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The Post Office Horizon IT Inquiry
Wednesday, 2 October 2024
(10.04 am)
MS PRICE: Good moming, sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MS PRICE: Sir, before we proceed to call Mr Brocklesby,
there's just one short matter of evidence I wonder if
I might raise.
SIR WYN WILLIAMS: Yes.
MS PRICE: There are two short statements from witnesses who
will not be required to give oral evidence but which
relate to the evidence of Mr Staunton, and which I'd
like to read into the record, please.
SIR WYN WILLIAMS: Yes.
MS PRICE: The first is from Benjamin Tidswell,
a Non-Executive Director of Post Office Limited, and the
reference for that is WITN11290100.
The second is from Marianne Tutin, a barrister. The
reference is WITN1 1620100.
SIR WYN WILLIAMS: Thanks very much.
MS PRICE: Thank you, sir. With those documents read in,
may we please call Mr Brocklesby.
SIR WYN WILLIAMS: Of course.
CHRISTOPHER WILLIAM BROCKLESBY (affirmed)
Questioned by MS PRICE
MS PRICE: Can you confirm your full name please,
1
right?
That's correct.
Upon graduating you embarked upon a career in IT?
Yes
That career has spanned 26 years to date?
Unfortunately, 36 years, I think!
36 years, forgive me. That is my error. And has
included Chief Information Officer roles for companies
pProropr
including Tesco Bank, easyJet, Vodafone UK, and Dunelm;
is that right?
That's correct.
Q._Isitright that at Vodafone UK in particular, your IT
responsibilities included a large transformation
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programme to consolidate multiple legacy systems?
That is correct, yes.
Is it right that you joined the Post Office in August
2023 as Chief Transformation Officer?
Yes.
ed
You were in this role until 6 September this year?
Correct.
Is it right that in this role you were a member of the
Strategic Executive Group responsible for IT, including
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the delivery of the subpostmaster programme which is to
replace the Horizon system?
A. Yes.
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INQ00001190
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2 October 2024
Mr Brocklesby?
Christopher William Brocklesby.
Thank you for coming to the Inquiry to assist it in its
work. As you know, my name is Emma Price and I ask
questions on behalf of the Inquiry.
You should have in front of you a hard copy of
a statement provided by you to the Inquiry; do you have
that?
Ido.
Itis dated 16 August this year. If you could tun
please to page 25, do you have a copy with a visible
signature?
Ido.
Is that your signature?
Itis.
Are the contents of that statement true to the best of
your knowledge and belief?
They are.
That witness statement, for which the reference is
WITN11350100, is now in evidence and will be published
on the Inquiry's website in due course.
I'd like to start, please, with your professional
background and the role you held with the Post Office
until recently. As you set out in you statement, you
have a first class BSc in chemical engineering; is that
2
The new system intended to replace the Horizon system
will be known as the New Branch IT System; is that
correct?
That's correct.
‘As CTO, you were accountable for the day-to-day
operation of Horizon from a Post Office perspective —
Yes.
~ although you say the service is still mostly
outsourced to Fujitsu?
That's correct.
You explain at paragraph 9 of your statement that you
were also responsible for all change activities on the
Horizon system?
Yes.
Could we have that paragraph on screen, please. It's
page 3 of WITN11350100.
So those change activities you list in this way:
a) the regular Horizon software releases which
include defect fixes and enhancements for postmasters
“b) implementation of the Horizon Issues Judgment
recommendations and improvements
“c) infrastructure upgrades to reduce operational
risk (known as Datacentre Fortification), and
"d) projects to re-architect components of the
Horizon system to bring them into [Post Office Limited]
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control and support.”
Starting with (d), please, are the components being
brought under Post Office control and support those
which you identify at paragraph 8 of your statement, so
namely those which interface with third party partners,
such as banks and the Royal Mail Group.
That's correct, yes.
Is it right that one of the reasons for this work was to
minimise the impact of migrating from Horizon to the new
system?
Yes.
So it was progressing, was it, alongside the work to
delivery the New Branch IT System?
Correct.
Turing, then, to (b), at the top of this page, and just
for the moment in terms of the parameters of your
responsibility in this area, what type of
recommendations and improvements arising from the
Horizon Issues judgment fell within your remit?
Most of the HiJ Remediation Programme, which had been
running for a number of years, had been completed by the
time I arrived at the Post Office. There was still
Phase 3 of that programme running but to call out
a couple of specific items that were left, there was
an improvement for postmasters called autostop rem in,
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Most of the work was delegated to Simon Oldnall. I had
fortnightly one-to-ones with Simon to review the
progress of the work that was being undertaken on
Horizon but, as it was only one component of my
responsibilities, it was - that was my main interaction
with the work.
You address the monthly governance meeting between the
Post Office and Fujitsu at paragraph 12 of your
statement. These were led by Mr Oldnall from the Post
Office side and Dan Walton from the Fujitsu side; is
that right?
That's right.
Did you attend those meetings?
Not as a matter of course. I did attend, I think, one
or two meetings when I first joined the Post Office, to
make sure I understood what was being discussed
Were there any times when you were requested to attend
those meetings for any specific issues?
I don't believe so, no.
Did Mr Oldnall report back to you on key points from the
meetings?
Yes.
That statement can come down now. Thank you.
Is it right that you joined the Post Office
Strategic Executive Group as soon as you started as
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2 October 2024
which was an improvement allow a much better process for
postmasters to accept stamps into their branches and
hence removing one of the causes of defects when those
stamps are booked in incorrectly.
And another was bringing the transactional database,
which is used for some data enquiries, under the --
re-architecting it and bringing it under Post Office
control.
You describe the team structure for Horizon work at the
Post Office at paragraph 10 of your statement. You had
a full-time IT Director reporting to you --
Yes.
~ Simon Oldnall —
That's correct.
~ who you say was responsible for all Horizon work at
the Post Office; is that right?
That's correct.
He had a team of 45 people who managed the service
provided by Fujitsu through six different functions,
which you set out here in the paragraph (a) to (f); is
that right?
That's correct.
To what extent were you involved in the actual work of
those functions, as opposed to Mr Oldnall reporting to
you on that work?
Chief Transformation Officer?
That's correct.
You also became a member of the Improvement Delivery
Group, which you address at paragraph 22 of your
statement. Can we have that on screen, please, it's
page 7. You, say there that the group had the remit of:
*... addressing past failings, responding to current
issues, driving operation and cultural change and
rebuilding trust with postmasters. The committee
assessed progress on topics such as postmaster induction
and training, shortfall in discrepancies, suspensions
and terminations. It also assessed the progress of
addressing the [Horizon Issues judgment] findings within
Horizon. This gave me insight into the issues of the
past and the action plans to address those issues.”
You say you were also the SEG sponsor for the HlJ
Remediation Programme, which had the remit of
implementing changes to the Horizon system in order to
address specific recommendations, and that was
a fortnightly meeting for that group chaired by the CEO.
You say there that this was:
“... a challenging environment in which [Post
Office] leaders were challenged on progress and pace.”
Who was doing the challenging and who was being
challenged?
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Each individual component that was being scrutinised was
led by a member of the leadership team and they
presented their progress. Most of the challenging was
coming from Nick Read, the Chief Executive.
What was your impression when you took up the two roles
we've just looked at of progress which had been made by
the Post Office, in addressing specific recommendations
from the Horizon Issues judgment?
My impression was that the scope was very broad, clearly
a lot of individual topics that were being discussed,
and that lot of change was being made and had been made
to the way that Post Office operated, and that was
making a material difference.
Can you recall an example of a point on which Post
Office leaders were challenged at meetings?
No, I can't.
Although the remit of the Horizon Issues Judgment
Remediation Programme went wider, is it right that your
role was limited to ensuring the implementation of the
judgment in so far as it applied to the operation of
Horizon?
Correct.
With that in mind, I'd like to ask you, please, about
some of the changes you deal with at paragraph 38 of
your statement. Could we go to that, please. It's
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to resolve the discrepancies
You say at paragraph 6 of your statement that support is
largely outsourced to Fujitsu. Can you help, please,
with the three tiers and which aspects of that are held
by Post Office and which aspects are held by Fujitsu?
I believe all three tiers are held by Post Office, the
branch support team, the Network Support Team, which
I believe is a more expert function in terms of trying
to resolve discrepancies, and the third tier would
involve my team trying to work with the Retail team to
resolve anything that remains after those first two
investigations.
In what sort of circumstances would your team be asked
to get involved?
When the root cause of a discrepancy hadn't been
discovered or understood by the previous two teams.
How frequently, in the year you were there, were your
team called on in those circumstances?
don't know.
Are there any different helplines or lines of support
run by Fujitsu available to postmasters?
I don't believe so.
I should ask first: is there a Post Office helpline that
is utilised as part of this support for subpostmasters?
Yes, the Branch Support Team. There's also — for IT
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page 12. Focusing on the changes which are, on their
face, directly relevant to the operation of Horizon, and
starting with (e), you say:
“There is now much more support for postmasters with
discrepancies. This includes a ‘Dispute button’ which
postmasters use to relied that they need help and
a 3-tier support process to analyse and identify the
root cause of discrepancies. My team work with the
[Post Office] Retail to support Postmasters during these
investigations.”
How does the Dispute button work?
My understanding is it’s an opportunity for post masters
to ask for help. So itis literally a part of the
Horizon application, which they can -- one they can
press and basically say, "I need help with what I
either my weekly or monthly reconciliatior
Who is alerted to the need for help once the button is
used?
The Branch Support Team within the Retail area of Post
Office.
Is that a Post Office support function?
Yes.
How is the dispute resolved?
That's not an area directly within my remit, so I can't
give a lot of detail on the process that team go through
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issues, there is an IT Helpdesk that postmasters can
call
Are regular reports produced summarising the issues
being raised by postmasters on the helplines?
I understand they are included in the retail dashboard
which is something ~ a report that is put together by
the Retail Team on a monthly basis and it goes to both
the Executive and the Board.
How is that retail dashboard considered or analysed at
those levels?
I can't speak for the Board because I'm not a member of
the Board. At the Exec Team it's part of our monthly
agenda and it's open to scrutiny by the Executive Team
and they can ask any questions during that meeting.
You say at paragraph 12(b) of your statement that:
"Defect reporting was a standing agenda item at the
monthly Post Office and Fujitsu governance meetings.”
Does discussion of this topic at those meetings
include an analysis of the subpostmaster issues raised
with either Post Office or Fujitsu regarding software?
I'm not sure I understand the question. There is
a review of any new defects that have been raised --
defects can be raised by either Post Office or
Fujitsu ~ and a review of where there are changes to be
made as a consequence of that defect being raised,
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a review of progress to resolve that defect,
My question is really where the issue is raised by
a subpostmaster but it hasn't necessarily been reported
as a defect or recognised as such by Fujitsu or Post
Office. Is that something that would come to the table
to be discussed?
I don't believe so, no.
Can you help at all with who is responsible for helpline
oversight; would that have been Mr Oldnalll or someone
else?
So the Business Support Team has oversight from the
Retail function and the IT support line has oversight
from IT. I have a separate IT -- I did have a separate
IT Director, Mark Nash, who is responsible for the IT
Helpdesk.
Looking again, please, at the changes you list at
paragraph 38 of your statement towards the bottom of
page 12, and this time at (h), you say there is:
"More openness on Horizon directs. Any defect with
a possibility of having financial impact to post masters
is posted on Branch Hub (the postmaster communication
portal) and resolution is updated. This area is
something which sits directly within my remit. There is
also monthly SEG and Board reporting on Horizon
defects.”
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and Board level?
Ultimately, it was myself that provided the information
from the Horizon team but I provided that into the —
I would review it and then provide it to CoSec for the
inclusion in the SEG meetings.
To what extent were these reports discussed or
challenged at SEG and board meetings?
Again, I wasn't a member of the Board meeting but I've
never been asked specifically, I don't believe, at
a board meeting. But, now and again, I would be asked
a question on the -- it wasn't just about defects. The
tech dashboard had a number of pieces of information in
terms of remote and privileged access, defects, number
of incidents, et cetera. So I would receive some
questions from fellow SEG members on a monthly basis.
You say in your statement that there is nobody on the
Board with IT experience. How does this impact upon the
ability of the Board, critically, to assess reports on
Horizon defects, in your view?
I don't think it would ~ on that specific topic, it
would have much impact because they, I'm sure, are able
to analyse a trend in terms of whether there was.
a material increase in defects and/or — or progress in
terms of resolving those defects based on the data that
they were presented on a monthly basis. So I don't
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INQ00001190
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2 October 2024
Dealing with the Hub, first of all, how do you
measure, if at all, subpostmaster engagement with the
Hub?
We have stats on a monthly basis, in terms of the number
of log-ins to Branch Hub, which has been consistently
going up since it was introduced
Are subpostmasters able to feed into the Branch Hub when
they have relevant experiences of problems with Horizon?
I believe that they can raise an incident on Branch Hub,
yes.
Is the Branch Hub and the information on it looked at by
those involved in suspensions, terminations and recovery
of shortfalls, as far as you can say?
1am not aware of whether they look at that or not.
Is any learning from the Hub used to inform the
development of the New Branch IT System?
can't see an obvious correlation. I mean, in terms of
specific defects, yes, they are analysed to make sure
that clearly that they're not ~ nothing equivalent to
them is included in the design of NBIT. So specifically
related to defects, yes.
The statement can come down now. Thank you
You refer in your statement to monthly Strategic
Executive Group and Board meetings reporting on Horizon
defects. Who provides the reports on this topic at SEG
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think, in terms of that aspect, that it would have had
an impact.
What aspects did it have an impact on?
I think in terms of the broader discussions on
technology, specifically on progress, on projects and
programmes such as the SPM programme, which is
delivering the new NBIT application, it's quite
difficult to engage the Board in a detailed
conversation, and I think the consequences would
typically be ~ and I refer to this in my statement ~
a risk aversion to how that progress is being made.
When you say “tisk aversion”, how does that manifest?
Well, I think, whether it be Board or ARC, if you're not
familiar with systems development and IT programme
delivery, when it comes to topics, such as -- the
current status of NBIT is that it's been piloted in
a small number, I think five directly managed branches.
I think in a discussion as to progress and readiness,
people who are not used to the topic tend to want
a level of perfection that is actually detrimental to
the ultimate quality of the product because a beta
version of software or a pilot of software is there to
test the software in the real world and, by definition,
it won't be perfect.
It needs to be good enough but it won't be perfect
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and that level of real-world experience means that the
ultimate end product would be of higher quality and
better for postmasters. So those types of topics are
difficult to engage in, if you've not been involved in
project delivery before.
Also, there's expert domain such as security, which
is a hot topic in any organisation, which relies on IT
systems, which, again, it's a technical topic. So
getting that balance -- the discussion as to how quickly
to remediate security issues, how much money to spend is
a difficult one to engage when people who are not
familiar with that topic.
Given the history of the issues being investigated by
the Chair in this Inquiry, do you think there should be
someone on the Board with IT experience?
Yes, I think in other boards that I've interacted with,
that's been more and more of a theme, where there's been
a specific NED role which has been a digital or data
NED, that's been recruited to various boards.
I'd like to turn, please, to the current Post Office
approach to the recovery of shortfalls. Could we have
on screen, please, paragraph 73 of Mr Brocklesby's
statement, that's page 22. At paragraph 73, you are
commenting on an article in The Times from February of
this year, and you say this:
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in 2021 to identify and resolve discrepancies arising
mainly during trading period balancing; this process was
documented and regularly assured by the Assurance and
Complex Investigation Team."
The bullet under that:
“A key consideration was whether Horizon transaction
data might be a cause to of the discrepancy.”
Then, going over the page, please, there is
an explanation of the thinking behind the voluntary
recovery/repayment process, and that's the third bullet
down. It says:
“The voluntary recoveryirepayment process was
predicated on Horizon data being robust and that [Post
Office Limited] could rely on the data; [Post Office
Limited] was currently awaiting confirmation from both
[Post Office Limited] IT and Fujitsu and that this was
the case and this would be a key prerequisite to any
process that sought recovery in circumstances where the
postmaster did not voluntarily agree.”
‘The minutes then record the SEG considering the
options for the process going forward:
“SEG considered the options ... and the associated
pros and cons. The options were to:
"Maintain the current situation.
“Maintain the current situation and communicate this
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"Specifically in relation to the suggestion that
‘there is a prevailing culture that postmasters continue
to be “guilty”, this is, again, not a culture that
Irecognise. For example, the way that discrepancies
are now handled by [Post Office] is unrecognisable from
the procedures of the past. Post masters are given the
benefit of the doubt and unexplained losses are not
pursued by [Post Office Limited.”
With that in mind, I'd like to ask you, please,
about a document from July of this year. It's
POL00448520. Could we have that on screen, please.
These are the minutes of a Post Office Limited SEG
tactical meeting, dated 17 July 2024, which record you
having been in attendance. The minutes noted discussion
regarding branch discrepancies and loss recovery. Some
background is given, starting at the third sub-bullet
point down:
"By way of background, SEG noted that following the
recommendations made in the GLO and ClJ in 2018/19,
[Post Office Limited] had ceased action to recover
established losses from postmasters.”
Then the next bullet down
“This activity had been hold since this time, except
where a postmaster both agreed to repay the established
loss and proceeded to repay under a process established
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as a policy decision to postmasters.
"Cease all future recovery of losses.
"Seek recovery of established losses via a civil
means/deduction from remuneration, following an agreed,
defined process with an external review board that would
make the final recovery decision.”
The prerequisites included the process involving an
external board, on this representative postmasters would
sit, and, towards the bottom of the page, the
penultimate line the prerequisites would include,
critically, "assurance on Horizon data”; do you see
that, highlighted there?
With your insight gained from your role in
implementing the recommendations of the Horizon Issues
judgment, do you think that Post Office's voluntary
recovery/repayment process should be predicated on
Horizon data being robust?
Yes, I do.
Can you explain why?
Well, it provides the foundation for the -- for the
discussion and investigation around whether there's
a discrepancy and the size of that discrepancy. All of
that information comes from Horizon.
The prerequisite for the proposed recovery plan was said
to be assurance on Horizon data. Is that referring to
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The Post Office Horizon IT Inquiry
a general assurance that Horizon data is reliable?
I believe so, yes.
From whom was that being sought?
Specifically, Simon Oldnall.
Was Simon Oldnall in a position to give that kind of
assurance?
Clearly, this is a topic that we've discussed around the
SEG table many times. I don't think any IT professional
can give a guaranteed assurance of the integrity of data
on any IT system, but what Simon can do ~ and I think
this meeting particularly included a couple of new
members of the Executive Team that hadn't been
previously involved in discussions around discrepancies,
and were unaware of the work that had previously been
done around the HiJ Remediation Programme.
So what Simon was being asked to do was to restate
and remind SEG of all the work that had been done to
improve the Horizon system, to remove known defects and,
therefore, improve the quality of the underlying data.
Given the history of Horizon issues and, in particular,
assurances given in the past that Horizon was robust in
a number of contexts, did you have any concerns about
this prerequisite or general assurance and what that
might lead to?
No, I didn't have any concerns about the data itself.
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Yes, well, we can look at it. So there was reference
underneath the bullet points we've just looked at:
“SEG discussed a number of other alternatives
including:
"Some form of ‘losses’ pool, to which all
postmasters contributed and from which repayments would
be made."
What was your view on that, as to whether that was
an appropriate recovery method?
Again, it's somewhat outside of my experience and
responsibilities but it appeared to me that that
wouldn't be a fair way forward in terms of all
postmasters contributing. There's obviously a range of
postmasters, their experience and the status of their
accounts. So it didn't feel as though that was a fair
way forward, to me.
By the time you left the Post Office, what stage had
decision making reached on the way forward in terms of
loss recovery?
I don't believe this had come back to SEG for further
discussion
Had any assurance been given on Horizon data in general
terms by that point?
I'm not aware. There is a working group that was pulled
together -- Simon Oldnall was the IT representative on
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These conversations can be frustrating when some members
of SEG want an absolute guarantee provided by IT,
because I -- as I've just previously stated, it's very
difficult to provide an absolute guarantee, but to
assert all the work that's been done to improve the
situation, to assert the remaining defects that are
outstanding and how they don't impact postmasters
specifically, or only impact a small number of kind of
edge cases, and the fact that the system supports a very
large branch network, 7 million transactions a day,
which are concluded successfully.
Did you agree that the correct way forward was to seek
recovery of established losses by civil means or
deduction from remuneration, with the prerequisites that
were set out in the minutes?
Yes, I did. I mean, I ~ clearly within my role, I am
not responsible for the processes around those
investigations, discussions with postmasters, so I don't
have full insight in terms of the process of reviewing
discrepancies but, based on what I'd heard and the
confidence I had in Horizon, yes.
What was your view on the alternative option that was
listed of a form of losses pool to which all post masters
contributed, and from which repayments would be made?
Sorry, could you ask me that question again?
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that Working Group -- but I'm not aware of the progress
that was being made.
Do you remain of the view that the way discrepancies are
now handled by the Post Office is unrecognisable from
the procedures of the past?
Yes, based on what I've heard reported at the Group
Executive, yes.
That document can come down now. Thank you
I'd like to ask you, please, about some clauses in
the subpostmaster contract, as amended in August 2020.
Could we have that on screen, please. It's POLO0000254.
It's page 32, please. We can see, towards the bottom of
the page, there are Post Office duties, and this is
towards the bottom of page 32, please. If we can go
over the page, please. Just towards the bottom there.
Thank you.
So this section deals with Post Office duties and,
going over the page, please, starting at clause 20.3,
this duty is set out:
"Properly and accurately effect, record, maintain
and keep records of all transactions effected using
Horizon ..."
Does a mechanism exist for monitoring the
identification of, and payment of, shortfalls by
subpostmasters? So I'm not asking you about the
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interpretation of this clause but, just in terms of what
this promises to do, is there a mechanism for monitoring
the identification of, and payment of, shortfalls by
postmasters?
I'm not aware of that level of detail.
Just looking the next two clauses:
"Properly and accurately produce all relevant
records and/or explain all relevant transactions and/or
any alleged or apparent shortfalls attributed to the
Subpostmaster ..."
Then 20.5:
“Cooperate in seeking to identify the possible or
likely causes of any apparent or alleged shortfalls
and/or whether or not there was indeed any shortfall at
all..."
Is the reason for all shortfalls, as a matter of
practice, identified by the Post Office?
Is your question is every single shortfall that's
experienced from a postmaster ~
Well, starting with any that have been raised, that in
issue.
Again, this is something that is the responsibility of
the Business Support Team, rather than IT, but my
understanding is not every shortfall is ~ has a root
cause.
25
and post office workers.”
Enclosed to Mr Patterson's letter is an email chain
between Simon Oldnall, so your direct report, John
Bartlett and Fujitsu, dated between 11 April and 1 May.
Could we have that on screen, please. It's FUJ00243158.
Starting on page 4, please, on 11 April, Mr Oldnall
emailed Daniel Walton of Fujitsu, saying
“Dan
“Lunderstand from John that there have been some
challenges with supporting an ongoing police
investigation that involves a large sum of money.
“l obviously understand broader context, but wanted
reassure [sic] that [Post Office Limited] is supporting
the police investigation and offering any and all
assistance we can. Can I ask that you help with any
conversation that City of London Police need to have
with Fujitsu Services Limited.”
Then on 19 April, Mr Bartlett replied in the chain.
That's page 2, please. Scrolling down, please. The
third paragraph down
“As the potential victim in this case, [Post Office
Limited] would be grateful if you can provide me with
contact details for either the equivalent person in
Fujitsu (in the UK) to my role (je in overall charge of
investigations, or perhaps the Head of Security if you
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Q. That document can come down now. Thank you
Moving, please, to the role played currently by the
Post Office in prosecutions. Between May and July of
this year, the CEOs of Post Office Limited and Fujitsu
exchanged correspondence regarding the conduct of Post
Office's investigations function. I think you've had
that correspondence sent to you by the Inquiry; is that
right?
That's correct.
You've had a chance to review that? Could we have on
screen, please, FUJ00243204. This is a letter from Paul
Patterson to Nick Read, dated 8 July 2024, seeking to
bring to Mr Read's attention concerns concerning conduct
exhibited by members of Post Office Limited. The second
paragraph says this:
"Lam glad that we both share a commitment to learn
lessons from the Post Office Horizon scandal and to
ensure that the appalling treatment of post masters, and
the miscarriages of justice that occurred, could never
happen again. That was the reason for my writing to
you. I was seeking to bring your attention concerning
conduct exhibited by members of your organisation
“In simple terms, the Post Office is requesting that
[Fujitsu Services Limited] give expert opinion evidence
to be used in criminal proceedings against postmasters
26
do not have a dedicated Investigation Team) or
an appropriate person in your UK Legal Team. I will
then pass those details on to [City of London Police}
who are looking to have a trilateral conversation with
Fujitsu, [Post Office Limited] and [City of London
Police].
