14
68/18 71/9 98/8 100/9
116/15 162/21
mentioning [1] 39/25

mentions [1] 40/4
message [2] 41/18
80/22

messages [3] 42/16
63/19 119/12

met [6] 21/21 29/19
31/14 36/25 125/4
134/16

microphone [1] 2/9
middle [3] 47/23
142/10 161/14
might [23] 36/14
45/10 45/24 48/1 50/2
57/20 58/7 61/12 69/2
77/6 78/9 103/9 110/6
117/21 117/22 118/11
128/21 129/15 134/17)
137/4 143/15 151/15
155/14

Mike [3] 12/3 12/3
47/10

mild [1] 70/17
Miller [3] 78/10 78/17
80/2
million [3] 59/7 61/19
158/9

mind [20] 13/1 33/12
43/11 43/15 57/19
58/9 63/20 75/6 75/10
90/25 96/14 110/15
112/15 112/23 113/4
126/3 136/2 137/18
144/3 161/23

mindful [2] 25/12
26/1

minds [1] 160/23

minister [11] 30/10
32/21 34/3 40/7 48/7
58/12 58/15 60/23
64/4 65/18 67/14

ministerial [5] 12/2
18/11 18/13 30/10
32/15

ministers [10] 18/7
18/9 18/20 19/4 26/16
31/13 41/12 50/12
64/20 103/2

minute [2] 44/23
136/22

minuted [1] 96/13

minutes [23] 28/10
32/10 68/14 69/19
70/17 77/19 86/19
99/18 103/24 106/2
113/8 116/18 126/18
136/19 136/24 137/1
137/11 137/14 138/14)
139/9 139/12 139/16
154/25

mischief [3] 131/11

131/14 132/5

misfortune [1]

159/23

mishandled [1] 66/19)

misleading [1] 56/1
misled [1] 151/16
mismatch [2] 150/22
152/8
misnoted [1] 145/19
missed [3] 107/14
107/17 136/3
misses [2] 82/13
115/12
missing [3] 3/4 84/16
1471]
mistakes [1] 82/19
misunderstanding
[1] 95/22
misunderstood [1]
79/18
model [1] 102/21
moment [14] 9/16
21/17 25/19 45/10
75/3 77/7 85/22 103/9
105/11 105/14 115/1
115/20 122/17 159/7
moment's [1] 110/5
moments [1] 5/22
Monday [13] 33/22
47/18 49/15 51/9
51/22 51/24 52/6
52/23 55/3 56/16
59/15 63/7 111/11
Monday's [1] 50/24
money [4] 62/20
146/8 146/24 146/25
monitor [1] 110/24
monitoring [1] 19/19
month [4] 134/2
134/5 134/5 134/13
months [6] 7/10 46/1
76/22 124/6 135/18
158/25
more [64] 21/13
26/20 27/14 28/7
32/20 34/1 38/4 38/6
38/13 42/7 42/16 46/3
49/17 50/14 52/16
59/6 59/7 59/17 60/20
61/19 65/9 65/16
69/17 70/12 73/13
74/25 76/1 76/3 76/10
77/4 79/19 80/10
81/11 88/8 90/22 91/3
96/17 102/18 102/18
102/24 105/22 106/14
108/8 108/24 110/17
110/23 112/4 116/4
119/1 123/25 125/16
125/17 125/21 126/5
129/4 129/5 129/25
130/6 135/22 136/1
136/2 136/8 137/9
145/11
morning [15] 1/3 1/5
1/5 39/23 45/11 48/3
54/24 55/7 55/10 66/8
66/10 66/11 77/7

90/10 111/12
mortem [1] 88/15
most [9] 4/19 8/2
56/25 60/19 75/20
78/11 97/13 122/20
150/19

mostly [1] 29/16
mounted [1] 31/18
move [6] 19/7 20/13
43/25 118/24 142/21
158/14

moved [2] 107/24
125/17

movement [1] 85/13
moving [9] 35/21
37/19 46/22 50/15
53/15 78/20 87/14
107/21 118/17

MP [3] 28/15 28/16
150/1

MPs [9] 28/20 29/19
31/18 35/11 36/5
41/11 64/20 133/15
133/20

Mr [48] 1/4 1/8 20/5
30/10 30/13 35/4 36/9
36/24 45/9 45/19
47/23 79/15 79/21
81/15 95/5 103/17
103/17 113/11 122/13}
123/25 125/12 136/18
139/6 139/7 139/16
139/16 141/22 142/22)
150/13 151/23 152/6
153/12 153/21 154/16
154/22 154/25 155/7
155/10 157/13 157/17)
159/22 160/1 162/19
163/2 163/3 164/5
164/11 164/13

Mr Arbuthnot [1]

35/4

Mr Bates [1] 30/13
Mr Beer [9] 103/17
136/18 154/22 154/25)
155/7 159/22 160/1
162/19 163/2

Mr Blake [9] 1/4 1/8
45/9 45/19 103/17
150/13 151/23 153/21
164/5

Mr Callard [1] 113/11

Mr Chapman [1]
163/3

Mr Clarke [1] 123/25

Mr Darlington [1]
142/22

Mr Day [4] 79/21

Mr Edwards [1]

47/23

Mr Folkes [2] 157/13
157/17

Mr Gibson [2] 36/9
36/24

Mr Ismay [2] 141/22
152/6
Mr Jenkins [1] 95/5
Mr Marnoch [2]
79/15 81/15
Mr McCausland [1]
125/12
Mr Page's [1] 139/16
Mr Stein [6] 122/13
139/6 139/7 139/16
154/16 164/11
Mr Whitehead [1]
30/10
Mr Wilson [1] 20/5
Ms [30] 1/6 1/12 3/16
36/25 77/14 122/13
122/14 122/16 123/9
123/9 123/15 123/15
124/8 124/8 136/4
136/16 136/17 137/20}
137/22 139/1 139/15
139/18 139/19 149/12)
151/5 151/22 154/4
154/20 154/24 164/9
Ms Crichton [2]
136/4 136/17
Ms Falcon [1] 154/4
Ms Page [6] 122/13
122/14 137/20 139/15)
151/22 164/9
Ms Perkins [6] 123/9
123/15 124/8 136/16
137/22 139/1
Ms Storey [9] 1/6
1/12 3/16 77/14
122/16 139/18 139/19)
154/20 154/24
Ms Vennells [6]
36/25 123/9 123/15
124/8 149/12 151/5
much [32] 1/9 1/23
2/21 3/3 3/14 20/25
21/5 41/3 59/15 60/20)
63/2 69/15 70/21
73/13 77/22 79/6 88/2I
88/20 96/17 103/19
123/25 129/22 130/1
131/4 132/3 136/8
137/17 140/8 155/5
160/14 160/15 163/7
multiple [4] 133/15
Museum [2] 45/22
45/24
musing [1] 121/10
must [3] 25/24 75/13
112/4
mutualisation [1]
9/21
my [154] 1/18 2/9
2/16 2/19 5/1 6/9 6/12
6/23 6/25 7/2 7/2 7/2
8/1 8/6 8/25 9/11 9/14)
9/19 10/8 10/20 10/24I
11/3 11/6 11/16 11/22I

(67) meeting... - my
my... [129] 15/1
16/20 17/14 17/23
17/24 18/16 19/1 19/3}
21/15 21/23 23/2 25/5
25/8 25/17 27/16
27/20 30/3 32/3 35/20
37/6 38/11 38/21 39/2
39/12 41/8 41/9 41/23,
42/1 43/4 45/3 46/6
47/3 49/18 50/5 50/9
51/13 51/25 55/21
57/12 57/19 58/6 58/9
63/20 64/1 64/3 64/16)
65/18 66/9 66/11
66/19 67/1 67/19
67/24 70/9 74/24
75/10 75/22 76/4
76/25 80/15 81/5
89/13 90/1 90/18 91/8
92/19 93/12 96/14
97/11 98/8 98/12
98/18 99/3 101/13
101/19 101/20 102/2
102/12 102/20 103/1
103/3 105/17 106/24
107/7 107/8 107/9
107/16 108/21 109/7
110/14 110/15 111/17)
111/17 112/15 112/24
112/25 113/4 113/25
115/22 116/16 119/2
120/2 123/14 123/18
124/14 124/17 124/17
125/11 131/24 131/24}
131/25 132/20 136/25)
137/8 138/2 138/22
140/17 141/12 144/14
145/1 145/3 148/8
148/10 150/25 153/21
160/12 162/16 163/1
163/6

myself [4] 40/20
46/21 121/21 125/10

N

name [7] 1/9 79/5
91/8 125/19 126/12
141/19 141/20
named [4] 24/2 67/16
73/8 104/13

namely [1] 153/14
names [7] 17/9 71/9
71/10 142/21 157/9
157/19 157/25
national [1] 146/3
nature [9] 11/5 22/4
23/9 110/16 116/25
137/1 141/18 144/19
155/15

navigate [1] 21/20
navigating [1] 30/4
near [2] 82/13 115/12

nearly [1] 156/17
necessarily [3] 37/1
74/5 121/23
necessary [4] 70/1
70/4 82/18 99/12
necessitate [1]
111/22
NED [1] 11/4
NEDs [5] 42/8 92/14
131/8 138/16 138/17
need [22] 9/4 55/17
62/20 71/6 73/4 79/16
80/7 81/25 87/1 87/3
112/3 118/13 124/13
127/3 127/10 127/14
127/19 127/20 128/22)
135/8 150/18 160/15
needed [17] 7/21 9/3
48/16 69/24 71/18
81/9 89/15 90/7 90/20
102/2 106/20 107/6
107/9 122/18 131/19
144/17 152/21
needs [2] 3/9 87/9
negotiating [1] 15/13
negotiations [2]
15/18 16/8
Neil [5] 20/20 24/5
66/13 126/3 138/16
nervous [1] 25/17
nervousness [2]
16/9 25/9
network [6] 31/9 59/5)
94/9 110/20 147/21
148/17
neutral [1] 52/16
never [8] 6/24 6/24
11/14 14/11 21/21
50/1 148/8 163/4
new [17] 11/19 11/19
16/16 25/19 30/10
42/21 42/24 54/3
54/16 80/8 94/6 97/8
102/7 104/2 105/2
113/4 113/22
newly [1] 11/4
news [2] 31/17 97/8
newspaper [1]
133/21
next [20] 2/22 28/11
44/2 44/5 52/9 53/2
54/2 54/22 58/11
80/14 85/21 93/25
99/6 112/4 115/14
127/6 131/7 135/1
157/17 162/16
NFSP [1] 140/14
night [7] 51/22 51/24
52/23 55/4 68/4 111/6
126/1
no [95] 5/8 5/12 7/7
TIT 7/14 11/14 18/16
18/25 19/19 21/18
21/23 32/18 32/20

33/21 35/13 36/18
36/23 37/1 37/14 38/9
39/3 41/8 45/2 47/3
48/25 49/15 51/19
52/6 52/20 57/16 61/2
66/3 66/3 68/8 68/9
79/16 92/11 93/21
94/12 99/22 100/14
103/6 109/21 114/4
115/18 115/22 119/13
121/25 121/25 123/20
123/20 124/3 126/2
128/3 128/3 128/7
129/6 129/20 130/4
130/9 130/20 133/1
133/2 133/10 133/17
133/25 134/1 134/2
136/13 137/11 137/19]
137/19 138/23 138/25]
139/5 139/10 142/3
145/16 146/11 147/12
149/4 149/4 150/3
150/6 150/8 150/10
151/1 151/1 151/10
151/18 151/25 152/4
152/19 153/19 155/9
nobody [5] 40/10
43/21 44/17 121/15
144/6

nodded [10] 4/7
92/24 98/23 118/16
136/7 136/10 136/15
150/21 150/23 151/4
nodding [2] 130/11
130/14

non [63] 4/8 4/15
5/10 5/15 5/15 8/17
8/20 9/1 9/15 10/13
11/9 11/19 11/23
12/16 12/17 14/2
14/14 15/20 16/1
16/11 17/22 19/8
20/18 20/23 20/24
21/22 24/10 24/11
24/14 24/18 26/6
26/13 27/8 43/20 46/9
50/8 66/12 66/15 67/5)
68/6 69/14 72/12 74/6
75/11 75/25 87/11
89/21 90/15 91/23
92/22 93/11 96/15
97/9 100/15 111/1
113/14 117/3 119/24
120/17 120/20 124/11
126/4 145/6
non-disclosure [1]
27/8

non-executive [46]
4/8 4/15 5/10 5/15
8/17 8/20 9/1 9/15
10/13 11/9 11/19
11/23 12/16 12/17
14/2 15/20 16/1 16/11
17/22 19/8 20/18

20/23 21/22 24/11
24/14 24/18 26/6
43/20 46/9 50/8 66/12
75/11 75/25 87/11
89/21 90/15 91/23
93/11 96/15 97/9
100/15 111/1 113/14
117/3 124/11 126/4
non-executives [3]
14/14 26/13 66/15
none [4] 96/2 110/19
136/19 152/13

nor [7] 7/14 18/10
18/20 32/2 112/12
129/14 133/8
normal [2] 8/20 46/6
normally [2] 34/25
82/5

Norman [3] 32/1 34/3
40/18

Northern [3] 121/15
122/4 154/1

not [155] 2/6 2/14
7/24 8/8 12/20 13/6
13/9 14/5 14/15 14/20}
15/8 16/1 18/5 18/6
18/8 20/20 25/1 25/3
30/8 33/21 34/1 36/6
36/16 37/1 40/2 40/16)
41/8 43/23 44/23 45/2)
46/4 46/12 46/20 47/3)
50/9 50/25 53/8 53/24)
54/16 55/24 60/15
60/18 66/1 66/4 68/12)
69/11 69/22 69/24
69/25 70/6 70/15 71/5)
73/4 TAIT 74/24 75/1
75/14 75/18 75/20
79/12 79/23 80/1 81/3}
81/16 81/16 86/20
89/1 89/3 89/10 92/14}
93/8 93/9 93/12 93/21
96/11 96/25 97/14
102/1 102/5 102/14
102/18 103/25 104/24)
105/14 105/20 106/15)
106/16 109/19 110/18}
111/16 114/5 115/1
115/8 116/11 118/4
118/11 121/16 121/23}
123/3 123/22 124/24
125/13 125/16 125/17]
125/21 125/25 126/14
127/17 128/3 128/6
129/11 129/12 129/14}
129/19 129/25 132/2
133/25 134/4 134/8
134/25 135/1 135/10
135/23 136/4 136/11
136/23 137/4 137/5
138/12 138/17 138/25}
140/23 143/21 143/25)
144/5 144/16 145/20
146/7 147/2 149/4

151/20 152/14 154/14I
154/21 156/7 156/11
156/14 157/20 159/24)
160/19 161/1 162/1
162/4 162/8 162/12
note [30] 27/5 34/21
36/15 48/14 48/17
55/25 56/1 65/25
72/20 80/22 81/2
81/18 83/8 84/1 84/10}
84/24 85/1 87/23
87/25 92/12 94/25
95/25 96/5 96/6 96/7
96/9 104/12 116/15
143/25 144/17
noted [14] 19/23 23/6I
29/9 35/7 35/16 35/18)
45/1 51/2 86/5 95/6
97/25 104/7 104/17
144/18
notes [3] 21/4 59/5
131/21
nothing [12] 23/23
42/2 49/8 109/21
131/4 133/10 133/17
134/20 135/7 135/15
137/18 145/8
notice [5] 41/25
59/23 72/22 94/7
110/6
notification [9] 22/7
77/15 90/14 93/19
94/3 95/20 116/1
116/2 116/4
notified [1] 90/7
notify [2] 73/4 90/20
noting [14] 21/6
22/19 22/25 23/9
23/11 26/8 33/13 39/5I
39/10 44/10 134/4
135/15 143/21 144/5
notwithstanding [1]
112/13
novel [1] 11/4
November [14] 27/3
47/4 102/10 103/22
108/4 108/21 112/11
112/13 123/10 124/7
140/21 161/12 161/13}
161/16
now [105] 13/12 17/8
24/1 24/11 25/9 25/14I
28/8 28/19 29/2 30/1
30/6 30/13 34/21 35/9I
35/21 36/20 37/24
39/7 39/11 39/15 40/4
40/24 42/9 42/12 43/5)
44/21 44/25 46/5
46/22 48/15 49/17
50/17 53/15 54/23
55/7 58/11 60/17 64/7I
64/15 64/23 65/8
66/10 67/23 69/4
71/24 72/9 73/20

