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INQ00001193
INQ00001193
The Post Office Horizon IT Inquiry 9 October 2024
Wednesday, 9 October 2024
(10.03 am)
SIR WYN WILLIAMS: Mr Beer, before we begin to hear evidence
this morning, I have an announcement to make.
Ladies and gentleman, it is my sad duty to announce
that Mrs Gillian Blakey, one of our Core Participants,
passed away last week. Mrs Blakey had been the
subpostmaster at Riby Post Office in Lincolnshire.
During her period as a subpostmaster, data from the
Horizon system suggested that there was a substantial
shortfall at the branch, and the use of that data, in
due course, led to Mrs Blakey's husband, David, being
prosecuted, and Mrs Blakey ceasing to be the
subpostmaster. Mr Blakey's conviction was quashed by
the Court of Appeal Criminal Division in April 2001.
Both Mr and Mrs Blakey were claimants in the Group
Litigation. My understanding is that Mrs Blakey had not
received the additional compensation to which she was
entitled under the GLO scheme. That must be a matter of
great regret for all concerned.
On behalf of all of the members of the Inquiry Team,
and on my own behalf, I extend my deepest sympathies
this to all Mrs Blakey's family and friends.
I understand -- and if any necessary formalities need to
be undertaken, this will be done -- that Mr Blakey will
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knowiedge and belief?
A. They are
Thank you very much. Your second witness statement
dated 3 September, ie the next day, WITN00760200, at
26 pages, excluding the appendix. Again, if you can
track that down, please.
Ihave, yes.
Thank you. Page 26, is that your signature?
Itis indeed
Are the contents of that true to the best of your
knowledge and belief?
They are
Thank you. Your third witness statement, WITNO0760300,
142 pages, excluding its appendix, dated 13 September,
I think there are three corrections to make to this. If
we can go to page 28, please, and look at paragraph 64,
in the third line, it says:
oP
“was conscious there was a lot of activity that
could be brought together to deal with the actions from
[the Common Issues Judgment and the Horizon Issues
Judgment]. This came together under the Improvement
Delivery Group set up in February 2021 and which until
October 2021 focused on the change delivery and tracking
the actions.”
Should that read October 2022?
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represent his wife's interest as a Core Participant
during the remainder of the Inquiry. Thank you.
Yes, Mr Beer.
MRBEER: May I call Nick Read.
SIR WYN WILLIAMS: Yes.
NICHOLAS JAMES READ (sworn)
Questioned by MR BEER
MR BEER: Good moming, Mr Read. As you know, my name is
Jason Beer and I ask questions on behalf of the Inquiry.
Can you give us your full name, please?
A. Nicholas James Read.
Q. You've made, kindly, four witness statements to the
Inquiry. Can we start, please, by going through each of
those. The first witness statement is dated 2 September
2024, it's 132 pages long, excluding its appendix. Can
we look at that, it's WITNO0760100. It'll come up on
the screen for you
This is your first witness statement, 132 pages. If
we go to page 132, please. Have you managed to track
down the hard copy?
A. I'm just looking for it, actually. Bear with me
a second. I've gotiit, yes.
Q. Ah, thank you. Is that your signature in the hard copy?
Itis indeed.
>
Q_ Are the contents of that true to the best of your
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Yes, that's correct.
So cross out "2021" and insert "2022"?
Correct.
prop
Secondly, page 108, at paragraph 231, second line:
"We had incomplete HR records which, given this was
a desktop exercise to review 700 colleagues ..."
Should that read"
It should.
Q. So 1,700, rather than 700
Then, thirdly, page 140, at paragraph 305, line 4:
“The working environment, being subject to public
700 colleagues"?
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sector pay, inventive and settlement constraints ..."
Should that read "incentive" rather than
“inventive”?
That's correct.
Thank you. Can you go to page 142, please, in the hard
copy?
Yes.
Is that your signature?
Itis indeed
With those three corrections brought into account, is
the statement true to the best of your knowledge and
belief?
Itis.
Thank you very much. That can be put to one side. Your
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The Post Office Horizon IT Inquiry
fourth witness statement, WITNO0760400. That's dated
24 September and is seven pages, excluding its appendix.
Can you tum up page 7, please.
Yes.
Is that your signature?
Itis indeed
Are the contents of that true to the best of your
knowledge and belief?
Yes, they are.
Thank you very much. Those witness statements, I think,
can all be put to one side now in their hard copy.
Thank you.
Before addressing your background, I just want to break
down the two species of witness statements that we have
just looked at and which, overall, I think, constitute
some 307 pages of material, if my maths is right. Is it
correct that the first, second and fourth witness
statements are corporate witness statements made on
behalf of Post Office Limited —
Yes, that's correct,
-- whereas the third witness statement is a personal
witness statement from you?
Absolutely right.
Can you please explain in your own words the difference
between them?
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of the content. Clearly, from a personal witness
perspective, they were my words.
Thank you. In relation to your background, you are
currently the Post Office's Group Chief Executive
Officer; is that correct?
That's correct.
You joined the Post Office in September 2019?
Yes,
You announced on 18 September this year that you will be
resigning from your position at the Post Office in March
2025; is that right?
That is correct.
In relation to your previous career before the Post
Office, can we look, please, at your third witness
statement at page 3. WITNO0760300. In paragraph 7, you
set out chronologically your career for us, by setting
out the jobs that you had before you joined the Post
Office in paragraphs 7(a) to 7(j); is that right, if we
just scroll down?
Yes, that's correct,
You tell us later in your witness statement that two of
those roles amounted to large-scale leadership roles as
a CEO of a challenged organisation and that, as
a result, you had experience on joining the Post Office
of crisis management and turnarounds; is that right?
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INQ00001193
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9 October 2024
Not a great deal because, to be fair, I think my role as
the CEO of the Post Office encompasses -- is all
encompassing, from a personal perspective, and such that
the deviation of my own reflections reflect exactly what
I believe has happened over the last five years.
So I don't think it differs enormously. There are
clearly elements within the questions that you asked me
in the third statement that are more personal but
I don't think the deviation from the corporate witness
statement to my personal witness statement is.
particularly different.
So it isn’t the case, in relation to the first, second.
and fourth witness statement, that you are saying things
that you do not personally agree with but you are saying
them because, on behalf of the company, corporately,
that is the company's position?
Yes, that's correct.
Was there any difference in the process by which each of
them came to be made, ie one subject to, for example,
Board approval or a group of executives’ approval,
whereas the third witness statement was your words and
your words alone?
Yes, I think it would be fair to say that the corporate
witness statements involved Subject Matter Experts from
within the business supporting and helping me with some
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That's correct.
‘One of those, I would guess, was the job at (i), the
Chief Executive Officer of Nisa Retail; is that right?
Yes, that's correct.
Which was the other one?
The other one was the CEO of ExtraEnergie GmbH, which is
at (i).
Could you explain briefly your experience in those two
organisations of stabilisation, modernisation and growth
ina struggling and challenged or failing business?
Yes, I'l start with (i), the Nisa Retail. I was
recruited into this role to a very challenged business.
It was suffering from breached banking governance, it
had just recorded its first loss as an organisation, it
had some serious governance issues associated with
shadow directors and issues of Board colleagues, and it
also overstated its income.
So it had four pretty fundamental issues at play and
it was in a very highly competitive market, which was
convenience retail.
My job was to come in and to stabilise the
organisation, to get the business growing again, and to
try and identify what the long-term future for Nisa
Retail would be, and that was and ultimately became
a sale to the Co-op organisation so it was a fairly
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The Post Office Horizon IT Inquiry
classic turnaround of some quite substantive challenges.
And ExtraEnergie?
ExtraEnergie, I was parachuted into ExtraEnergie to
salvage an organisation that was suffering immense
stress in the UK. It was a European energy business
with a UK arm; this particular challenge was a service
challenge and an IT challenge. Ultimately, after five
months, it became apparent that it wasn't salvageable
and I had the difficult challenge of explaining to the
‘owners of the business that, in my opinion, we should
put the business into administration, which is what we
did, which was extremely challenging for the 500
colleagues who worked in the UK, and, obviously, my job
was to see that process through to its conclusion, and
to regroup the organisation back to mainland Europe.
Thank you. In your witness statement at paragraphs 10
to 25 you provide details of your role as the Chief
Executive of the Post Office, the situation when you
joined the Post Office and the process which led to your
appointment.
If we can just look at a few paragraphs within that
section, starting with paragraph 12 on page 6. You say:
"Before and during this interview process
This is the interview process for the role of CEO at
Post Office:
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Yes, that's correct.
We can see it's a person (sic) specification for the CEO
of Post Office Limited. Then, if we go over the page,
it's a seven-page document. It sets out the history of
the Post Office on this page; its reach within the
United Kingdom; in the paragraph at the bottom of the
page there, its turnover. It sets out its products in
four strategic business areas and then, over the page,
it says ~ if we can just go over the page, thank you
“Post Office [underneath the bullet points] has made
strong process over the last five years in laying the
foundations for longer-term success [modernising] 7,000
branches ... 200,000 extra hours of opening .
continual programme of investing in, and modemising,
its branch network ..."
Three lines from the bottom of that paragraph:
“Legacy systems and IT are being addressed and
upgraded now that the separation from [RMG] is complete.
This will deliver around 15 per cent reduction in
annualised operating costs by March 2018."
That's obviously over a year before this —
Yes.
-- so that's out of date information that has been cut
into this document, presumably?
Yes.
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INQ00001193
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9 October 2024
I familiarised myself with Post Office and was
therefore aware that the Post Office was facing
litigation from Postmasters connected with allegations
of historic bugs in the IT system and the requirement
for postmasters to repay shortfalls. I did not at that
stage have a detailed understanding of what the
litigation involved, nor the postmasters’ allegations,
and had not, before being appointed, read the Common
Issues Judgment (as opposed to summaries). The job
specification did not mention the litigation, and as far
as I recall it was not mentioned during the interview
process. The job specification did not state that Post
Office needed to oversee a large scale and complex IT
transformation project (ie replacing Horizon); again, as
far as I [was aware], this also was not mentioned to me
during the interview process. I had no indication that
a significant part of my role would be a profound
cultural change of the scale needed, dealing with the
litigation or its implications, or in delivering
a large-scale IT transformation: these issues were never
presented to me as priorities during the interview
process."
Just stopping there, can we look, please, at the job
specification at POL00448890. This is, I think, the job
specification that you're referring to; is that right?
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If we carry on looking down that page, we'll see at the
bottom the strategic priorities:
"With a stable network, and ongoing investment to
modernise the network, improve convenience and service
for the customer, the Post Office has identified the
following five strategic priorities", and they're set
out over the page.
It sets out on this page, page 3, the corporate
history of the Post Office; scrolling down, the
Executive Team; the Board; the role that the person to
take the role of Chief Executive was to perform. Over
the page, scrolling down, the "Candidate Profile". Then
over the page, scrolling down, that's the end of the
substance of the document and the rest of the two-page
document contains biographies of members of the Board.
So it's right, isn't it, that that does not mention
Horizon from start to finish?
That's correct.
It doesn't mention, from start to finish, the move to
NBIT, does it?
No, it doesn't.
A very large and exceptionally complicated IT
transformation project?
That's correct.
It does not mention the litigation?
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The Post Office Horizon IT Inquiry
No, it doesn't
Even though at this time -- this will have been summer
2019 ~
Yes.
-- the recruitment process was taking place -- the
Common Issues Judgment had been handed down already —-
Yes, ithad.
-- earlier that year?
Absolutely.
That was rather a fundamental judgment for the Post
Office?
I agree.
The Horizon issues trial was just around the corner, was
about to start?
Yes.
Also a rather fundamental trial and, ultimately,
judgment for the Post Office. So looking at it, the job
specification does not properly address or describe the
role that you were, in fact, needed to perform, does it?
No, it doesn't
If we go back to your witness statement, please. Third
witness statement at page 7, paragraph 13, the last
three lines. You say:
“It is now clear to me that I did not have a proper
appreciation at this time of the scope or magnitude of
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the Post Office and from the start was convinced that
the postmasters had to be the central focus for that
purpose.”
Then about eight lines in, you say:
“The findings from the litigation confirmed that was
the right decision. [You] cannot recall exactly when
[you] found out that Post Office privately prosecuted
postmasters (and had stop [doing so] -- although [you]
know from having read the [Common Issues Judgment] that
was mentioned there). Private prosecutions were
presented to me as a historic issue that had ceased
before 2015 and that I did not need to dig into the
details of what had happened at Post Office in the past
as this conduct had ended."
Looking at that all together then, my questions: had
you, in fact, known what was involved in the role,
ie the things that you were not told, would you have
applied for and accepted the role?
I think I was very well placed to tackle the issues that
the job description described.
I'm focusing on the things that weren't in the job
description.
Yes, I was going to come on to that. I think there's no
question that I didn’t have experience of managing
a litigation, I didn't have experience of running
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9 October 2024
the injustice that Postmasters faced.”
Then at paragraph 16, scrolling down, you say:
"My understanding was that I was joining a business
that was challenged. Its core product areas ~- cash and
mails -- were ‘sunset’ products, experiencing year on
year declines in volume and revenue. There was a lack
of operational rigour, overheads were too high and cost
reduction needed to be driven harder.”
Reading on:
"I did understand to some degree that the
relationship with Post masters was strained, the
litigation required resolution and a new partnership
with Postmasters needed to be established. This felt
like a turnaround situation and [you] felt [you] had the
relevant experience to lead it.”
If we go forwards, please, to page 11 and
paragraph 22, you say:
“In the first couple of weeks of being CEO I had
only limited contact with the Post Office Legal team
about the GLO ... I did have contact with colleagues who
were dealing with the operational changes that Post
Office needed to put in place from the [Common Issues
Judgment}."
Paragraph 23 on page 12, you say:
“[Youl were keen to develop a purpose and vision for
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a compensation scheme or, indeed, of managing a public
inquiry, and so the scale of those activities are quite
profound and have been quite profound on my role for the
last five years. Clearly, there won't be many
individuals who would have that mix of skills to run
a retailer and to continue to maintain an organisation,
such as the Post Office, serving customers, as well as
running a public inquiry and a compensation scheme
Would I have accepted the role? I stil believe
that I had the necessary skills to do it, i's just that
‘coming in to the job it was described in a very
different way from what I obviously found in those first
few months.
Have you thought why that was —
Yes, I have.
— why it was that the true position was not revealed to
you, either before appointment or upon appointment?
I think I have thought about it, and I've thought about
it quite a lot. I think there was an underestimation of
the impact of the Common Issues Judgment on the
business. I characterise it in my witness statement in
two ways. First and foremost, there was a population
who simply didn't believe that they would lose the
litigation and, as a consequence, there were not
contingencies or plans in place for that eventuality,
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The Post Office Horizon IT Inquiry
and so a degree of denial, I would argue.
And for the majority —
But they'd already lost the Common Issues Judgment by
the time —
They had.
-- you joined, that was some six months —
They had but there was a degree of denial, I think, is
the point I was trying to make, in the sense that
I don't think people had come to terms with having lost
the Common Issues Judgment, or indeed what the
implications of losing it were. And I think, for the
vast majority of the organisation, they believed they'd
been doing a good job, what they'd been asked to do, and
were getting on with it.
So there were two very distinct camps within the
organisation: I think the majority of the organisation
was just getting on with what they thought their job
was; and I think the senior leadership were trying to
come to terms with the fact that they had not
anticipated losing the litigation. And so, therefore,
they were part in denial and part in paralysis.
Who briefed you when you were appointed CEO?
Who briefed me when I within the organisation?
Yes.
As I say in my witness statement, I spent time obviously
7
Were you provided with a clear analysis of the findings
of Mr Justice Fraser in the Common Issues Judgment?
Yes, I was. That piece of work had been done and I had
a breakdown of, and summary of, the findings and the
implications that we were - or what we were going to do
as a consequence.
So you were provided with an assessment of the work that
was required to be done in order to react to the Common
Issues Judgment and move forwards?
Work had started on the conformance plan. I think in
one of my exhibits, I provide detail of what that work
is, and work was beginning to be discussed at the Group
Executive around what the implications more broadly
looked like.
As part of the briefings, was the issue of the conduct,
competence and ethics of those within the Post Office
that had conducted investigations and prosecutions
against postmasters discussed?
No, it wasn't. The focus of the briefings that
I received were around conformance with the Common
Issues Judgment. What were we going to do in terms of
regaining trust and also the sort of specific themes
that Fraser J had identified from a process and
procedural and policy perspective.
Did you receive any briefings in relation to the
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9 October 2024
with the Chair, with Tim Parker, talking about the
priorities. I met with all of the Group Executive
before I joined, with the exception of one who was away
on holiday. I met with UKGI and with DBT officials
before I started - so this was throughout August
2019 -- so I had a relatively broad understanding coming
in on day one.
Amongst those briefings, I don't ~ and I think as.
I say in my statement, I don't think the scale or
enormity of the scandal was brought to life for me
because I don't think there was a realisation or
recognition at that stage within the business of what
needed to be done or indeed what was likely to happen.
Were you provided, in the course of those briefings,
with a clear analysis of the extent of the Post Office's
failings in relation to past enforcement action taken
against postmasters?
Til answer that in two ways. I think work had started
to be done to understand the implications of the Common
Issues Judgment, and that was work that was being led
ostensibly by the legal function but also by the
Operations and Retail teams.
In terms of broader prosecutorial implications, that
wasn't something that was necessarily explained in great
deal to me when I joined in September 2019.
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standard of conduct expected of either civil
investigators or criminal investigators within the Post
Office?
No, I didn't.
Therefore, I think it follows that no assessment of
whether currently, upon joining, the Post Office's
investigators met those standards, either now or in the
past?
I think, as I said in my witness statement, the way that
it was articulated to me in September 2019 was very much
prosecutorial activity had ceased in 2015. Indeed, it
hadn't been initiated since 2013. Nothing like this is
happening or could happen, we need to look forward
That would be my summary of how it was positioned.
But no analysis of the past, in terms of investigation
and prosecutorial decision making?
No.
You said that you had only limited contact with the Post,
Office Legal team about the GLO. Given the importance
or significance of the GLO, why did you only have
limited contact with the Legal Team?
I think it goes back to what I described at the start
when I came into role, which was that the litigation and
Common Issues Judgment wasn't part of the initial
briefings that I'd had in terms of ~ called out as
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The Post Office Horizon IT Inquiry
something very specific. Those early weeks were about
trying to get to know and understand the business more
broadly, and so there were a multitude of different
priorities that were required in those first four to six
weeks, and I think I identified them in one of the
exhibits that I provide, which breaks down pretty
precisely what occurred in those four to six weeks in
terms of the breadth of stakeholders and business
understanding that was required.
But it was during that period that it became
apparent that we could and we should be looking to
settle with the GLO, and it was in October that those
conversations started to occur.
Who was it who presented private prosecutions to you as
an historic issue?
The legal function and the General Counsel, in
particular.
If you can name —
Yes, at that stage, it was - Ben Foat was the General
Counsel, he was leading on the work that we were doing
in that space. I think ~
Can you give us a flavour? You tell us in your witness
statement that you were told that "I did not need to dig
into the details of what had happened at the Post Office
in the past". Can you give us some flavour of what
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(Pause)
MR BEER: Is the screen back on?
A. Yes.
SIR WYN WILLIAMS: All right, let's resume, then.
MR BEER: I've been asked to ask you if you can move
forwards a little bit and just keep your voice up so
that the microphones catch you. Some people are finding
it slightly difficult to —
A. Ofcourse, is that better? Okay
Q. We were looking at pages 13 and 14, and if we scroll
down to paragraph 28, please, you describe, under this
cross-heading, your first six months as CEO. If we just
go over the page, please, you describe in this section,
paragraphs 28 to 31, the provision of the Horizon Issues
Judgment, under embargo at the end of November 2019 and
its handing down in mid-December 2019, and you tell us
that you do not recall there being serious concerns
amongst Post Office's senior leadership when this
happened —
A. That's correct.
Q._Does that mean in the Board or in the Executive, or
both?
‘A. Itmeans both, and I think the statement I made there,
“no urgent calls or panicked discussions", is exactly
what I meant.
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9 October 2024
Mr Foat was saying?
Yes, the reassurance that Mr Foat was trying to provide
was that this was historic action and activity, as
I say, that had ceased in 2015, had not been initiated
until 2013. We were now in 2019, and this is activity
that had ceased within the business.
Was it Mr Foat who told you that you did not need to dig
into the past?
Yes, that's correct.
Did you accept what he said?
Yes, I had no reason to believe, at that stage, that we
should be looking -- going back and looking pre-2015 and
2013. I think we were very, very focused on making sure
we made the right changes to address the issues that
emerged from the ClJ, as opposed to historically
re-examining elements of prosecutorial activity.
Thank you. If we can move forward to pages 13 and 14 of
your witness statement, please.
I think I've just done what Karen did yesterday, I have
a feeling. I'm not quite sure what that —-
SIR WYN WILLIAMS: So yesterday we needed to call on the
assistance of our IT man and we all just sat here
quietly, so let's do that?
THE WITNESS: So I'll sit here quietly?
SIR WYN WILLIAMS: Yes.
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Instead, the focus was on trading profits, reducing the
Government subsidy and investment in the Post Office?
A. That's correct
Q. Looking back, would you agree that this description is
of a leadership team in 2019 that was living in
something of a dream world, given the content of the
Horizon Issues Judgment?
A. I think it would be impossible not to conclude that.
Q._ You describe the leadership team having pride in their
work and their organisation, benign consultative and
friendly communications amongst themselves, but
essentially oblivious to the harm that their
predecessors, and in some cases they, had inflicted?
A. Yes, that's the point I was trying to make.
Q. There wasn't really any appreciation, would this be
right, of the seismic nature of both the Common Issues
Judgment and the Horizon Issues Judgment taken together?
A. Agreed
Q._ Instead the concerns were essentially those that had
occupied the Post Office for the past 20 years, namely:
how do we achieve financial stability?
A. Yes, I'm not sure for the past 20 years but there was
certainly a focus following Network Transformation and
the desire to reduce the Government subsidy to drive
trading profit, and to reduce cost, and that was very
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much the focus of the organisation.
Why was it, in your assessment, that the senior
leadership, including you, did not understand the true
implications of the Common Issues Judgment and the
Horizon Issues Judgment taken together?
I think we became more -- it became more apparent and we
became more aware, as the negotiation with the GLO took
place through November and December. I think that was
the trigger for me personally, given that I'd spent
a number of days working with Alan Bates and with others
on trying to get to a settlement. So I think it became,
as November rolled into December, something that the
organisation was getting to grips with. But I think it
would also be fair to say that, prior to that, the
business was very definitely focused on the objectives
that were put in front of it by the shareholder, which
was very much about reducing subsidy, about driving
profit, and reducing the overall necessity for the
Government to invest in Post Office.
Were you amongst those that did not personally
understand the seriousness of the judgments taken
together, and their implications, including for criminal
convictions?
I think I was, certainly in those first three months,
faced with a number of issues, certainly trying to get
25
Judgment on the past?
Yes, I think focusing on today's Post Office for
tomorrow was very much the objective of both the Board
and the Group Executive back in 2019.
Was that, what I've described as a "dream world”,
reflected in your meeting with Tim Parker that you had
in early September 20197
Yes, I think the first meeting I had with Tim was to try
and establish, as CEO to Chair, what the underlying
priorities he had for me, and I think as I exhibited in
my statement, the majority of that conversation was
centred around the priorities that I described a little
earlier. So I think that was fairly widely felt across.
the Board and obviously with Tim
I think you made some notes of that meeting, it was on
4 September 2019, on your mobile telephone after the
meeting; is that right?
That's correct.
Essentially as an aide memoire —-
Yes.
-- of what had happened. Then more recently, you cut
those telephone notes into an email which you sent to
your solicitor, which has been disclosed to us?
That's correct.
Can we look at those, please. POL00448897. We can
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to grips with a new organisation as a CEO, and
determining what was important what wasn't important,
and what were priorities and what weren't. I think,
secondly, the negotiation and the settlement was a huge
opportunity for me to get to grips with the implications
of the HlJ and the ClJ but that was done ~- that was
work that I did with the General Counsel, as opposed to
the broader Group Executive and the Board. So I think
there was more of a realisation, I think, from my
perspective, simply because I was in the room and part
of that team and, clearly, therefore, that wasn't as
widely felt across the organisation. It was from -- as
I say, from December onwards that we became much more
aware of what the implications were.
If we move forwards in your witness statement to
page 80, please. You say, one line from the top in
paragraph 144:
“I did not spend much time digging into the
technical details of the [Horizon Issues Judgment], as
I was more focused on the future, to achieve cultural
change and drive modernisation and commercial
improvement."
Was that a common approach amongst the General
Executive and the Board at that time, focus on the
future, rather than the impact of the Horizon Issues
26
ignore the stuff at the top because that's the sending
on to your solicitor, which explains how it got to us
and then we can see this is an email sent to you in
August this year. But, as you said, this is essentially
you cutting from your mobile telephone into an email the
content of the near contemporaneous note you made back
on 4 September 2019?
That's correct.
I just want to ask you about one passage, please, which
is I think the only reference to the litigation. If we
scroll down, please. Thank you. Can you see, i's now
about halfway down the page, just beyond halfway, it
says:
"Resolve the Post Office litigation situation
quickly ... and put it behind us and move on. Not the
huge [public relations] risk that BEIS believe it to
be."
Firstly, who is that a note of speaking?
That's the note of the comments that Tim made at the
dinner, which, I think as you ~ all the notes are ~ it
was his set of priorities for me and his commentary.
Was this, in addition to him speaking, an agreed
position between you and him?
Sorry, I don't quite understand the question.
Yes. Does this record what you agreed should occur,
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ie you should resolve the litigation quickly, put it
behind you and move on?
These are the actions and priorities that he suggested
that I would want to do and what he saw me doing.
Was that therefore something that you thereafter carried
into effect?
I guess this is the backdrop to the job that I was going
to take on. I sawit as an important meeting because it
was giving Tim the opportunity to give me his
perspective -- having been Chair for six years at this
stage, it was an opportunity for Tim to give me his
perspective on the business before I joined. So this
was some 10 or 12 days before I actually started, and it
was his opportunity to describe to me what he saw going
on in the organisation and where he saw ~- where he
thought I should spend my time.
So that was the contemporaneous notes that I took of
that meeting, which was my recollection of how he
described it to me.
Can you help us, not all of us move in the circles of
CEOs and chairmen: when a chairman says you're to
resolve the litigation quickly, put it behind us and
move on, is that an instruction that you carry into
effect or is it something which you think, "Well, the
old man is just spouting, 1" do what I want"?
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Government believed it to be?
That's correct
I think you, in due course, came to understand that what
is suggested here ~ resolution of the litigation
quickly, putting it behind you, and moving on — was
wrong headed. There was no way that the GLO could be
quickly resolved and put behind you, was there?
No.
Interestingly, it seems that the Government knew that.
Did you ever explore that view with the Government?
Yes, I go on to mention in my witness statement that
there seemed to be two sort of schools. I think Greg
Clark was the Secretary of State at the time. His view
was very much around finding and seeking resolution with
the postmasters and ensuring that there was redress, and
that was the prevailing view, certainly, that I was
given from officials, that Greg Clark had
It seemed to be less the case amongst officials, but
certainly from the politicians, if that makes sense.
What do you mean, less the case amongst officials?
What do I mean by that? There wasn't a determination to
settle, necessarily, with the postmasters. I didn't
feel that in those opening months within the business
and that seemed slightly at odds with the position that
Greg Clark was adopting,
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No, I think, as I was brand new to the organisation, it
was important for me to understand where he saw the
priorities. 1 mean, looking at the list, there are,
gosh, it looks like 12, 14, 16 issues that he has
highlighted here.
Yes.
And this is one of those, and, clearly, I would take
this information with me as a sort of aide memoire as
I go into the organisation. That was the purpose of the
meeting. I wanted to check my understanding of what he
had suggested with what I then found in those first four
to six weeks within the organisation. That was the
purpose, for me, of the meeting, rather than getting
a set of instructions; I didn't view this as a set of
instructions.
Did they come from the Board, instructions, rather than
the Chairman speaking at a dinner?
Well, technically, the Chairman would give me a set of
objectives formally, which is what he did on a yearly
basis. This wasn't that. This was a first meeting
Yes. It's recorded that "Not the huge PR risk that BEIS
believe it to be"; is that Mr Parker speaking too?
Yes, itis.
So he was saying that the litigation was not the huge
public relations risk to the Post Office that the
30
Was there a view, within the Post Office, at this time,
that the civil judgments did not really impact upon any
past criminal proceedings?
Can you describe that a bit more: what do you mean by
that?
Yes. Was it the view, within either the General
Executive or the Board or, in particular, the Legal
function within the Post Office that the civil
judgments, the Horizon Issues Judgment and the Common
Issues Judgment, did not impact on past criminal
proceedings?
Yes, I think that's the case.
Who was expressing that view?
Idon't think I can - it's a sense. I mean, I'm not
saying people were expressing that view explicitly.
I think that's just a sense that I took.
‘SIR WYN WILLIAMS: By this time, over some years
periodically, the Criminal Cases Review Commission had
been corresponding with the Post Office.
A. Yes.
‘SIR WYN WILLIAMS: Were you made aware of that in
September/October 20197
A. Yes, I would believe so. I'm trying to think explicitly
how and by whom. I think as I say, at the start the
level of briefing that I received was relatively
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perfunctory, as opposed to in-depth and critical, which
I think is the point that you're making. That was not
the case.
SIR WYN WILLIAMS: Well, I just wondered whether the
significance of there being correspondence with the
Criminal Cases Review Commission was explicitly, well,
explained to you?
A. Not in September, no.
SIR WYN WILLIAMS: Right. Fine.
MR BEER: Subsequently?
A. Subsequently later but not in September. I think this
is -- this would have been post-litigation and it would
have been well into 2020 before we had those
conversations.
Q._ Ultimately, the Court of Appeal Criminal Division
essentially accepted and adopted the findings of the
High Court that, throughout the relevant period, there
were significant problems with Horizon, which problems
gave rise to a material risk that an apparent shortfall
in branch accounts did not, in fact, reflect missing
cash or stock but had been caused by more than one bug,
error or defect in Horizon, and that the Post Office
knew that there were problems at that time with Horizon.
When was that first made clear to you, the
connection between what had been found in the civil
33
Chisholm, BEIS Permanent Secretary, was more closely
aligned with the Board priorities and was not pushing
for a settlement and to some extent did not see the need
to broker a new deal with postmasters. [He] wanted
a short independent 4-month review so we could move on
and I could focus on the day job of moving the Post
Office forward. His view was more closely aligned with
the Board around the need for speed towards financial
sustainability. This left a somewhat unclear agreement
as to which priorities took precedence.”
Firstly, what did you do in the face of an unclear
picture from your shareholder?
A. Well, I-- let me take a step back. I think - I met
with Alex Chisholm and spoke to him specifically about
the independent review, and I'm sure we'll come on to
talk about that in a second but the specifics, I think,
in the point that I was trying to make here was that
postmasters had been left behind in the pursuit of
profit. That I was very clear about, in terms of what
had happened in 2016 to 2019, with the drive for Network
Transformation and commercial sustainability and
reducing the subsidy.
In that drive, I believed that postmasters had been
left behind and, by that, I mean the move from fixed fee
payments to postmasters to variable payments to
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judgments and its impact upon criminal appeals?
Probably in September and October 2019, it became --
well, no, maybe that's not strictly true. I think it
may have been as a consequence of the release of the HiJ
findings in November. That, I think, triggered
conversations about the robustness of Horizon and the
implications for the Legacy and HNG-X versions of
Horizon and the implications of potential bugs and what
they may or may not have done. That was as
a consequence of the judgment that was handed down in
November.
In relation to the differences of view between the
politicians and the civil servants, can we look, please,
at what you say on page 20 of your witness statement, at
paragraph 44. You say:
"These variations in strategic focus were reflected
in the Minister and Permanent Secretary. Greg Clark,
the ... Minister when I arrived, was clear that we.
should focus on postmasters and afford redress arising
from the court judgment in 2019."
That's essentially what you said to us two or three
minutes ago.
Yes.
“He wanted to solve things for the postmasters and make
sure that the injustices were genuinely settled. Alex
34
postmasters, to the level of support that was given to
postmasters, was not where it needed to be and it was my
intention to refocus the organisation around what I saw
as the central core to the Post Office, which was the
relationship between the postmaster and its local
communities and that's how we had to - and we had to
focus upon it.
That was slightly at odds, I think, with where the
officials were, which was very much around trying to
ensure that we didn't continue to spend money on the
Post Office and that we could reduce, as I say, the
subsidy and the like. And I think there was an attitude
that was very much around trying to ring-fence and
ensure that the Post Office was a stand alone business
without really thinking through what the implications of
that were for post masters, a new deal, understanding how
variable pay worked, what sort of support they would be
provided with, and it was that juxtaposition that I was
struggling to address.
‘As well as the approach to be taken to the GLO, there
was also the issue, is this right, of to what extent.
there should be an investigation or an Inquiry into the
past?
Yes.
Can we look, please, at pages 27 to 28 of your witness
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statement, paragraph 61, second line. You say:
“As mentioned, Permanent Secretary Alex Chisholm had
initially wanted this just to be a review, not
an inquiry and that it should be whilst independent,
essentially internal and importantly be forward looking.
That had been the plan from February 2020 when the Prime
Minister announced the review would look at historical
failings. Later in 2020 when the Minister announced the
Inquiry, it was truly a pivotal moment for the
organisation as a whole to fully grapple with the
process that it needed to go through and the changes
required.”
Paragraph 62:
“By summer it had developed into a judge-led
independent inquiry which was only meant to last.
4 months. This was reformulated into the Terms of
Reference that currently apply in January 2021."
So is it right that, in this earlier period,
Mr Chisholm continued to think that the problems exposed
by the Group Litigation could be addressed by a small,
internal inquiry?
Yes, that's precisely the point I was making
Was he of the view that we saw expressed in your note of
your dinner with Mr Parker: that the Post Office had
a significant PR disaster on its hands?
37
review to ensure that the Post Office was now in
a position where nothing like this could happen again.
Thank you. That can come down.
Can I turn to a different topic, namely the culture
within the Post Office in your five years as CEO and, in
particular, its attitude towards the guilt or innocence
of subpostmasters.
As a general question, have you come across
individuals within the organisation who adopt the view
that some subpostmasters whose convictions have been
quashed are nonetheless guilty?
I don't think I could say specifically that that is the
case but there will be a view that not every quashed
conviction will be innocent postmasters. I think -- and
certainly, if I was to reflect, I think the majority of
the organisation would agree that the action that has
been taken is absolutely the right action and whether
there are guilty postmasters who will be exonerated
really is no longer an issue. That is not something
that is of concer to people in the Post Office.
Can we tum, please, to paragraph 27 of your first
witness statement, please, which is on page 13. You
say:
“Post Office is in many ways a different
organisation to the Post Office of the past.”
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1 can't comment on what his view on that was.
Did he ever explain to you whether a view of the extent
of the wrongdoing had influenced his decision or
suggestion that there should be a short, internal
inquiry to essentially manage away the problem?
The conversations I had with Mr Chisholm on this
particular topic, I had become very clear by early 2020
that there was a growing need and desire amongst those
who had been impacted by the scandal to get to the
truth, to understand what had happened, why it had
happened and who was responsible, as opposed to the
notion that we have an inquiry to make sure nothing like
this could happen again.
I think this was ~ the point I'm trying to make
here is that there was a clear distinction that ~ and
the conversation I had with Mr Chisholm, was that
closure would not be achieved if we simply looked
forward to see what had been done by the Post Office to
ensure nothing could happen again, rather than
addressing what it was that the victims of the scandal
particularly wanted, which was to understand why it had
happened, who was responsible, and what was going to be
done as a consequence of that.
it was that that I struggled with, and Mr Chisholm
assured me that we would do a four-month forward-looking
38
Yes?
Yes.
1am underlining the words “of the past” at the moment.
Yes.
Then similarly, in this witness statement, at
paragraph 174, which is on page 84, you say:
"Post Office recognises the need for fundamental
cultural change. It recognises the presence of
oppressive behaviour and intimidating actions in the
past [and it's those words that I'm underlining] which
led to a lack of respect and trust between Post Office
and its postmasters. It acknowledges that there has
been a lack of effective leadership; a lack of effective
training and support; and a lack of responsibility
within the organisation. It accepts that it has work to
do to restore trust with postmasters and with the public
as a whole. Cultural changes in the Post Office are
integral to the rebuilding of that trust.”
if those sentiments are correct, why is it that
those who were involved in the investigation and
prosecution -- the wrongful prosecution -- of
subpostmasters are some of the same personnel who are
involved in the handling of compensation claims under
the Horizon Shortfall Scheme, which includes their
attendance with subpostmasters at good-faith meetings?
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I've been very clear that at no stage will we walk past
allegations of wrongdoing in the organisation, and I've
made that very clear publicly to all colleagues and to
postmasters themselves. Where evidence of wrongdoing is
brought to my attention or indeed to anybody else's
attention within the organisation, we will investigate
and we will take action fully, and that's very much what
we will do.
With regard to the Remediation Unit, I am very clear
that we have conducted a piece of work which you've
heard a lot about at this Inquiry, which is referred to
as the Past Roles piece of work, and once again, I am
confident that there are not individuals involved in
postmaster-facing activity that had roles in the past
where allegations or anything of wrongdoing has been
brought to my attention.
When you say “there are not", you mean as we sit here
today?
Yes, we have -
Can you say that there have not?
What, that have not been individuals in those units?
Yes.
As you'll be aware from the last couple of days, we have
individuals who are under investigation specifically.
I'm not convinced it would be appropriate to raise
41
place in the delivery of any form of compensation, and
that is absolutely what we are doing and are determined
to do.
Have part of the investigations that have been conducted
included the question of whether investigators were
given bonuses related to the number of successful
prosecutions they conducted and/or the recovery of money
under the Proceeds of Crime Act?
I'm not aware that we've done a specific piece of work
into that allegation but I may be mistaken. I don't
believe we have.
Can we look, please, at POL00113304. This, before we
get into the detail of it, is an email change that takes
place between May and July 2021, started by a man called
Gary Thomas, a former Post Office Investigator,
addressed in the first instance to you, in which he is
complaining about the Post Office's ill treatment of its
own investigators and security managers. If we can read
it first as a whole and then I'l ask some questions
about it.
This is a standalone email, is it?
No, we'll look at the whole chain.
Oh, we'll look at the chain.
So if we go to page 5 to see where it picks up, please.
If we just go up, please. Keep going. Essentially, he
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those —
I'm not asking you to name them at all.
Thank you. So I guess the point I'm trying to make is
that we're not walking past these situations and we will
address them where those allegations are made, and
ensure that law enforcement and other activity takes
place,
But we're five years on now from the Horizon Issues
Judgment, aren't we?
We are.
So you can't say that there have not been individuals
who were involved in the improper investigation and the
wrongful prosecution of postmasters who were involved in
the handling of compensation scheme claims under in the
HSS?
Involved —- it depends what you mean by involved
I guess certainly from my perspective, when I look at
the construct of the Remediation Unit and the work that
we've done on Past Roles and on Project Phoenix, I would
absolutely concede that that work has not gone quickly
enough. I would absolutely concede that we needed to be
more forthright, I think, in our actions. By that,
I mean giving confidence to post masters who were coming
forward in the HSS scheme or involved in the HSS scheme
that genuine independence and no sign of bias was taking
42
cuts into an email earlier emails that he suggests were
sent. If we just go down to page 5, please.
This is seemingly an email addressed to you and he
says he is writing in relation to all the Horizon system
prosecutions that were conducted by Post Office against
postmasters that have been successfully challenged and
won in the High Court.
His question to you and the new Board is the actual
effect this whole situation has had on himself and the
other investigators employed by Post Office:
“We were informed by Post Office that the Horizon
system was 100% correct and that the Horizon Data we
obtained to provide evidence was all accurate and again
100% correct.”
If we skip that paragraph and then the next
paragraph, pick up with "I took redundancy", he says:
“I took redundancy from Post Office in 2017 after
32 years loyal and committed service and now have to
live with all this every day as do my other Security
colleagues I have recently spoken [to]."
Then this:
"We even had a proceeds of crime unit within the
Post Office that ensured that some of these individuals
lost their homes and families.”
Then this:
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“In fact my yearly objectives that were bonus worthy
at the time were based on numbers of successful
prosecutions and recovery amounts of money to the
business. I had some instances of these postmasters
committing suicide, which now sits somewhat on my
[I think that's 'conscience’] because of my employer.
How do you think I deal with this and now actually sleep
at night now knowing my actions that were backed and
supported by my employer has affected the said
postmasters ...”
So a suggestion that yearly objectives of
an investigator, which were bonus worthy, included the
number of successful prosecutions and the recovery of
money to the business. You see that?
Yes, I can see that.
Then if we go up to page 4, please. If we scroll down,
please. This was the reply, if we scroll down a little
further. He's actually cut off who the reply was from.
This is said to be the Post Office's reply.
“Lam writing on behalf of Post Office to thank you
and respond to your email to Nick Read dated 9 May ...”
That's where I got the first date from -—
Yes.
--May 2021:
"We are working hard to improve Post Office, address
45
for Prosecutions and Financial Recovery Targets. The
recoveries, if not voluntary, were carried out under the
Proceeds of Crime Act where I know the Security Team
paid to train at least 3 or 4 of my colleagues to carry
out such work. This meant if it was proven that the
prosecuted postmaster was found guilty or admitted any
guilt they could make serious recoveries over and above
the amounts found to be missing under the Benefits of
Crime Act, including some postmasters life savings and
homes."
Then page 2, please. Thank you. We now actually
get an email from Stuart Lill, we scroll down,
please. You'll see he signs that off.
If we go back up please. We'll see that this isn't
a reply to Mr Thomas’ email; it's distributed amongst
those within the business, including people with whom we
are familiar: Rodric Williams, Melanie Corfield and Nick
Vamos. This is headed, "Former investigator email to
Nick Read update". Below is the response from —
Sorry, before I read it, are any of those people in
the distribution list part of your General Executive
correspondence team or anything similar, PA staff —
Yes.
Can you identify that person?
Avene was my PA at the time.
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the past and fundamentally reform for the future by
putting Post masters at the heart of everything we do.
Your email has drawn our attention to the prospect that
Post Office employees may have been incentivised to
bring successful prosecutions. We have not currently
identified this to be the case, however, we have
instructed our lawyers to find, recover and review
relevant material as part of our Post Conviction
Disclosure Exercise (‘PCDE"). It is the PCDE that has
assisted those prosecuted by Post Office to have their
convictions rightly overturned. The review of this
material will allow Post Office to recognise and, if
necessary, address this issue as part of our wider duty
to those who were convicted ..."
If we go to page 3, please. This is Mr Thomas’
reply. If we scroll down, please, and scroll down.
We're just missing the paragraph I'm looking for. If we
scroll back up, please. Ah, stop.
In that fourth paragraph, beginning "I will advise",
he says:
“L will advise you now to save you more time that
you will find nothing in any ‘PCDE" about any incentives
for prosecutions but if you still hold historical HR
records on Individuals -- Personal & Business Objectives
each year then I can assure you you will see the targets
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So you're included on this distribution list by the
inclusion of her as a recipient; is that right?
That's not normally how it works. I would normally be
put in the "To" or "CC" box if it was designed to come
to me but it does seem strange that it's been directed
to her and not to me.
‘So what would Ms Regan do if she received an email such
as this?
Well, I sincerely hope she would share it with me.
So this is essentially for your attention as a person to
whom the email was addressed, albeit by a circuitous
distribution route?
You would assume it was directed for me, yes. I'm not
familiar with it —
Anyway ~
~ but yeah
I interrupted myself. Belowis the response from Gary
Thomas who raised issues about the performance targets
given to former Post Office Investigators and then he,
Stuart, has included the email chain:
“This email is difficult to respond to for the
following reasons."
Then under 2:
“There is a new allegation that [Post Office] were
benefiting more than they were entitled to from the
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“Benefits of Crime Act’ (presumably [the Proceeds of
Crime Act});
"3, It makes allegations as to the knowledge about
Horizon’s failings by senior [Post Office] officials ...
“Whilst Mr Thomas does not say it expressly in
either of his emails, this appears to be an attempt to
negotiate a payment by [Post Office], otherwise there is,
little need to raise or threaten speaking to
a solicitor. Further allegations are made, although
[Peters & Peters] will note that he has narrowed and
clarified his previous point regarding objectives —
this may be capable of narrowing the current proposed
review.
“It seems to me that this email conversation needs
to be closed down as [Post Office] are unlikely to be
able to address the issues/allegations he makes either
for proper, sensible legal reasons or because Mr Thomas
appears to be using it as a forerunner to seek legal
advice ...
“... grateful for input ..."
Then if we go to page 1, the same distribution list,
I think, again, from Mr Lill:
“[Post Office] has no employment obligations to
Mr Thomas
“With regards to the whistleblowing policy, this can
49
So that's the chain of correspondence.
Given the addressee, your PA, Ms Regan, were you
aware of this correspondence with Mr Thomas?
No, I have no recollection of this correspondence.
Were you aware of the suggestion that it was said that
Post Office Investigators and/or Security Managers had
yearly bonus objectives based on the number of
successful prosecutions that they undertook?
I think my understanding of that came from the Inquiry,
as opposed to from individuals within the Post Office
perse. I think it's an allegation that's certainly
been made in this forum, as opposed to more broadly at
the Post Office
What about the suggestion that there were yearly bonus
objectives based on the amounts recovered for the Post
Office?
I guess my immediate reaction to this is the lack of
curiosity to understand whether that is the case. I
That's where I'm heading, Mr Read.
Yeah, I'm surprised that the tone of the response is
“Let's just close this down", as opposed to where is the
curiosity that says that this is something that was
going on? I think it would have been extremely
illuminating, culturally, to understand if that had been
the case.
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catch and so [Peters & Peters] will/are drafting
a proposal regarding investigating and responding to it.
This is in order to ensure that we uphold our own policy
and we can demonstrate that we have dealt with the issue
if it were to be raised at the Inquiry or elsewhere.
... [have drafted the response ... for
consideration and comment.”
If we scroll down:
“Thank you for your email..."
Second paragraph
"... reiterate its sincerest apologies for any
negative attention you or your former colleagues have
received as a result of your time at Post Office.”
Then this, which is the substance of the reply:
“It is not appropriate for Post Office to comment on
the general matters you raise at this time. As you will
be aware, Post Office is involved in ongoing legal
proceedings and is actively supporting and contributing
to the statutory Inquiry led by Sir Wyn Williams.
"You have stated that you will wait until Post
Office has addressed your questions and points before
seeking the advice of your solicitor. Whilst it is not
clear which specific matters you are referring to or why
it requires advice from a solicitor, itis... a matter
for you ..."
50
Q._ I think it follows that you weren't aware of the
suggestion that prosecution targets and financial
recovery targets might be found in Post Office's
historical HR records under personal and business
objectives?
‘A. No, wasn't and, as far as I'm aware, that hasn't been
explored. I may be mistaken but I don't believe it to
be the case.
SIR WYN WILLIAMS: One of the parties receiving this email
chain was Mr Declan Salter.
A. Yes.
SIR WYN WILLIAMS: From memory, when I first became involved
in this, he had an important position, did he not, in
the Post Office?
A. Yes, he did
SIR WYN WILLIAMS: Can you make that public, please?
A. Yes, he did, sir. Declan Salter was in charge of the
Inquiry Team and the Remediation Unit, which was
combined at that early stage, so he came in to do that
piece of work.
MR BEER: We scroll back down, please, to the distribution
list, at the top of page 2, he's the first addressee.
I think we know the functions that Mr Williams and
Ms Corfield were performing at this time. Can you help
us with Hannah Laming?
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Again, no. I'm not familiar with Hannah Laming
oP
The generic email address “flagcaseadvisor’. I think
we've seen that before?
No, it's not one that I'm familiar with.
Thomas Jennings?
No, again, not a name I'm familiar with:
Catherine Emanuel?
Yes, she is from Herbert Smith Freehills.
Andrew Robinson?
No, I'm not familiar with that name.
Tim Perkins?
Yes, Tim works in the organisation. Tim is currently
the People Services Director.
At this time in 20217
I am guessing he was working for Declan but I could be
Pe
mistaken. Alternatively, he may well, actually, on.
reflection, have worked in the Operations Team, Retail
Operations.