“It is impossible to overstate how important this
is: I need to advise both the police and [Post Office
Limited] as to the evidentially-established reliability
(oF not) of data that is being used every day in
establishing outcomes with postmasters and, potentially,
to be presented to the criminal justice system by the
police and the three public prosecuting agencies. The
non-provision of relevant witness statements from [Post
Office Limited] and Fujitsu will rightly be interpreted
by the police and prosecutors as [Post Office Limited]
and Fujitsu not having faith in the reliability of the
data with the obvious outcome resulting.”
That document can come down now. Thank you
Simon Oldnall reported to you. Before it was sent
to you by the Inquiry were you aware of this
correspondence?
No.
Ifyou had seen it at the time you were in your role,
would it have concemed you?
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Yes. I mean, there are politics at play, clearly, in
terms of people being careful about what they said and
did with regards to Horizon. But, yeah, it would have
concemed me if Fujitsu were not able to provide some
level of assurance, although I understood, as I said,
that there are politics at play here, so they may not
want to be providing that level of detail and assurance
to law enforcement.
Would it have concerned you that it was being requested
by Post Office, that is, Fujitsu were being asked to
give, in essence, expert evidence as to the reliability
of a system with the history that this has?
It was probably naive to get involved but I think, you
know, with the best of intent, people were trying to
help the police force in their investigations. So, with
hindsight, probably should have let the police get on
with it with Fujitsu.
Were you aware at the time of Mr Oldnal's role in
assisting the police with ongoing prosecutions of
subpostmasters?
No, not specifically.
Do you think you should have been aware of that aspect
of Mr Oldnall's work?
From what I understand from the email conversation, this
is one specific, significant case that the Met Police
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Yes.
"... outlined current arrangements with Fujitsu: support
runs to March '25 while infrastructure expires in March
'24. A request to extent infrastructure to March '25
will come to the October Board. The procurement
strategy beyond March '25 will kick off early next year
to extend those two contracts. To date [Post Office
Limited] has told Fujitsu that they would like
a flexible agreement going forward without a precise end
date, but Fujitsu would like to see a funded and
well-planned SPMP so they know [Post Office Limited] is
serious about replacement. In short Fujitsu is happy to
collaborate if they know [Post Office Limited] is
working to get out."
Just keeping that in mind, could we have on screen,
please, FUJ00243299. This is a letter from Fujitsu to
you, dated 15 December 2023, and it refers to a request
from Post Office Limited in November 2023 to extend the
Horizon contract. Fujitsu explains the various
challenges to the feasibility of the continued delivery
of the Horizon system and associated services.
There was then a further letter on 3 July this year,
from Fujitsu to Mr Oldnall. Could we have that on
screen, please. It's FUJ00243301. Starting at the
third paragraph down, please. There is this:
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were pursuing. I don't think — I'm comfortable that
Simon didn't feel it was necessary to raise this with
me.
I'd like to move, please, to progress on the New Branch
IT System. The Inquiry has received evidence that,
although it was initially proposed that the New Branch
IT System would be rolled out to enable the Post Office
to exit its contract with Fujitsu for Horizon Support
services by March 2025, delays in the development in
rollout of the system have meant that the proposed start
date for deployment of the system is now June 2026.
Does that accord with your understanding at the point
you left the Post Office?
That's correct, yes.
Could we have on screen, please, BEISO000776. These are
the minutes of a UKGI Post Office Limited quarterly
shareholder meeting, dated 14 September 2023. You were
in attendance and are abbreviated to "CB" in the
minutes. Going to page 4, please. Under item 5,
“NBIT", so that's the New Branch IT System, isn't it?
Yes.
The fifth bullet point there:
"CC asked about negotiations with Fujitsu. CB ...”
So is that you -- is that a reference to you, the
initials "CB" there?
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"We have seen limited formal engagement from [Post
Office Limited] to meaningfully progress the planning of
exit at the Exit Date. Post Office is instead focused
on seeking to secure an extension and planning for exit
to occur before the end of extended contract term.”
Then underneath
“The purpose of this letter is to escalate the
position so that {Post Office Limited] engages
proactively with [Fujitsu] to plan and prepare for [Post
Office Limited] to take over the services that [Fujitsu]
is due to cease providing on the Exit Date. As
discussed, [Post Office Limited] needs to assign an Exit
Manager to prepare with [Fujitsu] an exit plan."
Forgive me for going through that in some detail but
it sets out a little the chronology of the piece.
Yes.
What was the status of the development of the
replacement for the Horizon system on your departure
from Post Office?
So we had developed some software that was live in five
branches supporting a subset of postmaster transactions,
a pilot of the ultimate end software. There was still
a lot of software to be built and, hence, a two-year
timescale, just under two-year timescale, to build out
a full solution, that is not only across all of the
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transactions but includes a system that's performance
secure, et cetera.
But the fact that there was pilot software running
in a branch used to serve real customers was a great
start, but a long way to go in terms of the ultimate end
goal of retiring Horizon.
Do you think that the Post Office had in place
a realistic plan for delivery of a replacement system on
your arrival?
On my arrival?
Mm.
No.
Can you elaborate as to why you say that's the case?
On my arrival, the plan of record was that NBIT would be
delivered and fully deployed by March 2025, and there
was a lot of assumptions included in, yes, the Fujitsu
relationship, other procurement deals, et cetera, that
were built on the back of a March 2025 assumption. But
clearly, based on what I could see when I arrived,
namely there was little to no software that had been
delivered to date, that the software that had been built
had a lot of work stil to be done in terms of defects,
an awful lot of work in terms of things like security,
and, given the fact that there was a plan to deploy that
‘software to 11,700 branches that would have taken two to
33
credible leadership and governance. There was lots of
issues in terms of the quality of the software that had
been produced to date. So there was lots to do,
This was a remediation, this was a complete
rebaselining of the programme plan. This was
a restructuring of the team. This was removing 70 per
cent of the people that are on the programme in order to
regain control. So, as part of that, there was a lot of
remediation work to do but, in early 2024, we did then
start to build out a new plan based on an understanding
of where the programme was at that stage, which was the
plan that you previously referred to, which has the
software being built, tested, in real life, with
postmasters, and ready to be deployed by the middle of
2026 and, ultimately, all post masters and all branches
being online by the end of 2028
That plan, having been put in place in early 2024, did
you find any obstacles in relation to that plan, either
because of issues with the governance of Post Office or
otherwise?
Look, these things are hard to deliver, and that was
always going to be my expectation that there would be
issues along the way. It's never going to be an easy
ride. I think we had subsequent reviews of the
programme. I think governance was an issue, in terms of
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two and a half years, if you work back from March ‘25
and if it takes two to two and a half years to deploy
the software, then the software needs to have been ready
by the time -- at the time when I arrived, and it
clearly was not even close to being ready.
So no, there was no credible plan to deliver a March
'25 outcome.
Did you encounter any challenges in delivering the
replacement to Horizon programme?
I'm not sure I understand the question. It's a complex,
difficult programme to deliver. So it's ~
Breaking it down as to what those challenges might have
been, or starting from this position: did you put in
place a plan for delivery of the replacement system on
your arrival?
Yes, there was a lot to do. I think, as we've heard
from previous witnesses, there wasn't one programme;
there were two programmes: one that was building the
software; and another programme that was looking at how
to train postmasters to deploy the software into branch.
That wasn't a credible and realistic set-up because the
two programmes weren't interacting, talking,
‘communicating and there was no integrated plan.
The leadership of both of those programmes had left
the Post Office, so there was a vacuum in terms of
34
too much governance. There are a lot of stakeholders at
Post Office, so getting quick decisions made at the
right level is always a challenge. I've already
referred to risk aversion, which is difficult when
you're trying to take considered risks as part of the
development and ongoing deployment of the software. And
just finding out more issues from the past, which have
to be remediated, along the way.
So yes, there continually things that we needed to
address as part -- and they will continue, in order for
the programme to be successful.
The other thing, I think, is the ongoing funding of
the programme, which is very incremental, and so, you
know, there's always a sense that the programme is
funded for another few months, and then there's a lot of
work to be done to get another piece of funding through
from DBT, and ultimately HM Treasury. That is a
very difficult way to progress, when you're trying to
motivate people for a two, three-year journey, when
people know that we're only really formally funded for
another few months, and then who knows what might
happen?
Were you aware of the challenges to the feasibility of
the continued delivery of Horizon, which was referenced
in the Fujitsu letter of 15 December, that we looked at
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when looking at that ~
Yes.
-- chain of correspondence?
Yes.
Were you aware of that at the time?
Yes,
Was the Post Office Board aware of that at the time?
Yes.
Was it right that, at that point, the Post Office had
not assigned an Exit Manager to prepare an exit plan
with Fujitsu? So you will recall the later letter.
That is correct but Fujitsu were aware, and had been
aware for some time, that we needed an extension, There
was no option but to extend Fujitsu Services because
NBIT wasn't ready. So, you know, we had been working
with them on the ground at that stage for many months,
working through what an extension would look like at
a very detailed level, in terms of working through all
the contract schedules and some of the terms and
conditions. So they knew that we were going to be
asking for an extension, and those were ongoing
conversations.
So it was kind of, again, seen as slight game
playing by Fujitsu to ask for an Exit Manager when they
were very clear that there wouldn't be an exit in March
37
we sought and that included Fujitsu infrastructure. The
reason I hesitated was, of course, ultimately, because
of this incremental nature of funding, not all of the
investment that we were required, to mitigate those
risks was ultimately -- you know, this is an ongoing
process over discussions and incrementality. So it was
included in the approvals that we had been given to date
but, ultimately, that wouldn't have funded full risk
mitigation because there are future business cases that
need to be approved to address those risks.
Moving, please, to Project Willow. Is it right that
Project Willow relates to concerns which were raised
about the New Branch IT System?
Yes.
The Inquiry understands that there are three strands to
the investigation; is that your understanding?
I've only been aware of Willow2 and Willow3, I'm not
aware of what Willow was.
But there were three parts to it?
Yes, that was my understanding.
Could we have on screen, please, POL00448907. This is
an ad hoc A&CI Team report prepared by John Bartlett for
the Board in August 2024. This is a document that
you've only seen very recently and, is it right, that
you've only seen this for the first time this morning?
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Were there any risks, from an IT perspective, arising
from Horizon's end of service live status?
Yes, there are risks of having infrastructure that is
out of support or nearing, in terms of resilience, in
terms of the risk of failure. There had been
a programme called "Datacentre fortification", which had
spent a lot of money previously, and was, during my
tenure, continuing to spend money to improve the
standard of the infrastructure, to upgrade many
components, but there were still specific components
that needed further investment.
That investment was understood, had been worked
through with Fujitsu in terms of the cost ~ potential
costs and timescales, and all of those costs were
included in the business case that we put forward to
Treasury.
So, alongside the costs for the delivery of NBIT, we
were also asking for investment in the Horizon
infrastructure in line with the risks and the
requirements of Fujitsu, as they had identified.
Was investment related to or to mitigate those risks
forthcoming?
Yes, I mean, the conversations -- when we had approvals
during my tenure, they included all the components that
38
Correct.
We'll take this as slowly as we need to and, if you need
any time to consider the text that I'm asking to look
at, please do say?
Thank you.
Could we go, please, to page 6. This provides the
background to Willow2. It says:
"Multiple sources of information indicated that
there were potentially two heads of alleged concems
relating to the NBIT teams:
“That information provided to GE and the CEO was
presented in a skewed manner to prompt certain outcomes
and so past decision making was flawed; and
"[Secondly] That infosec elements of design and
testing were ‘tumed off’ due to pressure from
contractors on those responsible for infosec in order to
improve the speed of progression irrespective of the
long-term impact on the reliability of the system.”
So just taking those two parts in turn, is that
an accurate description of the first aspect of concer:
that information provided to GE and the CEO was
presented in a skewed manner, so past decision making
was flawed; is that an accurate summary of what the
concern was?
Yes.
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What can you tell us about the circumstances in which
that concern was raised and the response to it?
Iwas led to believe it was a whistleblower allegation.
I know no more detail than that.
In relation to the second aspect of this, was that
raised in the same way; was that part of the same
concern?
I don't know.
Okay. Can you help, please, with what this concern
might have been referring to, specifically in relation
to turning off of some aspects of the design and testing
to improve the speed of progression?
Yes. So when you're developing software, there is
obviously aspects of the software that can be seen and
can be demonstrated, ie the screens that a postmaster
would use to serve a customer. So they can be
demonstrated to postmasters, to whomever would like to
see them. But, in order to provide a fully resilient
piece of software that is fit for purpose to deploy to
a very large retail network, there are a lot of unseen
requirements. Those would be things like security;
performance, that it can not just work on one computer
but indeed works on 25,000 counters; that it can be
monitored so that the IT Team know when it's working and
when it isn't. So there are what would be called
41
investigate; is that what happened?
Yes, that's my understanding. Grant - Grant Thornton,
Irecognise. Pinsents, I do not.
Do you know what stage investigation had got to by the
point at which you left the Post Office?
No, and I think I need to point out that the bullet
point underneath suggests that I had SEG oversight of
this investigation. That wasn't my understanding. So
I certainly didn't — I was aware of the investigation,
I was interviewed by Grant Thornton as part of the
investigation, but I certainly wasn't aware that I was
the SEG owner. I certainly didn't receive any status
reports. I see in the document later on that there are
issues with Grant Thornton and their engagement.
I wasn't aware of that.
So on a number of occasions I would ask HR
specifically what the status was and when it was due to
complete, and was told that investigations were ongoing
So I don't recognise the statement that I had oversight
in some way for the investigation, and I'm not sure it
would have been appropriate.
We'll come on to what may have been being referred to
here in terms of you being conflicted. We'll come back
to that point but I just want to deal, first of all,
with the substance of what was being said in that
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non-functional requirements that are behind the scene
that are a very important part of delivering a full
software solution.
Can you help, please, with what aspect of the
reliability of the system the concern related to; what
was the concern about the impact?
Well, software, both the developed software and
software -- the party software that is used has ~- can
have -- vulnerabilities, ie weaknesses that could be
exploited in order to initiate some kind of cyber attack
‘on the Post Office. So it's important that those
vulnerabilities are understood, and they are addressed
before the software is rolled out to a material number
of postmasters and is relied upon by Post Office, or
else clearly there is an inherent risk of cyber threat.
So the risk here, you're saying, is one of cyber threat?
Yes.
Is there anything about that reference to the
reliability of the system and the concem that was being
raised that was relevant to accounting discrepancies or
their potential?
No, I don't believe so, no.
In terms of what was done about the concerns that were
raised, it appears from the bullet below Pinsents and
Grant Thorton were engaged to independently
42
concer dealt with under background. Do you consider
that past decision making had been flawed because of the
way that evidence or information had been presented?
I don't have specific reports in mind where I know for
sure that there's a report to a Board or any other
governance meeting where the reporting was overly
positive or incorrect, or ignoring of issues with the
programme. However, as I already stated, the fact that
the programme was continuing to report progress against
a March 2025 date in early 2023 wasn't credible, in my
mind, and therefore I can imagine that must have been
the case but I don't have access to specific reports
that would confirm that.
Going, please, to page 8 of this document, this deals
with Willow3, so the third limb of it, and it sets out
the background in this way:
“A&Cl were asked to investigate an allegation that:
"During a briefing to the Board on alternatives to
the in-house built NBIT, that Chris Brocklesby allegedly
misrepresented a possible alternative offered by
a company called Escher; and
“The true extent and completeness of the bid/offer
by Escher to [Post Office Limited] was incorrectly
discounted and suppressed as a viable alternative
without broader consideration.”
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Was this concem that had been raised discussed with
you before you left Post Office?
A. Yes, it was.
Q._ Who discussed it with you?
‘A. The third party that was investigating: Grant Thornton
Q. Did you misrepresent an alternative proposal to the
Board?
A. No, I didn't.
Q._ Has an independent external investigator been engaged to
support that Willow3 investigation; is that the company
you were just referring to?
A. Yes.
Q._Do you know when it is anticipated to conclude its
investigation?
A. No, I do not, no.
MS PRICE: That document can come down now. Thank you.
Sir, I have reached the end of a topic and I am
about to turn to another. Would that be a convenient
moment for the morning break, please?
SIR WYN WILLIAMS: Certainly, yes.
MS PRICE: If we could have 15 minutes, I think that takes
us to 11.35.
SIR WYN WILLIAMS: Certainly, fine.
MS PRICE: Thank you, sir.
(11.21 am)
45
Phoenix work?
A. No, I don't believe so. I believe they were happening
in parallel. They were a separate scope.
Q._ Were you involved in the Past Roles work, which was
happening and is referred to here?
A. No.
Q._ Having been present at this meeting, what was your
understanding of what the change in operational context
and political environment, referred to in the first
bullet point, was a reference to?
‘A. I think this referred to the fact that this had been
highlighted in the press and/or raised as an issue at
Board meetings that there were still members of Post
Office, particularly those in the RU, that had
previously been involved in postmaster investigations.
Q. Were it not for the change in operational context at
political environment, would this work have been
progressed?
A. It’s difficult for me to say, as I really wasn't
involved in the RU or discussions around those roles.
Q. There was a vote on how to proceed recorded on page 4,
over the page, please. About halfway down the page, the
penultimate bullet point there:
“The SEG discussed the difficult trade-offs at play,
with the majority voting for the ‘many to few’
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(A short break)
(11.36 am)
MS PRICE: Good moming, sir. Can you still see and hear
us?
SIR WYN WILLIAMS: Yes, thank you.
Ms PRICE: Mr Brocklesby, I'd like to come next, please, to
Project Phoenix and to Past Roles. Could we have on
screen, please, POL00448864. These are the minutes of
an SEG meeting which took place in March 2024, which you
attended.
Going to page 3, please. Under the heading "3.1
Past Roles’, there is this at the first two bullet
points:
"SR and NM spoke to the paper which set out
a recommendation on the approach to be taken in relation
to the Past Roles Review and staffing in the RU in the
light of the change in operational context and political
environment.
“As a reminder, the Past Roles Review had been
commissioned to look at the roles and activities of
current employees who may have previously undertaken
a role related to the subject of the POHIT Inquiry, to
examine whether any conflicts, or perception of
conflict, arose.”
Did the Past Roles Review arise out of the Project
46
recommendation. The inevitability of delays to redress
claim processing times was not, however, accepted and
SEG noted a number of different resourcing approaches
and models, including those adopted in other industries,
such as insurance and claims processing.”
Then there's a footnote at the bottom of the page,
please, which says this:
"NR, CB and KS ..."
Was "CB" a reference to you?
A. Yes, it was.
Q._ “... voted for Option 3, ‘many to few’; OW voted for
Option 2, ‘no further action’, KMcE abstained on the
basis Option 3 had the majority vote."
Then it goes on to give another reference to
non-voting members, noting they supported Option 2
You voted for the "many to few" option, over no
further action; what did this mean?
A. It meant that those members -- we'd seek to redeploy
those members of the RU team that were in scope,
ie I think there was a reference to red roles, ie those
people that were in the RU that had been involved in
previous investigation work.
Q. Just pausing there, RU, that's the remediation work, is
it?
‘A. Remediation Unit, yes.
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Okay. Please continue.
Pardon?
I didn't mean to interrupt, just to clarify that?
No, I think I was done. That's what it was. It was
considered to be ~ considering the pressure to make
‘sure that there was no conflict of interest, that, even
though there was no implication that there was any
wrongdoing on behalf of those individuals, it was -- the
best outcome for both Post Office but also for the
individuals concemed, was that they were, as it were,
taken out the firing line and there were other roles
sought for them elsewhere in Post Office.
Could we have on screen, please, paragraph 32 of
Mr Brocklesby's statement. That's page 10. At
paragraph 32, you say that:
“.. my observation is that the culture has been
significantly influenced by the historic issues being
addressed by the Horizon Inquiry which has resulted in
risk aversion and a tendency to defer decisions to
senior management.”
That risk aversion you've already referred to. You
go on at paragraph 33 to say:
“I would say that there is a positive culture of
constructive challenge with a good level of constructive
challenge in the organisation.”
49
“The claim that this is ‘difficult’ will simply not
cut it. Ifit was easy someone might that have done it
by now; but it is the fact that it is hard that we must
grasp the nettle and get it done. Itis both optically
and morally wrong that this has not been dealt with
before. This not a ‘witch hunt’ (as it has been
advertiser by light previously) ~ this is about making
certain the culture and frankly the future of this
business is not mired in the wrongdoing of bad people
who did truly awful things, some of whom — to this very
day -- believe they did the right thing!"
There is a further email in this email chain after
the email forwarding this one, on 10 February, and
that's on page 1. In the third paragraph here he says:
“It does however seem odd that not a single one is
suspended whilst this is ongoing? Why is that? We seem
to suspend people on a rejected basis when
investigations are ongoing? Why not on this matter?"
First of all, can you help with who is now
responsible for oversight of the Investigations Team?
If you can't help, just say.
No, I don't know, I'm afraid
Can you help with why you were a copied recipient of the
email chain we've just looked at?
Because I was the Chair of the Project Phoenix Panel.
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With that in mind, I'd like to go, please, to
an email from Owen Woodley to the Post Office Board from
February this year, which you were copied into. Could
we have on screen, please, POL00448309, page 2, please.
Scrolling down a bit, please. This email here of
9 February 2024 from Owen Woodley forwarded on an email
from Elliot Jacobs, and we see that over the next page,
please, page 4 -- two pages on, forgive me. That email
is there from Elliot Jacobs, also 9 February, to Nick
Read and others. In this email there is frustration
expressed about the progress of Project Phoenix
It's right, isn't it, that Project Phoenix is
a review of all historical investigations where
allegations have been made by postmasters of wrongdoing
on the part of the Post Office or Post Office employees,
as part of the Human Impact Hearings for the Inquiry.
That's correct.
Mr Jacobs started his email in this way:
“Following on from our meeting almost 2 weeks ago
where I expressed in the strongest of terms my
frustration and utter disbelief that the matter of
Project Phoenix was still nowhere resolved I am
concemed we have not received any update on the
activity since."
Then the third paragraph of his email says this:
50
Do you share Mr Jacobs’ view as expressed about the pace
and the nature of decision making on Project Phoenix?
No, I don't.
Why not?
Given the scope of the panel, which, to recap, was to
review investigations that had been conducted into
approximately -- on approximately 50 cases and make
a decision as to what action to take, namely to -- that
there is no further action, or more investigative work
is required, or indeed to pass that case or those
individuals to the HR team for a misconduct
investigation.
There were 50 cases to get through. We prioritised
the 20 or so cases that referred to current members of
staff. But each case needed to be investigated by
qualified investigator, required going through old
material, finding the recordings of previous interviews
with postmasters, offering postmasters the opportunity
to be interviewed again, specifically by those case
reviewers, and to come up with recommendations in each
case,
Given that quantity of work and the limited number
of investigators, it wasn't clear how we could go any
faster. We took the role very seriously. We, the
panel, was available immediately when cases had been
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completed and we quickly made decisions on everything
that was put before us. But it wasn't clear how we
could go any faster, given the workload.
Who, within the Post Office, had referred to Project
Phoenix as a "witch hunt"?
I'm not aware.
Is that how Project Phoenix was viewed by some employees
within the Post Office?
I don't think many people were aware of what Project
Phoenix was, so I can't answer that question. I think
it was a small number of people that were even aware
that this was ongoing.
SIR WYN WILLIAMS: Over what period of time, approximately,
A
were you chairing this panel, Mr Brocklesby?
From memory, Sir Wyn, the panel started at the beginning
of 2024, so January or February, through to my departure
on 6 September.
SIR WYN WILLIAMS: So it was still functioning in its role
A
in September, and we're looking at Mr Jacobs’ email in
February, yes?
That's correct, sir.
SIR WYN WILLIAMS: Yes.
A
It's coming to ~ it is very close to the end. I think
a number ~- the conclusions have been drawn on,
I believe now, all seven current members of staff and
53
Well, I don't recognise the phrase “witch hunt"; I've
never heard it being used. So I couldn't say, really.
That document can come down now. Thank you:
I'd like to come, please, to whistleblowing culture
at the Post Office. At paragraph 67 of your statement
you say that at Post Office whistleblowing is encouraged
much more than other organisations you've worked in, and
you also explain at paragraph 68 that you had chaired
an investigation into a whistleblower's accusation,
there were many more investigations under way than
elsewhere that you have worked and, in your view, these
investigations are taken seriously and confidentiality
is respected; does that remain your view?
Yes.
Could we have on screen, please, POL00448519. This is
a letter from Post Office Limited Whistleblowers, dated
28 May 2024 to Nigel Railton, a number of MPs, the Chair
of this Inquiry and lead Counsel to the Inquiry. The
first paragraph of the letter says this:
"We are writing to you as a group of highly
disenfranchised [Post Office Limited] employees, to seek
your support in addressing the ongoing intolerable
leadership and cover up within [Post Office Limited].
