INQ00001187 - Transcript (26/09/2024): Post Office Horizon IT Inquiry - Calum Greenhow [WITN0037]

Evidence on official site

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The Post Office Horizon IT Inquiry

Thursday, 26 September 2024

(10.00 am)
MS HODGE: Good morning, sir, can you see and hear me?
SIR WYN WILLIAMS: = (Microphone muted)

MS HODGE: You appear to be muted, sir. Currently we can't

hear you.

We are just making some enquiries to see why it is.
that we can't hear you, sir.

Sir, would you be able to speak so we can check
whether we can hear you now? Sir, we're going to take
a short break so we can establish the issue with your
connection.

13 (10.02 am)

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(A short break)

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16 MSHODGE: Hello again, sir. Can you see and hear me?

17 SIRWYN WILLIAMS: I can.

18 MSHODGE: Good. I'm pleased to say we can see and hear you

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again now.

20 SIRWYN WILLIAMS: Good, thank you very much. Sorry to

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everyone for the delay.

22 MSHODGE: Our witness today is Calum Greenhow. Please can

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the witness be sworn.
CALUM BRIAN GREENHOW (sworn)

Questioned by MS HODGE
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Inquiry but also Lord Justice Fraser for the work that
you've all done because, without your work, we would not
know what we know today.

I approach the Inquiry as a postmaster who has
served behind the counter and used Horizon since 1999
and still do today. I wanted to know the truth, the
whole truth and nothing but the truth, even if that
meant some uncomfortable truths were discovered about
the organisation that I lead today.

I'd like to thank those who you were involved, such
as Sir Alan Bates, Jo Hamilton, Lord Arbuthnot,
et cetera, because it's their tenacity, their dignity,
their courage and their determination that we're here
today. I'd like to offer them all my apologies as the
Chief Executive of the NFSP and ask for their
forgiveness for the part that the NFSP has played in
what they've experienced and what they've had to endure
over that period of time, and I hope that they will
accept my apologies in the manner that it is intended.
Thank you.
Thank you, Mr Greenhow. You are currently employed as
the Chief Executive Officer of the National Federation
of SubPostmasters; is that correct?
lam.

Before we examine the circumstances of your appointment
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26 September 2024

MS HODGE: Please give your full name.

A. Calum Brian Greenhow.

Q. You should have in front of you a copy of your witness
statement dated 4 September 2024?

A. Ido.

Q. That statement runs to 133 pages; is that correct?

A. Yes.

Q. Can please ask you to turn to page 124 of your
statement?

A. Yes.

Q. Do you see your signature there before you --

A. Ido.

Q. Is the content of that statement true to the best of
your knowledge and belief?

A. Itis.

Q. Mr Greenhow, my name is Ms Hodge and I'll be asking

questions on behalf of the Inquiry. Before I do so,
I believe there's a statement you would like to make; is
that correct?

A. Iflcan. Something rather odd happened yesterday.
When my Inquiry counsel and I were heading to
an accommodation last night, we came out of Holborn tube
station and I literally had to step out of the way of
Lord Justice Fraser. And the reason that I mention that

is I think it is important that I thank not only the
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as CEO, I'd like to ask you some brief questions about
your background, please. You say that in August 1995
you and your wife purchased the Post Office branch in
West Linton, a village located in the Scottish Borders;
is that right?

A. We did.

Q. You were appointed the SPM of that branch, which you ran
with your wife until your appointment as CEO; is that
correct?

A. Yes.

Q. In 2001 you became a member of the NFSP, which at that
time was registered as a trade union; is that right?

A. Yes.

Q. You've explained in your statement that the NFSP is
currently divided into 53 separate branches and ten
separate regions; is that correct?

A. Yes.

Q. Does that representation extend to the whole of the
United Kingdom, including Northern Ireland?

A. Yes, it does.

Q. Has the number of local branches and regions remained
consistent throughout the time covered by this Inquiry?

A. I don't think it has but I cannot confirm that. I am
giving it from its current basis.

Q. Before you were appointed the CEO of the NFSP, you held
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The Post Office Horizon IT Inquiry

various different roles within the organisation; is that
correct?

Yes.

In 2010, you were elected the President of the South of
Scotland branch; is that right?

I was.

Do you recall how many branches of the NFSP there were
in Scotland at that time, roughly?

Seven?

Do you know how many Post Office branches were located
within the South of Scotland at that time?

I can't remember offhand. It would be 100/150, I think.
What did your role as President of the South of Scotland
branch entail?

In essence, I was Chair of the region -- of the branch,

so if we had our branch meeting it would have been my
responsibility to chair the meeting and support the
branch secretary but it was the branch secretary who
really did most of the work. That would also involve
attending regional meetings, and then conference.

I attended the NFSP's annual conference for the first
time in 2010.

In 2012 you were elected the branch secretary of the
South of Scotland branch; is that right?

I was.

membership would be taken whether to adopt or not that
particular motion.

You say that the motion was a request, from whom?
From the members.

What function was performed by the Committee in relation
to these motions?

So, in essence, we were looking at whether there was
motions that came in that had a similar vein to them or
similar thought, and we might amalgamate those together;
whether that motion had been asked within the last two
years and had been rejected, so it would have to carry
‘over for another year. In essence, that was really it.

So the Committee was responsible for either permitting
motions to go to conference or rejecting them; is that
correct?

One of. I was -- ultimately the decision was of the
Executive Council, I believe but, certainly, we would
meet in the March of the calendar year to actually go
through those motions and, normally, the President of
the NFSP, along with the General Secretary of the NFSP_
would be present and others, and they would be
discussed, and then we would try and put them into
themes, et cetera. But, yes, in essence, we were a form
of the ability to enable those motions to be brought to
conference.

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Please can you describe the role performed by the
secretary of the local branch?

In essence, it was to be there as the contact point for
members, to distribute information, if any postmaster

had a problem or an issue I would be the first port of

call. If there was an interview with the Post Office,

I may go along to that or it may have been left to

others.

In 2013 you were elected as the representative for
Scotland on the NFSP's Standing Orders Committee; is
that correct?

Yes.

In your statement, you say that the committee was
responsible for dealing with the motions from branches
which would go to the annual conference. Can you please
explain what a motion is?

So a motion would be -- well, conference, in essence,
was a whole series of questions, thoughts, ideas, that
were being brought to the attention of the wider NFSP
membership, and a motion was an individual request that
may go to -- it would instruct the Executive Council to

do something, and then what would happen is that would
be debated at conference by all who attended conference.
It would be debated prior to that at a regional meeting,

for example, of members, and then a decision by the
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But also to filter them; would that be fair?

Yes.

In 2016 you were elected to the Board of the NFSP as the
Scotland Regional Non-Executive Director; is that
correct?

Yes.

By that stage, the organisation was no longer registered
as a trade union --

Yes.

-- having, in September 2015, established itself as

a private limited company; is that right?

Yes.

I'd like to ask you some questions about your decision
to seek appointment as the CEO of the NFSP. In your
statement, you say that you wished to make the
organisation more inclusive and representative of its
members; is that correct?

I think that was in relation to me being the Chief
Executive.

Yes. Forgive me, this is -- sorry.

Yes.

I'm asking you now about your appointment as Chief
Executive?

Oh, sorry, I thought you were talking about the Board.
Sorry. Apologies.

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The Post Office Horizon IT Inquiry

So, concerning your motivation for seeking appointment
as the Chief Executive, one of the points you raise in
your statement is that you wished to make the
organisation more inclusive --
Yes.
-- and representative of its members; is that correct?
Yes.
You also describe in your statement that you considered
your predecessor's approach to leadership was
autocratic; is that correct?
Yes.
Can you please explain why you characterised
Mr Thomson's leadership in that way?
Well, I think if anybody who's been to the Inquiry may
have seen just exactly how George acts. If you didn't
agree with him, he would let you know, and he was very
much about pushing forward his view, his thoughts, his
ideas. I felt that, as an ordinary member and even as
a Board member, there was a toxicity within the
membership of the NFSP towards him, there was a lot of
negative feeling against him, and I think a lot of
things that were going on -- that people didn't know
what was going on, there wasn't much communication, and
therefore I felt that that was not the right way.

I'm a completely different person. I'm not

The Inquiry has been shown the minutes of the meeting to
which you refer in your statement. For reference they
can be found at NFSP00000500. I think you accept, do
you not, that your comments are not recorded in those
minutes; is that correct?
Yes.
Why is it, do you think, that your comments about the
integrity of Horizon were not recorded in the minutes of
the meeting?
I don't think there was any particular reason for it.
I think what was recorded was what Peter Montgomery was
saying and we were coming at the same sort of issue from
a slightly different angle. But so I think Peter's
comments were maybe more valid or more a summation of
the debate and the conversation that was going on, so
that was all recorded. I don't think there was any
specific reason why my comments were not recorded.
There is a reference in the minutes of the meeting to
the principle of collective cabinet responsibility.
Please can we display the minutes to see that reference
in its context. It's the bottom of page 22 on to
page 23, please.

Thank you we see at the first bullet point your
colleague Peter Montgomery, who you reference raising

the issue of the Group Litigation, and if we go down to
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an exclusive person; I'm an inclusive person and I've
got nothing to hide in any way, shape or form, so

I really want to get out there, engage with my fellow
postmaster members, seek their views. You know, their
experiences is vast, their knowledge is vast and it's
important to listen to different ideas. It doesn't
necessarily mean to say that, just because someone puts
forward a view, that that would be the view that's taken
forward. But it's important to listen to what people

have to say, take it on board, and then make a decision
and that's not what I saw with George.

According to your statement, when you were first
appointed a member of the board in mid-June 2016, you
challenged the stance being taken by the Board and the
then CEO, in relation to the integrity of Horizon; is

that correct?

Yes, it is.

You state that you recall telling the Board at a meeting
in mid-June 2016 that Horizon could not be correct

100 per cent of the time; is that right?

Yes.

You also stated, you say, that even if there were no
systemic issues with the system, there might still be
local faults; is that correct?

Absolutely.
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the bottom, please, the final bullet point reads:

"The NFSP's policy has always been that it is
a robust system and we have fully confidence in it."

That being the Horizon system.

If we could scroll down, please:

"Do not believe the system is systematically faulty.

"Most people that blame Horizon for losses are
overinflating their cash declarations, false accounting.

“Subpostmasters take money sometimes and members of
staff also take money.

"Reminded that members of the Council should adhere
to collective cabinet responsibility.”

Did you feel compelled by your membership of the
NFSP Board to toe the party line on the integrity of
Horizon?

No.

You say in your statement that the purpose of raising
questions about Horizon's integrity in the first Board
meeting was to try to build some momentum that would be
capable of challenging the stance adopted by your
predecessor; is that correct?

Yes.

What further steps did you take, either at Board level

or within the wider NFSP organisation, to build that

momentum to challenge his stance on Horizon?
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The Post Office Horizon IT Inquiry

Difficult to remember everything that took place so long
ago but, in essence, obviously you can see from Peter's
view, we would regularly go for walks, we would have
discussions, I would talk to other individuals, with

members within the Federation, other postmasters who had
a different view. I felt that it was important to

understand the Board, see where the Board were sitting,
see, you know, many of them I didn't necessarily know
personally at that point. Get to know them, get to sort

of understand them and get to see where they went. And
whenever any opportunities arose to actually maybe have
different view, I would take that forward.

Now, we know that your appointment to the Board took
effect in or around June 2016; is that correct?

Yes.

Between that time and your appointment as CEO, did you
ever raise the issue of Horizon's integrity again with

the Board?

Sorry, say that again?

So between your appointment to the Board as

a Non-Executive Director --

Oh, sorry.

- in June 2016 and your appointment as CEO of the NFSP
in 2018, did you ever raise the issue of Horizon's

integrity again at the Board, so far as you recall?
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reliability of the Horizon system?

Correct, and can I just add to that, actually, as

someone who had used and was using Horizon, whilst there
may have been issues in relation to it freezing, or
problems as far as screen or a printer or a base unit

not working, that would be what maybe people would have
come to me about. But as far as ascribing losses to
Horizon, to my knowledge, no one came to me about that.
Looking back, does it surprise you that the problems

with Horizon were not brought to your attention in your
capacity either as President or Branch Secretary of the
South of Scotland branch?

Not really, no.

Why is it, do you think, that these problems weren't
reported to you?

I can't answer that specifically. All I can say is,

again, as someone who was using Horizon, I didn't see
Horizon as an issue. We were using it, it was

functioning; clearly, for some people, it wasn't. I can

only go on my own personal experience of having used
Horizon and, other than it freezing, a scanner not
working, I've not had any personal experience of faults
with the software that have caused -- that I believe

have caused losses in my own branch and, between 2012

and 2015, no one had raised that sort of issue with me,
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I don't think I did. Certainly, from what I can see

from the minutes and emails, I don't think it actually
came up.

I'd like to go back in time, please, to examine when you
first became aware of concerns about the integrity of
Horizon, in your statement you first date your awareness
of issues with Horizon's integrity to the summer of

2015; is that correct?

Yes.

By that stage, you'd held the role of branch secretary
since 2012; is that right?

Yes.

And you'd been appointed the elected representative for
Scotland on the Standing Orders Committee?

Yes.

You've explained in your statement and in your evidence
this morning that, if members of the NFSP had concerns
that they wished to raise, their first point of contact
would be the branch secretary; is that right?

Yes.

Or one of there first points of contact?

Yes.

Does it follow that during the time in which you served
as Branch Secretary for South of Scotland, that no

member ever raised any concerns with you about the
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and as I was going to regional meetings it wasn't really
being raised much there.

What was being raised was more about Network
Transformation and other sort of like issues.
We know from documents which have been disclosed by the
NFSP that some local branches of the organisation were
seeking to raise concerns about Horizon --
Absolutely.
-- in the motions which they submitted for consideration
at the annual conference. Please can one of these
documents be shown on the screen, it bears the reference
NFSP00001037. Thank you. This document appears to
contain a list of motions submitted by the Midlands
region of the NFSP for consideration at the annual
conference held in 2010; is that right?
Yes.
The third motion in the list reads as follows:

"This conference mandates the EC ..."

That's a reference to the Executive Council, is it?
Yes, the Executive Council, yes.
"... not to accept any changes to the Horizon system
(either firmware or software) until fully validated as
‘fit for purpose’ by the Horizon steering group."

Can you help us, who sat on the Horizon steering

group?
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This was obviously well before my time. I attended
a conference for the first time in 2010. I -- as I said

in my opening statement, I came in to try and find out,

this was something that I found out but, as far as who

that Horizon steering group is concerned, I've never

been able to find out exactly what that was.

Please could be scroll down to the sixth motion, thank
you, in the list. That reads:

"That this conference mandate the EC to demand that
POL retain all historical Horizon data that relate to
Horizon failures both firmware & software for a minimum
of [12 months].”

Mm.

From what you said just now, it appears to be that you
were not aware of these motions at the time when they
were submitted; is that correct?

No, I -- no.

You have said, however, that you attended the annual
conference of the NFSP for the first time in that year
of 2010; is that right?

Yes, I did.

Does it follow that these motions were not debated at
the annual conference which you attended?

I'm sorry, I can't answer that question, I don't --

I can't remember.
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responsibility of the subpostmaster."
Then it in brackets it reads:
"Subpostmasters not to be responsible for computer
generated discrepancies on Horizon."
Under the heading "Status", it reads:
"Where evidence exists that the error is not as
a result of human input then a claim will not be
pursued."
Who would have been responsible for reporting on the
status of this motion?
I would imagine the Executive Council.
This entry appears to accept the possibility that
discrepancies were generated by Horizon, does it not?
It certainly reads that way, yes.
When did this document first come to your attention?
I think, as I -- as we were preparing documents for this
Inquiry.
You mention in your statement that you watched the BBC
Panorama programme which was aired in August 2015; is
that right?
Yes.
In your statement, you say this about the programme:
“When I watched the Panorama programme and saw
Hughie Thomas, Jo Hamilton and Seema Misra, I couldn't

see them as people who had stolen money."
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Who would have been responsible for determining whether
or not these particular motions were debated at the
annual conference?

I'd imagine -- so the Standing Orders Committee and the
Executive Council.

To be fair to you, you weren't yet a member of the
Standing Orders Committee --

No.

- at that time?

No.

You took over in 2012 -- you joined in 2012?

No, I joined in 2013.

Sorry, 2013.

Please could we look at another set of motions, they
bear the reference NFSP00001044. Do you know from which
region of the NFSP these orders were submitted?

Off the top of my head, no, I don't.

Are you able to tell us to which annual conference they
related?

No, I can't.

Could we turn, please, to page 5 of this document. It's
motion number 43. Thank you. It reads:

"That this Conference instructs the Executive
Council to negotiate with Post Office Limited that

computer generated discrepancies are not the
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Is that right?
Absolutely.
Does it follow that after watching the Panorama
programme, you became concerned that the Post Office
might have wrongly prosecuted subpostmasters in reliance
on data generated by Horizon?
Yes, and, obviously, I've provided evidence, or there
has been evidence provided to the Inquiry, that shows
that.
Shortly after watching the programme, you received and
read a branch circular from George Thomson, then CEO of
the NFSP; is that right?
Yes.
Please can that document be shown on the screen. It
bears the reference WITN00370126.

Thank you. So this is the "Branch Secretaries’
Circular". Can you just briefly explain what the
purpose of a circular like this is and was?
Yes, so obviously this was before the mass usage of the
Internet, as we have, or the various social media
channels. So, at that time, providing information from
Shoreham to the members came via the Branch Secretary,
so we would receive these circulars and it was our duty
and our responsibility to distribute that information to

members within our particular branch or region.
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You said that it came from Shoreham?
Yes.

By that, you mean the central office of the National
Federation of SubPostmasters?

Yes, sorry, the NFSP headquarters in Shoreham, yes.

So this circular is dated 18 August 2015. It's

volume 24, addressed to the Branch Secretary, and it
bears the heading "Post Office under the Spotlight".

Could we go scroll down to the third paragraph, which
addresses the Panorama programme. It reads, the second
sentence please:

"Last night's Panorama BBC1 documentary sought to
get underneath the bright shiny exterior of the Post
Office and reveal a less palatable side of the business:
the longstanding issue of prosecutions of subpostmasters
and the alleged [systemic] failings of Horizon looks set
to continue for some time yet.

"Over the past few years the NFSP has received
thousands of telephone calls from subpostmasters. The
majority relate to employment law, contract issues and
Network Transformation. The remainder cover

ATMs, I assume that's meant to say.
Yes.
.. cash supply and just about every subject you care

to mention, including a handful every month on Horizon
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that document, it's already been shown in this Inquiry
but I'm happy to do so if there's any particular part of

it you wish to draw to the Chair's attention.

I just think, you know, obviously -- I mean, it was
difficult, so I think as a branch secretary at that

point, you know, I just considered myself an honorary
postmaster. I just, you know, having watched the
Panorama programme, it was really, in essence, me
starting to get, to understand, "Hang on a second, maybe
there's something more to this". Up to that point, you
know, we occasionally heard of people being convicted,
people admitting their guilt but we hadn't really heard
too much about the possibility that, actually, it could

be Horizon, and this was, in essence, me starting to get
to question that -- you know, a little question mark
going "Hang on, is there something more here?"

And I felt this statement was more saying, "There's
absolutely no possibility that there could be anything
wrong. You know, Horizon is absolutely sound", and
I just didn't -- I don't feel that a computer system, as
we have seen today, can be 100 per cent, 100 per cent of
the time. And, therefore, I felt that it was important
for myself to try and reach out to the General Secretary
and say, "Could you possibly look at this a different

way? Is there a possibility that there is something
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connectivity and the problems of getting through to ATOS
and the Helpdesk.

“Put simply, the NFSP has not received calls from
subpostmasters querying Horizon and alleging [systemic]
failings. If there was a widespread problem, our
subpostmasters would have made us aware of it. As
a result, we have no choice but to conclude that Horizon
is a fundamentally sound and safe system."

In your statement you explain that you did not agree
with the message conveyed in this circular and that you
decided to raise your concerns with the CEO; is that
correct?
I think he was General Secretary at that point but yes,
yes.

You wrote an email to Mr Thomson on 19 August 2015, in
which you invited him to consider the possibility that
those who were challenging the integrity of Horizon

might be correct?

Yes.

You invited him to show his support for the SPMs whose
cases were being reviewed by Second Sight; is that
right?

Yes.

For the benefit of the transcript, that email bears the

reference POL00162628. I don't propose to take you to
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different to this?"

In addition to raising that concern with the General
Secretary, you also contacted Paul McBain who was then
the Scottish Non-Executive Director; is that right?
Actually, at that time, he was the Regional Secretary.
Regional secretary.

He did eventually become Non-Executive Director but at
that time he was Regional Secretary.

And Donald Ramsay, who was then the Scottish Executive
officer; is that right?

Yes.

You proposed to Mr McBain that the NFSP conduct its own
and fully and independent inquiry into Horizon's

integrity; is that right?

Yes.

You requested that the issue be placed on the agenda for
the forthcoming regional meeting?
HEXAMIIIndex2I*{S.{TR:5}P}Yes.

That meeting took place on the 2 October 2015; is that
correct?

Itis.

You've provided the minutes of that meeting, which bear
the reference WITN00370131. Please can that be shown on
the screen.

This bears the title "Minutes of meeting of Scotland
24

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Regional Council Held Grampian Hotel, Perth on 2 October
2015."

To clarify, did you attend that meeting on

2 October?

Yes.

Itlists certain apologies but are you able to confirm
who else was in attendance at that meeting?

Sorry, I'm just looking at the Vice President sort of
above -- so, obviously, Jamil Ahmed was there; the
National President, Jim Nott was there; and Laura
Hobbins who, from memory, was an employee of
Parcelforce; and there would have been other branch
secretaries, obviously the Executive Officer, Donald
Ramsay, and Paul McBain.

In fact, at that time there would have been two, so
there might have been Andrew Gilhooly as well; as I say,
other individuals. But beyond that, I can't remember,
specifically.

You say Mr Jim Nott was the National President at that
time; is that right?

Yes.

Please can we turn to page 2 of the minutes where we can
see some discussion in relation to Horizon. If we could
scroll down, please. In bold there is a heading

"BSC 24", is that a reference to the branch circular we
25

Finally, the minutes record that:

"The agreement with the delegates was to accept the
response but believe that the issue would return due to
MPs signing an Early Day Motion.”

Now, the reference to the response, shall we
understand that to mean the response of the National
President or the response of Mr Thomson in the branch
circular; are you able to assist?
I think it would have been what was said on the day by
the National President.

By the National President. These minutes show, do they
not, that the delegates at this meeting, of which you
were one, agreed to accept the party line on Horizon?
Yeah, I suppose that's correct.

Why did you accept the response of the National
President if you believed, by this stage, that the Post
Office had wrongly prosecuted subpostmasters?

I think at this stage I was beginning to question,

rather than be absolutely certain, that the Post Office
were wrongly convicting. I think, at this point, I was
starting to think differently but, as far as evidence is
concerned, I didn't have that at that time. I was, you
know, watching sort of, obviously, the Panorama
programme and thinking something's not right here. But

as far as having absolute evidence and proof, as we now
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saw on screen a short time ago?
I believe it is.
It reads:

"BSC 24 under the spotlight with regards to the
Horizon system and what it does or does not do.

National President agreed that the Post Office did a lot
wrong in the early years but there is no evidence that
the systems were at fault."

What did you understand the National President to
mean when he said that the Post Office did a lot wrong
in the early years?
I cannot say for definite what that means. It's not
something I can remember discussing with Jim. So
I can't say for definite, sorry.

The minutes then say this:

"The National President also explained that the
system was checked annually for its robustness and no
issues were found by these outsourced companies of which
Pricewaterhouse was one."

Do you know from where the National President
obtained that information?

No, I don't. I can only -- if he's mentioned
Pricewaterhouse specifically, I can only assume that he
had received some information that had Pricewaterhouse

on it.
26

do, I did not have that at the time and neither did any
of the other individuals who were attending.

And, again, we were all postmasters, we are all
using the system. And whilst we may have had problems
with the -- as I say, with the screen or with the
hardware, as far as understanding that there was
potential problems with the software that may have been
making falls discrepancies, that the Post Office were
maliciously prosecuting those individuals as a result
of, I don't think any of us had that evidence at that
time.

But we were -- our feeling of the Post Office was
not one of -- yeah, they're -- well, put this way, sort
of I think even all -- even I have been stunned by
exactly what's gone on. I still struggle to understand
the scale of exactly what's gone on. As I've said
elsewhere in my statement, you know, Government, the
Civil Service, big business, in terms of Post Office,
Fujitsu, Royal Mail, even the legal industry, are
involved in this.

Collectively, we all got it wrong. You know, we
cannot ignore that there's 900 cases, that's 900
prosecutions, 900 defences, 900 judges that were all
involved in that. You know, our faith in the legal

industry is such that, well, we would hope and expect
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the legal industry to have investigated this properly,
and, if they were convicting, then it must be -- there
must be something in it. You know, that's where we
were. And, therefore, we didn't have the evidence to
suggest that the scale of the cover-up and the scale of
what was going on and the scale of the victimisation was
actually present.

Q. In your statement you say that you don't recall taking
any further steps after this meeting in October to raise
your concerns, to escalate your concerns about Horizon;
is that correct?

A. Itis. If! can just say, actually, I can't find any
evidence. I look back in my own personal emails at that
time to sort of see if I had done anything. I do
highlight that, obviously, I had to make a decision, my
wife and I were having to make a decision as far as our
own business in relation to Network Transformation and
we'd had to make the -- or were making the very
difficult decision to, in essence, exit the business and
what that implication was going to have on our future.
I mean, we live above the post office, our post office
is attached to the business. If we -- if we lost our
business, we were going to lose our home. We were going
to lose our ability to care for and provide our

daughters.
29

a result of the NFSP lobbying. I don't know.

SIR WYN WILLIAMS: Right. Thank you.

MS HODGE: Thank you, Mr Greenhow, I'd like to ask you now
about your knowledge of a defect in Horizon Online,
known as the Dalmellington bug.

A. Yes.

Q. The existence of this bug was brought to your attention
by Tim McCormack, a subpostmaster who, at that time, was
a member of the Communication Workers Union; is that
right?

A. Yes.

Q. Do you know why Mr McCormack came to you with his
concerns about this bug?

A. Tim and I sort of communicated backwards and forwards.
I can't remember the specifics of it. I can remember
obviously dealing with a particular case, and whether
I had read something or was aware of something or --
I mean, obviously Tim has provided a lot of blogs.

Maybe I had read something that he had said in a blog,
and contacted him but he certainly wouldn't have known
that I was dealing with this.

So I may have contacted him just to say, you know,
“Have you heard of anything along these lines?", or
I may have read something in what he said, which

encouraged me to contact him to ask a little bit more
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Those were big decisions and, you know,
understandably, that's where my focus was or was at the
time. I'd raised it, and other things came in that, you
know, demanded my time.

SIR WYN WILLIAMS: Mr Greenhow, what does the last part of
the last sentence mean, "believe that the issue would
return due to MPs signing an Early Day Motion"; can you
translate that for me please?

A. I can give you what I think it means. I can't
necessarily say that it's specific. Obviously, an Early
Day Motion, to my knowledge within the political field
is that an MP will bring a motion, which is called
an Early Day Motion --

SIR WYN WILLIAMS: Right, sorry to stop you. So I wondered
whether this was something to do with a person MP within
the NFSP but it's not, it's about an MP raising it --

A. Yes.

~ in an Early Day Motion?

A. Yes, if I may explain, sir. The NFSP does not have any
political affiliations. We're apolitical on that basis.

We provide no funds to any political party. So, you
know, we do engage, obviously, and we lobby MPs on
behalf of postmasters to highlight exactly what's going
‘on in the network but this may have been done

independently of the NFSP or it may have been done as
30

2

because the Dalmellington bug seemed to be similar to
what -- a situation that I was dealing with on behalf of
a colleague.

Q. You've produced a copy of the email which Mr McCormack
sent to you on 9 August 2016, please can that document
be shown on the screen. It bears the reference
WITNO0370129.

Thank you. So halfway down the first page, we can
see the email from Mr McCormack to you on 9 August. It
reads:

"Hi Calum

"Just had a call from Mark Daniels."

Who was Mark Daniels, please?

A. Mark Daniels was a dual member of both the CWU and the
NFSP.

Q. "We really need to talk about this. You won't know half
of the story surrounding Dalmellington yet but one of
the most important points that has come out of it has
been [the Post Office's] refusal to inform the network
that this type of problem can occur.

"Seema Misra was sent to prison for falsifying
accounts and the Judge specifically noted that if the
computer caused the shortfall in the accounts then she
should have noticed. Pretty difficult when [Post

Office] know about these problems and don't tell you
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what to look for.

"Please -- this is so important for all remaining
[SPMs] and new entrants."

He then gives his telephone number.

In this email, once again, we see, on this occasion,
Mr McCormack alerting you to the risk that
subpostmasters had been and were being wrongly held
accountable for bugs in Horizon, which the Post Office
knew about, but were not willing to disclose; is that
fair.
Yes.
We can see he asked you to contact him and, in the email
above, you say you will do. Did you, in fact, contact
Mr McCormack?
I think I did.
Do you recall what he told you about the Dalmellington
bug?
He described what actually happened. Would you like me
to -- yes.
Yes.
The Dalmellington bug to my understanding is where
a postmaster operates what's known as a core and
outreach. Now, the core is a full-time office and
an outreach would be a part-time office, where they

would go out to a small community, neighbouring
33

action to draw the existence of the bug to the attention
of the NFSP Board?

Unfortunately, I don't think did.

Looking back did the existence of this bug not provide
you with the ammunition which you needed to challenge
the stance being adopted by the then CEO?

Well, it certainly gave me further evidence that maybe
something isn't quite right. But I think -- I don't

know if you'll want to come on to it -- obviously, when
we had the interview with the Post Office, I documented
that I did challenge the Post Office --

I'll come on to that.

Oh okay, sorry.

But if we just take it in order ~

All right.

So you've explained in your statement that you later
became involved in a case of a subpostmaster who
operated an outreach branch in Scotland; is that
correct?

Yes.

That postmaster had experienced a discrepancy of
£39,000 --

From memory, yes.

-- which related to the transfer of cash and stock

between their core and outreach branches?
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community, and they would set up a Post Office,
basically they would take the Horizon kit with him, and
they would set it all out and then the community could
come in and they would be able to serve them and provide
them with the services that they require.

What would happen is you would transfer cash and
stock from your core office into your outreach office,
and take it, obviously, to that location. You may also
at times -- and I've never operated one so I'm going
from my understanding -- you may want to transfer cash
and stock from the outreach back into the core.

My understanding is that you did that in exactly the
same way as if we were sending cash and stock back to
the Cash Centre, or receiving cash and stock into our
post office.

Sorry, by Cash Centre you mean the Post Office?

The Post Office, sorry, yeah the Post Office Cash
Centre. And my understanding of the Dalmellington bug
is that that process could be faulty and could result in
double entering or triple entering and, I believe, in
Dalmellington, as the person was scanning it, it was
creating multiple entries, which was causing it to look

as if the -- her outreach or her core actually had more
cash and stock than it actually had.

Having been told this, by Mr McCormack, did you take any
34

Yes.

You believed, you said, based on the information which
you'd been told by Mr McCormack, that the discrepancy
might have been caused by the Dalmellington bug; is that
right?

Yes.

When you accompanied the subpostmaster at his interview,
which was conducted by Brian Trotter --

Yes.

the Post Office Contracts Manager in Scotland, you
raised the existence of the bug with Mr Trotter; is that
correct?

I asked him about if it was possible that the
Dalmellington bug could be responsible for the situation
here because it had very similar hallmarks to it.

How did Mr Trotter respond when you raised this --

He simply said that it couldn't possibly be because that
had been dealt with prior to this happening.

Were you satisfied by that explanation?

No.

How did the meeting conclude?

As I put in my statement, I believe there was two action
points. The Post Office were going to go away and get
the evidence and, unfortunately, one of the aspects

that, as I was asking for evidence, the Post Office were
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saying, "Well, that's not going to be easy, it's beyond
the six months that we keep, we're going to have to go
to Fujitsu".
Sorry, just to stop you. Evidence of what, please?
Evidence of what the Post Office were presenting as
potentially the reason why the -- well, in fact, they
weren't providing any evidence, to be truthful. They
were -- the way that they did the interviews is they
asked the postmaster why it couldn't possibly be -- how
did this discrepancy take place? They weren't providing
any evidence. They weren't coming in and saying, "On
such-and-such a day you did this, this and this"; they
were just simply asking, "You've got a loss, explain to
us how that happened". So, in other words, it was up to
the postmaster to be able to prove how that happened.
So I was challenging the Post Office for the
evidence as to how that discrepancy could take place
because the postmaster couldn't possibly get it, because
it was beyond -- we any have access to three months' of
data within our office. We were talking over a year
here. So, therefore, I was asking the Post Office, "You
need to go away and provide that evidence and, until you
provide that evidence and prove it, we're not prepared
to sort of accept it".

You were saying in relation to your request that they
37

made things worse. But I never got any information from
them unfortunately.
How did this particular case conclude?
I eventually contacted the postmaster, I think in
December, and he had been notified that his contract had
been terminated but I had -- as I say, no ever had been
provided to me, no further correspondence had taken
place with the Post Office, and I felt that that was,
you know -- was not right.
Looking back, do you consider that you could or should
have done more to challenge the Post Office's refusal or
failure to provide documentary evidence to support --
I mean, I think it's difficult, because when you're --
and as I learned with the Post Office, you ask them
something they don't want to say, I calll it they go into
their "black hole", and you just don't get any
correspondence from them. You can bang your head
against a brick wall until you've got a rather sore head
and it just doesn't happen. They just literally
withdraw, withdraw, withdraw. And, you know, to be
honest I didn't know what more I could do.

I just continued to believe in the postmaster,
support the postmaster and, obviously, when the GLO
concluded, I was straight on the phone to the

postmaster. When I heard there was the Historic
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supply that evidence?
Yes, I was asking for them to do that.
What was their response?
They would go away and they would provide it and, sadly,
they never did.
What, if any, steps did you take to follow up on that
request that the Post Office produce evidence of how the
discrepancy had occurred?
Well, I kept on asking for the evidence to be provided
because, again, as I say in my statement, I would be in
contact with the postmaster and they hadn't heard
anything. Getting any information out of the Post
Office was not easy, they were not great at responding
to either phone calls or to emails and, at one point,
I discovered that the case was being heard or was being
considered before the Senior Contracts Manager at the
time.

I had not been informed of that. The postmaster had
been. In fact, actually the Post Office didn't really
engage with us on it, which was really a concern to me
and it stuck with me ever since. In fact, I think, sort
of me bringing up the Dalmellington bug, I've always
wondered if that had an impact on how the Post Office
treated the postmaster, and it's always been a concern

to me if me bringing that up has actually, you know,
38

Shortfall Scheme, "You need to get yourself involved in

that, I think you've got a case", and it was then that

I discovered that he was thankfully part of the GLO.
But as we sit here today, five years after that, he

still has not received his redress, which I think is

shocking.

MS HODGE: Thank you, sir. That brings the end to that

particular topic I wish to discuss. It may be
a convenient time to take a 15-minute break.

SIR WYN WILLIAMS: Yes, by all means, Ms Hodge.

I've got it right, have I: the detail which
Mr Greenhow has been giving orally, essentially I can
find it at paragraphs 99 and 100 of his statement, yes?

MS HODGE: That's correct, sir.
SIR WYN WILLIAMS: Yes, thanks very much. Yes.

So we'll start again at 11.25, is it?

MS HODGE: Yes, sir.
SIR WYN WILLIAMS: Fine.
MS HODGE: Thank you.
(14.09 am)

(A short break)

(14.25 am)
MS HODGE: Good morning, sir. Can you see and hear me?
SIR WYN WILLIAMS: Yes, I can, thank you.

MS HODGE: Thank you.

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I'd like to move on, please, Mr Greenhow, to examine
your approach to the Group Litigation brought by
Sir Alan Bates and others against the Post Office.
Yes.
You say in your statement that you did not share your
predecessor's dismissive attitude towards the Group
Litigation; is that correct?
Correct.
And that, upon being appointed as the CFO of the NFSP,
you wished to demonstrate that your attitude to
litigation was different?
Yes.
In your written evidence, you say that you attended the
first day of the Common Issues trial and that you had
hoped to shake hands with Sir Alan Bates but the
opportunity did not arise; is that correct?
Maybe just the way I've described it. I can't remember
exactly the reason why but, obviously, as you know, the
layout of this room, there's the anteroom, and I was
outside, I can't remember the reason why I was outside,
and, all of a sudden, Sir Alan came out of the room and
it was only myself and him in this foyer or wherever.
I was at one end and he was at the other end, and he
quickly disappeared. He may have been going to the

toilet or something like that, I honestly don't know.
41

think we could get involved at that stage. I certainly
had no idea that the NFSP would be a significant focus
of the GLO proceedings.”
That can be brought down, thank you very much.
A short time ago, you told the Inquiry, that you
believed that Hughie Thomas, Jo Hamilton and Seema Misra
were not guilty of stealing from the Post Office. Why
then did you not speak out the publicly in support of
the Group Litigation?
Quite simply, I didn't think we could. It's as simple
as that.
You were given the opportunity to comment and throw your
weight behind the litigation, were you not?
(No audible answer)
Please can NFSP00000779 be shown on the screen?

THE STENOGRAPHER: Sorry, was there an answer to the last

A.

question?
Sorry, apologies. I wasn't really giving an answer,
sorry. I wasn't sure.

MS HODGE: Do you recall whether you were given

A
Qa

an opportunity to comment?
Not to my knowledge. You may be about to remind me.
Thank you.

This document contains an email from Nick Wallis to

the National Federation of SubPostmasters. Mr Wallis
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But I didn't get the chance but it would have -- it

would have been lovely to be able to go across, shake
his hand and just thank him for what he's done.

So that was an opportunity as you saw it, to express
your support privately, to Mr Bates --

Yes.

- in respect of --

Yes.

-- the bringing of the litigation?

Absolutely.

Now, please could we bring up paragraph 135 of your
statement, in which you address the approach which you
adopted publicly, to the Group Litigation. The

reference to the statement, please, WITN00370100, thank
you, and it's page 47. Thank you. If we scroll down,
please, paragraph 135, thank you very much. You say
here:

"The legal process was under way with court dates
set when I took on the Chief Executive role in June
2018, and the NFSP was not a party in the [Group
Litigation] case. Therefore, I determined it was right
to allow the due legal process to take place and allow
the courts to determine once and for all what the answer
to the Horizon issue was. Added, as someone not

experienced or practised in the legal process, I did not
42

reported extensively on the Group Litigation.

He has.

If we scroll down to the middle of page 2, please, we

can see there, his email, addressed to Amanda Cox, who,
from the email, appears to have been the General

Official Supervisor and Receptionist; is that correct?

Yes.

This email is dated 16 November 2018 and it reads as
follows:

"Hi

"lam a journalist covering the Bates v Post Office
High Court trial and yesterday, as you may know, the
NFSP's independence was queried in court.

"I have covered this as a reporter and published
a separate piece for my blog outlining the NFSP's
historic refusal to get behind claims that Horizon is
not fit for purpose.

"My separate piece is a piece of comment and I am
very hard on the NFSP -- focusing on its contractual
inability to criticise the Post Office on this issue and
the decision it appears to have taken as an organisation
that it is better to let its members hang out to dry if
they are having problems with Horizon, in order to
protect the integrity of the brand to clients and other

subpostmasters (as explained by George Thomson in his
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evidence to Parliament on 3 February 2015).”

He goes on to say:

“It is both right and fair to offer you the
‘opportunity to have your position acknowledged and
incorporated into the piece.

"You could do this in one of two ways -- issue
a statement or have the right of reply.”

He then goes on to suggest some topics that could be
covered if you were to issue a statement and he
expressly says, if we go down, please:

"If the CEO of the NFSP would prefer to write
a right of reply piece for publication on my blog, he
would be more than welcome."

If we scroll up to the bottom of the first page,
please, we can see that that email was forwarded by
Ms Cox to you and to Lynn Eccles. What was Ms Eccles’
role within the NFSP.

She was the Communication Director.

Thank you. If we could scroll up then please to the top
of the first page, Ms Eccles writes to you, it appears,
later the same day. She says:

"Thanks Amanda, Calum the ongoing court case line
doesn't entirely stand up because not all of these
questions are linked directly to what's happening in

court.
45

Was this not an excellent opportunity to set the record
straight and lend your support to the Group Litigation?
Well, as I've mentioned in my witness statement, I'm not
conversed as far as legal matters are concerned, and
I had faith and confidence -- well, I do have faith and
confidence in the legal process. I didn't think it was
right and appropriate for the NFSP to be making any
comment in relation to an ongoing case. I didn't think
that would be -- I didn't know if that could potentially
get us into trouble and I felt that the right thing to
do was to wait and allow Lord Justice Fraser and the due
judicial process to take place and therefore understand
exactly what is -- the powers of the justice system were
far greater than those of the NFSP. So as far as
understanding the truth, the whole truth and nothing but
the truth, I had confidence in that process.

So I didn't think we could. So we just sat back,
really, waiting for that process to take place. If --
sorry, you know, yeah, if I'm wrong in that, you know,
I'll accept that but certainly that's our mindset at
that time.
It might be thought that adopting a neutral stance was
quite a cynical decision to take, as it allowed the NFSP
to back the winning horse after the outcome the case had

been determined; is that fair?
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"Still, I don't think we should provide a detailed
comment, it'll give the discussion around our
independence legs. I think there is also a risk if we
just step up and defend the NFSP it gives support to the
perception that we only really care about the Fed and
not the [subpostmasters] which are part of this class
action.

"Nick will criticise us for hiding court process but
given that we are no longer firmly coming down on one
side or the other I think that's the best we can do for
now.

"Suggest something like this:

"Thanks for sharing the blog and giving us the right
to reply. We welcome the opportunity for these matters
to be explored fully in court and respect the court's
process. We do not wish to contribute to a running
commentary on the case and won't be making any comment
until all matters have been aired in the court."

She then says:

"FYI -- he [that is Nick] will come back to us for
a comment when it is all done and dusted so you will
need to be ready for that."

Did you agree with the response that was proposed by
Ms Eccles?

Yes, I did.
46

I think that would be a cynical view.

You had implored your predecessor, had you not, to
support the subpostmasters whose cases were being
reviewed by Second Sight before you became CEO of the
organisation?

Yes.

Why, then, did you not, in your role as CEO, support the
claimants who were bringing their claims in court?
Because I didn't think we could. 1, you know -- I --

sorry if that's -- if that was wrong in that way but

I honestly didn't think it was our place. As Lord

Justice Fraser made it clear, we were not involved in
the court case, so I didn't think we could make comment.
I honestly thought that if we did, that might prejudice

it in some way, shape or form. I didn't want to do

that.

So are you saying that, so far as you were concerned,
there was a fundamental difference between supporting
those cases that were being reviewed by Second Sight,
even though they might have resulted in a criminal
prosecution and therefore a legal process, and
supporting the Group Litigation, which was ongoing at
that time; is that your evidence?

Sorry, I'm not really understanding it. All I can say

is that I just didn't think that it was our place, we
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could make comment on an ongoing case. I didn't think
we could, so we didn't.

Please could NFSP00000710 be shown on the screen. This
is an external email chain between members of you team
discussing whether or not the NFSP should comment
publicly on the GLO proceedings. Please could we scroll
down to the bottom of page 4. We can see there an email
from Jon Follenfont, which has the title "Article for

the Magazine", it's dated 8 November 2018. It reads:

"Hi

"Two things:

"There is a Forum of [Post Office] people and
subpostmasters which meets to outline new proposals, new
kit, etc -- perhaps a report is needed in the magazine.

"I have been following the initial High Court case
about Horizon problems and the disciplinary action taken
by [Post Office] over the years -- quite interesting and
potentially a major issue for the [Post Office] in the
future. It must be costing [Post Office] and thus the
network a lot of money in legal fees. Whether we can be
that critical in a magazine funded by [Post Office] is
an interesting point."

"Regards.

"Jon."

He raises there a concern that because the
49

Now, what you appear to be saying here to your
colleagues is that you don't know which way the case is
going to be decided and so it would be in the best
interests of the NFSP to hedge their bets; is that fair?
No.