Q._ Eamon McCarthy-Keen?
No, that's not a name I'm familiar with
>
Q._ Some of these people, including Ms Laming, for example,
might be lawyers within, for example, Peters & Peters —
A. Right.
Q. --which may be why you're not familiar with them,
I think it follows, at least from this chain, that you
53
(11.52 am)
MR BEER: Mr Read, can I continue to seek to explore the
topic of Post Office's attitude and approach to
subpostmasters who have a shortfall alleged against them
or a shortfall is detected, including those who, in the
past, had been convicted of criminal offences on the
basis of such shortfalls being alleged, and look at the
issue of Mr Jacobs, Elliot Jacobs.
In your third witness statement -- there's no need
to turn it up, it's paragraphs 237 to 239 — you refer
to the Post Office's investigation concerning Elliot
Jacobs, and I think this was known as Project Venus; is
that right?
A. That's correct.
Q._You tell us about a conversation on 10 January between
Mr Staunton, Mr Jacobs and Mr Ismail, when they raise
concems about the Post Office's treatment of
subpostmasters.
A. Yes.
Q._ We're going to look at that in a moment.
Can I look at something that happened before then in
November 2023. POLO0448693. This is an email to you
from Mr Staunton of 25 November 2023, and I think it's
just to you. He says:
“Nick,
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didn't reply, "Hold on, I disagree with the suggestion
made by Stuart Lill that this conversation with
Mr Thomas needs to be closed down"?
A. I'm not familiar -- I'm not familiar with this exchange.
It may be that I did see it but I don't recall.
Q. Was this correspondence emblematic of a view within Post
Office, even at July 2021, that people that raised
issues as to the past and the past conduct of
investigations and prosecutions ought to be closed down?
‘A. No, I don't believe that to be the case.
Q._ This is unusual, then; this goes against the grain?
A. Yes, I think that certainly by 2021, the Hamilton
judgment would have been alive already by then. I think
the business, by this stage, was coming to terms with
the past. I don't think that was something, as
I mentioned at the start, that was necessarily the case
in 2019/2020 but I think it clearly was coming to terms
with the role of - that it had played in the past. So
lam surprised, yes.
MRBEER: Sir, I'm about to move within a topic to another
subtopic. Might we take morning break until 11.50?
SIR WYN WILLIAMS: Yes. Certainly.
MR BEER: Thank you very much.
(11.35 am)
(A short break)
54
"I drove home yesterday and had to deal with
a number of calls from both Saf and Elliot.”
So that's Saf Ismail and Elliot Jacobs:
“L will not repeat some of their comments but I am
annoyed that this has blown up. They think that Ben is
stirring this thing up even though it has been
investigated ..."
Just stopping there, the thing that's being spoken
about here, would you agree, is the investigation into
an alleged shortfall at Mr Jacobs’ branch?
A. That's correct.
Q. “... found the differences to be de minimis and well
within differences that may arise on a trading account
running to under £1 million per annum. It has been
looked at by a subcommittee of Loma and Amanda
"There were comments about the ‘old [Post Office)’,
things have not changed that much, [Post Office]
management think all [postmasters] are crooks etc, their
personal integrity is being questioned etc, etc,
I suggested they talk to Tom regarding the proposed note
in the ARA (of which they are unaware) who helped in his
replies for which I am grateful. Kathryn says she only
found out about this a day ago but then thought she
would ‘brief all the Directors a day later -- without
the full facts. Anyway I have suggested we hold off
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until you and I chat.
“{ needed to spend hours yesterday on this like
a hole in the head. What is behind this? Am I missing
something’, et cetera.
The suggestion, seemingly made by Messrs Ismail and
Jacobs, about the “old Post Office" and Post Office
Management currently thinking that postmasters are “all
crooks", is that a view that has been expressed by them
to you?
I don't think before or around the time of this email,
I think that's something that has happened subsequently,
I think both of them gave evidence to that effect: that
they had raised that in a Board conversation, I recall
How did you react to those suggestions that were being
made in this email to you? Essentially, if I summarise,
the two Postmaster Non-Executive Directors were
suggesting to the Chairman that Post Office Management
think that all postmasters are crooks.
I think I'd probably try and separate two elements to
this email. I think (1) is the potential investigation
into Saf and Elliot and (2) is this notion that all
management think they're crooks. I certainly don't
think all management are of that opinion, in fact
I absolutely don't think that at all
On the topic of this particular situation, and
57
the sense that there was a larger shortfall that was on
the account but, actually, once investigations had been
done, once the teams had worked, once the operational
team had worked with Elliot and his teams, we concluded
that, actually, the shortfall was around 16,000. So
yes.
I mean, if we just look over the page to see an email
addressed to Ben Foat and Kathryn Sheratt from
Mr Staunton, he summarises it in the second paragraph,
second sentence:
“A lengthy investigation found that Elliot owed
under £15,000 built up over 6 to 10 years. Bearing in
mind that about £1 million a year is transacted ... they
believe that the amount is de minimis."
Why do you say that the investigation into this
postmaster NED was heavy-handed?
I think certainly looking at the approach that was
recommended and suggested, which was originally to do
unannounced visits to Elliot's branches, I think you
will have seen emails to that effect, in order to try
and establish what the current loss was, was
an extraordinary ~ an extraordinary recommendation by
the team.
I think, as Elliot has rightly pointed out, a more
sensible and more balanced approach would have been to
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I think it’s perhaps quite important to talk a little
bit more about the context of this investigation, if
that's okay, the allegations that were sort of put tome
around Elliot Jacobs’ situation, in terms of his
liability to the business, was something that I passed
to the Company Secretary and the Chairman — which is
why Henry Staunton is obviously discussing it now -- for
them to decide what the best course of action should be,
and that, I think, is important context, as a Board
Director himself, Elliot, it was important that the
Chairman was overseeing this activity
I think it’s fair to say that the approach was
heavy-handed, I think I would say that, to Project
Venus. I think it was ~
Sorry, to stop you there, I think the suggestion was
that over a six to ten-year period the suggestion was
some £15,000 of debt had been built up on a business
that was trading at about £1 million a year and that's
why it was thought to be de minimis; is that right?
Not quite. I think the liabilities were 198,000, to my
recollection. The settlement, which ultimately was done
by ~ or agreed with Mel Park and her team in the
operations, was that identifying loss, for want of
a better word, that should be repaid, was some 16,000 as
is mentioned here. So I think it's slightly nuanced, in
58
‘employ members of the Operations Team to look into it in
a joint way with Elliot and that, I think, would have
been a more effective and more efficient way of doing
it.
The reason I say it's heavy-handed is that, clearly,
there was an issue with how this was going to be
recorded in the report and accounts. Clearly, there was
an issue with the volume and alleged volume of
shortfall, and I think it would be fair to say the sort
of over-enthusiastic investigative approach was
heavy-handed and that there were other ways that this
could have been addressed.
Going back to page 1, please. Second sentence in first
paragraph:
"They [that's Messrs Ismail and Jacobs] think that
Ben [that's Mr Foal! is stirring things up even though
it has been investigated’, et cetera.
What did you understand to be the suggestion against
Mr Foat?
I think -- I mean, I think this goes back to the fact
that the Investigation Team sits within Ben Foat's area
of responsibility. They work to him, as the General
Counsel, and I think, therefore, by association, they
were assuming that was the determinant of the
investigation, the manner of the investigation and the
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activity that occurred as a consequence.
SIR WYN WILLIAMS: I'm sorry, I'm a bit unsure that you're
actually addressing the point that Mr Beer is trying to
get at. Can I just remind you that the evidence,
I think, from both Mr Staunton and Mr Elliot (sic) was
that the investigation had taken place in April, then
there'd been what Mr Elliot (sic) described as a series
of meetings, which were "business meetings" which
resolved the issue.
A. Yes.
SIR WYN WILLIAMS: His complaint thereafter, as I'd
understood it, to the Inquiry, was that the
Investigative Department and Mr Foat in particular had
taken a long time to actually formally close the
investigation.
Now, it seems to me that this all happening in
November 2023 is some kind of complaint about Mr Foat
still pursuing an investigation, if you see what I mean.
Or that’s how it reads if you put it into the context
that I've just described, which I think is an accurate
summary of Mr Elliot (sic) and Mr Staunton's evidence.
A. itis.
SIR WYN WILLIAMS: So do you know what was going on in
November 2023, which caused this to resurrect itself, so
to speak?
61
please. This is a note sent by Mr Staunton to himself
by way of contemporaneous note of a conversation that he
had four days previously on 10 January 2014. The note
is dated 14 January 2014. I'll read it:
"Saf said the views expressed by Richard Taylor, and
previously by management and even members of the Board,
still persisted ~- that those [post masters] who had not
come forward to be exonerated were ‘guilty as charged’
Itis a view deep in the culture of the organisation
({including} at board level) including that postmasters
are not to be trusted. SOMETHING NEEDS TO BE DONE.”
“Martin Roberts and certain members of his team were
singled out. There has been no feedback on the
investigation into Mr Roberts ({including] for
inappropriate behaviour and lack of integrity). He was
responsible for the postage stamps debacle where changes
were made to accounts by his team just like Fujitsu. If
Elliot had not been on ARC the controls would not have
been strengthened. Roberts and his team do not want any
extension to their terms of office as they believe new
[postmasters] would not have the experience to challenge
them."
Scroll down:
“Equally Saf and Elliot are FED UP WITH THE AMOUNT
OF POWER WIELDED BY FOAT. He and other members of the
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A. So not specifically. I'm assuming, because Kathryn
Sheratt was engaged in this process, it had to do with
what director liabilities to the company were going to
be put into the report and accounts, and if the
investigation hadn't been formally closed down, which by
the sounds of things it hadn't, in terms of
specifically, that was the ~- giving rise to some
concer. I think you're quite right that a seven-month
investigation into some alleged shortfalls seems.
an inordinate length of time and I think that's
absolutely the case, and I think that -- well, I know
that the Investigations Team would recognise that that
was the case.
So, yes, I think there is some disappointment,
certainly on behalf of Elliot, and I heard what he said
two weeks ago, that the Retail Team were business-like
and confident in the way that they engaged with him to
resolve the issue, and it would have been far easier to
have done it that way than to have had something more
formal than what is obviously -- or obviously took
place.
MR BEER: Can we move forwards, please, to January 2024 —-
this was in November 2023 -- again, in relation to views
expressed by your Subpostmaster Non-Executive Directors.
By looking at POL00448302. If we can look at page 4,
62
senior team act as if [POSTMASTERS] ARE GUILTY UNTIL
PROVED INNOCENT (‘as per my experience’ they both said).
‘No one believes us' is a constant refrain from
[Postmasters]. WHILST FOAT IS AT THE HELM NOTHING WILL
CHANGE. we must also part company with all those
investigators who behaved so terribly with
[postmasters]. What on earth is happening if Steve
Bradshaw is still with us — his performance at the
Inquiry was a disgrace and reflected terribly on Post
Office. Foat uses his leadership of the Inquiry Team as
an instrument of his power --it all has to stop. The
[postmaster] ‘is not the enemy’. ‘Only [postmasters]
can solve this’ and tell us how to change. JB is
an ex-policeman. His behaviour has been unacceptable
and he needs to move on to prove we have changed.”
Then skipping a paragraph.
“There are some 48 people involved in
investigations. There are over 40 just like Bradshaw.
These people need to go. Project Phoenix was allowed by
Foat to go into the long grass. Bradshaw went into one
of Saf's stores some years go and immediately said ‘we
are closing you down’. [Postmasters] tell him not much
has changed since. There is a complete lack of respect
for [postmasters] and that has to change."
If we just scroll to the bottom, I don't think there
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is anything else that's relevant. He ends with this:
“A lot in this note to consider and take forward
with the Board.”
The reference to 40 people who are just like
Mr Bradshaw, investigators, have you ever referred to
such people as the "untouchables"?
No I haven't.
Mr Staunton ~- no need to turn it up ~ WITN11410100, at
paragraph 107 and on 1 October, when he gave evidence to
us, page 109, line 7, states that you used the term to
him, both privately and in a meeting; is he incorrect?
He is incorrect.
Mr Ismail says that you used the term “untouchables” to
refer to some individuals within Post Office in two.
contexts: in a private NED-only meeting and in a Board
meeting; is he incorrect?
He is.
Mr Jacobs said that you used the term in the context of
a NED-only meeting; is he incorrect?
Yes, he is.
Are you familiar with the term?
Well, 've obviously seen a lot of it in the media, seen
a lot of it in the press. Obviously, it has occurred in
this forum as well. I think there's a lot of conflation
between what has been described. There's this notion
65
email was in circulation. I think you'll be familiar
with how that occurred. Just to sort of take you back
to the mechanics of this, this was an email that,
emerged, I think, on a Sunday night, inadvertently sent
to me by Henry Staunton. I sent it on inadvertently,
given that there was no identification in the subject
matter box of the email or, indeed, any confidentiality
associated with it, inadvertently sent it on to
colleagues in order to help me write a response to the
Voice of the Postmaster Group, which is what Henry had
asked me to do.
We're just going to come to that in a moment.
Oh, okay.
But just on the "I inadvertently disclosed to
colleagues", you disclosed it on to Mr Roberts and
Mr Foat —
That's correct, yes.
-- who were the targets of the allegations.
That is correct, yes. At 8.00 the following morning,
I dropped an email to Saf and Elliot saying I was very
sorry that the situation had occurred, it had been
completely inadvertent in terms of a mistake on my part
and that I'd be happy to speak with him. I recommended
that we have a Teams call, the three of us in that
email. Saf was unable to join it so I therefore had
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that there are 40 untouchables who are Investigators
from the past. That is not an expression that is used
in the organisation. That is not an expression that is
familiar to the organisation.
I also discovered, two weeks ago, as part of the
disclosure exercise, that there was an investigation
conducted by Andrew Darfoor into the comments that
I made at the Select Committee, and this was obviously
one of the areas of investigation and, as I discovered
two weeks ago, I was unfamiliar that an investigation
had been conducted, but it was and it was found that
that was not the case, that this is not an expression
that is used more widely in the organisation, that this
is not an expression that I have used, 40 Investigators,
or 40 untouchables. So I can say with some confidence
that this idea of 40 untouchables is not something that
is widely used in the organisation.
In any event, given that Phase 4 of the Inquiry was
‘ongoing at the time of the conversation that this note
refers to in January 2024, were you concerned by these
reports from Mr Ismail and Mr Elliot (sic)?
As in the commentary that he’s written here? Of course.
Very, very concemed
What action did you take?
This obviously occurred at the time that the pineapple
66
a call with Elliot to apologise, and I didn't have
a chance to speak to Saf until the following week, which
is when we had a Board meeting, and so it did go
unanswered.
As to the substance of what was said, rather than that
difficult handling issue that followed, what did you do?
I spoke with both Mr Roberts and with Mr Foat, about the
allegations that had been made. Clearly, it was quite
a difficult conversation because, clearly, it had been
released to them both and they were angry and upset
about the fact that they had -- this had come to light
and, more importantly, they were angry and upset that
Saf and Elliot had that view of them. So it was
a difficult conversation
But, again, certainly from my perspective, the
challenge, I think, for Ben in particular, was the
management of the Investigations Unit and how we were
deploying it, and I think it is important to make a very
clear distinction between investigations work at the
Post Office now and how they worked historically. If
you'd like me to just describe that --
I think we'll come on to that in probably a passage in
this afternoon's questioning,
AL Okay.
25 Q. But this suggested that Mr Foat had allowed Project
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Phoenix to "go into the long grass". What was done as
a result of that suggestion?
Just going on to Project Phoenix very explicitly, this
is a source of some frustration in the sense that we
haven't moved quickly enough, and I know that the
Inquiry has seen emails to that effect. I certainly
have been and was keener that we were more forthright in
terms of how we addressed individuals who would be in
a potential position of postmaster-facing activity,
either those who were involved specifically, or those
who weren't.
But Project Phoenix, just to remind everybody, is
formed of two very, very distinct parts. The first part
is it's individuals who were named during the Human
Impact Hearings, and it's also individuals who may have
been involved in activity that resulted in the
prosecution of postmasters; and, secondly, it was as
a consequence of the restorative justice meetings that
myself and Simon Recaldin, and subsequently others, have
taken part in over the last 18 months or so.
The combination of which is we obviously heard about
individuals during those restorative justice meetings,
and clearly needed to investigate the allegations that
had been made to us by the victims, and that's clearly
what Project Phoenix is about. There are 47 particular
69
us understand precisely what had happened. That could
be recordings, that could be records of interviews,
there's a number of different things that we looked to
do but it was frustrating. Yes.
Just stopping you there, just to make sure I haven't
misunderstood your answer.
Yes.
You said a couple of times that you looked for
corroborating evidence, which may have a special magic
for some lawyers. In order to find a case to answer,
are you saying that there had to be something additional
to that which the postmaster said, ie some independent
evidence coming from somebody other than the postmaster?
Well, I think the recordings, as an example, and the
records of the meetings, would be obviously areas that
we would be looking at to try and understand whether or
not the allegations that had been made, you know, could
stand up.
So you weren't literally meaning corroborating evidence?
No, what I meant was supporting evidence I guess, fully
investigating each of the allegations that had arisen,
and that, as I say, involved specifically speaking with
those victims who had come forward and I am certainly of
the opinion that that took quite a long time to
organise, quite a lot of time to bring together, but too
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case studies that have emerged through the Human Impact
Hearings and through the restorative justice meetings,
and we have distilled those down to six individuals,
three of whom have been -- three of whom have no case to
answer. The allegations, we haven't found corroborating
evidence for.
We've looked through, I believe, 130,000 different
documents. We've interviewed many of the people who
I spoke to at the restorative justice meeting and,
indeed, who were at the Human Impact Hearings, to see if
we can find and understand what occurred. Three
individuals, however, are now under further
investigation, both by the Post Office and by external
agencies.
So would it have been, and do I wish that we could
have moved more quickly with Project Phoenix? Yes,
Ido. So I have sympathy with Elliot and Saf's view.
I think
What was the cause of the pace —
Primarily because we needed to speak to individuals who
had been involved ~ who had made these allegations,
I think and then obviously trying to find corroborating
evidence and, as you've heard in this Inquiry, that's
not often easy at Post Office, to get the right data and
the right disclosure and the right information to help
70
slow. And I think perhaps, if I took a step back,
I would say that the Investigations Unit specifically is
pretty overwhelmed with activity at the moment, and that
may well have been a reason why the pace was slower than
we would have hoped
Can we tum to what we just discussed, then, namely the
handling of the email, by looking at POL00448564. And
tum to page 3, please.
We should briefly just look at page 4, just so we
can see what was included, and just the bottom of
page 3. Thank you.
An email to Mr Staunton copied to Mr Ismail and
Mr Jacobs, containing a suggested email to the Board,
and then the suggested email includes in its second
paragraph:
"... please see attached a file note I prepared
following my conversation with Saf and Elliot on Sunday
That's their file note we just looked at, yes?
Understood, yes.
If we then go to page 3, please. Mr Staunton, by these
emails, essentially provided that Project Pineapple note
to you on 17 January; is that right?
Yes, that's correct.
Then if we go to page 2, please, and scroll down,
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please. This is the email that you were referring to,
I think, a moment ago, Mr Read - is that right —
Yes, that's correct.
--where you send the chain on, including the
filenote —
That is correct.
-- to Martin Roberts and Ben Foat, saying:
"... can you produce a suitable response for Henry.
“You will be aware of my views from discussions we
have had ...
“I assume there are GFA restrictions too?"
What does that refer to?
The grant funding agreement with the NFSP.
If we scroll up, please. Stop there. This Mr Foat's
reply, second paragraph:
“The Project Pineapple email contained very serious
allegations of which I have not been made aware. Given
the circumstances, I would be conflicted.”
Scroll up, please. Mr Roberts’ reply:
“Having read [the email] below I am in the same
place not knowing what Project Pineapple is and having
never been made aware of the allegations made against me
and my team.
“L... feel conflicted
You tell us in your witness statement, the
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there was a confidential meeting between myself, Elliot,
and the Chairman, where we discussed our observations
and concerns regarding the operations of the Post Office
and our ongoing cultural issues. Regrettably, it has
come to my knowledge that the notes of the meeting,
which were intended to be kept in strict confidence,
have been circulated to the individuals who were the
subject of our discussion.
“The implications of this breach of confidentiality
are far reaching and have placed me in an extremely
compromising position. It has not only damaged the
relationships between myself and those individuals (Head
of Legal and Head of Postmasters) but will have eroded
trust and will create an atmosphere of tension and
hostility and I worry about serious repercussions for me
as a postmaster as both these individuals are
‘untouchable’ as you have said.
“I am deeply troubled by how this breach occurred,
what measures were in place to prevent such a mishap
from happening,
"Please see below my concems which outline the
gravity of the situation. I request that you thoroughly
investigate how [the] breach of confidentiality occurred
and address the following:
“Was the breach as a result of negligence or a lack
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crossreference is paragraph 243, as you've done today,
that you forwarded this chain inadvertently to Messrs
Foat and Roberts; is that right?
That's correct.
You say that you didn’t open the attachment at the point
at which you had sent it on; is that right?
Yes.
That the email chain was not marked private and
confidential —
Yes, that's correct.
~ and that you didn't pick up from the subject line
“Future of Post Office branches”, what it in fact was
about?
That's correct.
Did those things contribute to your inadvertence?
Yes, they did.
Later that day on the 18th, Messrs Ismail and Jacobs
emailed you expressing their concerns, they having
learnt that you had provided the Project Pineapple note
to the individuals named in the complaint. Can we look
at that, please. POL00448383. Can we start, please, at
page 2. Mr Ismail's email to you later that day, it's
10.00 at night, copied to Mr Jacobs and Mr Staunton:
"... writing to address a deeply concerning and
distressing matter that has
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come to my attention
of judgement on your part?
“How can a mistake of this magnitude happen within
the organisation, especially when dealing with sensitive
matters and with all the current spotlight on us?
"By exposing me to such a compromising and
jeopardising position, how do you expect me to continue
working effectively with the individuals involved?"
Then to page 1, please. Mr Jacobs still later on
the same day, 11.58 at night, two minutes to midnight,
“I strongly echo Saf's views on this,” he said in
an email to you. The same distribution list:
“The release of the confidential briefing note to
the very people we have highlighted in the document is
a horrendous breach of trust.
"My only desire on this Board as a Postmaster NED
has been to ensure the organisation does the right thing
and my actions have always sought to protect the
organisation from both internal and external risks.
"Your description of these three men, (JB ....)"
That's Mr Bartlett - is that right —
Yes.
— who is Director of Investigations and Assurance —
That's correct.
~ so the old Investigations Division —
The new Investigations Division, yes.
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-- Mr Foat, General Counsel -
Yes.
-- and Martin Roberts, Chief Group Retail Officer,
correct?
Yes, that's correct,
*... as ‘untouchable’ in our call earlier today was
worrying enough (especially in the light of our grave
concerns as to their ability and the power they wield
without any real oversight) but is made worse by them
now being told of our view of them. Only one Board
meeting ago these people came to the Board to request
authority to recommendation police investigations into
postmasters without Board oversight or approval -- and
thought nothing of it! To be so staggeringly out of
step with reality of the world Post Office occupies.
today is beyond belief.”
You'll see that both emails refer to you referring
to the three men or some of them in a calll that day as
“untouchable”, did you do so?
My recollection of this is being very, very clear that
no one in the business is untouchable. I don't know if
used the word “untouchable” but no one is above the
law, and that is really important. The point that I was
making to them, and it wasn't specifically about Martin
Roberts, them, or indeed JB, was that we are trying to
7
in writing to confirm the apology he provided to me
about the assertions that were made to me in the
Pineapple file note. Comments attributed to him have
been published in the media and he has remained silent
when he is well aware that those comments contain
factual inaccuracies and even a basic lack of
understanding of Post Office's organisational
structure.”
So far as Mr Roberts is concerned, POL00448514,,
page 2, please. This is Mr Roberts’ email to Mr Jacobs
and Mr Ismail, third paragraph:
“I would now ask that you please put in writing the
apology and retract all the allegations and statements
presented in the email that I was copied in on.”
Then page 1, please. A joint reply, essentially:
“As promised, Saf and I sat down and talked with
Martin after the Board meeting yesterday. An honest and
open discussion was had we believe we had put the matter
to bed
“This evening, we have received the email below ..
asking us to retract the statements made in the
document.
“Whilst we have both made clear the tone and the way
it was delivered was unacceptable and should never have
been circulated; the content is not something we feel is
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bring a sense of transparency to the organisation, and
nobody is above the law. And that is the point that I'm
trying to make.
The sort of secondary observation, as a consequence
of this, is that my position, in terms of formally
addressing the Investigations Team, at that current time
was difficult. I was under investigation myself, by
this -- the oversight was being provided by the
Investigations Team, and the point that I was making was
that, until such time as that had concluded, it would be
difficult for me to ensure that we were getting the
right -- that we were getting the right kind of
oversight from Ben and JB in terms of the investigations
that they were adopting.
To move the matter on, what then happened, is this
right, is that Mr Foat and Mr Roberts, for their part
required written apologies to be provided by the two
Postmaster Non-Executive Directors, Mr Jacobs and
Mr Ismail?
Yes.
If we look at those, please, POLO0448577.
This, at the top of the page, is Mr Foat's email to
Ms McEwan and others, including you and, in his second
paragraph, Mr Foat says:
“As a minimum, Elliot Jacobs should go on record and
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incorrect with regard to the Retail Team leadership and
performance.
‘our position remains that these are both
important and urgent issues that must be addressed, not
ignored -- regardless of how they have come into his
mailbox."
Scroll down, please. Yes, we needn't look at the
remainder. What discussions, if any, did you have with
Mr Roberts and Mr Foat on Project Pineapple?
I spoke with both of them and Martin Roberts, in
particular, said that he felt he'd had a fulsome apology
in conversation with Saf and Elliot, and this email
would suggest slightly different: that they were
obviously apologetic that Martin got to hear about the
information in this particular way but that, actually,
they stood by what was said, and I think there was some
disagreement, I think. Well, misinterpretation perhaps
is a better way to describe it. I think Martin felt
that he had a fulsome apology from them and so that was
very unfortunate for sure.
What about the substance of the issues that these two
Subpostmaster Non-Executive Directors were raising: how
was that addressed; was it addressed?
Be more sort of specific, as in the sort of six
allegations they have made? Well, you've heard me talk
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about the specifics around ~ the specifics around the
investigation into past roles and ~- my memory has gone,
sorry. What was I going to say?
Do you want to look at the list?
Yes, that would be helpful. Thank you.
Scroll down, please?
Yeah, Phoenix, sorry. Absolutely. The issue around the
replacement plan. We were very clear that the two
Postmaster NEDs were the first that had been on the
Board in the Post Office's history, and we wanted to
work with them to ensure that really clear lessons were
leamt, and I know that the Retail Team did that and
subsequently did that. They took the Postmaster NED
comments about induction, about recruitment, about what
the next phase should look like. But we had been clear
that -- and they were under no illusions that the term
was a single term, in terms of their three years on the
Board, and that they would naturally roll off. I don't
think we had been explicit about that but I think that
was the intent. So they had good input into that
process.
The stamps issue was well spotted by Elliot and we
jumped on that straight away. Within 24 hours that
process had ceased, so I'm comfortable that we took the
right action on that.
81
to think very carefully when we get to that point in two
years’ time how we manage that particular problem. It's
a known challenge and I think the way it's been
discussed in the Board -- in the Inquiry is that somehow
we're going to address this in the next few months. It
simply isn’t the case. We've got lots of thinking to do
around this. It's a known problem.
So I hope I've tried to bring some colour to the —
in the issues here. This, you know, is a very important
and big deal. I am very sad that the situation
occurred. I think the events that have subsequently
happened have not been helpful, either to the Postmaster
Non-Executive Directors, and/or indeed to the members of
the Group Executive who were quoted, and I think in
terms of the confidence that it's given to the rest of
the postmaster organisation about what goes on at the
top of the organisation, and you can see that playing
out in people's confidence in the colleague survey
results for '24, which happened a few weeks after this
event.
So it's not a happy period in the Post Office's
history and I don't think it's something that anybody is
particularly proud of amongst the leadership team.
Would you describe what we read as the normal operation
of a Board and General Executive of a large corporation
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Martin Roberts was investigated and looked into and
there were no complaints that were upheld in that
regard.
I know, having spoken to Tracy Marshall and, indeed,
to the Postmaster Engagement Director, who is a current
serving postmaster, that they would absolutely refute
that. They feel that they've had good engagement with
the Non-Executive Directors, and this notion of path
clearing -- and I think this has come up a number of
times, Henry Staunton mentioned it ~ and I think it's
important that we understand precisely what this is
because I don't think it's been well articulated
Path clearing is an event that is going to occur
when the organisation rolls off the Horizon platform and
moves on to the NBIT platform.
What will be required to happen is that, in all
11,500 branches, there will need to be a full cash and
stock audit in order for the migration from one system
to another. We have no real understanding about what
the implications for that will be and, indeed, whether
or not there are going to be large surpluses or indeed
large gaps in terms of the stock and the cash that is
held in each individual branch. We really don't know
that.
We are flagging it as a challenge and we will need
82
undertaking complex issues or a sign to the outside
world, who have been given a glimpse into it, of the
dysfunctional operation of that company at Board and
General Executive level?
I think all businesses, all complex businesses, have
spats and issues that emerge at Group Executive and
Board level, certainly in my experience. I think it's
deeply unfortunate that this is a public spat, for want
of a better word, and I think it's fairly unedifying for
the Post Office but I don't think it's necessarily
reflective of anything more fundamental than that and
I think it is something that happens in large, complex
organisations.
Are you saying this is the kind of spat that goes on
regularly at Board and General Executive level, the
Public just don't get to see it?
No, I don't think I said that. I think this occurs and,
as I say, in large organisations and complex
organisations, people fall out, mistakes get made,
issues emerge. I don't think I would necessarily say
there is a corollary that this therefore means that it's
utterly dysfunctional
So to try to pin you down more precisely, take out the
word “regularly”, these are the kind of exchanges and
these are the type of relationships that one could
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reasonably expect to see in a well-functioning
organisation?
No, I don't think that's the case. I think the business
was under enormous amounts of pressure. I think that
has been well articulated by many of my colleagues who
have been at the Inquiry over the last couple of weeks.
I think, when a business is experiencing the level of
Parliamentary, media and Inquiry scrutiny that it is
under at the moment, it isn't entirely surprising that
issues that may be easily and more readily resolved,
suddenly take a life of their own, and I think that's
certainly the case with this particular issue, and there
are others as well.
Can we move forward with the issue of the Project
Phoenix and Past Roles Project —
Yes.
-- and the interaction between the two, by looking in
February 2024 at the minutes of a POL SEG and General
Executive tactical meeting. POL00458674. Thank you.
Can you just explain briefly what the SEG/GE Tactical
meeting is or was?
Yes, Ican. Yes. Every Wednesday we have a Strategic
Executive Group meeting. That is ~ the names of the
individuals are, I think, those who are present, and you
can see from the apologies who constitutes the Strategic
85
*{Ms Marriott] noted the latest position in relation to
Past Roles ... where 35 colleagues had been deemed to be
RED."
Firstly, what is involved in being "deemed to be
RED"?
Right. I think that figure is now 27 but, again, it's
exactly as you depicted, which is that — and I'll
provide some context to the Past Roles work, which is
effectively an assessment of the 1,700 individuals in
our organisation who have been with the Post Office for
ten or more years, and this was the start of a desktop
exercise to see if we could identify were there
individuals who were involved in activities that were
associated with this Inquiry and with the scandal, and
found themselves in roles where they could be
potentially conflicted because they would be involved in
activities that were informed with redress or indeed
with other postmasters themselves.
Just stopping there, can you be more specific —
Yes, I can.
-- to the current role, which gives rise to a potential
or actual conflict?
Yes, we specifically prioritised the Remediation Unit
and the Inquiry teams, simply because of the nature of
the work that they were doing, which is obviously
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Executive Group and, just for sort of clarity, the Group
Executive was replaced by this new group called the
Strategic Executive Group in January 2024.
You're named, amongst others, as being present and, if
we scroll down to item 4, please, which is over the
page, I'm sorry, "The Project Phoenix/Past Roles Verbal
Update”, "Key points of note", Nicola Marriott: can you
explain the function that Nicola Marriott performed at
this time?
Yes, I can. She is the number 2 to Karen McEwan in the
People department.
*... noted the distinction between Project Phoenix
(where allegations of wrongdoing were concemed) and
Past Roles Review, when no such allegations were made
Firstly, is that a distinction that you recognise?
Yes, itis.
.. and where the review was focused on determining any
conflicts or potential conflicts as between certain,
previous and current roles.”
So the latter, the Past Roles Review, concems
a past role and a present role which presents a conflict
or potential conflict, even absent an allegation of
wrongdoing.
That's correct.
86
administering operationally redress and/or supporting
this Inquiry, in a specific way. So I asked for the
work to -- for the 1,700 to focus most specifically on
those individuals who are involved with redress or the
Inquiry, and then trying to identify whether there were
individuals who might have, in the past, been involved
in activity that is covered by this Inquiry:
investigations, audit and work associated with
prosecutions as well
And, if there were -- and there's no allegation at,
this stage that those individuals have done anything
wrong -- if they were, we wanted to make sure that we
identified who they were, and what roles they were doing
today, and whether or not the roles that they were doing
today in some way could be conflicted or indeed could
postmasters who are involved in redress or receiving
redress be in some way intimidated or indeed affected by
the fact that these individuals were administering the
redress or indeed supporting the Inquiry.
That was the genesis of the work.
So why were these 35 individuals given a red rating?
Specifically, I can't go through all of them but it
would be, as I said, it would be those roles —
presumably retail facing roles historically, that they
may have been involved in, and now they are involved in
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some form of activity associated with redress in the
case of these individuals.
So in the Remediation Unit?
In the Remediation Unit.
The Inquiry Team?
None in the Inquiry Team, as I understand it, but these
were specifically associated with the Remediation Unit,
and those roles would have been shortfall analysis, they
would not have been decision-making roles, in the sense
of deciding or determining what an offer may or may not
be from a compensation perspective. However, we wanted
to be really confident that anybody coming forward to
the Remediation Unit had the confidence that they were
talking and speaking with people that were unbiased in
any shape or form. So it was for the individual's,
protection as well as specifically for the post master's
protection
We it might be suggested that this work in February 2024
was a little after the horse had bolted?
Yes, it's slower than we would have wanted and I think,
as you'll see from the correspondence -- and indeed as
this Inquiry has seen over the last couple of weeks --
there is no question that this piece of work was slower.
However, we can now -- I can now confirm with some
confidence that there should be no conflict arising from
89
identified who these individuals were and that they
weren't involved in activity supporting redress.
So it was more to do with what they did previously,
rather than the function they were now performing, that
made them high risk?
Yes.
... 2 had been through the panel review, with
recommendations to redeploy and the other 2 were due to
go to the panel soon, where recommendations for
redeployment were also the expected outcome.”
You are recorded as asking how it was that the
Remediation Unit had 35 red-rated colleagues. Not
an unreasonable question: you were concerned —-
Yes.
- why is our Remediation Unit staffed with 35 people --
Correct.
-- that occupied roles that brought them into conflict
or potential conflict with the task that they were then
undertaking?
That's exactly the question I was asking
The answer, from Ms Marriott, was that:
"... resourcing decisions at the time had likely
been based on a need for requisite knowledge ...."
Did you understand that to mean that we needed past
Investigators, Contract Managers and the like, audit
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individuals working within the RU team when it comes to
redress.
Are any of the 35 red-rated individuals the same 40-plus
Investigators that were mentioned in the Project
Pineapple note; are we referring to the same cohort?
Yes, I mean, I think we should be clear, this cohort
that’s 40 “untouchables” or 40 Investigators, is not
a cohort that I recognise. So I don't think the two are
the same.
How many of the 35 red-rated individuals are currently
within the Assurance & Complex Investigations Team?
I don't have the detail for that, but my understanding
is the A&CI team, which constitutes about 17
individuals, is brand new. It was established in 2022,
it was made up of individuals who have come in to the
organisation extemally, and so there is no crossover,
as I understand it.
The note continues:
"4 RED-rated colleagues were deemed to be high risk
Why was that?
They will have been individuals who will have been
involved in audit or investigative work, historically.
Again, not necessarily an allegation of wrongdoing but
clearly, from our perspective, it was important that we
90
functionaries, involved because the very complaints that
were being made now concerned the same activities?
Less so that. I think it was more the fact that the
technical nature of shortfall analysis and disclosure
was -- these were individuals and experts who were
better at doing it than anybody else, was the way that
it was described to me.
She continued:
"... the lens being applied now had not been
envisaged, but arguably it should have been.”
This was just after Mr Bates vs The Post Office,
I think, wasn't it?
Yes, it would have been, yes.
Did that affect the lens?
No, I don't think so. I think her point is well made.
I mean, I think it was a concern that this hadn't been
considered at the outset.
“That said, [she] emphasised her earlier point, that the
individuals had not been implicated in any wrongdoing,
then or now.
“On Project Phoenix, there were 6 people against
whom there had been specific allegations of wrongdoing.”
Over the page.
"[Post Office] had been engaging postmasters and
legal representatives to determine the facts and the
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basis for any disciplinaryimisconduct steps as proved
necessary.
*[Ms Marriott] noted the prospect that no findings
of misconduct would be made and the difficult position
this would present -- where there were competing
dependencies and interests including the expectations
and conviction of those who had made the allegations,
the proceedings of [this Inquiry] and the individuals
themselves who deserved fair treatment if they had done
nothing wrong.”
"GE", is that the meeting?
GE is the Group Executive, yes.
Rather than a reference to an individual?
Yes.
noted that there were also wider historic
organisational and cultural issues being brought to the
fore which would also likely be subject to close
external scrutiny.
“.. another lens to be applied beyond any
allegations of a historical nature, should be how
individuals presented themselves at the Inquiry, though
it noted the difficulties and dependencies in this
regard too.
"... agreed that the panel recommendations should go
on to [others] to make any final decisions on the
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You will remember that before lunch I asked you some
questions about an exchange of emails between May 2021
and July 2021 involving a man called Gary Thomas,
a former Post Office Investigator —
Yes.
-- and the suggestion made by him that there existed in
his time a bonus scheme that was related to the volume
of successful prosecutions and/or the volume of
recovery
Yes.
-- under the Proceeds of Crime Act?
Ido.
You noted that the correspondence had, in the final
analysis, been sent to your personal assistant but you
had not much recollection about it?
That's correct.
Ihave had helpfully drawn to my attention a document
that maybe rounds this issue off a little. Can we look
at that, please. POLO0142412. If we go to the last
page, please, which is page 7, you will see this is
a note from Peters & Peters Solicitors of 24 August
2022. If we go back to the first page, in the tramlines
at the top, it's a disclosure note in relation to,
amongst other things, number (2), "A Review of Bonus!
Incentivisation schemes”
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outcome
What does “there were wider historic organisational
and cultural issues being brought to the fore” mean?
A. I'm not sure I entirely know. No, I'm not sure
specifically what that refers to.
MR BEER: In which case, Mr Read, that will be my final
question before lunch.
SIR WYN WILLIAMS: Just so that I can be clear in my mind,
the six people that are referred to on the previous
page, you have told us are now three with no case to
answer.
A Yes.
SIR WYN WILLIAMS: I think it was Ms McEwan, although it
could have been Ms Scarrabelotti, told us that
a decision about the other three is imminent.
A. That's correct, sir.
SIR WYN WILLIAMS: Fine, yes. Thank you.
MRBEER: Can we say 2.00, please?
SIR WYN WILLIAMS: Yes.
MRBEER: Thank you
(12.57 pm)
(The Short Adjournment)
(2.00 pm)
MR BEER: Thank you
Good afternoon, Mr Read.
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It seems that it was addressed to defendants or
putative defendants, and perhaps the CCRC, because in
paragraph 1 it's noted that:
“In accordance with its ongoing disclosure
obligations ... the Respondent [that's Post Office] is
continuing to review material not previously considered
for disclosure ..."
Then paragraph 2, "This note is intended to address
three matters", the second of which was:
A [Post Office] review of bonus/incentivisation
schemes relating to [Post Office] employees involved in
the investigation and prosecution of criminal offences.”
If we go to the part of the note that concerns that,
that’s on page 3, paragraph 13. It says:
[Post Office] has conducted a review of material
relating to the bonus/incentivisation scheme that
applied to employees involved in criminal investigations
and prosecutions ... in order to determine whether it
operated so as to incentivise or encourage improper
conduct capable of leading to unfairness in those
prosecutions ..."
If we scroll down, please, it says Post Office is
providing the note to disclose the fact of the review to
allow appellants to make representations in relation to
the review, the relevance of the review or the facts of
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any particular appeal.”
“Scope and ambit’, if we go over the page, please.
I should have looked at the footnote at the foot of
the page:
“The Review was conducted by Peters & Peters as part
of the Post Conviction Disclosure Exercise ..."
If we carry on, please. "Scope and ambit". 17,000
documents, this included, where available, HR files
relating to individual members of the criminal law and
security teams.
Some interviews were conducted, paragraph 17, with
current and former Post Office Security Managers.
Then the note splits out its conclusions into
findings relating to the Security Team and then,
subsequently, findings relating to the Criminal Law
Team. 1'll just look at those relating to the Security
Team, which is what Mr Thomas was a member of:
“The [Post Office] Security Team operated a bonus/
incentivisation scheme during the period between [1999]
and 2013
“The scheme included, among others, objectives
relating to the recovery of [Post Office] losses through
criminal confiscation or compensation proceedings, or by
repayment direct to [Post Office] during the course of
an investigation or prosecution
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The Inquiry has heard a lot of evidence on these
issues, I should say, as to the accuracy of what is said
here
Yes.
Over the page, it goes on to the criminal law team.
So, essentially, it seems that there was a bonus!
incentivisation scheme —
Yes,
-- that was linked to recovery of funds but not the
number of prosecutions?
Yes, that would be my interpretation as well.
Of course, in order for there to be a recovery of funds
there needed to be a successful prosecution to start
with?
Yes.
Were you involved in this in any way; did you have any
knowledge of this exercise to investigate the extent to
which there was a bonus or incentivisation scheme?
No, I don't recall it, actually. Not something I do
recall.
Looking at it, it seems that part of what Mr Thomas said
would broadly align with what the review found?
Yes.
But part of it would not, in that there wasn't a metric
relating to the number of successful prosecutions but
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“The recovery of [Post Office] losses, typically
expressed as a percentage of losses caused by fraud
activity, was a recorded team objective within the [Post
Office] Security Team. The achievement of this would
account for a proportion, albeit a small one, of the
total bonus awarded to members of the [Post Office]
Security Team that were entitled to receive bonuses.
These objectives were concerned solely with team
outcomes, not individual performance."
Then paragraph 21:
"The level of bonuses ... would depend principally
upon the individual's Performance Development Review
score at an annual appraisal.”
Paragraph 22:
"The Review identified no evidence that the bonus/
incentivisation scheme applicable to the [Post Office]
Security Team was based on the numbers of prosecutions,
convictions or recommendations ... Peters & Peters
collected bonus data and conducted an exercise to
identify whether there was any correlation between the
number of convictions and level of bonus ... No such
correlation was found ..."
Number 24 notes that:
charging decisions were taken by lawyers
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not by investigators
there was in relation to recoveries?
That's what I would interpret too.
Thank you. Thank you, that can come down.
Can I turn to or continue with the topic of the
interaction between those that have been implicated in
the wrongs of the past and the payment of compensation.
Yes.
Would you agree, as a general rule, that, if one
perpetrates a wrong, you should promptly admit the wrong
and seek to rectify the problem that you have caused?
Yes, I would.
Would you agree that it has been established that the
Post Office devastated the lives of subpostmasters and
the lives of their families through the use of criminal
investigations, criminal prosecutions and civil claims?
Yes, I would.
That those wrongs took many years to surface?
Agreed.
Would you agree that when acting as a private
prosecutor, a public corporation, the Post Office
utilised its status and history to silence its
opponents?
Yes, I would.
Would you agree that it's been established that the Post
Office denied postmasters disclosure that would have
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enabled them, firstly, to contest the charges that were
wrongly laid at their door but, secondly, to seek to
remove unjust convictions that had been wrongly obtained
against them?
Yes, I would.
Is that why, in light of those recognitions, you say
that Post Office should not have been involved in
dealing with compensation for those wrongs?
Yes, itis.
Why was Post Office involved in the administration of
compensation for dealing with those wrongs?
Ostensibly because the shareholder, the Government,
wanted us to experience some of the discomfort that had
been caused by the Post Office and, therefore, be
involved in the redress. My personal view, and one that,
I've expressed consistently since this decision was made
by the shareholder, was that it seems astonishing to me
that an organisation that has been involved in the
investigation and the prosecution of postmasters in this
light should be involved in redress. It should be done
independently and I've been consistent with that view,
well, for three or four years now.
I've heard the analogy suggested it's like putting
a burglar in charge of deciding whether to give stolen
goods back. That may be strong language
101
that function within the Post Office had no connection
with the past?
Yes, I think that is the case. I mean, I would describe
it that structurally we have a problem here, the cause
is wrong and everything that has flowed from that cause
has been problematic for us. The building in of
independence has been critical to the schemes that are
operated by the Post Office, and that has had varying
degrees of success, I would argue.
The fact of the matter is that those that have been
involved, or are implicated in the events of the past,
have nonetheless had a role in making decisions as to
compensation?
{don't think making decisions; I think, going back to
the conversation we had before lunch, I was clear about
the number of "reds", as they were described, and we
were very clear that we had ensured that any “reds”, in
inverted commas, were not involved in decision making
associated with either offers or anything of that,
nature. They may well have been involved in the
shortfall analysis, they may well have been involved in
disclosure exercises but not involved in decision making
associated with compensation.
To take an example, Mr Rodric Williams was an important
figure in the Post Office's Steering Committee that
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Yes, I think that's strong language but, notwithstanding
your analogy, I do think that the confidence of the
process and the independence of the process would have
been enhanced if the Post Office had been ring-fenced
and removed from this -- or not even considered, as
opposed to removed.
You essentially explained it on the basis that the
Government said that the Post Office needed to feel some
of the pain?
Yes.
Was that phrase used?
Hooked at my contemporaneous notes and I think I may
well have disclosed something to this effect: that the
way it was portrayed to me was that Treasury were of the
opinion that the chaos -- I think was the word that was
used -- had been caused by the Post Office. There was
a desire for the Post Office to experience some of the
discomfort that had been caused. You could understand
why that might be the case but I just think it's missing
the point completely.
Given your understanding that it was, in principle,
morally wrong for the Post Office to act as the
custodian or the decision maker in the provision of
a large range of compensation, wasn't it doubly
important to ensure that those that were entrusted with
102
drove the defence of the Post Office in the Group
Litigation --
Yes.
~ and he went on to work on the Shortfalls Remuneration
Committee?
That may well be true. I couldn't confirm that.
Ifit is true, and I suggest it is —-
Right —
Do you see the problem?
I do see your problem and Mr Williams is not involved in
that activity any more.
Did it cross the mind of the Board or the General
Executive that the continuing -- and I think you've
described it as "inexcusable delay" in the delivery of
‘compensation might be that the wrong people were
involved in the provision of it?
I don't think expressly like that. I think, when we've
looked at disclosure as being a sort of core reason for
the delay in compensation or one of the core reasons for
the delay in compensation, I think there have been other
technical reasons and technical drivers, rather than
some of the individuals that you're alluding to
Can I tum to the Central Investigations Unit, as it was
initially called.
Yes.
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Just by way of background, can you help by confirming
the following: the Central Investigations Unit, or the
CIU, was established in the Post Office in February
2022
Correct.
-- and that was established as the Post Office's central
investigation function?
Yes.
It's now known as the Assurance & Complex Investigations
Team, A&Cl
That's correct.
Can you help by confirming that the establishment of the
CIU in February '22 followed a review undertaken by KPMG
between June and August 2021?
Yes, Project Birch, I think.
Project Birch, the KPMG report, was, would you agree,
heavily critical of the approach within Post Office to
investigations at that time?
Yes.
The report for the transcript ~ no need to tum it
up ~ is POLO0423697. Can you help by confirming that,
a number of GE papers were produced following the
Project Birch report and decisions taken by the GE on
the approach to investigations?
Yes, that's correct.