We represent a significant group from all levels of
[Post Office Limited], who are sick and tired of being
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the kind of thematic review document has also been
produced in terms of lessons learnt through the -- as.
a consequence of all of the investigations. So I expect
it to be closing soon
SIR WYN WILLIAMS: On the face of it - well, not on the
face of it. Can you explain to me, you know, in
summary, why you were thought appropriate to chair this
panel?
A Um-
SIR WYN WILLIAMS: Obviously you'd had nothing to do with
past so that helped
A. Nothing to do with the past, nothing to do with
investigations. I think there were ~ Nick Read asked
me to chair it. I think it was felt that a member of
the Executive Team should sit on the panel considering
its importance. My understanding is a number of other
members of the Executive Team were conflicted because of
their role, and others were also chairing other panels.
So I was asked by Nick to chair Project Phoenix.
MS PRICE: Thinking back to your comments at paragraph 33
about there being a positive culture of constructive
challenge in the Post Office, the reference to the
verbalised view, of at least some, that this was
a “witch hunt", is that an example of resistance to
challenge within the Post Office?
54
lied to and watching certain managers being favoured and
protected, because they are part of the inner circle of
Nick Read. The culture is terrible, there has never
been a plan in place to address the wrongs of the past
(recent key indicators are showing significantly
declining trends in our culture and trust between senior
leaders and the rest of the business). Worse still, the
current flawed leadership is not being appropriately and
objectively held accountable."
Were you aware, when you were at the Post Office,
that there were Post Office employees with this strength
of feeling about their place of work?
‘A. No, not ~- this is particularly an emotional letter, so
look, you know, we could see the results of various
engagement surveys, so, as an Executive Team, we were
aware that there's a lot more work to be done in terms
of the trust in leadership and overall morale of the
team, but I hadn't seen this particular letter until it
was given to me last week.
Q._ Having read through the letter now and without going
through them one by one, were you aware of the
particular allegations contained within it?
A. I mean, it covers a lot of different points, but
specifically, no. No
Q._ That document can come down now. Thank you.
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Do you believe that the Post Office's whistleblowing
policy has been effective in remedying past issues
within Post Office's culture?
It's difficult for me to answer that because the very
nature of whistleblowing investigations are
confidential. So, in terms of the nature of the
allegations, the findings, whether they're upheld or
not, and the subsequent lessons leamt, it's difficult
to answer that question because those aren't available
tome.
You appear in your statement to interpret a significant
number of whistleblowing investigations to be reflective
of a changed culture, one that's receptive to
whistleblowing; is that right?
Yes, I think that's fair.
Might a significant number of investigations also be
reflective of a reaction to the current culture?
Yes, it might.
I'd like to come, please, to Post Office governance and
effectiveness. Could we have on screen, please,
paragraph 25 of Mr Brocklesby's statement. That's
page 8. You say:
“In terms of Board structure, decision making
responsibilty lies with the Board across a wide range
of areas. In my opinion, the CEO does not have
57
terms of medium and long-term strategy and whether
an organisation is on the right trajectory, rather than
constantly being drawn into the details of the operation
of the organisation as it is today.
Going to page 11, please, and paragraph 35, you discuss
here a significant change in the SEG and Board
membership over the year you were at Post Office
Limited:
“.. which obviously has had an impact on corporate
knowledge and direction ... for an organisation of this
scale and complexity and in view of the current
challenges it is dealing with (including the Inquiry),
it is less than optimal that [Post Office] is, and has
been for some period, operating with a large proportion
of ‘interim’ senior managers and leaders. It is
important for the stability of [Post Office Limited]
that permanent appointments are made through the
appropriate rigorous recruitment processes.”
The high turnover point is one you retum to at
paragraph 59, that's page 17, please. You explain that:
“One of the major issues with SEG has been the high
tumover. When [you] joined in August 2023 there were
ten members. Of those, only three remain in the current
team, with five new members. Owen Woodley retires ..
in August, leaving the Chief of Staff and myself as the
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sufficient delegated financial authority, which means
that many decisions need to be signed off by the Board
as a whole. Any business case or procurement activity
over £5 million must be signed off by the Board.
Although this a large figure, given the size of [Post
Office Limited], there is a significant number of spends
which meet this threshold. Procurement activity
typically requires two Board visits; the first to agree
a procurement strategy and the second to agree the
contract award. The Board agenda is often full of
procurement and business case approvals due to the lack
of delegated authority to the CEO or SEG, as well as.
updates on remediation matters.”
You go on to say at paragraph 26 that the Post
Office Board spends more time on operational rather than
strategic issues.
In your view, what is the impact of these features
you discuss, in terms of longer-term planning?
It's exactly that: that the Board doesn't spend a lot of
time thinking ahead, in my view, in terms of how the
Post Office needs to build on the future. It's always
looking at what's -- you know, the current operational
matters that are before it. So my expectation and my
previous experience of boards is that their role is to
be able to take a step back and to challenge the exec in
58
only remaining members of the team from August 2023 .
this means there is a lack of corporate knowledge and
understanding of context although this does mean that
there is new experience available.”
Why do you think there has been such a high turnover
of staff at the senior level?
There are lots of reasons why there have been -~ people
have come and gone. Clearly some people have resigned.
It's a difficult place to work. It's been
an organisation that’s been in crisis management during
my tenure. Clearly, with the arrival of our new interim
Chair, he has decided to bring in a number of new
members of the Executive Team as well. So I don't think
there's one underlying reason, but there has been a lot
of change.
Is high turnover something which applies at the middle
management level in Post Office or is it really
an Executive and Board level issue?
Yes, I think it is mainly an Executive and Board level
issue.
You conclude in this way at paragraph 62 over the page,
please:
“It is too early to know whether these individuals
[that’s new individuals to the team] can work
effectively together to create a strong SEG team
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The Post Office Horizon IT Inquiry
1 something that has been lacking due to the high turnover
2 and constant crisis management which has been
3 a recurring theme of 2024. In my view SEG members have
4 been working at an unsustainable intensity and pressure
5 for some time."
6 Do you consider that the Post Office Board, as it
7 was when you left the Post Office last month, to be
8 effective?
9 A. That's a difficult one to answer succinctly.
10 Ultimately, I think there's lots of improvements that
ca need to be made in the way that the Post Office is
12 governed, the way that the Board operates, what they
13 focused their time on, the proportionality of different
14 topics and themes, the way that the Board engages with
15 the rest of the Post Office, postmasters and the
16 Executive Team, where there isn't much engagement from
7 the Board,
18 So I think there are lots of ways that the way the
19 Board operates needs to be improved.
20 @ That document can come down now. Thank you.
a In terms of your own appointment and the way your
22 contract was handled, you say in your statement that the
23 mutual intent was for you to join as a full-time
24 employee as Chief Transformation Officer and the terms
25 of your employment were negotiated on that basis; is
61
1 perspective. You had been there for only a year?
2 A. Yes.
3. Q What was your reaction to this reason for not extending
4 your contract?
5 A. Iwas disappointed, I was fully committed to Post
6 Office. When I was recruited by Nick Read, I absolutely
7 committed to him that it was something like a three-year
8 tenure, to make sure that I could make a difference, and
9 particularly break the back of the NBIT deployment. But
10 by then a number of new SEG members were being brought
ca in, particularly from Camelot, that were known to the
12 new interim Chair. So that had happened previously with
13 other roles, and now that was happening with the Chief
14 Transformation Officer role.
15 MSPRICE: Sir, those are all the questions that I have for
16 Mr Brocklesby. There may be some CP questions. There's
17 at least two sets of CP questions -- three sets of CP
18 questions, sir.
19 Questioned by SIR WYN WILLIAMS
20 SIRWYN WILLIAMS: All right.
a Let me just ask: when you departed, who took over
22 your role?
23 A. Agentleman named Andy Nice, who was the former Chief
24 Transformation Officer at Camelot.
25 SIRWYN WILLIAMS: So it was someone brought in?
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that right?
A. Correct.
It's right, though, isn't it, that you commenced as
a contractor instead?
A. Correct.
Why was that?
‘A. What I was told was that, despite RemCo having approved
my appointment, it was subsequently considered necessary
for the Department to also sign off on my appointment,
and my understanding is that approval was never
received. So I continued on a contract basis
How long did you expect that you would be working on
a contractor-based contract when you started?
A matter of weeks.
2
2
But one was not approved at all in your tenure?
Correct.
What do you think accounts for that state of affairs?
I don't know. I asked on a number of occasions as to
what was happening, and whether that was going to
ultimately be approved. But it was unclear why that
approval hadn't been given.
Pp oOro>
Q._ You say at paragraph 80 of your statement that you were
told in July of this year, by the acting CEO, that your
contract was not going to be extended as he and the
interim Chair wanted to bring in someone with a fresh
62
AL Yes.
SIR WYN WILLIAMS: Not at the Post Office?
A. Onan interim basis
SIR WYN WILLIAMS: Yes, he's on an interim basis as well?
A. Yes.
SIR WYN WILLIAMS: Right, fine. Thank you. Let the CPs ask
their questions, then.
Ms PRICE: Thank you, sir. Starting with Ms Page
Questioned by MS PAGE
MS PAGE: Mr Brocklesby, thank you. Can I just ask about
Project Phoenix again very briefly.
A. Yes.
Q._Itstarted in January of this year. Why did it start
then?
A. I don't know, I'm afraid.
Q. Was it because there was a furore after Steve Bradshaw
gave evidence at this Inquiry and it was revealed that
he was still effectively working in a post he should not
have been?
‘A. I don't know that for sure. You know, he was clearly
named in a number of the cases within scope for Project
Phoenix so it is definitely any part of the
investigation.
Q._ Do you have any light to shed on why nothing was done
about that between, let's say, the Hamilton rulings and
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January this year?
A. No.
MS PAGE: Thank you. Those are my questions.
SIR WYN WILLIAMS: Next, please.
left, I think, in September. We can see here there's
a section on the Investment Committee and the Inquiry
has heard a little bit about the Investment Committee
and its oversight of NBIT. It says here:
"The IC met on 16 May and focused on SPM.”
MS PATRICK: Thank you, sir. Now, first, "SPM", is that Strategic Platform
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Questioned by MS PATRICK 5
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Modernisation?
Patrick and I act for a number of subpostmasters who A. That's correct. It's the programme name that is
were convicted and have since had their convictions 9 delivering the NBIT ~
overturned. 10 @. Thank you, that's it. So it's the overarching programme
I have a couple of questions about one document, and "1 which is responsible for NBIT?
if we could go to POL00448648, I'd be grateful. I want 12 A Yes.
to look at one issue and it's going back and picking up 13 Q. Great. It goes on:
again the question of NBIT and the Fujitsu extension. 14 "There were uncertainties in respect of the project
We'll just wait until the document comes up. 15 across a number of issues including funding. Two
It should appear, it's going to be the minutes of 16 external reviews had been completed in respect of the
the Board from 4 June this year. Thank you. 7 project and both concluded red ratings. The build/buy
Can you see that there, Mr Brocklesby? 18 point had been considered, although the build approach
Ido. 19 without the necessary in-house expertise seemed flawed.
If we can see your name, you were in attendance at this 20 NRa [I think that's Nigel Railton] shared his view that
meeting; can you see that there? 21 the conversation on buy/built was the wrong question and
Ido. 22 thought that the question was build/build and then the
I want to ask about a few items in the minutes. Can we 23 question was whether to build internally or externally.
look at page 5 at the bottom, please, under section 3.5, 24 There needed to be a number of conditions met for
please. Now, this is June this year, shortly before you 25 a successful internal build however such as a staple
65 66
business, good governance and quick decision making. 1 clearly it's a report of a conversation at the Board
With the Company not fulfilling these conditions the 2 that I wasn't included in. So, yes, there was
view of NRa was that a third party should be 3 a conversation at a Board Meeting
commissioned to build. NRa advised that he saw 4 Q lonly ask you because, at this point, as I understand
3 options, firstly, SPM could carry on as was, secondly 5 it, you would have been responsible for oversight of
a third party could be engaged to build the new system, 6 NBIT still?
and thirdly that Horizon could be brought in house. All 7 A. Yes.
of these options needed to be carefully considered.” 8 Q. Were there still conversations going on about what the
It talks about the dashboard reporting up to IC, and 9 replacement would look like, whether it was being bought
then the last paragraph: 10 from somebody else, built in-house, built by somebody
“The Chair noted that the paper ... included in the "1 else or, as a third option: bringing Horizon as it stood
pack seemed surprisingly positive", and so on. 12 back in-house at the Post Office, as late as this year,
So this is June this year — 13 in June?
Yes. 14 A Yes
-- almost a year after you've come into post and quite 15 Q. Thank you
some considerable time after of the judgments in the 16 A. I think the logic here is somewhat confused. The point
Common Issues judgment and the Horizon Issues judgment. 17 about Horizon insourcing, I think, is a separate point
Now, were there still conversations going on in the 18 because, clearly, it doesn't get you to the same
business as to whether the replacement Horizon would be 19 outcome, which is a replacement for Horizon. The new
bought or built, in June this year? 20 interim Chair came in with a very clear view that he
Sorry, you're nodding, Mr Brocklesby. If you're 21 thought that Horizon should be insourced, and that is
saying yes or no, you have to say so for the transcript 22 being considered, I understand, as we speak, and there
This was not a conversation that I was included within, 23 may well have been a decision at the September Board
so this is a report from the Chair of the Investment 24 meeting after my departure, and I think that’s
Committee, so I am reading the paper and nodding because 25 completely separate from how to progress with SPM.
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I would say I find the debate about — in a kind of
build ourselves or build with a third party, also
slightly odd, in as much that we aren't just building —
I say “we" ~ sorry, I've leff, I revert to that,
I can't help myself ~ the Post Office has two very
material partners in Accenture and Coforge, so they're
not trying to build the system completely on its own.
It's got two expert development partners working
alongside it in order to build the new NBIT application.
We may come back to that issue about whether to build,
buy or bring in-house in a moment. But there, when it
says, "The Chair noted the paper seemed surprisingly
positive", were you involved in whether there was any
response to the Chair's question mark about whether the
paper was surprisingly positive?
Well, clearly, it refers to the fact that there is
a separate paper to be presented later in the meeting.
Okay.
So I presume would have responded to any questions that
the Chair had at that time.
Okay. Thank you. There is at least a part of the
meeting I would like us to look at and, unfortunately,
Ihave to find the page reference, so if you could bear
with me for a moment.
I'd like to look next at the section on transforming
69
IPA review. [You] advised that the articles had not
been well received and a number of questions had come in
from Fujitsu and the banks..."
You say, in relation to the IPA review, you were
asked by SJ whether you were confident and whether it
would go through and answer all the points in the review
satisfactorily, and you answered that.
If we go on a little bit further, at the bottom —
I apologise for this, I'm trying to find the relevant
section ~ if you then go to the bottom, you say, the
next section after that, that SO spoke to a paper
outlining the proposal for a five-year exit plan for
Fujitsu
Now "SO", would that be Simon Oldnall.
Yes
He's your direct report?
He is.
It says:
"SO advised that the Board were being asked to
include in the strategy a stage where if NBIT was not
completed within the term of the extension that the
Company would put in place an alternative approach to
supporting the Horizon platform to make sure that
Fujitsu was still able to exit at the 5-year point. SJ
queried what the alternative approach would constitute.
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technology, which starts on page 10. If we could scroll
down to that, I'd be very grateful. It's section 7.1.
I think we can see there you do join the meeting at
a later point
Yes.
—and you speak to a paper entitled "SPMP Update
Paper”, and that you're going to be talking about the
last update to the Board and updating on progress sense.
You're talking about the spectrum of services available.
You say that there's ongoing engagement with postmasters
and it had been well received.
At that point, you said it had been remaining within
budget and there was progress being made on recruitment,
and you going on to contractors working on the
programme, and so on and so forth. You wanted to talk
about some details there. I don't want to ask about
that; I want to ask about the next page. So if we could
scroll down, and we see there "SI", who I think is Saf
Ismail?
Yes.
Yes:
".. referenced the recent articles in Computer
Weekly and queried the mood in the team. CB [which
I think is you] outlined the 2 articles which had
covered the potential Fujitsu contract extension and the
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{Simon Oldnall] advised that the Horizon platform could
be brought inhouse or procurement undertaken for
external support for the platform. SO estimated that it
would be 18 months to 2 years when a decision would need
to be taken on this point..."
So just to take all of that on board, this sounds as
though planning is going on for Horizon still to be in
place, even after the prospect of an extension for five
years with Fujitsu; is that fair?
No. So may I explain?
Yes, please do.
So when we approached Fujitsu for an extension, one of
their immediate responses was, "This has to be the last
time, we don't want to extend our arrangements with Post
Office but we understand you're reliant on us and,
ultimately, we will need to and we will extend”
We then talked about a proposal for up to five
years, which covered the plan to build NBIT and deploy
it by the end of 2028, and gave us contingency if there
were further delays. This was a request from Fujitsu to
say, "Based on the fact that this has to be the last
time you extend the contract, we, Fujitsu, want to
include in the terms of that extension a guarantee that,
if for whatever reason NBIT is not fully deployed by the
end of the five-year term, that you will instigate
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an alternative strategy to make sure that you are no
longer reliant on us to support Horizon".
So it was us responding to requests from Fujitsu
rather than us undertaking in any way a plan to extend
Horizon after that time period.
Indeed. It's being requested by Fujitsu but this is now
some time on. As you said, you came in in mid-2023,
we're talking, several years after the judgments in the
Common Issues judgment and the Horizon Issues judgment,
when some of our clients had been raising problems with
Horizon for near decades.
Now, we are now here and the prospect of a drift
where Horizon would stay in place, albeit brought
in-house under the Post Office's auspices, that's.
a conversation that's on the table with the Board, isn’t
it?
It's a response to a request from our supplier.
Is it a realistic request from your supplier, noticing
that perhaps there has been some considerable drift in
this project already?
I don't believe it was realistic to assume that Horizon
would be operating past March 2030.
MS PATRICK: Okay, thank you, Mr Brocklesby. That's all the
questions I have for you.
THE WITNESS: Okay, thank you
73
term extension to fully migrate from Horizon to NBIT
So that's what I think you've been trying to say:
essentially the extension is approved for five years
and, within that time, frankly, fingers crossed,
hopefully you can sort it out in-house?
The second point is: if during the intervening period
between now and 31 March, it becomes apparent that,
Horizon is required before 31 March, we will commit to
initiating an insource project in sufficient time so
that we don't have to go back to Fujitsu and ask them to
extend yet again past 31 March 2030.
So the crux of this is that the Board has approved the
extension of the Horizon system and its use by
subpostmasters until 2030; do you agree?
Ifrequired. But the contract is such that it's up to
five years, so we can terminate earlier, when and if
NBIT is deployed. So it might be up to five years, but
if the plan sticks as it is today, then that would be
terminated earlier, namely at the end of 2028.
Right, and things always go extremely well at the Post
Office in terms of meeting timings, requirement and
output; do you agree?
We have a plan —
Yes.
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Questioned by MR STEIN
MR STEIN: Sir, could the document remain on the screen that
we currently have. Could we go, please, to page 12 of
the document, middle of the page, please.
If we look there and highlight "The Board RESOLVED
that"; do you see that entry, Mr Brocklesby?
A Ido.
Q._ I think this is what you've been trying to say. First
of all, let's just understand, for the Chair's note,
that the Board resolved at this June meeting that:
"Subject to seeking a 3-year break provision, the
proposed strategy for an extension of up to 5 years of
the Horizon Support contract with Fujitsu from 1 April
2025 [written with no irony] until 31 March 2030 be and
is hereby APPROVED..."
So that's the first part, yes?
A. Yes.
Q._ So what this is essentially saying is that the Board is,
approving the extension until 2030 of the contract with
Fujitsu and then, point (ii), there is reference to:
"The inclusion of a binding commitment to Fujitsu
that an alternative approach to supporting the Horizon
platform through commencement of a programme to
insource/reprocure elements [other corporate speak] be
activated if there is not sufficient time within the
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A. —I think a well-constructed plan to get the system
delivered by the end of '28.
Q. Allright. Let's have a look at something else.
POL00000254, page 34. We can see there, page 1,
"Standard Subpostmasters Contract”. There may be
different versions of this, I'm aware they exist on our
document system, but this is the one that I think will
at least help us with what happened after the Fraser
judgments and, therefore, what happened in relation to
at least the drafting of contracts and subpostmasters in
that regard. Page 34, please.
I'm going to take us to paragraphs 20.4, 20.5 and
20.6. If those three could be highlighted, I'd be
grateful
So Mr Brocklesby, these are contracts that have been
looked at, considered, after the Horizon High Court
judgments, okay? Right. Now I'm assuming that when you
came into post you must have read those judgments?
A. The judgments, not the contract, yes.
Q._ Right, well, you read the judgments, and then one of
your jobs, if not the main job, was to implement, if you
like, the result of those judgments; is that correct?
A. Yes, many of those judgments had already been
implemented —
Q. Right
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~ by my arrival
You're aware, having read those judgments, that, if you
like, the starting point for all of the scandal is that
subpostmasters were being blamed for shortfalls and told
to pay up, and all too often prosecuted; you're aware of
that background, it's a simple background?
Lam aware of that
Okay, let's have a look then at 20.4 and see what the
contract was saying then about matters after the
judgment. So 20.4:
“Properly and accurately produce all relevant
records and/or explain all relevant transactions and/or
any alleged or apparent shortfalls attributed to the
subpostmaster ..."
Then 20.5:
“Cooperate in seeking to identify the possible or
likely causes of any apparent or alleged shortfalls ..."
In 20.6, there's a kind of cover-all, I'l read this
one more slowy:
"Seek to identify the causes of any apparent or
alleged shortfalls, in any event ..."
Okay?
Yes.
Right. So you understand the historic background. High
Court judgments, shortfalls, problematic subpostmasters,
7
postmasters' queries, people who respond to postmasters
when they hit the Review and Dispute button.
Right. So the Dispute button and the phone lines, who
is maintaining the monitoring of the phone line and
where is that reported to?
Into the Retail Team at Post Office.
Right. Is that reported to the Board?
It reports into the SEG — who are responsible and,
ultimately, of course, everything reports in to the
Board, yes.
As an example, are issues that are commonly occurring in
relation to the helplines summarised, given maybe
percentage number, sent up to the Board for the Board to
review, so they can keep an eye on this?
It's not my part of my responsibility, was not part of
my responsibility. I'm aware that there's a retail
dashboard that's quite a detailed dashboard, with a lot
of data in terms of how those teams are operating, and
that is a dashboard that's reviewed by SEG and the Board
on a monthly basis.
Is that a long way of saying, "I don't know whether it's
summarised and put to the Board in a way that analyses
the commonly occurring issues"?
It's not -- it wasn't part of my responsibilities to run
those teams.
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people being prosecuted, contract being amended to try
and make sure that shortfalls are looked at and
considered carefully.
Right. Now, you answered a question of Ms Price's
earlier about shortfall matters and investigation. Your
answer was this: you're not aware of that level of
detail, in other words what is going on to investigate
shortfalls.
I'm not aware of, yes, the investigation into individual
shortfalls with postmasters.
Well, how, then, is this contractual term being
maintained, and I use the cover-all one, because that’s
the simplest one to look at here:
"Seeking to identify the causes of any apparent or
alleged shortfalls, in any event ..."
Now, that's to say to people, subpostmasters, that,
“Look, we're taking this seriously. We're going to look
at shortfalls. If you've got a shortfall, don't worry,
we're going to cover it". How is that being maintained
in terms of a contractual requirement?
By the Business Support Team and the Network Support
Team —
That's who; how?
People in the Retail Team, people are -- that man the
business support phone lines that respond to
78
So you don't know. Right.
Now, you were referred to the letter from
Mr Patterson, dated 17 May ‘24. I'll have that on
screen, please, FUJ00243199. I'm grateful. Scroll
down, please, and stop there if you would. What it says
there, second paragraph:
“To be clear FSL [Fujitsu] will not support the Post
Office to act against postmasters. 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."
Then continue down to “pursuit of Shortfalls from
Postmasters", please, section, at point (i) of that
page. We've looked at this before, Mr Brocklesby, so
I'm going to cut this down to the last sentence. So
this is from Fujitsu, this is Mr Patterson, who, if
I remember correctly, European Manager of Fujitsu. This
is some that should know his stuff. It's saying this,
“Pursuit of Shortfalls from Postmasters":
“It should not be relying on Horizon data as the
basis for such shortfall enforcement.”
Then further down, please ~ I don't think I need
take it any further on that.
This appears to be Mr Patterson saying, not just
about criminal matters, it's about shortfalls, it's
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about enforcement, it's about analysis or provide — or
use of Horizon system data, and it's essentially saying,
this is Fujitsu, "Given the history of this matter,
given problems with systems, don't use our data".
That's Fujitsu saying that
Now, when we go back in time to look at this
contractual requirement that I've been discussing with
you about shortfalls, to analyse, look into, consider
those shortfalls, how on earth is that being done with
Fujitsu being involved, if they're not prepared to play
ball?
I was very surprised by this letter when I was shown it
by Nick Read. My initial reaction was to check whether
anything had changed, whether any new defects had been
raised by either ourselves or Fujitsu, and they hadn't.