(68) my... -now
N

now... [58] 74/24
74/25 76/2 77/3 77/16
84/4 88/15 88/22
90/11 91/21 91/25
92/11 92/25 93/6 93/8)
95/19 96/16 96/21
97/15 99/9 100/3
103/21 105/25 114/14}
115/19 117/2 118/15
120/11 120/14 121/18}
124/15 127/8 129/3
133/18 135/16 137/7
137/7 137/15 139/17
140/18 141/5 141/9
141/21 143/8 143/11
143/15 145/13 148/2
148/13 150/18 151/11
154/11 155/6 156/15
158/25 160/6 160/11
161/23

nuances [1] 127/6
number [27] 4/16 5/3
12/11 17/9 18/13
19/23 21/6 30/16
30/23 31/6 35/24
49/16 55/1 61/21
61/23 65/10 65/24
71/12 124/21 129/9
131/4 133/20 133/20
156/6 158/11 160/9
162/3

number 1 [1] 160/9
numbers [3] 146/4
146/4 160/3
numerous [1] 74/23

(e)

O'Sullivan [1] 8/23
objection [1] 161/25
objective [1] 10/1
objectives [1] 9/13
objects [1] 161/24
obligation [2] 95/9
124/2

obligations [3] 20/7
38/22 123/18
observations [1]
64/16

observed [1] 19/21
observer [1] 107/4
obstacles [2] 33/13
102/22

obtained [2] 3/8 3/9
obtaining [1] 44/16
obvious [3] 81/1
110/18 119/7
obviously [45] 2/3
5/2 8/12 17/12 17/23
21/15 21/19 23/1 24/9
26/16 29/1 30/6 34/1
34/2 36/16 38/9 43/21
48/5 49/2 49/16 52/21

56/6 57/19 63/15
68/25 73/22 78/25
85/16 93/13 96/1
99/19 107/19 113/3
116/8 125/9 125/12
126/16 127/15 130/6
130/19 131/23 137/6
145/3 152/12 160/2
occasion [3] 104/3
104/6 159/25
occasionally [1] 33/2
occasions [3] 19/24
65/24 141/1
occurred [5] 23/13
33/5 33/5 69/7 73/24
occurrence [1]
162/21
occurring [1] 147/19
October [8] 12/8
12/18 13/6 47/4 97/17
99/25 103/20 161/16
October/November
2013 [1] 47/4
odd [2] 45/23 145/5
Odgers [1] 18/1
off [9] 18/10 98/10
103/18 138/10 138/12)
138/18 139/24 145/24)
162/15
offence [1] 155/8
offered [1] 59/11
office [102] 2/19 4/9
4/23 6/23 8/14 8/14
9/13 10/12 11/12 12/5)
12/10 12/13 12/19
13/21 14/4 15/14
15/16 15/17 15/23
16/15 18/9 18/19
19/14 20/5 21/16 22/7)
24/22 24/25 30/18
30/24 31/8 33/9 33/12
36/4 37/2 37/8 37/10
38/2 38/15 38/17
38/20 40/5 40/8 40/16
41/25 42/15 42/17
47/11 48/23 49/23
53/25 59/1 60/2 60/7
60/13 62/8 62/21 63/5)
64/8 64/22 73/10
73/18 74/1 75/4 81/17
89/3 89/4 89/11 91/19)
92/23 94/9 94/15
94/21 95/7 95/7 95/9
95/11 98/25 101/3
101/23 101/25 106/21
110/16 111/21 111/25)
117/25 119/25 129/8
141/2 144/15 146/9
146/23 150/6 152/9
154/3 156/1 158/16
158/17 158/19 160/20)
160/24 161/1
Office's [9] 9/8 15/18
22/10 30/15 60/5

93/20 105/25 107/21
120/21
Officers [3] 78/12
91/16 94/21
offices [2] 21/16 37/3
officials [1] 158/19
offline [1] 138/9
often [6] 16/23 37/17
60/7 73/2 118/25
137/2
Oh [1] 162/16
okay [14] 5/22 23/24
55/15 87/20 87/24
122/12 142/3 142/9
142/10 142/21 143/2
145/19 150/18 150/24)
old [2] 147/10 162/7
Oliver [1] 28/15
on [381]
once [4] 4/21 18/25
39/17 103/4
one [64] 2/22 8/2
8/19 11/4 11/12 11/13
13/2 16/20 19/12 21/7
21/15 23/19 23/22
25/20 26/12 32/2
34/19 35/16 41/9
46/13 50/5 50/10
54/11 63/10 64/5
64/16 65/10 69/16
72/17 78/12 78/16
80/11 84/8 87/17
91/22 94/16 95/12
102/5 103/7 105/7
107/18 114/4 119/12
119/22 123/12 129/14
131/20 134/16 142/16
142/16 143/19 144/11
145/2 148/20 149/11
150/1 150/18 150/22
151/8 151/24 153/10
154/22 155/3 156/8
ones [2] 38/4 86/16
ongoing [3] 44/12
112/6 159/6
only [23] 3/1 3/2
20/18 27/18 29/7 47/3
52/20 61/10 64/4
78/13 80/11 96/10
97/20 98/6 102/5
103/4 114/13 115/6
118/1 131/16 144/5
144/17 154/12
onto [2] 3/15 75/9
onwards [5] 14/15
40/14 49/16 77/4
112/17
open [5] 97/13
116/11 122/20 124/14
131/24
opened [2] 70/24
113/13
operate [3] 62/13
105/1 110/23

operation [2] 19/18
20/10
operational [1]
110/16
operator [1] 62/2
opinion [1] 52/15
opportunities [2]
107/14 107/17
opportunity [5] 46/10)
82/17 93/25 109/12
136/3
opposed [1] 112/8
optimistic [1] 69/24
option [8] 108/7
108/8 108/9 110/3
111/19 113/21 113/24)
113/24
Option A [1] 108/7
Option B [2] 108/8
113/21
Option C [4] 108/9
110/3 111/19 113/24
options [6] 108/6
108/7 108/12 108/23
109/5 121/11
or [119] 7/5 9/7 10/12
12/16 14/5 16/5 18/10)
18/11 18/24 19/19
20/10 21/13 22/4
23/12 23/19 24/4 25/4,
26/6 26/21 27/13 28/6
29/17 29/23 30/16
32/24 33/5 33/15
33/18 36/10 36/10
36/25 37/7 37/7 37/7
37/7 37/12 37/16 41/6)
41/25 42/5 43/7 44/16
46/14 47/9 48/6 48/24)
50/4 50/4 52/16 56/1
58/19 61/9 62/1 62/8
67/4 69/6 69/10 69/11
69/17 70/4 70/10 73/4
75/14 79/18 81/16
89/5 89/10 91/1 92/12,
92/13 93/18 95/23
96/6 97/4 100/9
101/18 102/1 105/22
108/18 110/17 120/8
120/13 121/11 121/14
122/7 123/15 125/18
125/18 126/10 129/22)
131/20 132/5 132/10
133/19 134/16 134/17,
137/23 138/8 140/23
141/17 143/21 144/5
144/7 146/7 147/5
148/6 149/12 151/7
151/11 152/2 152/15
152/15 153/2 154/22
154/25 156/9 156/17
159/9 162/3
oral [9] 64/4 156/5
156/10 158/4 158/14
162/4 162/5 162/9

162/10
oratorical [1] 162/7
order [4] 22/25
106/19 141/5 160/16
ordered [1] 23/16
orderly [5] 21/19
21/24 68/5 68/7
138/21
ordinary [3] 9/15
47/1 47/5
organisation [2] 68/7
4112/1
organisations [1]
111/22
organise [1] 92/7
other [60] 9/7 9/9
19/17 21/22 23/22
24/23 26/12 28/13
28/20 28/24 29/2 29/6)
29/24 30/8 33/6 35/16
37/8 43/20 48/13 49/7I
52/24 58/9 62/19
69/17 73/5 78/11 80/5)
81/22 82/2 86/2 90/19I
92/14 96/21 97/8
101/17 101/19 102/15)
102/16 105/2 105/17
106/12 107/24 110/9
111/22 112/1 119/13
119/17 119/20 126/6
126/19 128/9 128/9
132/4 133/25 137/2
146/16 151/11 151/21
155/19 156/10
others [8] 9/4 23/3
26/7 66/23 67/4 80/25
86/7 159/7
otherwise [1] 155/7
ought [3] 83/20
151/13 153/3
our [39] 32/11 41/11
45/11 50/24 53/3
53/21 54/19 55/23
56/20 59/4 59/8 74/20)
75/17 77/7 78/4 78/9
78/10 79/25 80/2
81/25 82/12 82/19
83/17 84/11 86/22
89/15 103/10 104/25
105/1 110/5 110/19
110/24 111/1 117/17
120/23 123/18 132/13)
141/10 141/14
ours [1] 110/21
ourselves [1] 117/11
out [49] 5/1 6/18 6/19
9/1 9/12 10/1 12/7
12/24 16/8 20/11
21/10 22/15 26/11
29/1 32/13 33/3 33/9
37/24 41/8 41/24 49/2I
50/5 54/17 65/16 66/4I
67/17 68/14 75/3 76/4)
82/13 86/18 88/8

(59) now... - out
[e)

out... [17] 88/16
88/19 92/21 100/3
104/18 107/16 109/6
111/9 118/10 120/16
131/24 143/3 143/5
144/10 154/9 157/20
161/3
outcome [1] 35/14
outlined [2] 24/20
46/2
outlines [1] 83/16
outlining [1] 41/4
outputs [1] 59/11
outs [2] 29/11 66/25
outset [1] 11/6
outside [8] 10/5
18/18 18/19 68/23
68/24 69/8 98/25
115/7
Outward [1] 153/24
over [57] 2/25 8/20
17/21 20/3 20/7 20/8
21/3 21/6 22/4 23/21
23/22 28/11 30/15
31/14 31/21 33/25
35/5 35/25 44/14
44/16 48/11 52/2 54/9
55/23 62/9 62/15
67/11 72/17 83/14
83/21 94/25 95/2
97/22 99/4 99/5 99/6
102/23 104/10 104/15
104/25 109/24 111/7
113/16 113/20 117/14}
118/20 127/2 132/21
133/12 134/14 135/10
141/17 155/24 157/16
157/22 158/4 159/8
overall [3] 52/13 59/9
116/8
overlaying [1] 25/13
overly [1] 69/24
oversight [1] 67/6
overtook [1] 68/20
Owing [1] 156/19
own [10] 62/17 62/22
66/19 66/23 73/10
82/19 86/8 125/7
130/20 136/5
owned [1] 4/17

Pp

pace [2] 118/24
131/9

pack [2] 37/21
143/14

packed [2] 69/11
69/17

packs [2] 37/12
37/14

Paddison [2] 55/19
63/14

page [108] 1/15 1/16
2/13 2/14 2/22 2/25
3/6 3/7 13/25 20/3
20/7 20/8 21/3 21/3
21/4 21/6 23/19 23/21
24/16 28/8 28/9 28/10
31/21 34/9 35/5 35/25
36/1 37/21 37/25
39/14 44/2 44/3 44/4
44/5 44/8 44/14 44/21
47/23 48/11 48/12
48/15 53/15 54/9
55/16 58/24 62/9
62/15 62/16 62/16
63/13 69/19 70/20
72/17 74/18 74/18
79/2 79/3 79/3 83/14
83/14 83/15 83/21
83/23 84/6 84/19
85/16 88/2 88/24
94/25 95/2 97/22 99/5)
99/5 99/6 100/5 100/9)
100/20 104/10 104/15)
104/15 108/13 108/15)
110/1 111/14 113/18
113/20 114/24 116/21
117/14 122/13 122/14)
125/13 137/20 139/15)
140/1 140/2 140/4
140/6 140/18 143/9
143/12 151/22 157/8
157/16 157/16 157/22)
157/24 164/9
page 10 [3] 2/13 2/14
140/18
page 100 [2] 74/18
74/18
page 102 [1] 1/16
page 17 [1] 140/1
page 2 [4] 36/1 79/3
113/18 157/8
page 3 [8] 79/2 79/3
83/14 83/15 84/6
104/15 104/15 110/1
page 30 [1] 84/19
page 32 [2] 143/9
143/12
page 4 [8] 21/3 21/4
24/16 48/12 48/15
108/13 108/15 116/21
page 49 [1] 2/22
page 5 [1] 100/20
page 6 [2] 34/9 70/20
page 7 [5] 13/25 28/8
31/21 62/16 83/23
page 8 [6] 28/9 88/2
114/24 140/2 140/4
140/6
page 90 [4] 3/6 3/7
37/21 44/3
page 93 [2] 37/25
44/4
Page's [1] 139/16
pages [1] 158/9

paid [6] 7/5 7/6 7/10
7/12 86/10 115/7
panel [1] 139/13
paper [37] 22/19
22/21 23/3 29/22 39/4
44/9 45/1 69/1 70/3
77/25 90/6 91/9 91/13)
104/18 104/19 104/20
105/14 106/7 108/22
109/6 109/9 111/8
111/18 112/12 112/17
112/20 112/22 117/8
117/9 117/12 121/20
133/8 136/5 136/11
136/18 137/5 147/11
papers [41] 15/25
16/21 21/7 21/11
22/23 23/1 23/9 23/10)
23/11 23/16 25/1 25/3
25/23 26/2 26/8 26/12
27/9 29/16 34/25
39/10 68/25 69/20
69/22 69/24 73/25
99/20 105/18 111/15
112/17 116/9 126/18
134/13 135/14 135/16
135/21 143/20 143/22)
143/23 143/24 144/4
148/19
para [1] 89/1
paragraph [59] 2/11
2/12 2/13 2/16 2/22
2/25 3/4 3/7 4/6 11/2
14/1 16/22 17/17
17/19 18/4 19/16 31/3}
50/22 52/9 52/10 53/2
53/22 54/2 55/2 56/23
56/24 60/25 73/16
74/18 74/19 76/4 78/6
83/21 83/23 83/24
84/25 88/1 88/4 88/13
88/17 88/18 91/8 96/5
119/2 123/16 140/1
140/3 140/5 140/7
140/8 140/18 140/19
142/12 143/8 143/9
143/12 146/1 146/17
146/21
paragraph 11 [2]
146/17 146/21
paragraph 110 [1]
2/22
paragraph 111 [1]
2/25
paragraph 127 [1]
73/16
paragraph 140 [2]
76/4 119/2
paragraph 17 [2]
83/21 140/3
paragraph 18 [1]
140/8
Paragraph 2 [1]
146/1

paragraph 2.16 [2]
14/1 16/22
paragraph 201 [1]
3/4
paragraph 21 [4]
2/12 2/13 140/18
140/19
paragraph 218 [2]
74/18 74/19
paragraph 30 [4]
83/23 83/24 88/1
88/18
paragraph 31 [3]
84/25 88/4 88/17
paragraph 32 [1]
88/13
Paragraph 50 [1]
11/2
paragraph 54 [3]
177 17/19 18/4
paragraph 66 [3]
143/8 143/9 143/12
paragraphs [3]
145/23 145/24 146/15}
paragraphs 11 [1]
146/15
paragraphs 2 [1]
145/24
parameters [1]
128/19
Parliament [2] 67/15
135/9
Parliamentary [4]
18/11 64/21 149/24
150/3
part [29] 10/17 11/21
14/15 14/18 15/11
16/9 18/5 18/8 18/20
37/24 37/25 38/14
44/6 50/7 67/18 73/6
101/11 102/18 114/13}
118/3 133/5 133/16
134/6 138/1 143/14
146/20 153/21 155/4
155/13
participants [3]
156/22 158/8 160/4
participates [1]
162/25
participating [1]
162/17
participation [1]
160/2
particular [31] 13/22
16/12 27/13 27/19
32/19 47/4 49/15 53/5
54/24 59/20 63/3
66/18 67/7 68/2 71/10)
72/4 89/8 89/9 91/13
98/7 104/3 114/7
114/12 115/2 117/7
145/21 145/23 149/8
153/19 159/3 160/10
particularly [35] 7/24