105
where relevant, we demonstrate that [Post Office] has
leamt from the past and would seek to determine actual
culpability, if any, which is treating the postmasters
fairly. Allegations of misconduct by postmasters would
be explicitly included in the proposed remit.”
Then if we go to page 6, please. If we scroll up,
please, this sets out the proposed operating model and
the interaction of the CIU with external agencies in
particular the police.
Yeah.
“As a Government organisation, Post Office is viewed by
[law enforcement agencies] differently from a privately
owned company. It is unfortunately fact that LEAs
deprioritise most reports of crime made by
government-linked organisations if made in the
traditional interest in way.
"4.2. Suspected offences with an element of
criminal dishonesty would form the vast majority, if not
all, of our criminal investigations and potential
referrals.
"4.3. Itis proposed ..."
Then a summary of this, would this be fair: that the
CIU would conduct an internal investigation but with the
intention of reporting any alleged criminality to the
police?
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They were put before the Board -- if we can look at
that, please — on 27 September 2022. POL00448320. So
this is essentially a paper to the Board as a result of
prior decision making by the GE, sponsored by Mr Foat,
for a meeting on 27 September 2022. If we go to
paragraph 2.4, please:
“It is our recommendation that the minimum remit ...
is Option 4 [that need not concem us]. This would
allow [Post Office] to act in determining facts relating
to situations ranging from allegations of theft or fraud
by postmasters and/or their staff using/misusing [Post
Office] systems or functions where either or both [Post
Office] and the postmaster are victims, through to
misconduct or process failings in [Post Office] and the
subsidiaries. The Horizon issue identified a failure to
investigate ..."
I think that means the Horizon Issues Judgment:
*... identified a failure to investigate beyond the
postmaster in determining culpability. Best practice
(and in some situations, law) requires all reasonable
lines of inquiry to be followed, whether they point away
or towards the considered investigative hypothesis as it
is the truth that is sought, not that a case is to be
made against a selected individual. By investigating
wider than the Postmasters, for example their staff
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We touched on this topic yesterday and, as you say, this
is a proposal to the Board. I think maybe if I could
take a step back and just describe what the activities
of the CIU are today and what it does, it might shed
some light on where we're going with the CIU more
broadly.
There are four or five very specific activities that
the A&CI are involved in. First and foremost, it's the
whistleblowing and there's a ring-fence team that look
after whistleblowing and Speak Up. It is independent
and that's what it does.
The second element is that it investigates those the
issues of more than £100,000 potential loss in ~ within
the sort of Post Office environment. That could be
branches or anywhere else. It obviously is the single
point of contact for liaising with LEAs and it's
important, we felt, to have a single place to do that,
and it acts in two other ways: it looks into and governs
the activity of the senior leadership group and the
Board, if there are investigations of conduct into those
individuals; and finally, it provides some assurance for
the organisation in terms of the way it conducts its
investigations.
I think the genesis of this work, in terms of
Project Birch, was particularly the fact that there were
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disparate groups across the organisation who were doing
various levels of investigation for various reasons with
inconsistent levels of training and support.
So the important element here, I think, is that the
evolution of this issue is that the A&CI team interplay
with law enforcement agencies when there are organised
crime and larger issues associated with fraud or money
laundering, or the like, as opposed to the inference
that the A&C! would be doing individual investigations
into specific post offices, discrepancies or losses.
They have to be of a size greater than £100,000 for
this team to be involved in any of that kind of
activity. I don't know if that helps.
That sets out the position now.
Yes.
I want to explore in slightly more detail what was
proposed, and then what happened.
Right.
If we go over the page, please, if we scroll down ~ and
over the page, keep scrolling, and again. I think
that's probably the end.
Was the KPMG Project Birch report circulated to the
Board?
{don't know. I don't believe so. I think it was in
draft form, so I'm not sure that it went to the Board.
109
Can you recall whether questions were raised, designed
to question assumptions about culpability or assumptions
made on the way to substantiating losses?
No, I don't recall.
The CIU team, I think, became properly operational in
January 2023 —
Yes.
-- and Mr Bartlett, John Bartlett, was appointed —
That's correct.
-- in February 2023 to head it, I think.
Yes.
Now, the Inquiry - and I'm not going to go into the
detail - has heard evidence from Mr Jacobs on his
experience of investigation by this CIU team. Has what
Mr Jacobs has said to the Board given the Board any
pause for thought as to the way in which the CIU were
conducting its investigations?
I think it will have given the Board some concem.
I think the Project Pineapple -- well, Project Venus
experience, as I mentioned before the break, the words
lused were "heavy-handed". I think there is certainly
a level of reflection associated with that. What we do
know is that the A&CI team is stretched and it is
involved in too many investigations. That may well be
a cultural reflection on the nervousness and broader
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Was the Project Birch report circulated to the General
Executive?
Yes, I believe so.
Did you see it?
Yes, I believe I did.
Do you agree with the criticisms in it of the Post
Office's then approach —
Yes, I mean, I —
~ to investigations?
My recollection of that was that they were inconsistent,
that they were conducted across the business without
levels of assurance and control and, more importantly,
they were conducted potentially by Area Managers, people
who weren't qualified to investigate, and part of the
recommendation was that we needed to bring this together
to drive some consistency, and that is what has happened
as a consequence of Project Birch.
Do you know why the Project Birch report may have not
gone before the Board?
No, I don't actually, no.
When the Board was asked to approve this new approach to
investigations, were any questions raised by the Board
as to the approach that was then being taken to
investigations?
I don't recall specifically, I'm afraid
110
nervousness in the business that currently pervades as
a consequence, as we discussed before, of the Inquiry
and the scrutiny that is occurring
I think there is a potential lack of judgement at
times and I think that is something that we are, as
a Board, conscious of. But, at the same time, as we
discussed yesterday, the Board is particularly aware
that there is no presumption of guilt when it comes to
loss recovery, when it comes to investigating
discrepancies, when it comes to looking at issues
associated with Horizon down in branches and, most
importantly, that that activity, in terms of working
with the postmasters, is conducted by the Retail Team
and not by this specialist team.
This specialist team is ostensibly there to work
with law enforcement agencies when organised crime is
identified, and vice versa, when we identify it as well.
‘As opposed to the -- I think the impression that is
being given is that this team is involved in the
day-to-day activity associated with branches. That
isn't the case at all
Given that at the time that the Board was asked to
approve the new approach to investigations set out in
that noting paper, the Common Issues Judgment the
Horizon Issues Judgment, and the Court of Appeal
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Criminal Division's decision in Hamilton had all been
handed down, decided —
Yes.
-- were then well established, how did the Board or did
the Board satisfy itself as to the steps that were to be
taken by the CIU to substantiate, in the words of the
paper, losses in branches before proceeding to act upon
them?
Well, I think the Board made it very clear that, if what
you're suggesting is that, if we are to work with any
law enforcement agencies around potential losses, then
clearly the Board needs to be involved in making those
decisions, which is where it is ~ which is what the
position it has today. So if we are to work with LEAs
in any sense of the word, it needs to be something that
is sanctioned by the Board.
But broadly, where LEAs ask for information, where
they ask for cooperation, we should and will provide it.
I was looking at it the other way round?
Right.
The paper envisages an investigation by the CIU in which
a loss will be “substantiated”. I'm asking whether any
particular attention was paid by the Board to that
issue. How is a "loss" ~ in inverted commas ~
substantiated?
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But it's important context to the questions about
enforcement action. In summary, the survey on
subpostmasters, the SPM survey, found that nearly half
of the SPMs surveyed were dissatisfied with how the
Horizon IT system currently operates, compared to 25 per
cent who were satisfied, and 25 per cent were very
dissatisfied. So 75 per cent were dissatisfied or very
dissatisfied
42 per cent were dissatisfied with the training that
they had received, compared to 25 per cent who were
satisfied
70 per cent said that they suffered from screen
freezes.
68 per cent suffered from loss of connection.
57 per cent said that they had experienced
unexplained discrepancies.
19 per cent said that they had recorded unexplained
transactions.
14 per cent experienced missing transactions.
10 per cent complained of double entry of
transactions.
65 per cent of the subpostmasters surveyed
experienced those issues at least once a month.
In relation to the contract provision,
15 per cent -- only 15 per cent -- said that they had
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No, I don't think the Board specifically got into that
level of detail.
What about the General Executive, this being an issue of
controversy ~
Yes.
~ the substantiation of whether a loss had in fact
occurred at all and, if so, who had caused it?
I don't think the Group Executive got into that extent.
This would be something that the Retail Committee would
be more focused on than A&CI, particularly, as I've
mentioned before, when it comes to identification of
discrepancies, when it comes to mismatches, when it
comes to transaction issues, that is something that will
be specifically in the domain of the Retail Team.
I think having sat in this room, you will have heard the
evidence produced by YouGov concerning the levels of
satisfaction and dissatisfaction with the operation of
the Horizon system currently, and the extent to which
faults within it seemed to cause unexplained losses.
Can we look at that, please, by way of context to the
questions that I'm going to ask?
The "Executive Summary’ will suffice, so
EXPG0000007, page 4, please. I'm going to whiz through
this because we've heard the evidence already.
Yes.
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received a full copy of their contract ~ scrolling
down -- since the Common Issues Judgment in March 2019.
55 per cent felt that the terms of their contract
were unfair; 32 per cent very unfair.
Then to page 5, 48 per cent of subpostmasters felt
dissatisfied with their role; 31 per cent felt
satisfied
72 per cent felt undervalued
60 per cent disagreed with the proposition that the
Post Office Board listened to their views.
74 per cent disagreed that the Post Office
understand the concerns of subpostmasters.
52 per cent did not think that the Post Office was
a good place to work.
55 per cent thought that the Post Office had not
learned the lessons from the past.
If we go on to page 28, please, at paragraph 4.5, in
relation to shortfalls, around 7 in 10, 69 per cent of
subpostmasters, reported they'd experienced
an unexplained discrepancy on Horizon since January
2020.
Those that had been working between six and ten
years were most likely to have reported this experience,
up at 83 per cent; at 21 years least likely at
61 per cent.
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Of the subpostmasters surveyed who reported
experiencing an unexplained discrepancy since January
2020, 1 in 3 had done so as frequently as a few times
a month, 17 per cent; or once a month, 18 per cent;
25 per cent who had experienced an unexplained
discrepancy said they had done so a couple of times
a year; 8 per cent, once a year; 9 per cent, less than
once a year. That's all represented in figure 15.
The vast majority, 89 per cent of subpostmasters
surveyed who reported experiencing an unexplained
discrepancy since January 2020 said that a typical
discrepancy was less than £1,000; 50 per cent, who said
less than £200; 39 per cent between £200 and £999; 8 per
cent reported a typical discrepancy was between £1,000
and £9,999.
That's all reported in figure 16, if we scroll down.
All subpostmasters surveyed who experienced
a discrepancy reported these were shortfalls, 98 per
cent; a third had surpluses with subpostmasters able to
have experienced both:
Over the page, please, when asked how discrepancies
were typically resolved, it was most common for
subpostmasters to report using their branch's money or
to have resolved it themselves, 74 per cent; more likely
among those who had been a subpostmaster for 11 to
17
where the Branch Support and Reconciliation Team are
involved, we have good metrics to support that progress
is being made in terms of how we engage with
postmasters, how we worked with postmasters, to identify
issues, and how that worked
So the reason I say surprising is that the internal
statistics don't necessarily mirror these particular
results. So that's why it's disappointing and that's
why we need to dig into it further and try and
understand some of the underlying issues.
I'm conscious that I think it was only 14 per cent
of the postmaster population responded to the survey,
despite the fact that we wrote to them in hard copy,
sent them emails. It's more an issue of engagement,
which I think is the one that we are challenged by.
What we noticed is that where we reach postmasters from
an engagement and from an awareness and from a -- yeah,
from an engagement perspective, we're getting better
results. I think it's noticeable that those who have
been postmaster for less than two years, for those who
have been involved in some of our forums, some of our
support groups, some of the way that we are changing
internally, have reported better results.
There's no question, though, that these are
disappointing. We've got more to do and I think,
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20 years up at 82 per cent.
Then there's a quote from one subpostmaster:
“The ... system is still flawed at month end we have
seen a discrepancy where a cheque had been shown to be
cashed on our system which created a shortfall, we do
not cash cheques as a local branch and this put us in
a discrepancy when we went to [the Business Support
Centre] they didn't resolve the issue properly and we
took on the loss personally.”
Figure 17, if we scroll down, shows how
discrepancies have generally been resolved: 74 per cent
resolved by the postmasters themselves or using the
branch's own money.
So the questions arising from that, Mr Read: these
statistically significant results that concern issues
with the frequency, volume and amount of discrepancy
transactions make dismal reading, don't they?
They're very disappointing and surprising.
Would you agree that they mean that the obligation in
the contract upon Post Office to maintain oversight and
investigate any apparent shortfalls or alleged
shortfalls, and whether or not there was indeed any
shortfall at all, is failing?
I think where we -- where the "Review or Dispute" button
is used, where the Branch Support Centre is engaged,
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despite the changes we've made to the Branch Assurance
Team, despite the changes we've made to the Network
Support and Reconciliation Team, despite the teams that
now go out and help individual postmasters specifically
with discrepancies or issues that emerge in branches,
where we can try and resolve, we're not getting the same
level of traction, even though we are communicating and
engaging with postmasters in a very different way.
When discrepancies or problems emerge with Horizon,
we are utterly transparent when that happens. We use
our Branch Hub tool. We use our Memo View tool. We
engage with postmasters. But we're obviously not
getting through to everybody, and you obviously
experienced as well in your survey, that we have more to
do to try and win the trust and win the confidence of
postmasters. Because these results certainly don't
suggest that we are making the progress that we would
like to have made.
I've got to ask you bluntly: how is it possible that, in
late 2024, the same issues with shortfalls are occurring
with postmasters paying them off themselves?
I just don't know why the postmasters feel the need to
do that. We have been absolutely explicit when we've
investigated shortfalls that, where it cannot
established how and why that shortfall has occurred, we
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are not imposing upon postmasters to pay off or pay it
themselves with their own money. We've been very, very
clear with that, maybe we're not getting that message
clearly through. But there is no enforcement by the
Post Office in that situation at all, and it's important
that we convey that.
So that's the engagement piece that I've spoken to
the team about over the last three weeks, since this
survey was delivered, and I know that the acting CEO is,
working with the Retail Team to try and get under the
skin of what it is that is — and why itis that we're
not engaging in the way that postmaster can understand.
Because, clearly, as I say, this is a disappointing set
of scores.
Q._ Has it occurred to the Board or the General Executive
that there may be a connection between the fact that
a very low percentage of subpostmasters report having
received the new contracts, 15 per cent, and the fact
that many postmasters, and notably more of the
longer-term ones, are still paying off shortfalls from
Horizon system errors, ie the changes that have been
wrought under the contract, have not
A. Haven't got through.
Q. Haven't got through because they haven't been given the
contracts?
121
our postmasters as well.
Q. Ifit’s right that only 15 per cent of postmasters have
access to the new contract, then only 15 per cent of
them would be aware of the new post-Common Issues
Judgment terms.
‘A. No, I don't believe so. We communicated the restatement
exercise to all postmasters. So if that needs to be
re-engineered then we need to do more to do so. I don't
personally believe that it's a contractual issue that is
affecting the way that we are engaging with postmasters.
I don't think it's about contract. I think it's about
behaviour, and we've clearly got more to do.
Q. When a postmaster pays off a shortfall, is the cause of
the shortfall investigated?
A. We only invite postmasters to pay for shortfalls when
there is an agreement between the Post Office and that
individual. If they believe that there is no causality
associated with either error or carelessness on behalf
of the postmaster themselves, they press the review and
Dispute button and we go into a deeper investigation.
But if, at the conclusion of that, we can't find any
agreed cause between the two parties, we do not enforce
the postmaster to make good that loss.
SIR WYN WILLIAMS: I follow that and I've understood that to
be the position as you say it should be in practice.
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A. don't think that’s necessarily the case. I think the
restatement exercise was back in 2019, which is when we
restated contractually to reflect the changes in the
Cid, was very quickly and comprehensively done.
This suggests to me this is more about engagement as
opposed to contractual. This is about behaviours and
this is about the Post Office today not getting its
message through about how we want to help and support
postmasters to improve their operational performance and
more importantly to ensure that discrepancies don't
occur.
Now we know that there are anything up to 10,000
transaction corrections in any given month, which, if
you think about 11,500 branches, is approximately one,
transaction correction per month. So you know that with
the vast amount of cash and the vast amount of stamps
that we are moving between branches and the centre, you
know, problems do occur.
But the fundamental issue from our perspective is we
are standing by with the Branch Support Centre, with our
reconciliation support team to help the postmasters get
to the bottom, and the presumption of guilt is no longer
applied. This is absolutely about presumption of
innocence and making sure that we understand the issue,
and then we can communicate the problem more broadly to
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But taking this survey at face value, there are still,
in numerical terms, perhaps hundreds of people who, when
faced with a shortfall, simply pay it back
A. Iknow.
SIR WYN WILLIAMS: Right? Now, I think that's what Mr Beer
may just have been asking you about. In those
circumstances, presumably nothing happens?
‘A. Well, we don't know.
SIR WYN WILLIAMS: You don't know.
A Yes.
SIR WYN WILLIAMS: The money goes to the Post Office and
that's the end of it
‘A. Well, we don't know, sir—~
SIR WYN WILLIAMS: Who has done it?
‘A. —who is paying money and that is troubling.
SIR WYN WILLIAMS: Right yes, okay.
MR BEER: That can come down, thank you
Does Post Office conduct surveys of this kind in
relation to the extent to which postmasters experience
Horizon issues that lead to shortfalls in branches?
‘A. We do two things. We do two surveys a month -- sorry,
two surveys a year with the postmasters, a pulse survey
in the autumn and then a full survey in January,
February, March, where we ask the postmasters about the
issues that are affecting them, and so that we can ~- we
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do it consistently every year so we can build up a trend
of what is going on. But we also have a number of
different —
Just before you move on from that answer, I was asking
specifically about issues with surveys asking the types
of questions that YouGov put to the full cohort of
subpostmasters.
Yes, is the short answer to that question, perhaps not
to the same extent and exactly the same wording, but we
do ask about the issues that they are facing, and we do
ask about Horizon and we do ask about, you know,
problems that are associated with it, whether or not
we're communicating discrepancies appropriately, whether
or not we're communicating issues separately, how best
to do that, which vehicles and which tools do
postmasters like to be communicated through and with,
whether that's Area Managers, whether that's through
Branch Hub, whether that's through communication
directly to the counter itself. So, yes, is the short
answer; we do do that.
You said in an answer a couple of answers back that only
14 per cent of the total subpostmaster cohort replied to
this part of the survey
I think that's correct, yes.
Did you mean, by that answer, to say that reliance
125
Okay. Can we look at some material relating to that,
please. BEIS0000789. This a quarterly shareholder
meeting. Can you just explain briefly, if you could,
what the quarterly shareholder meetings consist of?
Yes, certainly, it's a three-way meeting, effectively,
between DBT officials, UKGI officials and Post Office
senior leaders, non — in the main, non-Board members,
with the exception of the Chair. And we agree -- it's
a quarterly meeting and it's held for a couple of hours
every quarter. There's an agenda that is agreed by DBT
and the Post Office.
If we just scroll down we'll get a greater idea of those
that are present. Thank you. We'll see that you were
present at this one. If we just scroll up, we can get
the date: 10 January 2023. Can we go to page 4,
please, “Issues of note as required, including
interaction with policy guidance", and the third bullet
point, "AC" -- I've forgotten who that was.
Alisdair Cameron
Thank you:
"... mentioned they are seeing a rapid increase in
losses including shortfalls of cash in branches. [Post
Office] need to conduct a proper investigation and
demonstrate whether the postmasters are accountable.
However, itis difficult to conduct a proper
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should not be placed on the result?
No, I -- what I meant was we didn’t engage -- we didn't
manage to engage everybody to take part and so,
therefore, I think it's not unreasonable to ask the
question, you know, people who want to engage with the
survey will have an issue that is on their minds. I'm
just questioning whether the other 85 per cent had
an issue.
As the Chairman has said, the 1,000 or so that did
respond to this part of the survey, a very significant
proportion of them, hundreds, 74 per cent, said that
they were paying back shortfalls themselves. That, in
and of itself, irrespective of the cohort —
Is troubling,
~ that did reply, is a significant number of
postmasters?
Itis troubling, yes.
In your witness statements, you don't appear to discuss
in any detail the Post Office's continuing
investigations and enforcement actions against
subpostmasters and, in particular, the mechanisms for
obtaining data from Horizon. Was there a reason for
that or was it just because of the questions that you
were asked?
I think it was the questions I was asked, yes.
126
investigation based on the Horizon data, and also [Post
Office] are not in a position to ask for the relevant
money back in the current climate. It was noted as not
a good time to prosecute postmasters due to the current
historical cases, but this is seeing a rapid rise in
losses for [the Post Office]. MR's team ..."
That's Mr Roberts?
That's correct.
*... are working on putting a new system in place.
[Mr Roberts] noted a helpful summary from
[Mr Cameron] and added that in particular the view and
dispute buttons on the system are causing problems.
Getting in contact with postmasters was highlighted as
difficult, and they're not always available ... [Post
Office] noted they can do more in engagement with
postmasters. It is on the agenda for the next ... Board
meeting.
"[Mr Cameron] raised that there are other solutions
rather than going to the police. If post masters are
responsible and don't pay money back, there is an option
to take it off their remuneration. Any solutions as to
how any shortfalls that post masters are accountable for
can be recouped from postmasters, aside from
remuneration, were noted as preferable."
Then:
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“[Post Office said] ~ In cases where there is
fraud, these could be tested in a civil jurisdiction.
A paper on this was noted as being worked on currently
and would be raised to {the Government] in due course."
"TC", I think that’s Tom Cooper, the UKGI Director
and also the Shareholder NED; is that right?
That's correct.
*... noted there would be problems if money was deducted
from postmaster remuneration without an investigation.
*[Mr Cameron] confirmed no one is suggesting this.
Noted a key issue is that the investigations are not
currently being conducted in the most suitable way.
[Mr Roberts'] solution is forensic process.
“[Post Office] noted that where full investigations
are done quite often POL does get the repayment. The
issue is the investigation has to be good enough and
that it is independent ... the problem is that the data
is not sufficient to do an investigation in many cases.”
Then you are recorded as noting
“NR noted that ultimately those who steal from [Post
Office] will be prosecuted.”
So the questions arising from what was said by the
various parties at this meeting, did you agree with
Mr Cameron that it was “difficult to conduct a proper
investigation on the basis of the Horizon data"?
129
are shortfalls and where there are discrepancies. So
I think we have matured as an organisation in terms of
how we work with postmasters to identify what has gone
wrong. I still think we have more to do, invariably we
have more to do, but I think it has to be recognised
that this was not done properly and it has not been done
properly for many, many years and that's half of the
issue, so building a them that knows how to properly
interrogate and investigate Horizon data to come up with
an appropriate route through is something that we are
developing and learning and have been for the last four
or five years. It's clearly the whole Clu/HIJ findings,
whether we just were not doing this properly. So we're
making progress with this.
The third bullet point from the bottom ends in the last
line as saying:
“.. the problem is that the data is not sufficient
to do an investigation in many cases."
Why was it the Post Office's position that the data
is not sufficient to do an investigation in many cases?
I'm not sure of the genesis of that particular
statement.
It seems to accord with what Mr Cameron had been saying
in the second bullet point from the top?
Yeah, possibly. Possibly.
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No, I don't think that’s necessarily the case. I think
what he was alluding to was getting data from Fujitsu.
I think that's what he's implying.
It's not what's recorded as having been said ~
difficult to conduct a proper investigation based on the
Horizon data’.
Yeah.
The passage that's highlighted in the second bullet
point down. Do you know why ~
I'm sorry, I'm pausing because I'm just not sure whether
or not he was in a position to make that comment, as in
factually whether or not that was something he was
particularly aware of. I think we are confident today
that we have a mechanism for properly investigating
discrepancies so ~
i's
I'm going to come on to that. This is January 2023 --
Yeah.
~ and the CFO is saying it's difficult to conduct
a proper investigation based on Horizon data. What's
changed?
I think, you know, certainly from the maturity of the
teams that we've now got in terms of the way that we
have organised our Retail Teams to investigate, we are
much more confident in the way we can go about
an investigation and identifying, you know, where there
130
They seem to be the same thing, don't they: why was
Government being told it's difficult to do a proper
investigation, based on Horizon data?
I think what we saw at this particular time was
an escalation in potential liabilities as a consequence
of ~ well, losses were starting to grow in the network
and, not unsurprisingly, the shareholder were asking why
were losses growing in the network, and I think this was
the conversation that arose as a consequence of that
I think that was the primary.
The answer seems to be that it's difficult to conduct
a proper investigation based on Horizon and the data
from Horizon is not sufficient to do an investigation in
many cases, and I'm asking, was that true and, if so,
why?
Ihave to say, that's not necessarily my sort of my
conclusion. I think with a growing number of — with
a growing number of losses, we were trying to scratch
our heads as to why this was occurring.
That's a slightly different issue. I'm asking about why
Government was told, in answer to its reasonable
question, "Why are losses growing?", that's it's
difficult to conduct a proper investigation and the data
isn't sufficient to do so.
It's not my understanding, certainly now, that that is
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an issue for us.
Q. What new system was Mr Roberts putting in place?
A. We do a number of things. We set up two particular
schemes, I guess. We've been out to do operational ~
effectively operational training, so we're going out to
individual branches and doing operational visits to
those branches and we've also introduced an operational
incentive for post masters that is designed to encourage
them to follow the operational procedures for daily,
weekly and month-end transaction — month-end
reconciliations.
We've seen quite a significant increase since we
have gone out with effectively a carrot option, to try
and encourage postmasters to follow the procedures
correctly, which is what is happening.
So we went out and trained, effectively, all
branches individually, through our Area Managers and our
branch training teams, introducing them to and reminding
them of how procedures should be conducted, what the
mechanisms were for reconciliation, what the mechanisms
were for daily, weekly and monthly cash-end — end of
days, for want of a better word and, having done that,
we then established a system whereby we are
incentivising all branches on a monthly basis to fulfil
the process according to the operational manual
133
A. Not that I'm aware of, no.
Q. Thank you.
SIR WYN WILLIAMS: Sos it reasonable for me to infer that,
as of January 2023, that was thought of as a possibility
but it, in the end, turned out not to be —
A. That would be the ~
SIR WYN WILLIAMS:
A. That would be the case, sir.
SIR WYN WILLIAMS: Right
MR BEER: Mr Cameron is recorded as saying that
investigations were not being conducted in the most
suitable way.
Do you know how investigations were not being
since we're now in October '24?
conducted in the most suitable way at this time?
A. No, I'm surprised that Al had a view on that, to be
honest. My understanding of what is going on with the
Retail Team and how they are approaching the operational
effectiveness of our branches, the way they do — as
I said, the way they do training and support, and I use
the word "support" advisedly, is markedly improved. And
we can see that in the internal surveys that we've done,
with people who have experienced problems and issues and
have got in contact with the Branch Support Centre
and/or with the Branch Assurance Team or the review and
dispute.
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guidelines which is obviously something that hasn't
happened.
I think it probably plays to the comment about
training at the start of the survey, that we have more
to do in terms of training, particularly some of our
older post masters and some of those with longer service,
who perhaps didn't get the original training. I think
there is a lesson in here that says we will need to go
out in a more structured way to look at the older
postmasters, serving postmasters.
it was quite clear from this survey that those who
were more recently involved in the — recently joined
the Post Office have had better onboarding and better
training and better support.
What was the outcome of the paper relating to testing
fraud cases in a civil jurisdiction?
I don’t know the answer to that.
Is that something that is currently a planned route
within Post Office for addressing alleged shortfalls?
I don't have detail on that, I'm afraid.
So you're not aware of any plan —
No.
~ to use the civil courts ~
No.
~ as a means of testing cases of alleged fraud?
134
Would you agree that an important, indeed essential,
partner in any investigation into an alleged shortfall
is Fujitsu?
Yes, I would.
In paragraph 135(c), I wonder whether we could turn that
up, which is page 73 of your third witness statement,
page 73, and if we scroll down, please, and again. You
say:
"From Fujitsu's perspective, I think they are
suspicious of Post Office and my feeling is that they
consider some members of our Board are ‘anti-Fujitsu’.
Fujitsu recently sent Post Office correspondence raising
concems that they were being asked to give expert
opinion in prosecutions against postmasters, amongst
other matters -- that was not the case, and we reassured
Fujitsu that Post Office would never again prosecute
Postmasters, but we would comply with requests for
assistance from the police or CPS if asked which may
necessitate assistance from Fujitsu."
Then you give a reference to five lots of
correspondence:
“Again, I think that the correspondence was borne
out of a suspicion and distrust within the relationship.
It is also worth noting that Post Office has negotiated
with Fujitsu a standstill agreement in respect of [any]
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potential legal claims it may have against them, until
the end of the Inquiry."
I think the correspondence that you're referring to
there took place primarily between April and July this
year; is that right?
That's correct
It related to a criminal investigation being undertaken
by the City of London Police —
That's correct.
-- in which the Post Office had asked the City of London
Police to seek a witness statement from Fujitsu in
relation to an investigation into a subpostmaster; is
that right?
That's correct.
Post Office separately asked Fujitsu to provide that
witness statement?
Yes.
Thank you. Can we look at some of this correspondence,
the early parts of which you're not involved in but the
latter parts of which, you are.
FUJ00243203. Can we start, please, with page 3,
an email from Simon Oldnall, the Horizon IT Director, to
Daniel Walton, who is the Head of the Post Office
Account -- is that right --
That's correct.
137
year. With Christian Spelzini added in:
“One of my team has gone back to City of London
Police to see how the contract you referenced below was
progressing as we have an open and objective engagement
with [City of London Police] on this matter.
“[City of London Police] has informed us that they
have not had any additional information nor contact with
Fujitsu after the single, exploratory and inconclusive
conversation. They left that conversation with the
feeling that they were indirectly being told that the
Horizon system was unreliable and so the case could not
progress. We really need to explore this as this is not
the nuanced impression Simon Oldnall has given me.
“As the potential victim in this case [the Post
Office] would be grateful if you can provide me with
contact details for either the equivalent person in
Fujitsu ... to my role ... 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 ...
“Itis impossible to over state how important this
is: I need to advise both the police and [the Post
Office] as to the evidentially-established reliability
(or not) of data that is being used every day in
establishing outcomes with postmasters and, potentially,
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— within Fujitsu?
Yes, heis.
“Dan
“Iunderstand from John that there have been some
challenges with supporting an ongoing Police
investigation that involves a large sum of money.
"I obviously understand broader context, but wanted
to reassure that [Post Office] is supporting the police
investigation and offering any and all assistance we
can. Can I ask that you help with any conversations
that City of London Police need to have with Fujitsu
Then onto page 2, please, if we scroll up please,
a reply from Mr Walton back to Simon Oldnall, again
copied to John Bartlett, who was the John referred to in
the first email:
"Thank you for your message ...
“As this is a legal matter, [Fujitsu] Legal are
‘communicating with the City of London Police.
“Lam not involved in the discussions, and in any
event, [Fujitsu] considers it to be inappropriate for
Post Office and [Fujitsu] to be discussing a police
investigation."
Then page 1, please. And then scroll up.
Mr Bartlett joins the conversation on 19th April this
138
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] and Fujitsu will rightly be interpreted by the
police and prosecutors as [Post Office] and Fujitsu not
having faith in the reliability of the data with the
obvious outcome resulting.”
So that's, it seems, where the matter ended on
19 April. I think the next step in the chronology is
a letter from Mr Patterson to you, raising concerns in
relation to Mr Bartlett's email of 19 April. Is that
the first that you became aware of it: the Patterson
letter?
Yes.
Can we look at the Patterson letter, then. FUJ00243199,
This is a letter with which you'll be familiar, partly
because it’s been shown in the Inquiry before and partly
because you replied to it,
Yes.
He writes to you raising concems about Mr Bartlett's
email and essentially makes it clear, is this right,
that Fujitsu wouldn't support the pursuit of any
enforcement action, criminal or civil, against
subpostmasters, at least by the Post Office?
Yes.
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So if we just look at what's said, he is writing in
paragraph 1 to raise serious concems which indicate the
Post Office continues to pursue enforcement action
against postmasters and that it expects Fujitsu to
support such actions. Then this:
"To be clear, [Fujitsu] will not support the Post
Office to act against postmasters.”
Just stopping there, did you, and do you, understand
that broad statement to encompass alll and any action
taken against postmasters, whether by the police or by
the Post Office?
That was my inference, yes.
The letter continues, however:
“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.”
That may be a slightly narrower statement —
Itis, yes.
~-limited only to Post Office action against
postmasters?
I would agree with that.
Okay. He continues:
“In particular:
(i) Criminal investigations:
141
Horizon data as the basis for such shortfall
enforcement."
How did you react to that —
Badly.
-- quite strong statement?
Badly.
Why did you react badly to it?
Because it's not true, we aren't pursuing postmasters
for shortfalls, and I think the overall tone of the
letter was incendiary and provocative, and that was
certainly the reaction that it had in me.
"Postmaster Redress:
“[Fujitsu] recognises that it holds Horizon related
information that may assist postmasters and Post Office
workers to appeal convictions or seek appropriate
redress including compensation. [Fujitsu] has and will
continue to provide Horizon information", essentially to
that end.
[He has] asked Dan Walton to work with your team to
ensure this change is implemented, documented and
reported immediately.
"Based on what I have heard and seen in the Inquiry,
there is a significant behavioural and cultural aspect
to the Horizon scandal. As leaders of our respective
organisations, I believe we are both committed to learn
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"We have become aware of a recent investigation by
the [City police]. The approach of [Fujitsu] is to
cooperate with the police and any other third party
exercising independent investigative, prosecutorial,
regulatory or judicial powers.
"However, we are concemed by the behaviour of the
Post Office investigation [...] on this matter. That
team maintains an approach of Post Office as ‘victim’
and requires [Fujitsu] to provide a witness statement as
to the reliability of Horizon data stating that without
such [a] statement the case will not progress.”
I think that is a fair summary of the Bartlett
email, isn't it
A. Thatis, yes.
Q. "For the Investigations Team to act in this manner seems
to disregard the serious criticisms raised in multiple
judicial findings and indeed, exhibits a lack of respect
to the ongoing Inquiry.
"Pursuit of Shortfalls from postmasters:
"... Post Office may be continuing to pursue
postmasters for shortfalls in their accounts using
Horizon data. We would have expected that the Post
Office has changed its behaviour in light of the
criticisms and is appropriately circumspect with respect
to any enforcement actions. It should not be relying on
142
the lessons necessary so that this appalling scandal can
never be allowed to happen again."
Just shortly before the break, can I, for myself,
ask some broad questions?
A. Yes.
Q._ Given the history of the Horizon scandal, do you
consider that it is appropriate that the Post Office
continues its investigative function?
A. Yes, I think we still need to have an Investigations
Team.
Q._ Should the Post Office Investigation Team still be
carrying out recorded interviews?
‘A. Perhaps not in the way that we are doing at the moment
but, if they are for the purposes of sharing that
information, then fine. But in terms of the -- I think
the inference is that these are almost sort of police
orientated interviewing, then no.
SIR WYN WILLIAMS: In other words, there should not be
an investigation by the Post Office which includes, in
effect, an interview under caution?
A. Correct.
MRBEER: The name of these things has been changed, as
“assurance visits"?
A. Branch assurance visits. They are very, very materially
different. The only thing that a branch assurance visit
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does is count cash and count stock. It doesn't 1 our cash, they manage postmaster remuneration, they
investigate. Investigations are done by a completely 2 manage the transactions of our third parties in and out
different team. So we are very clear that there is 3 of our system.
a separation of accountability here. The Branch 4 I think it's entirely reasonable to rely on their
Assurance Team does stock checks, for all intents and 5 integrity and the integrity of the system, given what we
purposes, cash and stamps. The Branch Support and 6 pay and what we get from them.
Reconciliation Team will help investigate what the issue 7 MRBEER: With that answer, can we take a break? We will
is with those particular ~ in those particular 8 return after the break with, I think, some email traffic
circumstances. 9 that suggests that Fujitsu would provide a witness.
This statement refers, in that second paragraph on the 10 statement to the police.
page we're looking at, to a change being implemented; 11 SIRWYN WILLIAMS: Right. Thank you
can you see that? 12 MRBEER: Thank you
Yes, I can, yes. 13 SIRWYN WILLIAMS: What time shall we resume, Mr Beer?
What change did you understand was to be implemented: 14. MRBEER: 3.35, please, sir. Thank you.
from what and to what? 15 (3.19 pm)
I'm not entirely sure what change was being implemented 16 (Ashort break)
We'd been extremely clear and I was, certainly when 17 (3.37 pm)
I replied to Fujitsu, that we aren't prosecuting, which 18 MRBEER: Thank you, Mr Read.
is the major sort of consequence of this particular 19 Can we just go back, please, to FUJ00243203.
letter, but that we did expect them to support the 20 Do you remember, this was the exchange of emails
police and the law enforcement agencies. I think when 21 that you weren't copied into, which you said you didn't
I take a step back, I would say we pay hundreds of 22 know about, before you came to receive the letter of
millions of pounds to Fujitsu to manage our 23 17 May?
transactions, of which we do some 7 million transactions 24 You'll see that this finishes with Mr Bartlett's
every single day. They manage our stock, they manage 25 email of 19 April 2024, the "Good morning Dan" email,
145 146
which we looked at. 1 [Fujitsu] will continue to cooperate with the
Can we look now, please, at FUJ00243158, and go to 2 Police in relation to its ongoing investigation (or
page 2 and scroll down. There's in fact an extension to 3 indeed any other) and it will not discuss the nature and
this email chain, again, emails that you didn't see, but 4 substance of this engagement with others, unless the
Vl draw it to your attention. So you'll see that this 5 police directs this to happen.”
is the "Good morning Dan" email. 6 Then top of page 1, please, a reply by Mr Bartlett
Yes. 7 to that email:
If we scroll up to the bottom of page 1, you will see, 8 "We have had a call with [City of London Police]
at the bottom of page 1, Chris Breen, thank you. We can 9 following your email below and they will be in touch to
see a reply by Mr Breen to John Bartlett's email: 10 arrange the taking of a witness statement or statements.
“Dear Mr Bartlett ..." "1 We would be grateful for Fujitsu to extend any and all
So this is Fujitsu to Post Office: 12 assistance to the [City of London Police] to aid their
“I have been passed your message by the team within 13 objective understanding and assessment as to the
[Fujitsu] that looks after the delivery of contractual 14 reliability of the Horizon system and the admissibility
services to Post Office in relation to the Horizon 15 of evidence produced from it... to the investigation
system 16 they are conducting following {the Post Office] making
“Lam a solicitor in Fujitsu's Legal Team. Please 17 a crime report to them as a potential victim."
refer any further correspondence to me rather than 18 So taking the matter further than the exchange of
Mr Walton. 19 correspondence that we ended up on 19 April.
“I note your comments about [Fujitsu's] engagement 20 A. Yes.
with City of London Police, which are not accepted.” 21 @. Some further correspondence suggesting that there would
Then over the page. 22 be contact between the City of London Police and Fujitsu
“Itis not appropriate for [Fujitsu] to discuss with 23 about the possibility of providing a witness statement
[Post Office] the nature and substance of its 24 or statements.
cooperation with an ongoing police investigation. 25 We then come to the letter to you of 17 May. If we
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just go back to that, please. FUJ00243199, the
Patterson letter, as I've called it. We read through
that from start to finish —
Yes.
-- including your reflections on some of it. Was this
correspondence taken by you to the Board?
I shared it with Ben Tidswell and the shareholder
QP
>
representative, I think
What about to the Board more generally?
No, I don't think it went to the Board.
Why was that?
No particular reason. I think we've heard a lot about
information that goes up to the Board and information
that doesn't go up to the Board. There wasn't
a specific issue. I wanted to be certain that the
Pero
Acting Chair at the time and the shareholder
representative were aware, and that was as far as it
went.
Q._ Was this not significant information capable of
impacting upon the integrity of the business or at least
a critical relationship for the business?
A. [didn't really read it that way, no.
Q._ You were, I think, frustrated or worse with what your
partner was saying to you?
A. Yes, I was frustrated. Did that mean that I needed to
149
pursue postmasters for shortfalls ...
Then at the end of the paragraph:
“it [Post Office] should not be relying on Horizon
data as the basis for such shortfall enforcement."
Does the Post Office continue to rely on Horizon
data to pursue shortfalls from subpostmasters?
A. No, it doesn't,
Q._ What about the experience of Mr Jacobs, which rather
suggests that it does?
A. No, I think the situation with Mr Jacobs was exactly as
we discussed and described before, which is we worked
with -- well, once Mr Jacobs had started working with
the Retail Team, as indeed any postmaster would, who had
a shortfall, or a discrepancy, we all worked together
with the individual to see if we can resolve the
situation. And I think, as Mr Jacobs pointed out very
clearly, once that process began with the Retail Team,
he was very happy with the way that they engaged with
him and the way that they supported and helped him to
get a resolution to his problem
SIR WYN WILLIAMS: I understood that, that it had all worked
out in a business-like way, once that two-way
conversation had occurred. But it surely must be the
case that the starting point was the data provided by
Horizon, otherwise there would have been nothing to
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alert the Board to it? No, I don't think so. I think,
as I said in my witness statement, it's not an easy
relationship with Fujitsu for a multitude of reasons.
I think we all recognise and accept that. But,
ultimately, my relationship with Paul Patterson is
perfectly serviceable and transactional. I found this
particular exchange a surprise and I think, to be fair
to Paul, he reached out and tried to see if we could
resolve it, and I know Owen took him up on that. So,
you know, I think we moved on.
Didn't the position as described by Mr Patterson have
a considerable impact on the ability of Post Office to
pursue or to report alleged crimes against the business?
Yes, I mean I think the fact that my interpretation was
that they were unwilling to stand by the integrity of
their system and indeed unwilling, as I interpreted it,
to engage with the law enforcement agencies, I was
surprised. But, you know, having seen now some of the
‘emails that I wasn't copied into, that's not the
completely clear picture, I suppose. I think that they
are saying that they will be willing to do that, which
I think was encouraging.
If we scroll down in the letter, please, and under
“Pursuit of shortfalls":
“It seems that the Post Office may be continuing to
150
discuss? I'm not saying that in any critical sense.
No, no.
I'm just trying to analyse what occurred
No, I think that's fair. I think if you recall with
Mr Jacobs’ situation, some of the potential liabilities
went back a number of years, and so, therefore, it was
difficult to establish quite precisely what had
‘occurred, which is why we came to a situation where it
was only possible to identify £16,000 worth of losses
that he and we could naturally identify as being
a problem.
SIR WYN WILLIAMS: I suppose it's a good a time as any to
not ask you a question but just make a statement, which
is unusual for me.
But I am a little bemused about all of this debate
about the reliability or otherwise of the current
version of Horizon. Very early on in my role as Chair
of this Inquiry, I said that the judgments of Mr Justice
Fraser and of the Court of Appeal were, as far as I was
concemed, sacrosanct and not to be contradicted. Well,
unless I'm misreading it, one of the conclusions that
Mr Justice Fraser reached was that the version of
Horizon which was actually in use at the time of the
trial - and I have forgotten his precise words, but
this is my interpretation of it -- was reasonably fit
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for purpose.
I simply say that because we are having a great deal
of debate about current Horizon, which, at the moment,
doesn't seem to me to fit with one of the central
conclusions of Mr Justice Fraser's judgment in the
Horizon Issues trial, and so I want to know where I'm
going, having opened that up for you to all think about.
MR BEER: Yes, if I can be forgiven for offering —
SIR WYN WILLIAMS: An instant riposte? Yes.
MR BEER: An instant riposte.
He says, that is Sir Peter Fraser, a number of
things about current Horizon as at 2019, as disclosed by
the expert evidence, including that it is "relatively
robust”, in inverted commas, with —-
SIR WYN WILLIAMS: Well, these terms are no doubt wonderful
for debate but the general tenor of what he was finding
was as I've indicated. Now, I'm making no statement
other than that I have said that I regard what he said
as sacrosanct, insofar as it can be reasonably
interpreted, and yet, inevitably, as it seems to me,
there are streams and forces which are pushing me in
a direction away from that on that one issue. So I just
wanted everybody to remember what I've said and what he
said
MR BEER: Yes.
“Post Office's requests to use Horizon data may be
for any number of day-to-day business reasons, including
supporting postmasters in their branches ... in respect
of enforcement, [the] requests only relate to cases.
where our teams are supporting criminal investigations
or prosecutions pursued by independent third parties,
such as the police or {the CPS]. These independent
investigations may be initiated by (i) a third party,
(ii) by postmasters ... or indeed by a member of the
public ... or (ii) by Post Office."
Just stopping there, that doesn't bring into account
the use by Post Office of Horizon data in its own
investigations, does it?
A. No.
Q. “In response to this specific case you raised, potential
criminal activities were identified in the branch and
Post Office therefore reported the matter to the police.
We have assisted with the police's investigation,
including providing supporting data from the Horizon
system
“Naturally, it is vital to the police's
investigation that it can rely on the Horizon data it
has received. I am happy you have confirmed in your
letter that [Fujitsu] will cooperate with the police
when it is exercising its independent investigative
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You've told us that this wasn't taken to the Board,
this correspondence but you, in fact, yourself replied;
is that right?
That's correct.
Can we look at the reply, please. FUJ00243201. This
is, I think, your reply of 30 May: top right, yes?
Yes, that's correct.
You say that Mr Patterson makes number of concerning
statements about postmaster enforcement:
"... we share a commitment to learn lessons from the
scandal and to ensure that the appalling treatment
of postmasters, and the miscarriages of justice that
occurred, could never happen again."
Scrolling down:
[Post Office] has invested significant time and
resource effecting cultural and procedural change across
the business, taking on board the court's findings and
ensuring that our postmasters’ interests are central to
everything we do.”
Then "Criminal investigations":
"I can reassure you that the Post Office is not now
— and will not be in the future -- undertaking any
prosecutions against postmasters or any third parties as
the prosecuting body."
Then over the page:
154
powers as this case would require a statement from
[Fujitsu]. It is a matter for the police and [Fujitsu]
to determine the necessary content of the statement.”
Then in relation to his second point:
*... civil recovery of losses was stopped by Post
Office in 2018 so Horizon data is not currently being
used for civil recoveries from postmasters.”
Does that remain the case now?
Yes, it does.
Thank you:
“However, Post Office does rely on Horizon data for
a range of key day-to-day ... activities, including
supporting its post masters with resolving discrepancies
‘on their accounts."
Then you set out how that happens. Over the page,
please, "Postmaster redress"
“The reliability of Horizon data is central to the
compensation and redress schemes ... I welcome your
confirmations that [Fujitsu] will provide Post Office
with information to achieve redress at no charge, and
provide a credit note for any prior charges which have
been raised.”
Following this correspondence, this exchange of
correspondence with Fujitsu, what was your view as to
how any shortfall or discrepancy, based on Horizon data,
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could fairly be pursued by the business?
What do you mean by that particularly?
It's a deliberately broad question.
Right.
You've had an exchange of correspondence where
Mr Patterson has said, essentially, out of two of the
three activities that he mentions, Fujitsu will not
assist the Post Office in pursuing criminal proceedings
or civil recovery, at the same time has said that they
will assist the police —
Yes.
-- or other third party law enforcement agency?
(The witness nodded)
You have replied, not addressing some of those points
head on -
Mm-hm.
-- but explaining some assuring activity, or reassuring
activity, that the Post Office has undertaken in
relation to the first two categories.
Yeah,
Where did it, in your view, sit; what was the position;
what could be done by Post Office after this exchange of
correspondence?
It's a good question, I think there are couple of
things. One, I think we covered some common ground
157
previous correspondence was seeking to bring to your
attention concerning conduct exhibited by members of the
Post Office. He says:
“In simple terms, the Post Office is requesting that
[Fujitsu] give expert opinion .... to be used in criminal
proceedings against postmasters and Post Office
workers.”
He says that:
"... you rightly note that the content of any
witness statement is a matter between the police and
[Fujitsu]. [He] considers it necessary to address this
issue with you because the request was made by Post
Office and [he considers] the request to be entirely
inappropriate, particularly in the light of the evidence
being uncovered [in this] Inquiry."