I didn't understand the fact that they were prepared to.
provide detailed data in paragraph 3 here to assist with
postmaster redress, but weren't then suggesting that
exactly the same data could be relied upon for shortfall
enforcement. It didn't strike me as consistent.
I believed at the time this letter was written
specifically to be discovered by this Inquiry, and
I could see no other reason why, at this particular
time, considering that this version of Horizon has been
supported by Fujitsu for many years, they have hundreds
81
about this. We've gone to the 2020 version of
a contract that is post-Mr Justice Fraser's judgments,
So it is one that is clearly designed to try to say that
"Shortalls are not to be tolerated, we're going to look
into them’.
That's 2020. This letter is four years after that.
How on earth has a situation arisen whereby, from 2020
to 2024, it's taken all that time that Fujitsu don't
believe you can rely on their data from the Horizon
system to look at these things like shortfalls?
Well, I think that is a question for Fujitsu
Well, it isn't, Mr Brocklesby, because one of the things
that you were brought in to do ~
SIR WYN WILLIAMS: Mr Stein, he hasn't been there for three
of the four years. So I think it's a question that's
too wide in its current form.
MR STEIN: I'll cut it down.
You were there for about a year, Mr Brocklesby. One
of the issues, it relates to what's going on with the
system, trying to implement the changes that were put
forward through the judgments at the High Court. You
started in, I think, May 2023. Why, between May '23
until the time whereby you're essentially being asked to
leave the company, why did you not look into the
question of what support is Fujitsu playing in terms of
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of technical experts supporting Horizon, they know that
it's used by postmasters on a daily basis to run every
aspect of their business, and we have an open book in
terms of the outstanding defects on the system, and they
know that none of those branch affecting defects would
materially impact any of the data on the system, that
I didn't understand why this statement had been made.
Let me test that in two different ways. First of all,
in your answers to Ms Price earlier you were saying that,
you believed that this letter related to a particular
criminal case. That's my summary of what you appeared
to be saying. So you seemed to be saying that it was
connected with a criminal matter. One of the reasons
why I've raised it with you Mr Brocklesby ~- you can
speak in a moment, forgive me for putting it that way —
is because I just wanted to make sure that you are aware
that letter covered more than just criminal matters: it
covered civil matters, it covered shortfalls. So your
understanding of this letter was it based upon what you
thought at the time, in your recollection, were criminal
matters only?
No, when I answered the previous question from Ms Price,
I was responding to a question about the first
paragraph.
My second point, in terms of testing what you're saying
82
looking at this data question?
So I started in August '23. There was no equivalent
issue raised by Fujitsu until this letter, later in
2024. So there was nothing to respond to, in terms of
their question.
Why didn't Post Office check to see what support Fujitsu
was prepared to supply? I mean, I accept entirely you
came in in '23, that's years later. But it seems as
though nobody has looked at this and said to Fujitsu
“Hang on, everybody, will you provide support for this
function?"
It was providing support for this function, it was ~
SIR WYN WILLIAMS: Well, that's the question I wanted to ask
A.
you, Mr Brocklesby. Until this exchange of
correspondence, which I accept began with a request by
the Post Office that Fujitsu should facilitate a police
investigation, and then it widened out in the way that
Mr Stein has drawn attention to, until this exchange of
correspondence, had Fujitsu said anything along the
lines that they'd said in this correspondence, or failed
to provide support?
Not to my knowledge, no, sir.
SIR WYN WILLIAMS: Right.
MR STEIN: The question I've got that arises out of that is
this: what protocols, guidance, agreements were put in
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place, to your knowledge, post-the Horizon judgment and
the High Court, with Fujitsu, to ensure that they
provided such data for shortfall consideration? So what
guidance, protocols, or documents or agreements were put
in place with Fujitsu, so that they were providing the
material?
I don't know in any level of detail but, for example,
there's an ARQ process, which ~ whereby we could
request specific data, transactional level data from
Fujitsu to help with various investigations. That was
something that was common practice.
Okay, Mr Brocklesby. Let's try one more time on this.
So 2024, revision of contract. You would have thought
that the Post Office would have checked with Fujitsu in
some form of agreement, a document, a protocol,
guidance, some way of judging that Fujitsu were on board
with this type of investigation looked at in the
contract. Are you aware of any such of a discussion
document, agreement protocol?
No.
Fine. I'm going to take you to the YouGov document,
please, which is EXPG0000007, page 4, please. Grateful.
Can that be expanded? Yes, thank you very much
Ifyou can just go down the page, this is the
“Executive summary’, as you can see, Mr Brocklesby.
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subpostmasters surveyed, if I recall correctly, was just
under 1,000; it was 950 people that responded from the
subpostmaster group, okay?
Okay.
Now, look, 'm no mathematician, I think anyone will
agree with that, but this still seems to me to be
a large number of people out of group of subpostmasters
who were experiencing still the same problems with
shortfalls, discrepancies, difficulties, people talking
about surpluses as well. So it's missing money and it's
too much money, and they can't resolve it, and people
still paying out themselves.
Now, I've got two real questions that arise out of
this: what on earth is going on with this system that,
in 2024, by the time of this report in September 2024,
that these issues are still going on, Mr Brocklesby?
I don't know how to answer that. I mean, it's something
that I think the Post Office would need to look into
further, in terms of the -- particularly the number of
postmasters in this survey that experienced
discrepancies. I mean, discrepancies can be created for
a whole host of reasons, and it's something that we'd
have to deal with -- people would have to do some more
analysis on, in terms of making sure that they
understood why these were being created
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A. Yes
Q._ Okay, let's look at the second paragraph:
“The vast majority (92%) of SPMs surveyed reported
experiencing some form of issue with the Horizon IT
system in the last 12 months. This most commonly took
the form of screen freezes (70%) and/or loss of
connection ...."
Moving on:
“Over half (57%) said that they have experienced
unexplained discrepancies, with lower but still
significant proportions mentioning unexplained
transactions ... missing transactions’, and so on.
Then further down under "Discrepancies in the
Horizon IT System’, if we look, then, at the second
paragraph again:
“Almost all (98%) of the SPMs surveyed who have
experienced a discrepancy reported that they were
shortfalls, whilst around a third (34%) had also
experienced surpluses.”
Then perhaps crucially:
"When asked how these discrepancies were typically
resolved, it was most common for SPMs to report using
their branch's money or to have resolved it themselves
(74%)."
Now, one additional fact, the numbers of
86
Q._Mysecond point about this is culture, okay? There's
a lot of talk about culture and we're going to get
further witnesses talking about culture within the Post
Office.
A. Yeah.
Q. What work has been done on the culture within the
subpostmaster branches? You've got people that have run
these branches for ages, under essentially a system
that's broken, that's poor, that has sometimes
tyrannised them within their branches, people are afraid
to come forward, even out of the group of people working
in the branches, and that culture is no doubt repelling
people, when they're getting discrepancies to still pay
up, not use the button that says there's a problem, not
use the helpline to say to them there's a problem.
People are still paying up for shortfalls.
Do you agree that there's a culture problem that has
yet to be addressed with the people running the
branches? Not their fault, i's what's happened to them
that's causing it; do you agree with that,
Mr Brocklesby?
A. I don't recognise a culture problem that remains, no.
Q. What, you don't recognise a culture problem with people
within the branches of the Post Office still paying up
for shortfalls out of their own pocket or branch money?
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That may be valid
Project Phoenix, Mr Brocklesby, just so that you can
help a little bit further with that. We have some
information because some of our clients are affected by
this; they've essentially been at the centre of
investigations. Is it Project Phoenix, the project
that's employed ex-police officers to look into and
conduct investigations?
Yes, I think ~
Have they completed something like 18 internal reviews
or is it more?
In terms of the cases ~~
Individual cases.
--[ think it's more.
It's more. Have they been provided to the Inquiry?
don't know.
Have they been provided to the individuals who were the
subject of those reviews?
I don't know for sure. Certainly postmasters were
the postmasters affected were offered an interview, so
that they could provide more colour and clarity around
their original evidence to the Inquiry.
Are the people, to your knowledge, who are the subject
of these reviews going to be provided with a copy of the
review about their issue?
89
very brave in my opinion in coming to those meetings.
You'll understand that sometimes some people frankly
can't come to the meetings at all, don't want to take up
the offer -
Yeah, I understand that.
- or the other way round, too angry —-
Yes.
not wanting to engage; you understand that?
do understand that.
Mr Brocklesby, I don't know whether the right word is
“pleased” but you may be interested to learn that
people's reports about those meetings that included you
were very positive, that you listened, appeared to
listen, you appeared to gain information and you
appeared to be affected by the meetings and what people
said; is that a fair summary of how it came across to
you?
It is a fair summary. I found them enlightening but
very, very difficult.
Do you understand also that, as we know from your
statement and the evidence you've given with Ms Price
that, therefore, when you leave the Post Office, you
take with you that memory, your personal memory, of
those meetings, the lessons you've learnt, and that that
part of your, if you like, corporate involvement on
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I don't know.
Do you not think that’s a good idea, Mr Brocklesby?
Yes, I do think it's a good idea.
You were engaged with some of the meetings with our
clients. These are restorative justice meetings;
correct?
Yes.
You took part in the meetings, I think, in July this
year; is that correct?
Yes.
I may get the numbers wrong: five, six, seven meetings,
something like that?
Yes, it was over two days. It may be a little more than
that but something like that, yes.
These meetings, you're aware, I think, Mr Brocklesby are
difficult for the people that come to the restorative
justice meetings?
Very difficult, yes.
You'll understand when I say that people actually have
to summon up the courage to actually attend at all?
I really did ~ I didn't understand that before but, as
a consequence of going, I understand that many people
had suffered so much that they find it difficult to
travel and, in some cases, have found it very difficult
to talk about what they've been through and they were
90
behalf of the Post Office largely goes with you when you
leave the Post Office?
Yes.
Do you understand that goes? Others that have taken
part in those meetings, I think Mr Read, who sits behind
me today, has also been engaged in those meetings and
also, we believe, has been affected by them, and he is
also leaving the Post Office. Did you see that what is
happening is that this corporate churn, these
individuals that are, for you, just what, about a year
or so at the Post Office, other individuals, longer term
like Mr Read at the Post Office, engaging in these
meetings ~ I don't know whether our clients are going
to say it was a waste of time but it does feel a deep —
there seems to be a real shame that this understanding,
this knowledge, this emotional memory of what has
happened with subpostmasters through these discussions
is going to be lost from those people like yourself that
are leaving; do you agree?
Yes, I hope the new members of the Executive Team engage
in the whole process, and I certainly tried to share my
experiences when I returned to make sure people
understood, that hadn't done those sessions, just how
those postmasters and, I think, for me most importantly,
their families, had been so impacted and in ways that
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I hadn't previously understood, and the fact that that
impact was still being felt today, in some cases decades
after the events that actually impacted them and their
families.
MR STEIN: One moment, Mr Brocklesby.
Thank you, Mr Brocklesby.
Further questioned by SIR WYN WILLIAMS
SIR WYN WILLIAMS: Mr Brocklesby, I'm sorry to go back over
one or two things that you've been asked about but
I want to get as clearly in my mind as possible where
the Post Office had reached in terms of the new system,
as I'l call it, at the date you left. All right?
A. Yes.
SIR WYN WILLIAMS: Because we've looked at lots of minutes,
and all the rest of it, but I want your understanding,
if I may, of where we had got to or where the Post
Office, rather, had got to.
A. Yes. So~
SIR WYN WILLIAMS: First of all, can I work backwards?
A. Yes.
SIR WYN WILLIAMS: As of the date you left, were there, so
far as you were aware, any concluded contracts with
Fujitsu which related to any kind of extensions?
A. No, there were not.
SIR WYN WILLIAMS: Right. So when we're looking at minutes
93,
the period of time between the middle of 2026 and the
end of 2028.
Through that period, the Post Office will then start
to be able to tum off some of the services provided by
Fujitsu, until the end of 2028 when it will be able to
tum off the final of those services and cease to rely
on Fujitsu to support Horizon because every branch will
then be using the new system to serve its customers.
SIR WYN WILLIAMS: My last question is: so far as you know,
as of September 2024, was the necessary finance for
those things to happen approved?
A. No, it was not. Because of this incremental nature to
funding ~
SIR WYN WILLIAMS: Can I just ask you, and you tell me if
this is too simplistic, but which part, if any, of that
plan did have approved finance?
‘A. Itwas being approved in slices, in terms of timing. So
all of those activities, ie activities on Horizon and
activities for the new system, have been approved up to
the early months of next calendar year. So something
like January and February 2025. So new funding to move
forward past those dates will be required in short order
to make sure all of those activities can continue.
SIR WYN WILLIAMS: Would I be correct in thinking that, if
finance is approved, in effect, in tranches, as it is
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1 and resolutions, that's any one side of the story. So
2 far as you know, by September 2024, there were no
3 concluded agreements?
4 A. Yes. That's correct.
5 SIRWYNWILLIAMS: Right. That's clear in my mind.
6 Second thing I want to be clear in my mind is your
7 view of what will occur if things go to plan.
8 I appreciate things may not go to plan but I'd like you
9 to tell me what you think will happen if things go to
10 plan.
11 A. Yes. Let me try and summarise. If things go to plan,
12 between now and June 2026, this new system will be
13 built. It's being built incrementally starting with
14 a certain number of the transactions that postmasters
15 use and, building on that, more and more and more
16 transactions. In parallel with that, the system will be
7 piloted in up to 50 branches, so that we get postmaster
18 feedback and experience of the new system.
19 If that all goes to plan, then from June 2026, then
20 the system will actually be starting to be deployed into
21 branches. That means starting to turn off Horizon in
22 that branch and move to that branch fully relying on
23 NBIT by postmasters to serve its customers.
24 That process of training postmasters in the new
25 system, cutting over from the old to the new, will take
94
1 going along, we are talking about approving finance for
2 a period of work which covers months only, not years
3 into the future?
4 A. Yes, thatis correct. The funding discussions have
5 clearly been complicated by a general election and
6 a spending review from the new government. So the
7 expectation is that, at best, the next tranche of
8 funding would be for another year, to take it, I think,
9 through to March 2026. So again, that would just be
10 another tranche and other tranches would be subsequently
"1 needed
12 SIRWYN WILLIAMS: Again, if I am being too simplistic,