8/25 15/6 30/5 32/2
34/20 36/11 36/19
39/1 43/6 46/24 46/25]
49/1 53/8 53/13 59/22)
60/4 60/18 63/8 69/10
69/11 69/16 74/12
86/5 90/4 90/8 90/17
90/21 93/24 101/17
107/18 111/1 120/16
129/21 138/13
parties [1] 126/19
partner [5] 30/22
98/13 101/21 116/23
117/13
partnerships [1]
105/2
parts [2] 130/22
139/24
party [7] 35/10 54/4
73/8 87/4 91/20 99/13
107/22
passage [3] 13/25
70/7 72/18
passages [5] 13/15
50/19 60/24 69/18
139/23
passed [2] 6/1 33/7
passing [1] 111/17
past [14] 54/13 54/21
57/1 57/4 57/5 77/5
83/18 104/10 104/13
106/4 133/10 136/8
160/6 163/2
paternity [1] 98/18
path [1] 8/5
patience [1] 127/2
Patrick [1] 8/22
Paula [37] 28/14 29/8
32/11 32/12 35/22
36/13 36/20 41/15
47/7 47/10 49/21
50/17 51/17 52/5
52/23 53/16 55/20
56/14 56/19 63/14
66/21 69/3 71/11
79/15 80/17 84/10
110/12 111/9 112/8
125/3 126/23 127/24
128/21 131/3 134/10
134/16 148/19
Paula's [1] 48/9
pause [1] 85/12
pausing [1] 48/21
pay [4] 82/12 146/13
149/16 149/20
paying [2] 63/2 156/1
peculiar [1] 151/8
pending [1] 35/14
pension [4] 6/3 9/21
43/13 46/15
pensions [1] 43/10
penultimate [2] 31/3
62/16
people [37] 6/24 9/23)

(60) out... - people
P

people... [35] 16/7
27/20 40/8 55/1 59/2
59/6 67/8 67/25 72/14
75/4 75/14 75/14
95/24 97/13 98/11
99/11 125/10 130/20
133/13 133/22 138/1
138/6 139/20 144/7
144/20 144/24 147/3
147/25 149/19 150/24}
151/21 155/25 159/10
161/3 161/17
people's [1] 160/23
per [9] 13/10 23/14
33/21 61/23 92/7 96/9
116/13 159/11 161/9
per se [5] 13/10
23/14 33/21 96/9
116/13
performance [2]
67/22 67/25
performed [1] 21/23
performing [1] 15/21
perhaps [22] 1/23
2/4 10/10 17/18 24/8
30/8 46/19 48/12
55/16 89/6 90/18
92/17 110/18 125/19
125/23 126/5 126/5
129/22 130/9 130/16
151/11 160/13
period [19] 6/20 18/7
19/7 31/14 46/23 47/5
65/6 76/16 98/16
98/25 99/2 100/23
103/1 108/3 109/11
148/24 152/11 158/3
162/23
periods [1] 99/3
Perkins [15] 26/5
26/8 41/14 68/19 85/4
92/3 110/2 123/9
123/15 124/8 126/23
134/16 136/16 137/22
139/1
Permanent [3] 3/16
17/7 26/9
person [9] 15/3 42/4
71/20 75/24 93/23
107/3 125/17 139/3
162/25
personal [6] 7/4 8/6
8/8 15/9 88/9 89/18
personalities [1]
65/13
personally [6] 43/14
90/17 91/24 102/16
102/25 121/24
perspective [8] 8/22
9/7 9/9 15/22 49/18
118/4 153/22 159/17
Peter [1] 47/10

phase [23] 97/12
155/22 156/6 156/7
156/15 156/17 156/17)
157/1 157/11 157/13
157/16 157/19 157/23}
157/25 158/13 158/14)
158/18 158/24 159/17)
161/8 161/15 161/21
162/18
Phase 2 [3] 157/1
157/11 157/13
Phase 3 [3] 157/16
157/19 157/23
Phase 4 [1] 157/25
Phase 5 [2] 156/6
156/17
Phase 7 [9] 155/22
156/7 156/17 158/13
158/18 159/17 161/8
161/15 161/21
phases [10] 155/11
155/14 155/18 155/19)
155/19 155/23 156/10
156/15 156/19 156/24}
Phases 5 [4] 155/14
155/23 156/15 156/19
phone [2] 7/2 149/15
phrase [1] 14/20
phrased [1] 125/11
phrasing [1] 70/18
physical [2] 8/9 8/16
physically [2] 6/21
102/17
PI [2] 81/22 89/2
pick [5] 24/8 89/7
125/6 138/9 149/24
picture [2] 41/1 48/3
piece [2] 119/3 119/5
pieces [2] 40/25 77/1
pile [1] 81/12
pin [1] 87/1
pitches [1] 158/12
place [11] 34/12 62/2
75/1 88/11 98/21
100/7 106/16 107/10
107/25 116/2 121/13
placed [2] 30/8 78/14
places [1] 34/19
Plan [1] 97/22
planning [1] 31/17
plausible [1] 128/16
play [2] 6/18 48/4
played [1] 6/18
playing [1] 65/16
plead [1] 147/4
pleaded [1] 44/13
pleasantly [1] 75/10
please [74] 1/10
17/18 19/8 20/3 20/7
21/3 23/18 24/16 30/9)
34/6 34/9 35/5 35/21
35/25 37/19 37/20
44/5 46/22 47/22
47/24 50/16 53/14

53/15 54/6 54/9 56/8
62/15 65/21 70/7
70/14 70/15 70/15
72/17 73/15 74/17
77/16 79/2 80/15
83/23 84/10 84/17
84/21 87/14 88/1
88/22 91/7 91/21 92/6
94/6 95/3 97/23
104/15 108/5 108/13
110/1 110/11 113/9
113/9 113/18 114/8
114/24 117/14 123/7
126/20 139/24 140/3
140/18 141/7 141/8
157/9 157/16 157/22
157/24 161/4
pleased [1] 129/21
plus [2] 16/14 143/4
pm [6] 77/10 77/12
103/14 103/16 126/24
163/12
point [54] 14/21
34/24 42/6 45/8 48/16
49/9 49/19 51/11
51/24 52/21 54/15
59/21 63/23 63/24
74/13 75/1 75/7 75/12
75/21 77/4 79/11 86/7
91/14 92/9 96/11
99/25 101/6 101/6
101/13 101/16 105/15}
105/21 109/19 111/4
114/5 116/6 116/14
118/14 121/25 125/19}
126/13 127/13 131/1
132/1 133/7 134/5
145/9 146/5 149/4
152/17 153/18 153/21
159/12 160/13
pointed [1] 54/17
points [5] 54/10
65/10 79/23 91/13
130/23
POL [8] 136/22
140/11 140/20 141/21
146/12 146/18 146/23
147/2
POL's [1] 142/19
POLO00 [1] 23/18
POL00006590 [1]
87/14
POL00021506 [1]
20/16
POL00021507 [1]
23/25
POL00021516 [1]
65/22
POL00021520 [2]
103/23 106/3
POL00021522 [1]
113/9
POL00021523 [1]
114/8

POL0002158 [1] 34/6
POL00027136 [1]
100/19
POL00027483 [1]
104/20
POL00030724 [1]
116/20
POL00046944 [1]
19/9
POL00096747 [1]
35/8
POL00099121 [3]
53/14 56/12 56/17
POL00099330 [1]
TINT
POL00099331 [1]
78/20
POL00103348 [3]
37/19 44/3 45/21
POL00112856 [1]
94/4
POL001381414 [1]
111/13
POL00141382 [1]
145/13
POL00145185 [1]
50/17
POL00145882 [1]
84/5
POL00158089 [1]
97/18
POL00167751 [1]
108/13
POL00167917 [1]
46/23
POL00193010 [1]
88/22
POL00295498 [1]
35/21
POL00296944 [1]
126/21
POL00297468 [1]
55/18
POL00297469 [2]
56/8 58/22
POL00297470 [1]
60/12
POL00298004 [1]
83/2
POL00382001 [1]
123/7
POL00428835 [2]
91/21 91/25
POLB12 [1] 21/1
POLB12/44 [1] 21/1
police [1] 63/1
policies [2] 78/11
80/25
policy [13] 62/14
78/13 78/15 79/24
80/5 80/11 81/7 81/9
81/20 81/22 113/19
113/22 121/11
populist [3] 131/12

131/15 132/6
portfolio [1] 7/18
portrayed [1] 132/15
posed [1] 61/5
position [25] 7/23
11/3 14/4 67/15 72/19)
72/23 73/2 77/20 84/1
88/5 93/16 95/20
111/9 114/21 115/21
124/17 129/14 140/16)
141/2 142/23 143/1
145/4 148/25 151/22
159/19
positioned [1]
135/22
positions [1] 111/5
positive [1] 54/8
possible [14] 27/24
27/25 32/3 33/13
47/18 54/13 62/3 80/5)
82/1 94/23 141/14
159/19 160/5 160/15
possibly [4] 32/22
47/9 80/5 126/7
post [109] 2/18 4/9
4/23 5/10 8/13 8/14
9/8 9/13 10/12 11/12
12/5 12/10 12/12
12/19 13/21 14/3
15/14 15/15 15/17
15/17 15/22 16/15
18/9 19/13 20/4 21/15)
22/7 22/10 24/21
24/25 30/15 30/18
30/24 31/7 33/12 37/2
37/8 37/10 38/2 38/15}
38/16 38/20 40/5 40/8
40/16 41/25 42/14
42/17 47/11 48/23
49/22 53/25 59/1 60/1
60/4 60/7 60/13 62/8
62/21 63/5 64/8 64/22
73/10 73/17 74/1 75/4I
81/17 88/14 89/2 89/4I
89/11 91/19 92/23
93/20 94/9 94/15
94/21 95/6 95/7 95/9
95/11 97/24 98/25
101/3 101/25 105/25
106/21 107/21 110/16)
111/21 111/25 117/25)
119/25 120/21 129/8
141/2 144/15 146/9
146/23 150/6 152/9
154/2 156/1 158/16
158/17 158/19 160/20)
160/24 161/41
Post-Funding [1]
97/24
Postal [11] 4/3 4/21
5/3 6/1 18/2 32/21
34/3 35/23 38/25
45/22 45/23
postmasters [1]

(61) people... - postmasters
Pp

postmasters... [1]
117/18
postmasters' [1]
160/9

potential [5] 40/3
80/8 90/13 105/10
161/17

potentially [4] 54/11
90/11 94/18 95/14
power [1] 62/1

PowerPoint [2] 157/7

158/7
practical [1] 26/1
practice [3] 74/7
120/12 158/15
practices [1] 120/22
praise [1] 163/1
pre [3] 22/13 66/6
152/11
pre-2012 [1] 152/11
pre-action [1] 22/13
precise [1] 98/13
precisely [1] 122/19
predisposed [1]
132/10
prefer [1] 155/1
preference [1] 30/1
preferred [2] 81/8
113/24
pregnant [1] 6/7
preliminary [1] 13/18
premia [1] 80/6
premise [1] 118/10
premiums [2] 82/12
82/15
preparation [2] 18/10
124/15
prepare [1] 99/11
prepared [4] 13/13
48/2 95/1 104/20
present [26] 6/21
24/2 34/8 65/25 66/1
66/2 83/19 97/19 98/6
99/16 100/9 102/18
105/13 105/16 113/11
114/12 114/13 114/22)
115/1 115/17 136/9
136/11 136/17 137/5
160/7 160/9
presentation [2]
157/7 158/7
presented [5] 29/16
69/3 69/22 135/9
135/23
presenting [2] 75/14
136/5
preservation [1]
108/8
press [7] 41/25 59/16
59/23 59/25 59/25
60/5 60/20
pressure [1] 81/12

presumably [6]
36/21 40/15 55/20
90/14 129/2 131/20
pretty [1] 93/21
previous [8] 31/13
47/18 55/21 56/5
56/11 79/5 109/3
112/9
previously [2] 88/18
94/14
primarily [1] 120/21
principal [2] 38/14
155/13
principally [1] 107/11
prior [7] 5/7 12/17
33/2 36/24 48/14
101/16 119/23
priorities [1] 23/8
priority [3] 9/19
65/18 65/19
private [2] 48/5
120/13
privilege [1] 150/4
Privileged [1] 141/16
proactive [1] 74/23
probably [4] 70/19
89/6 115/23 138/7
probing [1] 42/7
problem [5] 65/2
65/5 82/16 149/21
150/3
problems [14] 51/7
91/1 94/13 94/17
95/13 118/20 119/4
119/15 143/7 144/21
147/15 147/25 150/24)
151/1
procedures [1]
158/16
process [8] 6/4 11/17)
15/13 80/10 82/7
82/17 87/3 99/15
processes [9] 22/11
33/16 59/4 61/10
61/19 82/19 90/24
129/8 142/20
processing [1] 59/7
Procurator [2] 122/7
154/2
produce [2] 37/12
142/5
produced [1] 29/23
product [1] 110/16
professional [5]
91/17 115/3 115/5
115/9 115/14
professionalism [1]
52/13
profile [3] 73/3 90/3
123/23
programme [6] 12/25]
41/24 72/11 82/25
83/9 84/11
progress [1] 104/8

project [12] 99/8
99/17 100/12 100/21
100/25 101/8 104/8

115/21 159/13
projects [1] 120/8
promised [4] 34/13
55/21 72/20 84/19
promising [1] 159/12
promote [1] 24/25
propensity [1] 132/9
proper [4] 87/3 135/6
135/15 160/16
properly [2] 2/2
127/1
proposal [1] 115/14
proposes [1] 26/25
proposing [1] 29/20
prosecute [3] 20/5
121/16 147/2
prosecuted [5] 12/13
30/18 30/24 133/13
154/4
prosecutes [2] 75/4
95/7
prosecuting [5]
62/21 62/24 73/18
110/8 153/25
prosecution [13]
38/24 45/25 63/1
70/25 83/15 94/16
94/19 94/22 95/12
107/22 108/10 113/19}
121/11
prosecutions [29]
38/17 39/25 40/9
48/19 49/5 54/13 57/2
57/4 57/5 62/17 71/2
77/5 83/19 95/3 95/8
104/11 104/11 104/14
106/4 106/5 106/7
108/23 112/19 113/22
133/10 133/15 136/9
154/3 154/6
provable [1] 118/1
provide [7] 13/17
54/21 67/6 79/13
80/13 109/5 115/13
provided [6] 5/9 5/14
51/6 82/25 104/1
116/10
provides [2] 83/8
84/2
providing [1] 84/11
prudent [3] 76/6
89/14 119/18
public [9] 41/25
53/11 62/20 63/5
63/23 105/3 127/16
128/1 156/22
publication [1]
135/19
published [4] 67/13

progressed [1] 99/14

114/15 114/23 114/25)

158/5 158/23 161/20
publishing [1]
156/25

purportedly [1] 31/9
purpose [4] 3/23
12/7 13/15 13/17
purposely [1] 15/23
purposes [1] 155/22
pursued [1] 53/6
pursuing [1] 10/5
pushed [1] 27/2

put [21] 16/13 18/25
19/5 40/13 46/17
63/16 65/4 67/14
68/16 76/24 85/6
99/13 101/1 105/24
106/16 123/3 125/1
125/10 132/3 135/13
135/14

puts [2] 130/25 134/3

Q
Q4 [1] 24/7
Q4-2011 [1] 24/7
quarterly [1] 120/7
question [19] 60/13
61/5 61/14 62/23 79/8)
79/17 81/5 81/16
86/17 89/2 89/4 94/14)
119/5 136/21 148/2
150/1 153/11 153/25
154/15
Questioned [8] 1/8
121/8 122/14 139/7
164/5 164/7 164/9
164/11
questions [16] 18/12
59/10 60/11 64/21
69/25 80/23 104/25
121/6 121/9 136/1
136/12 150/13 150/25)
154/19 155/4 156/2
quick [3] 53/16 79/19
94/3
quickly [5] 48/13
58/8 62/3 69/10 78/25)
quite [35] 10/14
21/12 21/14 23/7 26/1
29/6 36/16 41/11
43/14 49/23 51/25
53/1 70/17 70/18
71/23 74/3 75/13 86/8
86/10 90/14 109/16
119/7 120/15 124/11
125/7 135/17 138/7
139/3 141/12 145/7
147/8 151/10 154/21
155/20 161/12
quo [1] 108/8
quote [1] 70/19