He encloses with this letter an email chain, this is
the email chain we've looked at before the break ~
Yes.
-- which contains emails from a senior member of the
Post Office's Investigations Team, Bartlett to Walton:
"Mr Bartlett continues the prior narrative of seeing
the Post Office as the ‘victim’ and requests a witness
statement to address ‘the reliability of the Horizon
system and the admissibility of evidence produced from
it’ ... and suggests that a failure to do this would
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where law enforcement agencies and the Post Office and
Fujitsu would work together when there were organised or
large-scale fraud or issues. I think, with the sort of
specificity, your point is well made, which is, if the
police are able to rely on the data, then presumably the
data is accurate and that would be where I am,
certainly.
When it comes to the maturity of the organisation
and to whether or not it is going to pursue civil
actions against postmasters, I think, as I said at the
very start of the day, I don't think the business has
yet earned the right or the trust to do such things.
I think we're still learning and developing how to help
postmasters, both in terms of the quality of the support
we provide, and the quality of the training we provide.
So I think there is still more to be done, whilst,
at the same time, you know, we have to get ourselves to
a place where I think both postmasters and Post Office
feel confident that we have done everything we can to
ensure that the system and the training and the support
is appropriate, and that's obviously what we're
currently doing,
Mr Patterson replied. Can we look at FUJ00243204. On
8 July 2024, replying to your letter of 30 May 2024, he
explains at the end of his first paragraph that his
158
‘rightly be interpreted by the police and prosecutors as
[Post Office] and Fujitsu not having faith in the
reliability of the data ..."
He says:
“A.witness statement from [Fujitsu] attesting to the
reliability of the system and of data from it in
criminal proceedings would amount to expert opinion
evidence. [Fujitsu] is incapable of providing expert
opinion evidence as it is neither independent nor has it
sufficient information to provide such an opinion.
“As the Post Office is well aware, there have been,
and there continue to be, bugs, errors and defects in
the Horizon system. [Fujitsu] currently has, and
previously had, access to branch transaction records
Your letter ... acknowledges the existence of other
matters ... which could have operated to create innocent
discrepancies in branch accounts including '... miskeys,
or omissions when remitting cash or stamp stock based on
Horizon data ...' by end users.
*... the Horizon system is reliant on the delivery
of services by Post Office and third parties retained by
the Post Office. Therefore, records generated in
relation to its operation are not exclusively retained
by [Fujitsu]. The Post Office has appointed other
suppliers to manage aspects of the system such as the
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network and end user computing towers. Further, the
Post Office has insourced various services previously
provided by [Fujitsu] and other suppliers engaged by the
Post Office, including the Helpdesk and integration
services.”
Then over the page.
“[Fujitsu] considers that all of the matters
mentioned above would need to be investigated carefully
but the Post Office and the police, with the assistance
of an independent technical IT expert, and possibly also
a forensic accounting expert, to ascertain proper
explanations for branch account discrepancies ... only
after such an investigation has been undertaken could
a meaningful expert witness statement be made in ...
criminal proceedings which addresses the reliability of
the Horizon system. [Fujitsu] cannot provide such
a statement.”
So, just stopping there, leaving aside the meeting
that took place on 18 July, what did you understand
Fujitsu's position to be by this time, 8 July?
Yeah, I think we're going round the houses a little,
would be my observation. I think, taking a step back,
my expectation was that there would be one, two, three
maybe incidents/events of this sort of magnitude that
would require the police to engage with Fujitsu on very
161
it's very much up to the police and FSL to decide what
it is that is required or needed in whatever particular
circumstance occurs.
So I think there was a degree of cross purposes, in
terms of the engagement.
Even allowing for that, what did you understand
Fujitsu's position to be, at this point in time?
That they would engage with the police but they wouldn't
give a specific expert witness, and my understanding was
that they would obviously engage with them, but they
would engage with the police rather than Post Office
engaging with the police and engaging with FSL.
Thank you,
The meeting occurred on 18 July 2024 at Wood Street.
Can we look, please, at FUJ00243206. This is
Mr Patterson's own note of the meeting. It opened with
‘Owen explaining the absence of you, who was 100 per cent
focused on this. The COO joined the meeting, as he will
continue in post.
Then rolling down the page, please, about the fifth
paragraph on this page:
“To be clear Fujitsu will not provide expert witness
statements and will only work when requested [by] the
police ..."
Was that conclusion one that was fed back to you?
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specific issues, and I don't think a sort of blanket
expert statement was necessarily what we were trying to
achieve; we were trying to achieve a situation where
Fujitsu would cooperate with law enforcement agencies.
Just stopping there, I'm sorry to interrupt an answer
which I'm conscious I'm doing —-
Yes.
— you said that there would be one, two or three, or
maybe, I think, four occasions, on which ~ is that
because —
Because of the ~
Why is that?
Because of the scale of what we're discussing here is —-
and I think I said at the very start of the day, our
expectation is that where there is organised crime,
where there is fraud, where there is money laundering,
issues of that nature reported either by the Post Office
or by the branch or by postmasters, they would be very,
very small in number, and my expectation would be that,
Fujitsu would be willing to engage with the police on
whatever it was that they needed. So I think there's
a degree of cross purposes, in terms of some of the
engagement, and I suspect that Fujitsu felt that they
were being directed, to a degree, by John Bartlett in
terms of what they should or shouldn't do, and I think
162
Yes, it was.
Then, if we carry on scrolling down, please, over the
page: that's the end. That appears to be the only part
that concems provision of evidence ~
Yes.
~is that right?
I think so.
Can you recall what else was fed back to you as a result
of that meeting?
I spoke with Owen about the meeting, he said it was very
cordial. He said it was ~ that Paul was very
reasonable in terms of the issues that were at play,
that, actually, it moved fairly quickly on to the
concept of an extension, rather than being inclusively
focused on Fujitsu's position with providing expert
witness statementsirequests from the police.
Then I think Mr Woodley wrote to Mr Patterson,
essentially in response to Mr Patterson's letter of
8 July —
Yes.
~ and following this meeting?
That's right.
FUJ00243209. Scrolling down, paragraph 1 refers to the
Patterson letter, number 2, and the meeting. There's
a statement from Mr Woodley, as acting CEO, of shared
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commitments. He says that he was concerned by some of
the points raised in the letter of 8 July. There was
some misunderstanding, having talked them through.
Scrolling down, under "Expert evidence":
“Your letter said that Post Office was requesting
that Fujitsu give expert evidence ... That was not the
case. As you rightly say, [Fujitsu] is not able to
provide expert opinion evidence as it is not
sufficiently independent for any statements that it may
provide to be deemed expert evidence by the Crown
Prosecution Service. Post Office is aware of that and
has not/would not request that [Fujitsu] provides expert
opinion evidence."
So there seems to be a meeting of minds there?
Yes.
Over the page:
“[The Investigations Team] has been supporting
a police investigation into a significant financial
crime identified in one of our branches ... data from
the Horizon system has been shared with the police by
Post Office. The police have raised questions regarding
the data and [the system], and the [Investigations Team]
referred the police to [Fujitsu] -- as [the] provider of
the system ... The feedback they [the police] received
in April 2024 was that the police had only been able to
165
‘victim’ in correspondence with [Fujitsu]... while this
may be a legally and factually accurate description, it
does not reflect the change in Post Office's attitude
towards postmasters.”
Then (3), shortfalls:
“Thank you for confirming that [Fujitsu] will
continue to deliver its contractual obligations
including reporting promptly and transparently on branch
impacting incidents."
Next paragraph:
“While Post Office does not currently take civil
recoveries action to recover established losses ... this
may be necessary in future to establish a fair,
transparent and consistent approach ... this would only
be undertaken in future with the wide endorsement of the
Postmaster community and robust independent assurance.”
I think you've told us today that that is not
presently contemplated; is that right?
That's correct.
He welcomes the commitment that Fujitsu will work
collaboratively with the Post Office over the coming
months.
Then lastly in this chain, FUJ00243211,
Mr Patterson's reply to Mr Woodley:
“It is unfortunate that Nick was not able to attend
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have one conversation with [Fujitsu] at that time and
that the investigation officer's impression from that
conversation was that they were indirectly being told by
[Fujitsu] that the Horizon system was unreliable. As
a result, the police told the [Investigations Team] the
investigation could not progress.”
As a result, Mr Bartlett sent the email of 19 April
He was not asking Fujitsu to act as an independent
expert witness. He asked that Fujitsu engage with the
police and provide a statement regarding the reliability
of data. Fujitsu has confirmed that it will further
engage with the police on this matter.
So that seems to remove, would you agree, some of
the confusion, as it's been put, or misunderstanding.
Yes, I think so.
*(2) Criminal investigations and prosecutions."
There is essentially a restatement of what was said
in an earlier letter under 1, 2 and 3. If we go over
the page, please:
To get the right checks and balances in any of
these investigation processes, data will be required
from [Horizon] along with analysis of any known bugs,
defects or errors ... Thank you for confirming that such
data will be provided
“We discussed that Post Office had used the word
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the meeting ... The original purpose of writing to Nick
was to escalate, CEO to CEO, the concerns relating to
certain behaviours within the Post Office ... the Post
Office continues to have significant cultural issues,
sees itself as a ‘victim’ with the enforcement and
prosecution of postmasters considered as a business as
usual activity of a commercial retail company ...
Fujitsu finds the language and the suggested behaviour
unacceptable from Post Office's investigators.
"I do not intend to engage further with the Post
Office on the matters I raised ..
"You will recall, I have stated publicly Fujitsu
does not wish to extent the contract with Post Office
and your letter has reinforced the challenges we have as
an organisation with continuing to do business with the
Post Office."
Just stopping there, where did this leave
investigations that were ongoing?
I haven't had an update. I'm not fully aware of what
the next stage was, whether Owen responded to Paul or,
indeed, what the situation is with their support of the
police. That hasn't been fed back to me
What's the current state of play, therefore, in relation
to obtaining evidence from Fujitsu in support of either
investigations or in support of investigations or
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prosecutions being conducted by third-party LEAs?
Again, as I say, I haven't had an update since this
letter, so I can't give you that answer, I'm afraid
Was any of this correspondence taken back to the Board?
Again, I'm not aware of whether it was or not, I'm
afraid
By you?
Well, it wasn't by me, no, because ~ obviously as I've
stepped back because I've been working on this matter.
This would be, obviously, an activity for the Acting
CEO.
Was the Board, to your knowledge, aware of Post Office's
involvement in the City of London Police investigation?
I think, as we said at the very beginning, my
involvement was certainly to bring the Acting Chair and
the shareholder representative into the loop. I am
unaware of whether or not this was shared with the Board
in July or, indeed, in September.
Are you able to say whether the Post Office's current
investigative function is fully compliant with all
relevant legal standards?
As far as I'm aware, yes.
What's the current position, therefore, in relation to
obtaining evidence from Fujitsu?
As I say, I haven't had an update since this exchange.
169
report in an evidential format which shows why you
believe the Horizon system in place at {that post
office] was reporting correctly ~ the CPS will
inevitably want the same."
Then scrolling up, please, reply from Mr Morley,
a Senior Investigations Manager in the A&CI team:
“While I work through the information required can
I request that in response to item 1 and 2 below that
you obtain a statement from Chris Breen who is the Legal
Manager -- Litigation Europe for Fujitsu..."
Then some details are provided:
“As you may be aware Fujitsu are the company that
supply the Horizon software and are therefore best
placed to address the points you raise.”
So this is the A&CI team directing the police to
Fujitsu asking for a statement as to Horizon's
robustness and whether the system installed at this
branch, in I think it was 2020 or 2021, was the HNG-A.
system
Then scrolling up, please, you will see an email to
Fujitsu, to Mr Breen, so the detective constable
followed the suggestion made by the A&CI team. You'll
see what is said in the first two paragraphs, which are
sort of introductory:
“Are you able to assist by providing a written
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So I'm — going back to what it said earlier in the
email, I'm assuming that they are continuing to
cooperate with the police as they said they would
Can we look, please, at a separate train of
correspondence starting with FUJ00243191, starting with
page 3, please. If we just pan out a little bit,
please, and scroll down. Thank you,
it's an email from a Detective Constable Edwards in
Lancashire Constabulary’s Economic Crime Unit. If we
just look up, please, to the bottom of the next page,
it's addressed to Mr Morley, who we will in due course
see is in the A&Cl team?
That's correct.
"Good afternoon Andrew.”
So this June 2024.
"... could I ask that you/your Legal Team provide
the following:
"1) Documentary evidence which will confirm/verify
that more robust [I think that's ‘the more robust’)
Horizon [Online] was installed on the systems at [Blank]
post office from 2021. I appreciate your letter
confirms the same, but is there any documentary
evidence/records which show it was installed
"2) As the letter suggests are you able to get the
ball rolling to prepare and provide a formal statement!
170
statement dealing with points 1 and 2 ... below?"
So it seems that Fujitsu is receiving requests for
witness statements, or at least a witness statement from
another police force, whilst the exchange was going on
between those higher up the organisation --
Mm.
— both in Fujitsu and Post Office.
Mm-hm.
Did you become aware of this operation, which was called
Operation Jetfire?
No, I'm not familiar with it.
Were you aware of any investigation like this being
undertaken?
No, as I say, I wasn't aware of this investigation,
You said earlier, and it's reflected in some of the
written evidence, that a Board approval was required?
Yes.
Board approval for what?
Sharing information -- well, bringing to the table
information associated with interaction with law
enforcement agencies on specific issues.
If we just scroll up, please, you'll see this is the
24 July 2024, whilst the correspondence between you and
Mr Patterson and then Mr Woodley and Mr Patterson is
‘ongoing.
172
(43) Pages 169 - 172
OYE ARON A
The Post Office Horizon IT Inquiry
What steps were taken to ensure that those in the
A&CI team understood the nature of the relationship and
the limits of the relationship as between Post Office
and Fujitsu on the provision of Horizon evidence?
A. Personally, I haven't been involved in that activity,
but I am ~ I would be -- it would be obvious to ask the
General Counsel who looks after that particular function
to bring that to life, but I am not aware of what kind
of briefing they will have received.
Q._ Can we look, please, at FUJ00243192. This is a letter
to that detective constable, who on this version has
been redacted, I think:
“Post Office Legal have reviewed the reasoning for
not progressing ... to a charging decision.”
Scrolling down:
. not for Post Office to influence the
independence of the situation ... however the reasoning
around the credibility of the Horizon system seems to be
a significant factor ..."
Just for context, this was a letter saying "We're
going to NFA", take no further action:
“[Post Office] have been asked to address three
questions in respect of the decision to [take] No
Further Action ... [Post Office] hopes that the
information provided below
4173
is sufficient to assist
SIR WYN WILLIAMS: Are you going to cause me to resile from
or amend what I said earlier?
MR BEER: Well, I knew this was coming, sir.
You can see some passages which are, in my words,
lent on. Extracts from, for example, paragraph 964 of
the Horizon Issues Judgment and the relevant passages
are in bold, findings in relation to Legacy Horizon from
2000 to 2010, and then of Online from 2010 to 2018 are
not findings on the Horizon system, as it exists at the
date of the judgment. They cannot be routinely applied
to the way HNG-A operates, as at December 2019:
“Itis agreed by the experts that the Horizon System
in its HNG-A form is now relatively robust.”
Hence my answer to the point raised earlier.
Then carrying on over the page —
SIR WYN WILLIAMS: I can't help it. I love phrases like
“relatively robust". You could argue about them until
2030.
MR BEER: Yes, there's another variant on that theme, and
it's in bold, three lines in, where Mr Justice Fraser
says:
“HNG-A is a different matter, and the experts are
agreed that it is far more robust than Horizon in
earlier times."
Then another variant on that theme, paragraph 969,
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with the review of that decision.”
Then the three questions:
*... new Horizon is much more reliable than the old
system
“evidence that a Court has ruled so ...
“new system was installed and in place at the
[Blank] post office from 2021 onwards.”
Then, over the page, question (c) is answered:
"[The] branch was operating the HNG-A version of
Horizon."
Then questions (a) and (b) -- this letter goes on
for many pages, setting out extracts from the Horizon
Issues Judgment of Mr Justice Fraser -—
Right
— in answer to the question: which legal case
establishes or proves that the current Horizon system is,
reliable? You see that?
Is this is an approach that you, as Chief Executive,
knew was being taken, ie leaning on the Horizon Issues
Judgment?
Iwas unaware of that. I am unaware of this level of
engagement, candidly.
I'm not going to spend time now going through all of the
passages in this letter; it's there for the Chairman and
to others read. You can see --
174
again in bold, Mr Justice Fraser said in relation to
HNG-A:
"... the experts agree is a better system than
either of the other two iterations of Horizon."
Then carrying on, Mr Justice Fraser's finding at
paragraph 974 and 975 is set out:
*... [ave found that the system as it is in 2019
is far more robust than it was prior to 2017."
Then the letter leans on some explanatory notes to
the exoneration bill, essentially.
Were you aware of this approach that was being
taken ~
No, I wasn't.
~ ie picking out some extracts from Mr Justice Fraser's
judgment as evidence of -
I wasn't -
~ of the current reliability of Horizon?
No.
Was that a Board-sanctioned approach?
Not that I'm aware of.
Was it a General Executive sanctioned approach?
Not that I'm aware of.
I think it therefore follows that you didn't investigate
or cause to be investigated the extent to which extracts
from a judgment in civil proceedings could be used as
176
(44) Pages 173 - 176
OYE ARON A
The Post Office Horizon IT Inquiry
evidence in criminal proceedings --
A. No.
Q. -to prove the reliable of the system?
A. No.
MR BEER: Thank you.
Sir, that's the end of that topic and the end of my
questions for today.
‘SIR WYN WILLIAMS: All right.
MR BEER: Can we reconvene at 10.00 tomorrow, please, unless
you have any questions.
SIR WYN WILLIAMS: No, I have no questions.
MR BEER: I could sense one brewing.
SIR WYN WILLIAMS: No, no, no, it’s not a question. I was
simply going to say that perhaps I should amend my
statement to say that Mr Justice Fraser's judgment will
be sacrosanct once I decide what it means. Thank you.
(4.25 pm)
(The hearing adjourned until 10,00 am the following day)
477
INDEX
NICHOLAS JAMES READ (sworn)
Questioned by MR BEER .....
178
INQ00001193
INQ00001193
9 October 2024
(45) Pages 177 - 178
INQ00001193
INQ00001193
MR BEER: [29] 2/4
2/8 23/2 23/5 33/10
52/21 54/20 54/23
55/2 62/22 94/6 94/18
94/20 94/24 124/17
135/10 144/22 146/7
146/12 146/14 146/18)
153/8 153/10 153/25
175/3 175/19 17/5
177/9 177/12
SIR WYN WILLIAMS;
[42] 1/3 2/5 22/21
22/25 23/4 32/17
32/21 33/4 33/9 52/9
52/12 52/16 54/22
61/2 61/11 61/23 94/8
94/13 94/17 94/19
123/24 124/5 124/9
124/11 124/14 124/16
135/3 135/7 135/9
144/18 146/11 146/13
151/21 152/3 152/12
153/9 153/15 175/1
175/16 177/8 177/11
177/13
THE WITNESS: [1]
22/24
"22 [4] 105/13
"24 [2] 83/19 135/7
1] 136/11
i-Fujitsu' [1]
136/11
‘as [1] 64/2
‘Benefits [1] 49/1
‘brief [1] 56/24
‘conscience’ [1] 45/6
“guilty [1] 63/8
‘is [1] 64/12
"No [1] 64/3
‘old [1] 56/16
‘Only [1] 64/12
"PCDE' [2] 46/9 46/22)
‘rightly [1] 160/1
"sunset! [1] 14/5
‘the [2] 159/23
170/19
‘untouchable’ [2]
75/17 77/6
‘victim’ [4] 142/8
159/22 167/1 168/5
‘we [1] 64/21
= it [1] 64/11
-- who [1] 67/18
«' [2] 160/3 160/19
1
1 million [3] 56/14
58/18 59/13
1 October [1] 65/9
1,000 [3] 117/12
117/14 126/9
4,700 [4] 4/7 4/9 87/9
88/3
10 [3] 9/16 29/13
116/18
10 January [3] 55/15
63/3 127/15
10 per cent [1]
115/20
10 years [1] 59/12
10,000 [1] 122/12
10.00 [3] 74/23 177/9
177/18
10.03 [1] 1/2
100 [2] 44/12 44/14
100 per cent [1]
163/17
100,000 [2] 108/13
109/11
107 [1] 65/9
108 [1] 4/4
109 [1] 65/10
11 [2] 14/16 117/25
11,500 [2] 82/17
122/14
11.35 [1] 54/24
11.50 [1] 54/21
11.52 [1] 55/1
11.58 [1] 76/9
12 [4] 9/22 14/24
29/13 30/4
12.57 [1] 94/21
13 [5] 13/22 22/17
23/10 39/22 96/14
13 September [1]
3/14
130,000 [1] 70/7
132 [1] 2/19
132 pages [2] 2/15
2/18
135 [1] 136/5
14 [3] 22/17 23/10
30/4
14 January [1] 63/4
14 per cent [3]
115/19 119/11 125/22)
140 [1] 4/10
142 [1] 4/16
142 pages [1] 3/14
144 [4] 26/17
15 [2] 11/19 117/8
15 per cent [5]
115/25 115/25 121/18)
123/2 123/3
15,000 [2] 58/17
59/12
16 [3] 14/2 30/4
117/16
16,000 [3] 58/24 59/5
152/9
17 [5] 72/23 90/13
97/11 117/4 118/10
47 May [2] 146/23
148/25
17,000 [1] 97/7
174 [1] 40/6
48 [1] 69/20
18 July [2] 161/19
163/14
18 per cent [1] 117/4
48 September [1] 7/9
48th [1] 74/17
49 April [5] 140/9
140/11 146/25 148/19)
166/7
19 per cent [1]
115/17
198,000 [1] 58/20
1999 [1] 97/19
19th [1] 138/25
ix}
2 September [1] 2/14
2.00 [2] 94/18 94/23
2.4 [1] 106/6
20 [1] 34/14
20 years [3] 24/20
24/22 118/41
200 [2] 117/13
117/13,
200,000 [1] 11/13
2000 [1] 175/8
2001 [1] 1/15
2010 [2] 175/8 175/8
2013 [4] 20/12 22/5
22/13 97/20
2014 [2] 63/3 63/4
2015 [4] 15/12 20/11
22/4 22/12
2016 [1] 35/20
2017 [2] 44/17 176/8
2018 [3] 11/20 156/6
175/8
2019 [22] 7/7 13/3
18/6 18/25 20/10 22/5
23/15 23/16 24/5 27/4
27/7 27/16 28/7 32/22
34/2 34/20 35/20
116/2 122/2 153/12
175/11 176/7
2019/2020 [1] 54/17
2020 [9] 33/13 37/6
37/8 38/7 54/17
116/21 117/3 117/11
17118
2021 [15] 3/22 3/23
4/2 37/17 43/14 45/24
53/14 54/7 54/12 95/2
95/3 105/14 170/21
171/18 174/7
2022 [7] 3/25 4/2
90/14 95/22 105/4
106/2 106/5
2023 [10] 55/22
55/23 61/17 61/24
62/23 111/6 111/10
127/15 130/16 135/4
2024 [15] 1/1 2/15
62/22 66/20 85/18
86/3 89/18 120/20
146/25 158/24 158/24)
163/14 165/25 170/15)
172/23
2025 [1] 7/11
2030 [1] 175/18
21 [4] 98/10
21 years [1] 116/24
22 [2] 14/17 98/14
23 [4] 14/24
231 [1] 4/4
237 [1] 55/10
239 [1] 55/10
24 [1] 98/23
24 August [1] 95/21
24 hours [1] 81/23
24 July [1] 172/23
24 September [1] 5/2!
243 [1] 74/1
25 [1] 9/17
25 November [1]
55/23
25 per [1] 115/5
25 per cent [3] 115/6
115/10 117/5
26 [1] 3/8
26 pages [1] 3/5
27 [3] 36/25 39/21
87/6
27 September [2]
106/2 106/5
28 [5] 3/16 23/11
23/14 36/25 116/17
3
3 September [1] 3/4
3.19 [4] 146/15
3.35 [4] 146/14
3.37 [4] 146/17
30 May [2] 154/6
158/24
305 [1] 4/10
307 pages [1] 5/16
34 [1] 23/14
31 per cent [1] 116/6
32 per cent [1] 116/4
32 years [1] 44/18
35 [6] 87/2 88/21
90/3 90/10 91/12
91/15
39 [1] 117/13
4 months [1] 37/16
4 September [2]
27/16 28/7
4-month [1] 35/5
4.2 [1] 107/17
4.25 [1] 177/17
4.3 [1] 107/21
4.5 [1] 116/17
40 [8] 64/18 65/4
66/1 66/14 66/15
66/16 90/7 90/7
40-plus [1] 90/3
42 per cent [1] 115/9
44 [1] 34/15
47 [1] 69/25
48 [1] 64/17
48 per cent [1] 116/5
5
50 [1] 117/12
500 [1] 9/12
52 per cent [1]
116/13
55 per cent [2] 116/3
116/15
57 per cent [1]
115/15
o
60 per cent [1] 116/9
61 [1] 37/1
61 per cent [1]
116/25
62 [1] 37/13
64 [1] 3/16
65 per cent [1]
115/22
68 per cent [1]
115/14
69 per cent [1]
116/18
7
7 million [1] 145/24
7,000 [1] 11/12
70 per cent [1]
115/12
700 [2] 4/6 4/9
72 per cent [1] 116/8
73 [2] 136/6 136/7
74 [1] 117/24
74 per cent [3]
116/11 118/11 126/11
75 per cent [1] 115/7
8 July [4] 158/24
161/20 164/19 165/2
8 per [1] 117/13
8.00 [1] 67/19
80 [1] 26/16
82 per cent [1] 118/1
83 per cent [1]
116/24
84 [1] 40/6
85 per cent [1] 126/7
89 [1] 117/9
9
9 October [1] 1/1
9,999 [1] 117/15
(46) MR BEER: - 9,999
INQ00001193
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9 accord [1] 131/23 29/13 45/7 45/18 10/14 38/13 38/19 118/23 121/5 123/7
964 [1] 175/5 accordance [1] 96/4 I 47/11 53/16 59/2 59/5I 39/2 41/12 44/13 133/16 133/24 138/9
969 [4] 175/25 according [1] 133/25I 61/3 61/14 80/15 49/22 53/1 53/6 62/23] 141/9 145/5 148/11
974 [1] 176/6 account [7] 4/21 99/19 110/20 152/23 I 68/15 87/6 90/24 150/4 151/14 151/21
975 [1] 176/6 56/13 59/2 98/5 164/13 109/20 136/7 136/16 I 152/15 153/7 161/7
98 [1] 117/18 137/24 155/11 161/12Iadded [2] 128/11 136/22 138/14 144/2 I 169/20 174/23 177/8
999 [4] 117/13 accountability [1] 139/1 147/4 154/13 169/2 Iallegation [6] 43/10
I 1454 addition [1] 28/22 169/5 176/1 48/24 51/11 86/23
A accountable [2] additional [3] 1/18 Iagainst [23] 18/17 88/10 90/24
ability [2] 77/8 127/24 128/22 71/11 139/7 19/18 44/5 54/11 55/4I allegations [27] 10/3
150/12 accounting [2] address [16] 13/18 I 60/18 73/22 92/21 10/7 41/2 41/15 42/5
able [9] 49/16 117/19 141/17 161/11 22/14 36/19 42/5 101/4 106/24 126/20 I 49/3 49/9 49/16 58/3
158/5 165/7 165/25 accounts [7] 33/20 I 45/25 46/13 49/16 136/14 137/1 140/23 I 67/18 68/8 69/23 70/5)
1467/25 169/19 170/24I 60/7 62/4 63/17 53/2 74/24 75/24 83/5) 141/4 141/7 141/10 I 70/21 71/17 71/21
171125 142/21 156/14 160/17I 96/8 159/11 159/23 I 141/15 141/20 150/13) 73/17 73/22 79/13
about [93] 13/14 accuracy [1] 99/2 171/14 173/22 154/23 158/10 159/6 I 80/25 86/13 86/14
14/20 15/4 16/18 accurate [4] 44/13 I addressed [14] agencies [12] 70/14 I 92/22 93/7 93/20
46/18 18/1 20/19 21/1] 61/20 158/6 167/2 11/17 37/20 43/16 107/8 107/12 109/6 I 106/10 107/4
25/17 25/17 28/9 achieve [5] 24/21 44/3 48/11 50/21 59/8) 112/16 113/11 140/2 I alleged [12] 55/4
28/12 34/6 35/14 26/20 156/20 162/3 I 60/12 69/8 80/4 80/23) 145/21 150/17 158/1 I 55/7 56/10 60/8 62/9
35/16 35/19 41/11 I 162/3 80/23 96/1 170/11 I 162/4 172/21 107/24 118/21 134/19)
43/17 43/20 46/22 [achieved [1] 38/17 Iaddressee [2] 51/2 agency [1] 157/12 I 134/25 136/2 141/16
48/18 49/3 51/14. [achievement [1] 98/4] 52/22 agenda [2] 127/10 I 150/13
54/20 55/15 55/17 acknowledges [2] _Iaddresses [1] 161/15) 128/16 allow [3] 46/12 96/24
56/9 56/16 56/23 57/6) 40/12 160/15 addressing [6] 5/13 Iago [7] 34/22 56/23 I 106/9
58/2 58/18.59/13 across [6] 26/12 _I 38/20 61/3 78/6 62/16 66/5 66/10 73/2I allowed [3] 64/19
61/17 68/7 68/11 27/13 39/8 109/1 134/19 157/14 77/11 68/25 144/2
69/21 69/25 74/13 I 110/11 154/16 adjourned [1] 177/18I agree [18] 6/14 13/12I allowing [1] 163/6
75/15 77/24 79/2 \act [12] 43/8 47/3 I Adjournment [1] 24/4 39/16 56/9 100/8I alluding [2] 104/22
80/14 80/21 81/1 47/9 49/2 64/1 95/11 I 94/22 100/12 100/19 100/24] 130/2
81/14 81/14 81/14 102/22 106/9 113/7 Iadministering [2] 105/16 110/6 118/19 Ialmost [1] 144/16
gi/19 82/19 83/16 I 141/7 142/15 1686/8 I 88/1 88/18 127/8 129/23 136/1_ alone [2] 6/22 36/14
90/13 94/15 95/2 Act’ [1] 49/1 administration [2] 141/22 166/13 176/3 Ialong [1] 166/22
95/15 103/15 111/2 Iacting [6] 100/19 9/11 101/10 agreed [10] 24/18 already [4] 13/6 17/3
1714/3 115/1 121/8 I 121/9 149/16 164/25 I admissibility [2] 28/22 28/25 58/22 I 64/13 114/24
4122/5 122/6 122/7 I 169/10 169/15 148/14 159/24 93/24 100/18 123/22 Ialso [19] 8/17 10/15
422/8 122/14 122/23 [action [16] 18/16 —_Iadmit [1] 100/9 127/10 175/12 175/23] 13/16 18/21 19/22
423/11 123/11 124/6 I 22/3 39/16 39/17 41/7I admitted [1] 47/6 Iagreement [4] 35/9 I 25/14 36/21 64/5 66/5I
424/24 125/5 125/10 I 58/8 66/24 81/25 I adopt [1] 39/9 73/13 123/16 136/25 I 69/15 91/10 93/15
425/11 125/11 130/24] 115/2 140/23 141/3 Iadopted [1] 33/16 [Ah [2] 2/23 46/18 —_I 93/17 125/2 128/1
432/20 134/3 140/20 I 141/9 141/20 167/12 Iadopting [2] 31/25 aid [1] 148/12 129/6 133/7 136/24
446/22 147/20 148/23) 173/21 173/24 78/14 aide [2] 27/19 30/8 I 161/10
1449/9 149/12 151/8 Iactions [12] 3/19 advice [3] 49/19 Al[1] 135/15 Alternatively [1]
152/15 152/16 153/3 I 3/24 29/3 40/9 42/22 I 50/22 50/24 Alan [1] 25/10 53/16
4153/7 153/12 154/9 I 45/8 76/17 126/20 _ advise [3] 46/19 _Ialbeit [2] 48/11 98/5 Ialthough [3] 15/8
463/20 164/10 175/17] 141/5 141/15 142/25 I 46/21 139/22 alert [1] 150/1 49/9 94/13
above [4] 47/7 77/22 158/10 advisedly [1] 135/20 IAlex [3] 34/25 35/14 Ialways [2] 76/17
78/2 161/8 actively [1] 50/18 I affect [1] 92/14 37/2 128/14
absence [1] 163/17 {activities [9] 16/2 affected [2] 45/9 [align [1] 99/22 am [26] 1/2 40/3 41/9
absent [1] 86/23 87/13 87/17 92/2 88/17 aligned [2] 35/2 35/7 I 41/12 45/20 53/15
absolutely [12] 5/23 I 108/3 108/7 155/16 affecting [2] 123/10 IAlisdair [1] 127/19 I 54/19 54/24 55/1 56/4
13/9 39/17 42/20 I 156/12 187/7 124/25 alive [1] 54/13 56/22 57/3 71/23
42/21 43/2 57/24 _ [activity [26] 3/18 afford [1] 34/19 all [58] 1/20 1/21 __I 73/20 75/18 83/10
62/11 81/7 82/6 20/11 22/3 22/5 22/16Iafraid [4] 110/25 I 1/23 5/11 6/2 15/15 _I 138/20 147/17 152/15
120/23 122/93 41/14 42/6 58/11 61/1I 134/20 169/3 169/6 I 18/2 22/22 23/4 28/20) 155/23 158/6 169/16
AC [1] 127/18 69/9 69/16 72/3 88/7 Iafter [14] 9/7 27/16 I 29/20 41/3 42/2 44/4 I 173/6 173/8 174/21
accept [2] 22/10 89/1 91/2 98/3 104/11) 44/17 79/17 83/19 44/13 44/19 56/18 177/18
1450/4 108/19 109/13 112/12] 89/19 92/11 108/10 I 56/24 57/7 57/18 Amanda [1] 56/15
accepted [4] 15/18 112/20 157/17 157/18] 139/8 146/8 147/14 57/21 57/23 57/24 ambit [2] 97/2 97/7
16/9 33/16 147/21 168/7 169/10 173/5 I 157/22 161/13 173/7 I 61/16 64/5 64/11 76/4Iamend [2] 175/2
accepts [1] 40/15 acts [1] 108/18 afternoon [2] 94/25 I 79/13 82/16 84/5 84/5I 177/14
access [2] 123/3 [actual [3] 44/8 87/22 I 170/14 88/22 106/20 107/19 I among [2] 97/21
160/14 107/2 afternoon's [1] 68/23I 112/21 113/1114/7_ I 117/25
actually [15] 2/21 {again [26] 3/5 8/22 I 117/8 117/16 117/17 Iamongst [13] 18/8
(47) 964 - amongst
INQ00001193
INQ00001193
A 152/12 154/22 154/23I approval [5] 6/20 175/1 175/4 175/7 associated [15] 8/15
amongst... [12] 23/18 155/2 156/21 156/25 I 6/20 77/13 172/16 175/8 175/22 67/8 87/14 88/8 89/1
24/11 25/20 26/23 159/9 165/9 166/20 I 172/18 area [4] 60/21 110/13} 89/7 103/19 103/23
31/18 31/20 38/8 166/22 169/4 170/22 Iapprove [2] 110/21 I 125/17 133/17 109/7 111/22 112/11
47/15 83/23 86/4 172/12 177/10 112/23 areas [4] 11/8 14/4 112/20 123/18 125/12)
95/24 136/14 anybody [4] 41/5 approximately [1] 66/9 71/15 172/20
amount [6] 59/14 83/22 89/12 92/6 122/14 aren't [3] 42/9 143/8 Iassociation [1] 60/23)
63/24 118/16 122/16 anything [7] 41/15 I April [10] 1/15 61/6 145/18 assume [2] 48/13
422/16 160/7 47/22 65/1 84/11 137/4 138/25 140/9 Iarguably [1] 92/10 73/11
amounted [1] 7/22 88/11 103/19 122/12 I 140/11 146/25 148/19] argue [3] 17/1 103/9 Iassuming [3] 60/24
amounts [4] 45/3 Anyway [2] 48/15 165/25 166/7 175/17 62/1 170/2
47/8 51/15 85/4 56/25 ARA [1] 56/21 arise [1] 56/13 assumptions [2]
analogy [2] 101/23 anywhere [1] 108/15 I ARC [1] 63/18 arisen [1] 71/21 1141/2 111/2
102/2 apologetic [1] 80/14 Iare [167] 2/25 3/2 _Iarising [4] 34/19 assurance [12] 76/22!