13 please tell me, but, ultimately, this is not the Post
14 Office funding things from its own generated funds; this
15 is all roads lead to the Treasury, yes?
16 A. That's correct. There are some projects that -- the
17 project is able to fund itself but, certainly, there are
18 a bundle of transformation projects, including the SPM
19 programme, which need to be funded outside of Post
20 Office's finances.
21 SIRWYN WILLIAMS: One last question: I have heard from
22 other witnesses that there is, as we speak, a strategy
23 review being undertaken.
24 A. That's correct.
25 SIRWYN WILLIAMS: Does that have any impact or potential
96
(24) Pages 93 - 96
OYE ARON A
The Post Office Horizon IT Inquiry
impact on the progress or otherwise of the plan that
you've explained to me in summary?
A. Itabsolutely does have potential impact in terms of the
size of the branch network -- products that will be
continued to be sold or discontinued would all impact
the scope and timelines of the project. So that does
deliver a certain amount of uncertainty to the
programme.
SIR WYN WILLIAMS: Well, on that note -- I won't say happy
or unhappy -- thank you very much for your evidence,
Mr Brocklesby. I am grateful to you for your witness
statement and for your oral evidence.
THE WITNESS: Thank you.
SIR WYN WILLIAMS: Right, Ms Price. We have a day off
tomorrow, do we? When I say a day off, we are not
having a hearing tomorrow, I think is a more accurate
way of putting it, and we resume again on Friday, yes?
MS PRICE: That is correct, sir.
SIR WYN WILLIAMS: Thank you very much.
MS PRICE: Thank you
(12.59 pm)
(The hearing adjourned until 10.00 am
on Friday, 4 October 2024)
97
INDEX
INQ00001190
INQ00001190
2 October 2024
CHRISTOPHER WILLIAM BROCKLESBY (affirmed) ..1
Questioned by MS PRICE ..
Questioned by SIR WYN WILLIAMS
Questioned by MS PAGE .........
Questioned by MS PATRICK .....
Questioned by MR STEIN ....
Further questioned by SIR WYN WILLIAMS.
98
63
64
65
74
93
(25) Pages 97 - 98
INQ00001190
INQ00001190
MR STEIN: [4] 74/2
83/17 84/24 93/5
MS PAGE: [2] 64/10
65/3
MS PATRICK: [2]
65/6 73/23
MS PRICE: [16] 1/3
1/5 1/9 1/14 1/20 1/25
45/16 45/21 45/24
46/3 46/6 54/20 63/15
64/8 97/18 97/20
SIR WYN WILLIAMS;
[37] 1/4 1/8 1/13
4/19 1/22 45/20 45/23
46/5 53/13 53/18
53/22 54/5 54/10
63/20 63/25 64/2 64/4
64/6 65/4 83/14 84/13
84/23 93/8 93/14
93/19 93/21 93/25
94/5 95/9 95/14 95/24
96/12 96/21 96/25
97/9 97/14 97/19
THE WITNESS: [2]
73/25 97/13
"23 [3] 83/22 84/2
84/8
"24 [2] 31/4 80/3
"25 [6] 31/3 31/4 31/6
34/1 34/7 38/1
"28 [1] 76/2
‘difficult’ [1] 51/1
"Dispute [1] 10/5
‘interim’ [1] 59/15
‘losses’ [1] 23/5
‘many [2] 47/25
48/11
"no [4] 48/12
‘there [1] 18/2
"turned [1] 40/15
‘witch [4] 51/6
1
1 April [1] 74/13
1 May [1] 27/4
1,000 [1] 87/2
10 [3] 6/10 49/14
70/1
10 February [1]
51/13
10.00 [1] 97/22
10.04 [1] 1/2
11 [1] 59/5
41 April [2] 27/4 27/6
11,700 [1] 33/25
11.21 [1] 45/25
11.35 [1] 45/22
11.36 [1] 46/2
12 [5] 7/8 10/1 12/45
13/18 74/3
12 months [1] 86/5
12.59 [1] 97/21
14 September 2023
[1] 30/17
45 [1] 45/21
15 December [2]
31/17 36/25
16 August [1] 2/10
16 May [1] 66/5
17 [4] 59/20
17 July [1] 18/13
17 May [1] 80/3
18 [2] 72/4 89/10
49 [1] 18/19
19 April [1] 27/18
2
2 years [1] 72/4
20 [1] 52/14
20.3 [1] 24/18
20.4 [3] 76/12 77/8
77/10
20.5 [3] 25/11 76/12
7715
20.6 [2] 76/13 77/18
2018/19 [1] 18/19
2020 [4] 24/10 83/1
83/6 83/7
2021 [1] 19/1
2023 [9] 3/17 30/17
31/17 31/18 44/10
59/22 60/1 73/7 83/22
2024 [19] 1/1 18/13
26/12 35/9 35/17
39/23 46/9 50/6 53/16
55/17 61/3 83/8 84/4
85/13 87/15 87/15
94/2 95/10 97/23
2025 [6] 30/9 33/15
33/18 44/10 74/14
95/21
2026 [6] 30/11 35/15
94/12 94/19 95/1 96/9
2028 [5] 35/16 72/19
75/20 95/2 95/5
2030 [5] 73/22 74/14
74/19 75/12 75/15
22 [2] 8/4 17/23
25 [2] 2/11 57/21
25,000 [1] 41/23
26 [1] 58/14
26 years [1] 3/5
28 May [1] 55/17
3
3 July [1] 31/22
3 options [1] 67/5
3.1 [1] 46/11
3.5 [1] 65/24
34 March [3] 75/8
75/9 75/12
31 March 2030 [1]
74/14
32 [4] 24/12 24/14
49/13 49/15
33 [2] 49/22 54/20
34 [3] 76/4 76/11
86/18
35 [1] 59/5
36 years [2] 3/6 3/7
38 [2] 9/24 13/17
4
4 June [1] 65/17
4 October [1] 97/23
45 [1] 6/18
5
5 million [1] 58/4
5 years [1] 74/12
5-year [1] 71/24
50 [3] 52/7 52/13
94/17
57 [1] 86/9
59 [1] 59/20
o
6 September [2] 3/19)
53/17
62 [1] 60/21
67 [1] 55/5
68 [1] 55/8
7 million [1] 22/10
7.4 [1] 70/2
70 [2] 35/6 86/6
73 [2] 17/22 17/23
74 [4] 86/24
8 July [1] 26/12
80 [1] 62/22
9
9 February [2] 50/6
50/9
92 [1] 86/3
950 [1] 87/2
98 [1] 86/16
A
abbreviated [1]
30/18
ability [1] 15/18
able [8] 14/7 15/21
29/4 58/25 71/24 95/4
95/5 96/17
about [59] 9/23 15/11
18/10 21/22 21/25
24/9 24/25 29/2 30/23
31/12 39/13 41/1 42/6
42/18 42/23 45/18
47/22 50/11 51/7 52/1
54/21 56/12 64/10
64/25 65/11 65/23
66/3 67/9 68/8 68/17
69/1 69/10 69/14 70/7
70/9 70/16 70/16
70/17 72/17 77/9 78/5
80/25 80/25 81/1 81/1
81/8 82/23 83/1 83/18
87/10 88/1 88/2 88/3
89/25 90/25 91/12
92/10 93/9 96/1
absolute [2] 22/2
22/4
absolutely [2] 63/6
97/3
abstained [1] 48/12
Accenture [1] 69/6
accept [3] 6/2 84/7
84/15
accepted [1] 48/2
access [2] 15/13
44/12
accord [1] 30/12
accountable [2] 4/5
56/9
accounting [2] 42/20
80/11
accounts [2] 23/15
62/17
accurate [3] 40/20
40/23 97/16
accurately [3] 24/20
25/7 77/11
accusation [1] 55/9
across [4] 32/25
57/24 66/15 91/16
act [2] 65/8 80/8
acting [1] 62/23
action [5] 8/15 18/20
48/17 52/8 52/9
action’ [1] 48/12
actions [1] 80/9
activated [1] 74/25
activities [7] 4/12
4/17 46/20 95/18
95/18 95/19 95/23
activity [4] 18/23
50/24 58/3 58/7
actual [1] 6/23
actually [5] 16/20
90/19 90/20 93/3
94/20
ad [1] 39/22
additional [1] 86/25
address [7] 7/7 8/4
8/15 8/19 36/10 39/10
56/4
addressed [3] 42/12
49/18 88/18
addressing [4] 8/7
8/13 9/7 55/22
adjourned [1] 97/22
adopted [1] 48/4
advertiser [1] 51/7
advise [1] 28/8
advised [4] 67/4 71/1
71/19 72/1
affairs [1] 62/17
affected [4] 89/4
89/20 91/15 92/7
affecting [1] 82/5
affirmed [2] 1/23
98/2
afraid [3] 51/22 64/15}
88/10
after [15] 11/11 51/12)
64/16 67/15 67/16
68/24 71/11 72/8 73/5
73/8 76/8 76/16 77/9
83/6 93/3
again [18] 13/16 15/8
15/10 17/8 18/3 22/25)
23/10 25/22 26/20
37/23 52/19 64/11
65/14 75/12 86/15
96/9 96/12 97/17
against [4] 26/25
44/9 80/8 80/10
agencies [1] 28/13
agenda [3] 12/13
12/16 58/10
ages [1] 88/8
ago [1] 50/19
agree [10] 19/19
22/12 58/8 58/9 75/15
75/23 87/6 88/17
88/20 92/19
agreed [2] 18/24 20/4I
agreement [3] 31/9
85/15 85/19
agreements [3]
84/25 85/4 94/3
ahead [1] 58/20
albeit [1] 73/13
alerted [1] 10/17
all [60] 4/12 6/15
11/6 13/8 14/1 14/2
20/2 20/22 21/17 22/5
22/23 23/5 23/12
24/21 25/7 25/8 25/15)
25/16 27/14 32/25
35/15 35/15 37/18
38/15 38/25 39/3
43/24 50/13 51/19
53/25 54/3 55/24
62/15 63/15 63/20
67/7 71/6 72/6 73/23
74/9 76/3 77/3 77/5
77/11 77/12 77/18
78/12 82/8 83/8 86/16)
90/20 91/3 93/12
93/15 93/19 94/19
95/18 95/23 96/15
97/5
allegation [2] 41/3
44/17
allegations [3] 50/14
56/22 57/7
alleged [8] 25/9
25/13 40/9 77/13
77/17 77/21 78/15
80/11
(26) MR STEIN: - alleged
INQ00001190
INQ00001190
A
allegedly [1] 44/19
allow [1] 6/1
almost [3] 50/19
67/15 86/16
along [4] 35/23 36/8
84/19 96/1
alongside [3] 5/12
38/18 69/9
already [5] 36/3 44/8
49/21 73/20 76/23
also [21] 4/12 8/3
8/12 8/16 11/25 13/24,
17/6 38/19 49/9 50/9
54/1 54/18 55/8 57/16)
62/9 69/2 86/18 91/20
92/6 92/7 92/8
alternative [8] 22/22
44/20 44/24 45/6
71/22 71/25 73/1
74/22
alternatives [2] 23/3
44/18
although [7] 4/8 9/17
29/5 30/6 58/5 60/3
66/18
always [5] 35/22 36/3}
36/14 58/21 75/21
am [13] 1/2 14/14
22/16 26/16 45/17
45/25 46/2 50/22
67/25 77/7 96/12
97/11 97/22
amended [2] 24/10
78/1
amount [1] 97/7
analyse [3] 10/7
15/22 81/8
analysed [2] 12/9
14/18
analyses [1] 79/22
analysis [3] 12/19
81/1 87/24
Andy [1] 63/23
Angela [1] 65/7
angry [1] 91/6
another [9] 6/5 34/19
36/15 36/16 36/21
45/18 48/14 96/8
96/10
answer [7] 53/10
57/4 57/9 61/9 71/6
78/6 87/17
answered [3] 71/7
78/4 82/22
answers [1] 82/9
anticipated [1] 45/13
any [54] 7/17 7/18
11/20 12/14 12/22
13/19 14/15 17/7
19/17 21/8 21/10
21/22 21/25 23/22
25/9 25/13 25/14
25/20 27/14 27/15
34/8 35/18 38/2 40/3
43/12 44/5 46/23 49/7
50/23 52/23 53/3 58/3
64/22 64/24 69/13
69/19 73/4 77/13
TTT 77/20 77/21
78/14 78/15 80/9
80/23 81/14 82/6 85/7
85/18 93/22 93/23
94/1 95/15 96/25
anyone [1] 87/5
anything [4] 11/11
42/18 81/14 84/19
apologise [1] 71/9
appalling [1] 26/18
apparent [7] 25/9
25/13 75/8 77/13
TTINT 77/20 78/14
appear [2] 57/11
65/16
appeared [5] 23/11
82/11 91/13 91/14
91/15
appears [2] 42/24
80/24
application [3] 10/14
16/7 69/9
applied [1] 9/20
applies [1] 60/16
appointment [3]
61/21 62/8 62/9
appointments [1]
59/17
appreciate [1] 94/8
approach [6] 17/21
46/15 66/18 71/22
71/25 74/22
approached [1]
72/12
approaches [1] 48/3
appropriate [5] 23/9
28/2 43/21 54/7 59/18
appropriately [1]
6/8
approval [2] 62/10
62/21
approvals [3] 38/24
39/7 58/11
approved [12] 39/10
62/7 62/15 62/20
74/15 75/4 75/13
95/11 95/16 95/17
95/19 95/25
approving [2] 74/19
16/1
approximately [3]
52/7 52/7 53/13
April [4] 27/4 27/6
27/18 74/13
ARC [1] 16/13
architect [1] 4/24
architecting [1] 6/7
are [87] 1/9 2/16 2/18
5/2 6/4 10/1 11/4 11/5
11/6 11/20 12/3 12/5
12/24 14/7 14/18
15/21 16/19 17/3
17/11 17/23 18/5 18/6
18/7 18/12 22/6 22/11
24/3 24/13 28/4 29/1
29/6 30/15 30/18 35/7
35/21 36/1 38/4 39/9
39/15 41/20 41/25
42/1 42/2 42/12 42/12
43/13 46/8 51/18
55/12 55/20 55/25
56/2 56/5 57/5 58/23
59/17 60/7 61/18
63/15 65/3 73/1 73/12
76/15 78/2 78/24 79/8
79/11 79/11 79/18
82/16 83/4 85/18
87/16 88/10 88/16
89/4 89/23 89/23 90/5
90/15 92/10 92/13
92/19 96/1 96/16
96/17 97/15
area [4] 5/17 10/19
10/24 13/22
areas [1] 57/25
aren't [2] 57/9 69/3
arise [2] 46/25 87/13
arisen [1] 83/7
arises [1] 84/24
arising [3] 5/18 19/1
38/2
arose [1] 46/24
around [8] 20/21
21/7 21/13 21/15
22/17 47/20 86/18
89/21
ARQ [1] 85/8
arrangements [2]
31/2 72/14
arrival [6] 33/9 33/10
33/14 34/15 60/11
77M
arrived [3] 5/22
33/19 34/4
article [1] 17/24
articles [3] 70/22
70/24 71/1
as [108]
ask [21] 2/4 9/23
10/13 11/23 12/14
18/9 22/25 24/9 27/15
37/24 43/16 63/21
64/6 64/10 65/23 68/4
70/16 70/17 75/11
84/13 95/14
asked [15] 11/13
15/9 15/10 21/16
29/10 30/23 44/17
54/13 54/19 62/18
71/5 71/19 83/23
86/21 93/9
asking [4] 24/25
37/21 38/19 40/3
aspect [6] 16/1 29/22
40/20 41/5 42/4 82/3
aspects [5] 11/4 11/5
16/3 41/11 41/14
assert [2] 22/5 22/6
assess [1] 15/18
assessed [2] 8/10
8/12
assign [1] 32/12
ned [1] 37/10
[2] 2/3 81/17
tance [1] 27/15
assisting [1] 29/19
associated [2] 19/22
31/21
assume [1] 73/21
assuming [1] 76/17
assumption [1]
33/18
assumptions [1]
33/16
assurance [10] 19/3
20/11 20/25 21/1 21/6
21/9 21/23 23/22 29/5
29/7
assurances [1] 21/21
assured [1] 19/3
at [141]
attack [1] 42/10
attend [4] 7/13 7/14
7/17 90/20
attendance [3] 18/14
30/18 65/20
attended [1] 46/10
attention [3] 26/13
26/21 84/18
attributed [2] 25/9
7713
August [8] 2/10 3/16
24/10 39/23 59/22
59/25 60/1 84/2
auspices [1] 73/14
authority [2] 58/1
58/12
autostop [1] 5/25
available [5] 11/21
52/25 57/9 60/4 70/9
aversion [5] 16/11
16/12 36/4 49/19
49/21
awaiting [1] 19/15
award [1] 58/10
aware [34] 14/14
23/24 24/1 25/5 28/21
29/18 29/22 36/23
37/5 37/7 37/12 37/13
39/17 39/18 43/9
43/11 43/15 53/6 53/9
53/11 56/10 56/16
56/21 76/6 77/2 77/5
77IT 78/6 78/9 79/16
82/16 85/18 90/15
93/22
awful [2] 33/23 51/10
B
back [14] 7/20 23/20
33/18 34/1 43/23
54/20 58/25 63/9
65/13 68/12 69/10
75/11 81/6 93/8
background [9] 2/23
18/16 18/18 40/7 44/1
44/16 77/6 77/6 77/24
backwards [1] 93/19
bad [1] 51/9
balance [1] 17/9
balancing [1] 19/2
ball [1] 81/11
Bank [1] 3/9
banks [2] 5/6 71/3
barrister [1] 1/17
Bartlett [3] 27/4
27/18 39/22
based [8] 15/24
22/20 24/6 33/19
35/10 62/13 72/21
82/19
basically [1] 10/15
basis [13] 12/7 14/4
15/15 15/25 48/13
51/17 61/25 62/11
64/3 64/4 79/20 80/21
82/2
be [131]
bear [1] 69/23
became [1] 8/3
because [26] 12/11
15/21 16/21 22/3
34/21 35/19 37/14
39/2 39/9 44/2 51/25
54/17 56/2 57/4 57/9
64/16 67/25 68/4
68/18 78/12 82/16
83/12 89/4 93/14 95/7
95/12
becomes [1] 75/8
been [104]
before [13] 1/5 17/5
28/20 32/5 42/13 45/2
51/6 53/2 58/23 65/25)
75/9 80/14 90/21
began [1] 84/15
beginning [1] 53/15
behalf [3] 2/5 49/8
92/1
behind [3] 19/9 42/1
92/5
being [54] 5/2 7/3
7/16 8/24 9/1 9/10
9/11 12/4 12/25 16/11
17/13 19/13 20/17
21/3 21/16 24/2 28/10
29/2 29/9 29/10 34/5
35/13 35/16 42/19
43/22 43/23 43/25
49/17 54/21 55/2
(27) allegedly - being
INQ00001190
INQ00001190
B
being... [24] 55/25
56/1 56/8 59/3 63/10
68/9 68/22 70/13
71/19 73/6 77/4 78/1
78/1 78/11 78/19 81/9)
81/10 83/23 87/25
93/2 94/13 95/17
96/12 96/23
BEIS0000776 [1]
30/15
belief [1] 2/17
believe [19] 7/19
11/6 11/8 11/22 13/7
14/9 15/9 21/2 23/20
41/3 42/22 47/2 47/2
51/11 53/25 57/1
73/21 83/9 92/7
believed [2] 81/21
82/10
below [1] 42/24
benefit [1] 18/7
Benjamin [1] 1/14
best [4] 2/16 29/14
49/9 96/7
beta [1] 16/21
better [2] 6/1 17/3
between [10] 7/7
26/3 27/3 27/4 56/6
64/25 75/8 83/22
94/12 95/1
beyond [1] 31/6
bid [1] 44/22
bid/offer [1] 44/22
binding [1] 74/21
bit [4] 50/5 66/3 71/8
89/3
blamed [4] 77/4
board [59] 12/8
12/11 12/12 13/24
14/24 15/1 15/7 15/8
15/10 15/17 15/18
16/8 16/13 17/15 20/5)
20/8 31/5 37/7 39/23
44/5 44/18 45/7 47/13
50/2 57/23 57/24 58/2
58/4 58/8 58/10 58/15
58/19 59/6 60/18
60/19 61/6 61/12
61/14 61/17 61/19
65/17 68/1 68/3 68/23
70/8 71/19 72/6 73/15)
74/5 74/10 74/18
75/13 79/7 79/10
79/13 79/13 79/19
79/22 85/16
boards [3] 17/16
17/19 58/24
book [1] 82/3
booked [1] 6/4
both [10] 12/7 18/24
19/15 26/16 28/8
34/24 42/7 49/9 51/4
66/17
bottom [9] 13/17
20/9 24/12 24/14
24/15 48/6 65/24 71/8
71/10
bought [2] 67/20
68/9
Bradshaw [1] 64/16
branch [25] 4/2 5/13
10/19 11/7 11/25
13/21 14/5 14/7 14/9
14/11 14/16 18/15
22/10 30/4 30/6 30/20
33/4 34/20 39/13 82/5
88/25 94/22 94/22
95/7 97/4
branch's [1] 86/23
branches [13] 6/2
16/17 32/21 33/25
35/15 88/7 88/8 88/10
88/12 88/19 88/24
94/17 94/21
brave [4] 91/1
break [4] 45/19 46/1
63/9 74/11
Breaking [1] 34/12
briefing [1] 44/18
briefly [1] 64/11
bring [6] 4/25 26/13
26/21 60/12 62/25
69/11
bringing [3] 6/5 6/7
68/11
broad [1] 9/9
broader [3] 16/4
27/12 44/25
Brocklesby [34] 1/5
1/21 1/23 2/1 2/2
44/19 46/6 53/14
63/16 64/10 65/7
65/18 67/21 73/23
74/6 76/15 80/14
82/14 83/12 83/18
84/14 85/12 85/25
87/16 88/21 89/2 90/2
90/15 91/10 93/5 93/6
93/8 97/11 98/2
Brocklesby's [3]
17/22 49/14 57/21
broken [1] 88/9
brought [7] 5/3 63/10
63/25 67/7 72/2 73/13
83/13
BSc [1] 2/25
budget [1] 70/13
build [17] 32/24
35/10 58/21 66/17
66/18 66/22 66/22
66/23 66/25 67/4 67/6
69/2 69/2 69/7 69/9
69/10 72/18
build/build [1] 66/22
build/buy [1] 66/17
building [3] 34/18
69/3 94/15
built [11] 32/23 33/18
33/21 35/13 44/19
66/21 67/20 68/10
68/10 94/13 94/13
bullet [11] 18/16
18/22 19/5 19/10 23/2
30/22 42/24 43/6
46/12 47/10 47/23
bundle [1] 96/18
business [13] 13/11
25/23 38/16 39/9 51/9
56/7 58/3 58/11 67/1
67/19 78/21 78/25
82/3
but [67] 1/10 5/23 7/4
13/3 15/3 15/8 15/10
16/25 21/10 22/4
22/20 23/11 24/1 25/1
25/23 27/12 29/3
29/13 31/10 32/14
33/1 33/3 33/5 33/18
35/9 37/12 37/14
38/11 39/8 39/19
41/18 41/23 43/11
43/24 44/12 49/9 51/3
52/15 53/2 56/18
56/23 60/14 62/15
62/20 63/9 69/11
72/15 73/6 75/16
75/18 76/7 81/18 84/8
85/7 86/10 87/6 90/14
90/21 91/11 91/18
92/14 93/9 93/15 94/8
95/15 96/13 96/17
button [5] 10/11
10/17 79/2 79/3 88/14
button’ [1] 10/5
buy [3] 66/17 66/21
69/11
buy/built [1] 66/21
c
calendar [1] 95/20
call [5] 1/5 1/21 5/23
12/2 93/12
called [5] 5/25 11/18
38/7 41/25 44/21
came [5] 68/20 73/7
76/18 84/8 91/16
Camelot [2] 63/11
63/24
can [69] 1/3 1/25
7/23 8/5 9/14 10/14
10/14 11/3 12/1 12/14:
12/23 13/8 14/9 14/13)
14/22 20/19 21/9
21/10 22/1 23/1 24/8
24/12 24/14 26/1
27/15 27/15 27/22
28/19 33/13 41/1 41/9
41/14 41/15 41/16
41/22 41/23 42/4 42/8
44/11 45/16 46/3
51/19 51/23 54/6 55/3
56/25 60/24 61/20
64/10 65/18 65/20
65/21 65/23 66/1 70/3
75/6 75/17 76/4 79/14
82/14 83/9 85/23
85/24 85/25 87/21
89/2 93/19 95/14
95/23
can't [9] 9/16 10/24
12/11 14/17 51/21
53/10 69/5 87/11 91/3
career [2] 3/3 3/5
careful [1] 29/2
carefully [2] 67/8
78/3
carry [1] 67/5
case [13] 19/17
27/21 29/25 33/13
38/16 44/12 52/10
52/15 52/19 52/21
58/3 58/11 82/11
cases [11] 22/9 39/9
52/7 52/13 52/14
52/25 64/21 89/12
89/13 90/24 93/2
cause [4] 10/8 11/15
19/7 25/25
causes [5] 6/3 25/13
T7NMN7 77/20 78/14
causing [1] 88/20
CB [6] 30/18 30/23
30/25 48/8 48/9 70/23
CC [1] 30/23
cease [3] 20/2 32/11
95/6
ceased [1] 18/20
cent [1] 35/7
centre [1] 89/5
CEO [6] 8/20 40/11
40/21 57/25 58/12
62/23
CEOs [1] 26/4
certain [5] 40/12 51/8I
56/1 94/14 97/7
certainly [8] 43/9
43/11 43/12 45/20
45/23 89/19 92/21
96/17
cetera [3] 15/14 33/2
33/17
chain [5] 27/2 27/18
37/3 51/12 51/24
chair [14] 17/14
51/25 54/7 54/14
54/19 55/17 60/12
62/25 63/12 67/11
67/24 68/20 69/12
69/20
Chair's [2] 69/14
TAIS
chaired [2] 8/20 55/8
chairing [2] 53/14
54/18
challenge [6] 36/3
49/24 49/25 54/22
54/25 58/25
challenged [4] 8/23
8/25 9/15 15/7
challenges [6] 27/10
31/20 34/8 34/12
36/23 59/12
challenging [3] 8/22
8/24 9/3
chance [1] 26/10
change [9] 4/12 4/17
8/8 9/11 46/17 47/8
47/16 59/6 60/15
changed [2] 57/13
81/14
changes [6] 8/18
9/24 10/1 12/24 13/16)
83/20
charge [1] 27/24
check [2] 81/13 84/6
checked [1] 85/14
chemical [1] 2/25
Chief [8] 3/8 3/17 8/1
9/4 59/25 61/24 63/13)
63/23
Chris [4] 44/19
CHRISTOPHER [3]
1/23 2/2 98/2
chronology [1] 32/15
churn [1] 92/9
Cl [2] 39/22 44/17
ClJ [1] 18/19
circle [1] 56/2
circumstances [4]
11/13 11/18 19/18
41/1
City [3] 27/16 28/3
28/5
civil [4] 20/3 22/13
80/10 82/18
claim [2] 48/2 51/1
claims [1] 48/5
clarify [1] 49/3
clarity [1] 89/21
class [1] 2/25
clause [2] 24/18 25/1
clause 20.3 [1] 24/18
clauses [2] 24/9 25/6
clear [7] 37/25 52/23
53/2 68/20 80/7 94/5
94/6
clearly [17] 9/9 14/19
21/7 22/16 29/1 33/19
34/5 42/15 60/8 60/11
64/20 68/1 68/18
69/16 83/3 93/10 96/5
clients [4] 73/10 89/4
90/5 92/13
close [2] 34/5 53/23
closing [1] 54/4
Coforge [1] 69/6