Is there anything further you wish to say about this
email, before I move on?

Well, I think the very about is important as well. I'd
received an email, it's probably the vilest --

I can't -- I tried to find where that email is.

I haven't been able to find it but it gives indication

to really some of the stuff that we receive from people,
whether they're postmasters or just interested
individuals from the general public.

It was a lot of pressure on us in one way, shape or
form. As I say, all we were trying to do is allow the
due legal process to take place and here, because we
didn't know, we simply didn't -- we didn't have the
evidence and we hoped that, through the GLO, the
evidence would come out and reveal exactly what had gone
on in the past.

So that was just our view. We felt that it wasn't
right for us to make comment.

Please can NFSP00000707 be shown on the screen. This

document contains an email from you to an employee of
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SubPostmaster Magazine is ultimately funded by the Post
Office, it wouldn't be appropriate for the NFSP to
comment; did you agree with that?
No. Can I just sort of add, I mean this was
obviously -- Jon is a lovely, lovely gentleman, who
cares passionately about the business. He was
a postmaster for a good number of years and, thankfully,
has only very recently been able to finally retire and,
you know, I don't think he, in any way shape or form,
would try to put across a view that would be detrimental
to postmasters.
If we scroll up to the middle of the third page, please,
we can see your response. Thank you very much. So your
response of 8 November reads:

"Hi Jon

"My viewpoint is that as individuals with personal
interest in this case, we want to know the verdict of
the Judge but it would be unwise for us to make any
comment at this stage.

"I was present today. I would say that we are still
at the opening credits of the case so it is way too
early to ascertain which way it will go.

"As Lynn suggests acknowledging that the case is
being heard and we await the judgment with interest is

the best we should do via the SubPostmaster."
50

the Post Office named Rob Houghton. Can you please
explain his role and the nature of your relationship

with him?

So Rob Houghton was the Chief Information Officer at the
Post Office. He wasn't there long, maybe 2017 to 2019,

I don't think he was there that long, but anyway, that's
who he was.

I'd like to ask you about some comments which you make
in the second paragraph of this email, thank you. It's
dated 24 April 2018 from you to Rob with the subject
"Branch Refresh". You say:

"There are a number of aspects that I feel I need to
highlight with you but most pressing is the growing loss
of confidence by colleagues in the system due to both
a mixture of hardware and software issues during and
after installation of the new system and/or router. Add
to this that there have now been 4 system faults over
the last month, which have caused nationwide access
problems thus I am concerned that we are handing Freeths
a stronger case to bring to court in November as ‘the
present is a guide to the past is a strong argument."

Now, one possible reading of this email is that you
were not as well disposed to the group litigants and
their litigation as you are now claiming to be and that

you were primarily concerned about maintaining
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confidence in the Horizon system; would that be fair?
I think it would be fair to say that I was trying to
sort of ensure that there was confidence in the Horizon
system. I think that's important, as a postmaster,
someone who uses Horizon and, along with the rest of my
colleagues, I think it is vitally important that we have
confidence in it. But what I was trying to sort of do
here, and if I may, sort of, there was this branch
refresh that was going on at that time and postmasters
were coming to us and saying that they were having
problems.

Now, and where it says "It was literally good to
bump into you", that was a little description that
I happened to come out of a room within the Post Office,
turned a corner and I literally flattened him because
I bumped into him and he virtually ended up on the
floor. So hence the "it was literally good to bump into
you". But all I'm tying to do here is highlight that
there are problems with Horizon today and, if you don't
sort this out, then you're in essence giving -- making
it easy for -- you know, easier for Freeths as far as
their case is concerned. Do something about this.

But I'm not saying I disagree with what's going on.
I'm just trying to make sure that what was happening to

postmasters at that time in relation to the new system
53

the Post Office to enable the NFSP to offer support to
postmasters. It was designed so that this support was
free at the point of use to all postmasters.”

Is that correct?

Yes.

I think you accept that this apparent benevolence of the
Post Office came at a certain price; is that right?

Given the type of organisation that the Post Office is,

it is very difficult to deal with them in any way, shape

‘or form. I think, when -- you know, if you consider the
time period that the Inquiry looking at, the Grant
Framework Agreement is only in place to the very end of
it. That had nothing to do with the activities and
viewpoints of the NFSP prior to that.

As far as this situation is concerned, the Grant
Framework had nothing to do with the view that I was
taking. There was no influence from the Post Office in
any way, shape or form to pressurise the NFSP into
taking a view or a stance.

So it had nothing to do with it in that way.

I'd like, if we can, please, to look at the terms of

that agreement. It bears the reference NFSP00001075.
Thank you. So the agreement is dated 21 July 2015. The
relevant clause can be found at page 10, please, under

the heading "General Conditions of the Grant". So
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was problems and eventually what came out of this
meeting was we ended up with different suppliers from
the Post Office all in a room there I was able to
explain to those individuals what postmasters were
experiencing because postmasters were not able to trade.
They were losing business. That's what I was trying to
sort of do. Not anything -- I appreciate how you can
read it but that's not what I was trying to say.
I'd like to explore with you what, if any, role the
Grant Framework Agreement had in your decision not to
speak out in support of the Group Litigation. The
Inquiry has heard evidence from your predecessor about
the background to the Grant Framework Agreement.
I don't propose to go over the same ground with you, as
you were not directly involved in the negotiation which
led to it; is that correct?
Yes.
You are, however, familiar with its terms as it remained
in force when you took over as CEO in June 2018; is that
right?
Yes.
In your statement, you describe the Framework Agreement
in this way, you say:

"The Grant Framework Agreement is an agreement

between the NFSP and Post Office to provide funding from
54

paragraph 5.3:

"The NFSP shall not engage in the following
activities or behaviours ..."

These being the conditions on which the grant
funding is made:

"The NFSP shall not [firstly]:

"[Undertake] any public activity which may prevent
[Post Office] from implementing any of its initiatives,
policies or strategies;

"[Secondly] undertaking or inducing a third party to
undertake media or political campaigns against [the Post
Office];

"[hirdly] organising or inducing a third party to
organise public demonstrations, protests or petitions
against [the Post Office];

"[Fourthly] organising or inducing a third party to
‘organise boycotts of [Post Office] business:

"[Fifthly] funding or inducing any third party
litigation against [Post Office]; and

"[Finally, broad catch-all] other activities or
behaviour the effect of which may be materially
detrimental to [the Post Office]."

So those are some of the conditions of the Grant.
Can we please scroll to page 16 of the document. We see

there another related clause, which bears the heading,
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"Withholding, Suspending and Repayment of Grant", this
is clause number 17. It reads:

"[The Post Office's] intention is that the Grant
will be paid to the NFSP in full. However, without
prejudice to [the Post Office's] other rights and
remedies, [it] may at its discretion withhold or suspend
payment of the Annual Grant Payment and/or an Individual
Grant and/or require repayment of all or part of the
Annual Grant ... and/or an Individual Grant if there is
an Event of Clawback."

The term "Event of Clawback" is defined on the
following page under clause 17.2, and the first such
event or circumstance is where:

"... the NFSP commits a breach of any of its
obligations under clause 5 ... and/or clause 1 ..."

Now, you say that you said in your statement and you
claim in your evidence today that these clauses had no
bearing upon the actions of the NFSP in relation to
Horizon; is that your evidence?

No, I don't think that's what I'd said. In relation to

the GLO, because that's the question you were asking me,
it had no bearing on that and I don't think that, given

the fact that the GFA only came into place in 2016, when
all of the criminal prosecutions had stopped by then,

had really much to do, because it didn't really cover
57

at NFSP00000534. This a meeting of the Board in June
2017. By this stage you were a member of the Board of
the NFSP. If we could turn please to page 12, we see
there recorded a discussion about the Group Litigation,
it's under the heading "Communications". The third
bullet point reads:

"Against express instructions, in the last issue of
The SubPostmaster, LBM had taken an advert from
Freeths/Justice for Subpostmasters."

LBM were who, please?

Lewis Business Media, who publish The SubPostmaster
magazine.

[Post Office] understandably went ballistic. Emergency
meeting held with LBM with [Post Office] in attendance.
It was made crystal clear that their actions were

totally unacceptable. It made it look like the NFSP
were inciting subpostmasters to take the company to
court. May need to beef up resources and bring the
magazine in-house in the future. That mistake could
have cost the NFSP payments from [Post Office] and
ultimately finish the organisation. It was really very
serious.

Now, we see Ms Eccles mentioned at the top there,
was that an update, was that an update from her in her

capacity as Director of Communications?
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the time period, and -- when most of the time period
that the Inquiry and the GLO was covering, the NFSP was
a trade union funded by its members. So, therefore, it
couldn't have anything -- really, it didn't have
anything to do with it.
Now, you've made the point in your statement and this
morning that, so far as the period prior to the Grant
Framework Agreement is concerned, that could not have
been influenced by these provisions because they didn't
come into force until 2015. As you rightly say, I'm
asking you about the period after they came into force
and your conduct in relation to the Group Litigation.
Now, you've explained that you felt sympathy for the
group litigants and, indeed, you wished to convey that
and to show your support privately to Mr Bates, but you
weren't prepared to do so publicly. Is it your evidence
that that decision was not in any way influenced by
those provisions?
Absolutely.
You were aware though, were you not, that there was
arisk that the Post Office might seek to clawback the
funding provided to the NFSP if you incited other
subpostmasters to bring claims against it?
It's sort there sort of within the clause, clause 5.3.

Let's take a look, please, at some minutes of the Board
58

No, I don't think she had even started at that point.

It was more just informing the point that Lynn would be
starting.

These minutes show, do they not, that the Board of the
NFSP at that time was fearful that it would lose its
funding from the Post Office, if it were to lend its
support to the Group Litigation?

I think at that point it was being -- this discussion

was being led by George, rather than the Board and
George was putting forward his view. I think George's
view on Horizon is pretty clear but that doesn't
necessarily mean to say that that was the view of the
whole Board and, anyway, that was George's view,
George's opinion. But I wasn't aware -- I wasn't party
to the discussion that took place. I don't know if the
Post Office did go ballistic or whether that was.
George's interpretation of it. I've no idea.

These minutes suggest, do they not, that the loss of
grant funding would have brought an end to the National
Federation of SubPostmasters?

Well, I think so. You know, any business exists on its
ability to fund its outgoings. If it's not able to do

that, then it will no longer exist. It's as simple as

that.

Having been appointed the new leader of the NFSP, was
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your primary concer to ensure the survival of the
organisation, rather than to obtain justice for
subpostmasters who'd been wrongly convicted?
No. I think, you know, we've got a -- postmasters need
a body that represents them. It needs a body that can
do that but I think sort of what we really need to take
into account here is the culture within the Post Office.
I don't -- personally I don't think the GFA is
necessarily the issue. I think the culture within the
Post Office is. If the culture within the Post Office
is that they act in an honourable manner, then the GFA
works. But if you've got an organisation that is
incapable of doing it that and is going to use every
trick in the book and everything that it can to push
forward its view and defend its position, then it
doesn't matter what kind of -- it doesn't really matter.
It's not going to work.

The culture in the Post Office is the problem. Sort
the culture in the Post Office and we don't have
a problem. What we've seen over the last couple of days
in relation to the Postmaster Non-Executive Directors is
exactly how the Post Office works today. That's the
problem, not the GFA, in my view.

You know, we need something to be able to hold the

Post Office to account, and the fact of the matter is,
61

Civil Service, the Post Office, postmasters, working
together in unity and harmony for the good of this
business, not a business working for its own benefit.
And that's exactly what the Post Office has been doing,
and that's the problem. And if they were prepared to
behave in the right moral manner, we don't have

a problem.

The fact of the matter is, Lord Justice Fraser and
this Inquiry have demonstrated, time after time after
time, that this business is incapable of acting in the
right manner. How difficult has the Inquiry felt, with
all the power, authority and influence you have, in
getting this business to provide you with the
information to engage with this Inquiry in the right
manner? You've found it virtually impossible. The
frustration -- I've sat here in this room, time after
time, experiencing the frustration that the Inquiry has,
because the culture in the Post Office simply isn't
there. Get that sorted and I think we have a chance; if
the Post Office continues on its current trajectory, in
the manner it is, we don't, and postmasters will suffer
as a result, and we've got to get it right.

It might be suggested, Mr Greenhow, that, in your
evidence to this Inquiry, you are seeking to shift the

blame away from your organisation's focus on its own
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over this period, the Post Office has not been held to
account, by -- not been able to be held to account by
anyone, and it has done everything it possibly can to
obfuscate and to push through so it gets its views.

So, obviously, I'm sure you're wanting to come on to
it, is the new GFA and, you can see, sort of straight
away, so, like, I'm looking to remove these clauses.
Why these clauses were originally in the GFA, I don't
know, I can't say because I wasn't sort of party to it.

Do I agree with them? No. Should they be removed?
Absolutely. And, thankfully, they now have.

If, as you say the problem resides not in the GFA but in
the culture of the Post Office, why have you, in your
words, worked so hard to remove them from the agreement?
Well, is the culture in the Post Office today where it
needs to be? No, it's not. You know, we can see that.
This business is in absolute meltdown from the top.

It's Board, it's senior management, they're just
incapable of working in the right way. What Justice
Fraser has pointed to these as clauses that are -- were
problematic to him, we've followed the guidance from
Justice Fraser to have those removed. But still

think, if we have the right culture within the business,
then we can move forward.

I mean, from what I want, is I want Government, the
62

financial interests and are laying blame squarely on the
Post Office; would that be fair?
I think that's taking it a little bit sort of far.
I am -- you know, the reality is the NFSP, I think,
quite in essence, was on the wrong side of right, here.
We cannot escape that, and we -- I have been open from
when I came in, I have offered my apologies, I have been
‘open and straight with people that the NFSP got it
wrong. My predecessors put their faith in the Post
Office rather than actually in postmasters. They
believed the Post Office, rather than believing their
‘own fellow colleagues. The simple reality is they got
it wrong.

So I'm not trying to shift responsible at all but
I am trying to sort of highlight that the culture within
the Post Office is the fundamental problem. They misled
everybody.
But do you accept that you and your colleagues put the
financial interests of your organisation above the
interests of its members?
When?
In its decision to refuse to support the Group
Litigation?
I -- no, I don't think they did but I do think that

George's view of the past was fundamentally wrong and
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I don't think -- I mean, obviously you've had the
opportunity to ask George that and, unfortunately, you
didn't get the opportunity to get that out of him, but
certainly from -- I can’t answer for the past on that

basis but I can talk about, from my own part, and I've
certainly put the financial position of the NFSP before
members. In fact, I think the evidence demonstrates

that.

You've explained in your statement that you had not
anticipated the NFSP would become a focus of criticism

in the litigation?

Yeah.

One of the criminals which was made by Mr Justice
Fraser, as he then was, in his Common Issues judgment
concerned the NFSP's publication of the Grant Framework
Agreement on its website. In summary, the criticism
which was made of the NFSP was that, during the Common
Issues trial, it had made changes to its website to add

a link to the Framework Agreement in circumstances which
were highly suspicious. Do you agree that's a fair
characterisation of the criticism that was made --

Yes.

-- by Mr Justice Fraser. The reasons why these changes
to the website appeared suspicious to him at the time

were that, firstly, the link to the Framework Agreement
65

I couldn't print it off so I was having to email it to
myself so that could print it off. So that's -- if you
see that, that's the reason for it.
We can see the date there is, of course, September 2023.
Yes, but it's -- you could look at that and go "Oh, its
Calum Greenhow at the top, so therefore he must have
known about it" but, actually, that's what I was doing.
That, of course, significantly post-dates the actual
email?
Yes.
So the chain we have there is dated December 2016. It
concerned the publication of the GLO. If we could go to
the bottom of page 1, please. Thank you. There's
an email from Nick Beal to George Thomson and copied to
Jenna Khalfan. Please could you explain Nick Beal's
role there, please? We can see there, at the bottom of
the page, he was Head of Agents’ Development and
Remuneration?
Yeah.
So his email reads, subject "Grant Agreement":

"Dear George

"Further to the discussions we have had between us
since the inception of the Grant Agreement in 2013,
I can confirm that we are now in a position to agree

publication of the agreement (and associated Novation
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had not been present at the start of the Common Issues
trial, and the link had been added during the trial in
a manner which appeared to support the Post Office's
case. Again, is that a fair summary of what the
judge --
That's what Lord Justice Fraser -- however, I think as
you know I can --
Yes, we'll come on to your explanation but just --
Yes, yeah ~
-- to place it in context --
-- that's exactly what he said.
-- that was the nature of the criticism?

I'd like to ask you, please, first, to clarify when
it was that the framework agreement was first published
on the NFSP's website.
I can't answer that. That was before my time.
Please can NFSP00000728 be shown on the screen. Thank
you. So this is an email chain, an internal email
chain --
Sorry, before you go on, can I highlight, so this is
just at the top, just for everybody's benefit, you can
see that's an email Calum Greenhow, 21 September 2023 to
Calum Greenhow, that was me in relation to a Rule 9
Request, that was me going through, as information that

could -- that complied with the Rule 9 Request, and
66

Agreement)."

Are you able to confirm: what was the purpose of the
novation agreement, do you recall?
Well, it was before my time. It may be in the bundle
but I can't remember offhand.
"We have decided previously that this would be via NFSP
publishing via your website -- please proceed with this
as soon as possible. I have attached a PDF version of
each document -- please can you ensure for the GA [Grant
Agreement] it was clear that this was the version that
was entered into and the date of the agreement
(21/7/15).

"Please advise when this has been placed on your
website and a copy of the link."

If we scroll up, please, we can see an email from
Jenna Khalfan to George Thomson, so this now
19 December:

"George,

"I'm going to publish the attached grant agreement
‘on the ‘about us' page on our website. Do I need to
publish the deed of novation too?"

So far as you're aware, is this the best evidence
which the NFSP has as to the date on which the Framework
Agreement was first published on the website?

To my knowledge, yes.
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We know that by early October 2018, the GFA had been
removed from the website.

That was during the GLO, yeah.

Exactly. In your statement you say that the GFA was
removed as part some improvements that were being made
by the Communications Director; is that right?

Yes.

At that stage that would have been Ms Eccles?

Yes.

When were these improvements made which resulted in the
removal of the GFA?

They were ongoing at that period of time, so late 2018.

So after your appointment as CEO?

Yeah, yeah.

So they coincided with the Common Issues trial; is that
essentially what you're saying?

They did, yes.

But the agreement was removed before the trial
commenced?

I don't know if it was removed before the trial

commenced but I'm aware that it obviously was removed,
and then subsequently put back up.

Why was there any need to remove the agreement from the
website?

So Lynn ~- I mean, in essence, one of the -- you know,
69

Not until afterwards, actually. It wasn't a case of --

she was following Nick Wallis’ live blog, which was very
helpful, I was busy dealing with other things and,
obviously, she realised that it was there and, as I've
explained in my statement, she felt that people might go
and have a look for it. So she decided to put it back

on.

It is an odd coincidence that these changes coincided
with the Common Issues trial?

Call it a coincidence; these do happen.

But you can understand, can you, why the judge at least
appeared to think that was something that was quite
suspicious?

Yeah, I can understand, given sort of everything that he
was hearing, of course, I wasn't aware of exactly
everything he was hearing. I wasn't aware of all the
bundles all the evidence that he was getting but, yes,

I could understand it. But, from my perspective, as

I was looking at it, I know that there was nothing
suspicious about it, there was nothing going on, and we
were certainly not trying to bolster the position of the
Post Office. I know that for a fact.

Was Ms Eccles concerned, based on your discussions with
her, to answer the criticisms that were being made in

the proceedings about the lack of transparency that the
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through conversation that Lynn and I had been having, we

just felt that, in essence, I was a different person,

I have a different character, I have a different

outlook, that there were many aspects of the Federation

that were kind of oldie, and we wanted to really give

the whole outlook and business a freshen-up, in essence.
So we introduced you to our mission vision in

values, we were changing our colour schemes, the logo,

‘our tone of voice. We were doing -- going through doing

anew website, and Lyn felt that the "About Us" was not

the right place for it to be. She was going to put it

into a different part of the new website that she was

working on, and she had taken it off as she was working

on that particular page. That's certainly what she had

told me at the time.

Could the GFA, could the agreement, not have remained on

the website pending its relocation?

It could have.

You go on to explain in your statement that Ms Eccles

decided to place the GFA back on to the website but when

she discovered that its publication had become the

subject of discussion in the Common Issues trial; is

that right?

Yes.

Did you discuss this decision with her at the time?
70

NFSP and the Post Office were showing in relation to the
terms of the agreement?
No, I think it was more -- it's being discussed, people
might go and look for it, we'd better make sure that
it's there. I don't think there was anything of any
transparent concerns that were going on.
I'd like to move on to a new topic, please. This
concerns the outcome of the Group Litigation and how the
NFSP has responded to the issues raised in the judgment
of Mr Justice Fraser. How would you characterise your
initial reaction to the Common Issues judgment?
Well, I think there was an email where I -- I think
I sent to the Board, where I outline that the Common
Issues ruling has been handed down, that we need to read
it, we need to understand it. It was a long, obviously,
ruling, and, again, not I'm not a lawyer, it's going to
be take me a little bit time to actually understand the
nuance of it. Obviously, there's a lot of legal speak,
sort of in it which, I -- to someone who is not trained
might be difficult to understand. So let's take time to
actually fully understand exactly what's going on.

At the same time, across social media, there were
those who have an anti-NFSP feeling, who were using that
to challenge the NFSP, undermine the NFSP, criticise the

NFSP in front of our peers, and that caused us to have
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to, in essence, do a bit of a knee-jerk response without
really fully understanding exactly what Justice Fraser
had said. But, given the fact that they were focusing
on those specific aspects of, was it -- well, it was
clause 574 onwards, and (f), within his ruling, that
covered the NFSP. We had to respond to that.

But I think, as -- yeah, it's not what I wanted to
do, but I felt I had to say something, and I very
quickly -- once that was dealt with, very quickly was
able to focus on exactly what it was that Justice Fraser
said, and I think so that the evidence is there, that we
really start to really, you know -- the full reality of
exactly what the Post Office had done, and the exposure
to risk that postmasters, all postmasters and all
employees of the Post Office, in essence, anyone who
worked behind the counter of a Post Office, was faced.

And we really, you know, with -- we really couldn't
believe that the most trusted brand in the Post Office,
a government-owned department, could behave in the way
they actually did and you can see that sort of from the
statements that we were putting out at that time, that
there was one statement that we put out that has a bit
of a knee-jerk, but the rest of it was very much
critical of the Post Office and supportive of the

victims of this miscarriage of justice.
73

I think we were surprised, as the -- is the reality of

it. We -- you know, we just felt that in essence,
bemused, and again, I appreciate, as a lawyer who is
experienced in these things, but to people who are not,
we just couldn't sort of -- we didn't realise that we

would be focused -- be such a focus and, obviously,
there were things that were being said about the NFSP at
the time by others that were really making it difficult

for us -- making it difficult for the NFSP.

You know, the reality sort of was that we were also
aware that there were things that he said, ie "highly
suspicious", we knew that wasn't correct, we had
"bolstered the position of the Post Office", we knew
that wasn't correct and, you know, we were stunned, in
‘one sense.

It appears that your initial focus was upon the
reputation of the organisation: is that fair?

The immediate sort of aspect, the reputation of the
NFSP, yes, of course. The reality is that, you know, as
an organisation, you know, we wanted to help.
postmasters. We wanted to sort of make sure. We are
postmasters. You know, at this moment in time, I still
own a post office. I want to make sure that this
network not just survives but it thrives. I want to

make sure that sort of postmasters are able to continue
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It might be suggested, Mr Greenhow, that in the

explanation you've just given, you're somewhat

downplaying the sense of anger and frustration which you

expressed at the time, at the judgment of Mr Justice

Fraser in the Common Issues trial; is that fair?

Sorry, could you explain just what you're meaning by

that?

I'm suggesting that you are downplaying the anger and

frustration that you felt at the time about what was

said about the NFSP in the Common Issues judgment; is

that fair?

No.

Please can we look at NFSP00000558. These are the

minutes of a Board meeting held in March 2019 at which

you gave a presentation to the Board about the Common

Issues judgment; is that correct?

Yes.

We can see a description of your initial reaction at the

top of page 6, please. The third paragraph reads:
"General outrage that the judge should see fit to

cast aspersions about the NFSP who played no part in the

trial, gave no evidence, were not asked for

documentation, or given the right to defend ourselves."
Does that accurately summarise how you felt about

the judgment when it was first handed down?
74

to provide services in their community, and there were
those who were really trying to make it difficult for

the NFSP and they were using the judgment as a weapon to
criticise us. So that's, in essence, what we were
feeling. It wasn't just about what Lord Justice Fraser
had said it was about, sort of, actually, the level of

stuff that was being mentioned across social media.
Would I be right to say that your initial feelings of

anger gave way to a period of reflection and have
resulted in changes being made to the organisation --
Oh, absolutely.

-- and structure of the NFSP --

Absolutely, absolutely. I think, if I may, you can sort

of see the before the judgment that has come out, that

I was trying to make those and, in essence, I could see
this -- and this might sound wrong, so please forgive
me -- a little bit of a distraction, and where I felt

that I needed to take the business and where the Board
needed to take the NFSP, for the good of postmasters,
for the benefit of postmasters, that this was going to
make it difficult, this was making the journey or the

hill steeper and, as I say, there were those who were
trying to really weaponise the judgment against the NFSP
and, you know, this was kind of taking us back a step or

two.
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Whether that was going to make it more difficult for
us to make the changes within the NFSP that we needed to
and, in essence, this has haunted me all of the way
through sort of the time I've been the Chief Executive
of the NFSP.

I know what I need to do in this business. My board
knows what we need to do in this business to really take
this organisation forward for the good and benefit of
postmasters and, you know, people try to weaponise this
and it makes the harder. I keep on having to come back
to this, and deal with it, rather than being able to do
what I need to do, what we need to do to move the NFSP
forward for the good of postmasters.
The first initiative which I'd like to examine with you
relates to the recording and monitoring of members’
concerns.
Yes.
Prior to the GLO, is it right that there was no system
in place which required local representatives whether
Branch Secretaries or Regional Secretaries --
No.
-- to report to central office the issues which were
being communicated by their members?

No.

There was also no system in place to enable the central
77

Yes.

Please can you describe the nature of the concerns that
are still being raised by your members in relation to

the scheme?

I -- well, lately, what people have -- they've been
receiving the letters in relation to the 75,000, and
they've thought it was a scam. So they've been calling
us to say, "Is this right?" We've been able to

obviously assure them that it is. Others, you know,

"Just how long -- you know, how long is it taking? How
do I fill out the form? Where can I get the form? Can

I still apply?" All things like that.

It sounds from your description that those are more
queries than complaints; is that fair?

Yeah, I would say so, yeah.

Now, another method I think you've mentioned in your
statement for canvassing views of the membership is the
use of surveys; is that correct?

Yes.

How frequently are they undertaken?

On a monthly basis. We have done two large case member
surveys, 2019 and 2021, and on both of those occasions
I think we had about 1,000 postmasters that were
involved in that, and that was done to quite a -- I'm

not a statistician or -- I don't know what the term is
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recording and monitoring of such issues; is that right?
I would say to my knowledge, no.
Please can you describe the action which you have taken
to address this problem?
So one of the things that sort to we've tried to put in
a place or have put into place is the collation --
there's a spreadsheet that we deal with on a weekly
basis. If any branch secretary has received a call from
a member, that they fill in a form. They do it on
a weekly basis. That sort of automatically comes into
the central -- into the central NFSP and that is
collated onto a central record and then myself and two
employees of the NFSP on a monthly basis go through that
to ascertain whether there's any anomalies or any issues
that we really need to highlight.

That is then put into data that is provided to the
board. We put it into The SubPostmaster so that members
are aware of exactly what's going on.
So, in your statement, you've mentioned that the
spreadsheet is collated and it culminates in a quarterly
report to the Board. You've explained that the most
common issues raised, I think in at least the last year,
relate to the Historic Shortfall Scheme --
Yes.

-- is that correct?
78

but anyway -- a researcher. So -- but they're done to
industry standards and, you know, the information that
came back.

So we made sure there was a certain number of local
post offices, mains post offices, different contracts,
traditional contracts and also spread around the country
as well. So there we really got a very broad
cross-section, so we had an understanding of exactly
what it is the postmasters think.

The monthly ones are just put out and it's for any
postmaster to respond. So it's not done to the gold
standard. It's just literally a survey that goes out
and people respond.

Now, I think it's your evidence that, during the period
covered by this Inquiry, there was no formal
whistleblowing policy or complaints procedure in place
within the NFSP; is that correct?

That's correct.

What action have you taken to address that gap in the
procedures?

Well, we've done that now and we've obviously supplied
those to the Inquiry, they're on our website now and,
with the help of our Legal Team, we've drafted them, and
they are now available.

And --
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So that's a whistleblowing, a complaints and also
an equality and diversity policy.

They're now all publicly available on your website?
They're available to the members on our member -- so
there's two sides to our website; there's the members
side and then the public side, so they're available on
the members side.

Why are they not available on the public side?

It's for members, so that's why we've put it on that

side.

The second initiative which I would like to examine with
you concerns the provision of training given to those
responsible for representing subpostmasters in disputes
with the Post Office. You've explained in your
statement that, when you were appointed a branch
secretary in 2012, there was no formal training on the
conduct of interviews; is that correct?

That's correct.

You say that you believe this resulted in a lack of
consistency in the support which was provided to
subpostmasters in the period covered by this Inquiry; is
that right?

Would agree with that.

You have launched an initiative which you describe as
the advocacy representative project?

representatives who are trained in the Post Office's
contracts to represent subpostmasters --

Yes.

-- interview. Who provided or who provides the training
to those representatives?

So it was in-house that we did that. However, we did
seek the support and help of our employment
professionals, HR:4UK, and they gave us guidance on how
to do that. We have continued to reflect and continued
to look at that, and we are now engaging with ACAS
because they have a mediation service and we're looking
to sort of see if that could be something that would
actually sit better for us, so that it would be not only

an external, but it would be an accredited

qualification. So we're in the process of looking at

that and seeing if that would work and sit with us.

How is the performance of these new representatives
monitored by the NFSP; do you have any systems in place
for that purpose?

Good question. We don't have any KPIs if that's what
you're referring to, but I do meet with the two

individuals who are responsible for overlooking -- for
overlooking this and, in essence, you know, going
through and ascertaining whether the right decision has

been reached. I've not, as I've looked at things, had
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Yes.

Can you please describe that project which you've
established to address this issue?

So, again, sort of listening to the GLO and listening

to -- and taking my own experience into account, I felt
that, you know, dealing with the Post Office is not

an easy -- not an easy thing. As far as any policies,
procedures, the way the Post Office go about things,
they can change and, therefore, I felt that it was right
and appropriate that we had properly trained
individuals, a small team, that if there was

a contractual issue that may result in a suspension or
termination, that it wasn't just anybody who would deal
with thats. We would have a small team that could work
together, pool their resources together, pool their
experience together and, you know, make sure that, if
a colleague was in that situation again, as we've heard
just over the last couple of days just how harrowing
that can be, that the NFSP is there to challenge the
Post Office appropriately and to make sure that
everything is being done to investigate exactly why

a discrepancy has taken place, and that it's not simply,
"You're short, you owe us the money, if you don't give
us the money we're going to terminate your contract".

You said in your statement you now have six dedicated
82

any issues or any worries as far as outcomes are
concerned. However, I do -- we do feel that it would be
better for us to have an external accredited
qualification to give our members greater confidence in
relation to the quality of knowledge and understanding
that we have in that area.
Thank you. In your statement, you've described the
current approach that's adopted by the NFSP when
supporting subpostmasters in disputes with the Post
Office. That's at paragraph 273 of your statement,
please, at WITNO0370100. Thank you. The paragraph can
be found at page 94 going onto page 95. Thank you very
much. If we scroll down, please, thank you. So that
reads:

"Where the NFSP is asked for help, our goal is to
ensure that Post Office is respectful, helpful in terms
of providing access to any information, carries out
a full and thorough investigation and is understanding
in terms of any conclusion. In terms of
an investigation, Post Office must answer the three
questions of

"(a) Is it computer error?

"(b) Has someone made a mistake and why?

"(c) Have the funds of the Post Office been used in

the manner they are not intended and by whom?"
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You go on to say:

"If Post Office cannot answer these questions
factually, then the postmaster should not be held to
account. Some of these cases are very complex and are
being dealt with by the relevant police authorities."

Now, earlier in your evidence we examined a case in
which the Post Office did not provide the information
which you had requested on behalf of a member. What is
your organisation doing now to ensure that full
disclosure is being provided to subpostmasters as you've
outlined here?

Well, when it comes to -- there are certain -- there are
certain reports that the Post Office does, and that is
the first thing that we sort of ask for and, if we don't
get those, we don't move forward. It's as simple as
that. But I have to sort of say, Post Office --

certainly my understanding is -- are far more
transparent than they have been in the past, and
certainly going back to 2016, if we asked for
information, they will usually provide it. There's

not -- it's not been reported to me any concerns and any
issues on that.

So is it your evidence that these questions that you've
outlined here, they are now being answered, to your

knowledge, satisfactorily by the Post Office in cases in
85

a level of toxicity in the network, as a result of that.

Postmasters are understandably very, very worried
about their future and the viability of their business
and I think that is -- that pressure is causing some to
maybe act in a manner that maybe doesn't quite sort of
reach the standards that postmasters should maintain
and, therefore, on that basis, I think it's important
that we have postmasters themselves helping us to
establish what it is that that standard should be. What
is it - you know, we can all sit here and say that
subpostmasters are good, honest, decent people, fine,
upstanding pillars of the community, which
I fundamentally believe that they are, but what's wrong
within the network? And I do believe that it's very
important that we all take a good look at ourselves in
the mirror, everyone who has been involved in this, and
go, "Where did we get this wrong? How can -- you know,
where's our culture part of the problem?" And it's very
easy for us to point the finger of blame at sort of like
other people but we've got to sort of first and foremost
look at ourselves.

And, therefore, what I'm looking for is I'm looking
for postmasters to help us make sure that the culture
within the network is right, so that we can help take

this business forward and make sure that postmasters'
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which your members are concerned?
To my knowledge, yes.

I'd like to examine with you now the efforts you've made
to bring about cultural change within the NFSP. You
identify in your statement a number of initiatives,

which you have adopted to improve the culture of the
NFSP and the wellbeing of its members. One of those
initiatives is the establishment of a Culture Committee.
Can you please explain the background to that?

So we haven't -- that's not established yet. We're in

the process of doing that. As I highlighted, we had
Darren Burns from the Timpson Group come along to the
NFSP conference this year. In preparation for Darren
coming, I read Sir John Timpson's book, Upside Down
Management, and I came across this within his book and
he explained it beautifully, and I thought, "This is

exactly what we need. We need to do this".

As I've highlighted sort of before, I'm an inclusive
person rather than exclusive person. I want to
encourage people, I want to lift people up, I want to
encourage them on. I enjoy hearing and listening to
different voices, different viewpoints. But I do think
that, culturally, as I've already highlighted, the Post
Office has clearly not moved forward in any way, shape

or form since the GLO. I also think that there's
86

businesses are as viable as they possibly can.

So I don't want to be prescriptive as to what that
is, but I'm looking for ten people across the country,
‘one per region -- if there's more than one person comes
forward, they will have a democratic vote on that within
the region -- but I will be looking, and then, once that
Culture Committee has been established, we will sit down
and we will look at what is it that the focus of that
committee is going to be, what is it that's going to be
the priorities and how are we going to bring that about?
Mr Greenhow, in answer to my question about the NFSP's
culture, you said that you don't believe that the
culture of the Post Office has moved on.
Yes.
We'll come on a little later to the culture of the Post
Office but I want to test with you whether that's a fair
statement in light of the evidence that you've just
given about the approach that the Post Office is taking
to its investigation as to contractual shortfalls and
the disclosure that it's providing. You've just told
the Inquiry that, so far as you are aware, proper and
adequate disclosure is being provided now by the Post
Office in the context of those investigations. So does
that not reflect some change of culture and attitude

within the organisation?
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I would accept that and, actually, I have to sort of say
that -- and again, I say it in my statement, that,
actually, within the branch assurance team, I think
there are real major changes there and real efforts to
be far more open and transparent as -- than what

I experienced in the past. Sorry, I was, in essence,
highlighting at a senior level that the -- you know, and
what we've heard and what we've listened to, certainly
in relation to the two Postmaster Non-Executive
Directors and what they've experienced.

Clearly there are still a long way still to go, but
yes, there is -- I would say there are some lovely,
lovely people within the Post Office who really want to
engage in work and have the right attitude. I'm not
saying all is bad. There are some aspects that are
positive, and I think that comes down to the
individuals, and we have to encourage them and support
them as they move forward in that, and really try to
make that cultural change that is required.

Before we move off this topic, please, I'd like to ask
you about a recent decision of the NFSP to refuse the
application of an individual who wished to be admitted
as a member.

So far as the rules governing membership of the NFSP

are concerned, you've explained in your statement,
89

down with someone who is legally -- who would have

a legal understanding and gone through it line by line
and said, "Yeah, you need to change this, this would be
a good idea", and I do think that allowing an appeal
process would be a good thing to introduce.

And it's something I would like to do in -- maybe
when this Inquiry is all over. But it's consumed my
life for the last four years, as I'm sure it has yours,
and, you know, I feel that I need to deal with this now
and then I'll deal with that then. But there's a lot in
those Articles of Association that I think I would like
to change.

But when that happens, it will be done with the help
and support of postmasters, the membership of the NFSP.
Thank you. Please could we bring up your statement at
page 106, please, where we can the explanation that
you've given and the reasons you've given as to why the
Board refused that application. Paragraph 299, please.
Thank you. You say there:

"In this calendar year, one application was refused.
This is the only application I am aware of being refused
since I came into post as Chief Executive. This
application came from someone who had previously been
a member of the NFSP. I have highlighted above the

behaviour of some on social media, whether by members or
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26 September 2024

firstly, that anyone who holds a contract to operate as
a subpostmaster may be admitted to the organisation; is
that correct?

Correct.

That, secondly, the Board of the NFSP has the right, in
its reasonable discretion, to refuse to admit

an applicant and not to provide its reasons for doing

so; is that right?

Yes.

And that there is no right of appeal in respect of that
decision?

Yes.

That's all provided for in the NFSP's Articles of
Association?

Which were obviously laid down in 2015 when we became
a company limited by guarantee.

Now I wonder if we could turn, please, to --

Can I just come back to that, if I may. I'd love to

change the Articles of Association because I feel

there's a lot in there that we need to shift forward on.

It's a huge piece of work and I've tried to do some
things, particularly around the branch and regional
secretaries, just to give them far greater prominence
and position within the NFSP, but there's a lot that

I would like to -- but if I may, I haven't actually sat
90

former members, and the mental health impact of that on
our employees and [postmasters]."

Just pausing there, please, we haven't gone to that.
Can you describe what you're referring there, the
behaviour on social media and the impact that this had
on your employees?

Yeah, so the individual -- I'm not sure if I'm

allowed -- I don't know if I can talk about the
specifics or the generality but let me be general and,
if you feel you want me to be specific, I'm more than
happy to be.

But there are some within the network who use social
media to -- and that causes postmaster colleagues and
NFSP employees quite considerable mental stress. To
give an example, there was -- just about ten days ago
there was, on a social media site, an encouragement to
postmasters to single out and target a member of --
an employee of the NFSP, to harass them for a bit of
fun.

Obviously, on Monday, Tuesday, the Inquiry heard
about, you know, playground, schoolboy antics. I don't
consider that to necessarily fall into that level. To
specifically target an individual, to harass them,
I again, I don't think meets the standards of how

postmasters should behave. On groups, to encourage
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people to behave in that way, to me, is not acceptable.

And, therefore, if we are aware of that going on,
you know, it's not how we want -- it's part of the
reason why we want to set up the Culture Committee.
It's part of the reason why we want to do that. So that
postmasters, whilst we understand people's frustration,
there's a limit to sort of where that should go and
a limit to how that should -- you know, there's below
the line and there's above the line. There's acceptable
and unacceptable. And we just felt that, in this case,
the individual had displayed some of that in the past
and had caused employees distress and that, by admitting
the individual back into the NFSP, that was only
inviting or allowing that to happen again.

Therefore, on that basis, we have a duty of care
towards not only our postmaster members but our NFSP
employees and, therefore, reluctantly -- and we
deliberated at great length -- we decided that, you
know, to protect our members, that was the right
decision.

It's not what we want to do but, you know, some
people -- it doesn't matter what you say, they're not
prepared to -- they think they can do what they want,
when they want, how they want and, if you disagree with

them, they will use any avenue that they possibly can to
93

to admit this individual --
Yes.
-- into the NFSP, is that your evidence?
Yes.
Now --
Can I also clarify that they didn't actually apply in
their name, they applied in a pseudonym. So -- again,
so we felt that that wasn't -- that that was
disingenuous, that if you're not willing to be open and
transparent with us as to who you are, that doesn't
really show respect towards the NFSP and, therefore,
again, that was also part of the reasons why we declined
their membership.
Please can WITN00370127 be shown on the screen. Thank
you. If we scroll down, please -- sorry, if we could go
down a little bit further, thank you -- this appears to
be a draft of the letter which was sent to the applicant
refusing his application for membership; is that
correct?
Yes.
So it's dated 13 March 2024 and reads:

"Dear Mr Jay

“Thank you for your email and completed NFSP-
application form dated 6 February 2024.

"Lam writing to inform you that a decision has been
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call you for whatever. Well, that's not acceptable.
That's -- I personally don't think that that's the

standard that postmasters should behave in.

I just wanted to clarify with you, to make sure I've

fully understood the reasons. What I understand you to
be saying is that this individual applicant had been
responsible in the recent past for posting social media
posts which were abusive in their content?

Yes.

Is that what you're saying?

And they had specifically hounded an NFSP employee and
caused them quite considerable distress.

Again, sorry, it was this particular applicant who had
targeted --

Yes.

-- you say, one of your employees --

Yes.

-- on social media --

Yes.

-- in a manner that you've described as harassment,
harassing --

Yes.

-- is that correct? It was based on the content of the
abusive messages and the distress which it caused at

least one of your employees that the Board decided not
94

made by the NFSP's Board members to decline your

application for NFSP membership. The decision will also

become applicable if you or any other member applies to

nominate you as an Organisational Representative and

I refer you to Section 9, Item 9.3 of our Articles of

Association [which provide] 'The council may in its

reasonable discretion decline to accept any person as

a Member and need not provide its reasons for so

doing’."
Now, in your statement and in your evidence today

you've given a detailed reason as to why the application

was refused. Why did this letter provide no reason to

the applicant explaining the grounds for the refusal of

his application?

We just thought it was -- that's the decision we had

made. We didn't have to, as per 9.3, provide a specific

reason for doing so. We just felt that that was

probably the simplest and easiest way to sort of deal

with it. I don't think they, you know, I -- knowing the

individual, it wouldn't matter what we put down, I don't

think it would have been accepted. It didn't matter

what we said. It would be used in a manner to undermine

the NFSP, you know, because that's the behaviour -- that

was the behaviour of the individual, and it's sad that

that's the case.
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I would rather have -- as I say, I'm an inclusive
person. This is not something that sits easily with me,
it's not something that sits comfortably with me but
sometimes I have to make difficult decisions, and this
was one of them.

Q. The fact that you don't have a duty to give a reason, of
course, doesn't preclude you from giving a reason to the
applicant, does it?

A. Yeah, but, as I've already said, I don't think any

answer that we would have given would have -- there's --

I don't think there was any way that the individual
would go "Yeah, fair enough. That's fair enough.
That's a fair point". This is not an individual sort of
who, you know, has -- any conversation, any discourse
that we've had with him over the period, has ever
accepted anything that we've said, you know, and as I've
said, has gone to quite significant lengths, and has
caused our employees -- some really, really good
people -- distress.

And despite trying to say, "Look, you know, just

tone it down and maybe there's a different way we can do

this, it's not going to happen", so, you know, as I say,
knowing the individual, it didn't matter what we said,
it was never going to be accepted, so just quote the

rules and move on.
97

would never take anything that we said as, "All right,
okay, fair enough. I've overstepped the line. Maybe
the language that I've used or maybe the things that
I've done, I've gone too far". He demonstrated that
time after time. So, as I say, it was simply, to

protect our employees from further potential harassment,

we felt that this was the right course of action.