analyse [1] 152/3 apologies [3] 50/11 I 3/10 3/12 3/15 5/7 5/9) 89/25 118/14 129/22 I 90/11 105/9 108/21
analysis [8] 18/15 78/17 85/25 5/18 6/6 6/8 6/13 6/14/ arm [1] 9/6 110/12 120/1 135/24
19/1 20/15 89/8 92/4 I@Pologise [1] 68/1 7/3 11/17 16/2 23/7 Iarose [1] 132/9 144/23 144/24 144/25)
95/14 103/21 166/22 apology [4] 79/1 28/20 29/3 30/3 39/11) around [20] 11/19 145/5 167/16
Andrew [3] 53/9 66/7 79/13 80/11 80/19 39/18 40/17 40/19 13/13 19/13 19/20 assure [1] 46/25
470/14 appalling [2] 144/1 I 40/22 40/22 41/13 27/12 31/14 35/8 36/3I assured [1] 38/25
angry [2] 68/10 68/12 154/11 A117 41/24 42/5 36/9 36/13 57/10 58/4] assuring [1] 157/17
announce [1] 1/5 apparent [5] 9/8 42/10 43/2 43/2 45/25I 59/5 81/1 81/1 81/7 I astonishing [1]
announced [3] 7/9 21/11 25/6 33/19 47/17 47/20 49/9 83/7 113/11 116/18 I 101/17
37/7 37/8 118/21 49/15 50/1 50/23 173/18 at [211]
announcement [1] appeal [6] 1/15 33/15I 56/18 56/21 57/7 arrange [1] 148/10 Iat page 4 [1] 62/25
414 97/1 112/25 143/15 I 57/18 57/23 63/11 arrived [1] 34/18 atmosphere [1]
annoyed [1] 56/5 152/19 63/24 64/1 64/17 articulated [3] 20/10 I 75/14
annual [1] 98/13 appeals [1] 34/1 64/18 64/22 65/4 82/12 85/5 attached [1] 72/16
annualised [1] 11/20 appear [1] 126/18 65/21 66/1 66/1 69/25Ias [278] attachment [1] 74/5
annum [1] 56/14 appears [3] 49/6 70/12 71/11 73/11 ascertain [1] 161/11 Iattempt [1] 49/6
another [6] 54/20 49/18 164/3 75/10 75/16 77/25 aside [2] 128/23 attend [1] 167/25
82/19 93/19 172/4 appellants [1] 96/24 I 80/3 82/21 82/25 161/18 attendance [1] 40/25
175/19 175/25 appendix [4] 2/15 3/5I 84/14 84/24 84/25 ask [20] 2/9 23/5 attention [11] 41/5
answer [19] 18/18 3/14 5/2 85/13 85/24 85/24 28/9 43/19 79/12 41/6 41/16 46/3 48/10
70/5 71/6 71/10 91/21IaPPlicable [1] 98/16 I 88/4 88/16 88/25 90/3) 113/17 113/18 114/21I 50/12 74/25 95/17
94/11 125/4 125/8 _ IaPPlied [6] 15/18 90/5 90/8 90/10 91/11} 120/19 124/24 125/10) 113/23 147/5 159/2
92/9 93/19 96/17 94/9 94/10 103/7 125/11 125/11 126/4 Iattesting [1] 160/5
tons eept eae 122/23 175/10 103/11 106/13 108/4 I 128/2 138/10 144/4 I attitude [4] 36/12
1446/7 162/5 169/3 apply [1] 37/17 108/7 108/8 108/20 I 152/13 170/16 173/6 I 39/6 55/3 167/3
174/15 175/14 appointed [4] 10/8 I 109/6 112/5 113/10 Iasked [18] 6/7 17/13 Iattributed [1] 79/3
answered [1] 174/8 17/22 111/8 160/24 I 113/14 119/1 119/15 I 23/5 67/11 88/2 95/1 I audit [4] 82/18 88/8
answers [1] 125/21 appointment [3] 9/20] 119/22 119/24 120/7 I 110/21 112/22 117/21] 90/23 91/25
anticipated [1] 17/20 16/17 16/17 120/10 120/17 120/20) 126/24 126/25 136/13I August [4] 18/5 28/4
any [75] 1/24 6/18 appraisal [1] 98/13 I 121/1 121/20 122/12 I 136/18 137/10 137/15) 95/21 105/14
19/25 24/15 32/2 43/1I4PPreciate [1] 122/17 122/20 123/10) 143/19 166/9 173/22 I authority [1] 77/12
46/22 46/22 47/6 170/21 124/1 124/25 125/10 Iasking [13] 42/2 autumn [1] 124/23
47/20 50/11 63/19 I@PPreciation [2] 125/12 127/13 127/21) 79/21 91/11 91/20 I available [2] 97/8
66/18 67/7 77/9 80/8 I 19/25 24/15 127/24 128/2 128/9 I 113/22 124/6 125/4 I 128/14
86/18 89/15 90/3 approach [20] 26/23 I 128/12 128/18 128/19] 125/5 132/7 132/14 I Avene [1] 47/25
92/19 93/1 93/19 36/20 55/3 58/12 128/22 129/11 129/15) 132/20 166/8 171/16 Iawarded [1] 98/6
93/25 97/1 98/20 59/17 59/25 60/10 129/19 130/13 130/23Iaspect [1] 143/23 aware [38] 10/2
99/16 99/16 103/17 I 105/17 105/24 110/7 I 134/1 1314/1 131/10 _Iaspects [1] 160/25 I 10/15 25/7 26/14
104/11 107/3 107/24 I 110/21 110/23 112/23] 132/22 133/23 135/17I assertions [1] 79/2 I 32/21 41/23 43/9
409/12 110/22 111/15] 142/2 142/8 167/14 I 136/9 136/11 137/20 Iassessment [5] 19/7 I 50/17 51/3 51/5 52/1
413/10 113/15 113/22I 174/18 176/11 176/19] 138/18 139/19 142/6 I 20/5 25/2 87/9 148/13) 52/6 73/9 73/17 73/22
418/21 118/22 122/13} 176/21 143/25 144/13 144/14I assist [5] 143/14 79/5 112/7 123/4
123/21 126/19 128/21I4PProaching [1] 144/16 144/24 145/2 I 157/8 157/10 171/25 I 130/13 134/21 135/1
128/22 134/21 136/2 I 199/17 145/3 147/21 148/16 I 173/25 140/12 142/1 149/17
136/25 138/9 138/10 I@PPropriate [8] 41/25] 150/21 153/2 153/15 Iassistance [6] 22/22 I 160/11 165/11 168/19
138/20 139/7 140/22 I 50/15 131/10 139/17 I 153/21 153/21 154/18] 136/18 136/19 138/9 I 169/5 169/12 169/22
4141/9 144/14 1492/3 I 149/15 144/7 147/23 I 155/5 157/24 158/5 I 148/12 161/9 171/12 17219 172/12
442/25 147/18 148/3 I 198/21 160/23 169/19 170/2 Iassistant [1] 95/14 I 172/14 173/8 176/11
448/11 151/13 152/1 I@PPropriately [2] 170/24 171/11 171/12I assisted [2] 46/10 I 176/20 176/22
125/13 142/24 174/13 171/23 171/25] 155/18 awareness [1]
(48) amongst... - awareness
INQ00001193
1NQ00001193
A 143/8 153/2 159/12 I 103/15 106/1 110/19 benefiting [1] 48/25 I 136/11 149/6 149/9
awareness. [4] I 162/10 162/11 162/13) 111/20 112/2 113/7 Benefits [1] 47/8 I 149/10 149/13 149/14
187 169/8 169/9 114/11 125/4 140/17 Ibenign [1] 24/10 I 150/1 154/1 154/17
away [6] 1/7 1813 /Pecome [3] 38/7 I 144/3 146/22 151/11 Ibest [8] 2/25 3/10 I 169/4 169/12 169/17
38/5 81/23 106/21 142/1 172/9 159/17 4/22 5/7 58/8 106/19 I 172/16 172/18 176/19
153/22 bed [1] 79/19 began [1] 151/17 I 125/14 171/13 body [1] 154/24
ae __Ibeen [157] 1/7 11/23 Ibegin [1] 1/3 better [12] 23/9 bold [3] 175/7 175/20)
B 13/2 13/6 16/3 17/13 Ibeginning [3] 19/12 I 58/24 80/18 84/9 92/6I 176/1
back [39] 9/15 13/21 I 17/13 19/3 20/12 22/4] 46/19 169/14 119/18 119/23 133/22I bolted [1] 89/19
20/22 29/12 23/2 24/4I 23/5 27/23 29/10 I behalf [8] 1/21 1/22 I 134/13 134/13 134/14I bonus [15] 45/1
57/4 28/6 35/13 46/18I 32/19 33/12 33/13 I 2/95/19 6/15 45/20 I 176/3 45/12 51/7 51/14 95/7
47/14 52/21 60/13._I 33/2133/25 34/4 I 62/15 123/18 between [34] 5/25 I 95/24 96/10 96/16
60/20 67/2 72/1 95/22I 35/18 35/23 37/6 38/9Ibehaved [1] 64/6 I 28/23 33/25 34/12 _I 97/18 98/6 98/15
101/25 103/14 108/3 I 38/18 39/10 39/17 Ibehaviour [7] 40/9 I 36/5 40/11 43/14 —_I 98/19 98/21 99/6
422/2 124/3 125/21 I 40/13 41/1 41/15 63/15 64/14 123/12 I 55/15 65/25 68/19 99/18
126/12 128/3 128/20 I 41/21 42/11 43/4 44/6) 142/6 142/23 168/8 I 75/1 75/12 85/17 bonus/incentivisatio
438/14 139/2 145/22 I 46/4 48/5 51/12 51/23I behavioural [1] 86/12 86/19 95/2 n [2] 96/10 96/16
446/19 149/1 152/6 I 91/24 52/6 54/13 55/6) 143/23 97/19 98/20 100/5 bonuses [3] 43/6
1461/22 163/25 164/g I 96/6 56/14 57/8 58/17I behaviours [2] 122/6I 105/14 116/22 117/13) 98/7 98/11
168/22 169/4 169/9 I 59/2 59/25 60/3 60/12I 168/3 117/14 121/16 122/17I borne [1] 136/22
170/1 60/17 61/7 62/5 62/18I behind [8] 28/15 29/2) 123/16 123/22 127/6 Iboth [26] 1/16 23/22
backdrop [1] 29/7 63/13 63/18 63/19 29/22 31/5 31/7 35/18] 137/4 148/22 159/10 I 23/23 24/16 27/3 56/2
backed [1] 45/8 64/14 65/25 66/11 35/24 57/3 172/5 172/23 173/3 I 57/12 61/5 64/2 65/11
background [3] 5/13 67/21 68/8 68/9 69/7 Ibeing [47] 1/12 4/11 Ibeyond [4] 28/12 68/7 68/10 70/13
7/3 105/1 69/16 69/24 70/4 10/8 11/17 14/18 77/16 93/19 106/18 I 75/16 76/18 77/17
badly [3] 143/4 143/6 70/15 70/21 71/17 18/20 23/17 33/5 55/7I bias [1] 42/25 79/23 80/3 80/10
143/7 72/4 73/17 73/22 75/7) 56/8 56/19 57/14 big [1] 83/10 106/12 117/20 139/22)
balanced [1] 59/25 76/16 79/4 79/25 81/9) 77/10 77/20 78/8 86/4I bill [1] 176/10 143/25 158/14 158/18)
balances [1] 166/20 81/15 81/19 82/12 87/4 92/2 92/9 93/16 Ibiographies [1] 172/7
ball [1] 170/25 83/3 83/12 84/2 85/5 I 94/3 104/18 110/23 I 12/15 bottom [10] 11/6
banking [1] 8/13 I 85/6 87/2 87/10 88/6 I 112/19 114/3 119/3_IBirch [8] 105/15 I 11/16 12/2 64/25
Bartlett [12] 76/20 I 88/25 89/8 89/9 90/22} 129/3 129/12 132/2 I 105/16 105/23 108/25] 72/10 122/22 131/15
111/8 1141/8 138/15 I 90/22 91/7 91/23 92/9] 135/11 135/13 136/13] 109/22 110/1 110/17 I 147/8 147/9 170/10
138/25 142/12 147/11] 92/10 92/13 92/16 I 137/7 139/10 139/24 I 110/18 box [2] 48/4 67/7
4148/6 159/20 159/21 I 92/19. 92/22 92/24 I 145/11 145/16 152/10] bit [5] 23/6 32/4 58/2 IBradshaw [4] 64/8
162/24 166/7 94/14 95/14 100/5 I 156/6 159/15 162/24 I 61/2 170/6 64/18 64/20 65/5
Bartlett's [4] 140/11 I 100/12 100/24 101/3 I 164/14 166/3 169/1 IBlakey [6] 1/6 1/7 I branch [27] 1/11
140/20 146/24 147/10] 101/7 101/14 101/18 I 172/12 174/19 176/11] 1/13 1/16 1/17 1/25 I 11/15 33/20 56/10
based [13] 45/2 51/7 I 101/21 102/4 102/4 I BEIS [3] 28/16 30/21 IBlakey's [3] 1/12 I 82/23 118/6 118/25
51/15 91/23 98/17 102/16 102/18 103/6 I 35/1 1/14 1/23 119/1 120/1 120/11
1428/1 130/5 130/19 I 103/7 103/10 103/20 IBEIS0000789 [1] Blank [2] 170/20 122/20 125/18 133/18)
1432/3 132/12 143/22 I 103/21 104/20 113/1 I 127/2 174/7 135/23 135/24 144/24)
156/25 160/18 116/22 117/25 118/4 Ibelief [5] 3/1 3/11 blanket [1] 162/1 144/25 145/4 145/6
basic [1] 79/6 118/11 119/20 119/21I 4/23 5/8 77/16 blown [1] 56/5 155/16 160/14 160/17)
basis [8] 30/20 55/7 120/23 121/2 121/21 Ibelieve [22] 6/5 16/9 Ibluntly [1] 120/19 161/12 162/18 167/8
93/1 102/7 129/25 121/24 124/6 130/4 I 16/23 22/11 28/16 board [76] 6/20 8/16 I 171/18 174/9
433/24 143/1 151/4 I 1317/6 131/11 131/23 I 30/22 32/23 43/11 12/10 12/15 23/21 branch's [2] 117/23
Bates [2] 25/10 92/11 133/4 138/4 140/17 I 52/7 54/10 59/14 26/8 26/24 27/3 27/14I 118/13
be [239] 144/22 145/17 147/13] 63/20 70/7 79/18 30/16 32/7 35/2 35/8 I branches [20] 11/13
Bear [1] 2/21 151/25 156/22 160/11] 109/24 110/3 110/5 I 44/8 57/13 58/9 63/6 I 59/19 74/12 82/17
Bearing [1] 59/12 161/13 165/17 165/20) 123/6 123/9 123/17 I 63/10 65/3 65/15 68/3I 108/15 112/11 112/20}
became [12] 8/24 9/8 165/25 166/14 168/22) 143/25 171/2 72/13 76/15 77/10 113/7 120/5 122/14
21/10 25/6 25/6 25/7 I 1699/9 173/5 173/12 Ibelieved [3] 17/12 77/11 77/13 79/17 122/17 124/20 127/22)
25/11 26/13 34/2 173/22 31/1 35/23 81/10 81/18 83/4 133/6 133/7 133/17
52/12 111/5 140/12 IBeer [8] 1/3 2/3 2/7 Ibelieves [1] 64/3 83/25 84/3 84/7 84/15] 133/24 135/18 155/3
because [33] 6/1 2/9 61/3 124/5 146/13] below [10] 47/19 104/12 106/1 106/3 I 165/19
6/15 18/11 26/10 28/1) 178/4 48/17 73/20 75/21 108/2 108/20 109/23 I brand [2] 30/1 90/14
29/8 45/6 49/17 62/1 [before [35] 1/3 5/13 I 79/20 139/3 148/9 109/25 110/19 110/21I breach [5] 75/9 75/18)
68/9 70/20 82/12 7/13 7/17 9/23 10/8 171/8 172/1 173/25 110/22 111/15 111/15] 75/23 75/25 76/14
87/16 87/24 92/1 96/2I 11/21 15/12 16/17 bemused [1] 152/15 I 111/18 112/6 112/7 I breached [1] 8/13
401/12 114/24 120/16] 18/3 18/5 29/12 29/13IBen [9] 21/19 56/5 112/22 113/4 113/5 I breadth [1] 21/8
4124/13 121/24 126/23] 33/13 43/12 47/20 I 59/8 60/16 60/21 113/9 113/12 113/16 I break [9] 5/13 54/21
430/10 140/17 140/18] 50/21 53/3 55/21 I 68/16 73/7 78/13 I 113/23 114/1 116/10 I 54/25 111/20 144/3
57/10 94/7 95/1 149/7 121/15 127/7 128/16 I 146/7 146/8 146/16
(49) awareness... - break
INQ00001193
INQ00001193
B 21/10 24/11 24/22 83/17 85/14 85/20 122/16 127/22 133/21] 127/5 130/21 132/25
break... [1] 159/17 _ 25/13 26/6 28/4 31/18] 85/22 85/25 86/7 145/1 145/6 146/1 143/11 145/17 158/7
breakdown [1] 19/4 33/11 33/21 35/16 86/10 87/19 87/20 160/18 169/15
breaks [1] 21/6 39/13 42/8 43/10 89/24 89/24 94/8 cash-end [1] 133/21 Icetera [2] 57/4 60/17
Breen [4] 147/9 46/23 48/5 48/16 52/7I 94/18 95/18 100/3 cashed [1] 118/5 CFO [1] 130/18
147/10 171/9 171/21 I 93/15 54/5 54/17 56/4] 100/4 104/23 105/1_ Icatch [2] 23/7 50/1 [chain [13] 43/22
brewing [1] 177/12 56/23 59/2 66/11 105/12 105/21 106/1 Icategories [1] 43/23 48/20 51/1
briefed [2] 17/22 67/14 68/15 68/25 1114/1 114/20 120/6 I 157/19 52/10 53/25 73/4 74/2
17/23 69/12 71/4 71/25 121/12 122/25 124/17I Catherine [1] 53/7 74/8 147/4 159/16
briefing [3] 32/25 75/13 77/9 77/22 124/25 125/1 127/1 I causality [1] 123/17 I 159/17 167/23
76/12 173/9 80/15 81/15 81/19 127/3 127/14 127/15 Icause [8] 70/19 Chair [7] 18/1 27/9
briefings [6] 18/8 84/10 87/6 88/22 89/6I 128/15 128/23 130/24) 103/4 103/5 114/19 I 29/10 127/8 149/16
18/14 a518 19/19 90/12 90/24 92/10 135/21 137/18 137/21) 123/13 123/22 175/1 I 152/17 169/15
19/25 20/25 95/14 99/9 99/24 138/10 138/10 139/15) 176/24 chairman [9] 29/21
briefly [4] 8/8 72/9 99/25 101/2 102/1 140/15 144/1 144/3 Icaused [8] 33/21 30/17 30/18 57/17
85/20 127/3 102/19 103/22 107/23) 145/12 145/13 146/7 I 61/24 98/2 100/10 58/6 58/11 75/2 126/9
bring [9] 46/5 71/25 112/6 113/17 115/1 I 146/19 147/2 147/9 I 101/14 102/16 102/18) 174/24
78/1 83/8 110/15 120/12 121/4 122/19 I 151/15 153/8 153/19 I 114/7 chairmen [1] 29/21
1455/11 159/1 169/15 I 129/21 124/1 125/2 I 154/5 154/21 155/22 Icausing [1] 128/12 I challenge [8] 9/6 9/7
1473/8 125/9 128/5 131/5 158/19 158/23 163/15Icaution [1] 144/20 I 9/7 9/9 63/21 68/16
bringing [1] 172/19 135/5 136/17 137/19 I 164/8 170/4 171/7 CC [1] 48/4 82/25 83/3
broad [4] 18/6 141/9 138/7 144/14 144/15 I 173/10 174/25 175/4 ICCRC [1] 96/2 challenged [6] 7/23
1444/4 157/3 145/20 147/4 150/4 I 177/9 ceased [5] 15/11 8/10 8/12 14/4 44/6
broader [4] 18/23 150/18 151/23 152/13] can't [6] 38/1 42/11 I 20/11 22/4 22/6 81/24) 119/15
26/8 111/25 138/7 152/15 152/24 153/16] 88/22 123/21 169/3 Iceasing [1] 1/13 challenges [3] 9/1
broadly [7] 19/13 I 14/2 187/17 161/9__ I 175/16 cent [48] 11/19 115/6I 138/5 168/14
24/3 51/12 99/22 163/8 163/10 170/22 ICandidate [1] 12/12 I 115/6 115/7 115/9 _I challenging [1] 9/12
4108/6 113/17 122/25 I 173/6 173/8 candidly [1] 174/22 I 115/10 115/12 115/14I chance [1] 68/2
broker [1] 35/4 button [2] 118/24 cannot [4] 15/6 115/15 115/17 115/19I change [14] 3/23
brought [8] 3/19 4/21 123/20 120/24 161/16 175/10I 115/20 115/22 115/25] 10/18 26/21 40/8
18/10 41/5 41/16 Ibuttons [1] 128/12 Icapable [3] 49/12 I 115/25 116/3 116/4 I 43/13 64/5 64/13
o7oaes43 =le ~*~ 90020 149/19 116/5 116/6 116/8 I 64/24 143/20 145/11
bug [1] 33/21 ~_____Icareer [2] 7/13 7/16 I 116/9 116/11 116/13 I 145/14 145/16 154/16)
bugs [4] 10/4 34/8 [Call 7] 2/4 22/21 I carefully [2] 83/1 116/15 116/18 116/24] 167/3
160/19 166/22 67/24 68/1 77/6 77/18) 161/8 116/25 117/4 117/4_Ichanged [6] 56/17
build [4] 125/1 148/8 carelessness [1] 117/5 117/7 117/7 I 64/15 64/23 130/20
building [2] 103/6 called [7] 20/25 123/18 117/9 117/12 117/13 I 142/23 144/22
1314/8 43/14 86/2 95/3 carried [2] 29/5 47/2 I 117/14 117/19 117/24] changes [9] 14/21
built [2] 58/17 59/12 104/24 149/2 172/9 I carrot [1] 133/13 118/1 118/11 119/11 I 22/14 37/11 40/17
bullet [5] 11/10 calls [2] 23/24 56/2 I carry [5] 12/1 29/23 I 121/18 123/2 123/3 I 63/16 120/1 120/2
127/17 130/8 131/15 [came [9] 3/21 6/19 I 47/4 97/7 164/2 125/22 126/7 126/11 I 121/21 122/3
131/24 20/23 31/3 51/9 52/19I carrying [3] 144/12 I 163/17 changing [1] 119/22
burglar [1] 101/24 77/11 146/22 152/8 I 175/15 176/5 central [8] 15/2 36/4 Ichaos [1] 102/15
i Cameron [7] 127/19 Icase [41] 6/12 31/18 I 104/23 105/2 105/6 I characterise [1]
business ra) ees 128/11 128/18 129/10 31/20 32/12 33/3 153/4 154/18 156/17 I 16/21
9/10 9/11 11/8 14/3 I 129/24 131/23 135/10] 39/13 46/6 51/18 —_Icentre [5] 118/8 charge [3] 52/17
16/21 18/12 21/2 21/8, camps [1] 17/15 51/25 52/8 54/10 118/25 122/17 122/20I 101/24 156/20
22/6 25/15 29/12 can [123] 2/10 2/13 I 54/16 62/11 62/13 135/23 charged’ [1] 63/8
31/23 36/14 45/4 2/15 3/5 3/16 4/16 I 66/12 70/1 70/4 71/10Icentred [1] 27/12 I charges [2] 101/1
45/14 46/24 47/16 I 4/25 5/35/11 5/24 I 83/6 85/3 85/12 89/2 ICEO [16] 6/2 7/23 8/6I 156/21
52/4 54/14 58/5 58/17I 2/14 9/21 10/23 11/2 I 94/6 94/10 102/19 9/24 11/2 14/18 17/22I charging [2] 98/24
61/8 62/16 77/21 85/3) 1/9 21/18 21/22 103/3 106/23 112/21 I 23/12 26/1 27/9 39/5 I 173/14
B57 110/14 11/1 I 21/25 22/17 23/5 122/1 130/1 135/8 I 121/9 164/25 168/2 Ichat [4] 57/1
tte? 149/20 saga I 27/25 27125 28/3 136/15 139/11 139/14] 168/2 169/11 check [1] 30/10
450/13 181/22 184/17I 28111 29120 32/4 142/11 151/24 155/15ICEOs [1] 29/21 checks [2] 145/5
4155/2 17/1 158/11 I 32/14 34/13 36/25 I 156/1 156/8 165/7 __I certain [4] 63/12 166/20
168/6 168/15 39/3 39/4 39/21 41/20] 174/15 86/19 149/15 168/3 Icheque [1] 118/4
business-like [1] 43/12 43/18 45/15 cases [12] 24/13 certainly [27] 24/23 Icheques [1] 118/6
62/16 46/25 47/24 49/25 32/18 33/6 128/5 25/24 25/25 31/16 Chief [6] 7/4 8/3 9/17
businesses [2] 84/5 50/4 52/16 52/24 55/2I 129/1 129/18 131/18 I 31/19 39/15 42/17 12/11 77/3 174/18
84/5 55/21 61/4 62/22 131/20 132/14 134/16) 51/11 54/12 54/22 Chisholm [7] 35/1
but [93] 6/8 6/14 17/3 62/25 64/13 66/15 134/25 155/4 57/22 59/17 62/15 35/14 37/2 37/19 38/6
17/7 18/21 20/15 70/11 72/6 72/10 73/8] cash [12] 14/4 33/21 I 68/15 69/6 71/23 84/7I 38/16 38/24
74/20 74/21 76/2 82/17 82/22 118/6 85/12 111/21 120/16 IChris [2] 147/9 171/9
(60) break... - Chris
INQ00001193
INQ00001193
Cc 16/4 26/11 30/7 54/17Icommitments [1] 12/22 confirmations [1]
Christian [1] 139/1 I 60/5 60/7 68/8 68/9 I 165/1 comply [1] 136/17 156/19
chronologically [1] 69/23 69/24 90/25 committed [2] 44/18 Icomprehensively [1] Iconfirmed [4] 15/5
76 113/12 121/4 121/13 I 143/25 122/4 129/10 155/23 166/11
chronology [1] 140/9 123/12 131/12 151/17I Committee [4] 66/8 Icompromising [2] confirming [5] 105/1
C1 [12] 90/13 105/10 climate [1] 128/3 103/25 104/5 114/9 I 75/11 76/5 105/12 105/21 166/23)
108/8 109/5 109/9 close [3] 51/21 61/14Icommitting [1] 45/5 Icomputing [1] 161/1 I 167/6
411/23 114/10 170/12 93/17 common [22] 3/20 Iconcede [2] 42/20 Iconfirms [1] 170/22
4714/6 171/15 171/22 closed [4] 49/15 54/3I 10/8 13/6 14/22 15/9 I 42/21 confiscation [1]
1473/2 54/9 62/5 16/20 17/3 17/10 concept [1] 164/14 I 97/23
Cl [4] 22/15 2616 [closely [2] 35/1 35/7 I 18/19 19/2 19/8 19/20Iconcer [6] 39/20 I conflation [1] 65/24
12214 13412 closing [1] 64/22 I 20/24 24/16 25/4 62/8 92/16 106/8 —_I conflict [6] 86/22
CIM [1] 131/12 closure [1] 38/17 26/23 32/9 112/24 111/18 118/15 86/23 87/22 89/25
circles [1] 29/20 Co [1] 8/25 116/2 117/22 123/4 Iconcerned [11] 1/20 I 91/17 91/18
circuitous [4] 48/11 Co-op [1] 8/25 157/25 66/20 66/23 79/9 conflicted [4] 73/18
circulated [4] 75/7 cohort [6] 90/5 90/6 Icommunicate [1] 86/13 91/13 92/2 98/8] 73/24 87/16 88/15
79/25 109/22 110/1 90/8 125/6 125/22 122/25 142/6 152/20 165/1 I conflicts [2] 86/19
circulation [4] 67/1 I 126/13 communicated [2] _ Iconcerning [5] 55/11I 86/19
circumspect [1] collaboratively [1] 123/6 125/16 74/24 114/16 154/8 I conformance [2]
442/24 167/21 communicating [4] I 159/2 19/10 19/20
circumstance [1] colleague [1] 83/18 I 120/7 125/13 125/14 Iconcerns [16] 23/17 Iconfusion [1] 166/14
163/3 colleagues [15] 4/6 I 138/19 24/19 55/17 74/18 — Iconnected [1] 10/3
circumstances [3] I 4/7.8/169/13 14/20 Icommunication [1] I 75/3 75/21 77/8 86/21) connection [4] 33/25
73/18 124/7 145/9 41/3 44/20 47/4 50/12I 125/18 96/13 116/12 136/13 I 103/1 115/14 121/16
City [14] 137/8 67/9 67/15 85/5 87/2 Icommunications [1] I 140/10 140/20 141/2 Iconscious [4] 3/18
437/10 138/11 138/19 90/19 91/12 24/11 164/4 168/2 112/6 119/11 162/6
1439/2 139/5 139/6 collected [1] 98/19 Icommunities [1] conclude [1] 24/8 consequence [13]
439/19 142/2 147/21 colour [1] 83/8 36/6 concluded [2] 59/4 I 16/24 19/6 34/4 34/10
148/8 148/12 148/22 ICOmbination [1] community [1] 78/10 38/23 61/1 69/18 78/4,
169/13 69/21 167/16 conclusion [4] 9/14 I 110/17 112/2 132/5
ClU [11] 105/3 combined [1] 52/19 Icompany [8] 6/15 123/21 132/17 163/25] 132/9 145/19
405/13 107/8 107/23 Icome [25] 2/16 8/21 I 58/6 62/3 64/5 84/3 I conclusions [3] consider [3] 65/2
1408/4 108/5 111/5 15/23 17/9 17/19 107/13 168/7 171/12 I 97/13 152/21 153/5 136/11 144/7
411/14 111/16 113/6 30/16 35/15 39/3 39/8Icompany's [1] 6/16 Iconduct [16] 15/14 I considerable [1]
113/21 48/4 63/8 67/12 68/11Icompared [2] 115/5 I 19/15 20/1 54/8 96/20I 150/12
68/22 71/23 74/25 115/10 107/23 108/20 124/18 consideration [1]
civil [17] 20/1 32/2
32/8 33/25 34/13 75/5 80/5 82/9 90/15 Icompensation [19] I 127/23 127/25 129/24) 50/7
100/15 129/2 134/16 100/3 124/17 130/16 I 1/18 16/1 16/8 40/23 I 130/5 130/18 132/11 Iconsidered [5] 92/17
434/23 140/23 141/16 131/9 148/25 42/14 43/1 89/11 132/23 159/2 96/6 102/5 106/22
1456/5 156/7 157/9 comes [8] 90/1 112/8I 97/23 100/6 101/8 conducted [19] 168/6
1458/9 167/11 176/25 112/9 112/10 114/11 I 101/11 102/24 103/13) 19/17 41/10 43/4 43/7I considers [4] 138/21
claimants [1] 1/16 114/12 114/13 158/8 I 103/23 104/15 104/19) 44/5 66/7 66/11 96/15) 159/11 159/13 161/7
claims [4] 40/23 comfortable [1] 104/20 143/16 156/18) 97/5 97/11 98/19 consist [1] 127/4
42/14 100/15 137/1 81/24 competence [1] 110/11 110/13 112/13I consistency [1]
clarified [1] 49/11 coming [9] 16/11 19/16 129/12 133/19 135/11] 110/16
Clarity [1] 86/1 18/6 42/23 54/14 —_I competing [4] 93/5 I 135/14 169/1 consistent [2]
Clark [4] 31/13 31/17 54/17 71/13 89/12 competitive [1] 8/19 Iconducting [2] 101/21 167/14
31/25 34/17 167/21 175/3 complained [1] 111/17 148/16 consistently [2]
classic [1] 9/1 commas [3] 103/18 I 115/20 conducts [1] 108/22 I 101/16 125/1
clear [31] 13/24 113/24 153/14 complaining [1] confidence [9] 42/23 I constable [3] 170/8
18/15 19/1 33/24 comment [5] 38/1 43/17 66/15 75/6 83/15 171/21 173/11
34/18 35/19 38/7 50/7 50/15 130/11 Icomplaint [3] 61/11 I 83/18 89/13 89/25 _IConstabulary’s [1]
38/15 41/1 41/3 41/9 134/3 61/17 74/20 102/2 120/15 170/9
50/23 68/19 77/20 commentary [2] complaints [2] 82/2 Iconfident [6] 41/13 Iconstant [1] 64/3
79/23 81/8 81/11 28/21 66/22 92/1 62/17 89/12 130/13 I constitute [1] 5/15
81/15 90/6 94/8 comments [8] 28/19 Icomplete [2] 11/18 I 130/24 158/19 constitutes [2] 85/25
103/15 103/17 113/9 56/4 56/16 66/7 79/3 I 64/23 confidential [3] 74/9 I 90/13
1421/3 134/11 140/21 79/5 81/14 147/20 completely [4] 67/22 I 75/1 76/12 constraints [1] 4/12
4141/6 145/3 145/17 [commercial [3] 102/20 145/2 150/20 Iconfidentiality [3] _ Iconstruct [1] 42/18
150/20 163/22 26/21 35/21 168/7 complex [7] 10/13 67/7 75/9 75/23 consultative [1]
clearing [2] 82/9 Commission [2] 84/1 84/5 84/12 84/18I confirm [4] 79/1 24/10
82/13 32/18 33/6 90/11 105/9 89/24 104/6 170/18 Icontact [10] 14/19
clearly [19] 6/7 7/1 commitment [2] compliant [1] 169/20 I confirm/verify [1] 14/20 20/18 20/21
154/10 167/20 complicated [1] 170/18 108/16 128/13 135/23)
(61) Christian - contact
INQ00001193
INQ00001193
c 66/19 68/9 68/14 I 171/3 95/11 107/14 109/77 _ID
~——_________ 7217 80/12 103/15 _I correlation [2] 98/20 I 112/16 148/17 162/15I——
contact. 13] 13977 132/9 138/25 139/9 I 98/22 165/19 170/9 daily (2) 133/9
contain [1] 79/5 139/9 139/20 151/23 Icorrespondence [27]Icrimes [1] 150/13 I gamaged [1] 75/11
166/1 166/3 33/5 47/22 51/1 51/3 criminal [35] 1/15 9
Dan [4] 138/3 143/19
conversations [5] 51/4 54/6 89/21 95/13) 20/2 25/22 32/3 32/10) 4 yeio5 1447/6
i 21/13 33/14 34/6 38/6) 136/12 136/21 136/22) 32/18 33/6 33/15 34/1) 146!
contains [2] 12/15 I +38/10 137/3 137/18 147/18 I 55/6 96/12 96/17 97/9 Dace ty eo
contemplated [1] [eonvey [1] 1216 I 148/19 148/21 14916 I 97/5 97/23 995° Baoan tt Oa I
“ante convicted [2] 46/14 I 154/2 156/23 156/24 I 100/14 100/15 107/18) Gata [44] 119 Ait
contemporaneous I 55/6 1457/5 157/23 159/1 I 107/19 113/1 13717 I 156150 4961 429/17
Tay 28/6 25/17 ear2 [conviction [5] 1/14 I 167/1 169/4 17015 I 140/1 140/23 144/16 I $5006 130/2 13016
Fino 39/14 46/8 93/7 97/6 I 172/23 141/25 154/20 185/5 I }50/9 1341/0 134/17
content [6] 7/1 24/6 convictions [7] 25/23I corresponding [1] 155/16 157/8 159/5 131/19 132/3 132/12
ore ae teaig I 39/1046/11 98/18 I 32/19 160/7 161/15 166/16 I }35/99 yso/od s40I
159/9 98/21 101/3 143/15 I corroborating [4] 17/1 142/10 142/22 143/1
contents [3] 2/25 [Convinced [2] 15/1 I 70/5 70/22 74/9 71/19I criminality [1] 107/24] 45474 15116 151/24
oer 41/25 cost [2] 14/7 24/25 Icrisis [1] 7/25 teat 15/12. 156/19
contest 1] 1011 [COOL] 163718 [costs [1] 11/20 critical [5] 33/1 103/7I je00 see/e 1ee/14
context [9] 58/2 58/9 Cooper [1] 129/5 could [45] 3/19 8/8 I 105/17 149/21 152/1
ce ig. [cooperate [5] 142/3 I 20/13 21/11 31/6 36/6 criticisms [3] 110/6 I teen 1G 1¢ 158/5
158/6 160/3 160/6
T4120 115/1 1938/7 I 148/1 155/24 162/4 I 35/6 36/11 37/20 142/16 142/24 160/19 165/19 168/22
173/20 170/3 38/13 38/19 39/2 [crooks [4] 56/18 57/8) 466/44 16/21 166/24
contexts [1] 65/15 I®°Peration [2] 39/12 47/7 53/15 57/18 57/22 date [4] 11/23 45/22
contingencies [1] I 113/18 147/25 60/12 70/15 71/1 71/2\cross [5] 4/2 23/12 Iv tea zeay
Dee copied [6] 72/12 74/17 84/25 87/12 I 104/12 162/22 163/4 I 4
, lated [6] 2/14 3/4
continual [1] 11/14 I 74/2379/14 138/15 I 87/15 88/15 88/15 Icross-heading [1] ISrrag/1 45/21 63/4
146/21 150/19 94/14 102/18 108/2 I 23/12
continue [11] 16/6
rontinue [14] 1606 iglcopy [6] 2/20.2/23 I 108/14 12713 129/2 crossover (1] 90/16 IDaMig Lt] N12
day [21] 3/4 18/7
143/t7 148i 1515 I 410) 111 11601 Teo seats soma Ireasreference [1] I 3576 44/19 56/23
160/12 163/19 167/7
56/24 74/17 74/22
‘ cordial [1] 164/11 I 157/22 160/16 161/13ICrown [1] 165/10
conunued [2] 37/19 I Core [6] 1/6 2/1 14/4 I 166/6 170/16 175/17 Iculpability [3] 106/19] 7/9,77/18 112/20
112/20 139/24 145/25)
36/4 104/18 104/19 I 176/25 177/12 107/3 111/2 4155/2 155/2 156/12
156/12 158/11 162/14)
continues [7] 90/18 "4
1441/3 ren Bytes Corfield [2] 47/17 couldn't [1] 104/6 cultural [11] 10/18
52/24 Counsel [6] 21/16 I 26/20 40/8 40/17 75/4
144/8 159/21 168/4 I oorner [1] 13/13 I 21/20 26/7 60/23 77/1I 93/16 94/3 111/25 I 177/18
continuing [7] 96/6 lary [1] 84/21 I 173/7 143/23 154/16 168/4 I ays [5] 25/10 29/13
104/13 126/19 142/20] Corollary [1] 41/23 63/3 133/22
corporate [4] 5/18 {count [2] 145/1 145/1Iculturally [1] 51/24
150/25 168/15 170/2 DBT [3] 18/4 127/6
contract [10] 91/25 I £/9 6/23 12/8 counter [1] 125/19 [culture [2] 39/4 63/9 I"45745
115/24 116/1 116/3 corporately [1] 6/15 Icouple [9] 14/18 curiosity [2] 51/18 de [3] 56/12 58/19
418/20 121/22 123/3 ICorPoration [2] 83/25) 41/23 71/8 85/6 89/22I 51/22 Parl
100/20 117/6 125/21 127/9 Icurrent [18] 49/12 a
123/11 139/3 168/13 de minimis [3] 56/12
contracts [2] 121/18 [Correct [58] 4/1 4/3. I 157/24 59/21 76/4 78/6 82/5 I Farig 5o/14
12425 4/15 5/17 5/20 6/17 Icourse [10] 1/12 86/20 87/21 97/12
deal [9] 3/19 6/1
contractual [4] 122/6 7/5 7/6 7/12 7/20 8/1 I 18/14 23/9 31/3 58/8 I 128/3 128/4 152/16 I gioc 3514 36/16 45/7
8/4 11/1 12/18 12/24 I 66/22 97/24 99/12 153/3 153/12 168/23
123/9 147/14 167/7 56/1 83/10 153/2
contractually [1] 22/9 23/20 24/3 27/18) 129/4 170/11 169/19 169/23 174/16) dealing [6] 10/18
12/3 27/24 28/8 31/2 40/19Icourt [8] 1/15 33/15 I 176/17 14/21 76/3 101/8
contradicted [1] 44/12 44/14 55/14 33/17 34/20 44/7 currently [17] 7/4 101/11 172/1
152/20 56/11 67/17 67/19 112/25 152/19 174/5 I 20/6 37/17 46/5 53/12 ge aig [1] 50/4
contribute [4] 74/15 72/24 73/3 73/6 74/4 Icourt's [1] 154/17 57/7 90/10 112/1 Dear [1] 147/11
contributing [1] 74/10 74/14 76/23 courts [1] 134/23 114/18 115/5 129/3 I Genacte [1] 63/16
50/18 9 77/4 77/5 86/25 91/16I covered [2] 88/7 129/12 134/18 156/6
94/16 95/16 105/5 I 157/25 158/22 160/13 167/11] debate [3] 152/15
control [1] 110/12 153/3 153/16
controls [1] 63/18 105/11 105/25 111/9 ICPS [3] 136/18 155/7Icustodian [1] 102/23
debt [1] 58/17
125/24 128/8 129/7 I 171/3 customer [1] 12/5
ov nm 137/6 137/9 137/14 Icreate [2] 75/14 customers [1] 16/7 Panes 15) oa 16
: 137/25 144/21 154/4 I 160/16 cut [3] 11/23 27/21
convenience [2] 8/20! 175/11
154/7 167/19 170/13 Icreated [1] 118/5 I 45/18 ‘
12/4 tion [1] 122/15Icredibility [1] 173/18 Icuts [1] 44/1 decide [3] 58/6 163/1
conversation [21] correction [1] credibility [1] cuts [1] 177/16
Dri gare ayia [eotrections [3] 3/16 Ieredit 1] 156/21 leutting [1] 28/5 I geciaea [1] 11312
54/2 56/15 57/13 63/2I 4/21 122/13 crime [14] 43/8 44/22 deciding [2] 89/10
correctly [2] 133/15 I 47/3 47/9 49/1 49/2
(62) contact... - deciding
INQ00001193
INQ00001193
29/14 32/4 68/21 110/4 110/5 113/4 disclose [1] 96/23 17/13 19/5 19/21
deciding... [1] 101/24 80/18 83/24 103/3 113/4 116/13 125/25 Idisclosed [5] 27/23 I 22/23 23/17 24/21
decision [14] 15/6 108/3 126/9 126/15 129/23 I 67/14 67/15 102/13 I 29/4 29/25 31/20
20/16 38/3 89/9 94/15I described [14] 15/20 I 141/8 143/3 143/7 153/12 31/21 32/4 35/11
101/16 102/23 103/18I 16/11 20/22 27/5 145/14 145/20 149/25I disclosure [11] 46/9 I 38/25 40/16 41/8 43/3)
103/22 106/4 113/1. I 27/12 29/19 61/7 157/21 161/19 163/6 I 66/6 70/25 92/4 95/23I 44/19 45/7 46/2 48/7
173/14 173/23 174/1 I 91/20 65/25 92/7 168/17 172/9 96/4 96/7 97/6 100/25] 52/19 59/15 59/18
decision-making [1] 103/16 104/14 150/11I didn’t [20] 15/24 103/22 104/18 61/23 62/2 63/19
89/9 151/11 15/25 16/23 20/4 discomfort [2] 67/11 68/6 70/15
decisions [7] 91/22 description [5] 15/20) 30/14 31/22 36/10 101/13 102/18 70/17 71/4 76/6 77/19
93/25 98/24 103/12 I 19/22 24/4 76/19 54/1 68/1 74/5 74/11 Idiscovered [2] 66/5 I 81/4 83/6 91/3 95/12
167/2 118/8 126/2 126/2 66/9 99/19 102/2 104/9
103/14 105/23 113/13)
Declan [3] 52/10
52/17 53/15
deserved [1] 93/9 134/7 146/21 147/4 Idiscrepancies [15] I 104/10 108/17 110/6
designed [3] 48/4 149/22 150/11 176/23) 109/10 112/10 114/12I 110/18 111/22 118/5
declines [1] 14/6 111/1 133/8 difference [2] 5/24 I 115/16 117/21 118/11] 119/25 120/15 120/23
deducted [1] 129/8 desire [4] 24/24 38/8 I 6/18 120/5 120/9 122/10 I 122/18 123/8 123/8
deemed [4] 87/2 87/4 76/15 102/17 differences [3] 34/12I 125/13 130/15 131/1 I 123/12 123/22 124/21
desktop [2] 4/6 87/11] 56/12 56/13 156/13 160/17 161/12] 124/21 125/1 125/10
90/19 165/10
deep [1] 63/9
deeper [1] 123/20
deepest [1] 1/22
deeply [3] 74/24
despite [4] 119/13 Idifferent [14] 6/11 I discrepancy [12] 125/10 125/11 125/15
120/1 120/2 120/3 I 16/12 21/3 39/4 39/24] 116/20 117/2 117/6 I 125/15 125/20 125/20
detail [8] 19/11 43/13I 70/7 71/3 80/13 120/8I 117/11 117/12 117/14] 128/15 129/18 130/9
90/12 109/16 111/13 I 125/3 132/20 144/25 I 117/18 118/4 118/7 I 1341/4 131/5 131/18
75/18 84/8 114/2 126/19 134/20 I 145/3 175/22 118/16 151/14 156/25] 131/20 132/2 132/13
defect [1] 33/22 detailed [1] 10/6 differently [1] 107/12Idiscuss [4] 126/18 132/24 133/3 133/4
defects [2] 160/12 details [7] 9/17 15/13] differs [1] 6/6 147/23 148/3 152/1 134/5 135/13 135/18
166/23 21/24 26/19 139/16 I difficult [18] 9/9 23/8 Idiscussed [9] 19/12 I 135/19 141/8 144/6
defence [1] 104/1 139/18 171/11 48/21 68/6 68/9 68/14I 19/18 72/6 75/2 83/4 I 145/24 146/20 150/21
defendants [2] 96/1 detected [1] 55/5 78/7 78/11 93/4 112/2 112/7 151/11 154/19 157/2 158/12
96/2 detective [3] 170/8 I 127/25 128/14 129/24) 166/25 159/25 162/25 168/10)
definitely [1] 25/15 171/21 173/11 130/5 130/18 132/2 Idiscussing [3] 58/7 I 168/15
degree [6] 14/10 17/1 determinant [1] 132/11 132/23 152/7 I 138/22 162/13 document [7] 11/4
47/7 162/22 162/24 60/24 difficulties [1] 93/22 Idiscussion [2] 75/8 I 11/24 12/14 12/15
163/4 determination [1] dig [4] 15/12 21/23 I 79/18 76/13 79/22 95/17
degrees [1] 103/9 31/21 22/7 119/9 discussions [4] documentary [2]
delay [3] 104/14 determine [4] 92/25 I digging [1] 26/18 23/24 73/9 80/8 170/18 170/22
104018 104/20 96/18 107/2 156/3 {dinner [3] 28/20 138/20 documented [1]
deliberately [1] 157/3 determined [1] 43/2 I 30/17 37/24 disgrace [1] 64/9 143/20
deliver [2] 11/19 determining [5] 26/2 Idirect [1] 97/24 dishonesty [1] documents [2] 70/8
4167/7 86/18 89/10 106/9 directed [3] 48/5 107/18 97/8
delivered [2] 79/24 106/19 48/13 162/24 dismal [1] 118/17 does [27] 12/16
1421/9 devastated [1] directing [1] 171/15 Idisparate [1] 109/1 12/20 12/25 13/18
100/13 direction [1] 153/22 Idispute [4] 118/24 13/19 23/21 28/25
delivering [1] 10/19
delivery [6] 3/22 3/23)
43/1 104/14 147/14
develop [1] 14/25 directly [1] 125/19 123/20 128/12 135/25] 48/5 49/5 73/12 76/16
developed [1] 37/14 Idirector [7] 53/13 disregard [1] 142/16 I 94/2 108/4 108/11
160/20 developing [2] 58/10 62/3 76/22 82/5I dissatisfaction [1] 124/18 129/15 145/1
demonstrate [3] 50/4] 131/11 158/13 129/5 137/22 114/17 145/5 151/5 151/9
1407/1 127/24 Development [1] directors [8] 8/16 dissatisfied [6] 115/4) 155/13 156/8 156/9
denial [3] 17/1 17/7 98/12 56/24 57/16 62/24 115/7 115/7 115/8 156/11 167/3 167/11
17/21 deviation [2] 6/4 6/9 I 78/18 80/22 82/8 115/9 116/6 168/13
denied [1] 100/25 did [67] 9/12 10/5 83/13 distilled [1] 70/3 doesn't [9] 12/19
department [2] 61/13} 10/10 10/12 13/24 directs [1] 148/5 distinct [2] 17/15 12/21 13/1 13/20
86/11 14/10 14/20 15/12 disagree [1] 54/1 69/13 145/1 149/14 151/7
depend [1] 98/11 19/25 20/20 21/23 disagreed [2] 116/9 Idistinction [4] 38/15 I 153/4 155/11
dependencies [2] 22/7 22/10 22/19 25/3] 116/11 68/19 86/12 86/16 doing [17] 15/8 17/13)
93/6 93/22 25/20 26/7 26/18 disagreement [1] distressing [1] 74/25] 21/20 29/4 43/2 60/3
depends [1] 42/16 30/16 30/19 31/10 80/17 distributed [1] 47/15 I 87/25 88/13 88/14
depicted [1] 87/7 I 32/2 32/10 33/20 35/3Idisappointing [4] _I distribution [6] 47/21] 92/6 109/1 109/9
deploying [1] 68/18 35/11 38/2 52/13 118/18 119/8 119/25 I 48/1 48/12 49/21 131/13 133/6 144/13
deprioritise [1] 52/15 52/17 54/5 121/13 52/21 76/11 158/22 162/6
i714 57/14 60/18 66/24 Idisappointment [1] {distrust [1] 136/23 Idomain [1] 114/14
68/3 68/6 74/15 74/16) 62/14 Division [4] 1/15 Idon't [64] 6/6 6/9
77/19 80/8 81/12 disaster [1] 37/25 I 33/15 76/24 76/25 _I 17/9 18/8 18/9 18/11
81/13 91/3 91/24 I disciplinary [1] 93/1 IDivision's [1] 113/1 I 28/24 32/14 39/12
92/14 99/16 104/12 Idisciplinary/miscondIdo [94] 6/14 16/10 _ I 43/10 52/7 54/5 54/10
uct [1] 93/1
depth [1] 33/1
describe [11] 13/18
23/11 23/13 24/9
(63) deciding... - don't
INQ00001193
INQ00001193
D drivers [1] 104/21 72/17 75/1 78/25 143/18 151/2 158/25 I 108/14
don't... [51] 54/15 driving [1] 25/17 80/12 81/22 160/19 161/1 164/3 Ienvisaged [1] 92/10
57/10 57/22 67/24 IdFopped [1] 67/20 I Elliot's [1] 59/19 17716 177/6 envisages [1] 113/21
64/25 77/21 81/18 drove [2] 56/1 104/1 Ielse [4] 65/1 92/6 ended [3] 15/14 Equally [1] 63/24
82/12 82/23 83/22-:Idue [6] 1/12 31/3 108/15 164/8 140/8 148/19 equivalent [1] 139/16
84/10 84/16 84/17 91/8 128/4 129/4 else's [1] 41/5 endorsement [1] eroded [1] 75/13
84/20 85/3 90/8 90/12 170/11 elsewhere [1] 50/5 167/15 error [2] 33/22
92/15 99/19 103/14 IAuring [11] 1/9 2/2 Iemail [64] 27/22 28/3Iends [2] 65/1 131/15 I 123/18
104/17 109/13 109/24 9/23 10/11 10/16 28/5 43/13 43/21 44/1/enemy' [1] 64/12 errors [3] 121/21
409/24 110/20 110/25} 19/21 21/10 69/14 I 44/3 45/21 46/3 47/12Ienergy [1] 9/5 160/12 166/23
1114 11411 14/8 I 69/22.97/19 97/24 I 47/15 47/18 48/7 enforce [1] 123/22 escalate [1] 168/2
418/17 119/7 120/16 duty [2] 1/5 46/13 48/11 48/20 48/21 enforcement [24] escalation [1] 132/5
420/22 122/1 122/10 Idysfunctional [2] 49/14 50/9 52/9 53/2 I 18/16 42/6 107/12 _I especially [2] 76/3
4123/6 123/8 123/11 I 84/3 84/22 55/22 57/10 57/15 I 109/6 112/16 113/11 I 77/7
t2a/e 124/9 124/13 IB I 97/20 59/7 67/1 67/3 I 115/2 121/4 126/20 essential [1] 136/1
426/18 128/20 130/1 I=—————-—_ I 87/7 67/20 67/25 72/7I 140/23 141/3 141/14 essentially [22]
4302/1 134/17 134/20 [@2ch [5] 2/13 6/18 I 72/12 72/13 72/14 I 142/25 143/2 145/21 I 24/12 24/19 27/19
449/10 150/1 158/11 I 49/25 71/21 82/23 73/1 73/16 73/20 74/8I 150/17 151/4 154/9 I 28/4 33/16 34/21 37/5
4162/1 Eamon [1] 53/19 74/22 76/11 78/22 I 155/4 157/12 158/1 I 38/5 43/25 48/10
done [34] 1/25 18/13 earlier [12] 13/8 79/10 79/14 79/20 162/4 168/5 172/21 I 57/15 72/22 79/15.