collaborate [1] 31/13
colour [1] 89/21
(28) being... - colour
INQ00001190
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c
come [25] 7/23 13/5
14/22 23/20 24/8 26/1
28/19 31/5 43/22
43/23 45/16 46/6
52/20 55/3 55/4 56/25)
57/19 60/8 61/20
67/15 69/10 71/2
88/11 90/16 91/3
comes [3] 16/15
20/23 65/15
comfortable [1] 30/1
coming [4] 2/3 9/4
53/23 91/1
commenced [1] 62/3
commencement [1]
74/23
commenting [1]
17/24
comments [1] 54/20
commissioned [2]
46/20 67/4
commit [1] 75/9
commitment [2]
26/16 74/21
committed [2] 63/5
63/7
committee [4] 8/9
66/2 66/3 67/25
common [4] 67/17
73/9 85/11 86/22
commonly [3] 79/11
79/23 86/5
communicate [1]
communicating [1]
34/23
communication [1]
13/21
companies [1] 3/8
company [5] 44/21
45/10 67/2 71/22
83/24
complete [2] 35/4
43/18
completed [5] 5/21
53/1 66/16 71/21
89/10
completely [2] 68/25
69/7
completeness [1]
complex [2] 19/4
34/10
complexity [1] 59/11
complicated [1] 96/5
component [2] 7/4
9/1
components [5] 4/24
5/2 38/11 38/11 38/25)
computer [2] 41/22
70/22
concern [10] 40/20
40/24 41/2 41/7 41/9
42/5 42/6 42/19 44/1
45/1
concerned [5] 28/25
29/4 29/9 49/10 50/23
concerning [2] 26/13
26/21
concerns [6] 21/22
21/25 26/13 39/12
40/9 42/23
conclude [2] 45/13
60/21
concluded [4] 22/11
66/17 93/22 94/3
conclusions [1]
53/24
conditions [3] 37/20
66/24 67/2
conduct [4] 26/5
26/13 26/22 89/8
conducted [1] 52/6
confidence [4] 22/21
confident [1] 71/5
confidential [1] 57/6
confidentiality [1]
55/12
confirm [2] 1/25
44/13
confirmation [1]
19/15
conflict [2] 46/24
49/6
conflicted [2] 43/23
54/17
conflicts [1] 46/23
confused [1] 68/16
connected [1] 82/13
connection [1] 86/7
cons [1] 19/23
consequence [3]
12/25 54/3 90/22
consequences [1]
16/9
consider [4] 40/3
44/1 61/6 81/8
considerable [2]
67/16 73/19
consideration [3]
19/6 44/25 85/3
considered [10] 12/9
19/22 36/5 49/5 62/8
66/18 67/8 68/22
76/16 78/3
considering [4]
19/20 49/5 54/15
81/24
consistent [1] 81/20
consistently [1] 14/5
consolidate [1] 3/14
constant [1] 61/2
constantly [1] 59/3
constitute [1] 71/25
constructed [1] 76/1
constructive [3]
49/24 49/24 54/21
contact [1] 27/23
contained [1] 56/22
contents [1] 2/16
context [5] 27/12
46/17 47/8 47/16 60/3
contexts [1] 21/22
contingency [1]
72/19
continually [1] 36/9
continue [5] 18/2
36/10 49/1 80/12
95/23
continued [4] 31/20
36/24 62/11 97/5
continuing [2] 38/9
44/9
contract [23] 24/10
30/8 31/19 32/5 37/19
58/10 61/22 62/11
62/13 62/24 63/4
70/25 72/22 74/13
74/19 75/16 76/5
76/19 77/9 78/1 83/2
85/13 85/18
contractor [2] 62/4
62/13
contractors [2] 40/16
70/14
contracts [4] 31/7
76/10 76/15 93/22
contractual [3] 78/11
78/20 81/7
contributed [2] 22/24)
23/6
contributing [1]
23/13
control [4] 5/1 5/3
6/8 35/8
convenient [1] 45/18
conversation [9]
16/9 27/16 28/4 29/24:
66/21 67/23 68/1 68/3
73/15
conversations [5]
22/1 37/22 38/24
67/18 68/8
convicted [1] 65/9
convictions [1] 65/9
Cooperate [2] 25/12
77/16
copied [2] 50/3 51/23
copy [3] 2/6 2/11
89/24
corporate [5] 59/9
60/2 74/24 91/25 92/9
correct [34] 3/2 3/11
3/15 3/20 4/3 4/4 4/10
5/7 5/14 6/14 6/17
6/22 8/2 9/22 22/12
26/9 30/14 37/12 40/1
50/17 53/21 62/2 62/5
62/16 66/8 76/22 90/6
90/9 94/4 95/24 96/4
96/16 96/24 97/18
correctly [2] 80/17
87/1
correlation [1] 14/17
correspondence [7]
26/5 26/7 28/22 37/3
84/15 84/19 84/20
CoSec [1] 15/4
cost [1] 38/14
costs [3] 38/15 38/15
38/18
could [43] 2/10 4/15
9/25 17/21 18/11
19/14 22/25 24/11
26/10 26/19 27/5
30/15 31/15 31/23
33/19 39/21 40/6 42/9)
45/21 46/7 49/13 50/3
52/23 53/3 55/15
56/14 57/20 63/8
65/12 67/5 67/6 67/7
69/23 70/1 70/17 72/1
74/2 74/3 76/13 81/19
81/23 85/8 89/21
couldn't [1] 55/2
Counsel [1] 55/18
counters [1] 41/23
couple [3] 5/24 21/11
65/11
courage [1] 90/20
course [5] 1/22 2/21
7/14 39/2 79/9
Court [4] 76/16 77/25)
83/21 85/2
cover [4] 55/23 77/18)
78/12 78/19
cover-all [2] 77/18
78/12
covered [5] 70/25
72/18 82/17 82/18
82/18
covers [2] 56/23 96/2)
CP [3] 63/16 63/17
63/17
CPs [1] 64/6
create [1] 60/25
created [2] 87/21
87/25
credible [4] 34/6
34/21 35/1 44/10
criminal [8] 26/25
28/12 80/10 80/25
82/11 82/13 82/17
82/20
crisis [2] 60/10 61/2
critically [2] 15/18
20/11
crossed [1] 75/5
crucially [1] 86/20
crux [1] 75/13
CTO [1] 4/5
cultural [1] 8/8
culture [20] 18/2
18/3 49/16 49/23 51/8)
54/21 55/4 56/3 56/6
57/3 57/13 57/17 88/1
88/2 88/3 88/6 88/12
88/17 88/22 88/23
current [15] 8/7
16/16 17/20 19/24
19/25 31/2 46/21
52/14 53/25 56/8
57/17 58/22 59/11
59/23 83/16
currently [3] 19/15
26/2 74/3
customer [1] 41/16
customers [3] 33/4
94/23 95/8
cut [3] 51/2 80/15
83/17
cutting [1] 94/25
cyber [3] 42/10 42/15
42/16
D
daily [1] 82/2
Dan [2] 7/10 27/8
Daniel [1] 27/7
dashboard [7] 12/5
12/9 15/12 67/9 79/17)
79/17 79/19
data [28] 6/6 15/24
17/18 19/7 19/13
19/14 20/11 20/17
20/25 21/1 21/9 21/19
21/25 23/22 28/10
28/18 79/18 80/20
81/2 81/4 81/17 81/19)
82/6 83/9 84/1 85/3
85/9 85/9
database [1] 6/5
Datacentre [2] 4/23
38/7
date [12] 3/5 30/11
31/7 31/10 32/3 32/11
33/21 35/3 39/7 44/10)
93/12 93/21
dated [8] 2/10 18/13
26/12 27/4 30/17
31/17 55/16 80/3
dates [1] 95/22
day [7] 4/5 4/5 22/10
28/10 51/11 97/14
97/15
days [1] 90/13
DBT [1] 36/17
deal [3] 9/24 43/24
87/23
dealing [2] 14/1
59/12
deals [3] 24/17 33/17
44/14
dealt [2] 44/1 51/5
debate [1] 69/1
decades [2] 73/11
93/2
December [2] 31/17
(29) come - December
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D 85/7 discussed [10] 7/16 I 36/16 42/23 49/4 51/2I 50/10 50/18 50/25
December...[1] detailed [4] 16/8 9/10 13/6 15/6 21/7 I 51/4 56/16 64/24 81/9) 51/12 51/12 51/13
36/25 i 37/18 79/17 81/17 23/3 32/12 45/1 45/4 I 88/6 92/23 51/24 53/19
decision [12] 20/1
20/6 23/18 40/13
40/22 44/2 52/2 52/8
57/23 67/1 68/23 72/4
decisions [4] 36/2
49/19 53/1 58/2
declining [1] 56/6
dedicated [1] 28/1
deduction [2] 20/4
22/14
deep [1] 92/14
defect [6] 4/19 12/16
12/25 13/1 13/4 13/19}
defects [18] 6/3
12/22 12/23 13/25
14/18 14/21 14/25
15/11 15/13 15/19
15/23 15/24 21/18
22/6 33/22 81/14 82/4
82/5
defer [1] 49/19
defined [1] 20/5
definitely [1] 64/22
definition [1] 16/23
delays [3] 30/9 48/1
72/20
delegated [3] 7/1
58/1 58/12
deliver [4] 34/6 34/11
35/21 97/7
delivered [3] 33/15
33/21 76/2
delivering [4] 16/7
34/8 42/2 66/9
delivery [10] 3/23
5/13 8/3 16/15 17/5
31/20 33/8 34/14
36/24 38/18
demonstrated [2]
41/15 41/17
departed [1] 63/21
Department [1] 62/9
departure [3] 32/18
53/16 68/24
deploy [5] 33/24 34/2
34/20 41/19 72/18
deployed [5] 33/15
35/14 72/24 75/18
94/20
deployment [3]
30/11 36/6 63/9
describe [1] 6/9
description [1] 40/20
design [3] 14/20
40/14 41/11
designed [1] 83/3
despite [1] 62/7
detail [7] 10/25 25/5
29/7 32/14 41/4 78/7
details [4] 27/23 28/3
59/3 70/16
detrimental [1] 16/20
developed [2] 32/20
42/7
developing [1] 41/13
development [6]
14/16 16/14 30/9
32/17 36/6 69/8
did [25] 7/13 7/14
7/20 13/13 16/3 19/19
21/22 22/12 22/16
29/3 34/8 34/13 35/9
35/17 45/6 46/25
48/17 51/10 51/11
62/12 64/13 83/24
90/21 92/8 95/16
didn't [12] 21/25
23/15 30/2 43/9 43/12
45/8 49/3 81/16 81/20
82/7 84/6 90/21
difference [2] 9/13
63/8
different [7] 6/19
11/20 48/3 56/23
61/13 76/6 82/8
difficult [18] 16/8
17/4 17/11 22/4 34/11
36/4 36/18 47/19
47/24 57/4 57/8 60/9
61/9 90/16 90/18
90/23 90/24 91/19
difficulties [1] 87/9
digital [4] 17/18
direct [2] 27/3 71/16
direction [1] 59/10
directly [4] 10/2
10/24 13/23 16/17
Director [3] 1/15 6/11
13/14
directs [1] 13/19
disappointed [1]
63/5
disbelief [1] 50/21
discontinued [1]
97/5
discounted [1] 44/24
discovered [2] 11/16
81/22
discrepancies [19]
8/11 10/5 10/8 11/1
11/9 18/4 18/15 19/1
21/13 22/20 24/3
42/20 86/10 86/13
86/21 87/9 87/21
87/21 88/13
discrepancy [5]
11/15 19/7 20/22
20/22 86/17
discuss [2] 58/18
59/5
47/24
discussing [1] 81/7
discussion [7] 12/18
16/18 17/9 18/14
20/21 23/21 85/18
discussions [7] 16/4
21/13 22/18 39/6
47/20 92/17 96/4
disenfranchised [1]
55/21
dispute [4] 10/11
10/23 79/2 79/3
do [53] 2/7 2/9 2/11
2/13 14/1 17/14 20/11
20/15 20/18 21/10
21/16 24/3 25/2 28/1
29/22 33/7 34/16 35/3
35/9 40/4 43/3 43/4
44/1 45/13 45/15 52/1
54/10 54/12 54/12
57/1 60/5 61/6 62/17
64/24 65/19 65/22
70/3 72/11 74/6 74/7
75/15 75/23 83/13
87/23 88/17 88/20
90/2 90/3 91/9 91/20
92/4 92/19 97/15
document [20] 18/10
24/8 26/1 28/19 39/23
43/13 44/14 45/16
54/1 55/3 56/25 61/20
65/11 65/15 74/2 74/4
76/7 85/15 85/19
85/21
documented [1] 19/3
documents [2] 1/20
85/4
does [14] 10/11
12/18 15/17 16/12
24/23 30/12 51/15
55/13 57/25 60/3
92/14 96/25 97/3 97/6
doesn't [2] 58/19
68/18
doing [1] 8/24
domain [1] 17/6
don't [46] 7/19 11/19
11/22 13/7 15/9 15/20
15/25 21/8 22/7 22/18
23/20 30/1 41/8 42/22
43/19 44/4 44/12 47/2
51/22 52/3 53/9 55/1
60/13 62/18 64/15
64/20 70/16 72/14
73/21 75/11 78/18
79/21 80/1 80/22 81/4
83/8 85/7 87/17 88/22
88/23 89/16 89/19
90/1 91/3 91/10 92/13
done [14] 21/15
21/17 22/5 33/22
doubt [2] 18/7 88/12
down [27] 7/23 14/22:
18/17 18/22 19/11
24/8 26/1 27/19 27/20
28/19 31/25 34/12
45/16 47/22 50/5 55/3
56/25 61/20 70/2
70/18 80/5 80/12
80/15 80/22 83/17
85/24 86/13
drafting [1] 76/10
drawn [3] 53/24 59/3
84/18
drift [2] 73/12 73/19
driving [1] 8/8
due [6] 2/21 32/11
40/15 43/17 58/11
61/1
Dunelm [1] 3/9
during [8] 10/9 12/14
19/2 38/8 38/25 44/18)
60/10 75/7
duties [2] 24/13
24/117
duty [4] 24/19
E
each [3] 9/1 52/15
52/20
earlier [4] 75/17
75/20 78/5 82/9
early [6] 31/6 35/9
35/17 44/10 60/23
95/20
earth [3] 81/9 83/7
87/14
easy [2] 35/23 51/2
easyJet [1] 3/9
edge [1] 22/9
effect [2] 24/20 95/25)
effected [1] 24/21
effective [2] 57/2
61/8
effectively [2] 60/25
64/18
effectiveness [1]
57/20
either [6] 10/16 12/20]
12/23 27/23 35/18
81/15
elaborate [1] 33/13
election [1] 96/5
elements [2] 40/14
74124
Elliot [2] 50/7 50/9
else [5] 13/10 42/15
68/10 68/11 76/3
elsewhere [2] 49/12
55/11
email [14] 27/2 29/24
50/2 50/5 50/6 50/8
emailed [1] 27/7
embarked [1] 3/3
Emma [1] 2/4
emotional [2] 56/13
92/16
employed [1] 89/7
employee [1] 61/24
employees [5] 46/21
50/15 53/7 55/21
56/11
employment [1]
61/25
enable [1] 30/7
Enclosed [4] 27/2
encounter [1] 34/8
encouraged [1] 55/6
end [15] 17/2 31/9
32/5 32/22 33/5 35/16
38/3 45/17 53/23
72/19 72/25 75/20
76/2 95/2 95/5
enforcement [5] 29/8)
80/9 80/21 81/1 81/20
engage [5] 16/8 17/4
17/11 91/8 92/20
engaged [5] 42/25
45/9 67/6 90/4 92/6
engagement [6] 14/2
32/1 43/14 56/15
61/16 70/10
engages [2] 32/8
61/14
engaging [1] 92/12
engineering [1] 2/25
enhancements [1]
419
enlightening [1]
91/18
enough [1] 16/25
enquiries [1] 6/6
ensure [2] 26/18 85/2!
ensuring [1] 9/19
entirely [1] 84/7
entitled [1] 70/6
entry [1] 74/6
environment [4] 8/22)
46/18 47/9 47/17
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27/23 84/2
error [1] 3/7
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44/23
essence [1] 29/11
essentially [6] 74/18
75/4 81/2 83/23 88/8
89/5
established [6] 18/21
18/24 18/25 20/3
22/13 28/9
establishing [1]
(80) December... - establishing
INQ00001190
INQ00001190
E 86/19 87/20 faster [2] 52/24 53/3 I 83/16 85/15 86/4 86/6I 80/16 80/17 81/3 81/5I
establishing... [1] experiences [2] 14/8 I fault [1] 88/19 formal [1] 32/1 81/10 81/15 81/25
28/14 92/22 favoured [1] 56/1 Iformally [1] 36/20 I 83/8 83/11 83/25 84/3
estimated [1] 72/3 I@xPeriencing [2] feasibility [2] 31/20 Iformer [1] 63/23 84/6 84/9 84/16 84/19
et [3] 15/14 33/2 86/4 87/8 36/23 forth [4] 70/15 85/2 85/5 85/10 85/14
33/17 expert [5] 11/8 17/6 Ifeatures [1] 58/17 I forthcoming [1] 85/16 93/23 95/5 95/7
etcetera [3] 15/14 I 20/24 29/11 69/8 I February [8] 17/24 I 38/23 fulfilling [1] 67/2
33/2 33/17 expertise [1] 66/19 I 50/3 50/6 50/9 51/13 I fortification [2] 4/23 Ifull [8] 1/25 6/11
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even [5] 34/5 49/6 /EXPG0000007 [1] [feed [1] 14/7 fortnightly [2] 7/2 I 58/10 61/23
53/11 72/8 88/11 85/22 feedback [1] 94/18 I 8/20 fully [6] 33/15 41/18
event [2] 77/21 78/15IexPires [1] 31/3 feel [3] 23/15 30/2 Iforward [10] 19/21 I 63/5 72/24 75/1 94/22!
events [1] 93/3 explain [8] 4/11 92/14 22/12 23/12 23/16 —_I function [6] 10/21
every [5] 25/18 25/24) 20/19 25/8 54/6 55/8 feeling [1] 56/12 23/18 31/9 38/16 11/8 13/12 26/6 84/11
28/10 82/2 95/7 59/20 72/10 77/12 —_Ifell [1] 5/19 83/21 88/11 95/22 I 84/12
everybody [1] 84/10 explained [1] 97/2 I fellow [1] 15/15 forwarded [1] 50/6 I functional [1] 42/1
everything [2] 53/1 [explains [1] 31/19 [felt [2] 54/14 93/2 Iforwarding [1] 51/13 [functioning [1] 53/18
79/9 explanation [1] 19/9 Ifew [4] 36/15 36/21 Ifound [2] 90/24 91/18]functions [2] 6/19
evidence [13] 1/6 I@xPloited [1] 42/10 I 48/16 65/23 foundation [1] 20/20 I 6/24
4/10 1/11 2/20 26/24 [exPressed [3] 50/11 Ifew' [2] 47/25 48/11 Ifour [2] 83/6 83/15 fund [1] 96/17
29/11 30/5 44/3 64/17I 30/20 52/1 fifth [1] 30/22 frankly [3] 51/8 75/5 I funded [5] 31/10
89/22 91/21 97/10 Iextend [8] 31/7 31/18} figure [1] 58/5 91/2 36/15 36/20 39/8
O72 37/14 72/14 72/16 Ifinal [2] 20/6 95/6 I Fraser [1] 76/8 96/19
evidentially [1] 28/9 72/22 73/4 75/12 finance [4] 95/10 Fraser's [1] 83/2 funding [9] 36/12
evidentially-establish @xtended [2] 32/5 I 95/16 95/25 96/1 fraud [1] 80/11 36/16 39/3 66/15
ed [1] 28/9 62/24 finances [1] 96/20 I freezes [1] 86/6 95/13 95/21 96/4 96/8
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ex-police [1] 89/7 I&xtension [15] 32/4 I 58/1 fresh [1] 62/25 funds [1] 96/14
exactly [2] 58/19 37/13 37/17 37/21 _Ifind [5] 35/18 69/1 I Friday [2] 97/17 furore [1] 64/16
81/19 65/14 70/25 71/21 I 69/23 71/9 90/23 97/23 further [17] 23/20
examine [1] 46/23 I 72/8.72/12 72/23 ___ finding [2] 36/7 52/17\front [1] 2/6 31/22 38/12 48/12
example [5] 9/14 74/12 74/19 75/1 75/4I findings [2] 8/13 57/7/frustrating [1] 22/1 I 48/17 51/12 52/9 71/8
18/4 54/24 79/11 85/7I 75/14 fine [3] 45/23 64/6 frustration [2] 50/10 I 72/20 80/22 80/23
except [1] 18/23 extensions [1] 93/23 I 85/21 50/21 86/13 87/19 88/3 89/3,
exchange [2] 64/14. I@xtent [4] 6/23 15/6 Ifingers [1] 75/5 FSL [1] 80/7 93/7 98/14
84/18 31/4 44/22 firing [1] 49/11 FUJ00243158 [1] _Ifuture [5] 20/2 39/9
exchanged [1] 26/5 I@xternal [5] 20/6 20/8)first [20] 1/14 2/25 I I 27/5 51/8 58/21 96/3
exec [2] 12/12 58/25 I 45/9 66/16 72/3 745 11/11 11/23 14/1IFUso0243199 [1] [GS
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3/22 7/25 9/4 1218 [extremely [1] 75/21 I 46/12.47/951/19 — IFUJo0243204[1] _Igain [1] 91/14
12/13 14/24 21/12 jeve [1] 79/14 55/19 58/8 66/6 74/8 I 26/11 gained [1] 20/13
zarsaiissan7 = IpI 24/18. 82/8 82/23 IFUJ00243299[1] I game [1] 37/23
56/15 60/1360/18 I---I 93/19 31/16 gave [3] 8/14 64/17
60/19 61/16 5/25 (face [3] 10/2 54/5 firstly [1] 67/5 Fus00243301 [1] I 72/19
92/20 54/6 fit [4] 41/19 31/24 GE [2] 40/11 40/21
exhibited [2] 26/14 facilitate [1] 84/16 I five [11] 16/17 32/20 IFujitsu [84] 4/9 6/19 Igeneral [4] 21/1
26/22 fact [11] 22/9 33/3 I 59/24 71/12 72/8 7/8 7/10 11/3 11/5 I 21/23 23/22 96/5
exist [2] 24/23 76/6 33/24 44/8 47/11 51/3] 72/17 72/25 75/4 11/21 12/17 12/20 I generated [1] 96/14
exit [13] 30/8 32/3 69/16 72/21 81/16 I 75/17 75/18 90/11 12/24 13/4 19/16 26/4I gentleman [1] 63/23
32/3 32/4 32/11 32/12I 20/25 93/1 five-year [1] 72/25 I 26/24 27/4 27/7 27/17Iget [13] 11/14 29/13
32/13 37/10 37/10 {failed [1] 84/20 fixes [1] 4/19 27/24 28/5 28/15 29/16 31/14 36/16
37/24 37/25 74/12 __ {failings [1] 8/7 flawed [5] 40/13 28/17 29/4 29/10 51/4 52/13 68/18 76/1
71/24 failure [1] 38/6 40/23 44/2 56/8 66/19I 29/17 30/8 30/23 31/2I 88/2 90/11 93/10
expanded [1] 85/23 fair [6] 23/12 23/15 I flexible [1] 31/9 31/8 31/10 31/12 94/17
expect [2] 54/3 62/12 57/15 72/9 91/16 focused [3] 32/3 31/16 31/19 31/23 I getting [3] 17/9 36/2
expectation [3] 91/18 61/13 66/5 32/9 32/10 32/13 88/13
35/22 58/23 96/7 faith [1] 28/17 Focusing [1] 10/1 33/16 36/25 37/11 Igive [7] 1/10 10/25
experience [8] 15/17 false [1] 80/11 following [3] 18/18 I 37/12 37/14 37/24 I 21/5 21/9 26/24 29/11
Tt a7is 2310 Ifamiliar [2] 16/14 I 20/4 50/19 38/14 38/21 39/1 48/14
23/14 58/24 60/4 172 footnote [1] 48/6 I 65/14 70/25 71/3 _I given [18] 17/13 18/6
94/18 families [2] 92/25 I force [1] 29/15 71/13 71/24 72/9 18/16 21/20 21/21
experienced [5] 93/4 forgive [4] 3/7 32/14 I 72/12 72/20 72/22 I 23/22 33/24 39/7 52/5}
25/19 86/9 86/17 far [5] 9/20 14/13 50/8 82/15 73/3 73/6 74/13 74/20I 52/22 53/3 56/19 58/5
93/22 94/2 95/9 form [6] 22/23 23/5 I 74/21 75/11 80/7 62/21 79/12 81/3 81/4
(31) establishing... - given
INQ00001190
INQ00001190
G H 7712 97/16 hopefully [1] 75/6 I apologise [1] 71/9
; he [12] 6/1851/14_IHorizon [84] 3/24 4/1II appreciate [1] 94/8
glad [i] yee 21 fad 79) oe eee 60/12 62/24 64/18 I 4/6 4/13. 4/18 4/20 I arrived [3] 5/22
gro {ty 18/19 9/6 9/11 18/12 16/1 I 04/18 64/20 67/4 I 4/25 5/9 5/19 6/9 6/15I 33/19 34/4
go [241-9125 10125 I 18/20 18/23 21/14. I 88/20 71/17 83/14 I 7/4 8/13 8/14 8/18 9/6] ask [2] 2/4 27/15
92/7 9/17 9/21 10/2 10/14 Il asked [1] 62/18
aes bed ona aan are a he's [2] 64/4 71/16 I 13/19 13/24 14/8 I be [4] 95/24
85/12 71/6 71/8 71/10] 26/10 28/24 32/20 [Head [1] 27/25 14/24 15/3 15/19 19/6II believe [5] 11/6
74/3 75/11 75/21 81/6I 33/7 33/20 3/21 Reading [1] 46/11 I 19/13 20/11 20/14 I 11/8 14/9 47/2 53/25
85/24 93/8 94/7 94/8 I 33/29 34/24 35/2 Iheads [1] 40/9 20/17 20/23 20/25 I believed [1] 81/21
94/9 94/11 35/24 3719 37/12__—«((hear [2] 1/3 46/3 21/1 21/18 21/20 IIean [4] 44/11
goal [1] 33/6 37/15 38/6 38/7 38/13I heard [6] 22/20 24/6 I 21/21 22/21 23/22 _II can't [6] 9/16 10/24
34/16 55/2 66/3 96/21I 24/22 26/17 29/3 30/8I 12/11 14/17 53/10
hearing [2] 97/16 31/19 31/21 32/18 69/5
97/22 33/6 34/9 36/24 38/19/I certainly [4] 43/9
Hearings [1] 50/16 I 49/18 67/7 67/17 43/11 43/12 92/21
held [5] 2/23 11/4 67/19 68/11 68/17 I continued [1] 62/11
goes [6] 12/7 48/14 I 38/21 38/24 39/7 43/4
66/13 92/1 92/4 94/19] 43/7 43/19 44/2 44/3
going [40] 14/6 19/8 I 45/1 46/19 47/11
19/21 24/18 30/19 47/14 48/13 48/21
31/9 32/14 35/22 52/6 52/25 53/4 54/10