MS HODGE: Thank you, sir, that brings us to the end of that
topic. I'm mindful it's 12.55. It may be sensible to
break now.

SIR WYN WILLIAMS: Yes, by all means.

MS HODGE: Shall we return, then, at -- we can make it 2.00.

I don't think we're going to take up the whole of the
afternoon.
SIR WYN WILLIAMS: Yes, that's fine.
MS HODGE: Thank you.
(12.57 pm)
(The Short Adjournment)
(2.00 pm)

MS HODGE: Good afternoon, sir. Can you see and hear us?

SIR WYN WILLIAMS: Yes, I can, thank you.
MS HODGE: Thank you.
Mr Greenhow, before I move on, is there anything
further you wish to say about the matters we were

discussing shortly before the lunch break?
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If you are concerned about the culture on social
media --

Very concerned about the culture on social media.

-- why, then, not explain to the applicant the reasons
why you considered their conduct to be unacceptable?
Because I think that's only just going to invite more,

and more, and more, and more. You know, the reality is,
this is, as I've tried to sort of say, this is not

someone who will take -- this is someone who believes
they can do what they want, when they want, how they
want and, if you happen to disagree with them, they will
go to extreme lengths to get their way, even if it's
causing people mental distress. That's of no concern.
So, you know, I don't think that there's any --

sometimes you've really just got to go, "Sorry, no, move
on".

Do you not think it would help, Mr Greenhow, to be more
transparent about your decision making in order to avoid
possible misunderstandings or suspicion about the
motives of the Board in turning down an application like
this?

If you're dealing with an individual who would be

willing to be reasonable on that matter, then, yes,

I would agree with you but, as I've tried to explain, it

doesn't matter what we said to this individual, they
98

No, that's okay. Thank you.
My next topic is the extent of change which has been
brought about within the Post Office.
Sorry, the?
Within the Post Office?
No, but change?
The extent of change which has been bought about within
the Post Office?
Oh, sorry. Thank you.
In your statement and in your evidence to the Inquiry
this morning, you've expressed concern that the culture
of the Post Office has not changed; is that correct?
Certainly, at a Board and senior executive level, yes.
In your statement, you cite as an example the time which
it has taken to negotiate changes to the Grant Framework
Agreement --
Yes.
-- to remove the clauses which restricted the activities
of the NFSP --
Yeah.
-- is that correct?

You describe those negotiations as protracted and
difficult; is that fair?
Yes.

You suggest that, so far as you are concerned, they are
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evidence of the fact that the leopard has not changed
its spots?

Yes.

Please can we bring up your statement at paragraph 317,
page 113. You say there that:

"Post Office provided the NFSP with a note of
novation."

When was that, please; do you recall?

Yeah, it would be some point in 2019. The exact month
I can't remember but it would be in 2019.
You say:

"The legal advice we received said this did not
address the specific clauses which were raised by Lord
Justice Fraser at paragraphs 590 and 596 of the Common
Issues Judgment [those being those] related to clauses
5, 17 and 26."

You say:

"The advice we received is that the [Grant Framework
Agreement] would require significant alteration to
comply with the Common Issues judgment."

You go on to say that an amended note of novation
was prepared by your solicitors and presented to the
Board of the NFSP in October 2019 and approved prior
being sent to Post Office for consideration. You then

say this:
101

"We proposed that the term 'good faith’ be placed in
the recitals section, but this was ... rejected by Post
Office. The reality of the Post Office refusing all
attempts to include this tenet in the [Grant Framework
Agreement] gives voice to concerns that, culturally,
Post Office has not changed and that there is
an unwillingness by the Post Office to act in good faith
towards the NFSP and therefore our Postmaster members.”
Now, a new Grant Framework Agreement has now been
signed by both the NFSP and the Post Office; is that
correct?
Yes.
For the benefit of the transcript, that document bears
the reference WITN00370137. Please could that be shown
‘on the screen.
Thank you. If we scroll over the page, please.
Thank you and, again, then down to page 1, please. Yes,
thank you, the first page of the agreement. So it's
dated 16 September 2024, so very recent.
Itis.
-- since the time that you produced your statement. By
way of background, it states this:
"[The Post Office] and NFSP are parties to a Grant
Framework Agreement originally entering into between

[the Post Office] and the unincorporated association
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"It has taken the best part of five years to get the
Post Office to the point of agreeing some of the changes
we were proposing.”

Now, I think it’s right to say that you attribute
that significant period of delay to the Post Office; is
that correct?
Yes.
One of the issues you say that acted as a stumbling
block was their refusal to acknowledge that they had
a duty to act in good faith towards their members; is
that correct?
Well, acted -- one of the aspects that Lord Justice
Fraser talks about is that the Post Office had a duty to
act in good faith in relation to postmasters and he
makes such a -- that is really a central tenet of his
ruling, that we felt that it was important that, if that
is how the Post Office are supposed to behave towards
postmasters, that given the fact that the NFSP is
postmasters, then that's how they should act towards the
NFSP as well.
If we could look, please, at paragraph 319, onto the
next page, please. So you explain there what you've
just said: that so far as you were concerned, this issue
‘of good faith was a central tenet of the judgment. You

say this:
102

known as the National Federation of SubPostmasters dated
21 July 2015 and novated to the NFSP by a Deed of
Novation dated 5 November 2016 ..."

You may recall I asked you about the deed of
novation. Does that help you as to why there was a deed
of novation?

Yeah, but I'll be honest with you, I can't explain what
the deed of novation was about. Why there was

an update, I don't know.

There seems to be a distinction being drawn here
between --

Yes.

-- the NFSP as a unincorporated association and its
subsequent incarnation as a private limited company.
So that may be the reason why, then because, certainly
when the Certification Officer ruled that we weren't

a trade union, we were unincorporated for a period of
time and then -- until we actually got ourselves
incorporated.

It goes on to say this at B:

"Following Alan Bates and Others v Post Office
Limited (the Common Issues judgment), the parties have
agreed to amend the Original Grant Framework Agreement
to address those matters raised in the Common Issues

Judgment relating to the original Grant Framework
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Agreement.
"The parties have therefore agreed to amend and
restate the original Grant Framework Agreement as set
out in this deed.
We can see it's at page 14, please, there's a new
clause 5. This reads "General conditions of the Grant":

“Both parties shall use reasonable endeavours to
identify any issues which will or may create tension
between the interests of [the Post Office] and those of
Postmasters and use reasonable endeavours to resolve any
such issues.

“For the avoidance of doubt, it is hereby
acknowledged that the NFSP may:

"[Firstly] represent individual Postmasters;

[Secondly] discuss and comment on [the Post.
Office's] initiatives, policies or strategies with its
membership;

"[Thirdly] publicly comment on the same;

"[Fourthly] state and plea ins its opinions on the
same, even if not in support of [Post Office]; and

"[Finally] lobby relevant stakeholders such as BEIS
and Royal Mail Group Limited on behalf of its members."

So quite a significant change then, relative to the
provisions that we looked at this morning?

Yes, I mean, that's obviously in line with Lord Justice
105

Well, they determine sort of whether there is
a shortfall. They'll obviously -- you know, as I've
said earlier on, there's the three questions: is it
Horizon; is it a mistake and by whom; or has the assets
been used in the manner that was not intended?
Postmasters are still explaining that they are
experiencing losses. They then receive a letter, which
isn't a demand for money but is, "You've got a debt",
and, you know, we need to be in a situation where the
Post Office are able to bring that to an open and
transparent conclusion, rather than it just going on and
going on. Some of these cases have been outstanding for
years because they can't be brought to a conclusion.
And I do think we need to be in a situation where we
have complete confidence in Horizon as a system. As
I've highlighted, postmasters are still experiencing
shortfalls. We've asked the Government for a full,
in-depth look at the hardware, the software, the
telecommunications, the processes, practices within
Fujitsu and also within the Post Office, but there's
a reluctance to do that.
I still think that there's a belief within the Post
Office that Horizon is robust. I had a conversation
with officials in the Department of Business and Trade

not that long ago where I asked the question, and I was
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Fraser's ruling and why did it take five years to do
that? I have no idea.

I'd like to must move on, please, if I may to the

subject of audits and investigations. You've said

earlier in your evidence that I think you accept that

there has been a change of culture within the Post
Office, so far as their conduct of audits and

investigations is concerned; is that correct?

Yes, there has and I think that's down to the

individuals involved and I think they have to be
congratulated on that. However, that's not to sort of

say that we're kind of where we need to be. Not -- I do
feel that we need to do more and I still think the Post
Office is acting as judge, jury and executioner in

certain aspects, and we need to have something in place
that will enable the Post Office to bring its evidence,
particularly where there's a disagreement with the
postmaster, and the postmaster can bring their evidences
as well, and that can be deliberate on and discussed in

a far more open and transparent way rather than, as we
have seen, in relation to what took place with one of

the Postmaster Non-Executive Directors.

Can you please clarify what you mean when you say that,
in certain respects, the Post Office is still acting as

judge, jury and executioner?
106

told the Post Office are telling them that the system is
robust. However, postmasters are experiencing
shortfalls.

So I think we need to -- there needs to be something
else there that enables both the Post Office and
postmasters to come together so that it's -- certainly
I can't remember if it was Saf or -- Mr Ismail or
Mr Jacobs who were talking about these being done
externally. I don't disagree with that to a point but
what we have been saying for a long period of time is
that there needs to be another process where the Post
Office can bring to an independent body and the
postmaster can bring to an independent body if they have
concerns about what the conclusion that the Post Office
draw.

You've explained in your statement that the NFSP is
aware of four cases in which a subpostmaster has
requested support in their defence either of a criminal
prosecution --

Yes.

-- ora civil claim --

Yes.

-- and that, in one of those cases, the subpostmaster
has been exonerated; is that correct?

It was, yes. If I may sort of -- this wasn't something
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that was done by Post Office. It was actually -- it was
the police who bought this. I don't think I should go

into maybe the specifics of the case, only on the basis
I'm not sure if I can, you know, within this framework

or not, but --

Well, let me ask you this: in relation to the

exoneration, you said that a criminal prosecution was
brought?

Yes.

At what stage was the subpostmaster exonerated?

I think it went to court and it was thrown out.

Okay, so it will be a matter of public record. Did you

or any of your colleagues have any concerns about the
manner in which that case was investigated or the way in
which the prosecution was conducted?

Yes, but, as say it wasn't done by the police -- sorry,

it wasn't done by the Post Office; it was done by the
police, and I was concerned as to the way the police
were going about it. They seemed to just look at the
postmaster as guilty until proven otherwise. Hence, the
reason when they came to us, I know we need to get some
legal advice here, and I was directed to a solicitor who
would be able to help because it was down south and,
obviously, my connections are north of the border and

obviously a different jurisdiction, and I have to sort
109

by the Post Office to be open and honest with the NFSP.
about the extent of the problems that were being
encountered in the project to replace Horizon; is that
correct?

Not just the NFSP but other postmasters who were
present.

Can you expand, please, on that?

Well, there was another group of postmasters who were
present. So there was myself and my Chair, Tim
Boothman, who were present at that, and there were other
postmasters who were present.

At that meeting you were told what?

That there had been problems with the New Business IT,
but these had been overcome and that we were on track
and we've got a strategy ahead.

Why do you characterise that as displaying a lack of
transparency?

Well, given the fact that the very following day

Computer Weekly gave a completely different story, the
accurate story, that there are serious, serious concerns
within Government in relation to how the programme is
being developed, the cost of the programme, not only is
it behind schedule it's being taken in-house, I can't
remember exactly what the department within Government

it's being looked at but it's all to do with -- I do
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of say I was delighted in the way that the solicitor
approached it, how they engaged with the NFSP, how they
sought the NFSP's help and guidance in relation to
things, and just how they approached the postmaster with
the greatest of respect and support right the way
through.

And the stress that that postmaster was under was
colossal but thankfully, ultimately, the right decision
was made.
But to be clear, in this particular case, your concerns
related to the conduct of the police force --
Yes.
~- the officers investigating —
Yes.
-- rather than the Post Office?
Yes, the Post Office really didn't have anything to do
with it, as far as an investigation is concerned.
You say in your statement that your relationship, the
relationship of the NFSP, with the leadership of the
Post Office is very strained?
Yes.
You suggest there remains a lack of trust in the senior
management and Board of the Post Office --
Yes.

~- and you cite as an example what you say was a failure
110

mention it in my statement -- but it's the part of
Government that looks after all the major
infrastructures like HS2, et cetera, that's looking
after it.

I think there was a Government Audit Team that had
looked at it and highlighted grave concerns so there was
nothing along those lines.

Kind of ironically, my wife and I had been given
tickets to Chitty Chitty Bang Bang, and we were sitting
in the theatre and on the break, and I looked at my
phone and up came the report from Computer Weekly.
I read it, I immediately emailed Nick Read and said,
"What the heck's going on here? This is not what you
told us yesterday”. That resulted in a conversation on
the Friday with the Head of IT Services within the Post
Office and I simply said, "Listen, if I was the new
Chair and you had told me what you told me on Wednesday
and, on Thursday, I've learned what I've learned, what
do you think the conversation would be today?”

That's it. I mean, you had the most senior
individuals within the Post Office, from an executive
point of view in that meeting, bar obviously Al Cameron,
who was the Chief Financial Officer, and basically what
the NFSP and other postmasters were told was not

accurate.
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In your statement, you say that you believe the problem
lies in the governance of the Post Office?
Oh, without question, yes.
But you don't believe that the creation of the
Subpostmaster Non-Executive Director is the answer to
that problem; is that right?
I think it brings a conflict on the basis that they have
their own businesses, potentially directors within their
‘own businesses and, therefore, they have to act in the
interests of the business of which they are a director.
Itis possible, you know, they can't vote on a number of
things, particularly in relation to remuneration? So
I don't think it necessarily is the answer, no, and
unfortunately, you know, you have to listen with great
empathy and sympathy as to what both those two
Postmaster Non-Executive Directors have gone through.
They have tried everything they possibly can to try
to help this business turn around but this business is
not prepared to listen and it'll do anything and
everything to undermine anybody who threatens its
position of power, authority and influence.
Your proposed solution to the problem is the
establishment of an oversight committee; is that
correct?

Yes.
113

the knowledge, in my view, of Government, because
there's a Government representative on the Board.

After everything had taken place, not one Director
of the Board was asked to step down or looked at
themselves in the mirror and went, "Yeah, we got this
wrong". They all carried on. Indeed, the Chief
Executive, whilst she left the business, left with
a golden goodbye, a CBE and a job in the Cabinet Office.
That's hardly an indication of the owner of the
shareholder thinking that the Board had made the wrong
decision and given what came out right across the two --
the Common Issues and the Horizon Issues judgments,
never mind the recusal.

So I felt that the relationship between Post Office,
the Civil Service and Government was where the problem
was. And I also think that, as a postmaster, as an --
I am an investor -- well, I'm not a postmaster now, so
apologies, but I am -- my postmaster colleagues are
investors in this business and, over the last 30 years,

I've seen decision, after decision, after decision that

has resulted in the security in the viability of their
businesses being undermined and reduced. Postmasters'
income has declined from -- in '21 it's gone from

48 pence in the --

Mr --
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Can you please explain briefly what your proposal is in
that respect?

So it's actually quite common on the continent and I --
you know, back in 2022, I was sitting thinking, what can
we do? I was understanding that the governance was the
problem and I really felt that the relationship between
Government and Civil Service and Post Office was the
fundamental problem that had resulted in this scandal
happening and everything was being done just to push it
down the line, push it down the line, push it down the

line.

So we needed to have a situation where we could have
a body that would sit alongside. It's not to replace,
it's not to slow things down or obfuscate things but
actually to sit alongside and hold the Post Office to
account.

Because the reality is, in my view, as I look back
on it, unfortunately, I don't think Government have
actually held Post Office to account and let me explain
why.

Back in 2018 the Post Office Board set a strategy
and that strategy was to ensure -- to defend the
indefensible and ensure that the victims remained guilty
and they knew that there was a problem but they still

went ahead with it. And that would have been done with
114

Sorry. So put all of that together, put all that
together, I just feel we need to have another body that
can actually hold the Post Office to account and can
work alongside it. And it's quite common, as I say, on
the continent. So that's what we came up with.
Okay, so that's the background. What is your proposal
in relation to the composition of this committee?
So Government need to be on there, obviously they're the
shareholder. Obviously those who are the
representatives, so Unite, who represent the management
of the Post Office; the CWU, who represent the employees
of the Post Office; the NFSP who represents postmasters.
But I do think it's also really important we bring on
consumer champions because it's about -- you know, the
Post Office has a social purpose. So what is it that
society needs? What is it that the community needs from
the Post Office?

The Government are making decisions that are having
a detrimental impact; post offices are closing right
around the country; postmasters are no longer able to
afford to run their businesses; communities are being
left without post offices; services are being taken
away; and we need to bring those community champions or
those consumer champions on so that Government, when

it's making decisions, actually understand what
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consumers need, rather than, in essence, decisions being
made that actually have a detrimental impact on
communities the length and breadth of the country.
What I'd like to fix on, Mr Greenhow, is how to you
envisage this proposal for an oversight committee
bringing about change in the culture of the Post Office,
that being your primary concern, underlying a lot of the
other matters that you --
Yeah, well, given the fact that Government will be on
that committee, then you're basically saying to the
Government, "You're the shareholder, you own this is
business. Here's the evidence that things are not
right. We've got to put that right".

If 1 go to --
Can I just pause you there. What you've just said,
essentially, is that you would like to have direct
access to the Government to be able to communicate the
concerns of the organisation and the concerns of your
members to ministers; is that the essence of it?
Well, yes, I think what we need to sort of be able to
sort of do is there is -- to our knowledge, there is no
strategy for the Post Office going forward. There isn't
one. And, to our knowledge, there really hasn't been
one for a significant period of time. Now, Post Office

might say something different. Just saying that's our
117

Yes.

Does your proposal for an oversight committee reflect
a concern that that Working Group is not providing
adequate governance of the Post Office or contributing
to adequate governance of the Post Office at present?
Well, I mean, we talked just briefly about NBIT. I have
been trying to get the Head of IT to come along to that
tripartite working group so that they are -- he is.
providing an update within that forum as to how this is
progressing. He's never appeared. He's never sort of
come to it, and I don't know why. Every single time

I ask for NBIT to be on the agenda, but it's not. I'm
asking about what we can do to improve remuneration for
postmasters and not seeing anything.

I'm not seeing anything that is giving me confidence
that the Government and the Post Office after working
for the benefit of postmasters. It's just -- i's as
if ~ it's a talking group, it’s a talking shop.

There's nothing there that's giving me confidence that
we are actually working together for the good of the
future of this business. And that, I feel, sort of, is
indicative of how things have been.

I do believe that, behind the scenes, Government and
Post Office are talking and are working and -- but

I don't know what it is, I don't know what they're.
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view. And, therefore, I think those who represent the
employees and the postmasters, but also consumers, need
to be able to work with Government, the shareholder, to
ensure that there is a strategy in place for the good of

this business. Well, where things are being done wrong,
there is a body there that can actually highlight this,

and actually bring this to the surface and hold Post

Office to account. That was the problem in the past.

All of this was getting done -- we talked earlier on
about transparency -- this was all getting done behind
the scenes, between the Government the Civil Service and
the Post Office and, as a result of that, this was
kicked down the -- sorry, the can was kicked down the
road. There wasn't sort of the ability for it to really
be brought to the surface. It was suppressed,
suppressed, suppressed.

And I think, with an oversight committee, we've got
the opportunity to -- if there is anything like this
happens again, it's going to be brought to the surface,
and Government won't be able to obfuscate it. They
won't be able to just brush it under the carpet.

You've mentioned in your statement that you've
contributed to a tripartite working group comprising of
the Postal Affairs Minister and his Department, the Post

Office and the NFSP; is that correct?
118

doing, I don't know what plan they have, and I'm worried
about it and so are my colleagues.
I think you've explained in your statement that you
brought your proposal for an oversight committee to the
Working Group --
Yes.
-- is that correct? What is the current status of that
proposal?
Again, I describe in my statement that the Minister
asked us in January to -- for the Post Office and the
NFSP, to work together and bring it back to him. The
very first meeting that I had, I was told by the then
Chief Retail Officer that the Post Office has no desire
to change its governance whatsoever. Well, that kind of
tells you a story. I had to really sort of push back to
that individual and I don't think he'd ever been spoken
to in that manner by anyone before, not that I was
disrespectful but it was just the fact that I was going,
you know, "You're an employee of this organisation and
if the Minister tells you to do something, you've got
a duty to do that, and going against the wishes of the
Minister is not something that a senior employee of the
Post Office should be doing".

Where we are at this moment in time, yes, there are

discussions as far as potential governance proposals.
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Obviously, I wasn't aware that the Post Office had
commissioned Grant Thornton to look into governance of
the Post Office. That's obviously come out now via the
Inquiry, and all of this was going on before. So I've
been trying to push for a change in the governance of
the Post Office at least for two years now and it's good
to see that we are starting to make some progress.

If I may, I'm not saying that it's -- the oversight
committee is the only way. I'm not saying that if it's
not my way, I'm not playing. But I do think we need to
seriously look at the governance of the Post Office
because I think that is where it's fundamentally broken
down for -- over such a long period of time that has
resulted in so many people having their lives ruined.
Thank you. My final topic, Mr Greenhow, is the current
policies, that is to say the written policies of the
Post Office, in relation to audits, investigations,
suspensions and other decisions. Now, you say in your
statement that the NFSP was invited by the Post Office
to comment on drafts of the whole suite of policies
governing this whole area, that is to say the conduct of
audits --
Yes.
-- investigations and decision making in relation to the

suspension and termination of the subpostmaster's
121

-- at the point at which they come to the --

Yeah.

-- branch to carry out an audit?

Yeah.

Can we look, please, at your statement at paragraph 326,
page 117. Thank you. You say there:

"... we have raised concerns about the Audit
Reporting Script, we did suggest an alternative script
which the postmaster or OIC ..."

Can you explain that reference, please?

Officer in charge.
Thank you:

"... would be required to sign with a copy retained
by the postmaster. Part of the opening script informed
the postmaster or [Officer in Charge] that the NFSP was
available for help and support. Additionally, we
suggested a checklist for the postmaster and [the
officer in charge] to follow given the potential
stressful situation that may be dealt with. This would
enable notes to be taken for reflection afterwards."

You say:

"Sadly, this was rejected by the Post Office on
a number of occasions."

Were you given reasons as to why your proposals were
rejected?

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contract. In your statement you say that you're -- and
forgive me, that's something which you are now doing on
an annual basis -- is that correct --

Yes.

-- viewing and providing comments --

Yes.

-- upon the policies. You --

I have -- if I may, although I was personally dealing
with it, along with another colleague, obviously the
work that I'm doing as far as the Inquiry has taken up
so much of my time, I've had to step back from that at
this moment in time and delegate it to other individuals
within the NFSP.

You identify in your statement two areas of concern that
you have in relation to the existing policies. One
relates to what is known as the audit reporting script;
is that correct?

Yes.

That's a script, is this right, to be used by the Post
Office auditor --

Yes.

-- to address their first interactions --

Yes.

-- with the subpostmaster or his staff --

Yes.
122

It's not what they wanted to do.

Secondly, in the following paragraph, you mention some
reservations you have about the role of the Decision
Review Panel; is that correct?

Yes.

If we could turn, please, to the Decision Review Policy,
that's contained at POL00088892. Thank you. This is
version 2.3. At page 3, please, paragraph 1.3, under
the heading "Core Principles" it states:

"A challenge will be heard by a review panel who
will have no prior it in the circumstances which led to
the termination and the challenge being raised."

So this a proposal, effectively, for a level of
independent review of the decision to terminate the
subpostmaster's contract; is that correct?

My understanding, yes.

On page 7, please, at paragraph 2.4. Under the heading
“Roles & Responsibilities", it provides this in relation

to the review panel, it will be a panel of:

"... external members, who are responsible for
deploying the procedures set out in this policy and for
making a final decision on the review requested by the
postmaster. The Review Panel will be supported by the
Contract Investigation & Resolution manager to:

"[Firstly] apply Post Office's underpinning

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behaviours of fairness, transparency and
professionalism;

"[Secondly] be fully conversant with this policy and
linked policies;

"[Thirdly] gather as much information as possible
relating to the background behind the termination;

"[Fourthly] complete a Termination Decision Review
Rationale Document before making a decision in
consequence of a challenge. The rationale document is
a report which includes facts and findings of the
investigation, and the rationale used to determine the
outcome;

"[Fifthly] to ensure any decision arising from
a challenge is made in line with all other Post Office
policies ...

[Finally] ensure this policy is adhered to and the
postmaster is treated with fairness, transparency and
professionalism throughout the process ..."

If we could go, please, to page 12, under
paragraph 3.2, we see there an explanation of the role
of the review panel. It provides:

“It is the role of the Review Panel to ascertain
whether the decision to terminate was taken in
compliance with the relevant contract and requirement

set out in section 3.1.
125

the basis of, if something did go wrong, the Post Office
is then able to turn round and go "Well, we had
postmasters there, they said it was okay".

I don't think that's fair, for postmasters who may
be entering into these situations in good faith, and
I don't think it's -- you know, the Post Office have
still got too much control over it and hence the reason

we would prefer to see a proper mediation to the process

with CEDR or ACAS, so that, if it gets to that
situation, it's taken out of the Post Office's hands, in
essence, and it's someone else who is making the

decision, just as the Postmaster Non-Executive Directors

discussed earlier on this week.

Q._ So your proposal is for some form of formal mediation --

A. Yes.

Q. -- is that correct? Who in your view should be
responsible for funding that process?

A. Well, the Post Office.

MS HODGE: Thank you. I've no further questions for you,
Mr Greenhow. If you could remain there --

A. Thank you.

Participants.

SIR WYN WILLIAMS: Well, let's have the Core Participants,
127

MS HODGE: -- the Chair may have some questions for you and
I believe there are some questions from some of the Core

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"Any investigation must be a fair and unbiased
method of investigating the issues raised in the
challenge. The process of investigation allows the
Review Panel to establish facts relating to the issues
raised and gives the postmaster the opportunity to
identify and answer any points or queries raised by the
Review Panel. The Review Panel may have to undertake
further enquiries as a result of any new and/or
additional information provided as part of the decision
review process."

Just pausing there, the nature of your concern, as
I understand it, relates primarily to the composition of
that panel; is that correct?
Yes.
Now, I don't believe we see the composition of the panel
defined in this policy document. Why are you concerned
about Post Office's proposals in relation to who will
sit on this review panel and make a determination?
Yes, well, my understanding is it would consist of two
senior Post Office employees, a non-voting chair and
a postmaster, and we felt -- and we see this in a lot of
the processes that the Post Office are putting in place,
they're bringing postmasters into, in essence,
a decision-making place, and we feel that that's placing

those postmasters in a potential position of harm, on
126

please.
Questioned by MS PATRICK

MS PATRICK: Good afternoon, Mr Greenhow. My name is

prop

Ms Patrick and, together with Mr Moloney, we ask
questions on behalf of number of postmasters who were
convicted and have since had their convictions quashed.
You'll be happy to know I only want to ask you about two
documents and two issues.

Yes.

The first issue, is about the pre-GFA relationship
between the Post Office and the NFSP?

Yes.

I want to look at one document, it's POL00021485. Now,
just before it comes up I'll tell you what it is. It's

not a document we would have expected you to see at the
time.

Oh.

It's a Board minute from the Post Office from 2004.

Ah.

So before your time. I just want us to have a look at

it together. You see on the first page, just to

confirm, there's meetings of the Board, 13 October 2004.
The section I want to look at is on page 13, so if we
could scroll to page 13 I'd be very grateful.

It's the section at the bottom half, so if we can go
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to the bottom half of the page and stop there. If we
can scroll a little bit back up, I'd be grateful, thank
you. Now can you see that section there headed
"Subpostmaster exhibitior
Absolutely.

It says, "David Mills reported", and there's a little

bit of a conversation there about a subsidiary of Hayes
Travel being offered a stand at a subpostmaster
exhibition to promote a Bureau de Change product.
There's a little bit about a conflict of interest

potentially, and it says:

"The Board agreed that:

"It was both damaging and inappropriate for a direct
competitor of Post Office to be accommodated at the
exhibition in this way."

The second bullet point:

"Post Office Limited would reconsider the subsidy
provided to the NFSP if they continued to undermine the
position of Post Office Limited", and then they go on
with a few other things, the next steps they're going to
take, having suggested their concern.

Now, this suggests that, even in 2004, there were
some subsidies being paid by the Post Office to the
NFSP, doesn't it?

It does.
129

That relationship was always going to be one where the
interests of the Federation as a whole would be at the
forefront of the organisation and perhaps something that
would be difficult to put before the interests of
a small group of subpostmasters, no matter how
catastrophic the damage to that small group might be.
Well, I think if you -- and I don't know where it is
actually in my written statement but, when you not --
long after this in 2006, there is the evidence in
relation to the Green Giros and, at that point, the NFSP_
threatening to take legal action against the Post Office
for its actions against postmasters.

So no, I wouldn't necessarily agree with you but
what I can't turn round and say at this point in time
is, as I've indicated before, the simple reality is the
NFSP of the past believed the Post Office and put their
faith in the Post Office, rather than believing and
putting their faith in postmasters.
Okay.
It's particularly in relation to this case, and it is --
and, again, I put it in my witness statement -- that
it's sad in one sense that, despite the fact that
through the branch and regional network, the information
came to the Executive of the Post Office who acted upon

it, but it doesn't appear that when it comes to this
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As far as the Post Office at least was concerned from
this, one of the potential levers the business held was
in the manipulation or the use of the subsidies, wasn't
it?

Yes.

Now, you've said today that the problem lies in the
controlling culture of the Post Office and how that's
reflected in its relationship with subpostmasters and
with the Federation?

Yes.

\s that kind of attitude, that problematic culture,
reflected in this minute?

I would say so.

Yeah. Is it indicative of that kind of historic problem

in the relationship that you've told the Inquiry about
today?

Well, obviously back in 2004, I was just an honorary
member. So I wasn't really involved in the NFSP in any
way, shape or form at that point. However, I would
suggest, as I did read this, prior, that this gives

an indication of how long the manipulative behaviour of
the Post Office has existed.

If we can be really frank, this is a relationship
between the NFSP and the business, the Post Office?

Yes.
130

situation, that that unfortunately happened.

So again, you know, I offer my apologies to those
victims.
Okay. If we can move on to the second issue, thank you.
It's a point about the position of the NFSP during the
GLO, litigation?
Thank you.
You've gone over the information with the Counsel to the
Inquiry at some length; I only want to look at one
point. If we can go back, this morning you described
attending the first day of trial --
Yes.
-- and not being able to afford private support to
Mr Bates having missed him in the corridor during
a break?
Yes.
You said your colleagues at the NFSP were following the
trial, including daily updates being put online by
Mr Wallis on his blog --
Yes.
-- and, of course, it was important that the
‘organisation was following what was going on, wasn't it?
Yes.
Might you have dipped into the blog yourself?

I did on occasions, yes.
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Now, I'm just going to have a quick look at the Common
Issues judgment for the one point that I want to ask you
about it, and it's POL00112043. If that could be

brought up, I'd be grateful, if it can't, you can trust

me that I'm reading from it.

Which paragraph is it within there?

It might help you, Mr Greenhow, we're going to look at
the two paragraphs you said that initially you paid
particular attention to this morning, paragraph 574

which is on page 185, and I'll start reading and it may
appear, because I think this paragraph and the paragraph
after may be very familiar to you. I can see you've got
the hard copy, which is very helpful.

Yes.

It's under the heading, "The Post Office's relationship
with the NFSP".

Yes.

It says, "subject relevant for the following reasons",

and it's the first part of 574 I want us to look at:

"The Post Office relied in numerous places, both in
its evidence and in its submissions, upon the fact that
the NFSP does not support the litigation."

Mm-hm.
It gives an example:

“As an example, in its written opening it is
133

Office therefore relies upon this support by the NFSP to
support its stance in this litigation."

Now, I just have a few questions for you, having
read it, and I'm sorry that it's not come up on screen
for everyone. Did the NFSP have any discussion
internally during the trial when it became clear that
the Post Office was relying on their lack of support for
the GLO claimants?
I don't think so I think the first time that I became
aware of this was when I read it. However, I was
present in court when Mr Beal said what he said, and
I thought, "Well, that's strange. Where's he got that
from?" Obviously I've learned now, this side of the
GLO, exactly where it came from and, obviously, my
predecessor was very much supportive of the Post
Office's position but I don't think that was necessarily
indicative of everyone within the NFSP, but certainly
was indicative of his viewpoint.

You can see there, and you've said again, your view
points weren't necessarily indicative of your
predecessor. But you were in charge by this time, and
here was -- perhaps not unsurprisingly -- the Post,
Office relying expressly in the litigation on the

publicly repeatedly-expressed position of the NFSP that

Horizon was considered to be robust.
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submitted, ‘It should be noted that the National
Federation of SubPostmasters, the NFSP, which is the
organisation which represents subpostmasters and their
interests Nationwide, does not ['not’ underlined]

support this action and does not endorse the factual
premises of the claims."

If we can skip down to the next paragraph, down to
575, it goes on again:

"Public support for a cause or a lack of NFSP
support for the claimants does not cut much ice in
court."

Mm-hm.

"It plays no part whatsoever in the outcome. I have
already referred to public and press interest in this,
litigation for the reasons explained, and that plays no

part either. I'm entirely disinterested in whether the
NFSP does or does not support the proceedings. However,
for the two reasons identified, and because some of the
Post Office witnesses, for example Mr Beal, dealt with
NFSP involvement, and it was relied upon by the Post
Office, it was of sufficient relevance to permit

Mr Green some limited cross-examination on this subject.

"It should also be noted that Mrs van den Bogerd
also gave ever that the NFSP has publicly supported the

Post Office's view that Horizon is robust. The Post
134

When that became clear, did it become clear to you
during the trial?
I don't think it did, no.
So had the NFSP taken a position that it was going to be
studiously and positively neutral, without a clear
appreciation of the case that the business was going to
run against its former members?
You know, as I've already sort of explained, we just
felt -- you know, I was new to the role, and we were --
we were not involved in the case. We didn't know what
was being said, really, so we didn't know the inner
workings of it. We could sort of see what was being
said.
Can I just stop you there, Mr Greenhow. The NFSP
position really wasn't really truly neutral was it? You
were really just letting the Post Office do what it
wished with your name, holding your peace and waiting to
see where the chips fell?
Sorry, I don't agree with that.
In the circumstances of what happened, where the Post
Office was actively reliant on the lack of support from
the NFSP, where your colleagues were monitoring the
proceedings in the trial from the blog covering the
daily events, where you turned up to court on the first

day without expressing any support for those 555 GLO
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claimants, where you couldn't manage to reach out to

Mr Bates on the day, despite seeing him across the room,
can you appreciate that your position was seen by them
as very far, far away from neutral?

A. Yes, I can see that but that honestly wasn't sort of the
case, and I think the evidence that's been presented, to
the kind of viewpoint that I was taken to before, gave
an indication that my viewpoint was different to that of
my predecessor. But that's as much as I can say.

Q. Did you ever say that on the record, before the judgment
was handed down?

A. I don't think I did, no.

MS PATRICK: Thank you. No more questions, Mr Greenhow.

Questioned by MR STEIN

MR STEIN: Mr Greenhow, my name is Sam Stein. I represent
a large group of subpostmasters who have been affected
by the Post Office scandal.

Now, during the evidence this week, we heard the
questioning of Mr Ismail, Saf Ismail.

A. Yes.

Q. During the course of that, there was discussion
regarding a letter written on 17 May this year from
Mr Patterson of Fujitsu. Now, that letter -- and I'll
quote it from the evidence -- states that:

"To be clear, Fujitsu (FSL) will not support the
137

And my -- it really concerns me because it shouldn't be
a case that any postmaster, whether it's 20 quid, when
they do their trading period, that they put that 20 quid
in. That is a huge question.

Q. It goes to two issues, doesn't it: the one you've just
been speaking about that affects postmasters in their

branches --

A. Yeah.

Q. -- where there is a shortfall --

A. Yeah.

Q. -- and, as we know from the YouGov report, people are
still paying up for shortfalls?

A. Yes.

Q. So where there are shortfalls, it should have been made

clear, do you agree, immediately --

A. Absolutely.

Q._ -- that the data from Horizon was unreliable and
unreliable for the pursuit of shortfalls?

A. Yes.

Q. The second part that that particular information in May
of this year affects is the question of ongoing
investigations into postmasters --

A. Yeah.

Q._ -- for the obvious reason that, if the police are

carrying out, at this moment in time, an investigation
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Post Office to act against subpostmasters. We will not
provide support for any enforcement actions taken by the
Post Office against postmasters, whether civil or

criminal, for alleged shortfalls, fraud or false

accounting."

The letter goes on to say:

"It seems that the Post Office may be continuing to
pursue permits for shortfalls in their accounts using
Horizon data. We would have expected that the Post
Office has changed its behaviour in light of the
criticisms and is appropriately circumspect with respect
to any enforcement actions."

Then, lastly, Mr Patterson of Fujitsu says this:

"It should not be relying on Horizon data as the
basis for such shortfall enforcement.”

I'll repeat that last bit. So Mr Patterson, middle
of May 2024, is saying the Post Office should not be
relying on Horizon data as the basis for such shortfall
enforcement.

The date of that letter is 17 May 2024. Was the
NFSP told about the content of that letter from Fujitsu?
The first time I became aware of it was as it was read
out in court and I immediately contacted some colleagues
and said "Horizon is no longer reliable, what does that

mean in relation to what we do as far as any shortages?"
138

into any subpostmaster, they should have been informed
immediately in May 2024 that the Horizon system was, as.
ever, unreliable for the purposes of providing data to
support investigations; do you agree?

Yes, I do, and if I may to go back to what said earlier

on, I've tried to get the Government to do a full review

of Horizon. But there is a refusal to do that because
Post Office are telling Government that Horizon is
robust.

During this Inquiry we've considered what's happened
when investigations into individuals, subpostmasters,
have been the result of a failure of disclosure. We've
seen what's happened.

In May this year, the Post Office was told that
Fujitsu's Horizon system should not be used as the basis
for investigations, considerations for shortfalls, yet
nobody is told about it; is it same old, same old for
the Post Office.

It would appear so in that case, yes.

Now, I'll turn to a different point, if I may. You make

a point in your statement regarding the question of
Network Transformation --

Yes.

-- and its impact upon subpostmasters, branches and,

indeed, I think your own branch right?
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Yes, we will be losing our branch on 11 October.

Help us understand a little bit more how that's

connected to Network Transformation because, if we go
back in time, Network Transformation is a while ago.
Why is that still having an impact; why is that having

an impact on your branch and others in terms of closing
them?

So Network Transformation was a programme that was --
a Government programme that started in 2012 and it ran
to 2018. In 2018, when the programme finished, there
was about 700 postmasters who were classified as Hard to
Place and my own office was one of them, the reason
being is that no one was wanting -- there was no

potential new postmaster who was coming forward to take
‘on the business. As I've already explained in 2015, my
wife and I had to make the very difficult decision not

to sort of carry on -- or not convert to the local

model, because we felt -- sorry, I might be speaking too
quickly here -- we felt that it was -- it would not make
financial sense to do that.

Sadly, in 2023, in February 2023, the Post Office
came along and they presented good news to me that they
were going to shut all of the remaining Hard to Place
and at that time there was about 130 of them, and the

reason that I was given that was because of the NBIT
141

I've said, my office will close on 11 October.

May I just sort of say this point -- and it's
important -- because I think it's important to not just
hear but to colleagues who may be listening to this:
it's been said on some social media groups that I may
have accepted a deal from the Post Office and I want to
make it clear that in no way shape or form have
I accepted any financial agreement from the Post Office,
that benefits me to the detriment of my fellow
colleagues. I would never do that.
Did Network Transformation, and the issues you've
discussed, did that have an unfair or unequal impact
upon smaller branches, family branches, in rural areas
or areas of lower population?
I wouldn't go as far as to say that but what I would say
is that the way that business is being run today,
I would say that the new services that are coming on
tend to be going to the larger offices. So, for
example, Evri that's coming on, Amazon, DPD, a lot of
the banking is actually done within the larger offices
and that's meaning that more rural, urban, post offices
are not getting those services. They are losing income.
So we are seeing a disproportionate -- those who are
doing quite well versus those who are struggling.

Now, the Post Office has a social aspect, in terms of
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coming in by March 2025. They did not wish to put that
group of postmasters through the training and also the
investment, as far as the equipment is concerned. So
they were going to be closing those offices, leaving

those offices without potential provision.

But they also stated that they were going to change
the exit compensation that postmasters would receive
from 26 months down to 12 months, which would result in
those postmasters losing, on average, £43,000, which is
obviously a significant amount of money, depending on
the stage of life that you happen to be.

Many of those colleagues were well beyond state
retirement age and had underlying health issues that
meant that they shouldn't be working and -- but yet the
Post Office's attitude was, "We've made our Board
decision, that's what's happening, and we're not
prepared to shift in any way, shape or form".

The only concession that we could get was that, at
the start of this year, they would put boots on the
ground, as they said, and they would go round the
remaining offices to see if someone would be willing to
take on the office within the community. Unfortunately,
I've said in my statement there was 30. That is now 40
postmasters who are going to be in a situation, ten have

already closed, 30 are in the process of closing, and as
142

social provision of services within the community.
Absolutely.

Within the Government funding requirements, there are
requirements to ensure that there are certain numbers of
branches within given areas and head of population?
Access criteria, yeah.

Repeat that, please?

Access criteria.

Now, in terms of the access criteria, where you are
looking at a branch in an area perhaps of low population
density, which would tend to mean lower footfall within
the Post Office branch, is that reflected, that lower
income into the branch, is that reflected in the income
from the Post Office to the subpostmaster?

Well, yes. What we've got is a situation that, if we

were to go back to 2013, the average income to

a postmaster was about £42,000. It's now down to about
35,000. That's the average income to a postmaster. If
you take inflation into account, obviously that's going

to be significantly lower.

But just make sure we understand, and perhaps I missed
it because I was being given a piece of information, but
in the smaller branches, is there a funding, if you

like, bias towards those branches?

Yes.
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Right.
Now, some of them will be, for example, my own office,

still receive what's known as -- well, it was known as.

core tier payment, but it's now called an assigned

office payment, which is, in essence, a basic flat
remuneration, and then we get paid a commission on each
transaction that we do.

Right. When was that last reviewed?

It's that -- the review for the assigned office payment

is usually done on an annual basis and that is usually
linked to inflation, and that is something that the NFSP
have negotiated with the Post Office and got in place.
Okay, and can you just confirm that the DBT are

reviewing the National Transformation Scheme?

No, they're not, and I think they should. As you know,

we have launched a campaign, as far as Network
Transformation is concerned, because having -- you know,
having been part of this Inquiry for so long and

listening to what is being said, I came to realise, in

‘one sense, two things: that the organisation back in
2012/2015, that was doing everything it possibly could

in relation to the Complaints and Mediation Scheme was
exactly the same organisation that was implementing
Network Transformation.

Too often, I was hearing from colleagues that they
145

The helplines, the Post Office helpline and then the
Fujitsu helpline. The questions that we've been
pursuing, as you're well aware is whether those
helplines have actually provided any help at all or are
they, in fact, the unhelpful lines, okay? Now, we know
through the YouGov report that people are still having
difficulties with the Horizon system; people are still
experiencing shortfalls; they are still paying off
shortfalls, okay? Does the NFSP receive information
regarding the helplines, the calls that are being made,
the way that they are dealt with and trends being
expressed within those helplines?

Not that I'm aware of.

Why not?

Good question. That's -

Have you asked for that?

I'm not aware if we have, actually, to be honest.

Well, that sounds like a no.

No, okay.

Do you agree it will be helpful if the NFSP and any
other organisation had access to the data and is being
provided across the helplines, the scripts, the
complaints, the concerns being expressed to those
helplines, as far as it is possible to get them cleaned

of any confidential information?
147

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felt as if they were being cajoled or forced or bullied

into converting to one of the models, and that has led
to their financial detriment.