R

raft [1] 89/17
raise [5] 22/17 59/10

104/25 142/14 144/7
raised [12] 13/4
29/24 31/23 54/3 61/9I
72/23 80/23 83/11
93/22 115/1 144/16
147/9
raising [1] 64/20
range [3] 36/16 37/4
76/23
rapidly [1] 149/14
rate [4] 159/11
rather [12] 35/18
47/21 52/15 57/13
63/3 81/21 85/1 91/9
110/16 123/15 129/15)
143/16
re [3] 80/24 123/18
123/19
reach [1] 97/14
reached [2] 33/3
106/8
reaction [1] 126/22
reactions [2] 160/8
160/10
read [44] 3/1 3/9
13/14 15/8 23/2 23/12)
29/2 39/3 50/18 53/12
54/10 57/8 58/1 58/1
58/8 58/16 58/20
59/13 59/25 60/14
60/24 63/6 73/24 81/9
82/22 85/16 86/4
99/20 105/18 111/17
112/17 130/6 132/1
135/17 142/9 143/16
144/7 144/18 150/15
155/17 156/14 157/3
157/10 157/20
reader [3] 117/8
137/3 137/8
reading [8] 36/20
59/17 78/22 86/25
124/25 129/25 140/23)
156/24
reads [1] 144/7
ready [1] 64/9
real [6] 9/19 16/9
92/19 102/19 146/11
147/25
realised [1] 3/4
really [26] 6/20 9/20
10/25 10/25 11/17
25/7 41/11 41/22 42/1
43/10 51/25 58/8 67/5
67/22 68/9 69/7 73/12)
96/9 130/4 135/20
138/3 150/24 151/8
151/13 154/14 160/23)
realtime [1] 65/17
reason [9] 27/15 32/5)
101/1 101/11 114/12
125/20 128/3 128/3
156/9
reasonably [5] 42/24

(62) postmasters... - reasonably
R

reasonably... [4] 60/6

160/14 161/20 162/5
reasons [6] 16/20
24/20 38/8 50/5
111/19 133/11
reassured [6] 35/2
139/25 151/9 151/9
151/9 153/3
recall [68] 2/14 12/25
13/6 15/6 22/21 23/4
25/14 28/25 29/10
30/5 34/15 34/17
34/20 36/9 36/11
36/19 38/8 38/9 39/1
44/21 44/22 45/6 45/7)
47/15 56/3 58/1 58/3
58/8 60/4 60/15 60/18
63/2 63/8 63/24 64/1
66/25 67/18 68/24
69/12 69/16 71/9
71/10 72/23 72/25
73/12 73/24 78/21
83/3 83/5 85/13 85/17,
95/17 98/6 111/4
113/23 114/14 115/16}
116/21 121/20 121/20
126/1 127/8 128/14
131/19 139/3 139/4
140/23 145/1
receipt [3] 50/16
51/10 57/24
receive [2] 27/8
134/25
received [14] 7/7
15/25 22/3 22/7 23/17)
41/18 57/8 69/20
86/19 94/6 96/17
136/5 155/18 159/15
receiving [4] 56/3
78/21 86/11 135/21
recent [1] 30/24
recently [2] 4/19
131/16
recipient [1] 108/18
recipients [2] 84/8
159/8
recollect [1] 25/6
recollection [22]
16/20 17/23 17/24
18/16 21/24 35/20
38/5 38/24 42/1 43/4
51/13 51/25 57/12
66/11 66/14 67/2
72/25 89/13 98/18
121/18 132/20 136/25
recollections [2]
130/21 131/24
recommendations
[1] 94/12
reconciliation [2]
62/6 62/7
reconsider [2] 62/24

115/11
record [7] 6/16 85/6
92/14 155/17 156/14
157/3 157/10
recording [1] 131/22
records [1] 19/23
rectify [1] 62/3
redacted [2] 23/22
58/4
redress [1] 158/22
reduced [1] 162/19
refer [7] 20/1 36/4
40/1 40/3 139/25
141/7 143/13
reference [18] 34/9
51/9 51/19 57/3 71/8
72/4 83/22 84/18
91/22 100/8 116/18
128/20 140/21 141/6
141/20 142/7 142/11
160/12
referenced [3] 32/10
125/5 149/8
references [2] 32/6
90/10
referencing [1]
127/19
referred [8] 24/17
40/7 140/20 143/8
143/19 150/2 152/7
154/4
referring [8] 24/5
48/23 105/9 108/16
130/8 141/1 141/15
148/21
refers [2] 88/11
91/17
refilled [1] 15/1
reflect [6] 29/4 59/23
75/21 77/3 137/11
138/14
reflected [2] 136/19
136/23
reflecting [1] 67/23
reflection [7] 25/9
42/10 59/14 70/9 76/9)
121/1 145/3
reflections [4] 41/9
76/25 107/17 131/25
reflective [1] 39/12
regard [1] 52/19
regarding [3] 61/9
107/21 114/22
regardless [2] 73/3
146/13
regime [1] 160/9
register [2] 105/25
161/24
registers [2] 121/3
121/4
regret [2] 41/10
145/3
regular [4] 33/7
33/22 36/21 37/9

regularly [5] 19/21
33/2 36/13 37/3 65/7
regulation [1] 6/3
rejected [1] 142/23
rejecting [1] 81/25
rejoined [1] 109/13
relate [2] 84/3 155/19
related [7] 18/9 31/11
51/7 73/11 73/14
119/10 127/13
relates [4] 54/12
56/25 110/15 148/2
relating [15] 3/8 3/10
13/18 13/20 28/11
39/24 46/24 62/10
64/13 65/14 77/19
104/21 104/23 115/21
157/13
relation [18] 12/24
29/13 47/24 52/13
53/8 58/15 76/20 88/7
95/4 100/6 102/23
120/6 120/7 140/16
142/25 147/21 157/19
158/17
relationship [6] 8/9
8/11 85/24 85/25
97/24 132/21
relative [1] 124/22
relatively [4] 11/19
21/12 115/20 140/21
releases [1] 60/20
relevant [8] 3/23 4/19)
32/25 33/6 94/18
95/14 117/25 125/8
reliable [2] 117/21
118/6
reliance [1] 132/3
remain [1] 22/13
remained [1] 43/13
remaining [2] 55/25
56/25
remains [1] 36/7
remember [18] 37/14
44/24 46/20 69/4 72/5
86/6 90/1 90/8 90/18
90/20 112/22 114/2
114/6 120/10 121/21
125/24 131/2 132/7
Remembers [1]
131/3
reminded [1] 114/17
remit [1] 11/6
remote [1] 20/1
remuneration [4] 7/7
7/13 7/14 14/5
reopen [1] 54/13
repaid [1] 147/2
repay [1] 146/18
repeat [1] 159/25
repetition [1] 159/25
replace [1] 101/18
replaced [2] 17/25
106/19

replacement [4] 98/2
106/16 106/20 106/21
replied [1] 111/11
reply [4] 81/5 81/11
111/13 112/24
replying [1] 111/11
report [93] 16/25
21/8 21/25 22/2 35/6
35/8 35/9 35/17 37/23
39/18 40/4 44/1 46/2
49/3 50/15 50/16
51/12 51/20 51/21
52/4 52/8 52/12 52/19)
53/9 54/20 54/25 55/6)
55/22 56/7 56/13 57/2)
57/9 57/14 57/25 58/1
58/2 58/17 59/13
59/14 59/18 59/24
60/3 60/8 60/22 62/4
63/4 63/6 63/18 63/21
63/25 64/13 65/14
66/21 67/13 70/13
72/2 72/9 74/16 76/8
82/13 83/1 83/2 83/20)
87/15 89/17 90/13
96/18 97/2 99/7
100/20 118/22 119/10
119/11 119/20 120/18}
123/22 127/16 129/5
129/20 132/15 134/4
135/8 135/19 142/1
142/4 150/16 150/19
151/6 152/18 153/22
154/10 158/22 161/7
reported [10] 17/4
17/6 17/7 17/11 26/11
26/15 51/16 115/12
124/24 134/10
reporting [11] 17/15
17/20 18/1 82/18
119/23 119/25 120/6
120/9 128/5 130/19
131/13
reports [12] 19/21
31/16 38/3 39/9 40/1
40/6 59/25 60/5
129/23 134/8 134/13
144/19
represent [2] 28/4
139/19
representation [1]
24/21
representative [22]
4/22 6/6 7/8 9/2 10/12
11/9 11/13 11/15
15/20 25/11 26/14
26/19 27/6 65/1 98/2
99/22 100/24 101/2
105/12 109/20 109/23}
123/19
representatives [1]
24/22
represented [1] 40/8
representing [2] 26/6

100/15
reputational [1]
54/11
request [4] 12/9
30/13 88/14 104/12
requested [3] 83/25
88/6 143/25
requests [1] 156/21
require [1] 26/18
required [4] 7/1 27/8
62/8 133/23
requirement [1]
115/8
requires [1] 146/9
research [2] 159/2
159/13
resend [1] 84/17
reset [1] 10/16
resign [2] 50/6
101/15
resistance [1] 15/15
resolution [1] 82/20
resolve [1] 87/8
respect [5] 53/5
95/15 118/18 120/18
125/13
responding [1] 79/4
responds [2] 79/21
84/22
response [13] 53/21
80/18 81/14 84/11
84/13 88/14 91/5 92/2I
125/7 131/9 142/25
159/11 160/5
responsibilities [3]
9/16 24/23 74/9
responsible [9]
66/22 67/9 68/11 70/3
75/24 106/25 115/7
121/2 154/10
restaurant [1] 66/7
result [2] 62/1 82/14
resulted [3] 12/11
30/16 149/15
resulting [1] 91/20
resume [1] 103/11
retention [1] 62/14
retired [1] 125/18
retreat [1] 163/7
return [1] 158/20
returned [2] 42/19
159/10
revealed [2] 94/13
136/14
revenue [1] 105/22
reverse [1] 82/16
review [31] 25/12
35/11 36/5 51/2 53/21
54/12 57/1 59/3 59/5
59/8 61/6 61/9 61/11
61/12 61/18 61/22
70/24 71/5 71/14
72/22 83/15 83/22
84/3 85/10 88/7 88/10

(63) reasonably... - review
R

review... [5] 88/16
94/11 113/19 114/18
133/2
reviewers [1] 61/22
reviewing [2] 83/18
95/8
reviews [3] 83/13
119/14 152/19
rhythm [1] 46/7
Rich [1] 30/22
Richard [12] 17/21
17/23 17/25 27/5
107/9 109/24 113/3
113/14 114/11 130/17)
130/25 131/17
right [46] 2/7 3/22
7/19 14/7 16/5 18/14
23/1 23/24 33/1 33/21
38/18 39/4 61/11
62/22 64/4 82/4 98/17,
99/1 99/17 100/18
103/11 118/11 121/12
126/20 128/24 133/3
134/9 134/24 135/16
137/20 139/21 141/16}
145/10 145/19 148/3
148/5 150/11 151/5
151/19 152/7 154/11
154/21 157/14 157/21
158/1 163/11
right-hand [2] 141/16
157/14
rightly [1] 65/18
rigorous [2] 138/9
139/15
risk [41] 14/5 14/9
24/15 43/3 43/16
43/19 46/14 73/3 80/8
89/22 90/3 94/20
97/10 104/17 104/23
105/9 105/25 106/6
106/14 107/12 108/17)
108/22 108/25 109/2
109/4 109/7 109/9
109/13 109/20 109/25}
111/16 119/23 120/6
120/9 120/21 120/23
120/23 121/3 121/4
129/3 135/22
risks [11] 54/12 70/5
70/15 70/15 96/12
115/4 117/25 119/25
120/18 129/24 130/3
RMPS [1] 2/17
robust [10] 42/2
74/20 75/5 75/12
75/17 127/4 127/10
127/20 145/8 151/1
robustness [4] 41/20
104/25 140/13 140/22)
Rod [1] 141/21
Roger [3] 15/2 17/4

58/14
role [44] 2/20 4/15
5/10 6/15 7/5 7/5 7/6
8/17 8/21 9/1 9/6 9/14
10/5 10/8 11/22 14/1
14/24 15/1 15/21 16/6
17/6 17/12 19/1 19/3
24/18 26/5 28/4 42/21
42/22 43/18 50/3 67/5)
92/20 97/23 99/2
101/12 101/17 101/19)
102/17 105/17 107/22)
107/24 120/4 138/2
roles [1] 98/14
room [9] 10/18 67/7
69/6 69/7 69/8 69/9
93/9 114/2 163/4
rooms [1] 25/20
root [1] 51/7
roughly [1] 20/22
round [2] 9/9 111/9
route [1] 110/7
routes [1] 54/17
routinely [6] 18/8
18/19 31/25 32/13
46/12 113/1
Royal [15] 4/3 4/12
4/20 5/4 11/12 12/18
18/2 27/20 35/23
72/21 73/7 78/14 80/2
80/11 152/13
rule [3] 32/13 117/14
156/20
Rule 9 [1] 156/20
run [5] 31/17 62/16
76/14 156/2 161/12
running [2] 67/9
76/18
rush [3] 63/19 68/3
161/11
rushed [2] 67/12
69/10
Russell [9] 17/4 17/6
17/12 18/3 98/3 100/1
100/6 100/8 106/24

s

safeguard [1] 62/19
safety [1] 23/4

said [46] 6/25 9/7
9/23 11/8 24/2 26/4
26/23 27/12 27/12
38/15 41/17 46/6 56/4
58/1 60/22 63/2 73/22
77/14 87/22 93/9
102/20 103/3 105/6
106/23 107/7 114/6
116/8 117/21 122/25
125/15 125/25 127/4
127/24 128/9 128/14
132/5 134/18 137/3
138/10 139/1 143/15
145/3 152/19 153/21
160/20 162/13

salary [2] 7/9 7/12
same [9] 20/22 24/23
56/14 104/4 125/13
126/10 126/10 146/4
148/1
Sarah [2] 55/19
63/14
satisfactory [2]
103/6 110/7
Saturday [3] 55/7
55/10 87/21
saving [1] 82/17
saving/process [1]
82/17
saw [12] 10/8 22/19
31/15 40/6 41/2 54/24
55/12 90/10 91/12
91/22 103/4 131/16
say [53] 10/23 11/2
20/4 23/5 27/19 32/5
33/25 39/4 46/13
51/23 57/7 58/18
58/20 60/23 65/15
68/15 73/16 74/19
93/21 100/11 101/14
107/19 111/14 121/19]
122/18 123/1 124/16
124/19 127/9 129/5
129/11 129/15 129/22
130/5 131/22 132/8
135/21 138/7 138/19
139/8 139/10 146/8
147/18 149/21 151/7
151/15 154/7 155/20
160/3 160/11 160/14
161/8 162/10
saying [40] 4/20 6/5
7/24 15/5 16/10 18/14
23/16 33/21 36/12
41/14 42/17 52/5
56/19 59/19 59/20
61/6 70/14 75/15
87/18 89/17 90/17
92/16 95/22 96/4 97/7
118/13 132/4 142/3
143/6 144/3 144/20
144/20 144/23 145/9
147/10 147/13 147/15
147/25 148/14 150/19}
says [67] 2/16 3/8
13/16 14/13 18/4
19/16 22/6 22/15
24/19 26/12 27/23
28/13 30/11 31/12
34/10 35/9 38/1 49/7
50/22 52/10 53/17
54/6 54/10 55/20
56/23 58/24 60/25
61/8 61/17 62/12
62/18 70/23 77/22
78/7 78/24 79/7 79/15
79/22 80/19 81/15
83/6 83/24 84/15
84/22 85/5 86/25 87/5