18/19 19/3 19/8 22/19] 22/13 37/18 44/1 77/6) 80/12 137/22 138/16 Iengage [14] 119/3 I 99/6 102/7 106/3
26/6 34/9 38/18 38/23) 92/18 165/18 170/1 I 140/41 140/21 142/13) 120/12 126/2 126/3_ I 140/21 143/17 157/6
42/19 43/9 58/21 59/3I 172/15 175/2 175/14 I 146/8 146/25 146/25 I 126/5 150/17 161/25 I 164/18 166/17 176/10
175/24 147/4 147/6 147/10 I 162/20 163/8 163/10 Iestablish [4] 27/9
eerat ooo 10 early [6] 21/1 27/7 I 148/7 148/9 159/16 I 163/11 166/9 166/12 I 59/21 152/7 167/13
4117/3 11716 122/4 I 38/7 $2/19 137/19 I 159/17 166/7 170/2 I 168/10 established [11]
124/14 129/15 131/6 I 192/17 170/8 171/20 engaged [5] 62/2 14/13 90/14 100/12
4134/6 133/22 135/21 Ieamed [1] 158/12 emailed [1] 74/18 62/17 118/25 151/18 I 100/24 105/3 105/6
445/2 157/22 158/16 [earth [1] 64/7 emails [12] 44/1 49/6I 161/3 4113/4 120/25 133/23
158/19 easier [1] 62/18 59/20 69/6 72/22 engagement [14] 139/23 167/12
door [1] 101/2 easily [1] 85/10 77/17 95/2 119/14 I 82/5 82/7 119/14 establishes [1]
double [1] 115/20 [easy [21 70/24 150/2 I 146/20 147/4 150/19 I 119/17 119/18 121/7 I 174/16
doubly [4] 102/24 echo [1] 76/10 159/19 122/5 128/15 139/4_ I establishing [4]
doubt [1] 153/15 [Economic [1] 170/9 Emanuel [1] 53/7 I 147/20 148/4 162/23 I 139/25
down [59] 2/20 3/6 Edwards [1] 170/8 Iembargo [1] 23/15 I 163/5 174/22 establishment [1]
5/14 7/19 12/1 12/9 [effect [8] 29/6 29/24 Iemblematic [1] 54/6 Iengaging [6] 92/24 I 105/12
12/12 12/13 13/6 14/2I 44/9 57/12 59/20 69/6 emerge [4] 84/6 120/8 121/12 123/10 Iet [2] 57/4 60/17
2116 23/11 23/16 102/13 144/20 84/20 120/5 120/9 I 163/12 163/12 et cetera [2] 57/4
28/11 28/12 34/10 [effecting [1] 154/16 Iemerged [3] 22/15 engineered [1] 123/8) 60/17
39/3 44/2 45/16 45/17ICHrective [3] 40/13 I 67/4 70/1 enhanced [1] 102/4 Ietc [3] 56/18 56/19
46/16 46/16 47/12 40/13 60/3 emphasised [1] enormity [1] 18/10 I 56/19
49/15 50/8 51/21 effectively [6] 76/7 I 92/18 enormous [1] 85/4 [ethics [1] 19/16
52/21 54/3 54/9 62/5 I 82/9 127/5 133/5 —_Iemploy [1] 60/1 enormously [1] 6/6 IEurope [2] 9/15
63/23 70/3 72/25 133/13 133/16 employed [1] 44/10 Ienough [4] 42/21 1714/10
79/16 80/7 81/6 84/23I “tectiveness [1] employees [3] 46/4 I 69/5 77/7 129/16 European [1] 9/5
86/5 96/22 100/3 135/18 96/11 96/17 ensure [15] 36/10 _Ieven [11] 13/2 44/22
109/19 112/11 113/2 [efficient [1] 60/3 Iemployer [2] 45/6 I 36/14 38/19 39/1 42/6) 54/7 56/6 60/16 63/6
4146/2 117/16 118/10 [eight [1] 15/4 45/9 50/3 76/16 78/11 79/6 86/23 102/5
424/17 127/12 130/9 I@ither [15] 16/17 20/1Iemployment [1] 81/11 102/25 122/10 I 120/7 163/6
4136/7 147/3 150/23. I 20/7 32/6 49/6 49/16 I 49/23 143/20 154/11 158/20] evening [1] 79/20
154/14 163/20 164/2 I 99/10 83/12 103/19 enabled [1] 101/1 I 173/1 event [4] 66/18 82/13
164/23 165/4 1707 I 106/12 123/18 139/16 encloses [1] 159/16 Iensured [2] 44/23 I 83/20 138/21
173/15 162/17 168/24 176/4 Iencompass [1] 141/9I 103/17 events [3] 83/11
down’ [1] 64/22 element [3] 107/17 Iencompasses [1] 6/2\ensuring [2] 31/15 I 103/11 161/24
draft [1] 109/25 108/12 109/4 encompassing [1] I 154/18 eventuality [1] 16/25
drafted [1] 50/6 elements [3] 6/7 6/3 enthusiastic [1] ever [3] 31/10 38/2
drafting [4] 50/1 22/16 57/19 encourage [3] 96/19 I 60/10 65/5
draw [4] 147/5 Elliot [27] 55/8 55/11 I 133/8 133/14 entirely [5] 85/9 94/4 Ievery [7] 39/13 44/19
drawn [2] 46/3 95/17 56/2 56/3 57/21 58/4 Iencouraging [1] 145/16 146/4 159/13 I 85/22 125/1 127/10
dream [2] 24/6 27/5 58/10 59/4 59/11 150/22 entitled [3] 1/19 139/24 145/25
drive [5] 24/24 26/21 59/24 60/2 61/5 61/7 Iend [19] 12/13 23/15 I 48/25 98/7 everybody [4] 69/12
35/20 35/23 110/16 I 01/21 62/15 63/18 I 109/21 118/3 124/12 entrusted [1] 102/25 I 120/13 126/3 153/23
driven [1] 14/8 63/24 66/21 67/20 133/10 133/10 133/21Ientry [1] 115/20 everything [4] 46/2
68/1 68/13 70/17 133/21 135/5 137/2 Ienvironment [2] 4/11] 103/5 154/19 158/19
(64) don't... - everything
INQ00001193
1NQ00001193
E exposing [1] 76/5 __ Ifaith [3] 40/25 140/6 Ifinds [1] 168/8
evidence [39] 1/3. expressed [6] 37/23 I 160/2 fine [3] 33/9 94/17
evidence Bo) a) 2116 142/17 57/8 62/24 63/5 98/2 Ifall [4] 84/19 144/15
61/21 65/9 70/6 70/23) existed [1] 95/6 101/16 false [1] 141/17 finish [3] 12/17 12/19
7119 71/13 71/19 existence [1] 160/15 Iexpressing [3] 32/13 Ifamiliar [15] 47/17 I 149/3
71/20 98/15 99/1 exists [1] 175/9 32/15 74/18 48/14 53/1 53/4 53/6 I finishes [1] 146/24
111/13 114/16 114/241 exonerated [2] 39/18Iexpression [4] 66/2 I 53/10 53/20 53/24 first [31] 2/14 2/18
148/15 153/13 159/14] 63/8 66/3 66/12 66/14 54/4 54/4 65/21 66/4 I 5/17 6/12 8/14 14/18
1459/24 160/8 160/9 exoneration [1] expressly [2] 49/5 67/1 140/16 172/11 16/12 16/22 21/4
4164/4 165/4 1656 I 176/10 104/17 familiarised [1] 10/1 I 23/12 25/24 27/8
4165/8 165/10 165/13 IexPect [3] 76/6 85/1 extend [2] 1/22 families [2] 44/24 I 30/11 30/20 33/24
168/24 169/24 170/18] 145/20 148/11 100/14 39/21 43/16 43/19
470/23 172/16 173/4 expectation [3] extension [3] 63/20 Ifamily [1] 1/23 45/22 52/12 52/22
4174/5 176/15 1771 I 161/23 162/15 162/19] 147/3 164/14 far [11] 10/10 10/15 I 60/13 69/13 81/9
evidencelrecords [1] I°xPectations [1] extent [11] 18/15 52/6 62/18 75/10 79/9) 95/22 108/8 138/16
170/23 93/6 35/3 36/21 38/2 99/17I 149/17 152/19 169/22) 140/12 157/19 158/25
evidential [1] 1714/1 [@xPected [3] 20/1 I 114/8 114/18 124/19 I 175/23 176/8 171/23
evidentially [1] 91/10 142/22 125/9 168/13 176/24 Ifaults [1] 114/19 firstly [5] 28/18 35/11
139/23 expects [1] 141/4 external [4] 70/13 IFebruary [8] 3/22 I 86/16 87/4 101/1
experience [14] 7/24 I 76/18 93/18 107/8 37/6 85/18 89/18 fit [2] 152/25 153/4
evidentially establish) 37g 44/15 15/24 15/25I externally [1] 90/16 I 105/3 105/13 111/10 Ifive [10] 6/5 9/7
ed [1] 139/23
. 63/21 84/7 101/13 extra [1] 11/13 124/24 11/11 12/6 16/4 39/5
eae Hy 109/5 I t02/17 111/14 111/20] extracts [4] 174/12 Ifed [4] 63/24 163/25 I 42/8 108/7 131/12
exactly [7] 6/4 1516 I 116/23 124/19 151/8 I 175/5 176/14 176/24 I 164/8 168/22 136/20
23/24 87/7 91/20 experience’ [1] 64/2 IExtraEnergie [4] 8/6 Ifee [1] 35/24 five years [1] 131/12
125/9 151/10 experienced [9] 9/2 9/3 9/3 feedback [2] 63/13 I fixed [1] 35/24
examining [1] 22/16 I 115/15 115/19 115/23 I extraordinary [2] 165/24 flagcaseadvisor [1]
example [7] 6/19 116/19 117/5 117/17 I 59/22 59/22 feel [7] 31/23 73/24 I 53/2
53/21 53/22 71/14 I 117/20 120/14 135/22Iextremely [4] 9/12 I 79/25 82/7 102/8 _I flagging [1] 82/25
103/24 106/25 175/5 I@xPetiencing [4] 51/23 75/10 145/17 I 120/22 158/19 flavour [2] 21/22
exception [2] 18/3 I 14/5, 85/7 117/2 FO Ifeeting [3] 22/20 21/25
127/8 117/10 fC 136/40 139/10 flawed [1] 118/3
exceptionally [1] expert [18] 136/13 Iface [2] 35/11 124/1 Ifelt [12] 14/13 14/14 I flowed [1] 103/5
12/22 153/13 159/5 160/7_ Ifaced [3] 14/1 25/25 I 26/12 27/13 80/11 I Foat [23] 21/19 22/1
exchange [10] 54/4 I 160/8 161/10 161/11 I 124/3 80/18 108/17 116/3 I 22/2 22/7 59/8 60/16
95/2 146/20 148/18 I 161/14 162/2 163/9 _Ifacing [5] 10/2 41/14 I 116/5 116/6 116/8 I 60/19 61/13 61/17
1BOI7 186/23 157/5 I 163/22 164/15 165/4 I 69/9 88/24 125/10 I 162/23 63/25 64/4 64/10
157/22 169/25 172/4 I 1895/6 165/8 165/10 fact [22] 13/19 15/16 Ifence [2] 36/13 108/9I 64/20 67/16 68/7
exchanges [1] 84/24 I 165/12 166/9 17/19 33/20 45/1 fenced [1] 102/4 68/25 73/7 74/3 77/1
excluding [4] 2/15 I@xPerts [5] 6/24 92/6I 57/23 60/20 68/11 few [5] 9/21 16/13 I 78/16 78/24 80/9
3/5 3/14 5/2 175/12 175/22 176/3 I 74/12 88/18 92/3 83/5 83/19 117/3 106/4
exclusively [1] EXPG0000007 [1] _I 96/23 103/10 107/13 Ififth [14] 163/20 Foat's [3] 60/21
160/23 114/23 108/25 114/6 119/13 Ifigure [5] 87/6 73/14 78/22
Executive [38] 7/4 [@xPlain [6] 5/24 8/8 II 121/16 121/18 147/3 I 103/25 117/8 117/16 Ifocus [11] 15/2 19/19
8/3 9/18 12/10 12/11 I 38/2 85/20 86/8 127/3I 150/14 154/2 118/10 24/1 24/23 25/1 26/24I
18/2 19/13 23/21 26/8I€XPlained [3] 18/24 Ifactor[1] 173/19 __ file [3] 72/16 72/19 I 34/16 34/19 35/6 36/7}
26/24 27/4 32/7 47/24I 33/7 102I7 facts [4] 56/25 92/25 I 79/3 88/3
57/16 62/24 78/18 _ IexPlaining [3] 9/9 I 96/25 106/9 filenote [1] 73/5 focused [8] 3/23
80/22 82/8 83/13 157/17 163/17 factual [1] 79/6 files [1] 97/8 22/13 25/15 26/20
83/14 83/25 84/4 84/6) xPlains [2] 28/2 _I factually [2] 130/12 final [3] 93/25 94/6 I 86/18 114/10 163/18
84/15 85/19 85/23 I 198/25 167/2 95/13 164/15
86/1 86/2 86/3 93/12 I&XPlanations [1] failing [2] 8/10 finally [1] 108/21 focusing [2] 15/21
104/13 11072 114/3 I 161/12 118/23 financial [5] 24/21 I 27/2
4114/8 114/22 121/15 I@xPlanatory [1] failings [4] 18/16 35/8 47/1 52/2 165/18] follow [3] 123/24
174/18 176/21 176/9 37/8 49/4 106/14 find [6] 46/7 46/22 I 133/9 133/14
executives’ [1] 6/20 I@Plicit [2] 81/19 failure [3] 106/15 I 70/11 70/22 71/10 _ I followed [4] 68/6
exercise [9] 4/6 46/9 I 129/23 106/18 159/25 123/21 105/13 106/21 171/22
66/6 87/12 97/6 98/19I°XPlicitly [5] 32/15 fair [11] 6/1 6/23 finding [4] 23/7 31/14] following [15] 12/6
99/17 12912 123/7 I 32/23 33/6 69/3 107/5I 25/14 58/12 60/9 93/9] 153/16 176/5 24/23 48/22 67/19
exercises [1] 103/22 IexPloratory [1] 139/8I 107/22 142/12 150/7 findings [13] 15/5 _ I 68/2 72/17 75/24
exercising [2] 142/4 I@xPlore [4] 31/10 I 152/4 167/13 19/1 19/4 33/16 34/5 I 105/2 105/22 148/9
155/25 55/2 109/16 139/12 fairly [6] 8/25 27/13 I 93/3 97/14 97/15 148/16 156/23 164/21
exhibited [2] 27/10 I@xPlored [1] 52/7 I 84/9 107/4 17/1 131/12 142/17 154/17I 170/17 177/18
exposed [1] 37/19 I 164/13 175/7 175/9 follows [4] 20/5 52/1
(65) evidence - follows
INQ00001193
1NQ00001193
F fraud [9] 98/2 106/10IFujitsu' [1] 136/11 I 25/11 25/25 26/5 38/9) 130/16 133/5 135/16
Follows. [2} 53/05 I 109/7 129/2 134/16 IFujitsu’s [6] 136/9 I 43/13 47/12 61/4 153/7 158/9 161/21
176/23 134/25 141/16 158/3 I 147/17 147/20 161/20I 70/24 83/1 84/16 170/1 172/4 173/21
foot [1] 97/3 162/16 163/7 164/15 84/19 121/10 122/21 I 174/23 174/23 175/1
footnote [1] 97/3 IFreehills [1] 53/6 fulfil [1] 133/24 127/12 127/14 129/15) 177/14
force [1] 172/4 freezes [1] 115/13 Ifull [7] 2/1056/25 I 134/7 146/6 151/20 Igone [6] 42/20 81/2
forces [1] 153/21 Iffequency [1] 118/16] 82/17 116/1 124/23 I 158/17 166/20 170/24I 110/19 131/3 133/13
fore [2] 93/17 94/3 frequently [1] 117/3 I 125/6 129/14 getting [13] 17/14 139/2
foremost [2] 16/22 {ftiendly [1] 24/11 [fully [5] 37/10.41/7_ I 17/17 25/13 30/13 Igood [16] 2/8 17/13
1088 friends [1] 1/23 71/20 168/19 169/20 I 78/11 78/12 119/18 I 40/25 81/20 82/7
forensic [2] 129/13. Ifront [1] 25/16 fulsome [2] 80/11 I 120/6 120/13 121/3 I 94/25 116/14 119/2
161/11 frustrated [2] 149/23I 80/19 122/7 128/13 130/2 I 123/23 128/4 129/16
forerunner [1] 49/18 I 149/25 function [10] 18/21 IGFA[1] 73/11 146/25 147/6 152/12
forgiven [1] 153/8 _ I*ustrating [1] 71/4 I 21/16 32/8 86/8 91/4 Gillian [1] 1/6 157/24 170/14
forgotten [2] 127/18 Iftustration [1] 69/4 I 103/1 105/7 144/8 give [13] 2/10 21/22 Igood-faith [1] 40/26
152/24 FSL [2] 163/1 163/12 I 169/20 173/7 21/25 29/9 29/11 goods [1] 101/25
form [6] 43/1 89/1 IFUY00243158 [1] [functionaries [1] 30/18 101/24 136/13 Igosh [1] 30/4
89/15 107/18 109/25 I 147/2 92/1 136/20 159/5 163/9 I got [14] 2/22 28/2
175/13 FUJ00243191 [1] _Ifunctioning [1] 85/1 I 165/6 169/3 45/22 80/14 83/6
formal [2] 62/20 170/5 functions [2] 52/23 I given [25] 4/5 20/19 I 114/1 114/8 119/25
170/25 FUJ00243192 [1] 106/12 24/6 25/9 31/17 36/1 I 120/19 121/23 121/24
formalities [4] 1/24 I 173/10 fundamental [6] 8/18] 43/6 48/19 51/2 66/18) 123/12 130/22 135/23}
formally [4] 30/19 IFU400243199 [2] 13/10 13/16 40/7 67/6 73/17 83/15 84/2I governance [2] 8/13
61/14 62/5 78/5 140/15 149/1 84/11 122/19 88/21 102/21 111/15 I 8/15
format [1] 171/1 FUJ00243201 [1] fundamentally [1] 111/18 112/19 112/22I government [13]
formed [1] 69/13 154/5 46/1 121/24 122/13 139/13] 24/2 24/24 25/19 31/1
former [6] 43/15 FUJ00243203 [2] funding [1] 73/13 _ I 144/6 146/5 31/9 31/10 101/12
47/18 48/19 50/12 I 137/21 146/19 funds [2] 99/9 99/12 Igives [1] 87/21 102/8 107/11 107/15
95/4 97/12 FUJ00243204 [1] _Ifurther [12] 45/18 —_Igiving [3] 29/9 42/23 I 129/4 132/2 132/21
forthright [2] 42/22 I 158/23 49/9 70/12 119/9 62/7 government-linked
69/7 FUJ00243206 [1] 147/18 148/18 148/21Iglimpse [1] 84/2 [1] 107/15
forum [2] 51/12 163/15 161/1 166/11 168/10 IGLO [8] 1/19 14/20 Igoverns [1] 108/18
65/24 FUJ00243209 [1] 173/21 173/24 20/19 20/20 21/12 Igrain [1] 54/11
forums [1] 119/21 I 164/23 future [8] 8/23 26/20 I 25/7 31/6 36/20 grant [1] 73/13
forward [12] 20/13 /FUY00243211 [1] 26/25 46/1 74/12 IGmbH [1] 8/6 grapple [1] 37/10
22/17 35/7 37/5 38/18I 167/23 154/22 167/13 167/15Igo [48] 2/193/16 —_ I grass [2] 64/20 69/1
38/25 42/24 63/8 65/2IFujitsu [80] 63/17 I I 4/16 11/3 11/9 13/21 I grateful [4] 49/20
74/23 85/14 89/12 I 130/2 136/3 136/12 14/16 23/13 30/9 56/22 139/15 148/11
forward-looking [1] I 136/16 136/19 136/25Igaps [1] 82/22 31/11 37/11 43/24 Igrave [1] 77/7
38/25 137/11 137/15 138/1 IGary [3] 43/15 48/17 I 43/25 44/2 45/16 gravity [1] 75/22
forwarded [1] 74/2 I 138/11 138/18 138/21] 95/3 46/15 47/14 49/21 I great [4] 1/20 6/1
forwards [5] 14/16 I 138/22 139/8 139/17 Igave [3] 33/19 57/12 I 64/19 64/20 64/21 I 18/24 153/2
19/9 23/6 26/15 62/22) 140/4 140/5 140/22 I 65/9 68/3 69/1 72/21 72/25I greater [2] 109/11
found [18] 15/7 16/12) 1414 14176 142/2_ IGE [6] 85/2093/11 I 78/25 88/22 91/9 127/12
30/11 83/25 47/6 47/8) 142/9 143/13 143/16 I 93/12 105/22 108/23 I 93/24 95/19 95/22 IGreg [4] 31/12 31/17
52/3 56/12 56/23 145/18 145/23 146/9 I 106/4 96/13 97/2 106/5 31/25 34/17
59/11 66/11 70/5 147/12 147/14 147/23] general [22] 21/16 107/6 109/19 111/12 I grips [3] 25/13 26/1
87/15 98/22 99/22 I 148/1 148/11 148/22 I 21/19 26/7 26/23 32/6) 116/17 120/4 123/20 I 26/5
115/3 180/68 176/7 I 190/3 155/24 156/2 I 39/8 47/21 50/16 127/15 130/24 134/8 Iground [1] 157/25
foundations [1] 156/2 156/19 156/24 I 60/22 77/1 83/25 84/4I 146/19 147/2 149/1 I group [22] 1/16 3/22
157/7 158/2 159/5 I 84/15 85/18 100/8 I 149/14 166/18 6/20 7/4 18/2 19/12
four (12) 212 9/18 I 159/11 160/2 160/5 I 104/12 110/1 114/53 Igoes [9] 20/22 54/11 I 26/8 27/4 37/20 67/10
1118 21/4 24/7 30/11 I 160/8 160/13 160/24 I 121/15 153/16 173/7 I 60/20 83/16 84/14 I 77/3 83/14 84/6 85/23
38/25 63/3 101/22 I 161/3 16/7 161/16 I 176/21 99/5 124/11 149/13 I 86/1 86/1 86/2 86/3
1408/7 131/11 162/9 161/25 162/4 162/20 Igenerally [2] 118/11 I 174/11 93/12 104/1 108/19
fourth [4] 5/15/17 I 162/23 163/22 165/6 I 149/9 going [41] 2/13 15/23I 114/8
6/13 46/19 165/7 165/12 165/23 Igenerated [1] 160/22] 19/5 19/21 22/12 29/7I groups [2] 109/1
Fraser [8] 19/2 19/23I 166/1 16/4 166/8 —Igeneric [1] 53/2 29/14 38/22 43/25 I 119/22
152/19 152/22 153/11] 15/9 166/11 167/1 Igenesis [3] 88/20 I 51/23 55/20 60/6 grow [1] 132/6
474/13 175/20 176/1 I 1697/6 167/20 168/8 I 108/24 131/21 60/13 61/23 62/3 growing [6] 8/22
Fraser J [1] 19/23 I 168/12 168/24 169/24Igentleman [1] 1/5 I 67/12 69/3 81/3 82/13] 38/8 132/8 132/17
Fraser's [4] 13/5 I 171/10.171/12 174/16Igenuine [1] 42/25 I 62/21 83/5 103/14 I 132/18 132/22
4176/5 176/14 177/15 I 171/21 172/2 172/7 I Igenuinely [1] 34/25 I 108/5 111/12 114/21 I growth [1] 8/9
173/4 get [24] 8/22 21/2 I 114/23 125/2 128/19 I guess [7] 8/2 29/7
(56) follows... - guess
INQ00001193
INQ00001193
G 64/24 65/23 65/25 [he's [4] 45/18 52/22 I 64/22 65/11 67/23 I 144/6 147/15 148/14
guess...[5] 428 I 69/6 74/25 75/4 75/11) 66/22 130/3 79/3 95/6 150/9 151/3 151/5 151/25
NON Salt? 71/20 I 76/16 79/4 81/2 82/9 Ihead [6] 57/3 75/12 I 151/19 151/19 152/17 152/23 153/3
1339/4 85/5 89/22 96/15 99/1] 75/13 111/10 137/23 Ihimself [3] 44/9 153/6 153/12 155/1
guessing [1] 53/18 I 109/12 101/18 10315 I 157/15 58/10 63/1 155/12 155/19 155/22
tuidance [1] 127/17 I 103/6 103/7 10378 Iheaded [2] 31/6 his [33] 2/1 28/21 I 156/6 156/11 156/17
Ovidelines Ey 14/1 I 07/1 110/16 111/13 I 47/18 28/21 29/9 29/11 156/25 159/23 160/13
perenne 111/14 111/15 113/14] heading [2] 23/12 I 29/14 31/13 35/7 38/1I 160/19 160/20 161/16
ane 13 feb 120/25 121/15 124/14] 51/19 38/3 44/8 49/6 49/11 I 165/20 166/4 166/22
guilty [4] 39/11 39/18] 1269 129/16 131/3 Ineads [1] 132/19 I 86/21 58/4 59/4 61/11) 170/20 17112 171/13
A716 64/1 131/5 131/6 136/24 Ihear [2] 1/3 80/14 I 63/12. 63/17 63/19 __I 173/4 173/18 174/3
—_ I 139/2 139/6 139/13 Iheard [12] 41/11 64/8 64/10 64/11 174/10 174/12 174/16
H 142/23 143/16 143/19I 62/15 69/21 70/23 _—_I 64/14 78/23 80/5 95/7I 174/19 175/6 175/7
had [187] I 144/22 154/15 195/23] 80/25 99/1 101/23 I 114/13 151/20 152/24] 175/9 175/12 175/23
hadn't [4] 20/12 62/5 I 157/6 187/9 187/18 I 111/13 114/16 114/24] 186/4 158/25 158/25 I 176/4 176/17
62/6 92/16 158/11 160/9 160/13 I 143/22 149/12 historic [6] 10/4 Horizon's [2] 49/4
half [2] 115/3 1317 I 160/24 161/2 161/13 Ihearing [1] 17/18 I 15/11 21/16 22/3 171/16
halfway [2] 28/12 _ I 165/12 165/17 165/20IHearings [3] 69/15 I 93/15 94/2 horrendous [1] 76/14
2B/12 166/11 168/14 173/11] 70/2 70/10 hiatorial [5] 37/7 Ihorse [1] 89/19
f 17415 heart [1] 46/2 46/23 52/4 93/20 _I hostility [1] 75/15
Hamilton [2] 54/12 I cmt [3] 52/6 134/1 Iheavily [1] 105117 I 128/5 hours [4] 11/13 57/2
handed [8] 13/6 168/22 heavy [5] 58/13 historically [4] 22/15I 81/23 127/9
34/10 58/13 59/16 Ihave [203] 59/16 60/5 60/11 68/20 88/24 90/23 Ihouses [1] 161/21
60/5 60/11 111/21 Ihaven't [11] 65/7 I 111/21 history [6] 11/4 12/9 Ihow [51] 20/14 24/21
4113/2 69/5 70/5 71/5 121/23I heavy-handed [5] __I 81/10 83/22 100/21 _ I 28/2 29/18 32/24 36/6)
handing [1] 23/16 I 121/24 121/24 168/19] 58/13 59/16 60/5 144/6 36/16 45/7 48/3 57/14
handling [4] 40/23 I 169/2 169/25 173/5 I 60/11 111/21 hm [2] 157/16 172/8 I 60/6 61/19 64/13 67/2
42/14 68/6 72/7 having [18] 15/9 17/9Iheld [2] 82/23 127/9 IHNG [7] 34/7 171/18 I 68/17 68/20 69/8
hands [1] 37/25 24/9 29/10 73/20 — IHELM [1] 64/4 17419 175/11 175/13 I 75/18 75/23 76/2 76/6
Hannah [2] 52/25 I 73/21 74/18 82/4 Ihelp [14] 29/20 52/24I 175/22 176/2 80/5 80/22 83/2 90/10
53/1 114/15 121/17 130/4 I 67/9 70/25 105/1 HNG-A [6] 171/18 I 91/11 93/20 113/4
happen [10] 18/13 I 133/22 140/6 150/18 I 105/12 105/21 120/4 I 174/9 175/11 175/13 I 113/24 115/4 117/21
20/13 38/13 38/19 I 153/2 153/7 160/2 I 122/8 122/21 138/10 I 175/22 176/2 118/10 119/3 119/4
30/2 76/2 82/16 144/2I 165/3 145/7 158/13 175/16 IHNG-X [1] 34/7 119/5 120/19 120/25
148/5 154/13 he [89] 21/20 22/10 IHelpdesk [1] 161/4 Ihold [3] 46/23 54/1 I 122/8 125/14 128/22
happened [18] 6/5 I 27/10 29/3 29/4 29/14Ihelped [2] 56/21 56/25 131/3 131/8 133/19
15/13 21/24 23/19 I 29/15 29/15 29/18 I 151/19 holds [1] 143/13 135/13 135/17 139/3
27/21 35/20 38/10 I 30/2 30/4 30/10 30/19Ihelpful [3] 81/5 83/12Ihole [1] 57/3 139/21 143/3 156/15
38/11 38/22 55/21 I 30/24 34/24 35/4 128/10 holiday [1] 18/4 156/25 158/13
57/11 71/1 78/15 37/23 38/2 43/16 helpfully [1] 95/17 Ihome [1] 56/1 however [9] 46/6
83/12 83/19 109/17 I 43/25 44/1 44/3 44/4 Ihelping [1] 6/25 homes [2] 44/24 70/12 89/11 89/24
110/16 134/2 44/16 46/20 47/13 Ihelps [1] 109/13 47/0 127/25 141/13 142/6
happening [5] 20/13 I 48/1949/10 49/16 IHence [1] 175/14 Ihonest [2] 79/17 156/11 173/17
61/16 64/7 75/20 52/13 52/13 52/15 IHenry [5] 58/7 67/5. I 135/16 HR [4] 4/5 46/23 52/4
133/15 52/17 52/19 53/15 I 67/10 73/8 82/10 _Ihope [2] 48/9 83/8 I 97/8
happens [4] 84/12 I 93/16 55/24 59/9 —_Iher [6] 1/9 48/2 48/6 /noped [1] 72/5 HSS [3] 42/15 42/24
120/10 124/7 156/15. I 62/15 63/2 63/15 58/22 92/15 92/18 Ihopes [1] 173/24 I 42/24
happy [4] 67/23 63/25 64/15 65/1 65/9IHerbert [1] 53/8 Horizon [95] 1/10 IHub [2] 120/11
83/21 151/18 155/23 I 95/11 65/1265/16 here [17] 22/22 22/24] 3/20 10/14 12/17 125/18
hard [6] 2/20 2/23 I 65/17 65/19 65/20 _ I 30/5 31/4 36/17 38/15] 13/13 23/14 24/7 I huge [4] 26/4 28/16
4/16 5/11 45/25 76/10 79/1 79/4 79/5 I 41/17 56/9 58/25 24/17 25/5 26/19 30/21 30/24
119/13 80/11 80/19 104/4 I 66/22 83/9 99/3 103/4I 26/25 32/9 33/18 IHuman [3] 69/14
harder [1] 14/8 130/2 130/11 130/12 I 109/4 134/8 145/4 I 33/22 33/23 34/6 34/8I 70/1 70/10
harm [1] 24/12 138/2 140/20 141/1 I 162/13 40/24 42/8 44/4 44/11I hundreds [3] 124/2
has [91] 6/5 11/10 I 141/23 143/19 150/8 Ihigh [5] 14/7 33/17 I 44/12 82/14 106/15 I 126/11 145/22
11/23 12/5 27/23 30/4I 151/18 152/10 153/11) 44/7 90/19 91/5 106/17 112/11 112/25I husband [1] 1/12
39/16 40/12 40/15 I 153/16 153/18 153/23] higher [1] 172/5 114/18 115/5 116/20 Ihypothesis [1]
41/15 42/20 44/9 45/9I 157/7 158/24 159/3 Ihighlighted [4] 30/5 I 120/9 121/21 124/20 I 106/22
46/3 46/9 48/20 49/10I 159/8 159/11 159/13 I 76/13 128/13 130/8 I 125/11 126/22 1268/1 IF
159/16 160/4 163/18 Ihighly [1] 8/19 129/25 130/6 130/19 IE_
ar ee 58/6) 164/10 164/11 165/1 IHId [3] 26/6 34/4 131/9 132/3 132/12 Il absolutely [1] 57/24
59/24 60/17 63/13 I 165/1 166/8 166/9 I 131/12 132/13 137/22 139/11I1 actually [1] 29/13
64/11 64/14 64/23. I 167/20 him [13] 28/22 28/23 I 142/10 142/22 143/1 Ilagree [1] 13/12
he'd [1] 80/11 35/14 60/22 62/17 I 143/13 143/17 143/24II also [1] 66/5
(7) guess... -Talso
INQ00001193
INQ00001193
1 110/20 110/25 111/4 II meant [3] 23/25 I turn [3] 39/4 100/4 I 135/1 135/15 145/16
Tam [21] 40/3 41/9 114/1 114/8 122/1 71/20 126/2 104/23 152/1 152/3 152/21
41/12 45/20 53/15 123/6 123/8 123/11 I mentioned [2] I understand [4] 1/24) 153/6 153/17 162/5
54/19 56/4 56/22 130/1 134/17 134/20 I 54/16 111/20 89/6 90/17 138/4 162/6 162/6 168/19
71/23 73/20 75/18 149/10 150/1 158/11 II met [3] 18/2 18/4 II understood [1] 169/3 169/5 169/5
83/10 138/20 147/17 162/1 35/13 151/21 169/22 170/1 170/2
152/15 155/23 158/6 I! dropped [1] 67/20 II missing [1] 57/3 luse [1] 135/19 172/11 174/23 176/20)
169/16 173/6 173/8 I drove [1] 56/1 Ineed [1] 139/22 lused [2] 77/22 176/22
474/21 lentirely [1] 94/4 I needed [2] 57/2 111/21 I've [23] 2/22 16/18
I appreciate [1] l exhibited [1] 27/10 I 149/25 I want [3] 29/25 22/19 23/5 27/5 41/1
170/21 lextend [1] 1/22 I note [1] 147/20 109/16 153/6 41/2 61/20 65/22 83/8
I arrived [1] 34/18 I familiarised [1] 10/1I1 obviously [2] 16/12 II wanted [2] 30/10 101/16 101/21 101/23)
I ask [3] 2/9 138/10 I first [1] 52/12 138/7 149/15 114/10 120/19 121/7
170/16 I follow [1] 123/24 I passed [1] 58/5 I was [37] 3/18 8/11 I 123/24 127/18 149/2
I asked [2] 88/2 95/1 I found [1] 150/6 I prepared [1] 72/16 I 9/3 14/3 15/19 15/23 I 153/17 153/23 169/8
lassume [1] 73/11 I go [2] 30/9 31/11 I provide [2] 19/11 17/8 19/3 24/14 25/24I 169/9
I believe [5] 6/5 70/7 I! 99ing [1] 81/3 2116 26/10 26/20 29/7 30/1Iidea [2] 66/16 127/12
4110/3 110/5 143/25 I got [1] 45/22 raised [1] 168/11 31/16 35/17 35/19 identification [2]
I believed [1] 35/23 I guess [6] 29/7 42/3 II read [1] 47/20 36/18 37/22 39/15 67/6 114/11
call [1] 2/4 42/17 51/17 71/20 recall [2] 10/11 66/10 67/20 77/23 identified [12] 12/5
Icame [4] 20/23 133/4 57/13 78/7 78/9 79/14 91/20I 19/23 21/5 46/6 88/13
lean [12] 32/14 I had [12] 9/9 10/16 Il received [2] 19/20 I 103/15 113/19 125/4 I 91/1 98/15 106/15
45/15 46/25 66/15 14/18 16/10 18/6 19/3I 32/25 126/25 145/17 149/25] 106/18 112/17 155/16
85/22 86/10 87/20 22/11 27/8 38/6 38/7 II recognise [1] 90/8 I 150/17 152/19 174/21] 165/19
39/24 94/8 145/13 I 38/16 45/4 Iregard [4] 153/18 I 177/13 identify [10] 8/23
1453/8 154/21 Ihave [20] 1/4 3/7 Ireplied [1] 145/18 II wasn't [5] 52/6 47/24 87/12 88/5
lcan't [4] 38/1 88/22 16/9 16/15 16/18 I request [2] 75/22 150/19 172/14 176/13] 98/20 112/17 119/4
1469/3 175/16 22/19 44/20 51/4 17118 176/16 131/3 152/9 152/10
I certainly [2] 57/22 I 56/25 66/14 70/17 [I said [9] 20/9 84/17 II welcome [1] 156/18Iidentifying [2] 58/23
69/6 73/17 95/17 132/16 I 88/23 135/19 150/2 II will [4] 46/19 46/21 I 130/25
I characterise [1] 143/22 152/24 153/18) 152/18 158/10 162/14I 56/4 139/18 ie [9] 3/4 6/19 10/14
168/12 176/7 177/11 I 175/2 I wish [1] 70/15 15/17 29/1 71/12
I chat [1] 57/1 I haven't [6] 65/7 Isat [1] 79/16 I within [1] 17/23 121/21 174/19 176/14)
I continue [1] 55/2 71/5 168/19 169/2 I saw [2] 29/8 36/3 II wonder [1] 136/5 _Iie leaning [1] 174/19
I could [5] 35/6 39/12) 189/25 173/5 I say [14] 17/25 18/9 II work [1] 171/7 ie one [1] 6/19
S15 10812 177/12 I heard [1] 62/15 22/4 26/13 32/24 —II worry [1] 75/15 _Iie picking [1] 176/14
I couldn't [1] 104/6 I hope [1] 83/8 36/11 60/5 71/22 I would [24] 8/2 17/1 Iie replacing [1] 10/14)
Ideal [1] 45/7 lidentified [1] 21/5 I 84/18 119/6 121/13 I 29/4 30/7 32/23 42/19] ie some [1] 71/12
I decide [1] 177/16 I inadvertently [1] 169/2 169/25 172/14 I 42/21 48/3 58/13 72/2\ie the [3] 3/4 15/17
I described [2] 20/22 67/14 I sent [1] 67/5 73/18 79/12 84/20 121/21
O72 I interpreted [1] I shared [1] 149/7 I 100/2 100/11 100/16 Iie you [1] 29/1
I did [10] 10/5 13/24 150/16 I should [4] 29/16 100/23 101/5 103/3 lif [129] 1/24 2/18 3/5
14/10 14/20 15/12 I interrupted [1] 97/3 99/2 177/14 103/9 136/4 141/22 I 3/15 5/16 7/18 9/21
21/23 26/7 26/18 54/5 48/17 I simply [1] 153/2 145/22 173/6 11/3 11/9 12/1 13/21
110/5 I joined [3] 18/3 I sincerely [1] 48/9 [I'd [5] 20/25 25/9 14/16 21/18 22/17
I didn't [7] 15/24 18/25 29/12 I spoke [4] 68/7 70/9 I 57/19 61/11 67/23 23/5 23/10 23/12
15/25 20/4 30/14 I just [7] 5/13 28/9 80/10 164/10 [9] 8/11 18/18 26/15 28/10 31/19
31/22 68/1 149/22 33/4 61/4 102/19 I started [1] 18/5 22/24 29/25 43/19 38/17 39/15 40/19
I disagree [1] 54/1 120/22 153/22 I still [2] 16/9 131/4 I 63/4 87/7 97/16 147/5I 43/18 43/24 43/25
I discovered [1] 66/9 I knew [1] 175/3 I strongly [1] 76/10 [I'm [72] 2/21 15/21 44/2 44/15 45/16
Ido [6] 70/17 95/12 I know [8] 47/3 62/11II struggled [1] 38/24 I 22/20 24/22 32/14 45/16 45/17 46/12
99/19 102/2 104/10 69/5 81/12 82/4 121/9II suggest [1] 104/7 I 32/23 35/15 38/14 46/15 46/16 46/17
168/10 124/4 150/9 I suggested [1] 56/20) 40/10 41/25 42/2 42/3) 46/23 47/2 47/5 47/12)
I don't [48] 6/6 6/9 I look [2] 42/17 55/21I1 summarise [1] 43/9 46/17 48/13 47/14 48/4 48/7 49/21
17/9 18/8 18/9 18/11 Hooked [1] 102/12 I 57/15 51/19 51/20 52/6 53/1) 50/5 50/8 51/24 57/15)
28/24 39/12 43/10 _I! love [1] 175/16 I suppose [2] 150/20 I 53/4 53/6 53/10 53/20] 58/2 59/7 61/18 61/19
52/7 54/5 54/10 54/151 I made [2] 23/23 66/8I 152/12 54/4 54/4 54/20 61/2 I 62/4 62/25 63/17 64/1
57/10 64/25 77/21 I may [3] 43/10 52/7 II suspect [1] 162/23 I 61/2 62/1 78/2 81/24 I 64/7 64/25 68/20
81/18 82/12 83/22 102/12 I take [1] 145/22 86/6 94/4 94/4 109/25] 70/10 72/1 72/21
84/10 84/17 84/20 I mean [13] 30/3 I then [1] 30/11 110/25 111/12 113/22I 72/25 73/14 77/21
85/3 90/8 90/12 92/15 31/21 32/14 35/24 I therefore [1] 67/25 I 114/21 114/23 119/11] 78/21 80/8 86/4 87/12)
99/19 103/14 104/17 42/23 59/7 60/20 I think [233] 126/6 130/10 130/10 I 88/10 88/12 93/9
109/13 109/24 109/24! 61/18 90/6 92/16 I took [5] 29/17 32/16] 130/10 130/16 131/21] 95/19 95/22 96/13
103/3 110/8 150/14 I 44/16 44/17 72/1 132/14 132/20 134/20] 96/22 97/2 97/7 100/8)
(58) Lam - if
INQ00001193
INQ00001193
I 139/21 133/12 143/14 143/17 144/15] interest [2] 2/1
if. [511 1024 1047 impression [3] indeed [30] 2/24 3/9 I 149/13 149/13 149/19] 107/16
106/1 106/5 107/3._ I 112/18 139/13 16/2 I 4/20 5/6 16/1 17/10 _I 156/20 160/10 171/7 I Interestingly [1] 31/9
4107/6 107/6 107/15 IiMproper [2] 42/12 I 18/13 20/11 41/5 67/7I 172/19 172/20 173/25] interests [2] 93/6
96/19 70/10 77/25 82/4 informed [3] 44/11 154/18
eons tooo too9 improve [3] 12/4 82/20 82/21 83/13 87/17 139/6 internal [7] 37/5
413/9 113/10 113/14 45/25 122/9 87/17 88/15 88/17 initial [1] 20/24 37/21 38/4 76/18
4114/7 116/17 117/16 improved [1] 135/20 I 88/19 89/21 118/22 _Iinitially [2] 37/3 107/23 119/6 135/21
418/10 122/13 123/2 improvement [2] 136/1 142/17 148/3 I 104/24 internally [1] 119/23
423/7 123/17 123/21 3/21 26/22 150/16 151/13 155/9 Iinitiated [3] 20/12 interplay [1] 109/5
427/3 127/12 127/14 inaccuracies [1] 79/6I 168/21 169/18 22/4 155/8 interpret [1] 100/2
428/19 129/8 132/14 inadvertence [1] independence [4] injustice [1] 14/1 interpretation [3]
1436/7 136/18 138/13 74/15 42/25 102/3 103/7 injustices [1] 34/25 I 99/11 150/14 152/25
139/15 141/1 144/14 [inadvertent [1] 67/22) 173/17 innocence [2] 39/6 I interpreted [4] 140/4
1447/8 148/25 150/8 inadvertently [5] independent [16] 122/24 150/16 153/20 160/1
450/23 151/15 152/4 67/4 67/5 67/8 67/14 I 35/5 35/15 37/4 37/15Iinnocent [3] 39/14 I interrogate [1] 131/9
1453/8 158/4 164/2 74/2 71/12 108/10 129/17 I 64/2 160/16 interrupt [1] 162/5
166/18 170/6 170/9 inappropriate [3] 142/4 155/6 155/7 inordinate [1] 62/10 Iinterrupted [1] 48/17
1472/22 63/15 138/21 159/14 I 155/25 160/9 161/10 Iinput [2] 49/20 81/20 I interview [6] 9/23
ignore [1] 28/1 incapable [1] 160/8 I 165/9 166/8 167/16 inquiry [48] 1/21 2/2 I 9/24 10/11 10/16
ignored [1] 80/5 incendiary [1] 143/10Iindependently [1] _ I 2/9 2/13 16/2 16/8 I 10/21 144/20
iif) 155/9 incentive [2] 4/13 I 101/21 36/22 37/4 37/9 37/15) interviewed [1] 70/8
ii [1] 155/10 133/8 indicate [1] 141/2 37/21 38/5 38/12 interviewing [1]
ill [1] 43/17 incentives [1] 46/22 icated [1] 153/17 I 41/11 50/5 50/19 51/9) 144/17
illuminating [1] incentivisation [7] _ Iindication [1] 10/16 I 52/18 61/12 64/9 interviews [3] 71/2
51/24 95/25 96/10 96/16 indirectly [2] 139/10 I 64/10 66/18 69/6 97/11 144/12
illusions [1] 81/16 97/19 98/16 99/7 166/3 70/23 83/4 85/6 85/8 intimidated [1] 88/17
immediate [1] 51/17 99/18 individual [10] 82/23 I 87/14 87/24 88/2 88/5] intimidating [1] 40/9
incentivise [1] 96/19 I 93/13 97/9 98/9 88/7 88/19 89/5 89/6 Iinto [58] 4/21 8/12
immediately [2, A fai
64/21 ately I ] incentivised [1] 46/4 I 106/24 109/9 120/4 I 89/22 93/8 93/21 99/1) 9/3 9/11 11/24 15/12
immense [1] 9/4 incentivising [1] 123/17 133/6 151/15 I 106/21 111/12 112/2 I 20/23 21/24 22/8
panes 133/24 individual's [2] 89/15] 137/2 140/17 142/18 I 25/12 26/18 27/22
tapas: I Be0 incidents [2] 161/24 I 98/12 143/22 152/18 159/15I 28/5 29/6 29/23 30/9
oes 32/2 32/10 34/1I.167/9 individually [1] insert [1] 4/2 33/13 36/22 37/14
69/15 70/1 70/10 incidents/events [1] I 133/17 insofar [1] 153/19 37/16 43/10 43/13
450/12 161/24 individuals [44] 16/5 Iinsourced [1] 161/2 I 44/1 56/9 57/21 59/15
impacted [1] 38/9 included [8] 43/5 39/9 41/13 41/21 installed [4] 170/20 I 60/1 61/19 62/4 62/9
impacting [2] 149/20 45/12 48/1 48/20 41/24 42/11 44/23 170/23 171/17 174/6 I 63/14 64/20 64/20
1467/9 72/10 97/8 97/21 46/24 51/10 65/14 instance [1] 43/16 66/7 69/1 77/12 80/5
implemented [4] 107/5 69/8 69/14 69/15 instances [1] 45/4 81/2 81/20 82/1 84/2
143/20 145/11 145/14 includes [3] 40/24 69/22 70/3 70/12 instant [2] 153/9 91/17 97/13 108/18
145/16 72/14 144/19 70/20 74/20 75/7 153/10 108/20 109/10 111/12)
implicated [3] 92/19 including [23] 25/3 I 75/12 75/16 76/7 Instead [2] 24/1 114/1 114/8 119/9
1400/5 103/11 25/22 47/9 47/16 85/24 87/9 87/13 88/4) 24/19 123/20 136/2 137/12
implications [15] 53/21 55/5 63/10 88/6 88/11 88/18 instructed [1] 46/7 146/21 150/19 155/11
10/19 17/11 18/19 63/10 63/14 73/4 88/21 89/2 90/1 90/3 Iinstruction [1] 29/23 I 165/18 169/16
18/23 19/5 19/13 25/4 78/23 93/6 127/16 90/10 90/14 90/15 instructions [3] introduced [1] 133/7
127/22 143/16 149/5 I 90/22 91/1 92/5 92/19I 30/14 30/15 30/16 introducing [1]
25/22 26/5 26/14 34/7, ;
34/8 36/15 75/9 82/20I 109/13 155/2 155/19 I 93/8 93/21 104/22 instrument [1] 64/11 I 133/18
° . 156/12 160/17 161/4 I 108/21 integral [1] 40/18 introductory [1]
ee Cet ote 167/8 induction [1] 81/14 integration [1] 161/4 I 171/24
important [22] 26/2 inclusion [1] 48/2 inevitably [2] 153/20 Iintegrity [6] 56/19 invariably [1] 131/4
26/2 29/8 30/2 52/13 inclusively [1] 1711/4 63/15 146/5 146/5 inventive [2] 4/12
58/1 58/9 58/10 68/18). 164/14 inexcusable [1] 149/20 150/15 44
77/23 80/4 82/11 83/9Iincome [1] 8/17 104/14 intend [1] 168/10 inverted [3] 103/18
90/25 102/25 103/24 incomplete [1] 4/5 _ Iinfer [1] 135/3 intended [2] 75/6 113/24 153/14
108/17 109/4 115/1 inconclusive [1] inference [3] 109/8 I 96/8 invest [1] 25/19
1421/5 136/1 139/21 139/8 141/12 144/16 intent [1] 81/20 invested [1] 154/15
importantly [5] 37/5 inconsistent [2] inflicted [1] 24/13 intention [2] 36/3 investigate [13] 41/6
68/12 110/12 112/12 109/3 110/10 influence [1] 173/16 I 107/24 69/23 75/23 99/17
422/10 incorrect [5] 65/11 influenced [1] 38/3 intents [1] 145/5 106/16 106/18 110/14)
imposing [1] 121/1 65/12 65/16 65/19 information [18] interaction [5] 85/17 I 118/21 130/23 131/9
impossible [2] 24/8 80/1 11/23 30/8 70/25 100/5 107/8 127/17 145/2 145/7 176/23
increase [2] 127/21 I 80/15 113/17 139/7 172/20 investigated [7] 56/7
(59) if... - investigated
INQ00001193
INQ00001193
60/17 82/1 120/24
123/14 161/8 176/24
investigates [1]
108/12
investigating [5]
50/2 71/21 106/24
112/9 130/14
investigation [73]
20/15 36/22 40/20
41/24 42/12 55/11
56/9 57/20 58/2 59/11
59/15 60/21 60/25
60/25 61/6 61/15
101/19 105/7 107/23
109/2 111/14 113/21
123/20 127/23 128/1
129/9 129/16 129/18
129/25 130/5 130/19
132/3 132/12 132/13
132/23 136/2 137/7
137/12 138/6 138/9
138/23 142/1 142/7
144/11 144/19 147/25)
148/2 148/15 155/18
166/2 166/6 166/21
169/13 172/12 172/14}
investigations [57]
19/17 43/4 54/9 59/2
62/12 64/18 68/17
68/19 72/2 76/22
76/24 76/25 77/12
78/6 78/9 78/13 88/8
90/11 96/17 100/15
104/23 105/2 105/9
105/18 105/24 107/19)
108/20 108/23 109/9
110/9 110/22 110/24
111/17 111/24 112/23)
126/20 129/11 129/14}
135/11 135/13 141/25)
142/15 144/9 145/2
154/20 155/5 155/8
155/13 159/20 165/17
165/22 166/5 166/16
168/18 168/25 168/25)
171/16
investigative [8]
60/10 61/13 90/23
106/22 142/4 144/8
155/25 169/20
investigator [4]
43/15 45/12 47/18
95/4
investigators [17]
20/2 20/2 20/7 43/5
43/18 44/10 48/19
investigated... [6]
88/16 88/25 88/25
61/18 62/5 62/9 63/14
66/6 66/9 66/10 70/13) 90/23 91/2 92/1 96/11
96/17 99/16 101/7
7817 81/2 96/12 97/25) so41q 401/15 101/18) it [1] 159/25
101/20 103/11 103/18} It'll [1] 2/16
103/20 103/21 103/22Iit's [81] 2/15 2/16
11/2 11/4 12/16 16/10
130/25 131/18 131/20] 119/12 119/2 119/21
185/22 161/13 165/18) "tespective [1]
51/6 64/6 65/5 66/1
98/25 168/9
investing [1] 11/14
investment [2] 12/3
24/2
invite [1] 123/15
involved [56] 6/24
10/7 15/16 40/20
40/23 41/13 42/12
42/13 42/16 42/16
42/24 50/17 52/12
64/17 69/10 69/16
104/10 104/16 108/8
109/12 111/24 112/19)
134/12 137/19 138/20)
173/5
involvement [2]
169/13 169/15
involves [1] 138/6
involving [1] 95/3
126/13
is [465]
Ismail [10] 55/16
56/3 57/5 60/15 65/13,
66/21 72/12 74/17
78/19 79/11
Ismail's [1] 74/22
isn't [8] 6/12 12/16
47/14 83/6 85/9
112/21 132/24 142/13)
issue [38] 15/11
19/15 21/15 36/21
39/19 46/13 50/4 55/8
60/6 60/8 61/9 62/18
68/6 81/7 81/22 85/12
85/14 95/18 106/15
109/5 113/24 114/3
118/8 119/14 122/19
122/24 123/9 126/6
126/8 129/11 129/16
131/8 132/20 133/1
145/7 149/15 153/22
159/12
issues [80] 3/20 3/20
8/15 8/16 8/18 10/9
10/20 13/6 13/13
14/22 15/9 15/19
16/20 17/3 17/10
18/20 19/2 19/9 19/21
20/24 22/14 23/14
24/7 24/16 24/17 25/4
25/5 25/25 26/19
26/25 30/4 32/9 32/10
93/16 94/3 99/2
106/17 108/13 109/7
114/13 115/23 116/2
118/15 119/5 119/10
120/5 120/20 123/4
124/20 124/25 125/5
135/22 153/6 158/3
162/1 162/17 164/12
70/21 71/22 76/7 87/4I 168/4 172/21 174/13
87/13 87/16 88/4 88/6) 174/19 175/6
issues/allegations [1
49/16
it [429]
28/11 30/21 32/14
40/10 47/15 48/5
51/11 53/4 55/10
55/23 58/1 58/12
58/25 60/5 69/14
69/15 74/22 82/10
82/12 83/2 83/3 83/7
83/15 83/21 83/22
84/7 84/9 84/10 84/21
87/6 89/20 95/23 96/3
100/24 101/23 102/19
105/9 108/8 108/16
115/14 119/8 119/14
119/19 121/5 123/2
123/9 123/11 123/11
126/4 127/5 127/8
127/9 130/4 130/4
130/18 131/12 132/2
132/11 132/22 132/25
140/17 143/8 146/4
150/2 152/12 157/3
157/24 163/1 166/14
170/8 170/11 172/15
174/24 175/20 177/13
item [2] 86/5 171/8
item 4 [1] 86/5
iterations [1] 176/4
its [39] 2/15 3/14 5/2
8/14 8/17 9/14 10/19
14/5 11/7 11/7 11/15
14/4 23/16 34/1 36/5
37/25 39/6 40/12
43/17 50/11 72/14
96/4 97/13 100/21
100/21 108/22 111/17
122/7 132/21 142/23
144/8 147/24 148/2
155/12 155/25 156/13.