Now, I've described in my statement that I am
a qualified mortgage adviser, not practising any longer,
so I can't use the -- I'm not qualified -- I'm not
authorised, as you'd say, but I am qualified. And
I know under that that you have to be qualified and
authorised to give financial advice. Well, did that
constitute financial advice? When the Post Office came
in and said, "Right, okay, we think's a good idea for
you to move or convert" or whatever, was that
constituting financial advice?

So I think the Government should really do a full
review, how that review is done, whether that's
a judicial review or legal review, or whatever it is,
but do think Government has to look into that and
investigate whether the activities and the actions and
the culture of the Post Office has led to the detriment
of postmasters under the Network Transformation
programme.

Q. Okay. Last topic, should be quite short. Throughout

the Inquiry we've been pursuing the question of the
helplines.

A. The helplines?
146

A. Absolutely.
Q. Is that a matter that you're going to undertake to take
up with the Post Office?
A. Leave that with me. You can be assured that that will
be done.
MR STEIN: One minute.
Thank you.
Questioned by MS ALLAN

MS ALLAN: Good afternoon, Mr Greenhow. My name is Christie

Allan and, as you're aware, I represent Core Participant
Susan Sinclair, who was the first subpostmaster to
successfully appeal her conviction in Scotland.

I just have a few questions for you today. At
paragraph 174 of your first witness statement, you state
that:

"On the back of the mass exoneration legislation
proposed by the UK Government earlier this year, the
NFSP made several attempts to initiate a meeting with
the Scottish Justice Minister and the Lord Advocate but
to no avail."

A. Yeah.

Q. Can you please elaborate on your attempts to meet with
these individuals: when did you first contact them,
what; was the format of your communication; and have you

been successful in receiving any kind of response?
148

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A. Well, we've received a response, which I think is within

the core bundle and I can't remember the very specific
details of it, but I think you'll have been able to read
that. But as far as, you know, trying to get to the
Lord Advocate and the Justice Minister of Scotland has
proved difficult. I think they've obfuscated that down
the line.

I have to say, in contrast, we sent the same
correspondence at the same time to the counterparts
within Northern Ireland, who very graciously invited us
to meet with them and they were very clear about their
desire to be included within the new legislation that
the Government introduced. But we've heard nothing from
the Scottish Government or the Lord Advocate on that
basis.
So there's no proposed meeting at the moment with the
Lord Advocate?
No.
In recent months, the Lord Advocate in Scotland has
publicly confirmed that she and the Crown Office in
Scotland is committed to addressing all miscarriages of
justice and that she to achieving justice for those
impacted and that she is committed to reflecting on
whether anything could have been done definitely by

prosecutors in Scotland?
149

the Lord Advocate needs to sort of like answer, as to
why there is as many people within Scotland who have
been victimised on a proportional basis as there has.
been sort of down here.

But I do think it’s really important that, when it
comes to exonerating these people and making sure that
they get their redress that they deserve, that happens
as quickly as possible, and it's really important that
the Scottish Government and the Lord Advocate get that
sorted.

That brings me on to my final question: according to
information provided by the Scottish Cabinet Secretary,
Angela Constance, earlier this month, only two out of

a possible 141 affected subpostmasters have thus far
been written to in accordance with the terms of the mass
exoneration legislation in Scotland and, indeed, that

the Scottish Government is apparently still in the
process of assessing the 141 possible cases. In your
view, what more should be done in Scotland at this time
and by whom?

Ooh, that's a good question. I don't know the answer to
that one, to be honest. I'm sorry. But I think the

Lord Advocate -- you know, at the end of the day, the
Lord Advocate is the most senior person within the legal

industry within Scotland, so you'd have to sort of say
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Is this reflective of the NFSP's experience of the
personal commitment by the Lord Advocate to get to the
bottom of the events which gave rise to this scandal in
Scotland?

As you know, obviously the process in Scotland is
different than it is down here, and it's something that
has kind of perplexed me, I have to sort of say, and
again, I'm talking about someone who is non-legal. But
much has been made about the fact that the Post Office
can do private prosecutions. But coming from Scotland,
I'm aware that obviously that can't be done and, when
you look at the proportion of people who have been
convicted in Scotland, in comparison to the rest of the
country, it's not disproportionate.

So you kind of have to question what has gone on
within Scotland that's different to down here. Because
you would -- I would have hoped that, actually, given
the fact that the Procurator Fiscal has to take it --
and I hope right in saying that -- so the evidence is
presented to the Procurator Fiscal, who then sort of
looks at it and determines whether a case will still be
brought, rather than the Post Office being able to
obfuscate all of that and bring it. There would have
been less people in Scotland, but it doesn't seem to be

the case, and I think that's a fundamental question that
150

the responsibility lies with her. I think it's a her.
So, on that basis, I think that's where it should start.

I think what is worrying is my understanding is
that, when it comes to the number of people -- the
people who have been convicted, actually they're not
necessarily aware of who the people are. There's a lot
of people that they just don't know who -- they know
there's been convictions but they don't know who they
are or where they are. And that's really worrying
because there could be people sitting at home -- and
I think this is maybe something -- and I hope I'm not
talking out of turn here -- I am not sure whether we can
just exonerate someone, give them some money, "Job's
done, see you later, on you go”.

I don't think that's enough because I do think that
there are people out there who are broken: emotionally,
physically. As a result of that, they have absolutely
no trust within the authorities of this country. It has
left them broken, and I do think that there has been
an attempt -- maybe attempt is the wrong word -- but
there has been, well, a kind of thought process, "Well,
if we'd just say sorry, we exonerate them, give them
some money, everything is fine. Everything in the
garden is rosy", and I don't think that's going to be

the case.
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I think this is going to live with people for the
rest of their lives, irrespective of whether they are
exonerated and get compensation.

You know, one of the other things that is going on
at this moment in time or has just completed is the
infected blood scandal. Okay, so we say sorry, we give
them the compensation. You can't cure hepatitis on that
basis. These people unfortunately -- and I know people
who have sadly -- whose families have been impacted by
that. You can't just get away from that.

Q. So, in short, more work needs to be done in Scotland?

A. Oh, absolutely without question. Sorry.

MS ALLAN: Thank you, Mr Greenhow.

Questioned by SIR WYN WILLIAMS

SIR WYN WILLIAMS: Mr Greenhow, in respect either of
Scotland -- just Scotland -- or in relation to all parts
of the United Kingdom, do you think that the NFSP has
a role to play in speeding up the exoneration process?
I'm not asking you that just in the abstract but, in
particular, in relation to providing any information
that you may hold about former members who were
convicted.

A. Listen, if there's anything that we can do to help, we
will. I think we've shown through this Inquiry just

exactly how much time and effort that we have given to
153

related to their work as a subpostmaster, the
consequence would be that they'd cease to be

a subpostmaster but also cease to be a member of the
Federation, and I just wondered whether you'd have any
records of that kind?

A. No, I think we certainly weren't told the reason why
they were no longer a postmaster. So we -- I don't
think we know and, certainly to my knowledge, there
hasn't been any correlation work done, at the time, to
why someone stopped being a postmaster and whether there
was actually a court case was the reason behind it. So,
unfortunately, I don't think we know.

If there's anything we can do then --

SIR WYN WILLIAMS: = That's fine. Yeah, fine.

Any other questions?

MS HODGE: Sir, I think that concludes --

SIR WYN WILLIAMS: Well, then thank you very much,

Mr Greenhow, for your participation to date, which I'm
sure will continue. I think I'm right in saying that

you have been seeking to assist the Inquiry throughout
all its phases, including the non-statutory phase of it,
so I'm very grateful to you for that and, obviously, I'm
very grateful for your detailed witness statement and
your oral evidence today.

THE WITNESS: = Thank you.
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this Inquiry. If you've asked for any information,
we've given you the information. We've volunteered
information, even that we haven't been asked for. If
there's anything we can do, we will do it. We just --

SIR WYN WILLIAMS: Well, I think this wouldn't be the
Inquiry seeking information from you; this would be if
it's practical. I'm asking you an open-ended question:
if it's practical for the NFSP to search its records for
former members who were convicted and provide those
names to whichever authority it is, in whichever country
of the United Kingdom.

A. I don't think we know, actually, that's the problem.

‘SIR WYN WILLIAMS: You don't know either?

A. We don't know either, that's the problem. I mean, one
of the aspects and one of the things that sort of
concerns me about all of this is, when it came to
a conviction, the NFSP were not involved. That's not --
that's beyond our remit. That's within, dare I say it,

Sir Wyn, within your remit. That's within the legal
industry. That, you know, so -

SIR WYN WILLIAMS: Well, hang on a second --

A. We didn't get involved. We didn't get involved.

SIR WYN WILLIAMS: Hang on a sec. I would have expected,
I should say, not imagined, that if a member of the

Federation had, in fact, been convicted of an offence
154

SIR WYN WILLIAMS: So Ms Hodge we start again at 10.00
tomorrow morning?
MS HODGE: I believe so, sir, yes.
SIR WYN WILLIAMS: Fine. All right, thanks very much.
MS HODGE: Thank you.
(3.20 pm)
(The hearing adjourned until 10.00 am the following day)

156

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INDEX
CALUM BRIAN GREENHOW (sworn) ..

Questioned by MS HODGE ...

Questioned by MS PATRICK .... 128
Questioned by MR STEIN .. 137
Questioned by MS ALLAN ..... 148
Questioned by SIR WYN WILLIAMS ..... 153,

157

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MR STEIN: [2]
137/15 148/6

MS ALLAN: [2]

148/9 153/13

MS HODGE: [24] 1/3I
1/5 1/16 1/18 1/22 2/1
31/3 40/7 40/14 40/17
40/19 40/23 40/25
43/20 99/8 99/12
99/16 99/20 99/22
127/19 127/22 155/16
156/3 156/5

MS PATRICK: [2]
128/3 137/13

SIR WYN WILLIAMS:
[23] 1/4 1/17 1/20
30/5 30/14 31/2 40/10
40/15 40/18 40/24
99/11 99/15 99/21
127/25 153/15 154/5
154/13 154/21 154/23}
155/14 155/17 156/1
156/4

THE
STENOGRAPHER:
[1] 43/16

THE WITNESS: [1]
155/25

"24 [1] 115/23
‘about [1] 68/20
‘fit [1] 16/23
‘good [1] 103/1
‘It [4] 134/1

‘not’ [1] 134/4
‘the [2] 52/20 96/6

--and [1] 122/1

1
1,000 [1] 79/23

4.3 [1] 124/8

10 [1] 55/24

10.00 [2] 1/2 156/1
10.00 am [1] 156/7
10.02 [1] 1/13

10.12 [1] 1/15

100 [1] 40/13

100 per [1] 10/20
100 per cent [2]
23/21 23/21

100/150 [1] 5/12
106 [1] 91/16

11 October [2] 141/1
143/1

11.09 [1] 40/20
11.25 [2] 40/16 40/22
113 [1] 101/5

417 [1] 123/6

12 [2] 59/3 125/19

12 months [2] 17/12
142/8

12.55 [1] 99/9
12.57 [1] 99/17
124 [4] 2/8

13 [2] 128/23 128/24
13 March [1] 95/21
13 October [1]
128/22

130 [1] 141/24
133 pages [1] 2/6
135 [2] 42/11 42/16
14 [1] 105/5

144 [2] 151/14
151/18

15 [1] 68/12

150 [1] 5/12

16 [1] 56/24

16 November 2018
[1] 44/8

16 September [1]
103/19

17 [2] 57/2 101/16
17 May [2] 137/22
138/20

17.2 [1] 57/12

174 [1] 148/14

18 August [1] 21/6
185 [1] 133/10

19 August [1] 22/15
19 December [1]
68/17

1995 [1] 4/2

1999 [1] 3/5

2

2 October [3] 24/19
25/1 25/4

2.00 [2] 99/12 99/19
2.3 [1] 124/8

2.4 [4] 124/17

20 [2] 139/2 139/3
2001 [4] 4/11

2004 [4] 128/18
128/22 129/22 130/17)
2006 [1] 131/9

2010 [5] 5/4 5/22
16/15 17/2 17/20
2012 [7] 5/23 14/11
15/24 18/11 18/11
81/16 141/9
2012/2015 [1] 145/21
2013 [5] 6/9 18/12
18/13 67/23 144/16
2015 [15] 8/10 14/8
15/25 19/19 21/6
22/15 24/19 25/2 45/1
55/23 58/10 90/15
104/2 141/15 145/21
2016 [10] 8/3 10/13
10/19 13/14 13/23
32/5 57/23 67/11
85/19 104/3

2017 [2] 52/5 59/2

2018 [11] 13/24
42/20 44/8 49/9 52/10
54/19 69/1 69/12
114/21 141/10 141/10
2019 [6] 52/5 74/14
79/22 101/9 101/10
101/23

2021 [1] 79/22
2022 [1] 114/4
2023 [4] 66/22 67/4
141/21 141/21

2024 [8] 1/1 2/4
95/21 95/24 103/19
138/17 138/20 140/2
2025 [1] 142/1

21 July [2] 55/23
104/2

21 September [1]
66/22

24/7/15 [1] 68/12
22 [1] 11/21

23 [4] 11/22

24 [3] 21/7 25/25
26/4

24 April [1] 52/10
26 [1] 101/16

26 months [1] 142/8
26 September 2024
(ay 11

273 [1] 84/10

299 [1] 91/18

3

3.4 [1] 125/25

3.2 [1] 125/20

3.20 [1] 156/6

30 [2] 142/23 142/25
30 years [1] 115/19
317 [1] 101/4

319 [4] 102/21

326 [1] 123/5
35,000 [1] 144/18
39,000 [1] 35/22

4

4 September [1] 2/4
40 [1] 142/23
42,000 [1] 144/17
43 [4] 18/22
43,000 [1] 142/9
47 [4] 42/15

48 pence [1] 115/24

5

5 November [1]
104/3

5.3 [2] 56/1 58/24
53 [1] 4/15

555 [1] 136/25
574 [3] 73/5 133/9
133/19

575 [1] 134/8
590 [1] 101/14
596 [1] 101/14

6 February [1] 95/24

7

700 [4] 141/11
75,000 [1] 79/6

8

8 November [2] 49/9
50/14

9
9 August 2016 [1]
32/5

9.3 [2] 96/5 96/16
900 [4] 28/22 28/22
28/23 28/23

94 [1] 84/12

95 [1] 84/12

99 [1] 40/13

A

ability [4] 7/24 29/24
60/22 118/14

able [32] 1/9 17/6
18/18 25/6 27/8 34/4
37/15 42/2 50/8 51/11
54/3 54/5 60/22 61/24
62/2 68/2 73/10 75/25]
77/11 79/8 107/10
109/23 116/20 117/17
117/20 118/3 118/20
118/21 127/2 132/13
149/3 150/22

about [105] 3/8 4/1
8/13 8/22 8/24 9/17
11/7 12/18 14/5 14/25
15/7 15/8 16/3 16/7
19/22 21/24 23/13
29/10 30/16 31/4
31/13 32/16 32/25
33/9 33/16 36/13
43/22 46/5 49/16 50/6!
51/6 51/8 52/8 52/25
53/22 54/12 58/11
59/4 65/5 67/7 70/10
71120 71125 74/9
74/10 74/15 74/21
74/24 75/7 76/5 76/6
79/23 82/8 86/4 87/3
88/10 88/11 88/18
89/21 92/8 92/15
92/21 98/1 98/3 98/18
98/19 99/24 100/3
100/7 102/13 104/4
104/8 108/8 108/14
109/13 109/19 111/2
116/14 117/6 118/10
119/6 119/13 120/2
123/7 124/3 126/17
128/7 128/10 129/7
129/10 130/15 132/5
133/3 138/21 139/6

140/17 141/11 141/24I
144/17 144/17 149/11
150/8 150/9 153/21
154/16

above [6] 25/9 29/21
33/13 64/19 91/24
93/9

absolute [2] 27/25
62/17

absolutely [18] 10/25
16/8 20/2 23/18 23/19)
27/19 42/10 58/19
62/11 76/11 76/13
76/13 129/5 139/16
144/2 148/1 152/17
153/12

abstract [1] 153/19
abusive [2] 94/8
94/24

ACAS [2] 83/10
127/19

accept [14] 3/19 11/3
16/21 19/12 27/2
27/13 27/15 37/24
47/20 55/6 64/18 89/1
96/7 106/5
acceptable [3] 93/1
93/9 94/1

accepted [5] 96/21
97/16 97/24 143/6
143/8

access [8] 37/19
52/18 84/17 117/17
144/6 144/8 144/9
147/21
accommodated [1]
129/14
accommodation [1]
2/22

accompanied [1]
36/7

accordance [1]
151/15

according [2] 10/12
151/11

account [11] 61/7
61/25 62/2 62/2 82/5
85/4 114/16 114/19
116/3 118/8 144/19
accountable [1] 33/8
accounting [2] 12/8
138/5

accounts [3] 32/22
32/23 138/8
accredited [2] 83/14
84/3

accurate [2] 111/20
112/25

accurately [1] 74/24
achieving [1] 149/22
acknowledge [1]
102/9
acknowledged [2]
45/4 105/13

(41) MR STEIN: - acknowledged
A

acknowledging [1]
50/23

115/11 137/2 147/22
act [8] 61/11 87/5

103/7 113/9 138/1
acted [3] 102/8
102/12 131/24
acting [3] 63/10
106/14 106/24
action [9] 35/1 36/22
46/7 49/16 78/3 80/19)
99/7 131/11 134/5
actions [6] 57/18
59/15 131/12 138/2
138/12 146/18
actively [1] 136/21
activities [5] 55/13
56/3 56/20 100/18
146/18
activity [1] 56/7
acts [1] 9/15
actual [1] 67/8
actually [44] 7/18
13/11 14/2 15/2 23/13}
24/5 29/7 29/12 33/18
34/23 34/24 38/19
38/25 64/10 67/7 71/1
7217 72/21 73/20
76/6 83/13 89/1 89/3
90/25 95/6 104/18
109/1 114/3 114/15
114/19 116/3 116/25
117/2 118/6 118/7
119/20 131/8 143/20
147/4 147/17 150/17
152/5 154/12 155/11
add [4] 15/2 50/4
52/16 65/18
added [2] 42/24 66/2
addition [1] 24/2
additional [1] 126/9
Additionally [1]
123/16
address [7] 42/12
78/4 80/19 82/3
101/13 104/24 122/22)
addressed [2] 21/7
44/4
addresses [1] 21/10
addressing [1]
149/21
adequate [3] 88/22
119/4 119/5
adhere [1] 12/11
adhered [1] 125/16
adjourned [1] 156/7
Adjournment [1]
99/18
admit [2] 90/6 95/1

across [9] 42/2 50/10)
72/22 76/7 86/15 88/3

102/10 102/14 102/19)

admitted [2] 89/22
90/2
admitting [2] 23/12
93/12
adopt [1] 7/1
adopted [5] 12/20
35/6 42/13 84/8 86/6
adopting [1] 47/22
advert [1] 59/8
advice [6] 101/12
101/18 109/22 146/9
146/10 146/13
advise [1] 68/13
adviser [1] 146/5
advocacy [1] 81/25
Advocate [10]
148/19 149/5 149/14
149/17 149/19 150/2
151/1 151/9 151/23
151/24
Affairs [1] 118/24
affected [2] 137/16
151/14
affects [2] 139/6
139/21
affiliations [1] 30/20
afford [2] 116/21
132/13
after [20] 20/3 20/10
29/9 40/4 47/24 52/16
58/11 63/9 63/9 63/16
69/13 99/5 112/2
112/4 115/3 115/20
115/20 119/16 131/9
133/12
afternoon [4] 99/14
99/20 128/3 148/9
afterwards [2] 71/1
123/20
again [30] 1/16 1/19
13/17 13/19 13/25
15/17 28/3 33/5 38/10
40/16 66/4 72/16 75/3
82/4 82/17 89/2 92/24
93/14 94/13 95/7
95/12 103/17 118/19
120/9 131/21 132/2
134/8 135/19 150/8
156/1
against [15] 9/21
39/18 41/3 56/11
56/15 56/19 58/23
59/7 76/23 120/21
131/11 131/12 136/7
138/1 138/3
age [1] 142/13
agenda [2] 24/16
119/12
Agents' [1] 67/17
ago [6] 13/2 26/1
43/5 92/15 107/25
141/4
agree [14] 9/16 22/9
46/23 50/3 62/10

65/20 67/24 81/23
98/24 131/13 136/19
139/15 140/4 147/20

104/23 105/2 129/12
agreeing [1] 102/2
agreement [38] 27/2
54/10 54/13 54/22
54/24 54/24 55/12
55/22 55/23 58/8
62/14 65/16 65/19
65/25 66/14 67/20
67/23 67/25 68/1 68/3
68/10 68/11 68/19
68/24 69/18 69/23
70/16 72/2 100/16
101/19 103/5 103/9
103/18 103/24 104/23
105/1 105/3 143/8
Ah [1] 128/19
ahead [2] 111/15
114/25
Ahmed [1] 25/9
aired [2] 19/19 46/18
Al [4] 112/22
Al Cameron [1]
112/22
Alan [5] 3/11 41/3
41/15 41/21 104/21
alerting [1] 33/6
all [62] 3/2 3/14 6/23
11/16 15/16 17/10
28/3 28/3 28/14 28/21
28/23 33/2 34/3 35/15
40/10 41/21 42/23
45/23 46/18 46/21
48/24 51/16 53/18
54/3 55/3 56/20 57/8
57/24 63/12 64/14
71/16 71/17 73/14
73/14 77/3 79/12 81/3
87/10 87/15 89/15
90/13 91/7 99/1 99/11
103/3 111/25 112/2
115/6 116/1 116/1
118/9 118/10 121/4
125/14 141/23 147/4
149/21 150/23 153/16}
154/16 155/21 156/4
ALLAN [3] 148/8
148/10 157/10
alleged [2] 21/16
138/4
alleging [1] 22/4
allow [4] 42/22 42/22
47/11 51/16
allowed [2] 47/23
92/8
allowing [2] 91/4
93/14
allows [1] 126/3
along [9] 6/7 7/20
31/23 53/5 86/12
112/7 119/7 122/9

agreed [5] 26/6 27/13}

141/22
alongside [3] 114/13
114/15 116/4
already [7] 23/1
86/23 97/9 134/14
136/8 141/15 142/25
also [27] 3/1 5/19 8/1
9/8 10/22 12/10 24/3
26/16 34/8 46/3 75/10
77/25 80/6 81/1 86/25)
95/6 95/12 96/2
107/20 115/16 116/13
118/2 134/23 134/24
142/2 142/6 155/3
alteration [1] 101/19
alternative [1] 123/8
although [1] 122/8
always [4] 12/2 38/22)
38/24 131/1
am [20] 1/2 1/13 1/15
3/24 4/23 40/20 40/22,
44/11 44/18 52/19
64/4 64/15 91/21
95/25 115/17 115/18
146/4 146/7 152/12
156/7
amalgamate [1] 7/9
Amanda [2] 44/4
45/22
Amazon [1] 143/19
amend [2] 104/23
105/2
amended [1] 101/21
ammunition [1] 35/5
amount [1] 142/10
Andrew [1] 25/16
Angela [1] 151/13
anger [3] 74/3 74/8
76/9
angle [1] 11/13
annual [12] 5/21 6/15
16/10 16/14 17/18
17/23 18/3 18/18 57/7
57/9 122/3 145/10
annually [1] 26/17
anomalies [1] 78/14
another [8] 7/12
18/14 56/25 79/16
108/11 111/8 116/2
122/9
answer [18] 15/16
17/24 42/23 43/14
43/16 43/18 65/4
66/16 71/24 84/20
85/2 88/11 97/10
113/5 113/13 126/6
151/1 151/21
answered [1] 85/24
anteroom [1] 41/19
anti [1] 72/23
anticipated [1] 65/10
antics [1] 92/21
any [88] 6/4 10/2
11/10 11/16 13/11

14/25 15/22 16/21
23/2 28/1 28/10 29/9
29/12 30/19 30/21
34/25 37/7 37/11
37/19 38/6 38/12 39/1
39/16 46/17 47/7 50/9I
50/18 54/9 55/9 55/18}
56/7 56/8 56/18 57/14
58/17 60/21 69/23
72/5 78/8 78/14 78/14I
80/10 82/7 83/18
83/20 84/1 84/1 84/17
84/19 85/21 85/21
86/24 93/25 96/3 96/7I
97/9 97/11 97/14
97/14 98/14 105/8
105/10 109/13 109/13)
125/13 126/1 126/6
126/8 130/18 135/5
136/25 138/2 138/12
138/25 139/2 140/1
142/17 143/8 146/5
147/4 147/20 147/25
148/25 153/20 154/1
155/4 155/9 155/15
anybody [3] 9/14
82/13 113/20
anyone [4] 62/3
73/15 90/1 120/17
anything [21] 23/18
29/14 31/23 38/12
51/6 54/7 58/4 58/5
72/5 97/16 99/1 99/23}
110/16 113/19 118/18)
119/14 119/15 149/24I
153/23 154/4 155/13
anyway [3] 52/6
60/13 80/1
apolitical [1] 30/20
apologies [8] 3/14
3/19 8/25 25/6 43/18
64/7 115/18 132/2
apparent [1] 55/6
apparently [1]
151/17
appeal [3] 90/10 91/4
148/12
appear [5] 1/5 51/1
131/25 133/11 140/19}
appeared [4] 65/24
66/3 71/12 119/10
appears [8] 16/12
17/14 19/12 44/5
44/21 45/20 75/16
95/16
applicable [1] 96/3
applicant [7] 90/7
94/6 94/13 95/17
96/13 97/8 98/4
application [11]
89/22 91/18 91/20
91/21 91/23 95/18
95/24 96/2 96/11
96/14 98/20

(42) acknowledging - application
A

applied [1] 95/7
applies [1] 96/3
apply [3] 79/12 95/6
124/25
appointed [7] 4/7
4/25 10/13 14/13 41/9)
60/25 81/15
appointment [10]
3/25 4/8 8/14 8/22 9/1
13/13 13/16 13/20
13/23 69/13
appreciate [3] 54/7
75/3 137/3
appreciation [1]
136/6
approach [6] 3/4 9/9
41/2 42/12 84/8 88/18)
approached [2]
110/2 110/4
appropriate [3] 47/7
50/2 82/10
appropriately [2]
82/20 138/11
approved [1] 101/23
April [1] 52/10
Arbuthnot [1] 3/11
are [132] 1/7 3/21
11/4 12/7 18/18 18/25}
25/6 27/8 28/3 28/19
44/23 45/24 46/6 46/9
47/4 48/17 50/20
52/12 52/19 52/24
53/19 54/18 56/23
62/20 63/24 64/1
67/24 68/2 74/8 74/13,
75/4 75/21 75/25
78/18 79/3 79/13
79/20 80/10 80/24
81/8 83/1 83/10 83/22
84/1 84/25 85/4 85/4
85/12 85/12 85/17
85/24 86/1 87/2 87/11
87/13 88/1 88/10
88/21 89/4 89/11
89/12 89/15 89/15
89/25 92/12 93/2
95/10 98/1 100/25
100/25 102/17 103/23
107/6 107/6 107/10
107/16 108/1 108/2
109/24 111/20 113/10}
115/18 116/9 116/18
116/18 116/19 116/20)
116/21 116/22 117/12)
118/5 119/8 119/20
119/24 119/24 120/2
120/24 120/24 121/7
122/2 124/20 126/16
126/22 127/23 139/11
139/14 139/24 140/8
142/24 142/25 143/17)
143/22 143/22 143/23}

143/23 143/24 144/3
144/4 144/9 145/13
147/4 147/6 147/7
147/8 147/10 147/11
152/6 152/9 152/9
152/16 152/16 153/2
area [3] 84/6 121/21
144/10
areas [4] 122/14
143/13 143/14 144/5
argument [1] 52/21
arise [1] 41/16
arising [1] 125/13
arose [1] 13/11
around [6] 13/14
46/2 80/6 90/22
113/18 116/20
Article [1] 49/8
Articles [4] 90/13
90/19 91/11 96/5
as [270]
ascertain [3] 50/22
78/14 125/22
ascertaining [1]
83/24
ascribing [1] 15/7
ask [17] 2/8 3/15 4/1
8/13 31/3 31/25 39/14
52/8 65/2 66/13 85/14
89/20 109/6 119/12
128/4 128/7 133/2
asked [15] 7/10
33/12 36/13 37/9
74/22 84/15 85/19
104/4 107/17 107/25
115/4 120/10 147/16
154/1 154/3
asking [12] 2/16 8/22
36/25 37/13 37/21
38/2 38/9 57/21 58/11
119/13 153/19 154/7
aspect [2] 75/18
143/25
aspects [8] 36/24
52/12 70/4 73/4 89/15)
102/12 106/15 154/15)
aspersions [1] 74/21
assessing [1] 151/18
assets [1] 107/4
assigned [2] 145/4
145/9
assist [2] 27/8
155/20
associated [1] 67/25
association [6] 90/14
90/19 91/11 96/6
103/25 104/13
assume [2] 21/22
26/23
assurance [1] 89/3
assure [1] 79/9
assured [1] 148/4
at [170]
ATMs [1] 21/22

ATOS [1] 22/1
attached [3] 29/22
68/8 68/19
attempt [2] 152/20
152/20
attempts [3] 103/4
148/18 148/22
attend [1] 25/3
attendance [2] 25/7
59/14
attended [6] 5/21
6/23 17/1 17/18 17/23
41/13
attending [3] 5/20
28/2 132/11
attention [7] 6/19
15/10 19/15 23/3 31/7
35/1 133/9
attitude [6] 41/6
41/10 88/24 89/14
130/11 142/15
attribute [1] 102/4
audible [1] 43/14
audit [4] 112/5
122/16 123/3 123/7
auditor [1] 122/20
audits [4] 106/4
106/7 121/17 121/22
August [6] 4/2 19/19
21/6 22/15 32/5 32/9
August 1995 [1] 4/2
authorised [2] 146/7
146/9
authorities [2] 85/5
152/18
authority [3] 63/12
113/21 154/10
autocratic [1] 9/10
automatically [1]
78/10
avail [1] 148/20
available [6] 80/24
81/3 81/4 81/6 81/8
123/16
avenue [1] 93/25
average [3] 142/9
144/16 144/18
avoid [1] 98/18
avoidance [1] 105/12
await [1] 50/24
aware [25] 14/5
17/15 22/6 31/17
58/20 60/14 68/22
69/21 71/15 71/16
75/11 78/18 88/21
91/21 93/2 108/17
121/1 135/10 138/22
147/3 147/13 147/17
148/10 150/11 152/6
awareness [1] 14/6
away [8] 36/23 37/22
38/4 62/7 63/25
116/23 137/4 153/10

B

back [33] 14/4 15/9
29/13 34/11 34/13
35/4 39/10 46/20
47/17 47/24 69/22
70/20 71/6 76/24
77/10 80/3 85/19
90/18 93/13 114/4
114/17 114/21 120/11
120/15 122/11 129/2
130/17 132/10 140/5
141/4 144/16 145/20
148/16
background [6] 4/2
54/13 86/9 103/22
116/6 125/6
backwards [1] 31/14
bad [1] 89/15
ballistic [2] 59/13
60/16
bang [3] 39/17 112/9
112/9
banking [1] 143/20
bar [1] 112/22
base [1] 15/5
based [3] 36/2 71/23
94/23
basic [1] 145/5
basically [3] 34/2
112/23 117/10
basis [21] 4/24 30/20
65/5 78/8 78/10 78/13)
79/21 87/7 93/15
109/3 113/7 122/3
127/1 138/15 138/18
140/15 145/10 149/15)
151/3 152/2 153/8
Bates [9] 3/11 41/3
41/15 42/5 44/11
58/15 104/21 132/14
137/2
BBC [1] 19/18
BBC1 [1] 21/12
be [227]
Beal [3] 67/14 134/19)
135/11
Beal's [1] 67/15
bear [2] 18/15 24/22
bearing [2] 57/18
57/22
bears [9] 16/11 20/15)
21/8 22/24 24/25 32/6
55/22 56/25 103/13
beautifully [1] 86/16
became [10] 4/11
14/5 20/4 35/17 48/4
90/15 135/6 135/9
136/1 138/22
because [45] 3/2
3/12 10/7 32/1 36/15
36/17 37/18 37/18
38/10 39/13 45/23
48/9 49/25 51/17

53/15 54/5 57/21
57/25 58/9 62/9 63/18}
83/11 90/19 96/23
98/6 104/15 107/13
109/23 114/17 115/1
116/14 121/12 133/11
134/18 139/1 140/7
141/3 141/18 141/25
143/3 144/22 145/17
150/16 152/10 152/15)
become [5] 24/7
65/10 70/21 96/3
136/1
beef [1] 59/18
been [119] 5/16 6/7
7/10 7/11 9/14 11/1
12/2 14/13 15/4 16/5
17/6 18/1 19/9 20/8
23/1 25/12 25/15
25/16 27/9 28/7 28/14
30/24 30/25 32/19
33/7 34/25 36/3 36/4
36/18 38/18 38/19
38/24 39/5 39/6 39/6
40/12 41/24 42/2 44/5)
46/18 47/25 49/15
50/8 51/11 52/17 58/9
60/25 61/3 62/1 62/2
63/4 64/6 64/7 66/1
66/2 68/13 69/1 69/8
70/1 72/14 77/4 79/5
79/7 79/8 83/25 84/24I
85/18 85/21 87/16
88/7 91/23 94/6 95/25
96/21 100/2 100/7
103/9 106/6 107/5
107/12 108/10 108/24}
111/13 111/14 112/8
114/25 117/23 119/7
119/22 120/16 121/5
137/6 137/16 139/6
139/14 140/1 140/12
143/5 145/18 146/23
147/2 148/25 149/3
149/24 150/9 150/12
150/24 151/3 151/4
151/15 152/5 152/8
152/19 152/21 153/9
154/3 154/25 155/9
155/20
before [29] 2/11 2/17
3/25 4/25 17/1 20/19
38/16 48/4 51/7 65/6
66/16 66/20 68/4
69/18 69/20 76/14
86/18 89/20 99/23
99/25 120/17 121/4
125/8 128/14 128/20
131/4 131/15 137/7
137/10
beginning [1] 27/18
behalf [6] 2/17 30/23
32/2 85/8 105/22
128/5

(43) applied - behalf
B

behave [6] 63/6
73/19 92/25 93/1 94/3,
102/17
behaviour [7] 56/21
91/25 92/5 96/23
96/24 130/21 138/10
behaviours [2] 56/3
125/1
behind [9] 3/5 43/13
44/16 73/16 111/23
118/10 119/23 125/6
155/11
being [67] 6/19 8/18
10/14 12/4 16/2 16/3
22/21 23/11 33/7 35/6
38/15 38/15 41/9 48/3
48/19 50/24 56/4 60/8)
60/9 69/5 71/24 72/3
75/7 76/7 76/10 7/11
77/23 79/3 82/21 85/5)
85/10 85/24 88/22
91/21 101/15 101/24
104/10 108/8 111/2
111/22 111/23 111/25)
114/9 115/22 116/21
116/22 117/1 117/7
118/5 124/12 129/8
129/23 132/13 132/18
136/11 136/12 141/13
143/16 144/22 145/19}
146/1 147/10 147/11
147/21 147/23 150/22)
155/10
BEIS [1] 105/21
belief [2] 2/14 107/22
believe [21] 2/18
TIN7 12/6 15/23 26/2
27/3 30/6 34/20 36/22
39/22 73/18 81/19
87/13 87/14 88/12
113/1 113/4 119/23
126/15 127/23 156/3
believed [5] 27/16
36/2 43/6 64/11
131/16
believes [1] 98/9
believing [2] 64/11
131/17
below [1] 93/8
bemused [1] 75/3
benefit [7] 22/24 63/3
66/21 76/20 77/8
103/13 119/17
benefits [1] 143/9
benevolence [1] 55/6
best [6] 2/13 46/10
50/25 51/3 68/22
102/1
bets [1] 51/4
better [4] 44/22 72/4
83/13 84/3
between [16] 13/16

13/20 15/24 35/25
48/18 49/4 54/25
67/22 103/24 104/11
105/9 114/6 115/14
118/11 128/11 130/24)
beyond [5] 25/17
37/1 37/19 142/12
154/18
bias [1] 144/24
big [2] 28/18 30/1
bit [13] 31/25 64/3
72117 73/1 73/22
76/17 92/18 95/16
129/2 129/7 129/10
138/16 141/2
black [1] 39/16
blame [4] 12/7 63/25
64/1 87/19
block [1] 102/9
blog [8] 31/19 44/15
45/12 46/13 71/2
132/19 132/24 136/23)
blogs [1] 31/18
blood [1] 153/6
board [47] 8/3 8/24
9/19 10/10 10/13
10/14 10/18 12/14
12/18 12/23 13/7 13/7)
13/13 13/18 13/20
13/25 35/2 58/25 59/1
59/2 60/4 60/9 60/13
62/18 72/13 74/14
74/15 76/18 77/6
78/17 78/21 90/5
91/18 94/25 96/1
98/20 100/13 101/23
110/23 114/21 115/2
115/4 115/10 128/18
128/22 129/12 142/15)
body [7] 61/5 61/5
108/12 108/13 114/13)
116/2 118/6
Bogerd [1] 134/23
bold [1] 25/24
bolster [1] 71/21
bolstered [1] 75/13
book [3] 61/14 86/14
86/15
Boothman [1] 111/10
boots [1] 142/19
border [1] 109/24
Borders [1] 4/4
both [11] 17/11 32/14
45/3 52/14 79/22
103/10 105/7 108/5
113/15 129/13 133/20
bottom [9] 11/21
12/1 45/14 49/7 67/13
67/16 128/25 129/1
150/3
bought [2] 100/7
109/2
boycotts [1] 56/17
brackets [1] 19/2

branch [42] 4/3 4/7
5/5 5/14 5/15 5/16
5/18 5/18 5/23 5/24
6/2 14/10 14/19 14/24
15/11 15/12 15/24
20/11 20/16 20/22
20/25 21/7 23/5 25/12,
25/25 27/7 35/18
52/11 53/8 77/20 78/8
81/15 89/3 90/22
123/3 131/23 140/25
141/1 141/6 144/10
144/12 144/13
branches [14] 4/15
4/21 5/7 5/10 6/14
16/6 35/25 139/7
140/24 143/13 143/13
144/5 144/23 144/24
brand [2] 44/24
73/18
breach [1] 57/14
breadth [1] 117/3
break [8] 1/11 1/14
40/9 40/21 99/10
99/25 112/10 132/15
BRIAN [4] 1/24 2/2
36/8 157/2
brick [1] 39/18
brief [1] 4/1
briefly [3] 20/17
114/1 119/6
bright [1] 21/13
bring [19] 30/12
42/11 52/20 58/23
59/18 86/4 88/10
91/15 101/4 106/16
106/18 107/10 108/12
108/13 116/13 116/23}
118/7 120/11 150/23
bringing [6] 38/22
38/25 42/9 48/8 117/6
126/23
brings [4] 40/7 99/8
113/7 151/11
broad [2] 56/20 80/7
broken [3] 121/12
152/16 152/19
brought [15] 6/19
7/24 15/10 31/7 41/2
43/4 60/19 100/3
107/13 109/8 118/15
118/19 120/4 133/4
150/22
brush [4] 118/21
BSC [2] 25/25 26/4
BSC 24 [1] 25/25
bug [13] 31/5 31/7
31/13 32/1 33/17
33/21 34/18 35/1 35/4
36/4 36/11 36/14
38/22
bugs [1] 33/8
build [2] 12/19 12/24
bullet [4] 11/23 12/1

59/6 129/16
bullied [1] 146/1
bump [2] 53/13 53/17
bumped [1] 53/16
bundle [2] 68/4 149/2
bundles [1] 71/17
Bureau [1] 129/9
Burns [1] 86/12
business [38] 21/14
28/18 29/17 29/19
29/22 29/23 50/6 54/6)
56/17 59/11 60/21
62/17 62/23 63/3 63/3)
63/10 63/13 70/6
76/18 77/6 77/7 87/3
87/25 107/24 111/13
113/10 113/18 113/18}
115/7 115/19 117/12
118/5 119/21 130/2
130/24 136/6 141/15
143/16

businesses [5] 88/1
113/8 113/9 115/22
116/21

busy [1] 71/3

but [159]

co
cabinet [4] 11/19
12/12 115/8 151/12
cajoled [1] 146/1
calendar [2] 7/18
91/20
call [6] 6/6 32/12
39/15 71/10 78/8 94/1
called [2] 30/12
145/4
calling [1] 79/7
calls [4] 21/19 22/3
38/14 147/10
Calum [9] 1/22 1/24
2/2 32/11 45/22 66/22,
66/23 67/6 157/2
came [29] 2/22 7/8
14/3 15/8 17/3 20/22
21/1 30/3 31/12 41/21
54/1 55/7 57/23 58/11
64/7 80/3 86/15 91/22
91/23 109/21 112/11
115/11 116/5 131/24
135/14 141/22 145/19}
146/10 154/16
Cameron [1] 112/22
campaign [1] 145/16
campaigns [1] 56/11
can [150] 1/3 1/9
1/10 1/11 1/16 1/17
1/18 1/22 2/8 2/20 6/1
6/15 9/12 11/3 11/20
13/2 14/1 15/2 15/16
15/19 16/10 16/24
20/14 20/17 23/21
24/23 25/22 25/22
26/13 26/22 26/23

29/12 30/7 30/9 31/15
32/5 32/8 32/20 33/12I
39/17 40/12 40/23
40/24 43/4 43/15 44/4
45/15 46/10 48/24
49/7 49/20 50/4 50/13
51/24 52/1 54/7 55/21
55/24 56/24 61/5
61/14 62/3 62/6 62/16
62/24 65/5 66/7 66/17
66/20 66/21 67/4
67/16 67/24 68/9
68/15 71/11 71/11
71/14 73/20 74/13
74/18 76/13 78/3 79/2I
79/11 79/11 82/2 82/9
82/19 84/11 86/9
87/10 87/17 87/24
88/1 90/18 91/16 92/4
92/8 93/23 93/25 95/6
95/14 97/21 98/10
99/12 99/20 99/21
101/4 105/5 106/18
106/19 106/23 108/12)
108/13 109/4 111/7
113/17 114/1 114/4
116/3 116/3 117/15
118/6 118/13 119/13
123/5 123/10 128/25
129/2 129/3 130/23
132/4 132/10 133/4
133/12 134/7 135/19
136/14 137/3 137/5
137/9 145/13 148/4
148/22 150/10 152/12!
153/23 154/4 155/13
can't [32] 1/5 1/8
5/12 15/16 17/24
17/25 18/20 25/17
26/14 29/12 30/9
31/15 41/17 41/20
51/10 62/9 65/4 66/16
68/5 101/10 104/7
107/13 108/7 111/23
113/11 131/14 133/4
146/6 149/2 150/11
153/7 153/10
cannot [5] 4/23 26/12)
28/22 64/6 85/2
canvassing [1] 79/17
capable [1] 12/20
capacity [2] 15/11
59/25
care [4] 21/24 29/24
46/5 93/15
cares [1] 50/6
carpet [1] 118/21
carried [1] 115/6
carries [1] 84/17
carry [3] 7/11 123/3
141/17
carrying [1] 139/25
case [38] 31/16
35/17 38/15 39/3 40/2

(44) behave - case
Cc

case... [33] 42/21
45/22 46/17 47/8
47/24 48/13 49/1
49/15 50/17 50/21
50/23 51/2 52/20
53/22 66/4 71/1 79/21
85/6 93/10 96/25
109/3 109/14 110/10
131/20 136/6 136/10
137/6 139/2 140/19
150/21 150/25 152/25
155/11

cases [10] 22/21
28/22 48/3 48/19 85/4
85/25 107/12 108/17
108/23 151/18

cash [11] 12/8 21/24
34/6 34/10 34/13
34/14 34/14 34/16
34/17 34/24 35/24

cast [1] 74/21

catastrophic [1]
131/6

catch [1] 56/20

catch-all [1] 56/20

cause [1] 134/9

caused [10] 15/23
15/24 32/23 36/4
52/18 72/25 93/12
94/12 94/24 97/18

causes [1] 92/13

causing [3] 34/22
87/4 98/13

CBE [1] 115/8

cease [2] 155/2
155/3

CEDR [1] 127/9

cent [3] 10/20 23/21
23/21

central [8] 21/3 77/22)
77/25 78/11 78/11
78/12 102/15 102/24

Centre [3] 34/14
34/16 34/18

CEO [15] 4/1 4/8 4/25
8/14 10/15 13/16
13/23 20/11 22/11
35/6 45/11 48/4 48/7
54/19 69/13

certain [9] 25/6 27/19)
55/7 80/4 85/12 85/13
106/15 106/24 144/4

certainly [20] 7/17
14/1 19/14 31/20 35/7
43/1 47/20 65/4 65/6
70/14 71/21 85/17
85/19 89/8 100/13
104/15 108/6 135/17
155/6 155/8