88/5 88/25 91/6 91/11

97/24 98/4 110/3
110/13 110/22 115/2
117/15 117/19 128/8
129/13 131/1 146/21
scale [3] 61/25
110/19 156/19
scenes [1] 130/10
scheme [7] 6/3 77/1
90/23 114/19 119/17
159/5 160/10
schemes [2] 158/21
158/22
scope [1] 128/18
Scotland [3] 121/15
122/4 154/2
screen [8] 1/24 17/19)
44/1 60/15 140/3
141/18 141/12 162/3
scroll [50] 19/14 20/3
20/7 20/25 21/3 23/21
23/22 24/12 31/2
31/21 47/6 48/11 49/4
49/5 54/6 54/9 56/18
57/24 61/14 62/9
72/17 74/18 79/3
79/14 79/21 80/17
81/14 83/12 84/7
84/13 88/19 88/24
91/5 91/10 92/2 92/4
97/20 97/23 99/4
100/7 104/6 110/1
110/22 113/12 113/18}
114/15 114/24 117/14
123/14 130/16
scrolling [3] 83/21
84/21 99/5
scrutinise [1] 76/13
scrutinised [1] 116/4
scrutinising [1] 75/5
scrutiny [2] 74/21
75/17
se [5] 13/10 23/14
33/21 96/9 116/13
seated [1] 27/10
second [80] 29/7
30/3 34/13 36/6 39/17
40/21 41/6 47/11 49/2
49/9 50/15 50/21
50/22 51/12 51/20
52/17 53/15 53/22
55/22 55/24 57/8
57/25 58/16 58/24
59/13 59/18 60/2
60/25 63/13 64/13
65/14 66/20 70/13
71/5 72/2 72/2 74/10
74/15 77/2 77/7 78/2
78/4 83/13 83/20 85/9
85/14 85/20 86/1 87/1
87/1 89/16 90/12
91/14 96/18 97/1
100/5 118/22 119/9

92/4 92/13 94/10 95/5)

119/20 127/20 128/15}
128/22 129/1 129/18
130/3 130/25 132/14
132/21 133/2 133/11
134/6 134/7 134/11
135/11 135/18 141/15)
150/16 151/6 151/12
152/17
secondly [3] 80/2
81/2 155/16
secondment [1] 3/24
seconds [1] 152/24
secretary [8] 3/16
9/11 9/25 17/7 23/15
26/9 98/12 137/1
section [15] 22/3
24/17 28/12 36/1 44/4I
49/4 62/9 70/20 78/6
83/12 88/2 95/3 97/21
99/7 100/21
sections [1] 52/11
sector [1] 120/14
see [104] 7/3 9/10
10/5 10/20 18/13
18/19 18/22 19/9
19/14 20/3 20/17
20/25 21/6 21/21
21/23 23/20 23/23
24/12 31/2 32/17 34/8)
34/9 35/5 35/7 39/14
40/17 40/19 40/25
41/1 42/3 44/1 44/7
45/21 47/6 47/22 48/1
48/11 48/15 49/5
51/15 51/18 53/2
56/12 56/17 56/18
60/6 64/7 69/19 74/8
77/21 79/3 83/12
83/15 84/6 84/7 84/13}
86/17 88/3 88/19 91/5I
91/7 92/2 92/4 92/15
94/25 96/18 96/21
96/22 97/20 98/16
99/4 100/19 100/21
103/17 103/24 104/6
104/10 104/16 105/14I
106/9 108/15 110/1
113/12 113/20 114/15)
417/12 117/14 123/5
124/16 131/4 134/20
140/25 141/16 141/20)
142/6 142/8 143/3
143/17 145/8 146/3
149/9 161/13 163/4
163/9
seeing [3] 63/8
116/13 117/8
seek [2] 33/9 156/20
seeking [2] 22/12
87/10
seem [3] 84/16
111/18 115/19
seemed [2] 81/2
108/6

(64) review... - seemed
Ss

79/14 81/19 111/20
129/21

seen [42] 14/11
32/19 32/22 40/19
41/2 42/12 49/12
49/17 51/14 51/23

64/24 70/22 72/9
73/22 74/15 86/10
92/11 93/3 93/15
93/24 94/5 96/10
103/2 112/12 112/15
116/9 116/14 117/2
121/4 123/5 123/10

124/21 126/18 130/7
149/4

Select [8] 31/8 32/7
36/18 125/2 125/5
125/6 148/14 149/6
selected [1] 4/14
send [3] 50/18 50/20
96/4

sending [2] 26/17
52/24

senior [3] 24/9 126/3
158/19

sense [16] 7/13
10/15 10/24 43/16

75/17 109/21 124/10
128/13 133/19 138/21
138/22 138/25
sensible [1] 161/6
sensitive [5] 22/4
129/4 129/25 130/6
141/18

sent [11] 19/13 36/5
57/11 63/13 83/3
87/18 87/21 96/16

sentence [5] 2/14 3/7
85/21 128/6 130/4
sentenced [1] 55/1
sentencing [1] 46/1
sentiment [1] 42/3
separate [11] 5/19
14/22 16/7 17/14
18/18 19/2 19/5 26/25
29/1 84/1 85/12
separated [3] 11/11
37/24 43/11
separately [2] 7/6
28/6

separation [10] 4/12
4/23 6/1 9/14 9/21
10/16 21/17 39/2 73/6
101/2

September [8] 37/20
37/23 38/10 45/20

seemingly [1] 131/9
seems [6] 16/5 64/23

52/3 52/8 60/17 64/15)

123/12 123/21 124/15}

57/21 71/23 72/1 72/8

108/20 109/10 143/13)

92/12 94/2 161/10
163/13

September 2024 [1]
163/13

series [14] 42/11

96/18 106/10 106/19
107/16 119/11 120/5
132/16 153/7 153/20
serious [4] 26/24
57/17 147/8 152/20
seriously [3] 35/3
61/21 138/3

servant [3] 5/4 7/13
103/2

serve [1] 26/13
Service [4] 2/20 10/6
42/5 63/1

services [13] 4/3
4/21 5/3 6/1 18/2
32/21 34/3 35/24

110/17

session [1] 154/22
sessions [1] 161/19
set [36] 5/1 7/25 8/2
9/1 9/12 12/7 20/11
26/11 30/2 33/15
33/16 41/3 41/8 46/8

77/2 78/17 88/7 90/4
92/20 93/10 104/18
107/16 109/5 111/9

153/7 154/9

sets [2] 10/1 88/19
setting [5] 37/18
47/120 54/3 143/3
143/5,

settled [1] 13/23
seven [2] 62/14
157/12

several [2] 31/19
80/25

shall [2] 103/11
129/21

shaping [1] 46/20
share [11] 16/21 25/3
25/25 26/2 33/14
42/25 48/6 78/13
101/20 117/4 117/9
shared [11] 16/1 16/4I
18/15 25/23 49/13
49/22 52/11 96/8
96/23 116/25 140/14
shareholder [73] 4/8
4/16 6/5 6/13 7/7 8/9
8/11 8/14 9/2 10/12
10/23 11/4 11/8 11/9
11/13 11/15 11/22
12/5 13/19 14/2 14/14
14/16 14/19 15/1
15/11 15/13 15/16

56/4 57/13 86/3 86/21

38/25 73/9 77/25 78/2

50/5 65/16 66/16 76/4

112/16 118/10 119/18)
124/11 131/24 144/10)

15/19 15/24 15/25
16/2 16/11 16/17
16/25 17/2 18/5 18/7
19/4 25/10 25/18

27/11 27/22 33/18
36/22 37/1 40/18

42/13 43/22 49/22
49/24 50/8 50/12

50/14 58/10 64/22
65/17 75/25 98/19
98/21 100/2 101/1

120/2 121/1

sharing [6] 25/1
33/16 49/23 64/11
102/23 110/14

she [57] 24/22 24/25
25/1 26/11 26/12
26/25 27/3 27/12
27/12 27/12 34/13

87/5 87/8 87/10 92/1

128/8 128/21 129/1
129/4 129/13 129/21
129/23 131/2 132/15
132/19 134/3 136/5
136/8 136/11 138/2
138/3 138/7 138/9
139/3 148/21 151/7
151/15 151/18

she's [4] 48/10 52/23
127/19 128/4

ShEx [33] 3/23 6/22
10/7 15/20 17/11
24/18 24/21 24/22
25/2 26/6 28/4 32/25

47/24 49/13 50/4
63/25 64/1 64/12
97/24 98/1 98/2 98/3
98/17 100/24 102/18

120/19

ShEx's [1] 4/3
shoes [7] 40/13
63/17 93/12 125/10
145/5 145/11 151/17
Shoosmiths [19]
19/12 20/13 22/5
22/16 31/5 39/24 40/2
40/14 90/11 124/25
142/11 142/13 143/1
143/3 144/20 145/11
146/2 147/21 148/18
short [7] 45/17 77/11
103/15 108/3 155/20
162/5 162/23
shortcomings [1]

26/14 26/19 27/6 27/7

101/14 102/12 105/20
106/20 106/25 113/15}

48/9 53/17 56/14 64/9
69/6 69/6 71/12 71/19
80/19 85/4 85/5 86/25)

92/4 92/13 93/5 110/3
110/12 110/22 127/13

35/23 43/7 47/8 47/14

102/18 112/21 119/25)

129/7

Shortfall [1] 159/5
shortly [6] 19/11
20/13 73/15 85/3
157/4 163/8

41/5 42/6 44/24 51/2
76/1 76/3 76/10 77/4

95/10 109/4 110/8
115/12 122/19 129/5
129/5 153/13

show [2] 123/4
126/13

showed [2] 95/21
96/4

showing [1] 86/16

111/18

sic [1] 32/4

side [4] 5/4 32/24
141/16 157/11
sift [1] 143/17
Sight [61] 34/13 36/6
39/18 40/21 41/6

50/21 51/12 51/20
52/17 55/22 57/9
57/25 58/16 59/13
59/18 60/3 64/13
65/14 66/21 70/13
71/5 72/2 72/3 74/15

90/12 96/18 97/2
118/22 119/9 119/20

129/2 129/18 130/3
132/14 132/21 133/2
133/11 134/6 134/7

150/16 151/6 151/12
152/17

sighted [1] 48/10
sign [2] 18/10 27/8
sign-off [1] 18/10
signal [3] 96/15
96/24 96/25
signature [2] 1/17
1/18

significance [2]
34/23 141/22
significant [36] 2/15
3/8 3/9 21/7 21/17
21/25 22/2 30/7 34/16
35/6 35/7 35/17 37/23)
39/9 40/1 44/13 46/2
54/25 55/1 56/25 64/3
64/6 86/9 104/7
105/24 115/20 124/23}
124/24 126/16 134/3
134/8 134/12 137/13

should [26] 1/12 28/1
61/11 69/6 70/1 74/25}

84/23 87/22 91/8 93/1

shown [3] 86/3 89/24

47/11 49/3 49/9 50/15

77/2 78/4 83/13 83/20)
85/9 85/20 86/1 89/16

127/20 128/16 128/23)

134/11 135/11 135/18)

Sight's [2] 85/14 87/2

144/19 150/19 161/10}
signs [1] 75/1
similar [8] 22/17 35/8
63/10 95/4 111/18
140/19 142/14 151/22!
simple [2] 120/4
149/11
simply [8] 23/16
35/18 39/4 67/4 90/2
90/7 101/11 102/24
simultaneous [1]
148/11
since [3] 31/5 124/17
156/4
single [6] 2/23 8/2
36/8 39/18 90/24
162/25
single-most [1] 8/2
sir [32] 1/5 13/10
30/13 30/20 31/22
32/21 40/18 41/10
44/3 45/10 64/19 77/6)
99/9 103/9 121/6
121/8 122/13 132/18
134/17 137/21 139/5
139/8 154/17 154/19
155/11 155/24 159/14I
159/20 159/21 163/10)
164/7 164/15
Sir Alan [10] 13/10
30/13 30/20 31/22
32/21 40/18 41/10
64/19 132/18 134/17
Sir Anthony [1] 99/9
sister [1] 11/11
sit [4] 2/4 109/15
154/24 162/2
sitting [7] 6/24 15/17
43/8 68/23 68/24
100/24 106/13
sittings [1] 161/15
situation [7] 70/10
75/22 91/4 116/8
143/6 145/25 151/16
situations [6] 73/23
1412/3 117/2 120/3
120/5 135/23
six [3] 59/7 61/19
132/2
size [1] 110/20
skills [1] 162/7
skin [1] 153/23
sky [1] 163/1
slight [2] 88/17 150/3
slightly [20] 2/1 2/4
21/5 38/4 38/6 63/18
77/18 79/4 79/6 81/6
88/24 129/16 130/21
132/22 138/19 141/9
141/13 142/7 146/20
152/23
slip [1] 94/24
slow [1] 131/9
slowly [1] 118/17

(65) seemingly - slowly
Ss

SLR [3] 141/7 141/15
143/19

SLRs [1] 73/22
small [5] 1/21 131/4
139/21 141/12 156/6
smaller [1] 41/3
Smith [1] 142/4

so [224]

solely [1] 31/10

sol r [1] 40/8
solicitors [3] 30/23
31/6 83/17

some [56] 1/21 4/17
5/1 7/10 8/18 9/3 9/7
11/5 23/3 26/24 27/22
37/7 37/17 41/15
44/13 48/6 51/7 52/12
57/17 59/11 61/9
67/19 68/4 68/4 68/25)
73/8 73/14 79/13
79/13 85/6 86/19
89/18 89/23 89/25
90/5 90/19 93/24
95/24 96/1 107/22
116/9 116/10 118/13
125/18 125/23 126/5
126/18 128/19 130/9
143/10 150/13 152/20
155/17 160/20 160/23
162/9

somebody [12] 12/4
15/10 25/4 40/15 43/6
53/11 69/8 101/18
137/4 137/22 149/12
149/13

somebody's [1]
67/22

somehow [1] 160/24

someone [2] 44/13
122/1

something [29]

29/22 35/18 37/21
45/23 47/13 56/3
70/10 70/22 74/3
93/14 96/3 117/7
117/11 118/6 119/1
124/12 125/4 129/4
129/24 130/5 132/11
137/13 144/8 144/22
151/15 153/4 155/20
160/13 161/8

sometimes [4] 37/3
38/22 75/12 138/8

somewhat [1] 52/15

somewhere [1] 95/24)

soon [2] 97/25

161/20

sophisticated [1]

38/4

sorry [19] 3/4 8/15

21/5 23/5 24/6 32/20

45/9 56/11 56/17

60/15 79/6 79/23
87/17 116/12 128/6

149/1
sort [32] 7/25 25/8
25/16 25/20 27/21

67/2 72/25 73/12
74/11 81/21 82/3
102/1 102/3 107/3
112/24 116/13 128/8
128/19 128/21 130/1
130/2 135/1 135/13
135/22 138/12 150/7
150/9 152/11
sorts [1] 148/23
sound [1] 145/5
sounding [1] 129/16
space [1] 5/3
Sparrow [17] 99/8
99/17 100/12 100/21
100/25 101/8 102/15
104/8 107/10 114/15
114/18 114/23 114/25)
115/4 115/21 123/18
130/24
speak [9] 92/9 93/7
122/10 129/10 144/2
152/11 154/12 160/7
161/2
speakers [1] 148/11
speaking [7] 13/4
13/7 13/7 37/16 40/20
113/23 149/13
speaks [1] 112/10
specific [5] 5/10 37/5
49/9 71/9 96/24
specifically [6] 67/16
71/24 74/1 77/3 96/25)
128/14
speech [1] 154/14
speed [2] 8/13 113/4
spend [1] 70/21
SPM [2] 146/18 147/2I
SPMR [1] 142/24
SPMs [3] 146/3
146/13 147/6
spoken [4] 36/12
36/12 44/24 92/13
Sport [1] 3/17
spot [2] 119/14
152/18
spotlight [1] 67/24
SS [2] 123/21 127/2
stabilise [1] 6/2
stability [1] 9/21
stacked [1] 158/11
staff [2] 47/7 146/7
stage [22] 22/14
22/20 34/3 39/3 41/21
42/2 49/25 51/13
52/18 76/14 76/16
82/7 85/15 86/1 86/12
90/12 106/17 106/23