35/23 37/20 44/14 I 86/8 59/9 63/1 6g/12 I 11/5 11/6 56/9 68/19 68/21 71/23 II could [3] 33/19 63/8
4611 52/16 5620 I es/9eerte sea Ihelp [17] 10/6 10/13 I 72/1 72/7 73/2 7315 I 81/23
10/18 10/17 11/3 13/8] 73/9 73/11 73/13 I couldn't [1] 55/2
59/5 62/19 62/24 69/20 70/11 70/12
65/13 65/16 67/18 70/24 71/1 71/2 73/10
68/8 70/7 70/14 72/7 I 76/23 81/14 81/14
76/12 78/7 78/17 82/7 84/19 86/18
78/19 80/15 83/4 90/23 92/25 93/11
27/15 29/15 41/9 42/4I 73/21 74/13 74/22 I did [3] 7/14 13/13
51/19 51/21 51/23 75/1 75/9 75/14 76/16] 22/16
69/5 76/8 85/10 89/3 I 80/20 81/2 81/24 82/1II didn't [6] 21/25 45/8
Helpdesk [2] 12/1 83/9 85/1 86/4 86/14 I 49/3 81/16 82/7 90/21
13/15 94/21 95/7 95/18 II do [10] 2/9 2/13
ae renee bean (7h tt ns helped [1] 54/11 IHorizon's [1] 38/3 I 20/18 43/3 45/15
90/22 92/13 92/18 I 21/12 56/18 62/21 helpline [3] 11/23 Ihost [1] 87/22 65/19 65/22 74/7 90/3
96/1 81/15 92/23 93/1 13/8 88/15 hot [1] 17/7 91/9
gone [2] 60/8 83/1 halt [3] 34/1 34/2 _/Relplines [3] 11/20 Inouse [8] 44/19 I don't [37] 7/19
good [8] 1/3 16/25 86/9 12/4 79/12 66/19 67/7 68/10 11/19 11/22 13/7 15/9}
70/3 49/24 65/7 67/1 Ihalfway [1] 47/22 [Renee [2] 6/3 32/23 I 68/12.69/11 73/14 I 15/20 15/25 21/8
here [14] 6/20 29/6 I 75/6 22/18 23/20 30/1 41/8
90/2 90/3 Hamilton [1] 64/25
got [8] 43/4 69/8 handled [3] 18/5 24/4)
78/18 84/24 87/13 61/22
88/7 93/16 93/17 Hang [1] 84/10
governance [9] 7/7 Ihappen [4] 26/20
12/17 35/1 35/19 36/22 94/9 95/11
35/25 36/1 44/6 57/19Ihappened [6] 43/1
67/1 63/12 76/8 76/9 88/19
governed [1] 61/12 I 92/17
government [1] 96/6 Ihappening [5] 47/2
42/16 43/23 47/5 50/5I how [30] 10/11 10/23I 42/22 43/19 44/4
51/14 59/6 66/1 66/4 I 11/17 12/9 14/1 15/17I 44/12 47/2 51/22 52/3
68/16 73/12 78/13 16/11 16/12 17/9 53/9 55/1 60/13 62/18
81/17 17/10 22/7 28/7 34/19I 64/15 64/20 70/16
hereby [1] 74/15 47/21 52/23 53/2 53/7I 73/21 79/21 80/22
hesitated [1] 39/2 58/20 62/12 68/25 85/7 87/17 88/22
high [9] 59/19 59/21 I 78/11 78/19 78/23 89/16 89/19 90/1
60/5 60/16 61/1 76/16] 79/18 81/9 83/7 86/21I 91/10 92/13
77/24 83/21 85/2 87/17 91/16 92/23 l expect [1] 54/3
. higher [1] 17/2 however [4] 44/8 lexplain [1] 72/10
sents) 9 ae nappy 2] ait 78 highlight [4] 74/5 I 48/251/15 66/25 _Il expressed [4] 50/20]
25/2 4310 43/14 45/5 hard fa) 2/6 36/21. Ihighlighted [3] 20/12IHR [2] 43/16 52/11 [I find [1] 69/1
grasp [1] 51/4 3 47/12 76/13 Hub [8] 13/21 14/1 II first [4] 7/15
grateful [7] 27/22 has [44] 3153/7 _Ihighly [1] 85/20 14/3 14/5 14/7 1419 IIfound [1] 91/18
Ter TUN Té/14 BOIAI Tart alia 14s (HWW (3] 5208/16 I 14/11 14/15 Ihad [4] 7/1 22/21
85/22 97/11 17118 25/24 29/12 I 21/15 Human [1] 50/16 I 43/7 43/19
great [2] 33/4 66/13 I 30/5 31/8 35/12 42/8 Ihim [1] 63/7 hundreds [1] 81/25 II hadn't [2] 56/18
ground tt] 37/16 I 45/9 49/16 49/18 5176 hindsight [1] 29/16 Ihunt [3] 53/5 54/24 I 93/1
his [4] 50/18 50/25 I 55/1 Ihave [7] 13/13
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7/25 8/4 816 8/20 —_I 59/9 59/13 59/21 60/5) 6/20 I hunt’ [1] 51/6 I 45/17 63/15 65/11
14/24 23/24 24/1 24/6) 60/12 60/14 61/1 61/2) Historic [2] 49/17 (hesitated [1] 39/2
Re ee er TT eee oon ota Ihistorical [1] 50/13 Ii absolutely [1] 63/6 Ii hope [1] 92/20
guarantee [3] 22/2 I 83/7 84/9 84/18 8/6 Ihistory [4] 17/13 Il accept [2] 84/71 just [4] 43/24 64/10
22/4 72/23 88/9 88/17 92/6 92/7 I 21/20 29/12 81/3 I 84/15 82/16 95/14
guaranteed [1] 21/9 I 92/16 hit [1] 79/2 Vact [1] 65/8 I know [2] 41/4 44/4
guidance [3] 84/25 Ihasn't [2] 13/3 83/14 IHM [1] 36/17 Valready [1] 44/8 lI may [2] 90/11 93/16
85/4 85/16 have [113] HM Treasury [1] lam [9] 14/14 22/16 II mean [8] 14/17
guilty [1] 18/3 having [10] 13/20 I 30/17 26/16 45/17 50/22 I 22/46 29/1 38/24
Tarte asit7 saz hoc [1] 39/22 67/25 77/7 96/12 I 56/23 84/7 87/17
38/4 47/7 56/20 62/7 Ihold [1] 18/23 g7itt 87/21
hope [1] 92/20 answered [1] 82/22 I might [1] 1/7
(32) given... - Tmight
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90/21
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43/3
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I say [3] 69/4 90/19
97/15
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16/18 17/16 21/10
26/6 29/13 34/16
35/24 35/25 43/6
45/21 47/11 49/4
53/10 53/23 54/13
54/14 57/15 60/19
61/10 61/18 66/1
66/20 68/16 68/17
68/24 70/3 70/18
70/24 74/8 75/3 76/1
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65/23 70/17 93/10
93/15 94/6
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43/9 43/10 43/11 49/4
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63/5 63/6 67/23 81/12
81/12 82/23
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15/10 15/14 43/16
69/1 69/22
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9/23 17/20 18/9 22/20
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55/4 57/19 65/12
69/25 70/2 76/13 94/8
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I'm [26] 12/11 12/21
15/21 23/24 24/1
24/25 25/5 30/1 34/10
39/17 40/3 43/20
51/22 53/6 64/15 71/9
76/6 76/12 76/17 78/9
79/16 80/4 80/15
85/21 87/5 93/8
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22/3 24/6 36/3 39/17
55/1 69/4 81/7 82/14
84/24 87/13
IC [2] 66/5 67/9
idea [2] 90/2 90/3
identification [2]
24/24 25/3
identified [2] 25/17
38/21
identify [7] 5/4 10/7
19/1 25/12 77/16
77/20 78/14
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ie I think [1] 48/20
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42/9
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16/13 17/4 24/14
27/22 27/25 28/24
29/4 31/13 34/1 34/2
40/2 45/21 51/2 51/21
65/12 65/20 67/21
69/23 70/1 70/17 71/8
71/10 71/20 72/19
72/24 74/5 74/25 75/7
75/16 75/17 75/19
76/13 76/21 76/21
77/2 78/18 80/5 80/16
81/10 85/24 86/14
87/1 91/25 93/16 94/7
94/9 94/11 94/19
95/14 95/15 95/24
96/12
ignoring [1] 44/7
ii [2] 74/20 80/13
imagine [1] 44/11
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15/17 15/21 16/2 16/3)
22/7 22/8 40/18 42/6
50/16 58/17 59/9 82/6
93/2 96/25 97/1 97/3
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impacted [2] 92/25
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implement [2] 76/21
83/20
implementation [2]
4/20 9/19
implemented [1]
76/24
implementing [2]
8/18 20/14
implication [1] 49/7
importance [1] 54/16
important [4] 28/7
42/2 42/11 59/16
importantly [1] 92/24
impossible [1] 28/7
impression [2] 9/5
9/9
improve [6] 21/18
21/19 22/5 38/9 40/17
41/12
improved [1] 61/19
improvement [3]
5/25 6/1 8/3
improvements [3]
4/21 5/18 61/10
incident [1] 14/9
incidents [1] 15/14
include [5] 4/19
12/19 20/10 71/20
72/23
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3/13 12/5 14/20 20/7
21/11 33/16 38/16
38/25 39/1 39/7 67/11
67/23 68/2 91/12
includes [2] 10/5
33/1
including [7] 3/9 3/22I
23/4 48/4 59/12 66/15
96/18
inclusion [2] 15/5
74/21
incorrect [1] 44/7
incorrectly [2] 6/4
44/23
increase [1] 15/23
incremental [3]
36/13 39/3 95/12
incrementality [1]
9/6
incrementally [1]
94/13
indeed [4] 25/14
41/23 52/10 73/6
independent [1] 45/9
independently [1]
42/25
indicated [1] 40/8
indicators [1] 56/5
individual [4] 9/1
9/10 78/9 89/13
individuals [8] 49/8
49/10 52/11 60/23
60/24 89/17 92/10
92/11
induction [1] 8/10
industries [1] 48/4
inevitability [1] 48/1
influenced [1] 49/17
inform [1] 14/15
information [11] 3/8
14/11 15/2 15/12
20/23 40/8 40/11
40/21 44/3 89/4 91/14
infosec [2] 40/14
40/16
infrastructure [7]
4/22 31/3 31/4 38/4
38/10 38/20 39/1
inherent [1] 42/15
inhouse [1] 72/2
al [1] 81/13
ally [1] 30/6
als [1] 30/25
initiate [1] 42/10
initiating [1] 75/10
inner [1] 56/2
Inquiry [19] 2/3 2/5
2/7 17/14 26/7 28/21
30/5 39/15 46/22
49/18 50/16 55/18
55/18 59/12 64/17
66/2 81/22 89/15
89/22
Inquiry's [1] 2/21
ins [1] 14/5
insight [3] 8/14 20/13}
22/19
insource [2] 74/24
75/10
insource/reprocure
[1] 74/24
insourced [1] 68/21
insourcing [1] 68/17
instead [2] 32/3 62/4
instigate [1] 72/25
insurance [1] 48/5
integrated [1] 34/23
integrity [1] 21/9
intended [1] 4/1
intensity [1] 61/4
intent [2] 29/14 61/23}
interacted [1] 17/16
interacting [1] 34/22
interaction [1] 7/5
interest [1] 49/6
interested [1] 91/11
interface [1] 5/5
interim [6] 60/11
62/25 63/12 64/3 64/4
68/20
internal [2] 66/25
89/10
internally [1] 66/23
interpret [1] 57/11
interpretation [1]
25/1
interpreted [1] 28/15
interrupt [1] 49/3
intervening [1] 75/7
interview [1] 89/20
interviewed [2] 43/10)
52/19
interviews [1] 52/17
into [23] 1/12 4/25
6/2 8/14 14/7 15/3
34/20 50/3 52/6 55/9
59/3 67/15 76/18 78/9
79/6 79/8 81/8 83/5
83/24 87/18 89/7
94/20 96/3
intolerable [1] 55/22
introduced [1] 14/6
investigate [3] 43/1
44/17 78/7
investigated [2]
17/13 52/15
investigating [1]
45/5
investigation [21]
19/4 20/21 27/11
27/14 28/1 39/16 43/4
43/8 43/9 43/11 43/20
45/10 45/14 48/22
52/12 55/9 64/23 78/5
78/9 84/17 85/17
investigations [22]
10/10 11/12 22/18
26/6 27/25 29/15
43/18 47/15 50/13
51/18 51/20 52/6 54/3,
54/13 55/10 55/12
57/5 57/12 57/16
85/10 89/6 89/8
investigative [1] 52/9I
investigator [2] 45/9
52/16
investigators [1]
52/23
investment [8] 38/12
38/13 38/19 38/22
39/4 66/2 66/3 67/24
involve [1] 11/10
involved [12] 6/23
11/14 14/12 17/4
21/13 29/13 47/4
47/15 47/20 48/21
69/13 81/10
involvement [1]
91/25
involves [1] 27/11
involving [1] 20/7
IPA [2] 71/1 71/4
irony [1] 74/14
irrespective [1]
40/17
is [274]
Ismail [4] 70/19
(83) Ineed - Ismail
INQ00001190
INQ00001190
I
isn't [7] 30/20 41/25
50/12 61/16 62/3
73/15 83/12
issue [11] 13/2 25/21
35/25 47/12 60/18
60/20 65/13 69/10
84/3 86/4 89/25
issues [35] 4/20 5/19
7/18 8/8 8/13 8/14
8/15 9/8 9/17 12/1
12/3 12/19 17/10
17/13 20/14 21/20
35/2 35/19 35/23 36/7
43/14 44/7 49/17 57/2
58/16 59/21 66/15
67/17 67/17 73/9 73/9
79/11 79/23 83/19
87/16
it [234]
it's [62] 4/15 8/5 9/25
10/12 12/12 12/13
16/7 16/16 17/8 18/10
22/3 23/10 24/11
24/12 27/5 31/24
34/10 34/11 35/23
41/24 42/11 47/19
50/12 53/23 57/4 57/8
58/19 58/21 60/9 60/9
62/3 65/13 65/16 66/8
66/10 68/1 69/8 70/2
73/6 73/17 75/16 77/6
79/15 79/21 79/24
80/18 80/25 80/25
81/1 81/2 82/2 83/8
83/15 87/10 87/10
87/17 87/22 88/19
89/14 89/15 90/3
94/13
item [2] 12/16 30/19
items [2] 5/24 65/23
its [12] 2/3 30/8
45/13 53/18 54/16
66/4 69/7 75/14 83/16
94/23 95/8 96/14
itself [2] 21/25 96/17
J
Jacobs [3] 50/7 50/9
50/18
Jacobs’ [2] 52/1
53/19
January [4] 53/16
64/13 65/1 95/21
job [1] 76/21
jobs [1] 76/21
John [3] 27/3 27/9
39/22
join [2] 61/23 70/3
joined [4] 3/16 7/15
7/24 59/22
journey [1] 36/19
judging [1] 85/16
judgment [13] 4/20
5/19 8/13 9/8 9/17
9/20 20/15 67/17
67/17 73/9 73/9 77/10
85/1
judgments [13]
67/16 73/8 76/9 76/17
76/18 76/19 76/20
76/22 76/23 77/2
77/25 83/2 83/21
July [7] 18/10 18/13
26/3 26/12 31/22
62/23 90/8
June [9] 30/11 65/17
65/25 67/13 67/20
68/13 74/10 94/12
94/19
June 2026 [1] 94/12
just [36] 1/6 5/15 9/6
15/11 22/3 23/2 24/15)
25/1 25/6 31/15 32/24
36/7 40/19 41/22
43/24 45/11 48/23
49/3 51/21 51/24
63/21 64/10 65/15
69/3 72/6 74/9 80/24
82/16 82/17 85/24
87/1 89/2 92/10 92/23
95/14 96/9
justice [5] 26/19
28/12 83/2 90/5 90/17
K
keep [2] 24/21 79/14
keeping [1] 31/15
key [4] 7/20 19/6
19/17 56/5
kick [1] 31/6
kind [8] 21/5 22/8
37/23 42/10 54/1 69/1
77/18 93/23
KMcE [1] 48/12
knew [1] 37/20
know [39] 2/4 11/19
29/14 31/11 31/13
36/14 36/20 37/15
39/5 41/4 41/8 41/24
43/4 44/4 45/13 51/22
54/6 56/14 58/22
60/23 62/18 64/15
64/20 64/20 79/21
80/1 80/18 82/1 82/5
85/7 87/17 89/16
89/19 90/1 91/10
91/20 92/13 94/2 95/9
knowledge [7] 2/17
59/10 60/2 84/22 85/1
89/23 92/16
known [4] 4/2 4/23
21/18 63/11
knows [1] 36/21
KS [1] 48/8
L
lack [2] 58/11 60/2
lacking [1] 61/1
large [7] 3/13 22/10
27/11 41/20 58/5
59/14 87/7
largely [2] 11/3 92/1
last [10] 56/19 61/7
67/10 70/8 72/13
72/21 80/15 86/5 95/9
96/21
late [1] 68/12
later [6] 37/11 43/13
69/17 70/4 84/3 84/8
law [1] 29/8
lead [3] 21/24 55/18
96/15
leaders [4] 8/23 9/15
56/7 59/15
leadership [6] 9/2
34/24 35/1 55/23 56/8
56/17
learn [2] 26/16 91/11
learning [1] 14/15
learnt [3] 54/2 57/8
91/24
least [5] 54/23 63/17
69/21 76/8 76/10
leave [3] 83/24 91/22
92/2
leaving [3] 59/25
92/8 92/19
led [3] 7/9 9/2 41/3
left [11] 5/24 23/17
30/13 34/24 43/5 45/2
61/7 66/1 69/4 93/12
93/21
legacy [1] 3/14
Legal [1] 28/2
less [1] 59/13
lessons [4] 26/17
54/2 57/8 91/24
let [5] 29/16 63/21
64/6 82/8 94/11
let's [6] 64/25 74/9
76/3 77/8 85/12 86/2
letter [20] 26/11 27/2
31/16 31/22 32/7
36/25 37/11 55/16
55/19 56/13 56/18
56/20 80/2 81/12
81/21 82/10 82/17
82/19 83/6 84/3
level [16] 15/1 16/20
17/1 25/5 29/5 29/7
36/3 37/18 49/24 60/6
60/17 60/18 60/19
78/6 85/7 85/9
levels [2] 12/10
55/24
lied [1] 56/1
lies [1] 57/24
life [1] 35/13
light [3] 46/17 51/7
64/24
like [32] 1/12 2/22
9/23 17/20 18/9 24/9
30/4 31/8 31/10 33/23
37/17 41/17 41/21
46/6 50/1 55/4 57/19
63/7 68/9 69/22 69/25
76/22 77/3 83/10
89/10 90/12 90/14
91/25 92/12 92/18
94/8 95/21
likely [2] 25/13 77/17
limb [1] 44/15
limited [38] 1/15 4/25)
9/19 18/8 18/12 18/20
19/14 19/15 19/16
26/4 26/14 26/24
27/13 27/17 27/22
28/5 28/9 28/15 28/16
30/16 31/8 31/11
31/13 31/18 32/1 32/2
32/8 32/10 32/12
44/23 52/22 55/16
55/21 55/23 55/25
58/6 59/8 59/16
line [5] 13/12 20/10
38/20 49/11 79/4
lines [4] 11/20 78/25
79/3 84/20
list [2] 4/17 13/16
listed [1] 22/23
listen [1] 91/14
listened [1] 91/13
literally [1] 10/13
little [6] 32/15 33/20
66/3 71/8 89/3 90/13
live [2] 32/20 38/3
log [1] 14/5
log-ins [1] 14/5
logic [1] 68/16
London [3] 27/16
28/3 28/5
long [5] 33/5 40/18
59/1 62/12 79/21
long-term [2] 40/18
59/1
longer [3] 58/18 73/2
92/11
longer-term [1]
58/18
look [28] 14/14 23/1
35/21 37/17 40/3
46/20 56/14 65/13
65/24 68/9 69/22
69/25 74/5 76/3 77/8
78/13 78/17 78/17
81/6 81/8 83/4 83/10
83/24 86/2 86/14 87/5
87/18 89/7
looked [11] 9/6 14/11
23/2 36/25 51/24
76/16 78/2 80/14 84/9
85/17 93/14
looking [9] 13/16
25/6 28/4 34/19 37/1
53/19 58/22 84/1
93/25
loss [4] 18/15 18/25
23/19 86/6
losses [6] 18/7 18/21
20/2 20/3 22/13 22/23
lost [1] 92/18
lot [19] 9/10 9/11
10/25 32/23 33/16
33/22 33/23 34/16
35/8 36/1 36/15 38/8
41/20 56/16 56/23
58/19 60/14 79/17
88/2
lots [6] 35/1 35/3
60/7 61/10 61/18
93/14
lower [1] 86/10
M
made [16] 9/6 9/11
9/11 12/25 16/11
18/19 22/24 23/7 24/2)
36/2 50/14 53/1 59/17
61/11 70/13 82/7
Mail [1] 5/6
main [2] 7/5 76/21
mainly [2] 19/2 60/19
maintain [3] 19/24
19/25 24/20
maintained [2] 78/12
78/19
maintaining [1] 79/4
major [1] 59/21
majority [3] 47/25
48/13 86/3
make [13] 7/16 14/18
20/6 49/5 52/7 63/8
63/8 71/23 73/1 78/2
82/16 92/22 95/23
making [10] 9/13
23/18 40/13 40/22
44/2 51/7 52/2 57/23
67/1 87/24
man [1] 78/24
managed [2] 6/18
16/17
management [4]
49/20 60/10 60/17
61/2
Manager [4] 32/13
37/10 37/24 80/17
managers [2] 56/1
59/15
manifest [1] 16/12
manner [2] 40/12
40/22
many [10] 21/8 37/16
38/10 48/16 53/9
55/10 58/2 76/23
81/25 90/22
March [18] 30/9 31/3
(34) isn't - March
INQ00001190
INQ00001190
M
March... [16] 31/3
31/4 31/6 33/15 33/18
34/1 34/6 37/25 44/10)
46/9 73/22 74/14 75/8
75/9 75/12 96/9
Marianne [1] 1/17
mark [2] 13/14 69/14
material [6] 9/13
15/23 42/13 52/17
69/6 85/6
materially [1] 82/6
mathematician [1]
87/5
matter [8] 1/6 7/14
25/16 50/21 51/18
62/14 81/3 82/13
matters [8] 58/13
58/23 77/9 78/5 80/25)
82/17 82/18 82/21
may [22] 1/21 26/3
27/4 29/6 43/22 46/21
55/17 63/16 66/5
68/23 69/10 72/10
76/5 80/3 83/22 83/22
89/1 90/11 90/13
91/11 93/16 94/8
maybe [1] 79/12
me [29] 3/7 8/14
22/25 23/11 23/16
27/22 29/4 30/3 32/14
47/19 50/8 54/6 54/14
56/19 57/4 57/10
63/21 69/24 81/20
82/8 82/15 87/6 92/6
92/24 94/9 94/11
95/14 96/13 97/2
mean [11] 14/17
22/16 29/1 38/24
48/17 49/3 56/23 60/3
84/7 87/17 87/21
meaningfully [1]
32/2
means [6] 17/1 20/4
22/13 58/1 60/2 94/21
means/deduction [1]
20/4
meant [2] 30/10
48/18
measure [1] 14/2
mechanism [2] 24/23}
25/2
medium [1] 59/1
meet [1] 58/7
meeting [20] 7/7 8/20] 99
12/14 15/8 15/10
18/13 21/11 30/17
44/6 46/9 47/7 50/19
65/21 68/3 68/24
69/17 69/22 70/3
74/10 75/22
meetings [25] 7/13
7/15 7/18 7/21 9/15,
12/17 12/18 14/24
15/5 15/7 47/13 90/4
90/5 90/8 90/11 90/15,
90/17 91/1 91/3 91/12
91/15 91/24 92/5 92/6
92/13
member [6] 3/21 8/3
9/2 12/11 15/8 54/14
members [19] 15/15
21/12 22/1 26/14
26/22 47/13 48/15
48/18 48/19 52/14
53/25 54/17 59/23
59/24 60/1 60/13 61/3
63/10 92/20
membership [1] 59/7
memory [4] 53/15
91/23 91/23 92/16
mentioning [1] 86/11
met [3] 29/25 66/5
66/24
method [1] 23/9
mid [1] 73/7
mid-2023 [1] 73/7
middle [4] 35/14
60/16 74/4 95/1
might [10] 1/7 19/7
21/24 34/12 36/21
41/10 51/2 57/16
57/18 75/18
migrate [1] 75/1
mind [9] 9/23 18/9
31/15 44/4 44/11 50/1
93/10 94/5 94/6
inimise [1] 5/9
minutes [12] 18/12
18/14 19/20 22/15
30/16 30/19 45/21
46/8 65/16 65/23
93/14 93/25
mired [1] 51/9
miscarriages [1]
26/19
misconduct [1]
52/11
misrepresent [1]
45/6
misrepresented [1]
44/20
missing [2] 86/12
87/10
mitigate [2] 38/22
4
mitigation [1] 39/9
Mm [1] 33/11
models [1] 48/4
Modernisation [1]
66/7
moment [6] 5/16
45/19 69/11 69/24
82/15 93/5
money [8] 17/10
27/11 38/8 38/9 86/23
87/10 87/11 88/25
monitored [1] 41/24
monitoring [3] 24/23
25/2 79/4
month [1] 61/7
monthly [11] 7/7
10/16 12/7 12/12
12/17 13/24 14/4
14/23 15/15 15/25
79/20
months [7] 36/15
36/21 37/16 72/4 86/5
95/20 96/2
mood [1] 70/23
morale [1] 56/17
morally [1] 51/5
more [25] 10/4 11/8
13/19 17/17 17/17
36/7 41/4 52/9 55/7
55/10 56/16 58/15
77/19 82/17 85/12
87/23 89/11 89/14
89/15 89/21 90/13
94/15 94/15 94/15
97/16
morning [5] 1/3
39/25 45/19 46/3 65/7
most [6] 5/20 7/1 9/3
86/5 86/22 92/24
mostly [1] 4/8
motivate [1] 36/19
move [3] 30/4 94/22
95/21
Moving [3] 26/2
39/11 86/8
MPs [1] 55/17
Mr [58] 1/5 1/11 1/21
2/1 6/24 7/9 7/20 13/9
17/22 26/13 27/2 27/6
27/18 29/18 29/23
31/23 46/6 49/14
50/18 52/1 53/14
53/19 57/21 63/16
64/10 65/7 65/18
67/21 73/23 74/1 74/6
76/15 80/3 80/14
80/16 80/24 82/14
83/2 83/12 83/14
83/18 84/14 84/18
85/12 85/25 87/16
88/21 89/2 90/2 90/15
91/10 92/5 92/12 93/5
93/6 93/8 97/11 98/12
Mr Bartlett [1] 27/18
Mr Brocklesby [30]