Certification [1]
104/16

cetera [3] 3/12 7/23

112/3
CFO [1] 41/9
chain [4] 49/4 66/18
66/19 67/11
chair [6] 5/15 5/17
111/9 112/17 126/20
127/22
Chair's [1] 23/3
challenge [11] 12/25
35/5 35/11 39/11
72/24 82/19 124/10
124/12 125/9 125/14
126/3
challenged [1] 10/14
challenging [3] 12/20)
22/17 37/16
champions [3]
116/14 116/23 116/24)
chance [2] 42/1
63/19
change [17] 82/9
86/4 88/24 89/19
90/19 91/3 91/12
100/2 100/6 100/7
105/23 106/6 117/6
120/14 121/5 129/9
142/16
changed [4] 100/12
101/1 103/6 138/10
changes [9] 16/21
65/18 65/23 71/8
76/10 77/2 89/4
100/15 102/2
changing [1] 70/8
channels [1] 20/21
character [1] 70/3
characterisation [1]
65/21
characterise [2]
72/10 111/16
characterised [1]
9/12
charge [4] 123/11
123/15 123/18 135/21
check [1] 1/9
checked [1] 26/17
checklist [1] 123/17
Chief [12] 3/15 3/22
8/18 8/22 9/2 42/19
52/4 77/4 91/22
112/23 115/6 120/13
chips [1] 136/18
Chitty [2] 112/9
112/9
choice [1] 22/7
Christie [1] 148/9
circular [7] 20/11
20/17 20/18 21/6
22/10 25/25 27/8
circulars [1] 20/23
circumspect [1]
138/11
circumstance [1]
57/13

circumstances [4]
3/25 65/19 124/11
136/20
cite [2] 100/14
110/25
civil [7] 28/18 63/1
108/21 114/7 115/15
118/11 138/3
claim [3] 19/7 57/17
108/21
claimants [4] 48/8
134/10 135/8 137/1
claiming [1] 52/24
claims [4] 44/16 48/8
58/23 134/6
clarify [5] 25/3 66/13
94/4 95/6 106/23
class [1] 46/6
classified [1] 141/11
clause [10] 55/24
56/25 57/2 57/12
57/15 57/15 58/24
58/24 73/5 105/6
clause 1 [1] 57/15
clause 17.2 [1] 57/12
clause 5 [2] 57/15
105/6
clause 5.3 [1] 58/24
clause 574 [1] 73/5
clauses [7] 57/17
62/7 62/8 62/20
100/18 101/13 101/15}
clawback [3] 57/10
57/11 58/21
cleaned [1] 147/24
clear [13] 48/12
59/15 60/11 68/10
110/10 135/6 136/1
136/1 136/5 137/25
139/15 143/7 149/11
clearly [3] 15/19
86/24 89/11
clients [1] 44/24
close [1] 143/1
closed [1] 142/25
closing [4] 116/19
141/6 142/4 142/25
coincided [2] 69/15
71/8
coincidence [2] 71/8
71/10
collated [2] 78/12
78/20
collation [1] 78/6
colleague [4] 11/24
32/3 82/17 122/9
colleagues [16] 51/2
52/14 53/6 64/12
64/18 92/13 109/13
115/18 120/2 132/17
136/22 138/23 142/12
143/4 143/10 145/25
collective [2] 11/19
12/12

Collectively [1] 28/21
colossal [1] 110/8
colour [1] 70/8
come [23] 15/7 19/15
32/18 34/4 35/9 35/12
46/20 51/20 53/14
58/10 62/5 66/8 76/14)
77/10 86/12 88/15
90/18 108/6 119/7
119/11 121/3 123/1
135/4
comes [8] 78/10
85/12 88/4 89/16
128/14 131/25 151/6
152/4
comfortably [1] 97/3
coming [10] 11/12
37/11 46/9 53/10
86/14 141/14 142/1
143/17 143/19 150/10
commenced [2]
69/19 69/21
comment [16] 43/12
43/21 44/18 46/2
46/17 46/21 47/8
48/13 49/1 49/5 50/3
50/19 51/23 105/15
105/18 121/20
commentary [1]
46/17
comments [6] 11/4
11/7 11/14 11/17 52/8}
122/5
commission [1]
145/6
commissioned [1]
121/2
commitment [1]
150/2
commits [1] 57/14
committed [2]
149/21 149/23
committee [19] 6/10
6/13 7/5 7/13 14/14
18/4 18/7 86/8 88/7
88/9 93/4 113/23
116/7 117/5 117/10
118/17 119/2 120/4
121/9
common [21] 41/14
65/14 65/17 66/1
69/15 70/22 71/9
72/11 72/13 74/5
74/10 74/15 78/22
101/14 101/20 104/22)
104/24 114/3 115/12
116/4 133/1
communicate [1]
117/17
communicated [2]
31/14 77/23
communication [4]
9/23 31/9 45/18
148/24

Communications [3]
59/5 59/25 69/6
communities [2]
116/21 117/3
community [9] 33/25
34/1 34/3 76/1 87/12
116/16 116/23 142/22)
144/1
companies [1] 26/18
company [4] 8/11
59/17 90/16 104/14
comparison [1]
150/13
compelled [1] 12/13
compensation [3]
142/7 153/3 153/7
competitor [1]
129/14
complaints [5] 79/14
80/16 81/1 145/22
147/23
complete [2] 107/15
125/7
completed [2] 95/23
153/5
completely [2] 9/25
111/19
complex [1] 85/4
compliance [1]
125/24
complied [1] 66/25
comply [1] 101/20
composition [3]
116/7 126/12 126/15
comprising [1]
118/23
computer [7] 18/25
19/3 23/20 32/23
84/22 111/19 112/11
concern [12] 24/2
38/20 38/24 49/25
61/1 98/13 100/11
117/7 119/3 122/14
126/11 129/21
concerned [27] 17/5
20/4 27/22 47/4 48/17
52/19 52/25 53/22
55/15 58/8 65/15
67/12 71/23 84/2 86/1
89/25 98/1 98/3
100/25 102/23 106/8
109/18 110/17 126/16)
130/1 142/3 145/17
concerning [1] 9/1
concerns [26] 14/5
14/17 14/25 16/7
22/11 29/10 29/10
31/13 72/6 72/8 77/16)
79/2 81/12 85/21
103/5 108/14 109/13
110/10 111/20 112/6
117/18 117/18 123/7
139/1 147/23 154/16
concession [1]

(45) case... - concession
Cc

concession... [1]
142/18
conclude [3] 22/7
36/21 39/3
concluded [1] 39/24
concludes [1] 155/16)
conclusion [4] 84/19
107/11 107/13 108/14}
conditions [4] 55/25
56/4 56/23 105/6
conduct [7] 24/12
58/12 81/17 98/5
106/7 110/11 121/21
conducted [2] 36/8
109/15
conference [19] 5/20
5/21 6/15 6/17 6/23
6/23 7/14 7/25 16/10
16/15 16/18 17/2 17/9}
17/19 17/23 18/3
18/18 18/23 86/13
confidence [12] 12/3
47/5 47/6 47/16 52/14
53/1 53/3 53/7 84/4
107/15 119/15 119/19
confidential [1]
147/25
confirm [6] 4/23 25/6
67/24 68/2 128/22
145/13
confirmed [1] 149/20
conflict [2] 113/7
129/10
congratulated [1]
106/11
connected [1] 141/3
connection [1] 1/12
connections [1]
109/24
connectivity [1] 22/1
consequence [2]
125/9 155/2
consider [4] 22/16
39/10 55/10 92/22
considerable [2]
92/14 94/12
consideration [3]
16/9 16/14 101/24
considerations [1]
140/16
considered [6] 9/8
23/6 38/16 98/5
135/25 140/10
consist [1] 126/19
consistency [1]
81/20
consistent [1] 4/22
Constance [1]
151/13
constitute [1] 146/10
constituting [1]
146/13

consumed [1] 91/7
consumer [2] 116/14
116/24
consumers [2] 117/1
118/2
contact [8] 6/3 14/18
14/21 31/25 33/12
33/13 38/11 148/23
contacted [5] 24/3
31/20 31/22 39/4
138/23
contain [1] 16/13
contained [1] 124/7
contains [2] 43/24
51/25
content [4] 2/13 94/8
94/23 138/21
context [3] 11/21
66/10 88/23
continent [2] 114/3
116/5
continue [3] 21/17
75/25 155/19
continued [4] 39/22
83/9 83/9 129/18
continues [1] 63/20
continuing [1] 138/7
contract [8] 21/20
39/5 82/24 90/1 122/1
124/15 124/24 125/24)
contracts [5] 36/10
38/16 80/5 80/6 83/2
contractual [3] 44/19
82/12 88/19
contrast [1] 149/8
contribute [1] 46/16
contributed [1]
118/23
contributing [1]
119/4
control [1] 127/7
controlling [1] 130/7
convenient [1] 40/9
conversant [1] 125/3
conversation [7]
11/15 70/1 97/14
107/23 112/14 112/19)
129/7
conversed [1] 47/4
convert [2] 141/17
146/12
converting [1] 146/2
convey [1] 58/14
conveyed [1] 22/10
convicted [8] 23/11
61/3 128/6 150/13
152/5 153/22 154/9
154/25
convicting [2] 27/20
29/2
conviction [2] 148/12!
154/17
convictions [2] 128/6I
152/8

copied [1] 67/14
copy [5] 2/3 32/4
68/14 123/13 133/13
core [12] 33/22 33/23
34/7 34/11 34/23
35/25 124/9 127/23
127/25 145/4 148/10
149/2
corner [1] 53/15
correct [65] 2/6 2/19
3/23 4/9 4/16 5/2 6/11
7/15 8/5 8/17 9/6 9/10
10/16 10/19 10/24
11/5 12/21 13/14 14/8
15/2 17/16 22/12
22/18 24/20 27/14
29/11 35/19 36/12
40/14 41/7 41/8 41/16
44/6 54/16 55/4 74/16
75/12 75/14 78/25
79/18 80/17 80/18
81/17 81/18 90/3 90/4
94/23 95/19 100/12
100/21 102/6 102/11
103/11 106/8 108/24
111/4 113/24 118/25
120/7 122/3 122/17
124/4 124/15 126/13
127/16
correlation [1] 155/9
correspondence [3]
39/7 39/17 149/9
corridor [1] 132/14
cost [2] 59/20 111/22
costing [1] 49/19
could [64] 10/19 12/5
17/7 18/14 18/21 21/9
23/13 23/18 23/24
25/23 34/3 34/19
34/19 36/14 37/17
39/10 39/21 42/11
43/1 43/10 45/6 45/8
45/19 47/9 47/17 48/9
48/13 49/1 49/2 49/3
49/6 58/8 59/3 59/19
66/25 67/2 67/5 67/12
67/15 70/16 70/16
70/18 71/18 73/19
74/6 76/15 82/14
83/12 90/17 91/15
95/15 102/21 103/14
114/12 124/6 125/19
127/20 128/24 133/3
136/12 142/18 145/21
149/24 152/10
couldn't [9] 19/24
36/17 37/9 37/18 58/4
67/1 73/17 75/5 137/1
council [10] 6/21
7IN7 12/11 16/19
16/20 18/5 18/24
19/11 25/1 96/6
counsel [2] 2/21
132/8

counter [2] 3/5 73/16
counterparts [1]
149/9
country [7] 80/6 88/3
116/20 117/3 150/14
152/18 154/10
couple [2] 61/20
82/18
courage [1] 3/13
course [8] 67/4 67/8
71/15 75/19 97/7 99/7,
132/21 137/21
court [19] 42/18
44/12 44/13 45/22
45/25 46/8 46/15
46/18 48/8 48/13
49/15 52/20 59/18
109/11 134/11 135/11
136/24 138/23 155/11
court's [1] 46/15
courts [1] 42/23
cover [3] 21/21 29/5
57/25
cover-up [1] 29/5
covered [6] 4/22
44/14 45/9 73/6 80/15
81/21
covering [3] 44/11
58/2 136/23
Cox [2] 44/4 45/16
create [1] 105/8
creating [1] 34/22
creation [1] 113/4
credits [1] 50/21
criminal [5] 48/20
57/24 108/18 109/7
138/4
criminals [1] 65/13
criteria [3] 144/6
144/8 144/9
critical [2] 49/21
73/24
criticise [4] 44/20
46/8 72/24 76/4
criticism [4] 65/10
65/16 65/21 66/12
criticisms [2] 71/24
138/11
cross [2] 80/8 134/22
cross-examination
[1] 134/22
cross-section [1]
80/8
Crown [1] 149/20
crystal [1] 59/15
culminates [1] 78/20
cultural [2] 86/4
89/19
culturally [2] 86/23
103/5
culture [28] 61/7
61/9 61/10 61/18
61/19 62/13 62/15
62/23 63/18 64/15

86/6 86/8 87/18 87/23
88/7 88/12 88/13
88/15 88/24 93/4 98/1
98/3 100/11 106/6
117/6 130/7 130/11
146/19

cure [1] 153/7
current [5] 4/24
63/20 84/8 120/7
121/15

currently [3] 1/5 3/21
4/15

cut [1] 134/10

CWU [2] 32/14
116/11

cynical [2] 47/23
48/1

D

daily [2] 132/18
136/24
Dalmellington [10]
31/5 32/1 32/17 33/16I
33/21 34/18 34/21
36/4 36/14 38/22
damage [1] 131/6
damaging [1] 129/13
Daniels [3] 32/12
32/13 32/14
dare [1] 154/18
Darren [2] 86/12
86/13
data [10] 17/10 20/6
37/20 78/16 138/9
138/14 138/18 139/17)
140/3 147/21
date [6] 14/6 67/4
68/11 68/23 138/20
155/18
dated [12] 2/4 21/6
44/8 49/9 52/10 55/23
67/11 95/21 95/24
103/19 104/1 104/3
dates [2] 42/18 67/8
daughters [1] 29/25
David [1] 129/6
day [15] 27/4 27/9
30/7 30/11 30/13
30/18 37/12 41/14
45/21 111/18 132/11
136/25 137/2 151/23
156/7
days [3] 61/20 82/18
92/15
DBT [1] 145/13
de [1] 129/9
deal [8] 55/9 77/11
78/7 82/13 91/9 91/10}
96/18 143/6
dealing [8] 6/14
31/16 31/21 32/2 71/3}
82/6 98/22 122/8
dealt [6] 36/18 73/9
85/5 123/19 134/19

(46) concession... - dealt
D

dealt... [4] 147/11
Dear [2] 67/21 95/22
debate [1] 11/15
debated [4] 6/23 6/24)
17/22 18/2

debt [1] 107/8
December [3] 39/5
67/11 68/17
December 2016 [1]
67/11

decent [1] 87/11
decided [7] 22/11
51/3 68/6 70/20 71/6
93/18 94/25
decision [40] 6/25
7/16 8/13 10/10 29/15)
29/16 29/19 44/21
47/23 54/10 58/17
64/22 70/25 83/24
89/21 90/11 93/20
95/25 96/2 96/15
98/18 110/8 115/11
115/20 115/20 115/20}
121/24 124/3 124/6
124/14 124/22 125/7
125/8 125/13 125/23
126/9 126/24 127/12
141/16 142/16
decisions [6] 30/1
97/4 116/18 116/25
117/1 121/18
declarations [1] 12/8
decline [2] 96/1 96/7
declined [2] 95/12
115/23

dedicated [1] 82/25
deed [6] 68/21 104/2
104/4 104/5 104/8
105/4

defect [1] 31/4
defence [1] 108/18
defences [1] 28/23
defend [4] 46/4 61/15}
74/23 114/22
defined [2] 57/11
126/16

definite [2] 26/12
26/14

definitely [1] 149/24
delay [2] 1/21 102/5
delegate [1] 122/12
delegates [2] 27/2
27/12

deliberate [1] 106/19
deliberated [1] 93/18
delighted [1] 110/1
demand [2] 17/9
107/8

demanded [1] 30/4
democratic [1] 88/5
demonstrate [1]
41/10

demonstrated [2]
63/9 99/4
demonstrates [1]
65/7
demonstrations [1]
56/14

den [1] 134/23
density [1] 144/11
department [4] 73/19
107/24 111/24 118/24}
depending [1]

142/10

deploying [1] 124/21
depth [1] 107/18
describe [10] 6/1 9/8
54/22 78/3 79/2 81/24
82/2 92/4 100/22
120/9

described [6] 33/18
41/17 84/7 94/20
132/10 146/4
description [3] 53/13
74/18 79/13

deserve [1] 151/7
designed [1] 55/2
desire [2] 120/13
149/12

despite [3] 97/20
131/22 137/2

detail [1] 40/11
detailed [3] 46/1
96/11 155/23

details [1] 149/3
determination [2]
3/13 126/18
determine [3] 42/23
107/1 125/11
determined [2] 42/21
47/25

determines [1]

150/21

determining [1] 18/1
detriment [3] 143/9
146/3 146/19
detrimental [4] 50/10
56/22 116/19 117/2
developed [1] 111/22
Development [1]
67/17

did [70] 4/6 5/13 5/19
12/13 12/23 13/16
13/24 14/1 17/21
19/15 22/9 24/7 25/3
26/6 26/9 26/10 27/15
28/1 28/1 33/13 33/15)
34/12 34/25 35/3 35/4
35/11 36/16 36/21
37/8 37/10 37/12 38/5)
38/6 39/3 41/5 41/16
42/25 43/8 46/23
46/25 48/7 48/14 50/3
60/16 64/24 69/17
70/25 73/20 83/6 83/6
85/7 87/17 96/12

101/12 106/1 109/12
123/8 127/1 130/20
132/25 135/5 136/1
136/3 137/10 137/12
142/1 143/11 143/12
146/9 148/23

didn't [39] 9/15 9/22
13/8 15/17 23/20
27/22 29/4 38/19
39/21 42/1 43/10 47/6
47/8 47/9 47/17 48/9
48/11 48/13 48/15
48/25 49/1 49/2 51/18
51/18 51/18 57/25
58/4 58/9 65/3 75/5
95/6 96/16 96/21
97/23 110/16 136/10
136/11 154/22 154/22
difference [1] 48/18
different [25] 5/1
9/25 10/6 11/13 13/6
13/12 23/24 24/1
41/11 54/2 70/2 70/3
70/3 70/12 80/5 86/22
86/22 97/21 109/25
111/19 117/25 137/8
140/20 150/6 150/16
differently [1] 27/21
difficult [18] 13/1
23/5 29/19 32/24
39/13 55/9 63/11
72/20 75/8 75/9 76/2
76/21 77/1 97/4
100/23 131/4 141/16
149/6

iculties [1] 147/7
nity [1] 3/12
dipped [1] 132/24
direct [2] 117/16
129/13

directed [1] 109/22
directly [2] 45/24
54/15

director [10] 8/4
13/21 24/4 24/7 45/18
59/25 69/6 113/5
113/10 115/3
directors [6] 61/21
89/10 106/22 113/8
113/16 127/12
disagree [4] 53/23
93/24 98/11 108/9
disagreement [1]
106/17

disappeared [1]
41/24

disciplinary [1] 49/16
close [1] 33/9
disclosed [1] 16/5
disclosure [4] 85/10
88/20 88/22 140/12
discourse [1] 97/14
discovered [4] 3/8
38/15 40/3 70/21

discrepancies [4]
18/25 19/4 19/13 28/8}
discrepancy [6]
35/21 36/3 37/10
37/17 38/8 82/22
discretion [3] 57/6
90/6 96/7

discuss [3] 40/8
70/25 105/15
discussed [5] 7/22
72/3 106/19 127/13
143/12

discussing [3] 26/13
49/5 99/25
discussion [8] 25/23
46/2 59/4 60/8 60/15
70/22 135/5 137/21
discussions [4] 13/4
67/22 71/23 120/25
disingenuous [1]
95/9

disinterested [1]
134/16

dismissive [1] 41/6
display [4] 11/20
isplayed [1] 93/11
displaying [1] 111/16
disposed [1] 52/23
disproportionate [2]
143/23 150/14
disputes [2] 81/13
84/9

disrespectful [1]
120/18

distinction [1]

104/10

distraction [1] 76/17
distress [5] 93/12
94/12 94/24 97/19
98/13

distribute [2] 6/4
20/24

diversity [1] 81/2
divided [1] 4/15

do [127] 2/5 2/11
2/12 2/17 3/6 5/7 5/10
6/22 11/3 11/7 12/6
15/14 18/15 23/2 26/5)
26/20 27/11 28/1
29/14 30/15 30/22
31/12 33/13 33/16
38/2 39/10 39/21
43/20 45/6 46/10
46/16 47/5 47/11
48/15 50/25 51/16
53/7 53/18 53/22 54/7
55/13 55/16 55/20
57/25 58/5 58/16 60/4I
60/18 60/22 61/6
62/10 64/18 64/24
65/20 68/3 68/20
71/10 73/1 73/8 77/6
77/7 77/11 77/12
77/12 78/9 79/11 83/9

83/18 83/21 84/2 84/2
86/17 86/22 87/14
90/21 91/4 91/6 93/5
93/21 93/23 97/21
98/10 98/17 101/8
106/1 106/12 106/13
107/14 107/21 110/16)
111/16 111/25 111/25)
112/19 113/19 114/5
116/13 117/21 119/13}
119/23 120/20 120/21
121/10 124/1 136/16
138/25 139/3 139/15
140/4 140/5 140/6
140/7 141/20 143/10
145/7 146/14 146/17
147/20 150/10 151/5
152/15 152/19 153/17)
153/23 154/4 154/4
155/13
document [16] 16/12
18/21 19/15 20/14
23/1 32/5 43/24 51/25
56/24 68/9 103/13
125/8 125/9 126/16
128/13 128/15
documentary [2]
21/12 39/12
documentation [1]
74/23
documented [1]
35/10
documents [4] 16/5
16/11 19/16 128/8
does [26] 4/18 4/20
14/23 15/9 17/22
19/13 20/3 26/5 26/5
30/5 30/19 74/24
85/13 88/23 97/8
104/5 119/2 129/25
133/22 134/4 134/5
134/10 134/17 134/17
138/24 147/9
doesn't [15] 10/6
39/19 45/23 60/11
61/16 61/16 87/5
93/22 95/10 97/7
98/25 129/24 131/25
139/5 150/24
doing [15] 61/13 63/4
67/7 70/9 70/9 85/9
86/11 90/7 96/17
120/1 120/23 122/2
122/10 143/24 145/21
doing’ [1] 96/9
don't [87] 4/23 11/10
11/16 14/1 14/2 17/24)
18/17 22/25 23/20
26/22 28/10 29/8 31/1
32/25 35/3 35/8 39/15
39/16 41/25 46/1 50/9I
51/2 52/6 53/19 54/14I
57/20 57/22 60/1
60/15 61/8 61/8 61/19

(47) deait... - don't
D

don't... [55] 62/8 63/6
63/21 64/24 65/1
69/20 72/5 79/25
82/23 83/20 85/14
85/15 88/2 88/12 92/8
92/21 92/24 94/2
96/19 96/20 97/6 97/9
97/11 98/14 99/13
104/9 108/9 109/2
113/4 113/13 114/18
119/11 119/25 119/25
120/1 120/16 126/15
127/4 127/6 131/7
135/9 135/16 136/3
136/19 137/12 151/21
152/7 152/8 152/15
152/24 154/12 154/13}
154/14 155/7 155/12
Donald [2] 24/9
25/13
done [37] 3/2 29/14
30/24 30/25 39/11
42/3 46/21 62/3 73/13
79/21 79/24 80/1
80/11 80/21 82/21
91/13 99/4 108/8
109/1 109/16 109/17
109/17 114/9 114/25
118/5 118/9 118/10
143/20 145/10 146/15}
148/5 149/24 150/11
151/19 152/14 153/11
155/9
double [1] 34/20
doubt [1] 105/12
down [45] 11/25 12/5
1TIT 21/9 25/24 32/8
42/15 43/4 44/3 45/10
46/9 49/7 72/14 74/25)
84/13 86/14 88/7
89/16 90/15 91/1
95/15 95/16 96/20
97/21 98/20 103/17
106/9 109/23 114/10
114/10 114/10 114/14}
115/4 118/13 118/13
121/13 134/7 134/7
137/11 142/8 144/17
149/6 150/6 150/16
151/4
downplaying [2] 74/3}
74/8

DPD [1] 143/19
draft [1] 95/17
drafted [1] 80/23
drafts [1] 121/20
draw [3] 23/3 35/1
108/15

drawn [1] 104/10
dry [1] 44/22
dual [4] 32/14
due [6] 27/3 30/7

42/22 47/11 51/17
52/14

during [13] 14/23
52/15 65/17 66/2 69/3
80/14 132/5 132/14
135/6 136/2 137/18
137/21 140/10
dusted [1] 46/21
duty [6] 20/23 93/15
97/6 102/10 102/13
120/21

E

each [2] 68/9 145/6
earlier [8] 85/6 106/5
107/3 118/9 127/13
140/5 148/17 151/13
early [9] 26/7 26/11
27/4 30/7 30/10 30/13
30/18 50/22 69/1
easier [1] 53/21
easiest [1] 96/18
easily [1] 97/2
easy [6] 37/1 38/13
53/21 82/7 82/7 87/19)
EC [2] 16/18 17/9
Eccles [7] 45/16
45/20 46/24 59/23
69/8 70/19 71/23
Eccles' [1] 45/16
effect [2] 13/14 56/21
effectively [1] 124/13
effort [1] 153/25
efforts [2] 86/3 89/4
either [10] 7/13 12/23
15/11 16/22 38/14
108/18 134/16 153/15)
154/13 154/14
elaborate [1] 148/22
elected [5] 5/4 5/23
6/9 8/3 14/13
else [3] 25/7 108/5
127/11
elsewhere [1] 28/17
email [29] 22/15
22/24 32/4 32/9 33/5
33/12 43/24 44/4 44/5)
44/8 45/15 49/4 49/7
51/7 51/9 51/10 51/25)
52/9 52/22 66/18
66/18 66/22 67/1 67/9)
67/14 67/20 68/15
72/12 95/23
emailed [4] 112/12
emails [3] 14/2 29/13
38/14
Emergency [1] 59/13
emotionally [1]
152/16
empathy [1] 113/15
employed [1] 3/21
employee [6] 25/11
51/25 92/18 94/11
120/19 120/22

employees [14]
73/15 78/13 92/2 92/6
92/14 93/12 93/17
94/16 94/25 97/18
99/6 116/11 118/2
126/20

employment [2]
21/20 83/7

enable [5] 7/24 55/1
77/25 106/16 123/20

enables [1] 108/5

encountered [1]
111/3

encourage [4] 86/20
86/21 89/17 92/25

encouraged [1]
31/25

encouragement [1]
92/16

end [7] 40/7 41/23
41/23 55/12 60/19
99/8 151/23

endeavours [2]
105/7 105/10

ended [3] 53/16 54/2
154/7

endorse [1] 134/5

endure [1] 3/17

enforcement [4]
138/2 138/12 138/15
138/19

engage [6] 10/3
30/22 38/20 56/2
63/14 89/14

engaged [1] 110/2

engaging [1] 83/10

enjoy [1] 86/21

enough [4] 97/12
97/12 99/2 152/15

enquiries [2] 1/7
126/8

ensure [11] 53/3 61/1
68/9 84/16 85/9
114/22 114/23 118/4
125/13 125/16 144/4

entail [1] 5/14

entered [1] 68/11

entering [4] 34/20
34/20 103/24 127/5

entirely [2] 45/23
134/16

entrants [1] 33/3

entries [1] 34/22

entry [1] 19/12

envisage [1] 117/5

equality [1] 81/2

equipment [1] 142/3

error [2] 19/6 84/22

escalate [1] 29/10

escape [1] 64/6

essence [28] 5/15
6/3 6/17 7/7 7/12 7/23
13/2 23/8 23/14 29/19}
53/20 64/5 69/25 70/2

70/6 73/1 73/15 75/2
76/4 76/15 77/3 83/23,
89/6 117/1 117/19
126/23 127/11 145/5
essentially [3] 40/12
69/16 117/16
establish [3] 1/11
87/9 126/4
established [4] 8/10
82/3 86/10 88/7
establishment [2]
86/8 113/23
et [3] 3/12 7/23 112/3
et cetera [3] 3/12
7/23 112/3
etc [1] 49/14
even [12] 3/7 9/18
10/22 28/14 28/14
28/19 48/20 60/1
98/12 105/20 129/22
154/3
event [3] 57/10 57/11
57/13
events [2] 136/24
150/3
eventually [3] 24/7
39/4 54/1
ever [10] 13/17 13/24
14/25 38/21 39/6
97/15 120/16 134/24
137/10 140/3
every [4] 21/24 21/25
61/13 119/11
everybody [1] 64/17
everybody's [1]
66/21
everyone [4] 1/21
87/16 135/5 135/17
everything [13] 13/1
61/14 62/3 71/14
71/16 82/21 113/17
113/20 114/9 115/3
145/21 152/23 152/23}
evidence [57] 14/16
19/6 20/7 20/8 26/7
27/21 27/25 28/10
29/4 29/13 35/7 36/24,
36/25 37/4 37/5 37/7
37/11 37/17 37/22
37/23 38/1 38/7 38/9
39/12 41/13 45/1
48/23 51/19 51/20
54/12 57/17 57/19
58/16 63/24 65/7
68/22 71/17 73/11
74/22 80/14 85/6
85/23 88/17 95/3
96/10 100/10 101/1
106/5 106/16 117/12
131/9 133/21 137/6
137/18 137/24 150/19}
155/24
evidences [1] 106/18
Evri [1] 143/19

exact [1] 101/9
exactly [26] 9/15
17/6 28/15 28/16
30/23 34/12 41/18
47/13 51/20 61/22
63/4 66/11 69/4 71/15}
72/21 73/2 73/10
73/13 78/18 80/8
82/21 86/17 111/24
135/14 145/23 153/25)
examination [1]
134/22
examine [6] 3/25
14/4 41/1 77/14 81/11
86/3
examined [1] 85/6
example [9] 6/25
92/15 100/14 110/25
133/24 133/25 134/19}
143/19 145/2
excellent [1] 47/1
exclusive [2] 10/1
86/19
executioner [2]
106/14 106/25
executive [31] 3/15
3/22 6/21 7/17 8/4
8/19 8/23 9/2 13/21
16/19 16/20 18/5
18/23 19/11 24/4 24/7)
24/9 25/13 42/19
61/21 77/4 89/9 91/22I
100/13 106/22 112/21
113/5 113/16 115/7
127/12 131/24
exhibition [3] 129/4
129/9 129/15
exist [1] 60/23
existed [1] 130/22
existence [4] 31/7
35/1 35/4 36/11
existing [1] 122/15
exists [2] 19/6 60/21
exit [2] 29/19 142/7
exonerate [2] 152/13
152/22
exonerated [3]
108/24 109/10 153/3
exonerating [1]
151/6
exoneration [4]
109/7 148/16 151/16
153/18
expand [1] 111/7
expect [1] 28/25
expected [3] 128/15
138/9 154/23
experience [5] 15/20
15/22 82/5 82/16
150/1
experienced [6] 3/17
35/21 42/25 75/4 89/6I
89/10
experiences [1] 10/5

(48) don't... - experiences
E

experiencing [6]

54/5 63/17 107/7
107/16 108/2 147/8
explain [19] 6/16
9/12 20/17 22/9 30/19)
37/13 52/2 54/4 67/15)
70/19 74/6 86/9 98/4
98/24 102/22 104/7
114/1 114/19 123/10
explained [17] 4/14
14/16 26/16 35/16
44/25 58/13 65/9 71/5
78/21 81/14 86/16
89/25 108/16 120/3
134/15 136/8 141/15
explaining [2] 96/13
107/6

explanation [5] 36/19
66/8 74/2 91/16
125/20

explore [1] 54/9
explored [1] 46/15
exposure [1] 73/13
express [2] 42/4 59/7)
expressed [5] 74/4
100/11 135/24 147/12
147/23

expressing [1]
136/25

expressly [2] 45/10
135/23

extend [1] 4/18
extensively [1] 44/1
extent [3] 100/2
100/7 111/2

exterior [1] 21/13
external [4] 49/4
83/14 84/3 124/20
externally [1] 108/9
extreme [1] 98/12

F

faced [1] 73/16

fact [23] 25/15 33/13
37/6 38/19 38/21
57/23 61/25 63/8 65/7
71/22 73/3 97/6 101/1
102/18 111/18 117/9
120/18 131/22 133/21
147/5 150/9 150/18
154/25

facts [2] 125/10
126/4

factual [1] 134/5
factually [1] 85/3
failings [2] 21/16
22/5

failure [3] 39/12
110/25 140/12
failures [1] 17/11

fair [23] 8/1 18/6
33/10 45/3 47/25 51/4

53/1 53/2 64/2 65/20
66/4 74/5 74/11 75/17
79/14 88/16 97/12
97/12 97/13 99/2
100/23 126/1 127/4
fairness [2] 125/1
125/17

faith [11] 28/24 47/5
47/5 64/9 102/10
102/14 102/24 103/7
127/5 131/17 131/18
faith' [1] 103/1

fall [1] 92/22

falls [1] 28/8

false [2] 12/8 138/4
falsifying [1] 32/21
familiar [2] 54/18
133/12

families [1] 153/9
family [1] 143/13

far [42] 13/25 15/5
15/7 17/4 27/21 27/25)
28/6 29/16 47/4 47/14
47/14 48/17 53/21
55/15 58/7 64/3 68/22
82/7 84/1 85/17 88/21
89/5 89/24 90/23 99/4
100/25 102/23 106/7
106/20 110/17 120/25)
122/10 130/1 137/4
137/4 138/25 142/3
143/15 145/16 147/24)
149/4 151/14

fault [1] 26/8

faults [3] 10/24 15/22
52/17

faulty [2] 12/6 34/19
fearful [1] 60/5
February [3] 45/1
95/24 141/21
February 2015 [1]
45/1

February 2023 [1]
141/21

Fed [1] 46/5
Federation [12] 3/22
13/5 21/4 43/25 60/20
70/4 104/1 130/9
1314/2 134/2 154/25
155/4

feel [11] 12/13 23/20
52/12 84/2 90/19 91/9
92/10 106/13 116/2
119/21 126/24

feeling [4] 9/21 28/12
72/23 76/5

feelings [1] 76/8

fees [1] 49/20

fell [1] 136/18

fellow [3] 10/3 64/12
143/9

felt [32] 9/18 9/24
13/6 23/17 23/22 39/8
47/10 51/22 58/13

63/11 70/2 70/10 71/5
73/8 74/9 74/24 75/2
76/17 82/5 82/9 93/10)
95/8 96/17 99/7
102/16 114/6 115/14
126/21 136/9 141/18
141/19 146/1
few [4] 21/18 129/20
135/3 148/13
field [1] 30/11
Fifthly [2] 56/18
125/13
fill [2] 78/9 79/11
filter [1] 8/1
final [4] 12/1 121/15
124/22 151/11
finally [5] 27/1 50/8
56/20 105/21 125/16
financial [10] 64/1
64/19 65/6 112/23
141/20 143/8 146/3
146/9 146/10 146/13
find [6] 17/3 17/6
29/12 40/13 51/10
51/11
findings [1] 125/10
fine [7] 40/18 87/11
99/15 152/23 155/14
155/14 156/4
finger [1] 87/19
finish [1] 59/21
finished [1] 141/10
firmly [1] 46/9
firmware [2] 16/22
17/11
first [37] 5/21 6/5
10/12 11/23 12/18
14/5 14/6 14/18 14/21
17/2 17/19 19/15 32/8
41/14 45/14 45/20
57/12 66/13 66/14
68/24 74/25 77/14
85/14 87/20 103/18
120/12 122/22 128/10
128/21 132/11 133/19}
135/9 136/24 138/22
148/11 148/14 148/23
firstly [5] 56/6 65/25
90/1 105/14 124/25
Fiscal [2] 150/18
150/20
fit [2] 44/17 74/20
five [3] 40/4 102/1
106/1
fix [1] 117/4
flat [1] 145/5
flattened [1] 53/15
floor [1] 53/17
focus [8] 30/2 43/2
63/25 65/10 73/10
75/6 75/16 88/8
focused [1] 75/6
focusing [2] 44/19
73/3

Follenfont [1] 49/8
follow [5] 14/23
17/22 20/3 38/6
123/18
followed [1] 62/21
following [11] 49/15
56/2 57/12 71/2
104/21 111/18 124/2
132/17 132/22 133/18
156/7
follows [2] 16/17
44/9
footfall [1] 144/11
force [4] 54/19 58/10
58/11 110/11
forced [1] 146/1
forefront [1] 131/3
foremost [1] 87/20
forgive [3] 8/20 76/16
122/2
forgiveness [1] 3/16
form [16] 7/23 10/2
48/15 50/9 51/16
55/10 55/18 78/9
79/11 79/11 86/25
95/24 127/14 130/19
142/17 143/7
formal [3] 80/15
81/16 127/14
format [1] 148/24
former [4] 92/1 136/7
153/21 154/9
forthcoming [1]
24/17
forum [2] 49/12
119/9
forward [17] 9/17
10/8 10/9 13/12 60/10)
61/15 62/24 77/8
77/13 85/15 86/24
87/25 88/5 89/18
90/20 117/22 141/14
forwarded [1] 45/15
forwards [1] 31/14
found [6] 11/3 17/4
26/18 55/24 63/15
84/12
four [2] 91/8 108/17
Fourthly [3] 56/16
105/19 125/7
foyer [1] 41/22
framework [21]
54/10 54/13 54/22
54/24 55/12 55/16
58/8 65/15 65/19
65/25 66/14 68/23
100/15 101/18 103/4
103/9 103/24 104/23
104/25 105/3 109/4
frank [1] 130/23
Fraser [17] 2/24 3/1
47/11 48/12 62/20
62/22 63/8 65/14
65/23 66/6 72/10 73/2

73/10 74/5 76/5
101/14 102/13
Fraser's [1] 106/1
fraud [1] 138/4

free [1] 55/3

Freeths [3] 52/19
53/21 59/9
Freeths/Justice [1]
59/9

freezing [2] 15/4
15/21

frequently [1] 79/20
freshen [1] 70/6
Friday [1] 112/15
front [2] 2/3 72/25
frustration [5] 63/16
63/17 74/3 74/9 93/6
FSL [1] 137/25
Fujitsu [8] 28/19 37/3
107/20 137/23 137/25]
138/13 138/21 147/2
Fujitsu's [1] 140/15
full [9] 2/1 33/23 57/4
73/12 84/18 85/9
107/17 140/6 146/14
fully [8] 12/3 16/22
24/13 46/15 72/21
73/2 94/5 125/3
fun [1] 92/19
function [1] 7/5
functioning [1] 15/19
fund [4] 60/22
fundamental [4]
48/18 64/16 114/8
150/25
fundamentally [4]
22/8 64/25 87/13
121/12
funded [3] 49/21 50/1
58/3
funding [9] 54/25
56/5 56/18 58/22 60/6
60/19 127/17 144/3
144/23
funds [2] 30/21 84/24I
further [11] 12/23
29/9 35/7 39/7 51/6
67/22 95/16 99/6
99/24 126/8 127/19
future [5] 29/20
49/19 59/19 87/3
119/21

FYI [1] 46/20

G

GA [1] 68/9

gap [1] 80/19
garden [1] 152/24
gather [1] 125/5
gave [9] 35/7 74/15
74/22 76/9 83/8
111/19 134/24 137/7
150/3

general [10] 7/20

(49) experiencing - general
G

55/25 74/20 92/9
105/6

generality [1] 92/9
generated [4] 18/25
19/4 19/13 20/6
gentleman [1] 50/5
George [11] 9/15
10/11 20/11 44/25

67/21 68/16 68/18
George's [5] 60/10
60/13 60/14 60/17
64/25

get [38] 10/3 13/9

23/14 36/23 37/18
39/16 40/1 42/1 43/1
44/16 47/10 63/19
63/22 65/3 65/3 79/11
85/15 87/17 98/12
102/1 109/21 119/7
140/6 142/18 145/6
147/24 149/4 150/2
151/7 151/9 153/3

gets [2] 62/4 127/9

63/13 71/17 118/9
118/10 143/22
GFA [13] 57/23 61/8

62/12 69/1 69/4 69/11
70/16 70/20 128/10
Gilhooly [4] 25/16
Giros [1] 131/10
give [13] 2/1 30/9
46/2 70/5 82/23 84/4
90/23 92/15 97/6
146/9 152/13 152/22
153/6

given [28] 43/12
43/20 46/9 55/8 57/22)
71/14 73/3 74/2 74/23,
81/12 88/18 91/17
91/17 96/11 97/10
102/18 111/18 112/8
115/11 117/9 123/18
123/24 141/25 144/5
144/22 150/17 153/25}
154/2

gives [7] 33/4 46/4
51/11 103/5 126/5
130/20 133/24

giving [8] 4/24 40/12
43/18 46/13 53/20
97/7 119/15 119/19
GLO [16] 39/23 40/3
43/3 49/6 51/19 57/21
58/2 67/12 69/3 77/18
82/4 86/25 132/6

general... [9] 22/13
23/23 24/2 44/5 51/14,

60/9 60/10 65/2 67/14

13/9 13/10 21/13 23/9)

153/10 154/22 154/22)

getting [7] 22/1 38/12

61/11 61/23 62/6 62/8

135/8 135/14 136/25
go [52] 6/7 6/15 6/21
7/14 7/18 11/25 13/3

39/15 42/2 45/10
50/22 54/14 60/16
66/20 67/5 67/12

82/8 85/1 87/17 89/11
93/7 95/15 97/12
98/12 98/15 101/21
109/2 117/14 125/19
127/1 127/2 128/25
129/19 132/10 140/5
141/3 142/20 143/15
144/16 152/14

goal [1] 84/15

goes [7] 45/2 45/8
80/12 104/20 134/8
138/6 139/5

going [70] 1/10 9/22
9/23 11/15 16/1 23/16
29/6 29/20 29/23
29/23 30/23 34/9
36/23 37/1 37/2 41/24)
51/3 53/9 53/23 61/13
61/17 66/24 68/19
70/9 70/11 71/20 72/6
72/16 72/21 76/20
77/1 78/18 82/24
83/23 84/12 85/19
88/9 88/9 88/10 93/2
97/22 97/24 98/6
99/13 107/11 107/12
109/19 112/13 117/22)
118/19 120/18 120/21
121/4 129/20 131/1
132/22 133/1 133/7
136/4 136/6 141/23
142/4 142/6 142/24
143/18 144/19 148/2
152/24 153/1 153/4
gold [4] 80/11
golden [1] 115/8
gone [11] 28/15
28/16 51/20 91/2 92/3
97/17 99/4 113/16
115/23 132/8 150/15
good [32] 1/3 1/18
1/20 40/23 50/7 53/12
53/17 63/2 76/19 77/8
77/13 83/20 87/11
87/15 91/4 91/5 97/18)
99/20 102/10 102/14
102/24 103/7 118/4
119/20 121/6 127/5
128/3 141/22 146/11
147/15 148/9 151/21
goodbye [1] 115/8
got [27] 10/2 28/21
37/13 39/1 39/18 40/2
40/11 61/4 61/12
63/22 64/8 64/12 80/7)

14/4 15/20 21/9 33/25)
36/23 37/2 37/22 38/4

70/19 71/5 72/4 78/13

87/20 98/15 104/18
107/8 111/15 115/5

127/7 133/12 135/12
144/15 145/12
governance [9]
113/2 114/5 119/4
119/5 120/14 120/25
121/2 121/5 121/11
governing [2] 89/24
121/21

government [35]
28/17 62/25 73/19

112/2 112/5 114/7
114/18 115/1 115/2
115/15 116/8 116/18
116/24 117/9 117/11
117/17 118/3 118/11