130/14 132/23 145/17)

36/14 38/18 45/4 60/9)

156/2

stakeholder [1] 53/4
stakeholders [1]
53/6

standalone [1] 85/1
standards [1] 62/13
start [11] 2/11 11/16
53/14 77/17 84/5

149/13 155/7 159/12
started [16] 3/20 6/8
6/9 39/24 101/13

148/9 150/25 152/12
153/20 159/9
starting [1] 67/20
starts [2] 70/10
136/20

state [3] 9/11 9/25
117/23

statement [60] 1/13
1/19 1/24 3/11 3/14
5/1 6/25 10/20 11/2
17/18 25/5 37/22
38/16 39/12 41/9
41/17 41/23 42/22
46/6 50/5 56/9 56/9
56/15 56/20 58/12
58/23 59/16 66/9
67/15 73/16 74/17
75/22 76/5 98/9
102/20 103/4 107/7
107/16 119/3 122/16
122/25 123/3 124/17
125/11 131/25 139/24]
139/25 140/2 140/4
140/20 140/25 141/6
143/9 143/12 145/14
145/20 155/3 157/18
159/21 164/15
statements [14]
18/11 52/15 64/5
123/20 124/3 155/17
155/18 156/13 156/24
156/25 157/2 157/4
157/12 157/13
statistics [1] 111/24
status [1] 108/8
statutory [1] 38/22
stay [1] 69/8
stealing [2] 44/14
44/16
steered [3] 132/11
138/23 138/25
Stein [7] 122/13
139/6 139/7 139/16
153/12 154/16 164/11
step [4] 43/18 101/18
107/5 119/21
Stephen [2] 17/5
17/11

107/23 138/25 150/15}

stand [2] 21/10 67/17

108/13 139/24 145/24

101/17 102/12 131/10
134/12 145/16 145/17]

stepped [2] 43/2
154/12
steps [11] 74/23
76/13 89/15 90/22
106/22 107/5 112/4
119/17 127/6 152/22
153/20
sticking [3] 45/20
55/18 56/22
sticks [1] 137/18
still [7] 26/23 30/4
68/9 103/6 109/19
129/12 161/3
stolen [1] 146/38
stone [2] 118/25
119/8
stood [2] 73/10
136/13
stop [1] 154/11
store [1] 19/25
Storey [17] 1/6 1/7
1/12 3/16 14/3 24/20
27/25 28/3 77/14 98/5)
113/17 122/16 139/18}
139/19 154/20 154/24}
164/3
story [1] 1/11
straightforward [2]
21/12 91/7
Strategic [1] 97/22
strategy [4] 7/19 43/1
53/4 53/5
stress [2] 160/19
160/21
stressed [1] 71/6
stresses [1] 61/18
stretched [1] 160/12
strictly [1] 48/5
strike [1] 55/2
strong [7] 10/15
10/25 30/1 71/4 71/18}
96/24 145/7
stronger [2] 54/15
67/25
strongest [1] 96/14
strongly [2] 93/13
138/6
struck [2] 22/15 55/3
structural [2] 33/13
102/22
structurally [1] 14/22
structure [1] 36/23
struggling [1] 2/1
sub [2] 107/3 146/23
sub-in [1] 107/3
subcommittee [4]
24/15 27/1 107/10
114/4
subject [3] 3/11
136/12 146/6
subjective [1] 52/14
submission [10] 12/2!
30/10 31/1 32/6 32/23
148/13 148/18 148/19

149/4 149/8
submissions [11]
18/9 18/14 32/16
147/20 149/3 161/22
162/1 162/4 162/6
162/9 162/10
submitted [1] 31/8
subpostmaster [3]
31/6 117/24 118/3
subpostmasters [17]
12/9 12/11 13/5 19/17)
22/8 30/17 30/23 51/6
54/1 54/4 59/11 94/15]
95/7 131/5 139/20
149/13 159/4
subpostmasters' [2]
13/23 160/8
subsequent [2]
14/14 68/14
substance [1] 161/25]
substantial [3] 3/1
3/2 31/18
substantive [2] 1/15
28/10
substantively [1]
135/11
subtlety [1] 80/7
success [2] 24/25
28/18
successfully [1] 59/6
successor [2] 50/10
107/8
succinctly [1] 123/24
such [9] 25/22 64/2
67/23 69/9 73/10
96/23 117/22 117/25
125/18
suddenly [2] 52/2
67/12
suffered [1] 146/5
suffers [1] 20/9
sufficient [4] 46/16
76/13 101/25 111/19
sufficiently [1] 75/5
suggest [5] 16/6 61/3)
74/3 81/19 82/9
suggested [4] 36/4
41/5 81/18 153/12
suggesting [1] 44/23
suggestion [1] 15/8
suits [1] 139/12
sum [1] 22/12
summarily [1] 110/3
summarise [4] 68/20
102/14 146/1 147/1
summarised [1]
4117/7
summarises [1]
117/16
summarising [3]
60/9 118/11 148/24
summary [5] 21/13
60/2 117/15 143/5
145/24

(66) SLR - summary
Ss

summer [2] 116/16
122/17
Sunday [1] 111/6
support [10] 5/14
51/5 53/25 59/21
60/11 61/10 77/25
112/5 129/7 131/18
supported [1] 42/17
supporting [2] 59/1
59/4
supportive [3] 127/3
127/9 127/22
suppose [4] 38/19
69/2 69/4 140/5
sure [34] 9/15 9/18
12/20 13/9 14/20
18/17 26/2 36/17
43/23 52/25 60/18
79/11 81/21 86/16
89/14 90/3 93/12
93/21 100/14 103/7
105/14 112/5 114/5
127/11 127/21 128/23}
131/18 132/3 137/16
138/4 145/20 154/8
154/11 161/9
surprise [2] 45/3
A477
surprised [6] 44/17
52/1 63/18 68/12 74/2
75/10
surprises [2] 68/8
68/9
surprising [1] 111/25
surprisingly [1]
151/10
survey [2] 159/10
160/9
surveying [1] 159/10
surveys [8] 155/21
159/3 159/6 159/16
160/2 160/5 160/19
161/5
Susan [18] 54/18
66/1 66/2 68/18 68/23,
69/1 71/1 71/13 79/11
82/6 87/6 90/6 91/23
92/9 92/12 93/18
128/25 129/23
SUSANNAH [11] 1/7
1/11 14/3 14/15 24/20}
27/24 28/3 92/5 98/5
113/16 164/3
suspect [1] 42/8
sustainability [1]
9/22
sustainable [2] 43/13)
102/8
swim [2] 19/5 102/6
Swinson [4] 34/4
48/7 64/9 103/4
system [66] 2/2

12/11 13/21 18/16
18/17 19/2 19/18
19/22 20/9 20/10
28/18 28/22 29/21
30/15 41/20 42/2
46/25 49/11 51/1 59/3
59/9 60/10 61/3 61/16
61/18 61/24 61/25
62/6 91/2 94/8 94/11
94/18 95/14 104/22
104/24 118/2 118/5
118/12 119/7 119/10
119/24 120/17 140/1
140/1 140/12 140/12
140/13 140/23 141/3
143/7 144/21 145/7
146/8 147/12 147/12
147/16 147/17 149/20)
150/20 151/1 151/10
151/13 152/1 152/4
154/5 154/9
systemic [8] 51/1
51/19 52/6 57/16
94/13 119/13 129/6
152/20

systems [4] 48/20
62/2 105/1 129/8

T

table [3] 9/17 10/9
108/7
taint [1] 125/22
tainted [1] 122/23
take [32] 10/24 11/25
12/1 17/17 18/8 35/17
45/8 45/10 46/5 55/17
58/21 61/20 68/6
72/18 73/14 76/5 77/7
84/4 85/2 89/20 98/10
101/6 103/9 104/19
116/19 121/13 139/23}
144/12 145/9 153/20
155/8 161/18
taken [16] 35/2 35/14
43/12 57/23 63/5
72/10 84/20 89/15
104/18 106/6 106/22
108/22 109/3 109/7
118/23 156/8
taking [25] 19/1
28/16 34/6 34/12
53/10 53/21 56/21
83/8 83/10 89/14
90/22 92/20 93/12
98/18 98/21 100/7
107/25 113/16 115/25]
119/16 128/18 131/21
136/22 152/22 155/14)
talk [4] 47/19 67/22
92/8 145/11
talked [1] 73/23
talking [6] 27/4
122/21 140/10 140/11
142/23 145/10

tasked [2] 88/15
98/11

tasks [1] 67/10
team [67] 4/3 4/19
4/21 6/25 8/10 8/11
8/14 8/15 10/23 12/6
12/18 14/16 14/19
15/1 15/2 15/4 15/11
15/13 15/16 15/24
16/2 16/25 17/2 17/24
18/2 18/5 18/7 19/3
27/7 29/17 32/25
33/18 35/24 36/22
37/1 37/2 39/2 40/16
40/18 42/13 43/22
47/8 47/14 47/24
49/22 49/23 49/24
50/9 50/12 50/14
54/18 58/10 58/14
64/12 67/4 67/6 68/3
74/21 98/20 98/22
99/11 105/20 106/20
120/4 121/2 156/20
163/1

Team's [1] 65/18
teams [2] 67/24
163/5

technical [1] 18/23
teleconference [1]
108/17

telephone [3] 37/16
53/18 126/22

tell [7] 58/4 70/15
124/19 127/18 132/24
149/16 161/22
telling [4] 30/7 35/1
149/20 161/23

tells [1] 82/2

tempted [2] 139/8
139/10

ten [1] 13/1

tenure [2] 2/16
140/17

term [1] 161/17

terminated [2] 12/12
30/17

termination [2] 22/9
142/18

terminology [1]
48/22

terms [30] 8/17 10/11
15/21 17/12 21/10
21/18 26/1 34/2 51/3
52/3 55/1 65/25 72/4
76/11 76/25 83/4 83/5)
99/19 109/17 120/4
121/11 121/17 132/22]
134/14 141/5 143/11
144/22 155/15 160/8
160/12

tested [2] 61/2
140/12

testing [1] 82/6

than [22] 35/18 38/4

41/3 47/21 50/14
52/15 59/6 59/7 61/19)
61/22 63/3 69/17 85/1
86/6 91/9 103/3 103/6
110/16 119/20 129/15]
136/8 143/17
thank [52] 1/9 1/19
1/23 2/21 2/24 3/3
3/11 3/14 7/5 13/12
18/4 20/25 21/5 23/18}
23/24 26/4 34/6 38/1
45/15 47/6 50/15
69/18 77/6 77/13
77/22 79/2 79/6 88/2
88/24 97/19 103/19
103/24 108/5 108/15
109/11 110/1 121/6
122/13 122/15 139/5
139/13 140/7 154/17
154/18 154/19 155/2
155/5 159/20 159/22
162/17 163/7 163/10
thanked [1] 28/3
Thanks [1] 111/15
that [911]
that's [76] 1/16 3/6
3/22 4/1 4/5 5/21 5/22
7/19 8/2 8/22 13/13
14/8 16/5 20/20 33/1
35/20 38/18 43/4 44/7
44/8 45/21 46/1 48/7
56/12 56/20 57/3
57/24 65/22 70/13
72/18 76/7 77/15
79/17 84/18 84/18
92/2 92/25 94/4 97/12,
97/17 100/18 100/21
102/11 107/4 107/5
112/5 116/20 118/8
119/23 123/3 125/4
126/9 126/9 128/6
129/22 130/8 131/13
132/20 132/20 134/24}
135/9 135/16 140/7
141/13 143/9 144/23
145/2 147/12 147/22
149/19 151/8 153/15
154/14 157/22 159/14}
162/12
theft [1] 147/5
their [35] 12/12 18/10)
23/9 28/16 28/20
30/17 37/3 38/11
42/23 52/19 67/10
70/17 78/10 78/14
82/20 85/10 85/11
88/6 88/12 97/13
109/5 122/20 127/2
128/18 129/5 129/11
130/20 134/10 134/14,
146/7 153/18 156/7
161/25 162/6 163/5
them [39] 7/12 10/19
11/20 13/3 18/21

18/23 21/7 22/24 23/2I
26/21 28/12 28/16
32/17 34/14 37/15
38/23 41/13 44/12
44/13 52/22 55/24
57/16 62/7 64/7 64/8
81/25 85/24 91/9
113/1 113/2 116/11
129/23 135/24 138/7
146/9 150/13 150/14
157/18 159/16
themselves [2] 106/2)
117/23
then [105] 2/25 4/8
7/10 10/22 14/13
14/23 17/6 17/12 18/1
18/2 19/2 20/23 21/6
25/21 27/12 27/23
29/19 30/20 30/21
31/12 31/21 34/4
35/16 36/5 39/25 40/3}
40/17 44/7 48/7 49/11
49/21 52/23 54/7
54/17 55/6 55/19 56/5I
60/7 60/10 62/5 62/23}
71/25 78/6 82/24
84/22 86/19 87/5
88/11 88/12 90/5
97/21 98/4 98/9 99/7
100/2 100/22 106/8
106/9 110/11 113/19
114/1 116/12 118/8
119/3 121/2 122/13
124/23 125/4 127/18
128/8 129/13 129/21
131/7 134/2 134/11
135/6 135/7 135/24
135/25 137/5 140/21
141/5 141/19 141/20
142/6 142/21 142/25
143/1 143/4 144/14
1447/1 147/3 147/14
148/9 150/12 151/2
151/10 153/7 153/20
153/20 153/24 155/20)
156/22 157/24 158/13}
theory [1] 80/7
there [217]
there'd [4] 10/13
52/21 95/22 150/8
there's [39] 13/25
22/3 23/23 35/6 35/24
36/1 39/12 49/4 51/9
55/7 61/14 62/9 62/23}
70/20 71/8 72/17
83/12 83/15 83/21
88/17 91/7 91/10 95/3
97/10 100/5 100/7
100/21 104/8 104/12
106/18 116/18 117/7
128/3 132/23 134/6
134/6 137/12 149/21
150/20
therefore [13] 15/15

(67) summer - therefore
T

therefore... [12]
47/19 71/15 101/4
101/24 108/24 112/12)
115/7 125/21 129/12
133/14 150/4 161/5
these [59] 5/25 10/14
11/10 11/14 12/15
18/20 21/22 22/25
28/23 29/19 31/22
38/3 38/23 39/8 39/14
39/19 40/25 43/12
44/18 52/4 57/22
59/12 59/24 61/6 62/3
62/25 63/3 69/13 76/2
85/23 86/4 87/13
89/23 93/24 103/24
105/24 107/1 107/11
107/18 111/15 116/18
118/11 129/9 130/23
131/22 135/23 138/5
144/15 144/19 147/6
147/8 148/23 149/2
152/10 153/8 155/18
160/5 161/4 161/19
they [79] 10/18 11/11
11/18 11/20 15/10
17/6 18/14 20/4 22/16}
25/17 25/21 25/22
28/7 28/17 30/7 37/12
38/6 39/10 41/11
41/12 42/9 42/14
42/15 42/16 46/16
46/17 50/11 50/25
51/4 52/11 54/5 55/22
57/18 57/18 67/8 70/1
70/3 70/6 72/3 75/11
75/15 75/15 78/18
84/3 85/22 90/7 90/19)
99/14 108/24 121/2
121/3 121/4 125/2
125/17 125/18 127/3
127/17 127/18 129/3
129/5 129/10 129/10
129/11 129/15 134/17
136/3 138/6 142/13
144/8 146/5 146/6
146/7 146/8 146/11
146/16 149/16 149/20
160/21 161/7
they'd [6] 22/24 37/3
37/4 39/16 52/21
153/15
they'll [2] 72/13
161/24
they're [7] 86/5 95/25)
135/22 139/24 143/6
147/18 159/6
they've [4] 143/4
144/20 152/25 153/1
thing [19] 30/7 36/14
49/13 57/7 58/9 63/20)
64/6 68/9 72/7 73/5