160/23 167/7 175/13
itself [5] 61/24 113/5
125/19 126/13 168/5
112/10 112/24 112/25
125/10 125/14 127/16
42/8 48/18 49/16 54/8) J
66/14 90/4 90/7 91/25] 75/4 80/4 80/21 83/9
84/1 84/6 84/20 85/10
57/6 60/15 65/18
72/13 74/17 74/23
76/8 78/18 78/25
79/10 111/13 111/15
151/8 151/10 151/12
151/16
Jacobs’ [3] 56/10
58/4 152/5
JAMES [3] 2/6 2/11
178/2
January [16] 37/17
] 66/20 72/23 86/3
111/6 116/20 117/2
130/16 135/4
January 2020 [1]
117/11
Jason [1] 2/9
JB [4] 64/13 76/19
77125 78/13
Jennings [1] 53/5
jeopardising [1] 76/6
Jetfire [1] 172/10
job [15] 8/2 8/21 9/13
10/9 10/12 10/23
10/24 13/17 15/20
15/21 16/11 17/13
17/17 29/7 35/6
jobs [1] 7/17
John [6] 111/8 138/4
138/15 138/15 147/10)
162/24
join [1] 67/25
joined [9] 7/7 7/17
9/19 17/6 18/3 18/25
29/12 134/12 163/18
joining [3] 7/24 14/3
20/6
joins [1] 138/25
joint [2] 60/2 79/15
judge [1] 37/14
judgement [2] 76/1
112/4
judgment [43] 3/20
3/21 10/9 13/6 13/10
13/17 14/23 15/9
16/20 17/3 17/10
18/20 19/2 19/9 19/21
20/24 23/15 24/7
24/17 24/17 25/4 25/5
26/19 27/1 32/9 32/10
34/10 34/20 42/9
54/13 106/17 112/24
112/25 116/2 123/5
153/5 174/13 174/20
175/6 175/10 176/15
176/25 177/15
judgments [5] 25/21
32/2 32/9 34/1 152/18
Jacobs [21] 55/8
55/8 55/12 55/16 56/3I July [12] 43/14 54/7
55/15 62/22 63/3 63/4
417/11 124/23 127/15] 28/12 29/25 32/16
judicial [2] 142/5
142/17
95/3 137/4 158/24
161/19 161/20 163/14}
164/19 165/2 169/18
172/23
jumped [1] 81/23
June [2] 105/14
170/15
jurisdiction [2] 129/2
134/16
just [83] 2/21 5/13
5/15 7/19 8/14 9/21
10/23 11/9 13/13
16/10 17/17 22/19
22/22 23/6 23/12 28/9
33/4 37/3 43/25 44/2
46/17 51/21 55/24
56/8 59/7 61/4 61/20
63/17 64/18 64/25
65/4 67/2 67/12 67/14
68/21 69/3 69/12 71/5
71/5 72/6 72/9 72/9
72/10 72/19 84/16
85/20 86/1 87/19
92/11 94/8 97/16
102/19 105/1 108/3
120/22 124/6 125/4
126/7 126/23 127/3
127/12 127/14 130/10)
131/13 141/1 141/8
144/3 146/19 149/1
152/3 152/13 153/22
155/11 161/18 162/5
168/17 170/6 170/10
172/22 173/20
justice [16] 19/2
69/18 69/22 70/2 70/9
140/1 152/18 152/22
153/5 154/12 174/13
175/20 176/1 176/5
176/14 177/15
juxtaposition [1]
36/18
Karen [2] 22/19
86/10
Kathryn [3] 56/22
59/8 62/1
keen [2] 14/25 53/19
keener [1] 69/7
keep [3] 23/6 43/25
109/20
kept [1] 75/6
key [3] 86/7 129/11
156/12
kind [7] 61/17 78/12
84/14 84/24 109/12
124/18 173/8
kindly [4] 2/12
Kingdom [1] 11/6
(60)
investigated... - Kingdom
INQ00001193
1NQ00001193
K 137/20 116/16 144/1 154/10 I 10/3 10/7 10/10 10/19] loss [11] 8/14 58/23
a 3119 39/93, I laundering [2] 109/8 Ilet [4] 35/13 12/25 14/12 15/5 59/21 108/13 112/9
knew He wes 39/23 I e216 let's [3] 22/23 23/4 I 15/25 16/2417/20 I 113/22 113/24 114/6
know [41] 2/8 15/9 Ilaw [17] 42/6 77/23 I 51/21 20/23 28/10 28/14 I 115/14 118/9 123/23
21/2 47/5 52/23 61/23) 78/2 97/9 97/15 99/5 Iletter [29] 140/10 I 29/1 29/22 30/24 31/4I losses [17] 97/22
62/11 69/5 71/17 106/20 107/12 109/6 I 140/13 140/15 140/16] 33/12 37/20 104/2 I 98/1 98/2 109/10
77/21 81/12 82/4 112/16 113/11 145/21] 141/13 143/10 145/20] 171/10 4111/3 113/7 113/14
82/23 83/9 94/4 150/17 157/12 158/1 I 146/22 148/25 149/2 little [10] 23/6 27/12 I 114/19 127/22 128/6
109/13 109/24 110/18) 162/4 172/20 150/23 155/24 158/24] 45/17 49/8 58/1 89/19I 132/6 132/8 132/18
411/23 120/22 121/9 Ilawyers [4] 46/7 159/16 160/15 164/18] 95/18 152/15 161/21 I 132/22 152/9 156/5
4122/12 122/15 122/18I 33/22 71/10 98/24 I 164/24 165/2 165/5 I 170/6 167/12
4124/4 124/8 1249 [laying [1] 14/11 166/18 168/14 169/3 Ilive [1] 44/19 lost [3] 17/3 17/9
4124/13 125/11 126/5 Ilead [2] 14/15 124/20 170/21 170/24 173/10]lives [2] 100/13 44/24
4130/9 130/21 130/28 I!eaders [2] 127/7 173/20 174/11 174/24] 100/14 lot [10] 3/18 16/19
434/17 135/13 146/22] 143/24 176/9 living [4] 24/5 41/11 65/2 65/22
4150/9 150/10 150/18 I!eadership [11] 7/22 Ilevel [13] 32/25 36/1 Ilocal [2] 36/5 118/6 I 65/23 65/24 71/25
4153/6 158/17 17/18 23/18 24/5 24/9I 63/10 84/4 84/7 84/15ILondon [13] 137/8 I 99/1 149/12
knowing [2] 45/8 I 25/3 40/13 64/10 80/1I 85/7 98/11 98/21 137/10 138/11 138/19Ilots [2] 83/6 136/20
T3124 83/23 108/19 111/22 114/2 120/7 I 139/2 139/5 139/6 love [1] 175/16
knowledge [9] 3/1 _I!eading [2] 21/20 174/21 139/19 147/21 148/8 Ilow [1] 121/17
3/11 4/22 5/8 49/3_—‘I 96/20 levels [4] 109/2 148/12 148/22 169/13} loyal [1] 44/18
75/5 91/23 9o/17__ [leaning [1] 174/19 I 109/3 110/12 114/16 Ilong [6] 2/15 8/23 lunch [3] 94/7 95/1
169/12 leans [1] 176/9 liabilities [4] 58/20 I 61/14 64/20 69/1 103/15
known [6] 15/16 learn [2] 143/25 62/3 132/5 152/5 71124 M
55/12 83/3 83/7 105/9I 194/10 liability [1] 58/5 long-term [1] 8/23 [MO
166/22 learned [4] 116/16 Iliaising [1] 108/16 longer [5] 11/12 made [55] 2/12 5/18
knows [1] 131/8 learning [2] 131/11 Ilife [4] 18/10 47/9 39/19 121/20 122/22 I 6/19 11/10 22/14
KPMG [3] 105/13 I 158/13 85/11 173/8 134/6 23/23 27/15 28/6
105/16 109/22 learnt [3] 74/19 81/12Ilight [7] 68/11 77/7 Ilonger-term [2] 28/19 32/21 33/24
I 107/2 101/6 101/20 108/5 11/12 121/20 41/3 42/5 49/9 51/12
L LEAs [5] 107/13 142/23 159/14 look [43] 2/16 3/16 I 54/2 57/5 57/15 63/17
lack [12] 14/6 40/11 I 108/16 113/14 113/17Ilike [23] 14/14 19/14 I 7/14 9/21 10/23 20/13) 66/8 68/8 69/24 70/21
40/13 40/13 40/14_I 169/41 20/12 30/4 36/12 27/25 34/13 36/25 I 71/17 73/17 73/22
51/17 63/15 64/23 {least [7] 47/4 53/25 I 38/12 39/2 57/2 62/16) 37/7 42/17 43/12 73/22 77/9 79/2 79/21
75/25 79/6 112/4 115/23 116/24 140/24] 63/17 64/18 65/4 43/22 43/23 55/7 79/23 80/25 84/19
142/17 149/20 172/3 68/21 81/15 91/25 I 55/20 55/21 59/7 60/1I 86/14 90/15 91/5 92/2I
Ladies [1] 1/5 leave [1] 168/17 101/23 104/17 109/8 I 62/25 72/9 74/20 92/15 93/4 93/7 95/6
laid [1] 101/2 leaving [1] 161/18 I 120/18 125/16 151/22I 78/21 80/7 81/4 81/15I 101/16 106/24 107/14
Laming [3] 52/25 {led [6] 1/12 9/19 172/12 175/16 95/18 97/16 106/1 I 107/15 111/3 113/9
53/1 53/21 18/20 37/14 40/11 likely [6] 18/13 91/22] 108/9 114/20 127/11 I 119/3 120/1 120/2
Lancashire [1] 170/9 I 50/19 93/17 116/23 116/24 I 134/9 137/18 140/15 I 120/18 158/4 159/12
language [3] 101/25 Ileft [4] 35/9 35/18 I 117/24 4141/1 147/2 154/5 I 161/14 171/22
102/1 168/8 35/24 139/9 Lill [3] 47/12 49/22 I 158/23 163/15 170/4 Imagic [1] 71/9
large [12] 7/22 10/13 Legacy [3] 11/17 54/2 170/10 173/10 magnitude [3] 13/25
10/20 12/22 82/21 I 34/7 175/7 limited [6] 5/19 11/3 Ilooked [14] 5/15 76/2 161/24
82/22 83/25 84/12 {legal [21] 14/19 14/19 20/18 20/21 I 19/14 38/17 56/15 __ I mailbox [1] 80/6
84/18 102/24 138/6 I 18/21.20/19 20/21 I 141/20 70/7 71/3 71/8 72/19 \mails [1] 14/5
158/3 21/16 32/7 49/17 _I limits [1] 173/3 82/1 97/3 102/12 main [1] 127/7
large-scale [2] 7/22 I 49/18.50/17 75/13 ILincolnshire [1] 1/8 I 104/18 147/1 159/17 Imainland [1] 9/15
158/3 92/25 137/1 138/18 _Iline [8] 3/17 4/4 4/10 Ilooking [23] 2/21 _Imaintain [2] 16/6
larger [2] 59/1 109/7 I 138/18 139/18 147/17I 26/16 37/1 65/10 12/1 13/17 15/15 118/20
last [14] 1/7 6/5 169/21 170/16 171/9 I 74/11 131/16 24/11 22/12 22/12 _Imaintains [1] 142/8
11/14 13/22 16/4 173/13 174/15 line 4 [1] 4/10 23/10 24/4 30/3 37/5 Imajor [1] 145/19
37/45 41/23 69/20 __Ilegally [1] 167/2 line 7 [1] 65/10 38/25 46/17 59/17 Imajority [7] 17/2
85/6 89/22 95/19 _Ilength [1] 62/10 lines [5] 11/16 13/23 I 62/25 71/16 72/7 17/42 17/16 27/11
124/8 131/11 131/15 Ilengthy [1] 59/11 15/4 106/21 175/20 I 85/17 99/21 112/10 I 39/15 107/18 117/9
lastly [1] 167/23 lens [3] 92/9 92/14 _Ilinked [2] 99/9 113/19 139/19 145/11Imake [21] 1/4 3/15
late [1] 120/20 93/19 107/15 looks [4] 30/4 108/18] 17/8 24/14 34/24
later [7] 7/21 33/11 [lent [1] 175/5 list [7] 30/3 47/21 147/14 173/7 35/17 38/12 38/14
37/8 56/24 74/17 Iless [7] 31/18 31/20 I 48/1 49/21 52/22 —_IIoop [1] 169/16 42/3 47/7 52/16 68/18}
74/22 7618 92/3 117/7 117/12 I 76/11 81/4 Lorna [1] 56/15 71/5 78/3 88/12 93/25
latest [1] 87/1 117/13 119/20 listened [1] 116/10 Ilose [1] 16/23 96/24 118/17 123/23
latter [2] 86/21 lesson [1] 134/8 literally [1] 71/19 Ilosing [2] 17/41 130/11 152/13
lessons [4] 81/11 litigation [22] 1/17 I 17/20 maker [1] 102/23
(61) knew - maker
INQ00001193
INQ00001193
M 50/23 76/4 96/9 meant [5] 23/25 23/16 43/7 45/3 45/14 109/7
ean 1B) 37/10 49/3I 136/15 160/16 161/7 I 37/15 47/5 71/20 midnight [1] 76/9 117/23 118/13 121/2
makes [5] 31/10 403 168/11 4126/2 might [8] 52/3 53/22 I 124/11 124/15 128/3
making [18] 20/16 matured [1] 131/2 measures [1] 75/19 I 54/21 88/6 89/18 128/20 129/8 138/6
22/13 33/2 37/22 maturity [2] 130/21 Imechanics [1] 67/3 I 102/19 104/15 108/4 I 162/16
77/24 78/9 89/9 158/8 mechanism [1] migration [1] 82/18 Imonth [12] 35/5
103/12 103/14 103/18I™M4y. [48] 2/4 34/4 130/14 million [4] 56/14 38/25 62/8 115/23
103/22 106/4 113/12 34/9 34/9 43/10 43/14I mechanisms [3] 58/18 59/13 145/24 117/4 117/4 118/3
420/17 122/24 131/14 45/21 45/24 46/4 126/21 133/20 133/20) millions [1] 145/23 122/13 122/15 124/21
148/16 153/17 49/12 52/7 53/16 media [3] 65/22 79/4 Imind [3] 59/13 94/8 I 133/10 133/10
man [4] 22/22 29/25 53/24 54/5 56/13 85/8 104/12 month-end [2]
13/14 95/3 69/15 71/9 72/4 85/10I meeting [39] 27/6 I minds [2] 126/6 133/10 133/10
manage [9] 38/5 83/2 88/25 89/10 89/10 27/8 27/15 27/17 29/8] 165/14 monthly [2] 133/21
1426/3 145/23 145/25 95/2 101/25 102/12 I 29/18 30/10 30/13 minimis [3] 56/12 133/24
145/25 146/1 146/2 103/20 103/21 104/6 I 30/20 65/11 65/15 58/19 59/14 months [10] 9/8
160/25 110/18 111/24 121/16] 65/16 65/19 68/3 70/9) minimum [2] 78/25 I 16/13 17/6 23/12
managed [1] 2/19 124/6 136/18 137/1 75/1 75/5 77/11 79/17) 106/7 25/24 31/23 37/16
management [8] 141/18 142/20 143/14] 85/19 85/21 85/23 Minister [4] 34/17 69/20 83/5 167/22
7/25 56/18 57/7 57/17) 146/23 148/25 150/25I 93/11 106/5 127/3 34/18 37/7 37/8 morally [1] 102/22
57/22 57/23 63/6 154/6 155/1 155/8 127/5 127/9 128/17 Iminutes [3] 34/22 more [66] 6/8 19/13
68/17 158/24 165/9 167/2 I 129/23 161/18 163/14I 76/9 85/18 21/2 25/6 25/6 25/7
Manager [2] 171/6 167/13 171/12 163/16 163/18 164/9 Imirror [1] 119/7 26/9 26/13 26/20
1474/10 May 2021 [1] 45/24 I 164/10 164/21 164/24I miscarriages [1] 27/21 32/4 33/21 35/1
managers [7] 43/18 maybe [6] 34/3 95/18I 165/14 168/1 154/12 35/7 42/22 46/21
51/6 91/25 97/12 108/2 121/3 161/24 Imeetings [8] 40/25 Imisconduct [4] 93/1 I 48/25 51/12 58/2
410/13 125/17 133/17) 162/9 61/8 61/8 69/18 69/22! 93/4 106/14 107/4 59/24 59/25 60/3 60/3)
managing [2] 15/24 McCarthy [1] 53/19 I 70/2 71/15 127/4 mishap [1] 75/19 62/19 66/13 68/12
16 McCarthy-Keen [1] IMel [1] 58/22 misinterpretation [1] I 69/7 70/16 80/24
manner [2] 60/25 53/19 Melanie [1] 47/17 80/17 84/11 84/23 85/10
142/15 McEwan [3] 78/23 Imember [3] 97/17 miskeys [1] 160/17 I 87/11 87/19 91/3 92/3)
manual [1] 133/25 86/10 94/13 155/9 159/19 mismatches [1] 104/11 108/5 108/13
many [15] 16/4 39/24 me [62] 2/21 6/7 6/25Imembers [12] 1/21 114/12 109/16 110/12 114/10)
70/8 85/5 90/10 10/15 10/21 13/24 12/15 60/1 63/6 63/12I misreading [1] 117/24 119/14 119/25)
400/17 111/24 121/19) 15/11 17/23 18/10 63/25 83/13 97/9 98/6] 152/21 120/14 121/19 122/5
429/18 131/7 131/7 18/25 20/10 25/9 26/5I 127/7 136/11 159/2 Imissing [6] 33/20 122/10 122/25 123/8
1431/18 131/20 132/141 27/10 28/21 29/4 29/9IMemo [1] 120/11 46/17 47/8 57/3 123/12 128/15 130/24
174/12 29/11 29/14 29/19 memoire [2] 27/19 102/19 115/19 131/4 131/5 134/4
March [4] 7/10 11/20 30/2 30/8 30/13 30/18} 30/8 mistake [2] 67/22 134/9 134/12 149/9
1416/2 124/24 35/13 38/25 48/5 48/6Imemory [2] 52/12 76/2 158/16 170/19 170/19)
March 2018 [1] 11/20 48/9 48/13 49/14 58/3] 81/2 mistaken [3] 43/10 174/3 175/23 176/8
marked [1] 74/8 61/16 67/5 67/9 67/11Imen [2] 76/19 77/18 I 52/7 53/16 Morley [2] 170/11
markedly [1] 135/20 68/21 73/22 75/10 mention [5] 10/10 mistakes [1] 84/19 17115
market [1] 8/19 75/15 76/5 76/6 78/11) 12/16 12/19 12/25 misunderstanding I morning [6] 1/4 2/8
Marriott [5] 86/7 86/8 79/1 79/2 80/25 92/7 I 31/11 [2] 165/3 166/14 54/21 67/19 146/25
87/1 91/21 93/3 101/17 102/14 122/5 Imentioned [12] misunderstood [1] 147/16
Marshall [1] 82/4 135/3 139/13 139/15 I 10/11 10/15 15/10 7116 most [8] 88/3 107/14
Martin [9] 63/12 73/7 143/11 147/18 152/14I 37/2 54/16 58/25 misusing [1] 106/11 I 112/11 116/23 117/22)
77/3 77/24 79/17 153/4 153/20 153/21 I 82/10 90/4 111/20 mix [1] 16/5 129/12 135/11 135/14)
80/10 80/14 80/18 168/22 169/8 175/1 114/11 127/21 161/8 IMm [3] 157/16 172/6 Imove [17] 12/19 19/9
82/1 mean [24] 23/21 30/3Imentions [1] 157/7 I 172/8 22/17 23/5 26/15
material [7] 5/16 31/20 31/21 32/4 message [4] 121/3 IMm-hm [2] 157/16 28/15 29/2 29/20
33/19 46/8 46/12 96/6 32/14 35/24 41/17 122/8 138/17 147/13 I 172/8 29/23 35/5 35/24
96/15 127/14 42/16 42/23 59/7 Messrs [4] 57/5 mobile [2] 27/16 28/5I 54/20 62/22 64/15
materially [1] 144/24 60/20 61/18 90/6 60/15 74/2 74/17 model [1] 107/7 78/15 85/14 125/4
maths [1] 5/16 91/24 92/16 94/3 Messrs Ismail [3] modernisation [2] moved [4] 69/5 70/16
matter [19] 1/19 6/24 103/3 110/8 118/19 I 57/5 60/15 74/17 8/9 26/21 150/10 164/13
50/24 67/7 74/25 125/25 149/25 150/14I met [4] 18/2 18/4 modernise [1] 12/4 Imoves [1] 82/15
78/15 79/18 10910 I 157/2 20/7 35/13 modernising [2] moving [3] 31/5 35/6
138/18 139/5 140/8 meaning [1] 71/19 I metric [1] 99/24 11/12 11/14 122/17
4142/7 148/18 155/17 IMeaningful [1] metrics [1] 119/2 moment [9] 37/9 Mr [153] 1/3 1/14
1456/2 159/10 166/12 161/14 microphones [1] 40/3 55/20 67/12 72/3] 1/16 1/25 2/3 2/7 2/8
1469/9 175/22 means [5] 23/23 23/7 73/2 85/9 144/13 19/2 22/1 22/2 22/7
matters [8] 50/16 84/21 106/17 134/25 Imid [1] 23/16 153/3 30/22 37/19 37/24
177/16 mid-December [1] Imoney [15] 36/10 _ I 38/6 38/16 38/24
(62) makes - Mr
INQ00001193
INQ00001193
M 129/24 131/23 135/10] 46/15 47/15 150/14 152/17 152/25I needn't [1] 80/7
Mr... [136] 46/15 Mr Chisholm [4] Mr Walton [2] 138/14] 161/22 161/23 162/19Ineeds [7] 49/14 54/3
47/15 49/5 49/17 37/19 38/6 38/16 147/19 163/9 169/14 175/4 I 63/11 64/15 113/12
49/22 49/24 51/3 38/24 Mr Williams [2] 175/14 177/6 177/14 I 113/15 123/7
51/19 52/10 52/23 Mr Declan [1] 52/10 I 52/23 104/10 myself [7] 10/1 48/17I negative [1] 50/12
54/3 55/2 55/8 55/16 Mr Elliot [4] 61/5 Mr Woodley [4] 69/19 75/1 75/12 78/7I negligence [1] 75/25
55/16 55/16 55/23 61/7 61/21 66/21 164/17 164/25 167/24) 144/3 negotiate [1] 49/7
56/10 59/9 60/16 Mr Foat [15] 22/1 172/24 xn... negotiated [1]
60/19 61/3 61/5 61/5 I 22/2 22/7 60/16 60/19IMR's [1] 128/6 SI 136/24
617 61/13 61/17 61/13 61/17 67/16 IMrs [7] 1/6 1/7 1/12 Iname [8] 2/8 2/10 I negotiation [2] 25/7
61/21 61/21 63/1 68/7 68/25 77/1 78/16] 1/13 1/16 1/17 1/23 21/18 42/2 53/6 53/10! 26/4
63/14 65/5 65/8 65/13 78/24 80/9 106/4 Mrs Blakey [4] 1/7 53/20 144/22 neither [1] 160/9
65/18 66/21 66/21 Mr Foat's [2] 73/14 I 1/13 1/16 1/17 named [3] 69/14 nervousness [2]
67/15 67/16 68/7 68/7I “8/22 Mrs Blakey's [2] 1/12I 74/20 86/4 111/25 112/1
68/25 72/12 72/12 [Mr Ismail [6] 55/16 I 1/23 namely [3] 24/20 Inetwork [9] 11/15
72/13 72/21 73/2 65/13 66/21 72/12 Mrs Gillian [1] 1/6 39/4 72/6 12/3 12/4 24/23 35/20)
73/14 73/19 74/22 78/19 79/11 Ms [10] 48/7 51/2 names [1] 85/23 120/2 132/6 132/8
74/23 74/23 76/8 IMr Ismail's [1] 74/22 I 52/24 53/21 78/23 __Inarrative [1] 159/21 I 161/1
76/20 77/1 78/16 Mr Jacobs [14] 55/8 I 87/1 91/21 93/3 94/13I narrowed [1] 49/10 [never [6] 10/20 73/22
78/16 78/18 78/19 55/16 65/18 72/13 94/14 narrower [1] 141/18 I 79/24 136/16 144/2
78/22 78/24 79/9 74/23 76/8 78/18 Ms Corfield [1] 52/24Inarrowing [1] 49/12 I 154/13
79/10 79/10 79/11 79/10 111/13 111/15 IMs Laming [1] 53/21 Inaturally [3] 81/18 Inew [20] 14/12 26/1
151/8 151/10 151/12 IMs Marriott [3] 87/1 I 152/10 155/21 30/1 35/4 36/16 44/8
aoe argon I 151/16 91/21 93/3 nature [9] 24/16 I 48/24 63/20 76/25
103/24 104/10 106/4 IMr Jacobs’ [2] 56/10 IMs McEwan [2] 87/24 92/4 93/20 I 86/2 90/14 110/21
tiie 111/13 111/18 I 152/5 78/23 94/13 103/20 147/24 148/3 I 112/23 121/18 123/3
+e/14 124/5 128/7 Mr Justice [5] 152/18IMs Regan [2] 48/7 I 162/17 173/2 4123/4 128/9 13/2
toro 128/11 128/18I 152/22 13/5 174/13 I 51/2 NBIT [2] 12/20 82/15 I 174/3 174/6
to9r10 129/13 129/24) 177/15 Ms Scarrabelotti [1] Inear [1] 28/6 next [9] 3/4 44/15
131/23 133/2 136/10 [Mt Justice Fraser [3] I 94/14 nearly [1] 1153 I 81/15 83/5 128/16
toed 13808 140/101 192 175/20 1761 Imuch [20] 3/3 4/25 _Inecessarily [11] 140/9 167/10 168/20
Mr Justice Fraser's I 5/10 20/10 25/1 25/17I 18/24 31/22 54/16 I 170/10
Tate tdeoe Lacrtel (21 176/5 176/14 I 26/13 26/18 27/3 I 84/10 84/20 90/24 I NFATI] 173/21
447/11 147/19 148/6 (Me Lill [1] 49/22 31/14 36/9 36/13 41/7I 119/7 122/1 1301 INFSP [1] 73/13
ts0rt1 184/8 181/10 (ME Morley [2] 170/11I 54/23 56/17 64/22 I 132/16 162/2 NICHOLAS [3] 2/6
481/12 181/16 182/58 I 175 95/15 130/24 163/1 Inecessary [8] 1/24 I 2/11 178/2
452/18 152/22 163/5 IMt Parker [2] 30/22 I 174/3 16/10 46/13 93/2 I Nick [7] 2/4 45/21
48418 15716 158/03 I 37/24 multiple [1] 142/16 I 14/1 156/3 159/11. I 47/17 47/19 55/25
159/21 163/16 164/17/Mr Patterson [8] I multitude [2] 21/3 I 167/13. 167/25 168/1
164/17 164/18 164/25 140/10 150/11 154/8 I 150/3 necessitate [1] Nicola [2] 86/7 86/8
teeI7 167/24 167/24 I 157/6 158/23 164/17 Imust [4] 1/19 64/5 I 136/19 night [4] 45/8 67/4
tort 1747s 174101 I 172/24 172124 80/4 151/23 necessity [1] 25/18 I 74/23 76/9
472/24 172/24 172/24) Mt Patterson's [3] _ Imy [90] 1/5 1/17 1/22INED [6] 59/16 65/15 INisa [3] 8/3 8/11 8/23
174/13 175/20 176/1 I 183/16 164/18 167/24I 1/22 2/8 5/16 6/1 6/4 I 65/19 76/1581/13 — Ino [104] 10/16 12/21
Mr Read [8] 2/8 6/10 7/2 8/21 9/10 129/6 13/1 13/20 15/23
vee 176/14 177/15 51/19 55/2 73/2 94/6 I 9/13 10/17 14/3 15/15INED-only [1] 65/15 I 19/19 20/4 20/5 20/15
Mr Bartlett [7] 76/20 94/25 118/14 146/18 I 16/3 16/21 17/25 18/9/NEDs [1] 81/9 20/17 22/11 23/24
111/8 138/25 147/11 IMr Roberts [9] 63/14] 19/11 20/9 20/14 26/9Ineed [28] 1/24 15/12 I 30/1 31/6 31/8 33/8
14/6 189/21 1e0r7 _ I 67/15 68/7 78/16 79/9I 27/11 29/16 29/18 I 20/13 21/23 22/7 36/3I 34/3 39/19 41/1 42/25
Mr Bartlett's [3] 80/9 128/7 128/10 I 30/10 31/11 36/2 41/5) 35/8 38/8 40/7 49/8 I 43/22 49/23 51/4 51/4
133/2 41/16 42/17 44/19 55/9 64/19 65/8 82/17I 52/6 53/1 53/4 53/6
Mr Bates [1] 92/11 Mr Roberts’ [3] 73/19} 45/1 45/5 45/6 45/8 I 82/25 91/23 105/20 I 53/10 53/20 54/10
Mr Beer [6] 1/3 2/7 79/10 129/13 45/9 47/4 47/25 51/9 I 106/8 119/9 120/22 I 55/9 63/13 65/7 65/8
61/3 124/5 146/13 Mr Rodric [1] 103/24 I 51/17 58/20 64/2 123/8 127/23 134/8 I 67/6 70/4 71/20 77/21
1478/4 Mr Staunton [9] 67/22 68/15 72/17 138/11 139/12 139/22I 77/22 81/16 82/2
Mr Blakey [1] 1/25 55/16 55/23 59/9 61/5I 73/9 73/23 74/25 75/5I 144/9 161/8 82/19 84/17 85/3
Mr Blakey's [1] 1/14 63/1 65/8 72/12 72/21I 75/21 76/15 76/17 needed [21] 10/13 86/14 88/10 89/23
Mr Bradshaw [1] 74/23 77/20 78/5 81/2 84/7 I 10/18 13/19 14/8 89/25 90/16 92/15
65/5 Mr Staunton's [1] 85/5 90/12 94/6 94/8 I 14/13 14/22 18/13 93/3 94/4 94/10 98/15)
Mr Breen [2] 147/10 61/21 95/17 99/11 101/15 I 22/21 36/2 37/11 98/21 99/19 103/1
471/24 Mr Thomas [7] 49/5 I 102/12 110/10 132/16) 42/21 57/2 69/23 105/20 110/20 110/20)
Mr Cameron [6] 49/17 49/24 51/3 54/3) 132/16 132/25 135/16) 70/20 91/24 99/13 111/4 112/8 114/1
428/11 128/18 129/10) 97/17 99/21 136/10 139/2 139/17 I 102/8 110/15 149/25 I 119/24 121/4 122/22
Mr Thomas’ [2] 141/12 150/2 150/5 I 162/21 163/2 123/6 123/17 126/2
(63) Mr... - no
INQ00001193
INQ00001193
N
130/1 134/22 134/24
135/1 135/15 144/17
150/1 151/7 151/10
152/2 152/2 152/4
156/20 169/8 172/11
176/13 176/18 177/2
1771/4 177/11 177/11
nobody [1] 78/2
nodded [1] 157/13
non [9] 57/16 62/24
78/18 80/22 82/8
83/13 127/7 127/7
140/3
non-Board [1] 127/7
Non-Executive [6]
57/16 62/24 78/18
80/22 82/8 83/13
non-provision [1]
140/3
None [1] 89/6
nonetheless [2]
39/11 103/12
nor [3] 10/7 139/7
160/9
normal [1] 83/24
normally [2] 48/3
48/3
not [235]
not/would [1] 165/12
notably [1] 121/19
note [31] 28/6 28/18
28/19 37/23 49/10
56/20 63/1 63/2 63/3
65/2 66/19 72/16
72/19 72/22 74/19
76/12 79/3 86/7 90/5
90/18 95/21 95/23
96/8 96/13 96/23
97/13 127/16 147/20
156/21 159/9 163/16
noted [16] 86/12 87/1
93/3 93/15 93/22
95/13 96/3 128/3
128/10 128/15 128/24)
129/3 129/8 129/11
129/14 129/20
notes [8] 27/15 27/22
28/20 29/17 75/5
98/23 102/12 176/9
nothing [10] 20/12
38/12 38/19 39/2
46/22 64/4 77/14
93/10 124/7 151/25,
noticeable [1] 119/19}
noticed [1] 119/16
noting [3] 112/24
129/19 136/24
no... [34] 129/10
149/10 149/12 149/22)
153/15 153/17 155/14)
172/14 173/21 173/23)
notion [4] 38/12
57/21 65/25 82/8
notwithstanding [1]
102/1
55/22 55/23 61/17
61/24 62/23
now [46] 5/11 11/18
39/1 42/8 44/18 45/5
177113. 177/13 177/13] 98/7 61/16 68/20
70/12 77/10 79/12
87/6 88/25 89/24
89/24 91/4 92/2 92/9
92/20 94/10 101/22
105/9 109/14 111/12
120/4 122/12 124/5
130/22 132/25 135/7
147/2 150/18 153/17
154/21 156/8 174/23
175/13
NR [1] 129/20
nuanced [2] 58/25
139/13
number [27] 25/10
56/2 71/3 82/9 86/10
95/24 98/21 98/23
99/10 99/25 103/16
105/22 125/2 126/15
132/17 132/18 133/3
152/6 153/11 154/8
155/2 162/19 164/24
number 2 [2] 86/10
164/24
Number 24 [1] 98/23
numbers [2] 45/2
98/17
numerical [1] 124/2
fe)
objective [4] 27/3
98/3 139/4 148/13
objectives [11] 25/15
30/19 45/1 45/11
46/24 49/11 51/7
51/15 52/5 97/21 98/8
obligation [4] 118/19
obligations [3] 49/23
96/5 167/7
oblivious [1] 24/12
observation [2] 78/4
161/22
observations [1]
obtain [1] 171/9
obtained [2] 44/13
101/3
obtaining [3] 126/22
168/24 169/24
obvious [2] 140/7
173/6
obviously [26] 9/13
11/21 16/12 17/25
27/14 58/7 62/20
62/20 65/22 65/23
November [10] 23/15] 66/8 66/25 69/21
25/8 25/12 34/5 34/11) 70/22 71/15 80/14
87/25 108/15 120/12
120/13 134/1 138/7
158/21 163/10 169/8
13/24 20/7 22/5 28/11) 169/10
occasions [1] 162/9
45/7 45/8 46/21 47/11] occupied [2] 24/20
91/17
occupies [1] 77/15
82/13 122/11 122/18
occurred [18] 21/7
67/21 70/11 75/18
75/23 83/11 114/7
152/3 152/8 154/13
163/14
occurring [3] 112/3
120/20 132/19
occurs [2] 84/17
163/3
25/25 43/6 45/13 51/7IOctober [8] 1/1 3/23
65/9 135/7
odds [2] 31/24 36/8
off [11] 45/18 47/13
56/25 81/18 82/14
95/18 120/21 121/1
121/20 123/13 128/21
offences [3] 55/6
96/12 107/17
offer [1] 89/10
offering [2] 138/9
153/8
offers [1] 103/19
office [241]
Office's [24] 7/4
18/15 20/6 23/18
43/17 45/19 52/3 55/3
55/11 55/17 79/7
81/10 83/21 103/25
105/6 110/7 126/19
131/19 155/1 159/20
167/3 168/9 169/12
169/19
Officer [3] 7/5 8/3
773
officer's [1] 166/2
offices [1] 109/10
officials [8] 18/4
31/17 31/18 31/20
36/9 49/4 127/6 127/6
often [2] 70/24
129/15
Oh [2] 43/23 67/13
okay [7] 23/9 58/3
67/13 68/24 124/16
127/1 141/23
old [4] 29/25 57/6
76/24 174/3
older [2] 134/6 134/9
Oldnall [3] 137/22
138/14 139/13
on [228]
onboarding [1]
134/13
once [12] 41/12 59/2
59/3 59/3 115/23
117/4 117/7 117/8
177/16
occur [5] 21/13 28/25Ione [45] 1/6 4/25
5/11 6/19 8/2 8/5 8/6
18/3 18/7 19/11 21/5
61/1 65/23 66/25 67/2) 26/16 28/9 30/7 33/21
52/9 53/4 64/3 64/20
66/9 77/10 77/21
120/25 121/15 151/23) 77/22 82/18 84/25
98/5 100/8 101/15
104/19 118/2 119/15
139/2 152/21 153/4
162/8 163/25 165/19
166/1 177/12
3/25 21/12 32/22 34/2Iones [1] 121/20
ongoing [11] 12/3
138/5 142/18 147/25
148/2 168/18 172/25
Online [2] 170/20
175/8
only [26] 14/19 20/18
20/20 28/10 37/15
56/22 65/15 65/19
75/11 76/15 77/10
115/25 119/11 123/2
123/3 123/15 125/21
141/20 144/25 152/9
155/4 161/12 163/23
164/3 165/25 167/14
onto [1] 138/13
onwards [2] 26/13
174I7
op [1] 8/25
open [3] 74/5 79/18
139/4
opened [2] 153/7
163/16
opening [2] 11/13
31/23
operated [4] 96/19
97/18 103/8 160/16
operates [2] 115/5
175/11
operating [3] 11/20
107/7 174/9
operation [6] 83/24
84/3 114/17 160/23
172/9 172/10
operational [12] 14/7
omissions [1] 160/18) 88/1
151/12 151/17 151/22I 160/9 160/10 165/8
122/14 127/14 129/10I oppressive [1] 40/9
153/22 157/25 161/23] 128/20 133/13
50/17 66/19 75/4 96/4/ organisation [52]
14/21 59/3 111/5
122/9 133/4 133/5
133/6 133/7 133/9
133/25 135/17
operationally [1]
operations [6] 18/22
53/17 53/18 58/23
60/1 75/3
opinion [11] 9/10
57/23 71/24 102/15
136/14 159/5 160/7
165/13
opponents [1]
100/22
opportunity [4] 26/5
29/9 29/11 29/14
opposed [12] 10/9
22/15 26/7 33/1 38/11
51/10 51/12 51/21
102/6 109/8 112/18
122/6
option [3] 106/8
or [187]
order [8] 19/8 50/3
59/20 67/9 71/10
82/18 96/18 99/12
7/23 8/14 8/22 8/25
9/4 9/15 16/6 17/12
17/16 17/16 17/23
24/10 25/1 25/13 26/1
26/12 29/15 30/1 30/9
30/12 36/3 37/10 39/9
39/16 39/25 40/15
41/2 41/6 53/12 63/9
66/3 66/4 66/13 66/17
76/3 76/16 76/18 78/1
82/14 83/16 83/17
85/2 87/10 90/16
101/18 107/11 108/22)
109/1 131/2 158/8
168/15 172/5
organisational [3]
79/7 93/16 94/2
organisations [6] 8/9
84/13 84/18 84/19
107/15 143/25
organise [1] 71/25
organised [5] 109/6
112/16 130/23 158/2
162/15
orientated [1] 144/17
original [2] 134/7
168/1
originally [1] 59/18
ostensibly [3] 18/21
101/12 112/15
other [27] 8/5 8/6
42/6 44/10 44/19
60/11 63/25 71/13
(64) no... - other
INQ00001193
1NQ00001193
(e) 165/16 166/18 167/21Ipage 108 [1] 4/4 175/25 176/16 Parliamentary [1]
other... [19] 87a I 174/8 175/15 page 109 [1] 65/10 I paragraph 1 [3] 96/3 I 85/8
01/8. 94/15 95/24 [over state [1] 139/21Ipage 11 [1] 14/16 I 141/2 164/23 part [26] 10/17 17/21
104/20 108/18 113/19IOver-enthusiastic [1] Ipage 12 [1] 14/24 I paragraph 12 [1] 17/21 19/15 20/24
4126/7 128/18 136/15 I 60/10 page 13 [1] 39/22 I 9/22 26/10 43/4 46/8 46/13
44213 144/18 19/3. IOVeFall [3] 5/15 25/18I page 132 [1] 2/19 Iparagraph 13 [2] 47/21 64/5 66/5 67/22I
453/18 187/12 160/15] 143/9 page 140 [1] 4/10 I 13/22 96/14 69/13 69/20 76/1
160/24 161/3 176/4 IOverheads [1] 14/7 Ipage 142 [1] 4/16 [paragraph 135 [1] I 78/16 96/13 97/5
others [9] 25/10 oversee [1] 10/13 Ipage 2 [7] 47/11 136/5 99/21 99/24 110/14
69/19 78/23 85/13 [overseeing [1] 58/11I 52/22 72/25 74/22 Iparagraph 144 [1] _I 125/23 126/3 126/10
86/4 93/25 97/21 oversight [5] 77/9 I 79/10 138/13 147/3 I 26/17 164/3
148/4 174/25 77/13 78/8 78/13 page 20 [1] 34/14 I paragraph 16 [1] Participant [1] 2/1
otherwise [3] 49/7 I 118/20 Page 26 [1] 3/8 14/2 Participants [1] 1/6
151/25 152/16 overstated [1] 8/17 Ipage 28 [2] 3/16 paragraph 17 [1] particular [30] 9/6
ought [1] 54/9 overturned [1] 46/11 I 116/17 97/11 21/17 32/7 38/7 39/6
our [45] 1/6 22/22 _ Ioverwhelmed [1] page 3 [9] 7/15 12/8 Iparagraph 174 [1] I 57/25 61/13 68/16
42/22 46/3 46/7 46/8 I 72/3 46/15 72/8 72/11 40/6 69/25 80/11 80/15
46/13 50/3 75/2 75/4 \Owed [1] 59/11 72/21 96/14 137/21 Iparagraph 2 [4] 96/8 I 83/2 85/12 97/1 107/9I
75/8 7/6 77/7 77/10 IOwen [4] 150/9 170/6 paragraph 2.4 [1] 113/23 119/7 126/21
80/3 87/10 90/25 163/17 164/10 168/20Ipage 4 [4] 45/16 72/9I 106/6 128/11 131/21 132/4
91/18 106/7 107/19 [own [10] 1/22 5/24 I 114/23 127/15 paragraph 21 [1] 133/3 141/24 145/8
18/5 119/21 119/21 I 9/4 43/18 50/3 85/11 Ipage 5 [3] 43/24 44/2I 98/10 145/8 145/19 149/12
420/11 120/11 122/19) 118/13 121/2 155/12 I 116/5 paragraph 22 [2] 150/7 163/2 173/7
422/20 123/1 130/23 I 163/16 page 6 [2] 9/22 107/6I 14/17 98/14 particularly [40] 6/11
432/19 133/17 133/17;0WNed [1] 107/13 I page 7 [3] 5/3 13/22 I Paragraph 23 [1] 38/21 83/23 108/25
1434/5 135/18 136/11 Owners [1] 9/10 95/20 14/24 112/7 114/10 130/13
143/24 145/23 145/25Ip —=S*S*S*S*«~ GTZ 1936/6 [paragraph 234 [1] I 134/5 157/2 159/14
136/7 4/4 parties [7] 52/9
146/1 146/2 146/3
154/18 155/5 162/14 ra Bl 47/22 47/25 Ipage 80[1] 26/16 Iparagraph 243 [1] _I 123/22 129/23 146/2
165/19 page 84[1] 40/6 I 74/1 154/23 155/6 160/21
ourselves [1] 158/17 IPace [2] 70/19 72/4 Ipages [10] 2/15 2/18 I paragraph 27 [1] partly [2] 140/16
out [42] 4/2 7/16 7/17 page [93] 2/193/8 I 3/5 3/14 5/2 5/16 39/21 140/17
44/4 14/7 11/23 12/7 I 3/16 4/4 4/10 4/16 5/3) 22/17 23/10 36/25 —_I paragraph 28 [1] partner [2] 136/2
12/8 15/7 20/25 47/2 I 7/15 9/22 11/3 11/4 I 474/12 23/11 149/24
47/5 56/23 59124. I 11/5 11/7 11/8 11/9 I pages 13 [2] 22/17 Iparagraph 305 [1] _I partnership [1] 14/12
63/13 7/14 83/18 I 1/1 12/7 12/8 12/8 I 23/10 4/10 parts [3] 69/13
34/19 84/23 97/13 I 12/12 12/13 12/14 pages 27 [1] 36/25 Iparagraph 44[1] I 137/19 137/20
4107/7 109/14 112/23 I 13/22 14/16 14/24 I paid [2] 47/4 113/23 I 34/15 party [4] 142/3 155/8
4120/4 133/4 133/5 I 29/13 26/16 28/12 pain [1] 102/9 paragraph 61[1] I 157/12 169/1
133/13 133/16 134/9 I 34/14 39/22 40/6 Ipan [1] 170/6 371 pass [1] 139/18
43/24 44/2 45/16 I panel [3] 91/7 91/9 IParagraph 62[1] _I passage [3] 28/9
abe e018 11/16, I 018 47/11 49/21 I 93/24 37/13 68/22 130/8
Taino aperte tore I 52/22 59/7 60/13 panicked [1] 23/24 Iparagraph 64[1] _ Ipassages [3] 174/24
Te ae Tree, I 82/25 65/10 72/8 72/9I paper [6]. 106/3 3/16 175/4 17516
ena 72/11 72/21 72/25 I 112/24 113/7 113/21 Iparagraph 7 [1] 7/15 I passed [3] 1/7 58/5
outcome [4] 91/10 I 74/22 76/8 78/22 129/3 134/15 paragraph 964 [1] I 147/13
94/1 134/15 140/7 79/10 79/15 86/6 papers [1] 105/22 175/5 past [42] 15/13 18/16
outcomes [2] 98/9 92/23 94/10 95/20 I parachuted [1] 9/3 I paragraph 969 [1] 20/8 20/15 21/25 22/8
139/25 95/20 95/22 96/14 _I paragraph [51] 3/16 I 175/25 24/20 24/22 27/1 32/3
outline [1] 75/21 97/2 97/4 99/5 107/6 I 4/4 4/10 7/15 9/22 Iparagraph 974 [1] I 32/10 36/23 39/25
outset [1] 92/17 109/19 109/20 114/23] 11/6 11/16 13/22 14/2I 176/6 40/3 40/10 41/1 41/12
outside [1] 84/1 116/5 116/17 117/21 I 14/17 14/24 23/11 Iparagraphs [6] 7/18 I 41/14 42/4 42/19 46/1
over [39] 6/5113 I 127/15 136/6 136/7 I I 26/17 34/15 37/1 9/16 9/21 23/14 55/10) 54/8 54/8 54/15 54/18
11/8 11/9 11/14 11/21} 137/21 138/13 138/24) 37/13 39/21 40/6 171/23 55/6 66/2 81/2 85/15
12/7 12/11 12113 145/11 147/3 147/8 I 44/15 44/16 46/17 _ I paragraphs 237 [1] I 86/6 86/14 86/21
23/13 32/17 47/7 147/9 147/22 148/6 I 46/19 50/10 59/9 55/10 86/22 87/2 87/8 88/6
58/16 59/7 59/12 154/25 156/15 1641/6 I 60/14 64/16 65/9 paragraphs 28 [1] I 91/24 100/6 103/2
60/10 64/18 69/20 I 163/20 163/21 164/3 I 72/15 73/15 74/1 23/14 103/11 107/2 116/16
85/6 86/5 80/22 92/23I 165/16 166/19 170/6 I 78/24 79/11 96/3 96/8] paragraphs 7 [1] path [2] 82/8 82/13
97/2 99/5 109/19 170/10 174/8 175/15 I 96/14 97/11 98/10 7/18 Patterson [13]
109/20 117/21 121/8 IPage 1 [8] 49/21 98/14 106/6 116/17 Iparalysis [1] 17/21 I 140/10 140/12 140/15)
439/21 147/22 184/25] 60/13 76/8 79/15 136/5 141/2 145/10 IPark [1] 58/22 149/2 150/5 150/11
156/15 161/6 164/2. I 198/24 147/8 147/9 I 151/2 158/25 163/21 IParker [4] 18/1 27/6 I 154/8 157/6 158/23
148/6 164/23 167/10 175/5 I 30/22 37/24 164/17 164/24 172/24
(65) other... - Patterson
INQ00001193
INQ00001193
P perfunctory [1] 33/1 I 43/14 61/6 62/21 151/16 7/10 16/16 28/23
Patterson..[1] [Perhaps [9] 58/1 73/21 75/19 108/17 Ipoints [7] 11/10 31/24 39/2 52/13 69/9
472/24 - 72/1 80/17 96/2 124/2I 116/14 128/9 133/2 I 50/21 86/7 157/14 75/11 76/6 78/5 80/3
Patterson's [3] 125/8 134/7 144/13 I 137/4 158/18 161/19 I 165/2 171/14 172/41 87/1 93/4 109/14
163/16 164/18 167/24 17/14 171/2 174/6 POL [2] 85/18 129/15] 113/14 123/25 128/2
Paul [4] 150/5 10/8 [Period [7] 1/9 21/10 placed [4] 15/19 POL00113304 [1] 130/11 131/19 150/11
1464/11 168/20 33/17 37/18 58/16 75/10 126/1 171/14 I 43/12 157/21 161/20 163/7
pause [2] 23/1 83/21 97/19 plan [4] 19/10 37/6 IPOL00142412 [1] 164/15 169/23
414/16 periodically [1] 32/18] 81/8 134/21 95/19 positioned [1] 20/14
pausing [1] 130/10 Perkins [1] 53/11 _ Iplanned [1] 134/18 IPOL00423697 [1] possibility [2] 135/4
ay [9] 4/12 36/17 IPermanent [3] 34/17 Iplans [1] 16/25 105/21 148/23
ed ii r2iii 123/16 I 35/1 37/2 platform [2] 82/14 IPOL00448302 [1] _I possible [2] 120/19
1424/3 128/20 145/22 IPerpetrates [1] 100/9I 82/15 62/25 152/9
1446/6 persisted [1] 63/7 play [3] 8/18 164/12 IPOL00448320 [1] possibly [3] 131/25
paying [4] 120/21 person [6] 11/2 168/23 106/2 131/25 161/10
11/2) 124/18 126/12I 12/10.47/24 48/10 I played [1] 54/18 — IPOL00448383 [1] _I post [270]
payment [2] 49/7 139/16 139/17 playing [1] 83/17 74/21 post-Common [1]
1400/6 personal [10] 5/21 Iplays [1] 134/3 POL00448514 [1] 123/4
payments [2] 35/25 6/3 6/8 6/10 7/1 46/24I please [102] 2/10 79/9 post-litigation [1]
35/25 52/4 56/19 95/14 2/13 2/19 3/6 3/16 POL00448564 [1] 33/12
pays [1] 123/13 101/15 4/16 5/3 5/24 7/14 72/7 postage [1] 63/16
PCDE [1] 46/9 personally [6] 6/14 I 10/23 13/21 14/16 POL00448577 [1] postmaster [32] 36/5
people [27] 17/9 23/7 25/9 25/20 118/9 22/18 23/11 23/13 78/21 41/14 47/6 57/16
32/15 39/20 47/16 123/9 173/5 26/16 27/25 28/9 POL00448693 [1] 59/16 64/12 67/10
47/20 53/13 53/21 personnel [1] 40/22 I 28/11 34/13 36/25 55/22 69/9 71/12 71/13
54/7 64/17 64/19 65/4I Perspective [13] 6/3 I 39/21 39/22 43/12 IPOLO0448890[1] _I 75/16 76/15 78/18
65/6 70/8 76/13 7/11) 2/2 19/24 26/10 29/10] 43/24 43/25 44/2 10/24 81/9 81/13 82/5 82/6
84/19 86/11 89/14. I 29/12. 42/17 68/15 I 45/16 45/17 46/15 IPOLOD448897 [1] I 83/12 83/16 106/13
91/15 92/21 94/9 89/11 90/25 119/18 I 46/16 46/18 47/11 27/25 106/19 119/12 123/13)
104/15 110/13 124/2 122/19 136/9 47/13 47/14 52/16 POL00458674 [1] 123/19 123/23 129/9
126/5 135/22 pervades [1] 112/1 I 52/21 60/13 62/22 85/19 143/12 146/1 151/13
eople's [1] 83/18 Peter [1] 153/11 63/1 72/8 72/16 72/21I police [63] 77/12 154/9 156/16 167/16
eer is2) 11/19 51/11 (Peters [12] 49/10 I 72/26 73/1 73/14 107/9 107/25 128/19 I postmaster's [1]
Cea enters. I I 49/10 50/1 50/1 §3/22I 73/19 74/21 74/21 I 136/18 137/8 137/11 I 8/16
115/6 115/7 115/9 53/22 95/21 95/21 75/21 76/8 78/21 138/5 138/8 138/11 I postmaster-facing
415/10 115/12 115/14] 97/5 97/5 98/18 98/18] 79/10 79/12 79/15 I 138/19 138/22 139/3 I [2] 41/14 69/9
415/15 115/17 115/19I Phase [2] 66/18 80/7 81/6 86/5 94/18 I 139/5 139/6 139/19 I postmasters [122]
415/20 118/22 115/25) 81/15 95/19 95/20 96/22 I 139/22 140/2 140/5 I 10/3 10/5 14/1 14/11
118/25 116/3 116/4, [Phase 4[1] 66/18 I 97/2 97/7 106/2 106/6I 141/10 142/2 142/3_I 14/13 15/2 15/8 18/17
11615 116/6 16/8 IPhoenix [12] 42/19 I 107/6 107/7 109/19 I 144/16 145/21 146/10I 19/18 31/15 31/22
4116/9 146/11 116/13, I 84/19 69/1 69/3 69/12) 114/20 114/23 116/17I 147/21 147/25 148/2 I 34/19 34/24 35/4
116/15 116/18 116/24I 99/25 70/16 81/7 117/21 127/2 127/16 I 148/5 148/8 148/12 I 35/18 35/23 35/25
116/25 117/4 117/4_ I 85/15 86/6 86/12 136/7 137/21 138/13 I 148/22 155/7 155/17 I 36/1 36/2 36/16 39/14}
41715 117/7 11717 92/21 138/13 138/24 146/14) 155/24 156/2 157/10 I 39/18 40/12 40/16
4117/9 117/12 117/13 IPhoenix/Past [1] 146/19 147/2 147/17 I 158/5 159/10 160/1_ I 41/4 42/13 42/23 44/6)
417/13 117/18 117/24] 86/6 148/6 149/1 150/23 I 161/9 161/25 162/20 I 45/4 45/10 46/2 47/9
4118/1 118/11 119/11 IPhrase [1] 102/11 154/5 156/16 163/15 I 163/1 163/8 163/11 I 56/18 57/7 57/18 63/7!