140/6 140/8 141/9
144/3 146/14 146/17

151/9 151/17

Grampian [1] 25/1
grant [31] 54/10
54/13 54/24 55/11
55/15 55/25 56/4
56/23 57/1 57/3 57/7
57/8 57/9 57/9 58/7
60/19 65/15 67/20
67/23 68/9 68/19
100/15 101/18 103/4
103/9 103/23 104/23
104/25 105/3 105/6
121/2

grateful [5] 128/24
129/2 133/4 155/22
155/23

grave [1] 112/6
great [3] 38/13 93/18
113/14

greater [3] 47/14
84/4 90/23

greatest [1] 110/5
Green [2] 131/10
134/22

Greenhow [30] 1/22
1/24 2/2 2/16 3/21
30/5 31/3 40/12 41/1
63/23 66/22 66/23
67/6 74/1 88/11 98/17
99/23 117/4 121/15
127/20 128/3 133/7
136/14 137/13 137/15}
148/9 153/13 153/15
155/18 157/2

ground [2] 54/14
142/20

grounds [1] 96/13
group [32] 11/25
16/23 16/25 17/5 41/2I
41/6 42/13 42/20 43/9

117/13 118/17 120/20

107/17 111/21 111/24

118/20 119/16 119/23

148/17 149/13 149/14

graciously [1] 149/10]

54/11 58/12 58/14
59/4 60/7 64/22 72/8
86/12 105/22 111/8
118/23 119/3 119/8
119/18 120/5 131/5
131/6 137/16 142/2
groups [2] 92/25
143/5

growing [1] 52/13
guarantee [1] 90/16
guidance [3] 62/21
83/8 110/3

guide [1] 52/21
guilt [1] 23/12
guilty [3] 43/7 109/20
114/23

H

had [114] 2/23 3/17
5/16 6/5 7/8 7/10 7/11
13/5 14/17 15/3 15/22)
15/25 19/25 26/24
26/24 27/17 28/4
28/10 29/14 29/15
29/18 31/17 31/19
31/19 32/12 33/7
34/23 34/24 35/10
35/21 36/15 36/18
38/8 38/18 38/18
38/23 39/5 39/5 39/6
39/6 39/7 41/14 43/2
47/5 47/16 47/24 48/2
48/2 51/20 54/10
55/13 55/16 55/20
57/17 57/22 57/24
57/25 59/8 60/1 65/1
65/9 65/18 66/1 66/2
67/22 69/1 70/1 70/13)
70/14 70/21 73/3 73/6
73/8 73/13 75/12 76/6
79/23 80/8 82/10
83/25 85/8 86/11
91/23 92/5 93/11
93/12 94/6 94/11
94/13 96/15 97/15
102/9 102/13 107/23
111/13 111/14 112/5
112/8 112/17 112/20
114/8 115/3 115/10
120/12 120/15 121/1
122/11 127/2 128/6
136/4 141/16 142/13
147/21 154/25
hadn't [2] 23/12
38/11

half [3] 32/16 128/25
129/1

halfway [1] 32/8
hallmarks [1] 36/15
Hamilton [3] 3/11
19/24 43/6

hand [1] 42/3
handed [3] 72/14

44/1 47/2 48/22 52/23

74/25 137/11
handful [1] 21/25
handing [1] 52/19
hands [2] 41/15
127/10

hang [5] 23/9 23/16
44/22 154/21 154/23
happen [8] 6/22 34/6
39/19 71/10 93/14
97/22 98/11 142/11
happened [9] 2/20
33/18 37/14 37/15
53/14 132/1 136/20
140/10 140/13
happening [5] 36/18
45/24 53/24 114/9
142/16

happens [3] 91/13
118/19 151/7

happy [3] 23/2 92/11
128/7

harass [2] 92/18
92/23

harassing [1] 94/21
harassment [2]
94/20 99/6

hard [5] 44/19 62/14
133/13 141/11 141/23}
harder [1] 77/10
hardly [1] 115/9
hardware [3] 28/6
52/15 107/18
harm [1] 126/25
harmony [1] 63/2
harrowing [1] 82/18
has [85] 3/4 3/16
4/21 4/23 11/1 12/2
20/8 21/18 22/3 31/18
32/18 32/18 38/25
40/5 40/12 44/2 49/8
50/8 54/12 62/1 62/3
62/20 63/4 63/11
63/17 68/13 68/23
72/9 72/14 73/22
76/14 77/3 78/8 82/22)
83/24 84/23 86/24
87/16 88/7 88/13 90/5I
91/8 95/25 97/14
97/15 97/17 97/17
100/2 100/7 100/12
100/15 101/1 102/1
103/6 103/9 106/6
106/9 107/4 108/17
108/24 115/21 115/23)
116/15 120/13 121/13)
122/10 130/22 134/24)
138/10 143/25 146/2
146/17 146/19 149/5
149/19 150/7 150/9
150/15 150/18 151/3
152/18 152/19 152/21
153/5 153/17
hasn't [2] 117/23
155/9

(60) general... - hasn't
H

haunted [1] 77/3
have [208]
haven't [5] 51/11
86/10 90/25 92/3
154/3
having [22] 8/10
15/20 23/7 27/25
29/16 34/25 44/23
53/10 60/25 67/1 70/1
77/10 116/18 121/14
129/21 132/14 135/3
141/5 141/5 145/17
145/18 147/6
Hayes [1] 129/7
he [49] 9/16 9/16
22/13 24/5 24/7 24/8
26/10 26/23 31/19
31/20 31/24 33/4
33/12 33/16 33/18
36/17 39/5 40/3 40/4
41/23 41/23 41/24
44/2 45/2 45/8 45/9
45/12 46/20 49/25
50/6 50/9 52/5 52/6
52/7 53/16 65/14
66/11 67/6 67/17
71/14 71/16 71/17
75/11 86/16 99/4
102/14 119/8 135/11
135/12
he'd [1] 120/16
he's [4] 26/22 42/3
119/10 119/10
head [7] 18/17 39/17
39/18 67/17 112/15
119/7 144/5
headed [1] 129/3
heading [10] 2/21
19/5 21/8 25/24 55/25)
56/25 59/5 124/9
124/17 133/15
headquarters [1]
21/5
health [2] 92/1
142/13
hear [9] 1/3 1/6 1/8
1/10 1/16 1/18 40/23
99/20 143/4
heard [14] 23/11
23/12 31/23 38/11
38/15 39/25 50/24
54/12 82/17 89/8
92/20 124/10 137/18
149/13
hearing [5] 71/15
71/16 86/21 145/25
156/7
heck's [1] 112/13
hedge [1] 51/4
held [12] 4/25 14/10
16/15 25/1 33/7 59/14)
62/1 62/2 74/14 85/3

114/19 130/2
Hello [1] 1/16
help [18] 16/24 75/20
80/23 83/7 84/15
87/23 87/24 91/13
98/17 104/5 109/23
110/3 113/18 123/16
133/7 141/2 147/4
153/23
Helpdesk [1] 22/2
helpful [4] 71/3 84/16
133/13 147/20
helping [1] 87/8
helpline [2] 147/1
147/2
helplines [8] 146/24
146/25 147/1 147/4
147/10 147/12 147/22)
147/24
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109/20 127/7
hepatitis [4] 153/7
her [9] 34/23 34/23
59/24 59/24 70/25
71/24 148/12 152/1
152/1
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27/24 36/15 37/21
40/4 42/17 51/1 51/17
53/8 53/18 61/7 63/16
64/5 85/11 85/24
87/10 104/10 109/22
112/13 135/22 141/19)
150/6 150/16 151/4
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Here's [1] 117/12
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HEXAM [1] 24/18
Hi [4] 32/11 44/10
49/10 50/15
hide [1] 10/2
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High [2] 44/12 49/15
highlight [8] 29/15
30/23 52/13 53/18
64/15 66/20 78/15
118/6
highlighted [6] 86/11
86/18 86/23 91/24
107/16 112/6
highlighting [1] 89/7
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75/11
hill [1] 76/22
him [23] 9/16 9/20
9/21 22/16 22/20
31/20 31/22 31/25
33/12 34/2 36/13
41/22 42/3 52/3 53/15
53/16 62/21 65/3
65/24 97/15 120/11
132/14 137/2
his [27] 9/17 9/17
9/17 12/25 22/20

31/12 33/4 36/7 39/5
40/5 40/13 42/3 44/4
44/25 52/2 60/10
65/14 67/20 73/5
86/15 95/18 96/14
102/15 118/24 122/24
132/19 135/18
historic [4] 39/25
44/16 78/23 130/14
historical [1] 17/10
hm [2] 133/23 134/12
Hobbins [1] 25/11
HODGE [5] 1/25 2/16
40/10 156/1 157/4
Holborn [1] 2/22
hold [5] 61/24 114/15
116/3 118/7 153/21
holding [4] 136/17
holds [1] 90/1
hole [1] 39/16
home [2] 29/23
152/10
honest [6] 39/21
87/11 104/7 111/1
147/17 151/22
honestly [4] 41/25
48/11 48/14 137/5
honorary [2] 23/6
130/17
honourable [1] 61/11
hope [4] 3/18 28/25
150/19 152/11
hoped [3] 41/15
51/19 150/17
Horizon [67] 3/5
10/15 10/19 11/8 12/4
12/7 12/15 12/25 14/6
15/1 15/3 15/8 15/10
15/17 15/18 15/21
16/7 16/21 16/23
16/24 17/5 17/10
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21/16 21/25 22/4 22/7
22/17 23/14 23/19
25/23 26/5 27/13
29/10 31/4 33/8 34/2
42/24 44/16 44/23
49/16 53/1 53/3 53/5
53/19 57/19 60/11
107/4 107/15 107/23
111/3 115/12 134/25
135/25 138/9 138/14
138/18 138/24 139/17
140/2 140/7 140/8
140/15 147/7
Horizon's [5] 12/18
13/17 13/24 14/7
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horse [1] 47/24
Hotel [1] 25/1
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house [3] 59/19 83/6

111/23

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9/15 36/16 36/21 37/9)
37/14 37/15 37/17
38/7 38/23 39/3 54/7
61/22 63/11 72/8
72/10 74/24 79/10
79/10 79/10 79/20
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93/3 93/8 93/24 98/10)
102/17 102/19 110/2
110/2 110/4 111/21
117/4 119/9 119/22
130/7 130/21 131/5
141/2 146/15 153/25
however [11] 17/18
54/18 57/4 66/6 83/6
84/2 106/11 108/2
130/19 134/17 135/10
HR:4UK [1] 83/8
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huge [2] 90/21 139/4
Hughie [2] 19/24
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human [1] 19/7

l accepted [1] 143/8
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l agree [1] 62/10
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115/16

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44/18 52/19 64/4
64/15 91/21 95/25
115/17 115/18 146/4
146/7 152/12

l appreciate [2] 54/7
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67/24 71/14 92/8
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137/5 137/9
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18/20 25/17 26/14
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101/10 104/7 108/7
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149/2
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71/18 76/15
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42/21
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28/1 33/15 35/11
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132/25 137/12
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15/17 27/22 39/21
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47/9 47/17 48/9 48/13
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11/11 11/13 19/16
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53/4 53/6 55/6 55/10
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61/6 61/9 63/19 64/3
64/4 65/7 66/6 72/3
72/12 72/12 73/7
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78/22 79/16 79/23
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68/20 77/6 77/12 91/9

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153/24 154/5 155/6
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27/20 27/22 31/21
32/2 36/25 37/16
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41/19 41/20 41/23
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54/6 54/8 55/16 67/1
67/7 70/2 71/3 71/19
76/15 89/6 107/25
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112/16 114/4 114/5
120/12 120/17 120/18
122/8 130/17 135/10
136/9 137/7 141/25
144/22 145/25

I wasn't [9] 43/18
43/19 60/14 60/14
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13/12 19/11 38/10
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150/17 154/23
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89/20 90/18 106/3
117/4 128/24 129/2

l understand [2] 94/5

133/4
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138/16 140/20

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69/21 72/16 74/8
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92/7 92/7 92/10 97/1
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121/8 121/9 121/10
122/10 133/1 133/5
134/16 135/4 146/6
146/6 147/13 147/17
150/8 150/11 151/22
152/11 153/19 154/7
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71/4 77/4 83/25 83/25
86/18 86/23 90/21
94/4 97/9 97/16 98/8
98/24 99/2 99/3 99/4
99/4 107/2 107/16
112/18 112/18 115/20
121/4 122/11 127/19
131/15 135/13 136/8
140/6 141/15 142/23
143/1 146/4
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idea [5] 43/2 60/17
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26/22 27/16 29/2
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58/22 59/3 60/6 60/15
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62/12 62/23 63/5
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68/15 69/20 76/13
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83/20 84/13 85/2
85/14 85/19 88/4
90/17 90/18 90/25
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106/3 108/7 108/13
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120/20 121/8 121/9
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129/18 130/23 131/7
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154/1 154/3 154/6
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140/2
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140/24 141/5 141/6
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56/8 145/23
implication [1] 29/20
implored [1] 48/2
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10/6 10/9 13/6 23/22
32/18 33/2 51/8 53/4
53/6 87/7 87/15
102/16 116/13 132/21
143/3 143/3 151/5
151/8
impossible [1] 63/15
improve [2] 86/6
119/13
improvements [2]
69/5 69/10
inability [4] 44/20
inappropriate [1]
129/13

(62) I experienced... - inappropriate
incapable [3] 61/13
62/19 63/10
incarnation [1]
104/14

inception [1] 67/23
incited [1] 58/22
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143/22 144/13 144/13}
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104/19

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114/23
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63/12 113/21
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58/17

inform [2] 32/19
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125/5 126/9 131/23
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91/7 92/20 100/10
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22/17 24/14 44/24
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72/11 72/14 74/5
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105/8 105/11 115/12
115/12 126/2 126/4
128/8 133/2 139/5
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81/9 82/22 85/15
85/21 87/7 87/14
87/18 88/20 90/21
91/6 91/7 93/3 93/3
93/5 93/21 95/21
96/24 97/3 97/22
98/12 99/9 102/4
103/18 105/5 108/6
111/23 111/25 111/25}
112/1 114/3 114/13
114/14 115/23 116/4
116/13 116/14 116/25}
118/19 119/12 119/17]
119/17 119/18 119/18}
121/6 121/8 121/9
121/12 124/1 127/6
127/10 127/11 128/13}
128/14 128/18 128/25}
131/20 131/22 132/5
133/3 133/15 133/19
135/4 139/2 143/2
143/3 143/5 144/17
145/4 145/9 150/6
150/14 151/5 151/8
152/1 154/7 154/8
Item [1] 96/5

Item 9.3 [4] 96/5

its [55] 4/24 8/16 9/6

11/21 24/12 26/17
44/19 44/22 54/18
56/8 57/6 57/14 58/3
60/5 60/6 60/21 60/22
61/15 61/15 62/4 63/3I
63/20 63/25 64/20
64/22 65/16 65/18
67/5 70/17 70/21 86/7I
88/19 90/6 90/7 96/6
96/8 101/2 104/13
105/16 105/19 105/22I
106/16 113/20 120/14I
130/8 131/12 133/21
133/21 133/25 135/2
136/7 138/10 140/24
154/8 155/21

itself [1] 8/10

aq

Jacobs [1] 108/8
Jamil [1] 25/9
January [1] 120/10
Jay [1] 95/22
Jenna [2] 67/15
68/16
jerk [2] 73/1 73/23
Jim [3] 25/10 25/19
26/13
Jo [3] 3/11 19/24
43/6
job [1] 115/8
Job's [1] 152/13
John [1] 86/14
joined [2] 18/11
18/12
Jon [4] 49/8 49/24
50/5 50/15
journalist [1] 44/11
journey [1] 76/21
judge [7] 32/22 50/18
66/5 71/11 74/20
106/14 106/25
judges [1] 28/23
judgment [18] 50/24
65/14 72/9 72/11 74/4
74/10 74/16 74/25
76/3 76/14 76/23
101/15 101/20 102/24I
104/22 104/25 133/2
137/10
judgments [1]
115/12
judicial [2] 47/12
146/16
July [2] 55/23 104/2
June [7] 10/13 10/19
13/14 13/23 42/19
54/19 59/1
jurisdiction [1]
109/25
jury [2] 106/14
106/25
just [104] 1/7 9/15
10/7 15/2 17/14 20/17)

(53) incapable - just
J

just... [98] 21/24 23/4
23/6 23/7 23/20 25/8
29/12 31/22 32/12
35/14 37/4 37/13
39/16 39/19 39/19
39/22 41/17 42/3 46/4
47/17 48/25 50/4
51/13 51/22 53/24
60/2 62/18 66/8 66/21
66/21 70/2 74/2 74/6
75/2 75/5 75/24 76/5
79/10 80/10 80/12
82/13 82/18 82/18
88/17 88/20 90/18
90/23 92/3 92/15
93/10 94/4 96/15
96/17 97/20 97/24
98/6 98/15 102/23
107/11 109/19 110/4
111/5 114/9 116/2
117/15 117/15 117/25}
118/21 119/6 119/17
120/18 126/11 127/12)
128/14 128/20 128/21
130/17 133/1 135/3
136/8 136/14 136/16
139/5 143/2 143/3
144/21 145/13 148/13}
152/7 152/13 152/22
153/5 153/10 153/16
153/19 153/24 154/4
155/4
justice [26] 2/24 3/1
47/11 47/13 48/12
59/9 61/2 62/19 62/22
63/8 65/13 65/23 66/6
72/10 73/2 73/10
73/25 74/4 76/5
101/14 102/12 105/25)
148/19 149/5 149/22
149/22
Justice Fraser [2]
73/2 73/10

K

keep [2] 37/2 77/10
kept [1] 38/9
Khalfan [2] 67/15
68/16

kicked [2] 118/13
118/13

kind [14] 61/16 70/5
76/24 106/12 112/8
120/14 130/11 130/14
137/7 148/25 150/7
150/15 152/21 155/5
Kingdom [3] 4/19
153/17 154/11

kit [2] 34/2 49/14
knee [2] 73/1 73/23
knew [4] 33/9 75/12
75/13 114/24

know [142] 3/3 3/3
3/6 5/10 9/16 9/22
10/4 13/8 13/8 13/9
13/13 16/5 18/15 23/4
23/6 23/7 23/11 23/15)
23/19 26/20 27/23
28/17 28/21 28/24
29/3 30/1 30/4 30/22
31/1 31/12 31/22
32/16 32/25 35/9
38/25 39/9 39/20
39/21 41/18 41/25
44/12 47/9 47/19
47/19 48/9 50/9 50/17
51/2 51/18 53/21
55/10 60/15 60/21
61/4 61/24 62/9 62/16
64/4 66/7 69/1 69/20
69/25 71/19 71/22
73/12 73/17 75/2
75/10 75/14 75/19
75/20 75/22 76/24
77/6 77/9 79/9 79/10
79/25 80/2 82/6 82/16)
83/23 87/10 87/17
89/7 91/9 92/8 92/21
93/3 93/8 93/19 93/21
96/19 96/23 97/14
97/16 97/20 97/22
98/7 98/14 104/9
107/2 107/9 109/4
109/21 113/11 113/14}
114/4 116/14 119/11
119/25 119/25 120/1
120/19 127/6 128/7
131/7 132/2 136/8
136/9 136/10 136/11
139/11 145/15 145/17,
146/8 147/5 149/4
150/5 151/21 151/23
152/7 152/7 152/8
153/4 153/8 154/12
154/13 154/14 154/20)
155/8 155/12
knowing [2] 96/19
97/23
knowledge [15] 2/14
10/5 15/8 30/11 31/4
43/22 68/25 78/2 84/5)
85/25 86/2 115/1
117/21 117/23 155/8
known [8] 31/5 31/20
33/22 67/7 104/1
122/16 145/3 145/3
knows [1] 77/7
KPIs [4] 83/20

L

lack [7] 71/25 81/19
110/22 111/16 134/9
135/7 136/21

laid [1] 90/15
language [1] 99/3
large [2] 79/21

137/16

larger [2] 143/18
143/20

last [16] 2/22 7/10
21/12 30/5 30/6 43/16
52/18 59/7 61/20
78/22 82/18 91/8
115/19 138/16 145/8
146/22

lastly [1] 138/13

late [1] 69/12

lately [1] 79/5

later [4] 35/16 45/21
88/15 152/14
launched [2] 81/24
145/16

Laura [1] 25/10

law [1] 21/20

lawyer [2] 72/16 75/3
laying [1] 64/1
layout [4] 41/19
LBM [3] 59/8 59/10
59/14

lead [1] 3/9

leader [1] 60/25
leadership [3] 9/9
9/13 110/19

learned [4] 39/14
112/18 112/18 135/13
least [5] 71/11 78/22
94/25 121/6 130/1
Leave [1] 148/4
leaving [1] 142/4

led [5] 54/16 60/9
124/11 146/2 146/19
left [5] 6/7 115/7
115/7 116/22 152/19
legal [21] 28/19
28/24 29/1 42/18
42/22 42/25 47/4 47/6
48/21 49/20 51/17
72/18 80/23 91/2
101/12 109/22 131/11
146/16 150/8 151/24
154/19

legally [1] 91/1

legislation [3] 148/16
149/12 151/16

legs [1] 46/3

lend [2] 47/2 60/6

length [3] 93/18
117/3 132/9

lengths [2] 97/17
98/12

leopard [1] 101/1

less [2] 21/14 150/24

let [5] 9/16 44/22
92/9 109/6 114/19

let's [3] 58/25 72/20
127/25

letter [8] 95/17 96/12
107/7 137/22 137/23
138/6 138/20 138/21

letters [1] 79/6

letting [1] 136/16
level [7] 12/23 76/6
87/1 89/7 92/22
100/13 124/13
levers [1] 130/2
Lewis [1] 59/11
lies [3] 113/2 130/6
152/1
life [2] 91/8 142/11
lift [1] 86/20
light [2] 88/17 138/10
like [38] 2/18 3/10
3/14 4/1 8/13 14/4
16/4 20/18 31/3 33/18}
41/1 41/25 46/12 52/8
54/9 55/21 59/16 62/7
66/13 72/7 77/14
79/12 81/11 86/3
87/19 89/20 90/25
91/6 91/11 98/20
106/3 112/3 117/4
117/16 118/18 144/24}
147/18 151/1
limit [2] 93/7 93/8
limited [9] 8/11 18/24)
90/16 104/14 104/22
105/22 129/17 129/19)
134/22
line [14] 12/14 27/13
45/22 91/2 91/2 93/9
93/9 99/2 105/25
114/10 114/10 114/11
125/14 149/7
lines [3] 31/23 112/7
147/15
link [4] 65/19 65/25
66/2 68/14
linked [3] 45/24
125/4 145/11
Linton [1] 4/4
list [3] 16/13 16/17
17/8
listen [6] 10/6 10/9
112/16 113/14 113/19}
153/23
listened [1] 89/8
listening [5] 82/4
82/4 86/21 143/4
145/19
lists [1] 25/6
literally [6] 2/23
39/19 53/12 53/15
53/17 80/12
litigants [2] 52/23
58/14
litigation [26] 11/25
41/2 41/7 41/11 42/9
42/13 42/21 43/9
43/13 44/1 47/2 48/22)
52/24 54/11 56/19
58/12 59/4 60/7 64/23)
65/11 72/8 132/6
133/22 134/15 135/2
135/23

little [12] 23/15 31/25
53/13 64/3 72/17
76/17 88/15 95/16
129/2 129/6 129/10
141/2
live [3] 29/21 71/2
153/1
lives [2] 121/14
153/2
lobby [2] 30/22
105/21
lobbying [1] 31/1
local [7] 4/21 6/2
10/24 16/6 77/19 80/4)
141/17
located [2] 4/4 5/10
location [1] 34/8
logo [1] 70/8
long [13] 13/1 52/5
52/6 72/15 79/10
79/10 89/11 107/25
108/10 121/13 130/21
131/9 145/18
longer [7] 8/7 46/9
60/23 116/20 138/24
146/5 155/7
longstanding [1]
21/15
look [33] 18/14 23/24
29/13 33/1 34/22
55/21 58/25 59/16
67/5 71/6 72/4 74/13
83/10 87/15 87/21
88/8 97/20 102/21
107/18 109/19 114/17)
121/2 121/11 123/5
128/13 128/20 128/23)
132/9 133/1 133/7
133/19 146/17 150/12)
looked [6] 83/25
105/24 111/25 112/6
112/10 115/4
looking [16] 7/7 15/9
25/8 35/4 39/10 55/11
62/7 71/19 83/11
83/15 87/22 87/22
88/3 88/6 112/3
144/10
looks [3] 21/16 112/2
150/21
Lord [21] 2/24 3/1
3/11 47/11 48/11 63/8)
66/6 76/5 101/13
102/12 105/25 148/19)
149/5 149/14 149/17
149/19 150/2 151/1
151/9 151/23 151/24
Lord Arbuthnot [1]
3/11
Lord Justice [2] 63/8
102/12
Lord Justice Fraser
[5] 2/24 3/4 47/11
66/6 76/5

(54) ju:

st... - Lord Justice Fraser
L

lose [3] 29/23 29/24
60/5

losing [4] 54/6 141/1
142/9 143/22

loss [3] 37/13 52/13
60/18

losses [4] 12/7 15/7
15/24 107/7

lost [1] 29/22

lot [15] 9/20 9/21
26/6 26/10 31/18
49/20 51/15 72/18
90/20 90/24 91/10
117/7 126/21 143/19
152/6

love [1] 90/18
lovely [5] 42/2 50/5
50/5 89/12 89/13
low [4] 144/10
lower [4] 143/14
144/11 144/12 144/20)

lunch [1] 99/25

Lyn [1] 70/10

Lynn [5] 45/16 50/23
60/2 69/25 70/1

made [29] 22/6 39/1
48/12 56/5 58/6 59/15
59/16 65/13 65/17
65/18 65/21 69/5
69/10 71/24 76/10
80/4 84/23 86/3 96/1
96/16 110/9 115/10
117/2 125/14 139/14
142/15 147/10 148/18
150/9

magazine [6] 49/9
49/14 49/21 50/1
59/12 59/19

Mail [2] 28/19 105/22
mains [1] 80/5
maintain [1] 87/6
maintaining [1]

52/25

major [3] 49/18 89/4
112/2

majority [1] 21/20
make [37] 2/18 8/15
9/3 10/10 29/15 29/16
29/18 48/13 49/1
50/18 51/23 52/8
53/24 72/4 75/21
75/23 75/25 76/2
76/15 76/21 77/1 77/2
82/16 82/20 87/23
87/25 89/19 94/4 97/4
99/12 121/7 126/18
140/20 141/16 141/19}
143/7 144/21

makes [2] 77/10
102/15

making [18] 1/7 28/8
29/18 46/17 47/7
53/20 75/8 75/9 76/21
98/18 116/18 116/25
121/24 124/22 125/8
126/24 127/11 151/6
maliciously [1] 28/9
manage [1] 137/1
management [4]
62/18 86/15 110/23
116/10
manager [3] 36/10
38/16 124/24
mandate [1] 17/9
mandates [1] 16/18
manipulation [1]
130/3
manipulative [1]
130/21
manner [14] 3/19
61/11 63/6 63/11
63/15 63/21 66/3
84/25 87/5 94/20
96/22 107/5 109/14
120/17
many [7] 5/7 5/10
13/8 70/4 121/14
142/12 151/2
March [4] 7/18 74/14
95/21 142/1
March 2019 [1] 74/14
March 2025 [1] 142/1
mark [4] 23/15 32/12
32/13 32/14
mass [3] 20/19
148/16 151/15
materially [1] 56/21
matter [13] 61/16
61/16 61/25 63/8
93/22 96/20 96/21
97/23 98/23 98/25
109/12 131/5 148/2
matters [6] 46/14
46/18 47/4 99/24
104/24 117/8
may [58] 6/7 6/7 6/21
9/14 15/4 28/4 28/7
30/19 30/24 30/25
31/22 31/24 34/8
34/10 40/8 41/24
43/22 44/12 53/8 56/7
56/21 57/6 59/18 68/4
76/13 82/12 90/2
90/18 90/25 96/6 99/9)
104/4 104/15 105/8
105/13 106/3 108/25
121/8 122/8 123/19
126/7 127/4 127/22
133/10 133/12 137/22)
138/7 138/17 138/20
139/20 140/2 140/5
140/14 140/20 143/2
143/4 143/5 153/21
May 2024 [1] 140/2

maybe [17] 11/14

35/7 41/17 52/5 87/5
87/5 91/6 97/21 99/2
99/3 109/3 152/11
152/20
McBain [3] 24/3
24/12 25/14
McCormack [8] 31/8
31/12 32/4 32/9 33/6
33/14 34/25 36/3
me [49] 1/3 1/16 8/18
8/20 15/7 15/8 15/25
23/8 23/14 30/8 31/25
33/18 35/7 38/20
38/21 38/22 38/25
38/25 39/7 40/23
43/22 57/21 66/23
66/24 70/15 72/17
76/17 77/3 85/21 92/9
92/10 93/1 97/2 97/3
109/6 112/17 112/17
114/19 119/15 119/19}
122/2 133/5 139/1
141/22 143/9 148/4
150/7 151/11 154/16
mean [22] 10/7 21/3
23/4 26/10 27/6 29/21
30/6 31/18 34/16
39/13 50/4 60/12
62/25 65/1 69/25
105/25 106/23 112/20
119/6 138/25 144/11
154/14
meaning [2] 74/6
143/21
means [4] 26/12 30/9
40/10 99/11
meant [3] 3/8 21/22
142/14
media [14] 20/20
56/11 59/11 72/22
76/7 91/25 92/5 92/13
92/16 94/7 94/18 98/2
98/3 143/5
mediation [4] 83/11
127/18 127/14 145/22
meet [4] 7/18 83/21
148/22 149/11
meeting [26] 5/16
5/17 6/24 10/18 11/1
11/9 11/18 12/19
24/17 24/19 24/22
24/25 25/3 25/7 27/12
29/9 36/21 54/2 59/1
59/14 74/14 111/12
112/22 120/12 148/18}
149/16
meetings [3] 5/20
16/1 128/22
meets [2] 49/13
92/24
meltdown [1] 62/17
member [21] 4/11

13/11 15/6 23/9 31/19

9/18 9/19 10/13 14/25
18/6 31/9 32/14 59/2
78/9 79/21 81/4 85/8
89/23 91/24 92/17
96/3 96/8 130/18
154/24 155/3
members [40] 6/4
6/25 7/4 8/17 9/6 10/4
12/9 12/11 13/5 14/17,
20/22 20/25 44/22
49/4 58/3 64/20 65/7
77/23 78/17 79/3 81/4,
81/5 81/7 81/9 84/4
86/1 86/7 91/25 92/1
93/16 93/19 96/1
102/10 103/8 105/22
117/19 124/20 136/7
153/21 154/9
members' [1] 77/15
membership [11]
6/20 7/1 9/20 12/13
79/17 89/24 91/14
95/13 95/18 96/2
105/17
memory [2] 25/11
35/23
mental [3] 92/1 92/14
98/13
mention [5] 2/24
19/18 21/25 112/1
124/2
mentioned [7] 26/22
47/3 59/23 76/7 78/19)
79/16 118/22
message [1] 22/10
messages [1] 94/24
method [2] 79/16
126/2
Microphone [1] 1/4
mid [2] 10/13 10/19
mid-June [2] 10/13
10/19
middle [3] 44/3 50/12
138/16
Midlands [1] 16/13
might [21] 7/9 10/23
20/5 22/18 25/16 36/4,
47/22 48/14 48/20
58/21 63/23 71/5 72/4
72/20 74/1 76/16
117/25 131/6 132/24
133/7 141/18
Mills [1] 129/6
mind [1] 115/13
mindful [1] 99/9
mindset [1] 47/20
minimum [1] 17/11
Minister [6] 118/24
120/9 120/20 120/22
148/19 149/5
ministers [1] 117/19
minute [4] 40/9
128/18 130/12 148/6
minutes [16] 11/1

11/5 11/8 11/18 11/20}
14/2 24/22 24/25
25/22 26/15 27/1
27/11 58/25 60/4
60/18 74/14
mirror [2] 87/16
115/5
miscarriage [1]
73/25
miscarriages [1]
149/21
misled [1] 64/16
Misra [3] 19/24 32/21
43/6
missed [2] 132/14
144/21
mission [1] 70/7
mistake [3] 59/19
84/23 107/4
misunderstandings
[1] 98/19
mixture [1] 52/15
Mm [3] 17/13 133/23
134/12
Mm-hm [2] 133/23
134/12
model [1] 141/18
models [1] 146/2
Moloney [1] 128/4
moment [6] 75/22
120/24 122/12 139/25]
149/16 153/5
momentum [2] 12/19
12/25
Monday [1] 92/20
money [10] 12/9
12/10 19/25 49/20
82/23 82/24 107/8
142/10 152/13 152/23)
monitored [1] 83/18
monitoring [3] 77/15
78/1 136/22
Montgomery [2]
11/11 11/24
month [4] 21/25
52/18 101/9 151/13
monthly [3] 78/13
79/21 80/10
months [5] 17/12
37/2 142/8 142/8
149/19
months' [1] 37/19
moral [1] 63/6
more [33] 8/16 9/4
11/14 11/14 16/3
23/10 23/16 23/17
31/25 34/23 39/11
39/21 45/13 60/2 72/3}
77/1 79/13 85/17 88/4I
89/5 92/10 98/6 98/7
98/7 98/7 98/17
106/13 106/20 137/13)
141/2 143/21 151/19
153/11

(65) lose - more
14/17 40/23 58/7

133/9 156/2
mortgage [1] 146/5
most [9] 5/19 12/7
32/18 52/13 58/1
73/18 78/21 112/20
151/24

6/20 7/2 7/3 7/10
16/17 17/7 18/22
19/10 27/4 30/7 30/11
30/12 30/13 30/18

7/8 7/14 7/19 7/24
16/9 16/13 17/15
17/22 18/2 18/14
motivation [1] 9/1
motives [1] 98/20
move [14] 41/1 51/7
62/24 72/7 77/12
85/15 89/18 89/20
97/25 98/15 99/23
106/3 132/4 146/12
moved [2] 86/24
88/13

MP [3] 30/12 30/15
30/16

MPs [3] 27/4 30/7
30/22

Mr [61] 2/16 3/21
9/13 22/15 24/12
25/19 27/7 30/5 31/3
31/12 32/4 32/9 33/6
33/14 34/25 36/3
36/11 36/16 40/12
41/1 42/5 43/25 58/15
63/23 65/13 65/23
72/10 74/1 74/4 88/11
95/22 98/17 99/23
108/7 108/8 115/25
117/4 121/15 127/20
128/3 128/4 132/14
132/19 133/7 134/19
134/22 135/11 136/14}
137/2 137/13 137/14
137/15 137/19 137/23
138/13 138/16 148/9
153/13 153/15 155/18)
157/8

Mr Bates [4] 42/5
58/15 132/14 137/2
Mr Beal [2] 134/19
135/11

Mr Green [1] 134/22
Mr Greenhow [23]
2/16 3/21 30/5 31/3
40/12 41/1 63/23 74/1
88/11 98/17 99/23
117/4 121/15 127/20
128/3 133/7 136/14

morning [9] 1/3

100/11 105/24 132/10)

motion [16] 6/16 6/17I

motions [12] 6/14 7/6)

137/13 137/15 148/9
153/13 153/15 155/18)
Mr Ismail [2] 108/7
137/19

Mr Jacobs [1] 108/8
Mr Jay [4] 95/22

Mr Jim [1] 25/19

Mr Justice [3] 65/13
72/10 74/4

Mr Justice Fraser [1]
65/23

Mr McBain [1] 24/12
Mr McCormack [7]
31/12 32/4 32/9 33/6
33/14 34/25 36/3

Mr Moloney [1] 128/4I
Mr Patterson [3]
137/23 138/13 138/16)
Mr Thomson [2]
22/15 27/7

Mr Thomson's [1]
9/13

Mr Trotter [2] 36/11
36/16

Mr Wallis [2] 43/25
132/19

Mrs [1] 134/23

Mrs van den Bogerd
[1] 134/23

MS [18] 1/25 2/16
40/10 45/16 45/16
45/20 46/24 59/23
69/8 70/19 71/23
128/2 128/4 148/8
156/1 157/4 157/6
157/10

Ms Cox [1] 45/16

Ms Eccles [6] 45/20
46/24 59/23 69/8
70/19 71/23

Ms Eccles' [1] 45/16

MS HODGE [5] 1/25
2/16 40/10 156/1
157/4

MS PATRICK [3]

128/2 128/4 157/6

much [22] 1/20 9/17

9/23 16/2 23/13 40/15)

42/16 43/4 50/13

57/25 73/23 84/13
122/11 125/5 127/7

134/10 135/15 137/9

150/9 153/25 155/17

156/4

multiple [1] 34/22

must [7] 29/2 29/3

49/19 67/6 84/20
106/3 126/1

muted [2] 1/4 1/5

my [85] 2/16 2/21

3/14 3/19 5/16 10/3
11/17 15/8 15/20
15/24 17/1 17/3 18/17

28/17 29/13 29/15

30/2 30/4 30/11 33/21
34/10 34/12 34/18
36/22 38/10 43/22
44/15 44/18 45/12

64/7 64/9 65/5 66/16

77/6 78/2 82/5 85/17
86/2 88/11 89/2 91/7
100/2 109/24 111/9
112/1 112/8 112/10
114/17 115/1 115/18
120/2 120/9 121/10

126/19 128/3 131/8
131/21 132/2 135/14
137/8 137/9 137/15
139/1 141/12 141/15
142/23 143/1 143/9
145/2 146/4 148/9
151/11 152/3 155/8
myself [6] 23/6 23/23
41/22 67/2 78/12
111/9

N

name [7] 2/1 2/16
95/7 128/3 136/17
137/15 148/9

named [1] 52/1
names [1] 154/10
National [17] 3/22
21/3 25/10 25/19 26/6
26/9 26/16 26/20 27/6
27/10 27/11 27/15
43/25 60/19 104/1
134/1 145/14
nationwide [2] 52/18
134/4

nature [4] 52/2 66/12
79/2 126/11

NBIT [3] 119/6
119/12 141/25
necessarily [11] 10/7
13/8 30/10 60/12 61/9}
92/22 113/13 131/13
135/16 135/20 152/6
need [38] 32/16
37/22 40/1 46/22
52/12 59/18 61/4 61/6
61/24 68/20 69/23
72/14 72/15 77/6 77/7
77/12 77/12 78/15
86/17 86/17 90/20
91/3 91/9 96/8 106/12
106/13 106/15 107/9
107/14 108/4 109/21
116/2 116/8 116/23
117/1 117/20 118/2
121/10

needed [6] 35/5
49/14 76/18 76/19
77/2 114/12

needs [8] 61/5 62/16

47/3 50/16 53/5 61/23

68/4 68/25 71/5 71/18

121/15 122/11 124/16

108/4 108/11 116/16
116/16 151/1 153/11
negative [1] 9/21
negotiate [2] 18/24
100/15
negotiated [1]
145/12
negotiation [1] 54/15
negotiations [1]
100/22
neighbouring [1]
33/25
neither [1] 28/1
network [20] 16/3
21/21 29/17 30/24
32/19 49/20 75/24
87/1 87/14 87/24
92/12 131/23 140/22
141/3 141/4 141/8
143/11 145/16 145/24,
146/20
neutral [4] 47/22
136/5 136/15 137/4
never [10] 17/5 34/9
38/5 39/1 97/24 99/1
115/13 119/10 119/10
143/10
new [20] 33/3 49/13
49/13 52/16 53/25
60/25 62/6 70/10
70/12 72/7 83/17
103/9 105/5 111/13
112/16 126/8 136/9
141/14 143/17 149/12)
news [1] 141/22
next [4] 100/2 102/22
129/20 134/7
NFSP [166]
NFSP's [12] 5/21
6/10 12/2 44/13 44/15)
65/15 66/15 88/11
90/13 96/1 110/3
150/1
NFSP00000500 [1]
11/3
NFSP00000534 [1]
59/1
NFSP00000558 [1]
74/13
NFSP00000707 [1]
51/24
NFSP00000710 [1]
49/3
NFSP00000728 [1]
66/17
NFSP00000779 [1]
43/15
NFSP00001037 [1]
16/12
NFSP00001044 [1]
18/15
NFSP00001075 [1]
55/22
Nick [7] 43/24 46/8

46/20 67/14 67/15
71/2 112/12
night [1] 2/22
night's [1] 21/12
no [83] 8/7 10/22
12/16 14/24 15/8
15/13 15/25 17/17
17/17 18/8 18/10
18/12 18/17 18/20
22/7 23/18 26/7 26/17
26/22 30/21 36/20
39/6 39/7 43/2 43/14
46/9 50/4 51/5 55/17
57/17 57/20 57/22
60/1 60/17 60/23 61/4
62/10 62/16 64/24
72/3 74/12 74/21
74/22 77/18 77/21
77/24 77/25 78/2
80/15 81/16 90/10
96/12 98/13 98/15
100/1 100/6 106/2
113/13 116/20 117/21
120/13 124/11 127/19)
131/5 131/13 134/13
134/15 136/3 137/12
137/13 138/24 141/13}
141/13 143/7 145/15
147/18 147/19 148/20)
149/16 149/18 152/18)
155/6 155/7
nobody [1] 140/17
nominate [1] 96/4
non [13] 8/4 13/21
24/4 24/7 61/21 89/9
106/22 113/5 113/16
126/20 127/12 150/8
155/21
Non-Executive [9]
8/4 24/4 24/7 61/21
89/9 106/22 113/5
113/16 127/12
non-legal [1] 150/8
non-statutory [1]
155/21
normally [1] 7/19
north [4] 109/24
Northern [2] 4/19
149/10
not [206]
note [2] 101/6 101/21
noted [3] 32/22 134/1
134/23
notes [1] 123/20
nothing [11] 3/7 10/2
47/15 55/13 55/16
55/20 71/19 71/20
112/7 119/19 149/13
noticed [1] 32/24
notified [1] 39/5
Nott [2] 25/10 25/19
novated [1] 104/2
novation [9] 67/25
68/3 68/21 101/7

(56) morning - novation
N

novation... [5] 101/21
104/3 104/5 104/6
104/8
November [5] 44/8
49/9 50/14 52/20
104/3
now [69] 1/10 1/19
8/22 13/13 17/14 27/5
27/25 31/3 33/23
42/11 46/11 51/1
52/17 52/22 52/24
53/12 57/16 58/6
58/13 59/23 62/11
67/24 68/16 79/16
80/14 80/21 80/22
80/24 81/3 82/25
83/10 85/6 85/9 85/24
86/3 88/22 90/17 91/9
95/5 96/10 99/10
102/4 103/9 103/9
115/17 117/24 121/3
121/6 121/18 122/2
126/15 128/13 129/3
129/22 130/6 133/1
135/3 135/13 137/18
137/23 140/20 142/23
143/25 144/9 144/17
145/2 145/4 146/4
147/15
nuance [1] 72/18
number [12] 4/21
18/22 33/4 50/7 52/12
57/2 80/4 86/5 113/11
123/23 128/5 152/4
number 17 [1] 57/2
number 43 [1] 18/22
numbers [1] 144/4
numerous [1] 133/20