91/14 93/5 102/7
105/15 112/24 130/25)
131/2 135/1 151/24
things [50] 7/20 7/25
9/3 9/18 10/25 18/18
25/21 29/3 37/4 38/21
38/23 39/13 41/9
42/11 42/18 44/18
50/13 57/14 57/22
64/20 68/1 68/6 71/15
71/17 75/19 76/8
76/23 77/24 78/25
86/2 89/18 90/5 93/8
97/1 101/16 102/1
106/19 112/16 118/17)
118/24 124/12 124/21
131/23 138/6 141/5
145/3 150/19 151/8
152/10 153/9

think [214]

thinking [15] 7/19
30/5 53/12 59/20
59/22 60/4 74/5 74/12
82/7 85/17 117/2
120/10 144/23 148/3
152/24

third [6] 35/10 54/4
78/4 87/3 91/20
142/16

thirdly [1] 155/20
this [415]

Thomson [2] 125/3
150/1

thorough [2] 27/17
41/22

those [70] 3/11 6/24
7/22 8/19 9/10 9/18
15/18 16/7 22/4 22/23
23/4 26/2 26/12 26/20
27/9 28/23 32/10
40/11 42/7 42/16
42/17 43/7 50/13
54/10 54/23 57/4
58/22 65/2 65/25
66/12 67/17 67/21
70/11 75/11 93/15
98/6 104/4 107/13
107/22 108/11 113/8
114/2 116/9 121/4
121/6 123/4 124/13
125/10 126/7 132/7
133/7 133/15 134/7
140/24 141/17 146/5
152/18 152/22 154/19)
155/17 157/1 157/6
158/6 158/10 158/25
159/6 159/15 159/23
160/15 162/9

though [12] 29/5
38/3 56/22 68/1 76/9
79/11 79/14 113/3
119/8 135/6 151/23
162/8

thought [34] 8/16 9/4

9/13 9/14 13/9 33/6
37/10 44/18 48/1 50/7
50/9 55/12 64/14
68/21 69/2 69/5 69/6
72/6 75/15 76/6 85/18
89/15 95/21 102/20
110/14 112/4 113/5
125/22 127/1 127/4
128/5 128/10 152/22
155/14
thoughtful [1] 68/8
thoughts [3] 85/6
110/14 111/17
threads [2] 39/22
155/15
threat [1] 130/1
three [8] 20/23 77/23
79/1 101/20 101/21
108/6 146/9 156/2
through [29] 7/25
11/1 28/16 34/24 36/4
38/12 39/17 50/22
52/9 56/5 62/2 64/20
69/13 69/18 79/13
82/21 83/17 86/20
102/3 119/14 120/22
141/11 145/23 149/11
150/12 151/11 156/2
158/4 162/22
throughout [3] 6/20
140/17 156/21
throw [4] 110/5
Thursday [2] 12/8
55/6
ticked [2] 152/25
153/1
ticking [2] 146/2
152/24
tier [1] 25/16
time [134] 2/19 5/14
5/19 6/7 6/12 8/7 9/23
10/22 11/25 12/3 12/6}
12/20 12/21 13/3 13/9
15/12 16/15 19/10
19/10 20/17 20/22
26/3 26/24 27/17 28/6
30/3 30/5 31/23 33/25
34/7 37/2 37/6 37/13
37/13 39/20 41/2 42/6
42/19 43/2 44/10 45/4
46/5 46/24 47/1 48/22
53/7 57/19 58/3 58/20
59/15 60/5 60/15
60/19 63/4 64/3 64/15)
68/13 69/23 70/1
70/21 72/8 73/17 75/1
75/3 76/6 76/7 76/24
85/17 89/10 89/16
91/24 92/8 92/10
92/17 92/22 93/5
93/10 93/13 93/19
94/23 95/16 95/18
96/3 96/10 96/16
96/24 98/13 100/23

101/25 102/2 102/23
103/3 103/11 106/13
108/20 108/23 111/4
112/14 112/23 118/5
118/21 119/16 119/21
120/2 120/13 122/19
124/16 125/23 126/10}
126/11 128/18 131/5
131/17 131/17 132/17,
132/22 133/19 134/14}
134/15 134/15 134/18}
134/18 137/21 139/18
145/21 148/7 148/7
148/23 148/24 149/10)
149/15 152/21 153/5
162/24
times [6] 52/14 70/11
94/5 123/5 123/8
124/13
timetable [2] 144/11
161/19
timing [2] 148/3
148/5
title [4] 2/19
today [9] 14/4 52/11
68/10 115/23 130/6
138/13 155/4 156/25
159/14
today's [1] 3/23
together [7] 29/9
39/22 40/11 57/21
146/15 155/15 163/5
told [22] 51/14 52/20
55/5 57/13 72/5 113/5
125/12 125/15 125/24
126/14 127/15 129/23}
135/8 149/15 151/1
151/2 151/14 151/25
152/1 152/4 158/10
159/12
Tom [1] 130/17
tomorrow [4] 91/15
127/1 127/7 129/10
tonight [1] 127/2
too [5] 2/9 81/8 110/3
129/22 129/25
took [17] 5/9 7/23
17/21 41/15 55/23
56/13 76/12 89/18
105/7 107/5 109/14
109/24 112/7 116/1
138/2 150/1 153/17
top [7] 9/15 13/1
55/12 57/24 79/3
81/14 140/6
topic [1] 47/10
total [3] 22/8 61/21
61/23
totalling [1] 158/9
totally [2] 45/8
105/20
touch [1] 87/12
towards [3] 85/14
104/15 132/11

tracking [1] 82/20
tracks [1] 115/11
trail [1] 112/14
train [3] 68/17 105/24I
112/16
training [8] 5/9 31/11
51/5 59/10 59/21
60/11 61/10 112/5
transactions [5] 8/3
8/4 19/20 59/7 61/20
transcript [1] 130/13
Transformation [3]
31/10 147/22 148/18
transition [1] 98/16
transitional [2] 73/9
77125
translate [2] 117/23
144/2
treat [1] 162/7
treated [1] 157/2
trick [1] 142/17
y [1] 82/4
tried [5] 25/5 37/6
39/11 124/10 131/23
triggered [1] 37/5
true [7] 1/19 3/12
16/18 126/9 126/9
153/4 155/12
trust [3] 11/18 11/20
128/2
trusting [1] 145/8
try [7] 34/19 57/10
57/10 59/18 119/18
153/8 153/22
trying [13] 11/16
16/16 21/19 21/20
57/15 73/9 75/19
76/17 90/23 96/11
118/24 137/8 149/20
Tuesday [3] 1/1 64/5
77123
turn [44] 1/15 13/12
19/8 20/14 23/18
23/25 24/16 28/8 30/9I
34/6 34/8 35/5 35/21
37/19 37/20 46/22
47/22 50/16 53/14
55/16 56/8 56/17
60/12 65/21 70/20
74/17 79/2 82/15 88/1
88/22 91/21 100/5
100/19 100/20 103/21
106/2 108/11 108/15
110/11 113/9 114/8
119/22 158/13 158/15)
turning [2] 19/12
62/15
two [30] 2/16 5/25
10/25 11/11 17/15
20/18 25/16 25/20
29/19 44/15 46/1
53/18 54/10 64/4 73/6I
79/23 80/23 83/2
101/22 107/13 139/23}

(68) therefore... - two
T

two... [9] 140/25
153/15 154/22 157/13)
158/11 159/3 159/6
160/2 162/11
two-tier [1] 25/16
two-way [1] 10/25
tying [1] 6/2

type [1] 89/6
typically [1] 147/6

U

UK [1] 13/19
UKGI [1] 13/13
UKG100000062 [1]
12/2
UKGI00000065 [1]
30/9
UKGI00001656 [1]
47/22
UKGI00018251 [2]
22/1 141/8
UKGI00043711 [1]
110/11
UKGI00045624 [1]
130/15
UKG1I00048174 [1]
13/12
ultimate [1] 59/25
ultimately [2] 161/6
162/13
Um [2] 107/16 137/15}
unable [1] 87/8
uncertainty [1] 11/5
unclear [3] 70/4
94/22 148/11
uncomfortable [8]
55/9 73/20 73/21 74/2
74/16 112/18 121/21
138/15
uncontrollable [2]
138/19 138/20
uncover [1] 118/24
under [12] 28/12
28/24 29/5 29/24
36/18 44/6 78/15
81/19 142/10 142/12
153/23 158/9
underlines [1] 59/8
underlying [2] 117/4
4117/5
undermined [1]
123/21
underneath [1] 95/24
understand [22]
10/18 15/14 23/7 27/7I
44/9 44/10 50/25
57/10 58/13 59/18
66/1 80/4 80/25 96/22
110/4 121/22 129/3
133/7 133/18 135/24
145/4 159/8
understandably [1]

132/17
understanding [8]
38/18 51/11 51/18
79/25 80/15 89/16
108/21 109/8
understatement [1]
162/19
understood [7] 33/10)
33/11 79/17 96/16
128/7 133/19 141/1
undertake [1] 114/20
undertaken [3] 61/11
94/11 94/20
undertaking [3]
14/24 38/11 67/9
underwriters [4]
81/25 82/3 82/12
82/18
unequivocal [3]
41/18 42/1 42/16
unfair [1] 20/10
unfolded [1] 66/17
unfortunately [5]
13/2 25/7 39/20 41/8
118/20
unless [1] 132/23
Unlike [4] 14/14
unlikely [1] 88/8
unnecessarily [1]
81/13
unreliable [1] 97/3
unsafe [5] 49/10
123/9 123/19 124/1
124/9
unsophisticated [1]
120/15
until [10] 14/11 38/19
51/15 95/18 109/22
134/21 135/7 144/13
154/12 163/13
unturn [1] 119/8
unusual [6] 29/6
34/18 53/13 64/17
116/24 137/6
up [72] 5/9 6/14 8/13
17/18 17/20 21/5 24/8)
25/16 26/16 28/5 32/3
33/15 33/16 35/11
37/18 38/24 47/20
54/3 57/24 58/12 64/5)
69/23 70/25 71/25
77/2 78/17 79/14
79/21 80/17 81/14
84/7 84/13 84/21 89/7,
91/5 91/10 91/23 92/4
93/1 93/2 93/23 99/13
105/19 107/8 110/1
112/20 113/3 113/23
115/24 123/8 124/7
125/6 126/25 128/25
129/3 129/24 132/24
134/3 135/19 138/9
139/21 142/16 144/12)
146/4 149/15 149/24

152/5 158/11 160/6
160/18 162/11 163/1
update [28] 36/14
50/18 50/19 50/20
53/17 54/21 55/6
70/21 80/13 82/25
83/8 84/11 84/17
84/18 99/21 99/21
104/7 104/17 105/7
105/9 115/13 134/17
134/23 135/7 135/22
143/1 149/5 159/7
updated [12] 28/14
34/11 35/9 47/13
47/15 52/23 54/24
82/3 85/2 87/15 87/25
135/11
updates [4] 36/21
41/15 71/13 134/15
updating [4] 29/8
34/21 37/13 93/5
uploaded [2] 3/15
157/4
upon [3] 4/12 130/24
142/19
urgent [2] 57/22
135/8
urgently [1] 118/5
URNs [3] 157/14
157/20 158/1
us [62] 4/14 11/7
14/17 16/5 29/8 30/7
33/23 34/22 35/1
37/16 40/13 41/15
45/8 47/17 49/9 51/17
52/11 52/23 52/24
53/21 57/1 57/11
65/20 70/7 70/14
70/15 70/16 74/22
75/1 75/6 80/4 81/20
81/22 87/18 96/2
96/12 108/16 108/19
109/10 110/20 112/7
114/2 116/11 116/11
118/21 118/21 122/20
124/19 124/24 125/12)
127/18 128/12 132/16
132/24 134/11 135/23
138/8 143/10 144/2
144/8 149/16 149/20
use [7] 28/21 48/22
52/14 68/10 133/6
138/13 146/9
used [10] 34/19 59/5
75/12 76/11 94/9
120/7 125/16 125/17
125/21 146/19
useful [1] 48/9
users [2] 61/19 61/23
using [6] 7/3 85/9
143/11 151/11 154/5
154/6
usual [1] 162/19
usually [1] 143/25

Vv

vacuum [1] 151/24
vague [1] 72/25
vanilla [1] 25/22
variable [1] 102/1
varies [1] 78/15
various [8] 20/6 31/1
35/11 40/11 77/1
130/22 131/19 153/5
vast [1] 74/8
vehicle [1] 38/12
Vennells [31] 28/14
32/12 35/22 36/25
41/15 47/8 47/10
49/21 50/17 51/17
52/5 53/16 55/20
56/14 56/19 63/14
66/21 69/3 71/12
79/15 80/18 112/8
123/9 123/15 124/8
125/3 126/23 134/16
148/20 149/12 151/5
Vennells' [1] 110/12
verbal [1] 37/11
verified [1] 80/1
version [8] 54/24
55/19 84/23 85/2
87/15 87/23 87/25
122/8
versions [1] 83/2
very [84] 1/9 1/23
2/21 3/3 3/14 9/12
10/19 16/6 20/25 21/5)
25/15 25/22 29/1 30/1
30/6 33/7 37/2 37/2
37/9 39/11 42/1 43/10)
44/13 45/12 49/16
53/18 55/9 56/6 57/17
57/22 57/22 58/8
58/13 61/20 65/7
65/17 67/12 69/10
69/15 76/7 76/24
77/22 78/25 79/6 82/4,
85/2 86/22 88/2 88/20
89/20 98/14 102/4
103/18 103/19 104/2
107/2 107/8 116/19
119/14 119/22 123/24}
131/16 131/24 132/18
135/20 137/21 138/3
138/3 139/13 140/7
140/8 140/19 141/13
141/21 142/7 145/24
152/19 154/24 155/3
155/5 159/24 160/14
162/23 163/7
veto [1] 114/4
victims [1] 30/14
view [26] 8/25 9/11
13/18 18/22 29/24
52/18 53/25 60/1
66/19 66/23 74/24
78/10 91/3 97/14

107/9 110/2 112/7
112/8 114/3 115/22
118/17 121/12 121/23)
127/22 128/5 153/18
view' [1] 129/2
views [5] 66/23 71/4
113/25 121/1 159/4
vigorously [1]

140/12

Vince [1] 26/16
violently [1] 161/24
Virginia [3] 20/21
21/1 46/15

visibility [1] 101/5
visualise [1] 158/10
vital [1] 159/16
volume [2] 134/20
156/13

vulnerable [1] 53/25

Wo
wait [1] 17/20
waiting [1] 63/18
Wales [2] 121/17
163/8
walk [1] 110/5
want [25] 5/13 6/16
16/23 19/7 68/12
68/15 70/11 72/13
81/12 85/6 97/12
124/8 129/11 132/24
143/10 145/23 160/7
160/19 160/21 160/23}
161/11 161/17 161/22)
161/25 162/1
wanted [34] 1/22
4/22 6/5 10/16 15/10
21/21 21/22 44/7
50/20 57/9 57/10
57/22 69/6 72/9 72/11
75/21 89/14 90/3
96/18 96/19 98/10
101/5 101/12 101/15
117/10 119/3 124/1
124/4 124/12 127/25
130/24 131/18 132/19)
138/4
wants [1] 154/22
warning [4] 70/5
70/14 96/12 130/3
warrant [1] 95/6
was [574]
wasn't [40] 2/18 7/5
12/19 15/10 16/3
17/24 18/16 26/1
33/24 39/20 46/2
48/25 66/2 89/25
90/16 93/22 93/22
95/17 96/2 96/23
99/24 101/22 105/11
105/16 107/3 107/20
109/2 109/22 116/12
118/6 119/7 120/8
121/19 125/18 128/1