1/5 1/21 2/1 46/6
53/14 63/16 64/10
65/7 65/18 67/21
73/23 74/6 76/15
80/14 82/14 83/12
83/18 84/14 85/12
85/25 87/16 88/21
89/2 90/2 90/15 91/10
93/5 93/6 93/8 97/11
Mr Brocklesby's [3]
17/22 49/14 57/21
Mr Jacobs [1] 50/18
Mr Jacobs' [2] 52/1
53/19
Mr Oldnall [6] 6/24
7/9 7/20 13/9 27/6
31/23
Mr Oldnall's [2]
29/18 29/23
Mr Patterson [3]
80/3 80/16 80/24
Mr Patterson's [1]
27/2
Mr Read [2] 92/5
92/12
Mr Read's [1] 26/13
Mr Staunton [1] 1/11
Mr Stein [2] 83/14
84/18
MS [12] 1/24 64/8
64/9 65/5 78/4 82/9
82/22 91/21 97/14
98/4 98/8 98/10
Ms Page [3] 64/8
64/9 98/8
MS PRICE [6] 1/24
82/9 82/22 91/21
97/14 98/4
Ms Price's [1] 78/4
much [14] 1/19 6/1
10/4 15/21 17/10 36/1
55/7 61/16 69/3 85/23,
87/11 90/23 97/10
97/19
multiple [2] 3/14 40/8I
must [4] 44/11 51/3
58/4 76/18
mutual [1] 61/23
my [59] 2/4 3/7 7/4
7/5 9/9 10/8 10/12
10/16 10/24 11/10
13/2 13/23 16/10
22/16 23/10 25/23
26/20 27/24 33/10
33/14 35/22 38/8
38/25 39/20 43/2 43/8
44/10 49/16 50/20
53/16 54/16 57/25
58/20 58/23 58/23
60/11 61/3 62/8 62/9
62/10 65/3 65/7 68/24
77/1 79/15 79/15,
79/16 79/24 81/13
82/11 82/25 84/22
88/1 91/1 92/21 93/10
94/5 94/6 95/9
myself [3] 15/2 59/25
69/5
N
naive [1] 29/13
name [5] 1/25 2/4
65/7 65/20 66/8
named [2] 63/23
64/21
namely [4] 5/5 33/20
52/8 75/20
Nash [1] 13/14
nature [5] 39/3 52/2
57/5 57/6 95/12
NBIT [22] 14/20 16/7
16/16 30/20 33/14
37/15 38/18 40/10
44/19 63/9 65/14 66/4
66/9 66/11 68/6 69/9
71/20 72/18 72/24
75/1 75/18 94/23
near [1] 73/11
nearing [1] 38/5
necessarily [1] 13/3
necessary [4] 30/2
62/8 66/19 95/10
NED [2] 17/18 17/19
need [16] 10/6 10/15
10/17 27/16 28/8
39/10 40/2 40/2 43/6
58/2 61/11 72/4 72/16)
80/22 87/18 96/19
needed [7] 36/9
37/13 38/12 52/15
66/24 67/8 96/11
needs [5] 16/25
32/12 34/3 58/21
61/19
negotiated [1] 61/25
negotiations [1]
30/23
nettle [1] 51/4
network [5] 11/7
22/10 41/20 78/21
97/4
never [6] 15/9 26/19
35/23 55/2 56/3 62/10)
new [34] 4/1 4/2 5/9
5/13 12/22 14/16 16/7,
21/11 30/4 30/6 30/20
35/10 39/13 59/24
60/4 60/11 60/12
60/24 63/10 63/12
67/6 68/19 69/9 81/14
92/20 93/11 94/12
94/18 94/24 94/25
95/8 95/19 95/21 96/6)
next [11] 18/22 25/6
31/6 46/6 50/7 65/4
69/25 70/17 71/11
95/20 96/7
Nice [1] 63/23
Nick [8] 9/4 26/12
50/9 54/13 54/19 56/3,
63/6 81/13
Nigel [2] 55/17 66/20
NM [1] 46/14
no [47] 7/19 9/16
13/7 21/25 28/23
29/21 33/12 33/20
(35) March... -no
INQ00001190
INQ00001190
N 31/18 Officer [6] 3/8 3/17 Ioption [8] 22/22 46/25 49/11 75/6
no... [39] 34/6 34/6 now [37] 2/20 7/23 I 8/1 61/24 63/14 63/24] 37/14 48/11 48/12 84/17 84/24 87/7
34/23 37/14 41/4 10/4 14/22 15/10 18/5) officers [1] 89/7 48/13 48/15 48/16 87/12 87/13 88/11
42/22 42/22 43/6 45/8 24/4 24/8 26/1 28/19 Ioffs [1] 47/24 68/11 88/25
45/15 45/15 47/2 47/6 30/11 45/16 51/3 often [2] 58/10 77/5 Ioptions [5] 19/21 outcome [4] 28/18
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recipient [1] 51/23
recognise [6] 18/4
43/3 43/19 55/1 88/22
88/23
recognised [1] 13/4
recollection [1]
82/20
recommendation [2]
46/15 48/1
recommendations
[7] 4/21 5/18 8/19
9/7 18/19 20/14 52/20
reconciliation [1]
10/16
record [5] 1/12 18/13
19/20 24/20 33/14
recorded [1] 47/21
recordings [1] 52/17
records [3] 24/21
25/8 77/12
recover [1] 18/20
recovery [14] 14/12
17/21 18/15 19/10
19/12 19/18 20/2 20/3)
20/6 20/16 20/24
22/13 23/9 23/19
recovery/repayment
[3] 19/10 19/12
20/16
recruited [2] 17/19
63/6
recruitment [2] 59/18)
70/13
recurring [1] 61/3
red [2] 48/20 66/17
redeploy [1] 48/18
redress [2] 48/1
81/18
reduce [1] 4/22
refer [2] 14/23 16/10
reference [13] 1/16
1/18 2/19 23/1 30/24
42/18 47/10 48/9
48/14 48/20 54/22
69/23 74/20
referenced [2] 36/24
70/22
referred [10] 35/12
36/4 43/22 47/5 47/9
47/11 49/21 52/14
53/4 80/2
referring [3] 20/25
41/10 45/11
refers [2] 31/17
69/16
reflective [2] 57/12
57/17
regain [1] 35/8
regard [1] 76/11
regarding [3] 12/20
18/15 26/5
regards [1] 29/3
regular [2] 4/18 12/3
regularly [1] 19/3
rejected [1] 51/17
relate [1] 1/11
related [6] 14/21
38/22 42/5 46/22
82/10 93/23
relates [2] 39/12
83/19
relating [1] 40/10
relation [8] 18/1
35/18 41/5 41/10
46/15 71/4 76/9 79/12
relationship [1]
33/17
releases [1] 4/18
relevant [9] 10/2 14/8]
(38) prevailing - relevant
INQ00001190
INQ00001190
R 14/24 44/6 67/9 35/6 47/4 47/20 48/20 46/8 49/13 50/4 55/15
relevant... [7] 25/7 _ reports [10] 12/3 result [1] 76/22 49/11 63/13 57/20 74/2 80/4 86/6
25/8 28/14 42/20 71/9 14/25 15/6 15/18 resulted [1] 49/18 rolled [2] 30/7 42/13 Iscreens [1] 41/15
77/11 77/12
reliability [6] 28/9
28/17 29/11 40/18
42/5 42/19
reliable [1] 21/1
reliant [2] 72/15 73/2
relied [3] 10/6 42/14
81/19
relies [1] 17/7
rely [3] 19/14 83/9
95/6
relying [2] 80/20
94/22
rem [1] 5/25
remain [4] 24/3 55/13I
59/23 74/2
remaining [3] 22/6
60/1 70/12
remains [2] 11/11
88/22
RemCo [1] 62/7
remediate [1] 17/10
remediated [1] 36/8
remediation [9] 5/20
8/17 9/18 21/15 35/4
35/9 48/23 48/25
58/13
remedying [1] 57/2
remember [1] 80/17
remind [4] 21/17
reminder [1] 46/19
remit [6] 5/19 8/6
8/17 9/17 10/24 13/23,
remote [1] 15/13
remove [1] 21/18
removing [2] 6/3
35/6
remuneration [2]
20/4 22/14
repay [2] 18/24 18/25]
repayment [3] 19/10
19/12 20/16
repayments [2]
22/24 23/6
repelling [1] 88/12
replace [2] 3/24 4/1
replacement [8]
31/12 32/18 33/8 34/9)
34/14 67/19 68/9
68/19
replied [1] 27/18
report [11] 7/20 12/6
27/3 39/22 44/5 44/9
67/24 68/1 71/16
86/22 87/15
reported [7] 13/3
24/6 28/20 79/5 79/7
86/3 86/17
reporting [7] 6/11
6/24 12/16 13/24
43/13 44/4 44/12 79/8
79/9 91/12
represent [1] 55/24
representative [2]
20/8 23/25
reprocure [1] 74/24
request [7] 31/4
31/17 72/20 73/17
73/18 84/15 85/9
requested [3] 7/17
29/9 73/6
requesting [1] 26/23
requests [1] 73/3
required [7] 1/10
39/4 52/10 52/16 75/9
75/16 95/22
requirement [3]
75/22 78/20 81/7
requirements [3]
38/21 41/21 42/1
requires [1] 58/8
resigned [1] 60/8
resilience [1] 38/5
resilient [1] 41/18
resistance [1] 54/24
resolution [1] 13/22
resolutions [1] 94/1
resolve [6] 11/1 11/9
11/11 13/1 19/1 87/11
resolved [6] 10/23
50/22 74/5 74/10
86/22 86/23
resolving [1] 15/24
resourcing [1] 48/3
respect [2] 66/14
66/16
respected [1] 55/13
respond [3] 78/25
79/1 84/4
responded [2] 69/19
87/2
responding [3] 8/7
73/3 82/23
response [3] 41/2
69/14 73/17
responses [1] 72/13
responsibilities [4]
3/13 7/5 23/11 79/24
responsibility [5]
5/17 25/22 57/24
79/15 79/16
responsible [11]
3/22 4/12 6/15 13/8
13/14 22/17 40/16
51/20 66/11 68/5 79/8
rest [3] 56/7 61/15
93/15
restate [1] 21/16
restorative [2] 90/5
90/16
restructuring [1]
resulting [1] 28/18
results [1] 56/14
resume [1] 97/17
retail [11] 10/9 10/19
11/10 12/5 12/7 12/9
13/12 41/20 78/24
79/6 79/16
retires [1] 59/24
retiring [1] 33/6
return [1] 59/19
returned [1] 92/22
revealed [1] 64/17
revert [1] 69/4
review [21] 7/2 12/22
12/24 13/1 15/4 20/5
26/10 46/16 46/19
46/25 50/13 52/6 54/1
71/1 71/4 71/6 79/2
79/14 89/25 96/6
96/23
reviewed [1] 79/19
reviewers [1] 52/20
reviewing [1] 22/19
reviews [5] 35/24
66/16 89/10 89/18
89/24
revision [4] 85/13
ride [1] 35/24
right [41] 3/1 3/10
3/12 3/16 3/21 5/8
6/16 6/21 7/11 7/12
7/24 9/18 26/8 36/3
37/9 39/11 39/24
50/12 51/11 57/14
59/2 62/1 62/3 63/20
64/6 75/21 76/3 76/17
76/20 76/25 77/24
78/4 79/3 79/7 80/1
84/23 91/10 93/12
93/25 94/5 97/14
rightly [1] 28/15
rigorous [1] 59/18
risk [10] 4/23 16/11
16/12 36/4 38/6 39/8
42/15 42/16 49/19
49/21
risks [7] 36/5 38/2
38/4 38/20 38/22 39/5
39/10
roads [1] 96/15
robust [3] 19/13
20/17 21/21
role [18] 2/23 3/19
3/21 9/19 17/18 20/13
22/16 26/2 27/24
28/24 29/18 46/22
52/24 53/18 54/18
58/24 63/14 63/22
roles [13] 3/8 9/5
46/7 46/12 46/16
46/19 46/20 46/25
rollout [1] 30/10
root [3] 10/8 11/15
25/24
round [1] 91/6
Royal [1] 5/6
RU [6] 46/16 47/14
47/20 48/19 48/21
48/23
rulings [1] 64/25
run [4] 11/21 79/24
82/2 88/7
running [4] 5/21 5/23
33/3 88/18
runs [1] 31/3
Ss
Saf [1] 70/18
said [11] 20/24 29/2
29/5 43/25 70/12 73/7
84/9 84/19 84/20 86/9
91/16
same [5] 41/6 41/6
68/18 81/19 87/8
satisfactorily [1]
717
saw [1] 67/4
say [44] 4/8 6/15 8/6
8/16 8/21 10/3 10/15
11/2 12/15 13/18
14/13 15/16 16/12
17/25 33/13 40/4
47/19 49/15 49/22
49/23 51/21 55/2 55/6
57/22 58/14 61/22
62/22 64/25 67/22
69/1 69/4 70/10 71/4
71/10 72/21 74/8 75/3
78/16 83/3 88/15,
90/19 92/14 97/9
97/15
saying [14] 27/7
42/16 67/22 74/18
77/9 79/21 80/18
80/24 81/2 81/5 82/9
82/12 82/12 82/25
says [12] 19/11
26/15 40/7 48/7 50/25
51/14 55/19 66/4
69/12 71/18 80/5
88/14
scale [1] 59/11
scandal [2] 26/17
77/3
scene [1] 42/1
schedules [1] 37/19
scope [6] 9/9 47/3
48/19 52/5 64/21 97/6
screen [19] 4/15 8/5
17/22 18/11 24/11
26/11 27/5 30/15
31/15 31/24 39/21
scroll [3] 70/1 70/18
80/4
Scrolling [2] 27/19
50/5
scrutinised [1] 9/1
scrutiny [1] 12/13
second [11] 1/17
26/14 41/5 58/9 75/7
80/6 82/25 86/2 86/14,
88/1 94/6
secondly [2] 40/14
67/5
section [8] 24/17
65/24 66/2 69/25 70/2
71/10 71/11 80/13
section 3.5 [1] 65/24
section 7.1 [1] 70/2
secure [2] 32/4 33/2
security [5] 17/6
17/10 27/25 33/23
41/21
see [24] 1/3 14/17
20/11 24/12 31/10
33/19 41/18 43/13
46/3 50/7 56/14 65/18
65/20 65/21 66/1 70/3
70/18 74/6 76/4 77/8
81/23 84/6 85/25 92/8,
seek [5] 20/3 22/12
48/18 55/21 77/20
seeking [7] 25/12
26/12 26/21 32/4
74/11 77/16 78/14
seem [2] 51/15 51/16
seemed [4] 66/19
67/12 69/12 82/12
seems [3] 84/8 87/6
92/15
seen [7] 28/24 32/1
37/23 39/24 39/25
41/14 56/18
SEG [28] 8/16 13/24
14/25 15/5 15/7 15/15)
18/12 18/18 19/20
19/22 21/8 21/17 22/2)
23/3 23/20 43/7 43/12
46/9 47/24 48/3 58/12
59/6 59/21 60/25 61/3)
63/10 79/8 79/19
senior [4] 49/20 56/6
59/15 60/6
sense [2] 36/14 70/8
sent [3] 26/7 28/20
79/13
sentence [1] 80/15
separate [6] 13/13
13/13 47/3 68/17
68/25 69/17
September [9] 3/19
30/17 53/17 53/19
66/1 68/23 87/15 94/2
(39) relevant... - September
INQ00001190
INQ00001190
s signed [2] 58/2 58/4 I 85/15 85/16 86/4 stakeholders [1] 57/23
September. [4] [Significant [7] 29/26 I 87/23 89/3 89/4 90/4 I 36/1 stuff [4] 80/18
95/10 i 55/24 57/11 57/16 90/24 91/2 93/2 95/4 Istamps [2] 6/2 6/4 Isub [1] 18/16
serious [1] 31/12 58/6 59/6 86/11 96/16 standard [2] 38/10 I sub-bullet [1] 18/16
seriously [3] 52/24 significantly [2] somebody [2] 68/10 I 76/5 subject [4] 46/22
55/12 78/17 49/17 56/5 68/10 standing [1] 12/16 74/11 89/18 89/23
serve [4] 33/4 41/16 Simon [13] 6/13 7/1 Isomeone [5] 13/9 staple [1] 66/25 subpostmaster [9]
94/23 95/8 7/2 21/4 21/5 21/10 I 17/15 51/2 62/25 start [6] 2/22 30/10 I 3/23 12/19 13/3 14/2
service [3] 4/8 6/18 21/16 23/25 27/3 63/25 33/5 35/10 64/13 95/3) 24/10 25/10 77/14
38/3 28/20 30/2 71/14 72/1Isomething [15] 12/6 Istarted [7] 7/25 87/3 88/7
services [9] 26/24 simple [2] 26/23 77/6I 13/5 13/23 25/22 50/18 53/15 62/13 I subpostmasters [14]
27/17 30/9 31/21 simplest [1] 78/13 I 60/16 61/1 63/7 76/3 I 64/13 83/22 84/2 11/24 14/7 24/25
32/10 37/14 70/9 95/4 Simplistic [2] 95/15 I 85/11 87/17 87/22 starting [13] 5/2 10/3I 29/20 65/8 75/15 76/5
95/6 96/12 89/10 90/12 90/14 18/16 24/18 25/20 76/10 77/4 77/25
sessions [1] 92/23 simply [1] 51/1 95/20 27/6 31/24 34/13 64/8] 78/16 87/1 87/7 92/17
set [6] 2/24 6/20 since [4] 14/6 18/23 Isometimes [2] 88/9 I 77/3 94/13 94/20 subsequent [2]
22/15 24/19 34/21 50/24 65/9 91/2 94/21 35/24 57/8
464 single [2] 25/18 somewhat [2] 23/10 Istarts [1] 70/1 subsequently [2]
51/15 68/16 state [1] 62/17 62/8 96/10
set-up [1] 34/21
sets [4] 32/15 44/15
63/17 63/17
seven [2] 53/25
90/11
several [1] 73/8
sir [19] 1/3 1/5 1/20 Isoon [2] 7/25 54/4 Istated [2] 22/3 44/8 I subset [4] 32/21
45/17 45/24 46/3 sorry [4] 22/25 67/21 Istatement [29] 2/7 Isubstance [1] 43/25
53/15 53/21 63/15 69/4 93/8 2/16 2/19 2/24 4/11 I successful [2] 36/11
63/18 63/19 64/8 65/6I sort [2] 11/13 75/6 5/4 6/10 7/9 7/23 8/5 I 66/25
74/2 84/22 93/7 97/18) sought [4] 19/18 21/3) 9/25 11/2 12/15 13/17I successfully [1]
shame [1] 92/15 98/6 98/14 39/1 49/12 14/22 14/23 15/16 22/11
share [3] 26/16 52/1 [Sit Wyn [1] 53/15 Isounds [1] 72/6 16/10 17/23 43/19 I succinctly [1] 61/9
92/21 sit [2] 20/9 54/15 sources [1] 40/8 49/14 55/5 57/11 such [13] 5/6 8/10
shared [1] 66/20 sits [2] 13/23 92/5 Ispanned [1] 3/5 57/21 61/22 62/22 13/4 16/6 16/15 17/6
shareholder [1] situation [4] 19/24 Ispeak [6] 12/11 82/7 91/21 97/12 48/5 60/5 66/25 75/16
30/17 19/25 22/6 83/7 68/22 70/6 74/24 statements [2] 1/9 80/21 85/3 85/18
shed [1] 64/24 six [2] 6/19 90/11 82/15 96/22 28/14 suffered [1] 90/23
short [5] 1/6 1/9 size [3] 20/22 58/5 Ispecific [12] 5/24 stats [1] 14/4 sufficient [3] 58/1
31/12 46/1 95/22 97/4 7/18 8/19 9/7 14/18 I status [6] 16/16 74/25 75/10
shortfall [9] 8/11 SJ [2] 71/5 71/24 15/20 17/18 29/25 23/14 32/17 38/3 suggesting [1] 81/18
Ded 25/18 25/24 ISKewed [2] 40/12 I 38/11 44/4 44/12 85/9] 43/12 43/17 suggestion [1] 18/1
78/5 78/18 BOIZ1 40/22 specifically [12] Staunton [1] 1/11 Isuggests [1] 43/7
81/19 85/3 slices [1] 95/17 14/20 15/9 16/5 18/1 Istay [1] 73/13 sum [1] 27/11
shortfalls [30] 14/13 slight [1] 37/23 21/4 22/8 29/21 41/10ISTEIN [4] 74/1 83/14 Isummarise [1] 94/11
17/21 24/24 25/3 25/9 slightly [1] 69/3 43/17 52/19 56/24 84/18 98/12 summarised [2]
25/13 25/16 77/4 slowly [2] 40/2 77/19I 81/22 step [1] 58/25 79/12 79/22
7713 77/17 77/21 small [3] 16/17 22/8 Ispectrum [1] 70/9 Steve [1] 64/16 summarising [1]
77/25 78/2 78/8 78/10 53/11 speed [2] 40/17 sticks [1] 75/19 12/3
78/15 78/18 80/11 so [141] 41/12 still [25] 4/8 5/22 summary [7] 40/23
80/12 80/19 80/25 software [28] 4/18 Ispend [3] 17/10 38/9 I 32/22 33/22 38/11 54/7 82/11 85/25
81/8 81/9 82/18 83/4 12/20 16/22 16/22 58/19 46/3 47/13 50/22 91/16 91/18 97/2
83/10 86/18 87/9 16/23 32/20 32/22 spending [1] 96/6 53/18 56/7 64/18 summon [1] 90/20
88/16 88/25 32/23 33/3 33/20 spends [2] 58/6 67/18 68/6 68/8 71/24I supplier [2] 73/17
shortly [1] 65/25 33/21 33/25 34/3 34/3) 58/15 72/7 86/10 87/6 87/8 I 73/18
should [14] 2/6 11/23 34/19 34/20 35/2 spent [1] 38/8 87/12 87/16 88/13 supply [1] 84/7
17/14 20/16 29/16 35/13 36/6 41/13 SPM [6] 16/6 66/5 88/16 88/24 93/2 support [35] 5/1 5/3
29/22 54/15 64/18 41/14 41/19 42/3 42/7I 66/6 67/5 68/25 96/18I stood [1] 68/11 10/4 10/7 10/9 10/19
65/16 67/3 68/21 42/7 42/8 42/8 42/13 ISPMP [2] 31/11 70/6 Istop [1] 80/5 10/21 11/2 11/7 11/7
80/18 80/20 84/16 sold [1] 97/5 SPMs [3] 86/3 86/16 Istory [1] 94/1 11/20 11/24 11/25
showing [1] 56/5 solution [2] 32/25 86/22 strands [1] 39/15 13/11 13/12 25/23
shown [1] 81/12 42/3 spoke [2] 46/14 strategic [5] 3/22 30/8 31/2 38/5 45/10
SI [4] 70/18 some [41] 6/69/24 I 71/11 7/25 14/23 58/16 66/6I 55/22 72/3 73/2 74/13
sic [1] 27/13 15/14 18/15 22/1 23/5Isponsor [1] 8/16 _Istrategy [7] 31/6 58/9I 78/21 78/21 78/25
sick [1] 55/25 24/9 27/9 29/4 32/14 ISR [1] 46/14 59/1 71/20 73/1 74/12! 80/7 80/9 83/25 84/6
side [3] 7/10 7/10 32/20 37/13 37/19 stability [1] 59/16 96/22 84/10 84/12 84/21
94/1 41/11 42/10 43/20 staff [4] 52/15 53/25 Istrength [1] 56/11 95/7
sign [1] 62/9 51/10 53/7 54/23 59/25 60/6 strike [1] 81/20 supported [2] 48/15
59/14 60/8 61/5 63/16I staffing [1] 46/16 I strong [1] 60/25 81/25
signature [2] 2/12
ah 67/16 70/16 73/7 _I stage [5] 23/17 35/11Istrongest [1] 50/20 Isupporting [6] 27/10
73/10 73/19 80/18 37/16 43/4 71/20 structure [2] 6/9 27/13 32/21 71/23
(40) September... - supporting
INQ00001190
INQ00001190
s
supporting... [2]
74/22 82/1
supports [1] 22/9
suppressed [1]
44/24
sure [18] 7/16 12/21
14/18 15/21 34/10
43/20 44/5 49/6 63/8
64/20 71/23 73/1 78/2
82/16 87/24 89/19
92/22 95/23
surpluses [2] 86/19
87/10
surprised [1] 81/12
surprisingly [3]
67/12 69/12 69/15
survey [1] 87/20
surveyed [3] 86/3
86/16 87/1
surveys [1] 56/15
suspend [1] 51/17
suspended [1] 51/16
suspensions [2] 8/11
14/12
system [51] 3/24 4/1
4/1 4/2 4/13 4/25 5/10
5/13 8/18 14/16 21/10)
21/18 22/9 28/12
29/12 30/5 30/7 30/10
30/11 30/20 31/21
32/18 33/1 33/8 34/14)
39/13 40/18 42/5
42/19 67/6 69/7 75/14
76/1 76/7 81/2 82/4
82/6 83/10 83/20 86/5)
86/14 87/14 88/8
93/11 94/12 94/16
94/18 94/20 94/25
95/8 95/19
systems [4] 3/14
16/14 17/8 81/4
T
table [3] 13/5 21/8
73/15
tactical [1] 18/13
take [13] 32/10 36/5
40/2 52/8 58/25 72/6
76/12 80/23 85/21
91/3 91/23 94/25 96/8)
taken [8] 33/25 46/15
49/11 55/12 72/5 80/9
83/8 92/4
takes [2] 34/2 45/21
taking [2] 40/19
78/17
talk [3] 70/15 88/2
90/25
talked [1] 72/17
talking [7] 34/22 70/7
70/9 73/8 87/9 88/3
96/1
talks [4] 67/9
team [45] 6/9 6/18
9/2 10/8 10/19 10/25
11/7 11/7 11/10 11/10)
11/13 11/18 11/25
12/7 12/12 12/13
13/11 15/3 19/4 21/12)
25/23 28/1 28/2 35/6
39/22 41/24 48/19
51/20 52/11 54/15
54/17 56/15 56/18
59/24 60/1 60/13
60/24 60/25 61/16
70/23 78/21 78/22
78/24 79/6 92/20
teams [4] 11/16
40/10 79/18 79/25
tech [1] 15/12
technical [2] 17/8
82/1
technology [2] 16/5
70/1
tell [4] 41/1 94/9
95/14 96/13
ten [1] 59/23
tend [1] 16/19
tendency [1] 49/19
tenure [5] 38/9 38/25
60/11 62/15 63/8
term [9] 32/5 40/18
58/18 59/1 71/21
72/25 75/1 78/11
92/11
terminate [1] 75/17
terminated [1] 75/20
terminations [2] 8/12)
14/12
terms [53] 5/16 11/8
14/4 14/17 15/13
15/22 15/24 16/1 16/4)
22/19 23/12 23/18
23/23 25/1 26/23 29/2
33/5 33/22 33/23
34/25 35/2 35/25
37/18 37/19 38/5 38/6
38/14 42/23 43/23
50/20 54/2 56/16 57/6
57/23 58/18 58/20
59/1 61/21 61/24
72/23 75/22 78/20
79/18 82/4 82/25
83/25 84/4 87/19
87/24 89/12 93/11
95/17 97/3
terrible [1] 56/3
Tesco [1] 3/9
test [2] 16/23 82/8
tested [1] 35/13
testing [3] 40/15
41/11 82/25
text [1] 40/3
than [10] 25/23 41/4
55/7 55/10 58/15 59/2
59/13 73/4 82/17
90/13
thank [33] 1/4 1/20
2/3 7/23 14/22 24/8
24/16 26/1 28/19 40/5
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timelines [1] 97/6 ied [1] 92/21 90/19 90/21 90/22 using [3] 24/21 86/22Iwasn't [14] 15/8
times [4] 7/17 17/24 {trilateral [1] 28/4 91/2 91/5 91/8 91/9 I 95/8 15/11 34/17 34/21
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timescale (2) 32/24 Ittuly [11 51/10 understanding [15] utter [1] 50/21 43/15 44/10 47/19
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