[e)

obfuscate [4] 62/4
114/14 118/20 150/23}
obfuscated [1] 149/6
obligations [1] 57/15
obtain [1] 61/2
obtained [1] 26/21
obvious [1] 139/24
obviously [47] 13/2
17/1 20/7 20/19 23/4
25/9 25/13 27/23
29/15 30/10 30/22
31/16 31/18 34/8 35/9
39/23 41/18 50/5 62/5}
65/1 69/21 71/4 72/15
72/18 75/6 79/9 80/21
90/15 92/20 105/25
107/2 109/24 109/25
112/22 116/8 116/9
121/1 121/3 122/9
130/17 135/13 135/14}
142/10 144/19 150/5
150/11 155/22

occasion [1] 33/5
occasionally [1]
23/11
occasions [3] 79/22
123/23 132/25
occur [1] 32/20
occurred [1] 38/8
October [9] 24/19
25/1 25/4 29/9 69/1
101/23 128/22 141/1
143/1
odd [2] 2/20 71/8
off [6] 18/17 67/1
67/2 70/13 89/20
147/8
offence [1] 154/25
offer [4] 3/14 45/3
55/1 132/2
offered [2] 64/7
129/8
offhand [2] 5/12 68/5
office [251]
Office's [14] 32/19
39/11 57/3 57/5 66/3
83/1 105/16 124/25
126/17 127/10 133/15)
134/25 135/16 142/15)
officer [10] 3/22
24/10 25/13 52/4
104/16 112/23 120/13)
123/11 123/15 123/18)
officers [1] 110/13
offices [10] 80/5 80/5
116/19 116/22 142/4
142/5 142/21 143/18
143/20 143/21
Official [1] 44/6
officials [1] 107/24
often [1] 145/25
Oh [9] 8/24 13/22
35/13 67/5 76/11
100/9 113/3 128/17
153/12
Olc [1] 123/9
okay [15] 35/13 99/2
100/1 109/12 116/6
127/13 131/19 132/4
145/13 146/11 146/22)
147/5 147/9 147/19
153/6
old [2] 140/17 140/17
oldie [1] 70/5
on [245]
once [4] 33/5 42/23
73/9 88/6
one [54] 7/16 9/2
14/21 15/8 15/25
16/10 26/19 27/13
28/13 32/17 34/9
36/24 38/14 41/23
45/6 46/9 51/15 52/22
65/13 69/25 73/22
75/15 78/5 86/7 88/4
88/4 91/20 94/16

94/25 97/5 102/8
102/12 106/21 108/23
115/3 117/23 117/24
122/15 128/13 130/2
131/1 131/22 132/9
133/2 139/5 141/12
141/13 145/20 146/2
148/6 151/22 153/4
154/14 154/15
ones [1] 80/10
ongoing [6] 45/22
47/8 48/22 49/1 69/12
139/21
online [2] 31/4
132/18
only [21] 2/25 15/20
26/22 26/23 41/22
46/5 50/8 55/12 57/23)
83/13 91/21 93/13
93/16 98/6 109/3
111/22 121/9 128/7
132/9 142/18 151/13
onto [3] 78/12 84/12
102/21
onwards [1] 73/5
Ooh [1] 151/21
open [8] 64/6 64/8
89/5 95/9 106/20
107/10 111/1 154/7
open-ended [1]
154/7
opening [4] 17/3
50/21 123/14 133/25
operate [1] 90/1
operated [2] 34/9
35/18
operates [1] 33/22
opinion [1] 60/14
opinions [1] 105/19
opportunities [1]
13/11
opportunity [11]
41/16 42/4 43/12
43/21 45/4 46/14 47/1
65/2 65/3 118/18
126/5
or [125] 6/5 6/7 7/1
7/8 7/14 10/2 11/14
12/24 13/14 14/21
15/4 15/5 15/5 15/11
16/22 18/2 20/7 20/20
20/25 26/5 27/7 28/5
29/18 30/2 30/25
31/17 31/17 31/23
34/14 34/20 34/23
38/14 38/15 39/10
39/11 41/22 41/25
42/25 45/7 46/10
48/15 49/5 50/9 51/13)
51/15 52/16 55/10
55/18 55/19 56/3 56/9
56/10 56/11 56/13
56/14 56/16 56/18
56/20 57/6 57/7 57/8

57/8 57/9 57/13 57/15
60/16 74/23 76/21
76/24 77/20 78/6
78/14 79/25 80/16
82/12 83/4 84/1 86/25
91/25 92/9 93/14 96/3,
98/19 99/3 105/8
105/16 107/4 108/7
108/7 108/21 109/5
109/13 109/14 114/14}
115/4 116/23 119/4
122/24 123/9 123/15
126/6 126/8 127/9
130/3 130/19 134/9
134/17 138/3 138/4
141/17 142/17 143/7
143/12 143/14 146/1
146/1 146/12 146/12
146/16 146/16 147/4
149/14 152/9 153/5
153/16
oral [1] 155/24
orally [1] 40/12
order [3] 35/14 44/23
98/18
orders [5] 6/10 14/14
18/4 18/7 18/16
ordinary [1] 9/18
organisation [29] 3/9
5/1 8/7 8/16 9/4 12/24
16/6 44/21 48/5 55/8
59/21 61/2 61/12
64/19 75/17 75/20
76/10 77/8 85/9 88/25
90/2 117/18 120/19
131/3 132/22 134/3
145/20 145/23 147/21
organisation's [1]
63/25
Organisational [1]
96/4
organise [2] 56/14
56/17
organising [2] 56/13
56/16
original [3] 104/23
104/25 105/3
originally [2] 62/8
103/24
other [29] 13/4 13/5
15/21 16/4 25/12
25/17 28/2 30/3 37/14,
41/23 44/24 46/10
56/20 57/5 58/22 71/3,
87/20 96/3 111/5
111/10 112/24 117/8
121/18 122/12 125/14
129/20 147/21 153/4
155/15,
others [7] 6/8 7/21
41/3 75/8 79/9 104/21
141/6
otherwise [1] 109/20
our [49] 1/22 5/16

20/23 20/24 20/25
22/5 28/12 28/24
29/16 29/20 29/21
29/22 29/23 29/24
29/24 34/14 37/20
46/2 47/20 48/11
48/25 51/22 68/20
70/7 70/8 70/9 72/25
80/22 80/23 81/4 81/5
83/7 84/4 84/15 87/18)
92/2 93/16 93/16
93/19 96/5 97/18 99/6
103/8 117/21 117/23
117/25 141/1 142/15
154/18
ourselves [4] 74/23
87/15 87/21 104/18
out [42] 2/22 2/23
10/3 17/3 17/4 17/6
23/23 32/18 33/25
34/3 38/12 41/21 43/8)
44/22 51/20 53/14
53/20 54/1 54/11 65/3
73/21 73/22 76/14
79/11 80/10 80/12
84/17 92/17 105/4
109/11 115/11 121/3
123/3 124/21 125/25
127/10 137/1 138/23
139/25 151/13 152/12)
152/16
outcome [4] 47/24
72/8 125/12 134/13
outcomes [1] 84/1
outgoings [1] 60/22
outline [2] 49/13
72113
outlined [2] 85/11
85/24
outlining [1] 44/15
outlook [2] 70/4 70/6
outrage [1] 74/20
outreach [7] 33/23
33/24 34/7 34/11
34/23 35/18 35/25
outside [2] 41/20
41/20
outsourced [1] 26/18
outstanding [1]
107/12
over [19] 3/18 7/12
18/11 21/18 37/20
49/17 52/17 54/14
54/19 61/20 62/1
82/18 91/7 97/15
103/16 115/19 121/13)
127/7 132/8
overcome [1] 111/14
overinflating [1] 12/8
overlooking [2]
83/22 83/23
oversight [6] 113/23
117/5 118/17 119/2
120/4 121/8

(57) novation... - oversight
[e)

overstepped [1] 99/2
owe [1] 82/23

own [17] 15/20 15/24
24/12 29/13 29/17
63/3 63/25 64/12 65/5)
75/23 82/5 113/8
113/9 117/11 140/25
141/12 145/2

owned [1] 73/19
owner [1] 115/9

P
page [39] 2/8 11/21
11/22 18/21 25/22
32/8 42/15 44/3 45/14,
45/20 49/7 50/12
55/24 56/24 57/12
59/3 67/13 67/17
68/20 70/14 74/19
84/12 84/12 91/16
101/5 102/22 103/16
103/17 103/18 105/5
123/6 124/8 124/17
125/19 128/21 128/23}
128/24 129/1 133/10
page 1 [2] 67/13
103/17
page 10 [1] 55/24
page 106 [1] 91/16
page 113 [1] 101/5
page 117 [1] 123/6
page 12 [2] 59/3
125/19
page 124 [1] 2/8
page 13 [2] 128/23
128/24
page 14 [1] 105/5
page 16 [1] 56/24
page 185 [1] 133/10
page 2 [2] 25/22 44/3
page 22 [1] 11/21
page 23 [1] 11/22
page 3 [1] 124/8
page 4 [1] 49/7
page 47 [1] 42/15
page 5 [1] 18/21
page 6 [1] 74/19
page 7 [1] 124/17
page 94 [1] 84/12
page 95 [1] 84/12
pages [1] 2/6
paid [4] 57/4 129/23
133/8 145/6
palatable [1] 21/14
panel [13] 124/4
124/10 124/19 124/19)
124/23 125/21 125/22)
126/4 126/7 126/7
126/13 126/15 126/18}
Panorama [7] 19/19
19/23 20/3 21/10
21/12 23/8 27/23

paragraph [22] 21/9
42/11 42/16 52/9 56/1
74/19 84/10 84/11
91/18 101/4 102/21
123/5 124/2 124/8
124/17 125/20 133/6
133/9 133/11 133/11
134/7 148/14
paragraph 1.3 [1]
124/8

paragraph 135 [2]
42/11 42/16
paragraph 174 [1]
148/14

paragraph 2.4 [1]
124/17

paragraph 273 [1]
84/10

Paragraph 299 [1]
91/18

paragraph 3.2 [1]
125/20

paragraph 317 [1]
101/4

paragraph 319 [1]
102/21

paragraph 326 [1]
123/5

paragraph 5.3 [1]
56/1

paragraph 574 [1]
133/9

paragraphs [3] 40/13
101/14 133/8
paragraphs 590 [1]
101/14

paragraphs 99 [1]
40/13

Parcelforce [1] 25/12
Parliament [1] 45/1
part [24] 3/16 23/2
30/5 33/24 40/3 46/6
57/8 65/5 69/5 70/12
74/21 87/18 93/3 93/5)
95/12 102/1 112/1
123/14 126/9 133/19
134/13 134/16 139/20)
145/18

Participant [1]

148/10

Participants [2]
127/24 127/25

participation [1]
155/18

particular [14] 7/2
11/10 18/2 20/25 23/2
31/16 39/3 40/8 70/14
94/13 110/10 133/9
139/20 153/20

particularly [4] 90/22
106/17 113/12 131/20)

parties [4] 103/23
104/22 105/2 105/7

parts [1] 153/16

party [10] 12/14
27/13 30/21 42/20
56/10 56/13 56/16
56/18 60/14 62/9
passionately [1] 50/6
past [10] 21/18 51/21
64/25 65/4 85/18 89/6
93/11 94/7 118/8
131/16
past' [1] 52/21
PATRICK [3] 128/2
128/4 157/6
Patterson [3] 137/23
138/13 138/16
Paul [2] 24/3 25/14
pause [1] 117/15
pausing [2] 92/3
126/11
paying [2] 139/12
147/8
payment [5] 57/7
57/7 145/4 145/5
145/9
payments [1] 59/20
PDF [1] 68/8
peace [1] 136/17
peers [1] 72/25
pence [1] 115/24
pending [1] 70/17
people [44] 9/22 10/9
12/7 15/6 15/19 19/25}
23/11 23/12 49/12
51/12 64/8 71/5 72/3
75/4 77/9 79/5 80/13
86/20 86/20 87/11
87/20 88/3 89/13 93/1
93/22 97/19 98/13
121/14 139/11 147/6
147/7 150/12 150/24
151/2 151/6 152/4
152/5 152/6 152/7
152/10 152/16 153/1
153/8 153/8
people's [1] 93/6
per [5] 10/20 23/21
23/21 88/4 96/16
perception [1] 46/5
performance [1]
83/17
performed [2] 6/1 7/5
perhaps [5] 49/14
131/3 135/22 144/10
144/21
period [18] 3/18
55/11 58/1 58/1 58/7
58/11 62/1 69/12 76/9
80/14 81/21 97/15
102/5 104/17 108/10
117/24 121/13 139/3
permit [1] 134/21
permits [1] 138/8
permitting [1] 7/13
perplexed [1] 150/7
person [12] 9/25

10/1 10/1 30/15 34/21
70/2 86/19 86/19 88/4,
96/7 97/2 151/24
personal [5] 15/20
15/22 29/13 50/16
150/2
personally [4] 13/9
61/8 94/2 122/8
perspective [1]
71/18
Perth [1] 25/1
Peter [2] 11/11 11/24
Peter's [2] 11/13 13/2
petitions [1] 56/14
phase [1] 155/21
phases [1] 155/21
phone [3] 38/14
39/24 112/11
physically [1] 152/17
piece [7] 44/15 44/18
44/18 45/5 45/12
90/21 144/22
pillars [1] 87/12
place [33] 13/1 24/19
37/10 37/17 39/8
42/22 47/12 47/18
48/11 48/25 51/17
55/12 57/23 60/15
66/10 70/11 70/20
77/19 77/25 78/6 78/6
80/16 82/22 83/18
106/15 106/21 115/3
118/4 126/22 126/24
141/12 141/23 145/12)
placed [3] 24/16
68/13 103/1
places [1] 133/20
placing [1] 126/24
plan [1] 120/1
play [4] 153/18
played [2] 3/16 74/21
playground [1] 92/21
playing [1] 121/10
plays [2] 134/13
134/15
plea [1] 105/19
please [94] 1/22 2/1
2/8 4/2 6/1 6/15 9/12
11/20 11/22 12/1 12/5
14/4 16/10 17/7 18/14}
18/21 20/14 21/11
24/23 25/22 25/24
30/8 32/5 32/13 33/2
37/4 41/1 42/11 42/14)
42/16 43/15 44/3
45/10 45/15 45/19
49/3 49/6 50/12 51/24)
52/1 55/21 55/24
56/24 58/25 59/3
59/10 66/13 66/17
67/13 67/15 67/16
68/7 68/9 68/13 68/15)
72/7 74/13 74/19
76/16 78/3 79/2 82/2

84/11 84/13 86/9
89/20 90/17 91/15
91/16 91/18 92/3
95/14 95/15 101/4
101/8 102/21 102/22
103/14 103/16 103/17)
105/5 106/3 106/23
111/7 114/1 123/5
123/10 124/6 124/8
124/17 125/19 128/1
144/7 148/22
pleased [1] 1/18
pm [3] 99/17 99/19
156/6
point [34] 6/3 11/23
12/1 13/9 14/18 22/13}
23/6 23/10 27/20
38/14 49/22 55/3 58/6I
59/6 60/1 60/2 60/8
87/19 97/13 101/9
102/2 108/9 112/22
123/1 129/16 130/19
131/10 131/14 132/5
132/10 133/2 140/20
140/21 143/2
pointed [1] 62/20
points [6] 9/2 14/21
32/18 36/23 126/6
135/20
POL [1] 17/10
POL00021485 [1]
128/13
POL00088892 [1]
124/7
POL00112043 [1]
133/3
POL00162628 [1]
22/25
police [7] 85/5 109/2
109/16 109/18 109/18)
110/11 139/24
policies [10] 56/9
82/7 105/16 121/16
121/16 121/20 122/7
122/15 125/4 125/15
policy [8] 12/2 80/16
81/2 124/6 124/21
125/3 125/16 126/16
political [4] 30/11
30/20 30/21 56/11
pool [2] 82/15 82/15
population [3]
143/14 144/5 144/10
port [1] 6/5
position [16] 45/4
61/15 65/6 67/24
71/21 75/13 90/24
113/21 126/25 129/19)
132/5 135/16 135/24
136/4 136/15 137/3
positive [1] 89/16
ively [1] 136/5
ity [5] 19/12
22/16 23/13 23/18

(58)

overstepped - possibility
~aihility 41 I 129/11

possible [10] 36/13
52/22 68/8 98/19
113/11 125/5 147/24
151/8 151/14 151/18
possibly [9] 23/24
36/17 37/9 37/18 62/3
88/1 93/25 113/17
145/21
post [257]
post-dates [1] 67/8
Postal [1] 118/24
posting [1] 94/7
postmaster [51] 3/4
6/4 10/4 23/7 33/22
35/21 37/9 37/15
37/18 38/11 38/18
38/24 39/4 39/22
39/23 39/25 50/7 53/4,
61/21 80/11 85/3 89/9
92/13 93/16 103/8
106/18 106/18 106/22)
108/13 109/20 110/4
110/7 113/16 115/16
115/17 115/18 123/9
123/14 123/15 123/17)
124/23 125/17 126/5
126/21 127/12 139/2
141/14 144/17 144/18)
155/7 155/10
postmasters [70]
13/5 28/3 30/23 50/11
51/13 53/9 53/25 54/4
54/5 55/2 55/3 61/4
63/1 63/21 64/10
73/14 73/14 75/21
75/22 75/25 76/19
76/20 77/9 77/13
79/23 80/9 87/2 87/6
87/8 87/23 91/14 92/2
92/17 92/25 93/6 94/3,
102/14 102/18 102/19}
105/10 105/14 107/6
107/16 108/2 108/6
4111/5 111/8 111/11
112/24 116/12 116/20)
118/2 119/14 119/17
126/23 126/25 127/3
127/4 128/5 131/12
131/18 138/3 139/6
139/22 141/11 142/2
142/7 142/9 142/24
146/20
postmasters' [2]
87/25 115/22
posts [1] 94/8
potential [8] 28/7
99/6 120/25 123/18
126/25 130/2 141/14
142/5
potentially [5] 37/6

47/9 49/18 113/8

power [2] 63/12
113/21
powers [1] 47/13
practical [2] 154/7
154/8
practices [1] 107/19
practised [1] 42/25
practising [1] 146/5
pre [1] 128/10
pre-GFA [1] 128/10
preclude [1] 97/7
predecessor [6]
12/21 48/2 54/12
135/15 135/21 137/9
predecessor's [2]
9/9 41/6
predecessors [1]
64/9
prefer [2] 45/11
127/18
prejudice [2] 48/14
57/5
premises [1] 134/6
preparation [1] 86/13)
prepared [7] 37/23
58/16 63/5 93/23
101/22 113/19 142/17)
preparing [1] 19/16
prescriptive [1] 88/2
present [11] 7/21
29/7 50/20 52/21 66/1
111/6 111/9 111/10
111/11 119/5 135/11
presentation [1]
74/15
presented [4] 101/22
137/6 141/22 150/20
presenting [1] 37/5
President [15] 5/4
5/13 7/19 15/11 25/8
25/10 25/19 26/6 26/9
26/16 26/20 27/7
27/10 27/11 27/16
press [1] 134/14
pressing [1] 52/13
pressure [2] 51/15
87/4
pressurise [1] 55/18
pretty [2] 32/24 60/11
prevent [1] 56/7
previously [2] 68/6
91/23
price [1] 55/7
Pricewaterhouse [3]
26/19 26/23 26/24
primarily [2] 52/25
126/12
primary [2] 61/1
4117/7
principle [1] 11/19
Principles [1] 124/9
print [2] 67/1 67/2

printer [1] 15/5
prior [8] 6/24 36/18

55/14 58/7 77/18

101/23 124/11 130/20
priorities [1] 88/10
prison [1] 32/21
private [4] 8/11

104/14 132/13 150/10
privately [2] 42/5

58/15
probably [2] 51/9

96/18
problem [24] 6/5

22/5 32/20 61/18

61/20 61/23 62/12

63/5 63/7 64/16 78/4

87/18 113/1 113/6

113/22 114/6 114/8

114/24 115/15 118/8

130/6 130/14 154/12

154/14
problematic [2]

62/21 130/11
problems [15] 15/5

15/9 15/14 22/1 28/4

28/7 32/25 44/23

49/16 52/19 53/11

53/19 54/1 111/2

111/13
procedure [1] 80/16
procedures [3] 80/20
82/8 124/21
proceed [1] 68/7
proceedings [5] 43/3
49/6 71/25 134/17

136/23
process [26] 34/19
42/18 42/22 42/25
46/8 46/16 47/6 47/12
47/16 47/18 48/21
51/17 83/15 86/11
91/5 108/11 125/18

126/3 126/10 127/8

127/17 142/25 150/5

151/18 152/21 153/18
processes [2] 107/19

126/22
Procurator [2]

150/18 150/20
produce [1] 38/7
produced [2] 32/4
103/21
product [1] 129/9
professionalism [2]
125/2 125/18
professionals [1]
83/8
programme [14]
19/19 19/22 19/23
20/4 20/10 21/10 23/8
27/24 111/21 111/22
141/8 141/9 141/10
146/21
progress [1] 121/7

progressing [1]
119/10
project [3] 81/25
82/2 111/3
prominence [1]
90/23
promote [1] 129/9
proof [1] 27/25
proper [2] 88/21
127/18
properly [2] 29/1
82/10
proportion [1]
150/12
proportional [1]
151/3
proposal [8] 114/1
116/6 117/5 119/2
120/4 120/8 124/13
127/14
proposals [4] 49/13
120/25 123/24 126/17}
propose [2] 22/25
54/14
proposed [6] 24/12
46/23 103/1 113/22
148/17 149/16
proposing [1] 102/3
prosecuted [2] 20/5
2717
prosecuting [1] 28/9
prosecution [4]
48/21 108/19 109/7
109/15
prosecutions [4]
21/15 28/23 57/24
150/10
prosecutors [1]
149/25
protect [3] 44/24
93/19 99/6
protests [1] 56/14
protracted [1] 100/22!
prove [2] 37/15 37/23
proved [1] 149/6
proven [1] 109/20
provide [21] 29/24
30/21 34/4 35/4 37/22)
37/23 38/4 39/12 46/1
54/25 63/13 76/1 85/7,
85/20 90/7 96/6 96/8
96/12 96/16 138/2
154/9
provided [19] 20/7
20/8 24/22 31/18 38/9)
39/7 58/22 78/16
81/20 83/4 85/10
88/22 90/13 101/6
126/9 129/18 147/4
147/22 151/12
provides [3] 83/4
124/18 125/21
providing [10] 20/21
37/7 37/10 84/17

88/20 119/3 119/9
122/5 140/3 153/20
provision [3] 81/12
142/5 144/1
provisions [3] 58/9
58/18 105/24
pseudonym [1] 95/7
public [8] 51/14 56/7
56/14 81/6 81/8
109/12 134/9 134/14
publication [5] 45/12
65/15 67/12 67/25
70/21
publicly [9] 42/13
43/8 49/6 58/16 81/3
105/18 134/24 135/24I
149/20
publish [3] 59/11
68/19 68/21
published [3] 44/14
66/14 68/24
publishing [1] 68/7
purchased [1] 4/3
purpose [6] 12/17
20/18 44/17 68/2
83/19 116/15
purpose’ [1] 16/23
purposes [1] 140/3
pursue [1] 138/8
pursued [1] 19/8
pursuing [2] 146/23
147/13
pursuit [1] 139/18
push [7] 61/14 62/4
114/9 114/10 114/10
120/15 121/5
pushing [1] 9/17
put [29] 7/22 22/3
28/13 36/22 50/10
64/9 64/18 65/6 69/22I
70/11 71/6 73/22 78/5I
78/6 78/16 78/17
80/10 81/9 96/20
116/1 116/1 117/13
131/4 131/16 131/21
132/18 139/3 142/1
142/19
puts [1] 10/7
putting [4] 60/10
73/21 126/22 131/18

Qu
qualification [2]
83/15 84/4
qualified [4] 146/5
146/6 146/7 146/8
quality [1] 84/5
quarterly [1] 78/20
quashed [1] 128/6
queried [1] 44/13
queries [2] 79/14
126/6

querying [1] 22/4
question [21] 17/24

iG

9) possibi

= question
Qu
question... [20] 23/15]
23/15 27/18 43/17
57/21 83/20 88/11
107/25 113/3 139/4
139/21 140/21 146/23)
147/15 150/15 150/25
151/11 151/21 153/12
154/7

Questioned [10] 1/25]
128/2 137/14 148/8
153/14 157/4 157/6
157/8 157/10 157/12
questioning [1]
137/19

questions [19] 2/17
4/1 6/18 8/13 12/18
45/24 84/21 85/2
85/23 107/3 127/19
127/22 127/23 128/5
135/3 137/13 147/2
148/13 155/15

quick [1] 133/1
quickly [5] 41/24
73/9 73/9 141/19
151/8

quid [2] 139/2 139/3
quite [16] 35/8 43/10
47/23 49/17 64/5
71/12 79/24 87/5
92/14 94/12 97/17
105/23 114/3 116/4
143/24 146/22

quote [2] 97/24
137/24

R

raise [7] 9/2 13/17
13/24 14/18 16/7
22/11 29/9

raised [17] 14/25
15/25 16/2 16/3 30/3
36/11 36/16 72/9
78/22 79/3 101/13
104/24 123/7 124/12
126/2 126/5 126/6
raises [1] 49/25
raising [4] 11/24
12/17 24/2 30/16
Ramsay [2] 24/9
25/14

ran [2] 4/7 141/9
rather [16] 2/20
27/19 39/18 60/9 61/2
64/10 64/11 77/11
86/19 97/1 106/20
107/11 110/15 117/1
131/17 150/22
rationale [3] 125/8
125/9 125/11

reach [3] 23/23 87/6
137/1

reached [1] 83/25

reaction [2] 72/11
74/18
read [14] 20/11 31/17
31/19 31/24 54/8
72/14 86/14 112/12
112/12 130/20 135/4
135/10 138/22 149/3
reading [3] 52/22
133/5 133/10
reads [20] 12/1 16/17
17/8 18/22 19/2 19/5
19/14 21/10 26/3
32/10 44/8 49/9 50/14)
57/2 59/6 67/20 74/19)
84/14 95/21 105/6
ready [1] 46/22
real [2] 89/4 89/4
realise [2] 75/5
145/19
realised [1] 71/4
reality [10] 64/4
64/12 73/12 75/1
75/10 75/19 98/7
103/3 114/17 131/15
really [57] 5/19 7/12
10/3 15/13 16/1 23/8
23/12 32/16 38/19
38/20 43/18 46/5
47/18 48/24 51/12
57/25 57/25 58/4
59/21 61/6 61/16 70/5
73/2 73/12 73/12
73/17 73/17 75/8 76/2
76/23 77/7 78/15 80/7
89/13 89/18 95/11
97/18 97/18 98/15
102/15 110/16 114/6
116/13 117/23 118/14)
120/15 130/18 130/23)
136/11 136/15 136/15)
136/16 139/1 146/14
151/5 151/8 152/9
reason [22] 2/24
11/10 11/17 37/6
41/18 41/20 67/3 93/4
93/5 96/11 96/12
96/17 97/6 97/7
104/15 109/21 127/7
139/24 141/12 141/25)
155/6 155/11
reasonable [5] 90/6
96/7 98/23 105/7
105/10
reasons [11] 65/23
90/7 91/17 94/5 95/12
96/8 98/4 123/24
133/18 134/15 134/18)
recall [9] 5/7 10/18
13/25 29/8 33/16
43/20 68/3 101/8
104/4
receive [6] 20/23
51/12 107/7 142/7
145/3 147/9

received [10] 20/10
21/18 22/3 26/24 40/5
51/9 78/8 101/12
101/18 149/1
receiving [3] 34/14
79/6 148/25
recent [4] 89/21 94/7
103/19 149/19
recently [1] 50/8
Receptionist [1] 44/6
recitals [1] 103/2
reconsider [1]
129/17
record [5] 27/1 47/1
78/12 109/12 137/10
recorded [6] 11/4
11/8 11/11 11/16
11/17 59/4
recording [2] 77/15
78/1
records [2] 154/8
155/5
recusal [1] 115/13
redress [2] 40/5
151/7
reduced [1] 115/22
refer [2] 11/2 96/5
reference [17] 11/2
11/18 11/20 11/24
16/11 16/19 18/15
20/15 22/25 24/23
25/25 27/5 32/6 42/14
55/22 103/14 123/10
referred [1] 134/14
referring [2] 83/21
92/4
reflect [3] 83/9 88/24
119/2
reflected [4] 130/8
130/12 144/12 144/13
reflecting [1] 149/23
reflection [2] 76/9
123/20
reflective [1] 150/1
refresh [2] 52/11
53/9
refusal [6] 32/19
39/11 44/16 96/13
102/9 140/7
refuse [3] 64/22
89/21 90/6
refused [4] 91/18
91/20 91/21 96/12
refusing [2] 95/18
103/3
regarding [3] 137/22
140/21 147/10
regards [2] 26/4
49/23
region [6] 5/15 16/14
18/16 20/25 88/4 88/6
regional [12] 5/20
6/24 8/4 16/1 24/5
24/6 24/8 24/17 25/1

77/20 90/22 131/23
regions [2] 4/16 4/21
registered [2] 4/12
8/7

regularly [1] 13/3
rejected [4] 7/11
103/2 123/22 123/25
rejecting [1] 7/14
relate [3] 17/10 21/20
78/23

related [6] 18/19
35/24 56/25 101/15
110/11 155/1

relates [3] 77/15
122/16 126/12
relating [3] 104/25
125/6 126/4

relation [37] 7/5 8/18
10/15 15/4 25/23
29/17 37/25 47/8
53/25 57/18 57/20
58/12 61/21 66/23
72/1 79/3 79/6 84/5
89/9 102/14 106/21
109/6 110/3 111/21
113/12 116/7 121/17
121/24 122/15 124/18
126/17 131/10 131/20}
138/25 145/22 153/16}
153/20

relationship [11]
52/2 110/18 110/19
114/6 115/14 128/10
130/8 130/15 130/23
131/14 133/15
relative [1] 105/23
relevance [1] 134/21
relevant [5] 55/24
85/5 105/21 125/24
133/18

reliability [1] 15/1
reliable [1] 138/24
reliance [1] 20/5
reliant [1] 136/21
relied [2] 133/20
134/20

relies [1] 135/1
relocation [1] 70/17
reluctance [1]

107/21

reluctantly [1] 93/17
relying [4] 135/7
135/23 138/14 138/18
remain [1] 127/20
remainder [1] 21/21
remained [4] 4/21
54/18 70/16 114/23
remaining [3] 33/2
141/23 142/21
remains [1] 110/22
remedies [1] 57/6
remember [14] 5/12
13/1 17/25 25/17
26/13 31/15 31/15

41/17 41/20 68/5
101/10 108/7 111/24
149/2
remind [1] 43/22
Reminded [1] 12/11
remit [2] 154/18
154/19
removal [1] 69/11
remove [4] 62/7
62/14 69/23 100/18
removed [7] 62/10
62/22 69/2 69/5 69/18
69/20 69/21
remuneration [4]
67/18 113/12 119/13
145/6
repayment [2] 57/1
57/8
repeat [2] 138/16
144/7
repeatedly [1] 135/24)
repeatedly-expresse
d [4] 135/24
replace [2] 111/3
114/13
reply [3] 45/7 45/12
46/14
report [7] 49/14
77/22 78/21 112/11
125/10 139/11 147/6
reported [4] 15/15
44/1 85/21 129/6
reporter [1] 44/14
reporting [3] 19/9
122/16 123/8
reports [1] 85/13
represent [7] 83/2
105/14 116/10 116/11
118/1 137/15 148/10
representation [1]
4/18
representative [7]
6/9 8/16 9/6 14/13
81/25 96/4 115/2
representatives [5]
77/19 83/1 83/5 83/17
116/10
representing [1]
81/13
represents [3] 61/5
116/12 134/3
reputation [2] 75/17
75/18
request [6] 6/20 7/3
37/25 38/7 66/24
66/25
requested [4] 24/16
85/8 108/18 124/22
require [3] 34/5 57/8
101/19
required [3] 77/19
89/19 123/13
requirement [1]
125/24

(60) question... - requirement
R

requirements [2]
144/3 144/4
researcher [1] 80/1
reservations [1]
124/3

resides [1] 62/12
Resolution [1]
124/24

resolve [1] 105/10
resources [2] 59/18
82/15

respect [8] 42/7
46/15 90/10 95/11
110/5 114/2 138/11
153/15

respectful [1] 84/16
respects [1] 106/24
respond [4] 36/16
73/6 80/11 80/13
responded [1] 72/9
responding [1] 38/13
response [12] 27/3
27/5 27/6 27/7 27/15
38/3 46/23 50/13
50/14 73/1 148/25
149/1
Responsibilities [1]
124/18
responsibility [6]
5/17 11/19 12/12 19/1
20/24 152/1
responsible [12]
6/14 7/13 18/1 19/3
19/9 36/14 64/14
81/13 83/22 94/7
124/20 127/17

rest [4] 53/5 73/23
150/13 153/2
restate [1] 105/3
restricted [1] 100/18
result [13] 19/7 22/7
28/9 31/1 34/19 63/22
82/12 87/1 118/12
126/8 140/12 142/8
152/17

resulted [8] 48/20
69/10 76/10 81/19
112/14 114/8 115/21
121/14

Retail [1] 120/13
retain [1] 17/10
retained [1] 123/13
retire [1] 50/8
retirement [1] 142/13
return [3] 27/3 30/7
99/12

reveal [2] 21/14
51/20

review [21] 124/4
124/6 124/10 124/14
124/19 124/22 124/23)
125/7 125/21 125/22

126/4 126/7 126/7
126/10 126/18 140/6
145/9 146/15 146/15
146/16 146/16
reviewed [4] 22/21
48/4 48/19 145/8
reviewing [1] 145/14
right [80] 4/5 4/12 5/5)
5/24 8/11 9/24 10/20
14/11 14/19 16/15
17/20 19/20 20/1
20/12 22/22 24/4
24/10 24/14 25/20
27/24 30/14 31/2
31/10 35/8 35/15 36/5
39/9 40/11 42/21 45/3
45/7 45/12 46/13 47/7
47/10 51/23 54/20
55/7 62/19 62/23 63/6
63/11 63/14 63/22
64/5 69/6 70/11 70/23
74/23 76/8 77/18 78/1
79/8 81/22 82/9 83/24
87/24 89/14 90/5 90/8)
90/10 93/19 99/1 99/7
102/4 110/5 110/8
113/6 115/11 116/19
117/13 117/13 122/19)
140/25 145/1 145/8
146/11 150/19 155/19)
156/4
rightly [4] 58/10
rights [1] 57/5
rise [1] 150/3
risk [4] 33/6 46/3
58/21 73/14
road [1] 118/14
Rob [3] 52/1 52/4
52/10
robust [6] 12/3
107/23 108/2 134/25
135/25 140/9
robustness [1] 26/17
role [14] 5/13 6/1
14/10 42/19 45/17
48/7 52/2 54/9 67/16
124/3 125/20 125/22
136/9 153/18
roles [2] 5/1 124/18
room [6] 41/19 41/21
53/14 54/3 63/16
137/2
rosy [1] 152/24
roughly [1] 5/8
round [3] 127/2
131/14 142/20
router [1] 52/16
Royal [2] 28/19
105/22
ruined [1] 121/14
Rule [2] 66/23 66/25
Rule 9 [1] 66/25
ruled [1] 104/16
rules [2] 89/24 97/25

ruling [5] 72/14 72/16)
73/5 102/16 106/1
run [3] 116/21 136/7
143/16

running [1] 46/16
runs [1] 2/6

rural [2] 143/13
143/21

s

sad [2] 96/24 131/22
sadly [4] 38/4 123/22
141/21 153/9
Saf [2] 108/7 137/19
safe [1] 22/8
said [55] 17/2 17/14
17/18 21/1 26/10 27/9
28/16 31/19 31/24
36/2 36/17 57/16
57/20 66/11 73/3
73/11 74/10 75/7
75/11 76/6 82/25
88/12 91/3 96/22 97/9
97/16 97/17 97/23
98/25 99/1 101/12
102/23 106/4 107/3
109/7 112/12 112/16
117/15 127/3 130/6
132/17 133/8 135/11
135/11 135/19 136/11
136/13 138/24 140/5
142/20 142/23 143/1
143/5 145/19 146/11
Sam [1] 137/15
same [12] 11/12
34/13 45/21 54/14
72/22 105/18 105/20
140/17 140/17 145/23
149/8 149/9
sat [4] 16/24 47/17
63/16 90/25
satisfactorily [1]
85/25
satisfied [1] 36/19
saw [4] 10/11 19/23
26/1 42/4
say [109] 1/18 4/2
6/13 7/3 8/15 10/7
10/10 10/22 12/17
13/19 15/16 19/22
21/22 23/24 25/16
25/19 26/12 26/14
26/15 28/5 29/8 29/12
30/10 31/22 33/13
38/10 39/6 39/15 41/5
41/13 42/16 45/2
48/24 50/20 51/6
51/16 52/11 53/2 54/8
54/23 57/16 58/10
60/12 62/9 62/12 69/4
73/8 76/8 76/22 78/2
79/8 79/15 81/19 85/1
85/16 87/10 89/1 89/2
89/12 91/19 93/22

94/16 97/1 97/20
97/22 98/8 99/5 99/24,
101/5 101/11 101/17
101/21 101/25 102/4
102/8 102/25 104/20
106/12 106/23 109/16}
110/1 110/18 110/25
113/1 116/4 117/25
121/16 121/18 121/21
122/1 123/6 123/21
130/13 131/14 137/9
137/10 138/6 143/2
143/15 143/15 143/17]
146/7 149/8 150/7
151/25 152/22 153/6
154/18 154/24
saying [21] 11/12
23/17 37/1 37/11
37/25 48/17 51/1
53/10 53/23 69/16
89/15 94/6 94/10
108/10 117/10 117/25}
121/8 121/9 138/17
150/19 155/19
says [8] 45/10 45/21
46/19 53/12 129/6
129/11 133/18 138/13
scale [4] 28/16 29/5
29/5 29/6
scam [1] 79/7
scandal [4] 114/8
137/17 150/3 153/6
scanner [1] 15/21
scanning [1] 34/21
scenes [2] 118/11
119/23
schedule [1] 111/23
scheme [5] 40/1
78/23 79/4 145/14
145/22
schemes [1] 70/8
schoolboy [1] 92/21
Scotland [31] 5/5 5/8
5/11 5/13 5/24 6/10
8/4 14/14 14/24 15/12,
24/25 35/18 36/10
148/12 149/5 149/19
149/21 149/25 150/4
150/5 150/10 150/13
150/16 150/24 151/2
151/16 151/19 151/25)
153/11 153/16 153/16
Scottish [8] 4/4 24/4
24/9 148/19 149/14
151/9 151/12 151/17
screen [14] 15/5
16/11 20/14 24/24
26/1 28/5 32/6 43/15
49/3 51/24 66/17
95/14 103/15 135/4
script [5] 122/16
122/19 123/8 123/8
123/14
scripts [1] 147/22

scroll [17] 12/5 17/7
21/9 25/24 42/15 44/3}
45/14 45/19 49/6
50/12 56/24 68/15
84/13 95/15 103/16
128/24 129/2
search [1] 154/8
sec [1] 154/23
second [11] 21/10
22/21 23/9 48/4 48/19I
52/9 81/11 129/16
132/4 139/20 154/21
secondly [5] 56/10
90/5 105/15 124/2
125/3
secretaries [4] 25/13
77/20 77/20 90/23
Secretaries’ [1]
20/16
secretary [21] 5/18
5/18 5/23 6/2 7/20
14/10 14/19 14/24
15/11 20/22 21/7
22/13 23/5 23/23 24/3I
24/5 24/6 24/8 78/8
81/16 151/12
section [7] 80/8 96/5
103/2 125/25 128/23
128/25 129/3
section 3.1 [1]
125/25
security [1] 115/21
see [57] 1/3 1/7 1/16
1/18 2/11 11/20 11/23)
13/2 13/7 13/8 13/10
14/1 15/17 19/25
25/23 29/14 32/9 33/5
33/12 40/23 44/4
45/15 49/7 50/13
56/24 59/3 59/23 62/6I
62/16 66/22 67/3 67/4
67/16 68/15 73/20
74/18 74/20 76/14
76/15 83/12 99/20
105/5 121/7 125/20
126/15 126/21 127/8
128/15 128/21 129/3
133/12 135/19 136/12
136/18 137/5 142/21
152/14
seeing [5] 83/16
119/14 119/15 137/2
143/23
seek [4] 8/14 10/4
58/21 83/7
seeking [5] 9/1 16/7
63/24 154/6 155/20
seem [1] 150/24
Seema [3] 19/24
32/21 43/6
seemed [2] 32/1
109/19
seems [2] 104/10
138/7

(61) requirements - seems
Ss

seen [7] 9/15 23/21
61/20 106/21 115/20
137/3 140/13
sending [1] 34/13
senior [9] 38/16
62/18 89/7 100/13
110/22 112/20 120/22
126/20 151/24
sense [5] 74/3 75/15
131/22 141/20 145/20)
sensible [1] 99/9
sent [6] 32/5 32/21
72/13 95/17 101/24
149/8
sentence [2] 21/11
30/6
separate [4] 4/15
4/16 44/15 44/18
September [6] 1/1
2/4 8/10 66/22 67/4
103/19
series [1] 6/18
serious [3] 59/22
111/20 111/20
seriously [1] 121/11
serve [1] 34/4
served [2] 3/5 14/23
service [6] 28/18
63/1 83/11 114/7
115/15 118/11
services [7] 34/5
76/1 112/15 116/22
143/17 143/22 144/1
set [11] 18/14 21/16
34/1 34/3 42/19 47/1
93/4 105/3 114/21
124/21 125/25
Seven [1] 5/9
several [1] 148/18
shake [2] 41/15 42/2
shall [5] 27/5 56/2
56/6 99/12 105/7
shape [10] 10/2
48/15 50/9 51/15 55/9)
55/18 86/24 130/19
142/17 143/7
share [1] 41/5
shareholder [4]
115/10 116/9 117/11
118/3
sharing [1] 46/13
she [19] 32/23 45/18
45/21 46/19 60/1
70/11 70/12 70/13
70/13 70/14 70/21
71/2 71/4 71/5 7116
115/7 149/20 149/22
149/23
shift [4] 63/24 64/14
90/20 142/17
shiny [1] 21/13
shocking [1] 40/6

shop [1] 119/18
Shoreham [3] 20/22
21/1 21/5
short [9] 1/11 1/14
26/1 40/21 43/5 82/23
99/18 146/22 153/11
shortages [1] 138/25
shortfall [7] 32/23
40/1 78/23 107/2
138/15 138/18 139/9
shortfalls [11] 88/19
107/17 108/3 138/4
138/8 139/12 139/14
139/18 140/16 147/8
147/9
shortly [2] 20/10
99/25
should [33] 2/3 12/11
32/24 39/10 46/1 49/5)
50/25 62/10 74/20
85/3 87/6 87/9 92/25
93/7 93/8 94/3 102/19)
109/2 120/23 127/16
134/1 134/23 138/14
138/17 139/14 140/1
140/15 145/15 146/14)
146/22 151/19 152/2
154/24
shouldn't [2] 139/1
142/14
show [5] 22/20 27/11
58/15 60/4 95/11
showing [1] 72/1
shown [13] 11/1
16/11 20/14 23/1
24/23 32/6 43/15 49/3
51/24 66/17 95/14
103/14 153/24
shows [1] 20/8
shut [4] 141/23
side [9] 21/14 46/10
64/5 81/6 81/6 81/7
81/8 81/10 135/13
sides [1] 81/5
Sight [3] 22/21 48/4
48/19
sign [1] 123/13
signature [1] 2/11
signed [1] 103/10
significant [7] 43/2
97/17 101/19 102/5
105/23 117/24 142/10)
significantly [2] 67/8
144/20
signing [2] 27/4 30/7
similar [4] 7/8 7/9
32/1 36/15
simple [5] 43/10
60/23 64/12 85/15
131/15
simplest [1] 96/18
simply [9] 22/3 36/17
37/13 43/10 51/18
63/18 82/22 99/5

112/16
since [8] 3/5 14/11
38/21 67/23 86/25
91/22 103/21 128/6
Sinclair [1] 148/11
single [2] 92/17
119/11
sir [23] 1/3 1/5 1/8
1/9 1/10 1/16 3/11
30/19 40/7 40/14
40/17 40/23 41/3
41/15 41/21 86/14
99/8 99/20 153/14
154/19 155/16 156/3
157/12
Sir Alan [4] 3/11 41/3
41/15 41/21
Sir John [1] 86/14
Sir Wyn [1] 154/19
sit [8] 40/4 83/13
83/16 87/10 88/7
114/13 114/15 126/18
site [1] 92/16
[2] 97/2 97/3
ing [4] 13/7 112/9
114/4 152/10
situation [12] 32/2
36/14 55/15 82/17
107/9 107/14 114/12
123/19 127/10 132/1
142/24 144/15
situations [1] 127/5
six [2] 37/2 82/25
sixth [1] 17/7
skip [1] 134/7
slightly [4] 11/13
slow [1] 114/14
small [5] 33/25 82/11
82/14 131/5 131/6
smaller [2] 143/13
144/23
so [190]
social [15] 20/20
72/22 76/7 91/25 92/5)
92/12 92/16 94/7
94/18 98/1 98/3
116/15 143/5 143/25
144/1
society [1] 116/16
software [6] 15/23
16/22 17/11 28/7
52/15 107/18
solicitor [2] 109/22
110/1
solicitors [1] 101/22
solution [1] 113/22
some [47] 1/7 3/8 4/1
8/13 12/19 15/19 16/6
21/17 25/23 26/24
45/8 48/15 51/12 52/8
56/23 58/25 69/5 85/4
87/4 88/24 89/12
89/15 90/21 91/25
92/12 93/11 93/21