(69) two... - wasn't
Ww

wasn't... [5] 133/16
133/23 138/20 149/8
150/2
watch [1] 139/16
watched [1] 125/25
way [57] 7/6 9/4 9/9
10/6 10/9 10/25 11/1
15/3 15/7 19/14 19/19}
20/13 27/17 33/8
33/21 34/25 37/6
40/12 41/22 42/11
52/19 59/2 63/16 65/6
66/16 71/2 76/14
76/19 79/19 80/3
80/12 85/7 85/17 87/9
87/9 91/1 101/12
101/25 112/3 116/1
119/4 119/18 125/11
129/19 131/24 132/15}
135/12 135/24 138/11
141/10 141/14 144/25}
145/1 148/1 148/6
159/7 162/12
ways [2] 147/15
149/11
we [481]
we'd [12] 10/18 41/2
51/14 55/4 55/6 70/12
72/9 102/8 105/24
112/17 115/22 118/23}
we'll [12] 10/10 11/24
15/8 20/12 52/25
55/14 84/7 86/16
141/10 142/21 154/15}
161/13
we're [12] 1/5 16/10
50/17 83/8 90/11
91/25 102/14 118/15
130/18 141/10 154/21
159/10
we've [21] 39/23 44/6]
49/6 49/12 70/22
71/12 77/17 86/10
94/5 95/1 102/17
102/22 107/13 119/11
120/25 138/13 142/11
143/19 148/1 153/3
155/11
weaker [1] 68/1
wearing [2] 10/11
42/9
website [2] 3/15
157/5
weeds [1] 8/6
week [22] 47/19
49/15 49/24 51/16
54/22 56/5 56/5 57/11
64/23 67/12 70/8
77/24 80/14 82/24
101/20 101/21 101/22)
124/25 125/5 161/10
161/16 161/16

weekend [5] 55/24
68/4 86/20 111/7
1114/7
weeks [8] 14/12
76/22 104/4 155/24
156/8 160/20 161/17
162/3
weight [1] 124/23
welcome [1] 154/24
welcomed [3] 21/1
24/13 113/13
well [40] 5/3 10/23
17/5 24/11 29/6 29/16
30/1 43/9 44/20 50/1
55/14 60/17 68/2
68/13 70/8 71/5 71/18
82/14 99/24 99/25
106/6 106/18 111/8
119/2 119/9 128/24
132/21 134/12 139/15)
145/10 152/2 153/1
153/2 153/5 153/11
154/7 154/12 154/14
155/12 159/23
went [7] 9/19 14/25
68/15 75/9 126/7
127/18 144/13
were [210]
weren't [9] 6/21
14/18 18/14 38/16
99/16 102/17 106/13
115/16 151/14
what [126] 6/22 9/13
10/17 10/18 10/24
41/7 11/15 11/21 13/1
15/5 16/3 27/4 29/11
29/12 33/10 33/11
33/24 38/20 39/15
41/2 44/7 46/10 48/10
51/10 51/14 51/18
52/5 52/20 58/13
59/18 59/20 59/24
60/6 60/8 60/22 60/22
60/23 63/6 63/21
63/21 64/17 65/13
66/23 67/21 71/22
72/13 72/19 73/20
74/1 74/8 75/15 75/15)
76/3 78/8 88/18 89/16
90/22 90/23 91/3
95/15 96/19 97/15
100/14 103/11 105/14)
107/4 111/2 111/4
112/10 113/5 117/5
117/20 117/21 118/12)
120/22 120/24 121/2
123/4 123/24 124/19
125/25 126/17 126/18)
127/8 127/24 128/4
128/5 128/14 129/15
129/18 130/4 130/8
131/23 132/14 133/18)
133/19 134/18 137/3
139/1 140/10 141/1

141/25 142/6 143/10
144/6 144/9 145/9
147/10 147/12 149/2
149/14 151/21 153/13
153/15 153/17 154/8
156/3 159/24 160/3
160/17 161/11 161/22
161/25 162/5 162/13
162/16
what's [7] 10/24 17/8
34/23 36/1 132/20
147/22 152/5
whatever [5] 32/1
32/1 42/8 58/19 72/15)
whatsoever [1] 22/20}
when [81] 5/5 5/16
5/17 5/21 6/10 7/10
7/16 9/19 11/11 12/16
14/25 14/25 16/23
17/13 17/21 19/24
25/7 27/5 29/3 34/4
36/11 38/24 39/8
39/14 39/17 40/21
40/24 42/13 43/11
44/20 47/16 50/6 57/8
58/1 58/20 65/8 66/8
67/5 69/13 70/5 74/21
75/9 80/13 82/13
92/15 93/7 97/11
97/12 99/19 100/23
101/16 103/2 106/18
107/20 109/14 109/23
114/3 120/13 120/20
121/5 122/17 122/19
124/12 124/13 124/19}
125/25 129/9 134/10
135/4 144/3 148/3
148/5 148/10 149/5
151/5 152/12 152/17
156/3 156/17 160/21
161/17
whenever [2] 9/16
62/6
where [36] 10/24
15/17 25/21 26/10
35/12 50/2 50/13
50/21 61/12 67/18
68/15 75/3 83/15
83/19 90/12 90/19
92/12 95/6 96/4
101/22 102/14 106/4
107/11 107/15 108/11
108/12 109/12 110/7
110/17 111/10 118/19}
131/14 131/22 134/5
137/12 150/25
whereby [2] 139/25
150/15
whether [28] 2/1 16/5]
26/20 54/19 60/1 62/1
73/4 81/16 89/9 89/11
95/9 95/23 97/4 99/14
100/4 100/11 102/1
105/20 117/20 118/5

123/1 145/20 146/22
146/25 154/1 154/1
154/2 160/17
which [112] 2/11
2/15 5/16 5/25 6/8 6/9
7/2 9/3 9/10 10/11
13/23 16/10 19/21
21/17 22/17 28/16
30/15 31/4 31/10
31/23 32/9 34/18 36/5)
37/24 37/25 37/25
38/12 48/2 49/9 49/21
52/5 52/12 53/19 54/8)
54/25 55/4 55/20 56/1
62/19 65/6 71/24
73/23 75/20 78/9
79/24 80/4 80/25 81/6
81/7 81/9 81/18 81/22
84/24 85/6 85/9 86/18
86/20 87/8 87/8 88/22
89/2 89/25 91/17 94/8)
94/13 95/23 98/14
100/4 102/7 105/16
107/8 107/10 108/23
109/1 109/15 112/13
114/19 115/1 115/6
115/12 115/25 116/7
118/2 118/6 118/13
119/4 121/13 123/8
123/20 124/23 125/8
125/10 126/7 126/17
132/2 134/13 134/25
135/1 141/7 142/14
143/6 143/24 144/17
150/1 150/22 155/3
155/19 156/2 157/20
159/11 160/1 161/3
while [6] 15/20 61/20
74/22 85/8 120/17
132/24
whilst [7] 16/13
17/20 19/25 76/25
78/10 94/12 99/23
Whitehead [3] 12/3
12/4 30/10
whitewash [1] 142/1
who [49] 12/4 15/10
16/7 16/25 18/1 24/7
26/9 26/21 27/19
28/20 29/19 30/23
30/24 35/23 40/8 42/4,
46/14 46/15 63/17
65/2 65/25 66/12 67/8
72/14 72/25 89/19
93/22 100/1 100/15
104/13 106/24 107/3
108/2 113/15 114/2
137/3 138/16 152/6
153/25 154/4 156/3
156/14 157/6 157/18
157/25 159/15 159/23}
160/15 162/25
who'd [2] 20/21
118/22

Who's [4] 152/4
whoever [1] 107/6
whole [28] 15/1 15/4
23/20 27/7 30/2 37/4
37/21 55/3 55/7 56/4
65/9 66/20 68/16 76/8I
76/13 85/19 86/21
89/17 90/16 91/9 96/5
106/10 106/18 117/8
117/9 130/24 132/16
135/10
whom [2] 31/19
161/4
whose [2] 25/3 79/5
why [44] 7/2 16/20
32/5 36/17 40/10 41/1
58/18 62/10 62/16
63/15 66/2 69/3 70/14!
96/22 97/14 98/6
101/1 101/11 101/13
102/11 106/16 107/5
108/19 110/10 110/15)
4112/7 114/12 114/14
115/16 118/8 118/17
121/19 121/20 125/10)
127/5 128/10 133/11
135/2 136/16 136/18
145/4 151/14 152/3
153/3
wide [1] 36/16
widely [2] 26/21
105/22
wider [2] 51/5 104/25
widespread [1] 52/14)
will [67] 3/14 16/3
17/25 18/13 19/11
22/3 27/4 32/4 32/14
33/22 35/14 35/23
36/6 47/10 47/20
58/14 62/24 72/15
79/11 79/19 80/2 80/4
80/13 81/9 81/21
81/22 82/11 82/14
85/23 87/10 87/12
92/7 97/25 98/18
99/18 1114/2 113/4
129/7 129/10 129/11
145/5 146/18 147/1
147/2 156/5 156/12
156/14 156/20 156/21
156/25 157/2 157/4
158/15 158/18 158/20}
159/1 159/24 160/22
161/7 161/9 161/12
161/19 161/21 162/5
162/8 162/10 162/14
WILLIAMS [4] 121/8
159/21 164/7 164/15
willingness [1] 53/20
Wilson [2] 19/13 20/5I
wind [1] 162/14
wish [5] 39/15 42/10
130/22 137/9 159/25
wished [2] 65/9 65/9

(70) wasn't... - wished
Ww

within [19] 8/14
16/25 17/2 31/23

141/6 141/25 143/7
144/4 155/25 158/16
158/17 158/19
without [3] 15/4 80/9
110/23
WITN00920100 [2]
1/24 17/19

witness [43] 1/12
3/14 4/7 10/20 11/2
177 25/5 37/22
38/16 39/12 41/17
42/22 46/6 73/16
74/17 76/4 92/24

98/23 102/20 118/16
122/23 123/9 123/19
124/1 124/9 124/17

136/7 136/10 136/15
150/21 150/23 151/4
155/3 157/3 157/18
161/19

witnesses [18] 8/18
9/7 48/13 49/7 95/2
156/5 156/6 156/14
156/16 157/1 157/6
157/9 157/12 157/17
157/23 157/24 158/5
162/20
won't [3] 70/21 155/8
161/15
wonder [4] 41/1 76/9
90/2 128/15
wondered [1] 73/12
wondering [1]
111/25
word [3] 3/5 48/21
70/18
wording [1] 77/19
words [17] 39/14
44/24 85/16 86/4 88/3)
88/4 95/4 118/11
119/13 123/4 123/13
128/9 128/22 132/4
132/7 133/7 151/11
work [47] 23/4 27/20
34/25 38/11 38/25
39/2 40/22 52/1 52/21
53/20 54/22 58/7
67/12 72/11 72/15
77/1 82/25 83/9 84/11
85/19 89/23 92/18
92/20 98/12 98/25
99/11 100/3 102/2
104/2 107/24 114/19
118/9 119/2 119/4
119/5 119/9 128/18

wishing [1] 158/10

48/23 50/4 50/4 98/17
119/25 122/21 123/16}

94/16 95/12 97/3 98/8

125/16 125/21 131/25)

158/3 158/24 162/23
163/6

worked [8] 3/23 5/3
12/4 34/5 43/24 65/6
91/2 120/3

5/5 54/19 60/10 65/3
74/10 87/4 99/10
99/11 99/13 101/20
101/21 101/23 102/8
104/9 139/20
works [2] 118/12
141/3
worlds [1] 25/19
worried [5] 43/13
43/14 75/16 131/8
132/18
worry [3] 25/17 90/1
97/11
worrying [2] 60/21
90/5
worst [1] 25/19
worth [3] 53/23
110/14 136/2
would [191]
wouldn't [20] 18/25
25/25 26/13 27/2
31/25 32/13 32/19
32/22 37/5 52/8 53/12
58/18 65/4 69/7 93/23)
113/1 121/3 127/25
133/6 138/19
write [3] 91/8 95/25
129/15
writing [3] 161/6
162/1 162/12
written [11] 31/8 69/1
100/3 125/1 129/18
133/21 135/21 148/13)
148/19 156/18 158/6
wrong [4] 16/5 70/11
74/3 124/13
wrongful [3] 22/9
70/25 142/18
wrongly [2] 12/12
30/17
wrote [5] 31/19 66/9
112/10 124/17 141/25)
WYN [4] 121/8
159/21 164/7 164/15

Y

yeah [35] 10/4 23/24
24/7 29/9 43/16 45/6
51/22 66/14 69/2
76/23 86/15 86/21
97/7 99/18 102/11
104/5 105/8 118/8
122/3 12/6 122/9
122/11 123/12 124/13)
127/24 128/3 131/16
133/5 135/5 135/16

129/11 132/19 134/12,
134/19 135/11 141/14)

working [17] 2/2 4/23)

138/24 142/2 142/4
152/11 153/17

year [18] 1/13 6/7
6/14 46/20 50/6 52/2
62/14 67/11 74/14
101/15 101/24 102/9

135/10 156/4 158/23
years [11] 5/4 30/16
30/25 46/1 58/19
58/19 69/13 132/2
133/12 152/9 158/4
yellow [1] 142/17

4/4 4/13 10/8 11/8
12/5 13/6 21/9 24/11
29/15 30/8 32/8 35/20)
36/23 38/7 39/6 39/7
42/3 42/24 43/4 43/4
44/5 44/7 44/9 44/12
45/9 45/14 45/19
55/14 56/4 56/17 76/2
76/15 77/8 78/23
78/24 86/14 98/8
101/9 101/10 101/12
103/5 103/7 104/4
106/10 108/3 116/17
116/23 121/22 122/24
123/16 130/12 130/14
134/9 139/13 141/4
141/12 142/6 144/9
145/12 147/24 149/1
149/24 150/17 152/25}
yesterday [3] 54/8
125/12 125/25
yesterday's [1] 84/24
yet [8] 36/6 36/8
50/25 51/19 60/15
127/6 128/11 152/1
you [468]

you'd [2] 120/15
155/6

you'll [3] 7/3 10/20
134/20

you're [38] 3/16 6/11
7/9 16/10 41/4 63/15
63/16 67/5 72/12
79/12 82/14 87/18
97/11 105/15 106/18
108/18 108/18 115/1
116/6 116/14 130/11
133/7 134/9 135/7
139/21 140/10 140/10}
143/11 144/3 145/10
145/20 148/14 150/15}
151/1 151/2 151/22
152/1 154/24

you've [19] 26/4
37/22 38/15 41/17
42/21 73/19 74/10
78/22 89/24 93/9
103/17 123/10 126/17
141/22 147/20 151/25)
155/16 155/24 163/1

109/15 109/16 112/18)

yes [67] 1/14 2/14 3/7

YouGov [1] 159/3
your [97] 1/9 1/16
1/19 3/12 5/13 5/14
10/5 10/24 11/2 12/3
13/1 14/1 15/9 17/17
18/22 18/24 19/7
20/12 20/15 20/16
21/4 29/24 32/16
37/22 38/5 38/16
A117 42/19 42/21
42/21 44/25 45/8 47/1
50/3 51/10 51/18
57/24 62/16 66/23
67/5 73/16 73/19
74/17 79/10 86/8 94/7,
94/24 97/5 97/14
98/25 101/6 101/17
102/16 104/1 107/24
109/11 111/2 111/13
113/23 114/9 116/24
118/4 118/17 120/18
121/25 122/16 122/25)
123/3 131/13 136/22
137/18 137/21 139/23}
140/2 140/25 141/6
143/9 143/12 143/14
143/15 144/22 144/24
145/4 145/9 145/14
145/19 148/4 148/24
152/17 154/23 155/3
155/6 156/19 158/3
158/7 158/22 162/15
yours [1] 25/4
yourself [8] 17/10
37/12 62/25 63/16
64/12 85/5 98/24
153/1
yourselves [1] 40/13

Zo
zoom [1] 123/13

(71) wishing - zoom