97/18 101/9 102/2
107/12 109/21 121/7
124/2 127/14 127/22
127/23 127/23 129/23}
132/9 134/18 134/22
138/23 143/5 145/2
152/13 152/23
someone [16] 10/7
15/3 15/17 42/24 53/5)
72/19 84/23 91/1
91/23 98/9 98/9
127/11 142/21 150/8
152/13 155/10
something [37] 2/20
6/22 17/4 23/10 23/16)
23/25 26/13 29/3
30/15 31/17 31/17
31/19 31/24 35/8
39/15 41/25 46/12
53/22 61/24 71/12
73/8 83/12 91/6 97/2
97/3 106/15 108/4
108/25 117/25 120/20)
120/22 122/2 127/1
131/3 145/11 150/6
152/11
something's [1]
27124
sometimes [3] 12/9
97/4 98/15
somewhat [1] 74/2
soon [1] 68/8
sore [1] 39/18
sorry [40] 1/20 8/20
8/24 8/25 13/19 13/22
17/24 18/13 21/5 25/8}
26/14 30/14 34/16
34/17 35/13 37/4
43/16 43/18 43/19
47/19 48/10 48/24
66/20 74/6 89/6 94/13
95/15 98/15 100/4
100/9 109/16 116/1
118/13 135/4 136/19
141/18 151/22 152/22}
153/6 153/12
sort [72] 11/12 13/9
15/25 16/4 25/8 27/23}
28/13 29/14 31/14
37/24 38/21 50/4 53/3)
53/7 53/8 53/20 54/7
58/24 58/24 61/6
61/18 62/6 62/9 64/3
64/15 71/14 72/19
73/20 75/5 75/10
75/18 75/21 75/25
76/6 76/13 77/4 78/5
78/10 82/4 83/12
85/14 85/16 86/18
87/5 87/19 87/20 89/1
93/7 96/18 97/13 98/8,
106/11 107/1 108/25
109/25 117/20 117/21
118/14 119/10 119/21

120/15 136/8 136/12
137/5 141/17 143/2
150/7 150/20 151/1
151/4 151/25 154/15
sorted [2] 63/19
151/10
sought [2] 21/12
110/3
sound [3] 22/8 23/19
76/16
sounds [2] 79/13
147/18
south [7] 5/45/11
5/13 5/24 14/24 15/12I
109/23
speak [4] 1/9 43/8
54/11 72/18
speaking [2] 139/6
141/18
specific [7] 11/17
30/10 73/4 92/10
96/16 101/13 149/2
specifically [6] 15/16
25/18 26/23 32/22
92/23 94/11
specifics [3] 31/15
92/9 109/3
speeding [1] 153/18
SPM [1] 4/7
SPMs [2] 22/20 33/3
spoken [1] 120/16
spotlight [2] 21/8
26/4
spots [1] 101/2
spread [1] 80/6
spreadsheet [2] 78/7
78/20
squarely [1] 64/1
staff [2] 12/10 122/24
stage [10] 8/7 14/10
27/16 27/18 43/1
50/19 59/2 69/8
109/10 142/11
stakeholders [1]
105/21
stance [7] 10/14
12/20 12/25 35/6
47/22 55/19 135/2
stand [2] 45/23 129/8)
standard [3] 80/12
87/9 94/3
standards [3] 80/2
87/6 92/24
Standing [4] 6/10
14/14 18/4 18/7
start [7] 40/16 66/1
73/12 133/10 142/19
152/2 156/1
started [2] 60/1
14119
starting [5] 23/9
23/14 27/21 60/3
121/7
state [4] 10/18

(62) seen - state
Ss

state... [3] 105/19
142/12 148/14
stated [2] 10/22
142/16
statement [74] 2/4
2/6 2/9 2/13 2/18 4/14
6/13 8/15 9/3 9/8
10/12 11/2 12/17 14/6)
14/16 17/3 19/18
19/22 22/9 23/17
28/17 29/8 35/16
36/22 38/10 40/13
41/5 42/12 42/14 45/7)
45/9 47/3 54/22 57/16)
58/6 65/9 69/4 70/19
71/5 73/22 78/19
79/17 81/15 82/25
84/7 84/10 86/5 88/17
89/2 89/25 91/15
96/10 100/10 100/14
101/4 103/21 108/16
110/18 112/1 113/1
118/22 120/3 120/9
121/19 122/1 122/14
123/5 131/8 131/21
140/21 142/23 146/4
148/14 155/23
statements [1] 73/21
states [3] 103/22
124/9 137/24
station [1] 2/23
statistician [1] 79/25
status [3] 19/5 19/10
120/7
statutory [1] 155/21
stealing [1] 43/7
steeper [1] 76/22
steering [3] 16/23
16/24 17/5
STEIN [3] 137/14
137/15 157/8
step [5] 2/23 46/4
76/24 115/4 122/11
steps [4] 12/23 29/9
38/6 129/20
still [27] 3/6 10/23
28/15 40/5 46/1 50/20
62/22 75/22 79/3
79/12 89/11 89/11
106/13 106/24 107/6
107/16 107/22 114/24}
127/7 139/12 141/5
145/3 147/6 147/7
147/8 150/21 151/17
stock [6] 34/7 34/11
34/13 34/14 34/24
35/24
stolen [1] 19/25
stop [4] 30/14 37/4
129/1 136/14
stopped [2] 57/24
155/10

story [4] 32/17
111/19 111/20 120/15)
straight [4] 39/24
47/2 62/6 64/8
strained [1] 110/20
strange [1] 135/12
strategies [2] 56/9
105/16
strategy [5] 111/15
114/21 114/22 117/22)
118/4
stress [2] 92/14
110/7
stressful [1] 123/19
strong [1] 52/21
stronger [1] 52/20
structure [1] 76/12
struggle [1] 28/15
struggling [1] 143/24
stuck [1] 38/21
studiously [1] 136/5
stuff [2] 51/12 76/7
stumbling [1] 102/8
stunned [2] 28/14
75/14
subject [7] 21/24
52/10 67/20 70/22
106/4 133/18 134/22
submissions [1]
133/21
submitted [5] 16/9
16/13 17/16 18/16
134/1
subpostmaster [22]
19/1 31/8 35/17 36/7
50/1 50/25 59/8 59/11
78/17 90/2 108/17
108/23 109/10 113/5
122/24 129/4 129/8
140/1 144/14 148/11
155/1 155/3
subpostmaster's [2]
121/25 124/15
subpostmasters [37]
3/23 12/9 19/3 20/5
21/4 21/15 21/19 22/4
22/6 27/17 33/7 43/25
44/25 46/6 48/3 49/13
58/23 59/9 59/17
60/20 61/3 81/13
81/21 83/2 84/9 85/10
87/11 104/1 130/8
1314/5 134/2 134/3
137/16 138/1 140/11
140/24 151/14
subsequent [1]
104/14
subsequently [1]
69/22
subsidiary [1] 129/7
subsidies [2] 129/23
130/3
subsidy [1] 129/17
successful [1]

148/25
successfully [1]
148/12
such [13] 3/10 28/25
37/12 37/12 57/12
75/6 78/1 102/15
105/11 105/21 121/13
138/15 138/18
sudden [1] 41/21
suffer [1] 63/21
sufficient [1] 134/21
suggest [8] 29/5 45/8)
46/12 60/18 100/25
110/22 123/8 130/20
suggested [4] 63/23
74/1 123/17 129/21
suggesting [1] 74/8
suggests [2] 50/23
129/22
suite [1] 121/20
summarise [1] 74/24
summary [2] 65/16
66/4
summation [1] 11/14
summer [1] 14/7
Supervisor [1] 44/6
supplied [1] 80/21
suppliers [1] 54/2
supply [2] 21/24 38/1
support [39] 5/17
22/20 39/12 39/23
42/15 43/8 46/4 47/2
48/3 48/7 54/11 55/1
55/2 58/15 60/7 64/22
66/3 81/20 83/7 89/17
91/14 105/20 108/18
110/5 123/16 132/13
133/22 134/5 134/9
134/10 134/17 135/1
135/2 135/7 136/21
136/25 137/25 138/2
140/4
supported [2] 124/23
134/24
supporting [3] 48/18
48/22 84/9
supportive [2] 73/24
135/15
suppose [1] 27/14
supposed [1] 102/17
suppressed [3]
118/15 118/16 118/16
sure [20] 43/19 53/24
62/5 72/4 75/21 75/23
75/25 80/4 82/16
82/20 87/23 87/25
91/8 92/7 94/4 109/4
144/21 151/6 152/12
155/19
surface [3] 118/7
118/15 118/19
surprise [1] 15/9
surprised [1] 75/1
surrounding [1]

32/17

survey [1] 80/12
surveys [2] 79/18
79/22

survival [1] 61/1
survives [1] 75/24
Susan [1] 148/11
suspend [1] 57/6
Suspending [1] 57/1

121/25
suspensions [1]
121/18
suspicion [1] 98/19
suspicious [5] 65/20
65/24 71/13 71/20
75/12
sworn [3] 1/23 1/24
157/2
sympathy [2] 58/13
113/15
system [25] 10/23
12/3 12/4 12/6 15/1
16/21 22/8 23/20 26/5}
26/17 28/4 47/13
52/14 52/16 52/17
53/1 53/4 53/25 77/18
77/25 107/15 108/1
140/2 140/15 147/7
systematically [1]
12/6
systemic [3] 10/23
21/16 22/4
systems [2] 26/8
83/18

T

take [44] 1/10 10/10
12/9 12/10 12/23
13/12 22/25 34/2 34/8}
34/25 35/14 37/10
37/17 38/6 40/9 42/22,
47/12 47/18 47/23
51/17 58/25 59/17
61/6 72/17 72/20
76/18 76/19 77/7
87/15 87/24 98/9 99/1
99/13 106/1 129/21
131/11 141/14 142/22}
144/19 148/2 150/18

taken [23] 7/1 10/8
10/14 39/7 44/21
49/16 59/8 70/13 78/3
80/19 82/22 100/15
102/1 111/23 115/3
116/22 122/10 123/20
125/23 127/10 136/4
137/7 138/2

taking [8] 29/8 55/17
55/19 64/3 76/24
79/10 82/5 88/18

talk [4] 13/4 32/16
65/5 92/8

talked [2] 118/9

suspension [2] 82/12)

119/6
talking [8] 8/24 37/20
108/8 119/18 119/18
119/24 150/8 152/12
talks [1] 102/13
target [2] 92/17
92/23
targeted [1] 94/14
team [6] 49/4 80/23
82/11 82/14 89/3
112/5
telecommunications
[1] 107/19
telephone [2] 21/19
33/4
tell [3] 18/18 32/25
128/14
telling [3] 10/18
108/1 140/8
tells [2] 120/15
120/20
ten [4] 4/15 88/3
92/15 142/24
tenacity [1] 3/12
tend [2] 143/18
144/11
tenet [3] 102/15
102/24 103/4
tension [1] 105/8
term [3] 57/11 79/25
103/1
terminate [3] 82/24
124/14 125/23
terminated [1] 39/6
termination [5] 82/13
121/25 124/12 125/6
125/7
terms [11] 28/18
54/18 55/21 72/2
84/16 84/19 84/19
141/6 143/25 144/9
151/15
test [1] 88/16
than [23] 15/21 27/19)
34/24 45/13 47/14
60/9 61/2 64/10 64/11
77/11 79/14 85/18
86/19 88/4 89/5 92/10
106/20 107/11 110/15}
117/1 131/17 150/6
150/22
thank [62] 1/20 2/25
3/10 3/20 3/21 11/23
16/12 17/7 18/22
20/16 31/2 31/3 32/8
40/7 40/19 40/24
40/25 42/3 42/14
42/15 42/16 43/4
43/23 45/19 50/13
52/9 55/23 66/17
67/13 84/7 84/11
84/12 84/13 91/15
91/19 95/14 95/16
95/23 99/8 99/16

(63) state... - thank
T

thank... [22] 99/21
99/22 100/1 100/9
103/16 103/17 103/18
121/15 123/6 123/12
124/7 127/19 127/21
129/2 132/4 132/7
137/13 148/7 153/13
155/17 155/25 156/5
thankfully [4] 40/3
50/7 62/11 110/8
thanks [4] 40/15
45/22 46/13 156/4
that [1089]
that's [98] 10/8 10/11
16/19 21/22 27/14
28/22 29/3 30/2 37/1
40/14 46/10 47/20
48/10 52/6 53/4 54/6
54/8 57/20 57/21
61/22 63/4 63/5 64/3
65/20 66/6 66/11
66/22 67/2 67/3 67/7
70/14 76/4 80/18 81/1
81/9 81/18 83/20 84/8
84/10 86/10 88/9
88/16 90/13 94/1 94/2
94/2 96/15 96/23
96/25 97/12 97/13
98/6 98/13 99/15
100/1 102/19 105/25
106/9 106/11 112/3
112/20 115/9 116/5
116/6 117/25 119/19
121/3 122/2 122/19
124/7 126/24 127/4
130/7 135/12 137/6
137/9 141/2 142/16
143/19 143/21 144/18)
144/19 146/15 147/15)
150/16 150/25 151/21
152/2 152/9 152/15
152/24 154/12 154/14)
154/17 154/18 154/18)
154/19 155/14
thats [1] 82/14
theatre [1] 112/10
their [57] 3/12 3/12
3/13 3/13 3/15 10/4
10/4 10/5 12/8 14/18
23/12 35/25 38/3
39/16 48/8 51/4 52/24
53/22 59/15 64/9
64/11 76/1 77/23
82/15 82/15 87/3 87/3
94/8 95/7 95/13 98/5
98/12 102/9 102/10
106/7 106/18 108/18
113/8 113/8 115/21
116/21 121/14 122/22
128/6 129/21 131/16
131/18 134/3 135/7
138/8 139/3 139/6

146/3 149/11 151/7
153/2 155/1
them [45] 3/14 7/8
7/14 7/22 8/1 13/8
13/9 13/10 19/25 34/4
34/5 38/2 39/2 39/14
39/17 55/9 61/5 62/10
62/14 79/9 80/23
86/21 89/17 89/18
90/23 92/18 92/23
93/25 94/12 97/5
98/11 108/1 137/3
1414/7 141/12 141/24
145/2 147/24 148/23
149/11 152/13 152/19)
152/22 152/22 153/7
themes [1] 7/23
themselves [2] 87/8
115/5
then [58] 5/20 6/22
6/25 7/22 10/10 10/15
19/2 19/7 20/11 24/3
24/9 26/15 29/2 32/23
33/4 34/3 35/6 40/2
43/8 45/8 45/19 46/19)
48/7 53/20 57/24
60/23 61/11 61/15
62/24 65/14 69/22
78/12 78/16 81/6 85/3
88/6 91/10 91/10 98/4
98/23 99/12 101/24
102/19 103/17 104/15)
104/18 105/23 107/7
117/10 120/12 127/2
129/19 138/13 145/6
147/1 150/20 155/13
155/17
there [172]
there's [41] 2/18 23/2
23/10 23/17 28/22
41/19 67/13 72/18
78/7 78/14 81/5 81/5
85/20 86/25 88/4
90/20 90/24 91/10
93/7 93/8 93/9 93/9
97/10 97/21 98/14
105/5 106/17 107/3
107/20 107/22 115/2
119/19 128/22 129/6
129/10 149/16 152/6
152/8 153/23 154/4
155/13
therefore [21] 9/24
23/22 29/4 37/21
42/21 47/12 48/21
58/3 67/6 82/9 87/7
87/22 93/2 93/15
93/17 95/11 103/8
105/2 113/9 118/1
135/1
these [39] 7/6 15/14
16/10 17/15 17/22
18/2 18/16 20/23
26/18 27/11 31/23

32/25 45/23 46/14
56/4 57/17 58/9 60/4
60/18 62/7 62/8 62/20
65/23 69/10 71/8
71/10 74/13 75/4
83/17 85/2 85/4 85/23
107/12 108/8 111/14
127/5 148/23 151/6
153/8
they [150] 3/18 7/21
11/2 13/10 14/18 16/9
17/15 18/14 18/18
27/11 29/2 33/24 34/1
34/2 34/3 34/4 34/5
37/6 37/7 37/8 37/8
37/10 37/11 37/12
37/25 38/4 38/4 38/5
38/11 38/13 39/15
39/15 39/19 44/23
48/20 53/10 54/6 58/9
58/11 60/4 60/18
61/11 62/10 62/11
63/5 64/10 64/12
64/16 64/24 69/12
69/15 69/17 73/3
73/20 76/3 78/9 78/9
79/20 80/24 81/8 82/9
83/8 83/11 84/25
85/18 85/20 85/24
87/13 88/1 88/5 89/18
93/23 93/23 93/23
93/24 93/24 93/25
93/25 94/11 95/6 95/7
96/19 98/10 98/10
98/10 98/10 98/11
98/25 100/25 102/9
102/19 106/10 107/1
107/6 107/7 107/13
108/13 109/19 109/21
4110/2 110/2 110/4
113/7 113/9 113/10
113/11 113/17 113/17I
114/24 114/24 115/6
118/20 119/8 120/1
4123/1 124/1 127/3
129/18 129/19 139/3
139/3 140/1 141/22
141/22 142/1 142/4
142/6 142/6 142/14
142/19 142/20 142/20
143/22 145/15 145/25I
146/1 147/5 147/8
147/11 149/11 1514/7
4151/7 152/7 152/7
152/8 152/8 152/9
152/17 153/2 155/7
they'd [1] 155/2
They'll [1] 107/2
they're [15] 28/13
51/13 62/18 80/1
80/22 81/3 81/4 81/6
93/22 116/8 119/25
126/23 129/20 145/15I
152/5

they've [7] 3/17 3/17
79/5 79/7 79/7 89/10
149/6
thing [4] 47/10 82/7
85/14 91/5
things [25] 9/22 30/3
39/1 49/11 71/3 75/4
75/7 75/11 78/5 79/12
82/8 83/25 90/22 99/3
110/4 113/12 114/14
114/14 117/12 118/5
119/22 129/20 145/20}
153/4 154/15
think [171]
think's [1] 146/11
thinking [3] 27/24
114/4 115/10
third [9] 16/17 21/9
50/12 56/10 56/13
56/16 56/18 59/5
7419
Thirdly [3] 56/13
105/18 125/5
this [259]
Thomas [2] 19/24
43/6
Thomson [6] 20/11
22/15 27/7 44/25
67/14 68/16
Thomson's [1] 9/13
Thornton [1] 121/2
thorough [1] 84/18
those [56] 3/10 7/9
7/19 7/24 11/4 22/17
28/9 30/1 47/14 48/19
54/4 56/23 58/18
62/22 72/23 73/4 76/2
76/15 76/22 79/13
79/22 80/22 81/12
83/5 85/15 86/7 88/23)
91/11 100/22 101/15
101/15 104/24 105/9
108/23 112/7 113/15
116/9 116/23 116/24
118/1 126/25 132/2
136/25 142/4 142/5
142/9 142/12 143/22
143/23 143/24 144/24]
14713 147/12 147/23
149/22 154/9
though [2] 48/20
58/20
thought [9] 7/9 8/24
47/22 48/14 79/7
86/16 96/15 135/12
152/21
thoughts [2] 6/18
9/7
thousands [1] 21/19
threatening [1]
131/11
threatens [1] 113/20
three [3] 37/19 84/20
107/3

thrives [1] 75/24
through [17] 7/19
22/1 51/19 62/4 66/24I
70/1 70/9 77/4 78/13
83/24 91/2 110/6
113/16 131/23 142/2
147/6 153/24
throughout [4] 4/22
125/18 146/22 155/20)
throw [1] 43/12
thrown [1] 109/11
Thursday [2] 1/1
112/18
thus [3] 49/19 52/19
151/14
tickets [1] 112/9
tier [1] 145/4
Tim [4] 31/8 31/14
31/18 111/9
time [89] 3/18 4/12
4/22 5/8 5/11 5/22
10/20 13/16 14/4
14/23 17/1 17/2 17/15)
17/19 18/9 20/21
21/17 23/22 24/5 24/8I
25/15 25/20 26/1
27/22 28/1 28/11
29/14 30/3 30/4 31/8
33/23 33/24 38/17
40/9 43/5 47/21 48/23)
53/9 53/25 55/11 58/1
58/1 60/5 63/9 63/9
63/10 63/16 63/17
65/24 66/16 68/4
69/12 70/15 70/25
7217 72/20 72/22
73/21 74/4 74/9 75/8
75/22 77/4 99/5 99/5
100/14 103/21 104/18)
108/10 117/24 119/11
120/24 121/13 122/11
122/12 128/16 128/20)
131/14 135/9 135/21
138/22 139/25 141/4
141/24 149/9 151/19
153/5 153/25 155/9
times [1] 34/9
Timpson [1] 86/12
Timpson's [1] 86/14
title [2] 24/25 49/8
today [19] 1/22 3/3
3/6 3/9 3/14 23/21
40/4 50/20 53/19
57/17 61/22 62/15
96/10 112/19 130/6
130/16 143/16 148/13}
155/24
toe [1] 12/14
together [12] 7/9
63/2 82/15 82/15
82/16 108/6 116/1
116/2 119/20 120/11
128/4 128/21
toilet [1] 41/25

(64) thank... - toilet
T

told [18] 33/16 34/25
36/3 43/5 70/15 88/20
108/1 111/12 112/14
112/17 112/17 112/24
120/12 130/15 138/21
140/14 140/17 155/6
tomorrow [1] 156/2
tone [2] 70/9 97/21
too [7] 23/13 50/21
68/21 99/4 127/7
141/18 145/25
took [8] 13/1 13/13
18/11 24/19 42/19
54/19 60/15 106/21
top [7] 18/17 45/19
59/23 62/17 66/21
67/6 74/19
topic [7] 40/8 72/7
89/20 99/9 100/2
121/15 146/22
topics [1] 45/8
totally [1] 59/16
towards [9] 9/20 41/6
93/16 95/11 102/10
102/17 102/19 103/8
144/24
toxicity [2] 9/19 87/1
TR:5 [1] 24/18
track [1] 111/14
trade [6] 4/12 8/8
54/5 58/3 104/17
107/24
trading [1] 139/3
traditional [1] 80/6
trained [3] 72/19
82/10 83/1
training [4] 81/12
81/16 83/4 142/2
trajectory [1] 63/20
transaction [1] 145/7
transcript [2] 22/24
103/13
transfer [3] 34/6
34/10 35/24
Transformation [12]
16/4 21/21 29/17
140/22 141/3 141/4
141/8 143/11 145/14
145/17 145/24 146/20)
translate [1] 30/8
transparency [5]
71/25 111/17 118/10
125/1 125/17
transparent [7] 72/6
85/18 89/5 95/10
98/18 106/20 107/11
Travel [1] 129/8
treated [2] 38/24
125/17
trends [1] 147/11
trial [17] 41/14 44/12
65/18 66/2 66/2 69/15

69/18 69/20 70/22
71/9 74/5 74/22
132/11 132/18 135/6
136/2 136/23
trick [1] 61/14
tried [7] 51/10 78/5
90/21 98/8 98/24
113/17 140/6
tripartite [2] 118/23
119/8
triple [4] 34/20
Trotter [3] 36/8 36/11
36/16
trouble [1] 47/10
true [1] 2/13
truly [1] 136/15
trust [3] 110/22
133/4 152/18
trusted [1] 73/18
truth [6] 3/6 3/7 3/7
47/15 47/15 47/16
truthful [1] 37/7
truths [1] 3/8
try [8] 7/22 12/19
17/3 23/23 50/10 77/9)
89/18 113/17
trying [16] 51/16 53/2
53/7 53/24 54/6 54/8
64/14 64/15 71/21
76/2 76/15 76/23
97/20 119/7 121/5
149/4
tube [1] 2/22
Tuesday [1] 92/20
turn [11] 2/8 18/21
25/22 59/3 90/17
113/18 124/6 127/2
131/14 140/20 152/12)
turned [2] 53/15
136/24
turning [1] 98/20
two [23] 7/10 25/15
36/22 45/6 49/11
76/25 78/12 79/21
81/5 83/21 89/9
113/15 115/11 121/6
122/14 126/19 128/7
128/8 133/8 134/18
139/5 145/20 151/13
two years [1] 121/6
tying [1] 53/18
type [2] 32/20 55/8

Uo
UK [1] 148/17

UK Government [1]
148/17

ultimately [4] 7/16
50/1 59/21 110/8
unacceptable [3]
59/16 93/10 98/5
unbiased [1] 126/1
uncomfortable [1]
3/8

under [16] 19/5 21/8
26/4 42/18 55/24
57/12 57/15 59/5
110/7 118/21 124/8
124/17 125/19 133/15}
146/8 146/20
underlined [1] 134/4
underlying [2] 117/7
142/13
undermine [4] 72/24
96/22 113/20 129/18
undermined [1]
115/22
underneath [1] 21/13
underpinning [1]
124/25
understand [20] 13/7
13/10 23/9 26/9 27/6
28/15 47/12 71/11
71/14 71/18 72/15
72/17 72/20 72/21
93/6 94/5 116/25
126/12 141/2 144/21
understandably [3]
30/2 59/13 87/2
understanding [17]
28/6 33/21 34/10
34/12 34/18 47/15
48/24 73/2 80/8 84/5
84/18 85/17 91/2
114/5 124/16 126/19
152/3
understood [1] 94/5
undertake [4] 56/7
56/11 126/7 148/2
undertaken [1] 79/20
undertaking [1]
56/10
unequal [1] 143/12
unfair [1] 143/12
unfortunately [10]
35/3 36/24 39/2 65/2
113/14 114/18 132/1
142/22 153/8 155/12
unhelpful [1] 147/5
unincorporated [3]
103/25 104/13 104/17]
union [5] 4/12 8/8
31/9 58/3 104/17
unit [1] 15/5
Unite [1] 116/10
United [3] 4/19
153/17 154/11
unity [4] 63/2
unreliable [3] 139/17
139/18 140/3
unsurprisingly [1]
135/22
until [10] 4/8 16/22
37/22 39/18 46/18
58/10 71/1 104/18
109/20 156/7
unwillingness [1]
103/7

unwise [1] 50/18
up [36] 14/3 23/10
29/5 34/1 37/14 38/6
38/22 38/25 42/11
45/14 45/19 45/23
46/4 50/12 53/16 54/2
59/18 68/15 69/22
70/6 86/20 91/15 93/4
99/13 101/4 112/11
116/5 122/10 128/14
129/2 133/4 135/4
136/24 139/12 148/3
153/18
update [4] 59/24
59/24 104/9 119/9
updates [1] 132/18
upon [10] 41/9 57/18
75/16 122/7 131/24
133/21 134/20 135/1
140/24 143/13
Upside [1] 86/14
upstanding [1] 87/12
urban [1] 143/21
us [41] 16/24 18/18
22/6 28/10 37/14
38/20 46/8 46/13
46/20 47/10 50/18
51/15 51/23 53/10
67/22 70/10 72/25
75/9 76/4 76/24 77/2
79/8 82/23 82/24 83/8
83/13 83/16 84/3 87/8
87/19 87/23 95/10
99/8 99/20 109/21
112/14 120/10 128/20
133/19 141/2 149/10
us' [1] 68/20
usage [1] 20/19
use [9] 55/3 61/13
79/18 92/12 93/25
105/7 105/10 130/3
146/6
used [10] 3/5 15/3
15/20 84/24 96/22
99/3 107/5 122/19
125/11 140/15
uses [1] 53/5
using [7] 15/3 15/17
15/18 28/4 72/23 76/3
138/8
usually [3] 85/20
145/10 145/10

Vo
valid [1] 11/14
validated [1] 16/22
values [1] 70/8

van [1] 134/23
various [2] 5/1 20/20
vast [2] 10/5 10/5
vein [1] 7/8

verdict [1] 50/17
version [3] 68/8
68/10 124/8

versus [1] 143/24
very [43] 1/20 9/16
29/18 36/15 40/15
42/16 43/4 44/19 50/8
50/13 51/8 55/9 55/12
59/21 71/2 73/8 73/9
73/23 80/7 84/12 85/4I
87/2 87/2 87/14 87/18)
98/3 103/19 110/20
111/18 120/12 128/24}
133/12 133/13 135/15)
137/4 141/16 149/2
149/10 149/11 155/17)
155/22 155/23 156/4
via [5] 20/22 50/25

68/6 68/7 121/3
viability [2] 87/3
115/21
viable [1] 88/1
Vice [1] 25/8
victimisation [1] 29/6]
i ised [1] 151/3
victims [3] 73/25
114/23 132/3
view [26] 9/17 10/8
10/8 13/3 13/6 13/12
48/1 50/10 51/22
55/16 55/19 60/10
60/11 60/12 60/13
61/15 61/23 64/25
112/22 114/17 115/1
118/1 127/16 134/25
135/19 151/19
viewing [1] 122/5
viewpoint [4] 50/16
135/18 137/7 137/8
viewpoints [2] 55/14
86/22
views [3] 10/4 62/4
79/17
vilest [1] 51/9
village [1] 4/4
virtually [2] 53/16
63/15
vision [1] 70/7
vitally [1] 53/6
voice [2] 70/9 103/5
voices [1] 86/22
volume [1] 21/7
volume 24 [1] 21/7
volunteered [1]
154/2
vote [2] 88/5 113/11
voting [1] 126/20

W

wait [1] 47/11
waiting [2] 47/18
136/17

walks [1] 13/3
wall [1] 39/18
Wallis [3] 43/24
43/25 132/19
Wallis’ [4] 71/2

<

(65) told - Wallis’
Ww

want [35] 10/3 34/10
35/9 39/15 48/15
50/17 62/25 62/25
75/23 75/24 86/19
86/20 86/20 88/2
88/16 89/13 92/10
93/3 93/4 93/5 93/21
93/23 93/24 93/24
98/10 98/10 98/11
128/7 128/13 128/20
128/23 132/9 133/2
133/19 143/6

wanted [7] 3/6 70/5
73/7 75/20 75/21 94/4)
124/1

wanting [2] 62/5
141/13

was [406]

wasn't [28] 9/23
15/19 16/1 43/18
43/19 51/22 52/5
60/14 60/14 62/9 71/1
71/15 71/16 75/12
75/14 76/5 82/13 95/8
108/25 109/16 109/17
118/14 121/1 130/3
130/18 132/22 136/15}
137/5

watched [3] 19/18
19/23 23/7

watching [3] 20/3
20/10 27/23

way [49] 2/23 9/13
9/24 10/2 19/14 23/25
28/13 34/13 37/8
41/17 42/18 48/10
48/15 50/9 50/21
50/22 51/2 51/15
54/23 55/9 55/18
55/20 58/17 62/19
73/19 76/9 77/3 82/8
86/24 89/11 93/1
96/18 97/11 97/21
98/12 103/22 106/20
109/14 109/18 110/1
110/5 121/9 121/10
129/15 130/19 142/17)
143/7 143/16 147/11

ways [1] 45/6

we [361]

we'd [3] 29/18 72/4
152/22

we'll [3] 40/16 66/8
88/15

we're [13] 1/10 3/13
30/20 37/2 37/23
82/24 83/11 83/15
86/10 99/13 106/12
133/7 142/16

we've [31] 61/4 61/20)
62/21 63/22 78/5 79/8
80/21 80/21 80/23

81/9 82/17 87/20 89/8
89/8 97/15 97/16
107/17 111/15 117/13)
118/17 140/10 140/12)
142/15 144/15 146/23)
147/2 149/1 149/13
153/24 154/2 154/2
weapon [1] 76/3
weaponise [2] 76/23
7719
website [17] 65/16
65/18 65/24 66/15
68/7 68/14 68/20
68/24 69/2 69/24
70/10 70/12 70/17
70/20 80/22 81/3 81/5
Wednesday [1]
112/17
week [2] 127/13
137/18
weekly [4] 78/7 78/10}
111/19 112/11
weight [1] 43/13
welcome [2] 45/13
46/14
well [58] 6/17 9/14
17/1 25/16 28/13
28/25 35/7 37/1 37/6
38/9 47/3 47/5 51/8
51/8 52/23 60/21
62/15 68/4 72/12 73/4
79/5 80/7 80/21 85/12
94/1 102/12 102/20
106/19 107/1 109/6
1411/8 111/18 115/17
117/9 117/20 118/5
119/6 120/14 126/19
127/2 127/18 127/25
130/17 131/7 135/12
142/12 143/24 144/15)
145/3 146/9 147/3
147/18 149/1 152/21
152/21 154/5 154/21
155/17
wellbeing [1] 86/7
went [5] 13/10 59/13
109/11 114/25 115/5
were [169]
weren't [9] 15/14
18/6 37/7 37/10 37/11
58/16 104/16 135/20
155/6
West [1] 4/4
what [158]
what's [13] 28/15
28/16 30/23 33/22
45/24 53/23 72/21
78/18 87/13 140/10
140/13 142/16 145/3
whatever [3] 94/1
146/12 146/16
whatsoever [2]
120/14 134/13
when [56] 2/21 10/12

14/4 17/15 19/15
19/23 26/10 32/24
35/9 36/7 36/16 39/13)
39/23 39/25 42/19
46/21 54/19 55/10
57/23 58/1 64/7 64/21
66/13 68/13 69/10
70/20 74/25 81/15
84/8 85/12 90/15 91/7
91/13 93/24 98/10
101/8 104/16 106/23
109/21 116/24 131/8
131/25 135/6 135/10
135/11 136/1 139/2
140/11 141/10 145/8
146/10 148/23 150/11
151/5 152/4 154/16
whenever [1] 13/11
where [46] 13/7
13/10 19/6 25/22
26/20 29/3 30/2 33/21
33/24 51/10 53/12
57/13 62/15 72/12
72/13 76/17 76/18
79/11 84/15 87/17
91/16 93/7 106/12
106/17 107/9 107/14
107/25 108/11 114/12
115/15 118/5 120/24
121/12 131/1 131/7
135/14 136/18 136/20}
136/22 136/24 137/1
139/9 139/14 144/9
152/2 152/9
where's [2] 87/18
135/12
wherever [1] 41/22
whether [32] 1/10 7/1
7/7 7/10 18/1 30/15
31/16 43/20 49/5
49/20 51/13 60/16
77/1 77/19 78/14
83/24 88/16 91/25
107/1 125/23 134/16
138/3 139/2 146/15
146/18 147/3 149/24
150/21 152/12 153/2
155/4 155/10
which [100] 4/7 4/11
6/15 11/2 14/23 16/5
16/9 17/23 18/15
18/18 19/19 21/9
22/16 24/22 26/18
27/12 30/12 31/24
32/4 33/8 34/22 35/5
35/24 36/2 36/8 38/20
40/5 40/11 42/12
42/12 46/6 48/22 49/8
49/13 50/22 51/2 52/8
52/18 54/15 56/4 56/7
56/21 56/25 65/13
65/17 65/19 66/3
68/23 68/23 69/10
71/2 72/19 74/3 74/14

77/14 77/19 7/22
78/3 81/11 81/20
81/24 82/2 85/7 85/8
86/1 86/6 87/12 90/15
94/8 94/24 95/17 96/6
100/2 100/7 100/14
100/18 101/13 105/8
107/7 108/17 109/14
109/15 113/10 122/2
123/1 123/9 124/11
125/10 133/6 133/10
133/13 134/2 134/3
142/8 142/9 144/11
145/5 149/1 150/3
155/18
whichever [2] 154/10
154/10
while [1] 141/4
whilst [4] 15/3 28/4
93/6 115/7
whistleblowing [2]
80/16 81/1
who [100] 3/4 3/10
5/18 6/23 11/24 13/5
15/3 15/17 16/24 17/4}
18/1 19/9 19/25 22/17]
24/3 24/9 25/7 25/11
28/2 31/8 32/13 35/17,
44/4 48/8 50/5 52/7
53/5 59/10 59/11
72/19 72/23 72/23
73/15 74/21 75/3 75/4,
76/2 76/22 82/13 83/1
83/4 83/4 83/22 87/16
89/13 89/22 90/1 91/1
91/1 91/23 92/12
94/13 95/10 97/14
98/9 98/9 98/22 108/8
109/2 109/22 111/5
111/8 111/10 111/11
112/23 113/20 116/9
116/10 116/11 116/12
118/1 124/10 124/20
126/17 127/4 127/11
127/16 128/5 131/24
137/16 141/11 141/14
142/24 143/4 143/23
143/24 148/11 149/10}
150/8 150/12 150/20
151/2 152/5 152/6
152/7 152/8 152/16
153/9 153/21 154/9
who'd [4] 61/3
who's [1] 9/14
whole [10] 3/7 4/18
6/18 47/15 60/13 70/6
99/13 121/20 121/21
131/2
whom [4] 7/3 84/25
107/4 151/20
whose [3] 22/20 48/3
153/9
why [45] 1/7 9/12
41/7 11/17 15/14

27/15 31/12 37/6 37/9
41/18 41/20 43/7 48/7
62/8 62/13 65/23
69/23 71/11 81/8 81/9
82/21 84/23 91/17
93/4 93/5 95/12 96/11
96/12 98/4 98/5 104/5I
104/8 104/15 106/1
111/16 114/20 119/11
123/24 126/16 141/5
141/5 147/14 151/2
155/6 155/10
wider [2] 6/19 12/24
widespread [1] 22/5
wife [5] 4/3 4/8 29/16
112/8 141/16
will [41] 3/18 19/7
30/12 33/13 46/8
46/20 46/21 50/22
57/4 60/23 63/21
85/20 88/5 88/6 88/7
88/8 91/13 93/25 96/2I
98/9 98/11 105/8
106/16 109/12 117/9
124/10 124/11 124/19)
124/23 126/17 137/25)
138/1 141/1 143/1
145/2 147/20 148/4
150/21 153/24 154/4
155/19
WILLIAMS [2] 153/14
157/12
willing [4] 33/9 95/9
98/23 142/21
winning [1] 47/24
wish [6] 23/3 40/8
46/16 51/6 99/24
142/1
wished [7] 8/15 9/3
14/18 41/10 58/14
89/22 136/17
wishes [1] 120/21
withdraw [3] 39/20
39/20 39/20
withhold [1] 57/6
Withholding [4] 57/1
within [66] 5/1 5/11
7/10 9/19 12/24 13/5
20/25 30/11 30/15
37/20 45/17 53/14
58/24 61/7 61/9 61/10)
62/23 64/15 73/5 77/2
80/17 86/4 86/15
87/14 87/24 88/5
88/25 89/3 89/13
90/24 92/12 100/3
100/5 100/7 106/6
107/19 107/20 107/22)
109/4 111/21 111/24
112/15 112/21 113/8
119/9 122/13 133/6
135/17 142/22 143/20)
144/1 144/3 144/5
144/11 147/12 149/1

(66) want - within
Ww

within... [10] 149/10
149/12 150/16 151/2
151/24 151/25 152/18}
154/18 154/19 154/19
without [9] 3/2 57/4
73/1 113/3 116/22
136/5 136/25 142/5
153/12
WITN00370100 [2]
42/14 84/11
WITN00370126 [1]
20/15
WITN00370127 [1]
95/14
WITN00370129 [1]
32/7
WITN00370131 [1]
24/23
WITN00370137 [1]
103/14
witness [7] 1/22 1/23
2/3 47/3 131/21
148/14 155/23
witnesses [1] 134/19
won't [4] 32/16 46/17
118/20 118/21
wonder [1] 90/17
wondered [3] 30/14
38/23 155/4
word [1] 152/20
words [2] 37/14
62/14
work [15] 3/1 3/2
5/19 61/17 82/14
83/16 89/14 90/21
116/4 118/3 120/11
122/10 153/11 155/1
155/9
worked [2] 62/14
73/16
Workers [1] 31/9
working [15] 15/6
15/22 62/19 63/1 63/3
70/13 70/13 118/23
119/3 119/8 119/16
119/20 119/24 120/5
142/14
workings [1] 136/12
works [2] 61/12
61/22
worried [2] 87/2
120/1
worries [1] 84/1
worrying [2] 152/3
152/9
worse [1] 39/1
would [143] 1/9 2/18
3/2 5/12 5/16 5/19 6/5
6/15 6/17 6/21 6/22
6/22 6/24 7/1 7/11
TINT 7/21 7/21 7/22
8/1 9/16 10/8 12/19

13/3 13/3 13/4 13/12
14/19 15/6 15/6 18/1
19/9 19/11 20/23 22/6
25/12 25/15 27/3 27/9
28/25 30/6 33/18
33/24 33/25 34/1 34/2
34/3 34/4 34/6 34/6
38/4 38/4 38/10 42/1
42/2 43/2 45/11 45/13
47/9 48/1 50/10 50/10
50/18 50/20 51/3
51/20 53/1 53/2 60/2
60/5 60/19 64/2 65/10
68/6 69/8 72/10 75/6
76/8 78/2 79/15 81/11
81/23 82/13 82/14
83/12 83/13 83/14
83/16 84/2 89/1 89/12
90/25 91/1 91/3 91/5
91/6 91/11 96/21
96/22 97/1 97/10
97/10 97/12 98/17
98/22 98/24 99/1
101/9 101/10 101/19
109/23 112/19 114/13)
114/25 117/16 123/13)
123/19 126/19 127/8
128/15 129/17 130/13)
130/19 131/2 131/4
138/9 140/19 141/19
142/7 142/8 142/19
142/20 142/21 143/10)
143/15 143/17 144/11
150/17 150/17 150/23}
154/6 154/23 155/2
wouldn't [6] 31/20
50/2 96/20 131/13
143/15 154/5
write [1] 45/11
writes [1] 45/20
writing [1] 95/25
written [6] 41/13
121/16 131/8 133/25
137/22 151/15
wrong [18] 23/19
26/7 26/10 28/21
47/19 48/10 64/5 64/9
64/13 64/25 76/16
87/13 87/17 115/6
115/10 118/5 127/1
152/20
wrongly [5] 20/5
27/17 27/20 33/7 61/3
wrote [1] 22/15
WYN [3] 153/14
154/19 157/12

Y

yeah [32] 27/14
28/13 34/17 47/19
65/12 66/9 67/19 69/3
69/14 69/14 71/14
73/7 79/15 79/15 91/3)
92/7 97/9 97/12

100/20 101/9 104/7
115/5 117/9 123/2
123/4 130/14 139/8
139/10 139/23 144/6
148/21 155/14

year [12] 7/12 7/18
17/19 37/20 78/22
86/13 91/20 137/22
139/21 140/14 142/19}
148/17

years [13] 7/11 21/18
26/7 26/11 40/4 49/17
50/7 91/8 102/1 106/1
107/13 115/19 121/6
yes [176]

yesterday [3] 2/20
44/12 112/14

yet [6] 18/6 21/17
32/17 86/10 140/16
142/14

you [598]

you'd [6] 14/10 14/13
36/3 146/7 151/25
155/4

you'll [3] 35/9 128/7
149/3

you're [20] 39/13
53/20 62/5 68/22
69/16 74/2 74/6 82/23
83/21 92/4 94/10 95/9
98/22 117/10 117/11
120/19 122/1 147/3
148/2 148/10

you've [51] 3/2 4/14
14/16 24/22 32/4
35/16 37/13 39/18
40/2 58/6 58/13 61/12
63/15 65/1 65/9 74/2
78/19 78/21 79/16
81/14 82/2 84/7 85/10)
85/23 86/3 88/17
88/20 89/25 91/17
91/17 94/20 96/11
98/15 100/11 102/22
106/4 107/8 108/16
117/15 118/22 118/22]
120/3 120/20 130/6
130/15 132/8 133/12
135/19 139/5 143/11
154/1

YouGov [2] 139/11
147/16

your [177]

yours [1] 91/8
yourself [2] 40/1
132/24

(67) within... - yourself