121/18 122/15 123/2 IPhrases [1] 175/16 I 163/20 164/2 166/19 I 163/12 163/24 164/16] 63/10 63/21 64/1 64/4
1423/3 125/22 126/7 pick [2] 44/16 74/11 I 170/4 170/6 170/7 165/18 165/20 165/21I 64/7 64/12 64/22
q2e/1 163/17 picking [1] 176/14 I 170/10 1714/5 171/20 I 165/23 165/24 165/25I 64/24 69/17 75/13
per annum [1] 56/14 IPicks [1] 43/24 172122 173/10 17/9 I 166/5 166/10 166/12 I 7/13 87/18 88/16
er se [1] 51/11 picture [2] 35/12 I plus [1] 90/3 168/22 169/13 170/3 I 92/24 100/25 101/19
percenta e [2] 98/2 I 150/20 pm [5] 94/21 94/23 I 171/15 172/4 106/11 106/25 107/3
eed piece [7] 19/3 41/10 I 146/15 146/17 177/17I police's [2] 155/18 I 107/4 112/13 118/12
perfectly [1] 150/6 I 41/12 43/9 62/20 point [28] 17/8 24/14 I 155/21 119/4 119/4 119/16
erform [2] 12/11 I 89/23 121/7 33/2 35/17 37/22 _Ipoliceman [4] 64/14 I 119/20 120/4 120/8
meio pin [1] 84/23 38/14 42/3 49/11 61/3I policy [4] 19/24 120/12 120/16 120/21
erformance [6] pineapple [9] 66/25 I 74/5 77/23 78/2 78/9 I 49/25 50/3 127/17 120/22 121/1 121/12
vee 64/8 80/2 98/9 72/22 73/16 73/21 83/1 92/15 92/18 politicians [2] 31/19 I 121/19 122/9 122/21
98/12 122/9 74/19 79/3 80/9 90/5 I 102/20 106/21 108/16] 34/13 4123/1 123/2 123/7
erformed [1] 86 I 11/19 127/18 130/9 131/15 Ipopulation [2] 16/22 I 123/10 123/15 124/19]
ee rforming [2] 52/24 [Pivotal [1] 37/9 131/24 151/24 156/4 I 119/12 124/22 124/24 125/16
Ot Forming [ ] place [20] 13/5 14/22I 158/4 163/7 175/14 Iportrayed [1] 102/14 I 126/16 127/24 128/4
16/25 25/8 42/7 43/1 I pointed [2] 59/24 position [26] 6/16 128/13 128/16 128/19)
(66) Patterson... - postmasters
INQ00001193
INQ00001193
P pretty [3] 8/18 21/6 Iprocesses [1] 166/21] 15/10 19/17 21/14 I pursue [6] 141/3
ore I 72/3, produce [1] 73/8 43/7 44/5 45/3 45/13 I 142/20 150/13 151/1
postmasters., (34). Iprevailing [1] 31/16 Iproduced [4] 105/22 I 46/5 46/23 47/1 51/8 I 151/6 158/9
133/8 133/14 134/6 [Prevent [1] 75/19 114/16 148/15 159/24) 54/9 88/9 95/8 96/18 I pursued [2] 155/6
previous [5] 7/13 Iproduct [1] 14/4 96/21 98/17 99/10 1857/1
teen one er" 49/11 86/20 94/9 I products [2] 11/7 I 99/25 100/15 136/14 I pursuing [3] 61/18
qav7 14110 141/15 I 1591 14/5 154/23 155/6 166/16 I 143/8 157/8
441/21 142/19 142/21 previously [6] 63/3 IProfile [1] 12/12 169/1 pursuit [4] 35/18
4143/8 143/14 11/1. I 63/6 91/3 96/6 160/14] profit [3] 24/25 25/18 I prosecutor [1] 140/22 142/19 150/24
154/12 154/23 155/3 I 1691/2 35/19 100/20 pushing [2] 35/2
4155/9 156/7 156/13 IPride [1] 24/9 profits [1] 24/1 prosecutorial [5] 153/21
488/10 158/14 156/18I Primarily [2] 70/20 Iprofound [3] 10/17 I 18/23 20/11 20/16 _I put [19] 4/25 5/11
4159/6 162/18 16714 I 137/4 16/3 16/3 22/16 142/4 9/11 14/22 25/16
168/6 primary [1] 132/10 Iprogramme [1] 11/14I prosecutors [2] 28/15 29/1 29/22 31/7
postmasters' [2] Prime [1] 37/6 progress [6] 119/2 I 140/5 160/1 48/4 58/3 61/19 62/4
10/7 154/18 principally [1] 98/11 I 120/17 131/14 139/12I prospect [2] 46/3 I 79/12 79/18 106/1
potential [17] 34/8 Principle [1] 102/21 I 142/11 166/6 93/3 118/6 125/6 166/14
57/20 69/9 86/19 _I Prior [5] 25/14 106/4 I progressing [2] protect [1] 76/17 _I putative [1] 96/2
36/23 87/21 91/18 I 196/21 159/21 176/8 I 139/4 173/14 protection [2] 89/16 I putting [5] 31/5 46/2
107/19 108/13 112/4 [Priorities [13] 10/21 Iproject [32] 10/14 I 89/17 101/23 128/9 133/2
413/11 132/5 137/71 I 12/2 12/6 18/2 21/4 I 12/23 42/19 55/12 I proud [1] 83/23 a
439/14 148/17 152/5 I 26/3.27/1027/12 I 58/13 64/19 68/25 _I prove [2] 64/15 177/3It_
455/15 28/21 29/3 30/3 35/2 I 69/3 69/12 69/25 _—I proved [2] 64/2 93/1 Iqualified [1] 110/14
potentially [3] 87/16 I 95/10 70/16 72/22 73/16 Iproven [1] 47/5 quality [2] 158/14
140/13 139/25 prioritised [1] 87/23 I 73/21 74/19 80/9 _—Iproves [1] 174/16 I 158/15
pounds [1] 145/23 Private [5] 15/10 85/14 85/15 86/6 —_Iprovide [25] 9/17 Iquarter [1] 127/10
ower [3] 63/25 21/14 65/15 74/8 86/12 90/4 92/21 19/11 24/6 22/2 44/13I quarterly [3] 127/2
Ratt 77/8 100/19 105/15 105/16 105/23I 87/8 113/18 137/15 I 127/4 127/9
powers [2] 142/5 [Privately [3] 15/7 I 108/25 109/22 110/1 I 139/15 141/14 142/9 Iquashed [3] 1/14
4156/1 65/11 107/12 110/17 110/18 111/19I 143/17 146/9 156/19 I 39/11 39/13
PR [2] 30/21 37/25 probably [5] 34/2 111/19 156/21 158/15 158/15I question [20] 15/24
practice [2] 106/19 I 57/19 68/22 109/21 [promised [1] 79/16 I 160/10 161/16 163/22) 28/24 39/8 43/5 44/8
123/25 134/3 promptly [2] 100/9 I 165/8 165/10 166/10 I 89/23 91/13 91/20
pre [1] 22/12 problem [12] 38/5 I 167/8 170/16 170/25 94/7 111/2 119/24
pre-2015 [1] 22/12 I 83/2 83/7 100/10 Iproper [11] 13/24 Iprovided [14] 18/14 II 125/8 126/5 132/22
103/4 104/9 104/10 I 49/17 127/23 127/25 I 19/1 19/7 36/18 72/22) 152/13 157/3 157/24
precedence [1]
35/10 122/25 129/17 131/17I 129/24 130/5 130/19 I 74/19 78/8 78/17 79/1I 174/8 174/15 177/13
precise [1] 152/24 I 151/20 152/11 132/2 132/12 132/23 I 151/24 161/3 166/24 Iquestioned [3] 2/7
recisely [6] 21/7 problematic [1] 161/11 171/11 173/25 56/19 178/4
"37ie2 74/1 82/11 103/6 properly [8] 13/18 I provider [1] 165/23 I questioning [2]
84/23 152/7 problems [10] 33/18 I 111/5 118/8 130/14 I provides [2] 108/21 I 68/23 126/7
predecessors [1] I 22/18 33/23 37/19 I 131/6 131/7 1318 I 165/12 questions [23] 2/9
24/13, 120/9 122/18 125/12 I 131/13 providing [6] 96/23 I 6/7 15/15 43/19 50/21
referable [1] 128/24] 128/12 129/8 135/22 I proportion [2] 98/5 I 148/23 155/19 160/8 I 95/2 110/22 11/1
P 4] 170/25 IProcedural [2] 19/24 I 126/11 164/15 171/25 114/21 115/1 118/14
Prepare [ th jong I 154/16 proposal [2] 50/2 _Iprovision [7] 23/14 I 125/6 126/23 126/25
oeeoence [1] 408 [Procedures [3] 133/9I 108/2 102/23 104/16 115/24] 129/22 144/4 165/21
a eecent [eo] 85/24 I 133/14 133/19 proposed [6] 49/12 I 140/3 164/4 173/4 I 173/23 174/2 174/11
rela 86/22 93/5 proceeding [1] 113/7I 56/20 107/5 107/7 __I provocative [1] 4177/7 177/10 177/41
127/13 127/14 proceedings [11] 107/21 109/17 143/10 quickly [10] 28/15
resented [6] 10/21 32/3 32/11 50/18 93/8I proposition [1] 116/9I public [12] 4/11 16/1 I 29/1 29/22 31/5 31/7
eat 21/14 79/14 97/23 157/8 159/6 prosecute [2] 128/4 I 16/8 28/16 30/25 42/20 69/5 70/16
93/21 140/1 160/7 161/15 176/25 I 136/16 40/16 52/16 84/8 12214 164/13
presently [1] 167/18 I 177/1 prosecuted [5] 1/13 I 84/16 100/20 140/2 I quietly [2] 22/23
resents [1] 86/22 [Proceeds [5] 43/8 I 15/7 46/10 47/6 155/10 22/24
press [2] 65/23 44/22 47/3 49/1 95/11] 129/21 publicly [2] 41/3 quite [17] 9/1 16/2
Pate process [21] 6/18 _ I prosecuting [3] 168/12 16/3 16/19 22/20
pressure [1] 85/4 I 9149/19 9/23 9/24 I 140/2 145/18 154/24 Ipublished [1] 79/4 I 26/24 58/1 58/20 62/6
resumably [5] 10/12 10/16 10/22 Iprosecution [11] _Ipulse [1] 124/22 68/8 71/24 71/25
Pita 4o/1 36/24 11/11 13/5 19/23 I 40/21 40/21 42/13 purpose [6] 14/25 I 129/15 133/12 134/11
4124/7 1585 37/11 62/2 81/21 52/2 69/17 96/12 15/3 30/9 30/13 153/1I 143/5 152/7
presumption [3] 81/24 102/3 102/3 I 97/25 99/13 101/19 I 168/1 quote [1] 118/2
1 1o/8 1p2/22 132/23 I 106/14 129/13 133/25] 165/11 168/6 purposes [4] 144/14 Iquoted [1] 83/14
151/47 prosecutions [25] I 145/6 162/22 163/4
(67) postmasters... - raise
INQ00001193
INQ00001193
R 152/25 153/19 135/10 144/12 reflected [4] 27/6 128/2 140/3 169/21
iced 115) JANA [reasoning [2] 173/13Irecordings [2] 71/2 I 34/16 64/9 172/15 175/16
raised ('s] ane 173/17 714 reflection [3] 53/17 Ireliability [12] 139/23
110/22 111/1 128/18 I"easons [7] 48/22 records [8] 4/5 46/24I 111/22 111/25 140/6 142/10 148/14
1429/4 142/16 155/15 49/17 104/19 104/21 I 52/4 71/2 71/15 reflections [2] 6/4 152/16 156/17 159/23)
156/22 165/2 165/21 109/2 150/3 155/2 160/14 160/22 170/23) 149/5 160/3 160/6 161/15
1468/11 175/14 reassurance [1] 22/2Irecouped [1] 128/23 Ireflective [1] 84/11 166/10 176/17
raising [4] 80/22 reassure [2] 138/8 Irecover [2] 46/7 refocus [1] 36/3 reliable [3] 174/3
136/12 140/10 140/20 154/21 167/12 reform [1] 46/1 174/17 177/3
range [2] 102/24 reassured [1] 136/15Irecovered [1] 51/15 Ireformulated [1] reliance [1] 125/25
450/12 reassuring [1] recoveries [5] 47/2 I 37/16 reliant [1] 160/20
ranging [1] 106/10 I 197/17 47/7 100/1 156/7 refrain [1] 64/3 rely [5] 146/4 151/5
rapid [2] 127/21 rebuilding [1] 40/18 I 167/12 refute [1] 82/6 155/22 156/11 158/5
1428/5 Recaldin [1] 69/19 recovery [13] 43/7 Iregaining [1] 19/22 [relying [2] 142/25
rated [4] 90/3 90/10 recall [13] 10/11 15/6] 45/3 45/13 47/1 52/3 IRegan [2] 48/7 51/2 I 151/3
90/19 91/12 23/17 54/5 57/13 95/9 97/22 98/1 99/9 Iregard [5] 41/9 80/1 Iremain [1] 156/8
rather [17] 4/9 4/13 99/19 99/20 110/25 I 99/12 112/9 156/5 82/3 93/23 153/18 remainder [2] 2/2
T3/10 13/16 26/25 I 111/1111/4 152/4 I 17/9 regarding [6] 49/11 I 80/8
30/13 30/16 38/19 164/8 168/12 recruited [1] 8/12 50/2 56/20 75/3 remained [1] 79/4
68/5 91/4 93/13 receive [3] 19/25 _ recruitment [2] 13/5 I 165/21 166/10 remains [1] 80/3
104/21 128/19 147/18 98/7 146/22 81/14 regardless [1] 80/5 IRemediation [10]
4181/8 163/11 164/14 Ireceived [12] 1/18 rectify [1] 100/10 regards [1] 49/25 I 41/9 42/18 52/18
rating [1] 88/21 19/20 32/25 48/7 red [7] 87/3 87/5 regret [1] 1/20 87/23 89/3 89/4 89/7
re [2] 22/16 123/8 50/13 79/20 115/10 I 88/21 90/3 90/10 Regrettably [1] 75/4 I 89/13 91/12 91/15
re-engineered [1] 116/1 121/18 155/23 I 90/19 91/12 regroup [1] 9/15 remember [3] 95/1
q2a/e 165/24 173/9 red-rated [4] 90/3 regularly [2] 84/15 I 146/20 153/23
re-examining [1] receiving [3] 52/9 90/10 90/19 91/12 84/24 remind [2] 61/4
22/16 88/16 172/2 redacted [1] 173/12 Iregulatory [1] 142/5 I 69/12
reach [2] 11/5 119/16/Fecent [1] 142/1 redeploy [1] 91/8 _Ireinforced [1] 168/14I reminding [1] 133/18
reached [2] 150/8 /fecently {5] 27/21 Iredeployment [1] reiterate [1] 50/11 I remit [2] 106/7 107/5
452/22 44/20 134/12 134/12 I 91/10 relate [1] 155/4 remitting [1] 160/18
reaching [1] 75/10 136/12 redress [18] 31/15 [related [4] 43/6 95/7 Iremove [2] 101/3
react [4] 19/8 57/14 recipient [1] 48/2 34/19 87/17 88/1 88/4) 137/7 143/13 166/13
143/3 143/7 recognise [5] 46/12 I 88/16 88/17 88/19 relating [12] 96/11 Iremoved [2] 102/5
reaction [2] 51/17 62/12 86/16 90/8 89/1 90/2 91/2 101/15] 96/16 97/9 97/14 102/6
143/11 150/4 101/20 143/12 143/16) 97/15 97/16 97/22 remuneration [5]
read [27] 2/4 2/6 2/8 recognised [1] 131/5I 156/16 156/18 156/20 99/25 106/9 127/1 104/4 128/21 128/24
2/11 3/25 4/7 4/13 recognises [3] 40/7 Ireds [2] 103/16 134/15 168/2 129/9 146/1
10/8 15/9 43/18 45/21 40/8 143/13 103/17 relation [26] 6/12 7/3 I repaid [1] 58/24
47/19 47/20 51/19 recognition [1] 18/12Ireduce [3] 24/24 7/13 18/16 19/25 repay [1] 10/5
55/2 63/4 73/2 73/20 recognitions [1] 24/25 36/11 34/12 44/4 62/23 87/1I repayment [2] 97/24
83/24 94/6 94/25 101/6 reducing [4] 24/1 95/23 96/24 100/1 129/15
118/14 146/18 149/2 recollection [6] 25/17 25/18 35/22 115/24 116/18 124/19] repeat [1] 56/4
149/22 174/25 178/2 29/18 51/4 58/21 reduction [2] 11/19 I 137/12 140/11 147/15I repercussions [1]
readily [1] 85/10 77/20 95/15 110/10 I 14/8 148/2 156/4 157/19 I 75/15
reading [2] 14/9 recommendation [4] Iredundancy [2] 160/23 168/23 169/23I replaced [1] 86/2
118/17 59/22 77/12 106/7 44/16 44/17 175/7 176/1 replacement [1] 81/8
reads [1] 61/19 110/15 refer [5] 55/10 65/14 Irelations [2] 28/16 Ireplacing [1] 10/14
real [2] 77/9 82/19 recommendations 73/12 77/17 147/18 I 30/25 replied [6] 125/22
realisation [2] 18/11 [4] 91/8 91/9 93/24 Ireference [5] 28/10 relationship [8] 140/18 145/18 154/2
98/18 37/17 65/4 93/13 14/11 36/5 136/23 157/14 158/23
reality [1] 77/15 recommended [2] _ I 136/20 149/21 150/3 150/5 replies [1] 56/22
really [10] 24/15 32/2 59/18 67/23 referenced [1] 139/3 I 173/2 173/3 reply [18] 45/17
36/15 39/19 77/23 reconciliation [5] referrals [1] 107/20 Irelationships [2] 45/18 45/19 46/16
81/11 82/23 89/12 119/1 120/3 122/21 Ireferred [5] 41/11 75/12 84/25 47/15 50/14 54/1
139/12 149/22 133/20 145/7 65/5 94/9 138/15 relatively [5] 18/6 73/15 73/19 79/15
reason [7] 22/11 60/5I reconciliations [1] 165/23 32/25 153/13 175/13 I 126/15 138/14 147/10
72/4 104/18 119/6 133/11 referring [6] 10/25 175/17 148/6 154/5 154/6
126/22 149/12 reconvene [1] 177/9 I 50/23 73/1 77/17 90/5Irelease [2] 34/4 167/24 171/5
reasonable [5] record [2] 28/25 137/3 76/12 replying [1] 158/24
106/20 132/21 135/3 78/25 refers [4] 66/20 94/5 Ireleased [1] 68/10 I report [13] 60/7 62/4
146/4 164/12 recorded [10] 8/14 I 145/10 164/23 relevance [1] 96/25 I 105/16 105/20 105/23)
reasonably [3] 85/1 30/21 60/7 91/11 98/3) reflect [5] 6/4 33/20 Irelevant [9] 14/15 109/22 110/1 110/18
115/17 129/19 130/4 I 39/15 122/3 167/3 33/17 46/8 65/1 107/1I 117/23 121/17 148/17
(68) raised - report
INQ00001193
INQ00001193
R Respondent [1] 96/5 I 37/18 39/17 48/2 rolled [1] 25/12 113/16 176/19 176/21
report... [2] 150/13 I"SPonding [1] 50/2 I 53/23 66/13 58/19 rolling [2] 163/20 _Isat [3] 22/22 79/16
Nh response [9] 47/19 I 62/8 70/24 70/25 170/25 114/15
reported [11] 116/19 I 48/17 50/6 51/20 67/9I 70/26 72/23 73/2 74/3)rolls [1] 82/14 satisfaction [1]
116/23 117/1 117/10 I 73/8 155/15 164/18 I 74/6 76/16 76/20 room [2] 26/10 114/17
117/14 117/16 117/18) 17 V8 78/12 78/12 78/16 I 114/15 satisfied [3] 115/6
419/23 143/21 155/17IeSPonsibility [2] 81/25 87/6 104/8 round [2] 113/19 115/11 116/7
462/17 40/14 60/22 109/18 113/20 123/2 I 161/21 satisfy [1] 113/5
reporting [3] 107/24 responsible [4] 124/5 124/16 129/6 Irounds [1] 95/18 save [1] 46/21
167/8 17113 38/11 38/22 63/16 I 135/9 137/5 137/13 route [3] 48/12 savings [1] 47/9
reports [2] 66/21 128/20 137/24 140/21 146/11] 131/10 134/18 saw [8] 29/4 29/8
107/14 rest [2] 12/14 83/15 I 154/3 154/6 157/4 routinely [1] 175/10 I 29/14 29/15 30/2 36/3
represent [1] 2/1 Ifestated [1] 122/3 I 158/12 164/6 164/22 IRU [1] 90/1 37/23 132/4
representations [4] restatement [3] 166/20 167/18 174/14I rule [1] 100/8 say [57] 6/23 9/22
96/24 122/2 123/6 166/17 I 177/8 ruled [1] 174/5 13/23 14/2 14/17
representative [3] restorative [4] 69/18 Irightly [5] 46/11 run [1] 16/5 14/24 15/4 17/25 18/9)
4149/8 149/17 169/16 I 69/22 70/2 70/9 59/24 140/4 159/9 Irunning [3] 15/25 I 22/4 25/14 26/13
representatives [1] "eStore [1] 40/16 165/7 16/8 56/14 26/16 32/24 34/14
92/25 restrictions [1] 73/11Irigour [1] 14/7 SI 34/18 36/11 37/1
represented [1] result [9] 7/24 50/13 Iring [3] 36/13 102/4 IB =I 39/12 39/23 40/6
117/18 69/2 75/25 106/3 108/9 sacrosanct [3] 41/17 41/20 42/11
request [6] 75/22 126/1 164/8 166/5 _Iring-fence [1] 36/13 I 152/20 153/19 177/16] 49/5 58/12 58/13
77/11 159/12 159/13 166/7 ring-fenced [1] 102/4Isad [2] 1/5 83/10 59/15 60/5 60/9 66/15)
165/12 171/8 resulted [1] 69/16 riposte [2] 153/9 Saf [12] 56/2 56/3 71/22 72/2 74/5 81/3
requested [1] 163/23I"eSulting [1] 140/7 I 153/10 57/21 63/5 63/24 84/18 84/20 94/18
requesting [2] 159/4 I"esults [6] 83/19 rise [4] 33/19 62/7 I 67/20 67/25 68/2 99/2 101/6 108/1
4165/5 118/15 119/8 119/19 I 87/21 128/5 68/13 72/17 79/16 I 119/6 121/13 123/25
requests [6] 136/17 I 119/23 120/16 risk [6] 28/16 30/21 I 80/12 125/25 132/16 136/8
4155/1 155/4 159/22 resume [2] 23/4 30/25 33/19 90/19 I Saf's [3] 64/21 70/17 I 145/22 153/2 154/8
164/16 172/2 146/13 91/5 76/10 165/7 169/2 169/19
require [2] 156/1 resurrect [1] 61/24 [risks [1] 76/18 said [65] 20/9 20/18 I 169/25 172/14 177/14I
161/25 retail [20] 8/38/11 IRMG [1] 11/18 22/10 28/4 34/21 45/9] 177/15
required [12] 14/12 8/20 8/24 18/22 53/17IRoberts [17] 63/12 I 45/19 51/5 62/15 63/5I saying [17] 6/13 6/14
19/8 21/4 21/9 37/12 I 62/16 77/3 80/1 81/12] 63/14 63/19 67/15 64/2 64/21 65/18 68/5I 22/1 30/24 32/15
78/17 82/16 127/16 I 88/24 112/13 114/9_ I 68/7 73/7 74/3 77/3 71/8 71/12 75/17 67/20 71/11 73/7
1463/2 166/21 171/7 I 114/14 121/10 130/23] 77/25 78/16 79/9 80/9 76/10 80/11 80/16 84/14 130/18 131/16
172/16 135/17 151/13 151/17I 80/10 82/1 128/7 84/17 88/23 92/18 131/23 135/10 149/24)
requirement [1] 10/4 168/7 128/10 133/2 99/2 99/21 102/8 150/21 152/1 173/20
requires [3] 50/24 retailer [1] 16/6 Roberts’ [3] 73/19 111/15 115/12 115/15) says [21] 3/17 11/9
106/20 142/9 retained [2] 160/21 I 79/10 129/13 115/17 115/25 117/6 I 28/13 29/21 44/4
requisite [1] 91/23 160/23 Robinson [1] 53/9 117/11 117/12 125/21) 44/16 46/20 51/22
resigning [1] 7/10 retract [2] 79/13 robust [7] 153/14 126/9 126/11 129/1 I 55/24 56/22 65/13
resile [1] 175/1 79/21 167/16 170/19 175/13I 129/22 130/4 135/19 I 78/24 96/14 96/22
return [1] 146/8 175/17 175/23 176/8 I 141/1 146/21 150/2 I 134/8 153/11 159/3
resolution [4] rte revealed [1] 16/16 Irobust' [1] 170/19 I 152/18 153/18 153/18) 159/8 160/4 165/1
resolve [8] 28/14 revenue [1] 14/6 robustness [2] 34/6 I 153/23 153/24 157/6 I 175/21
29/1 29/22 62/18. IFeview [31] 4/6 32/18) 171/17 157/9 158/10 162/8 I scale [8] 7/22 10/13
+18/8 12016 150/9 I 33/6 35/5 35/15 37/3 IRodric [2] 47/17 162/14 164/10 164/11I 10/18 10/20 16/2 18/9
151/15 37/7 39/1 46/7 46/11 I 103/24 165/5 166/17 169/14 I 158/3 162/13
resolved [7] 31/7 49/13 86/14 86/18 role [21] 6/1 8/12 170/1 170/3 171/23 I scandal [8] 18/10
61/9 85/10 117/22 86/21 91/7 95/24 96/6I 9/17 9/24 10/17 12/10] 172/15 175/2 176/1 I 38/9 38/20 87/14
96/10 96/15 96/23 12/11 13/19 15/16 sale [1] 8/25 143/24 144/1 144/6
esolving I 1 aie 96/25 96/25 97/5 15/18 16/3 16/9 20/23 Salter [2] 52/10 154/11
resource [1] 184/16 I 98/12.98/15 99/22 I 54/18 86/22 86/22 52/17 Scarrabelotti [1]
resourcing [1] 91/22 105/13 118/24 123/19] 87/21 103/12 116/6 Isalvage [1] 9/4 94/14
respect [7] 40/11 135/24 174/1 139/17 152/17 salvageable [1] 9/8 Ischeme [14] 1/19
64/23 136/25 142/17 reviewed [1] 173/13 Iroles [21] 7/22 7/22 Isame [19] 40/22 16/1 16/8 40/24 42/14)
Riby [1] 1/8 41/12 41/14 42/19 49/21 73/20 76/9 42/24 42/24 95/7
142/24 155/3 173/23
; hard [1] 63/5 I 81/2 85/15 86/6 86/14I 76/11 90/3 90/5 90/9 I 96/16 97/19 97/21
hioniie b Rieee 24\ Fight [59] 5/16 5/23 I 86/20 86/21 87/2 87/8) 92/2 112/6 120/6 _I 98/16 99/7 99/18
Sebel 7/11 718 7/25 8/3 I 87/15 88/13 88/14 I 120/20 125/9 125/9 I schemes [5] 95/25
responded [2] 10/25 12/16 15/6 _I 88/23 88/24 89/8 89/9I 132/1 157/9 158/17 I 96/11 103/7 133/4
Tone toabe 22/14 23/4 24/16 I 91/17 470/22 17414 156/18
27/17 33/9 36/21 roll [1] 81/18 sanctioned [3] schools [1] 31/12
(69) report... - schools
INQ00001193
INQ00001193
Ss
97/7
score [1] 98/13
scores [1] 121/14
scratch [1] 132/18
screen [3] 2/17 23/2
115/12
28/11 45/16 45/17
46/16 46/16 46/18
47/12 50/8 52/21
63/23 64/25 72/25
86/5 96/22 107/6
127/12 127/14 136/7
138/13 138/24 147/3
147/8 150/23 170/7
172/22
scrolling [13] 12/9
12/12 12/13 14/2
109/20 116/1 154/14
164/2 164/23 165/4
1711/5 171/20 173/15
scrutiny [3] 85/8
93/18 112/3
se [1] 51/11
second [20] 2/22 3/3
4/4 5/17 6/12 35/16
60/13 72/14 73/15
78/23 96/9 108/12
130/8 131/24 145/10
156/4
secondary [1] 78/4
69/17 101/2
Secretary [5] 31/13
34/17 35/1 37/2 58/6
section [2] 9/22
23/13
sector [1] 4/12
security [12] 43/18
97/12 97/14 97/16
see [49] 9/14 11/2
12/1 28/3 28/11 35/3
75/21 77/17 83/17
84/16 85/1 85/25
87/12 89/21 95/20
104/9 104/10 110/4
127/13 135/21 139/3
145/12 146/24 147/4
147/5 147/8 147/10
150/8 151/15 170/12
171/20 171/23 172/22)
174/17 174/25 175/4
scope [3] 13/25 97/2
scroll [34] 7/19 23/10)
secondly [4] 4/4 26/4
seeing [3] 127/21
128/5 159/21
seek [7] 49/18 55/2
100/10 101/2 107/2
137/11 143/15
seeking [3] 31/14
50/22 159/1
seem [3] 48/5 132/1
153/4
seemed [4] 31/12
31/18 31/24 114/19
seemingly [2] 44/3
57/5
seems [18] 31/9
73/14 73/19 80/7 81/6) 49/14 61/16 62/9 96/1] 134/10
109/19 117/16 118/10] 99/6 99/21 101/17
131/23 132/11 140/8
165/14 166/13 172/2
173/18
seen [10] 53/3 59/20
65/22 65/22 69/6
89/22 118/4 133/12
143/22 150/18
sees [1] 168/5
SEG [2] 85/18 85/20
SEGI/GE [1] 85/20
seismic [1] 24/16
Select [1] 66/8
selected [1] 106/24
37/1 50/10 59/9 59/10ISend [1] 73/4
sending [1] 28/1
senior [9] 17/18
23/18 25/2 49/4 64/1
108/19 127/7 159/19
171/16
sense [11] 17/8
31/19 32/14 32/16
59/1 69/4 78/1 89/9
113/15 152/1 177/12
sensible [2] 49/17
59/25
sensitive [1] 76/3
sent [12] 27/22 28/3
44/19 47/3 51/6 97/10] 44/2 63/1 67/4 67/5
67/8 74/6 95/14
97/18 98/4 98/7 98/17I 119/14 136/12 166/7
sentence [2] 59/10
60/13
sentiments [1] 40/19
38/18 43/24 45/14
45/15 46/25 47/13 ISeparate [2] 57/19
47/14 54/5 59/7 61/18) 1704
7oM10 72/10 72/16 [Separately [2] 125/14
separation [2] 11/18
145/4
September [18] 2/14
3/4 3/14 5/2 7/7 7/9
18/25 20/10 27/7
27/16 28/7 32/22 33/8
33/11 34/2 106/2
106/5 169/18
September/October
[1] 32/22
series [1] 61/7
serious [7] 8/15
23/17 47/7 73/16
75/15 141/2 142/16
seriousness [1]
25/21
servants [1] 34/13
service [5] 9/6 12/4
44/18 134/6 165/11
services [5] 53/13
147/15 160/21 161/2
161/5
set [12] 3/22 7/16
12/6 28/21 30/14
142/15 150/25 153/20) 30/14 30/18 112/23
121/13 133/3 156/15
176/6
sets [5] 11/4 11/7
12/8 107/7 109/14
setting [2] 7/16
174/12
settled [1] 34/25
settlement [5] 4/12
seven [3] 5/2 11/4
62/8
shadow [1] 8/16
shall [1] 146/13
shape [1] 89/15
shared [4] 149/7
shareholder [11]
25/16 35/12 101/12
101/17 127/2 127/4
129/6 132/7 149/7
149/16 169/16
sharing [2] 144/14
172/19
she [9] 1/18 48/7
86/10 92/8 92/18
shed [1] 108/4
Sheratt [2] 59/8 62/2
short [7] 35/5 38/4
54/25 94/22 125/8
125/19 146/16
shortfall [23] 1/11
33/19 40/24 55/4 55/5
56/10 59/1 59/5 60/9
89/8 92/4 103/21
118/5 118/23 120/25
123/13 123/14 124/3
136/2 143/1 151/4
151/14 156/25
shortfalls [26] 10/5
55/7 62/9 104/4
116/18 117/18 118/21
118/22 120/20 120/24
121/20 123/15 124/20
serviceable [1] 150/6I 29/16 34/19 36/22
serving [3] 16/7 82/6 I 92/10 93/20 93/24
settle [2] 21/12 31/22I 171/1
25/11 26/4 35/3 58/21Iside [2] 4/25 5/11
share [2] 48/9 154/10Isignificant [13] 10/17I
164/25 165/20 169/17I 126/10 126/15 133/12)
48/9 53/8 56/22 56/23) 137/22 138/14 139/13)
131/1 134/19 141/16
142/19 142/21 143/9
150/24 151/1 151/6
167/5
shortly [1] 144/3
should [41] 3/25 4/7
4/8 4/13 9/10 21/11
22/12 28/25 29/1
37/4 38/4 58/8 58/24
72/9 78/25 79/24
81/15 89/25 90/6
97/3 99/2 100/9 101/7
101/20 101/20 113/18
123/25 126/1 133/19
142/25 144/11 144/18)
4151/3 162/25 177/14
shouldn't [1] 162/25
show [1] 170/23
shown [2] 118/4
140/17
shows [2] 118/10
sic [5] 11/2 61/5 61/7
61/21 66/21
sign [2] 42/25 84/1
signature [4] 2/23
3/8 4/19 5/5
significance [2]
20/20 33/5
33/18 37/25 118/15
143/23 149/19 154/15)
165/18 168/4 173/19
signs [1] 47/13
silence [1] 100/21
silent [1] 79/4
similar [1] 47/22
similarly [1] 40/5
Simon [4] 69/19
simple [1] 159/4
simply [8] 16/23
26/10 38/17 83/6
87/24 124/3 153/2
177/14
since [12] 20/12
64/23 101/16 116/2
116/20 117/2 117/11
121/8 133/12 135/7
169/2 169/25
sincerely [1] 48/9
sincerest [1] 50/11
single [5] 81/17
108/15 108/17 139/8
145/25
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sir [10] 50/19 52/17
54/20 94/16 124/13
135/8 146/14 153/11
126/12 127/22 128/22I 175/3 177/6
sit [3] 22/24 41/17
157/21
sits [2] 45/5 60/21
situation [17] 9/18
14/14 28/14 44/9
57/25 58/4 67/21
75/22 83/10 121/5
151/10 151/16 152/5
152/8 162/3 168/21
173/17
situations [3] 42/4
106/10 106/20
six [11] 17/6 21/4
21/7 23/12 29/10
30/12 58/16 70/3
80/24 94/9 116/22
size [1] 109/11
skills [2] 16/5 16/10
skin [1] 121/14
skip [1] 44/15
skipping [1] 64/16
sleep [1] 45/7
slightly [8] 23/8
31/24 36/8 58/25
80/13 109/16 132/20
141/18
slow [1] 72/1
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89/23
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18/6 19/7 21/3 22/21
22/23 22/24 23/6
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61/24 62/1 62/14 64/6
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68/13 69/20 70/15
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109/4 109/24 109/25
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114/22 115/7 117/3
117/6 118/14 119/6
119/8 121/7 122/15
123/6 123/7 123/8
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s 130/12 131/10 134/1 I 56/8 82/4 121/7 161/17 162/2 164/25 I stretched [1] 111/23
7491 1968/2 196)9I 134/18 sponsored [1] 106/4 I 166/10 170/25 171/9 Istrict [1] 75/6
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4131/8 13413 12/14 I 455 spotted [1] 81/22 177/15 strong [4] 11/11
132/24 133/5 133/16 IS00n [1] 91/9 spouting [1] 29/25 Istatements [17] 2/12] 101/25 102/1 143/5
134/21 135/3 139/11 [Sorry [11] 28/24 stabilisation [1] 8/9 I 5/10 5/14 5/18 5/18 I strongly [1] 76/10
1440/8 141/1 144/1 47/20 58/15 61/2 stabilise [1] 8/21 6/24 79/13 79/21 structurally [1] 103/4)
145/3 147/5 147/12 I 67/21 81/3 81/7 86/6 I stability [1] 24/21 126/18 140/3 148/10 Istructure [1] 79/8
148/18 150/1 150/9 I 124/21 130/10 162/5 Istable [1] 12/3 148/24 154/9 163/23 I structured [1] 134/9
1452/6 153/6 153/22 ISOrt[20] 19/22 30/8 Istaff [3] 47/22 106/11) 164/16 165/9 172/3 I struggled [1] 38/24
156/6 158/16 161/18 I 31/12 36/17 58/3 60/9] 106/25 statements/requests I struggling [2] 8/10
162/21 163/4 164/7 I 97/2 78/4 80/24 80/24Istaffed [1] 91/15 [1] 164/16 36/19
165/14 166/13 166/15I 86/1 104/18 108/14 I stage [10] 10/6 18/12) states [1] 65/10 Stuart [3] 47/12
1469/3 170/1 170/15 I 132/16 144/16 145/19] 21/19 22/11 29/11 stating [1] 142/10 48/20 54/2
471/15 171/21 172/2 I 198/3 161/24 162/1 I 41/1 52/19 54/14 statistically [1] studies [1] 70/1
4174/5 171/24 88/11 168/20 118/15 stuff [1] 28/1
software [1] 171/13 sought [2] 76/17 staggeringly [1] statistics [1] 119/7 Isubcommittee [1]
solely [1] 98/8 106/23 7714 status [1] 100/21 56/15
solicitor [6] 27/23 sounds [1] 62/6 stakeholders [1] statutory [1] 50/19 I subject [7] 4/11 6/19
28/2 49/9 50/22 50/24ISource [1] 69/4 21/8 Staunton [12] 55/16 I 6/24 67/6 74/11 75/8
147/17 space [1] 21/21 stamp [1] 160/18 55/23 58/7 59/9 61/5 I 93/17
Solicitors [1] 95/21 spat [2] 84/8 84/14 Istamps [4] 63/16 63/1 65/8 67/5 72/12 Isubpostmaster [9]
solution [1] 129/13 spats [1] 84/6 81/22 122/16 145/6 I 72/21 74/23 82/10 1/8 1/9 1/14 62/24
solutions [2] 128/18 speak [5] 61/25 stand [3] 36/14 71/18IStaunton's [1] 61/21 I 80/22 117/25 118/2
128/21 67/23 68/2 70/20 150/15 steal [1] 129/20 125/22 137/12
solve [2] 34/24 64/13 108/10 standalone [1] 43/21 ISteering [1] 103/25 Isubpostmasters [22]
some [82] 5/16 6/25 speaking [7] 28/18 Istandard [1] 20/1 step [7] 35/13 72/1 I 39/7 39/10 40/22
8/15 9/1 14/10 17/6 I 28/22 30/17 30/22 standards [2] 20/7 I 77/15 108/3 140/9 40/25 55/4 55/18
21/25 23/7 24/13 49/8 71/22 89/14 169/21 145/22 161/22 100/13 115/3 115/22
27/18 29/13 32/17 ISpecial [1] 71/9 standing [1] 122/20 Istepped [1] 169/9 I 116/5 116/12 116/19
35/3 39/10 40/22 _ISPecialist [2] 112/14 Istandstill [1] 136/25 Isteps [3] 93/1 113/5 I 117/1 117/9 117/17
43/19 44/23 45/4 47/9I 112/15 start [17] 2/13 8/11 I 173/1 117/19 117/23 121/17
53/21 56/4 58/17 (SPecies [1] 5/14 12/17 12/19 13/14 ISteve [1] 64/7 4125/7 126/21 140/24
specific [15] 19/22 I 15/1 20/22 32/24 still [14] 16/9 46/23 I 151/6
ea ay eee 21/1 43/9 50/23 80/24] 54/16 74/21 87/11 61/18 63/7 64/8 76/8 Isubsequently [7]
65/14 665 69/4 87/19 88/2 92/22 99/13 134/4 137/21 I 118/3 121/20 124/1 I 33/10 33/11 57/11
nino zie 7718 I 108!7 109/10 149/15 I 149/3 158/11 162/14 I 131/4 144/9 144/11 I 69/19 81/13 83/11
80/16 83/8 87/6 88/15I 155/15 162/1 163/9 Istarted [7] 18/5 158/13 158/16 97/15
88/17 89/1 B9re4 95/1] 172/21 18/18 19/10 21/13 _I stirring [2] 56/6 subsidiaries [1]
97/11 101/13 1028 ISPecifically [20] 29/13 43/14 151/12 I 60/16 106/15
102/17 104/22 106/20I 39/14 39/12 41/24 starting [5] 9/22 stock [7] 33/21 82/18Isubsidy [5] 24/2
1408/5 108/21 110/16 I 82/1 62/7 69/10 71/22I 132/6 151/24 170/5 I 82/22 145/1 145/5 24/24 25/17 35/22
414/18 119/10 119/21) 72/2 7/24 87/23 88/3) 170/5 145/25 160/18 36/12
419/21 119/22 127/1 I 88/22 89/7 89/16 94/5Istate [4] 10/12 31/13 Istolen [1] 101/24 substance [6] 12/14
4134/5 134/6 136/11 I 110/25 114/1 114/14 I 139/21 168/23 stood [1] 80/16 50/14 68/5 80/21
437/18 138/4 144/4 I 120/4 125/5 stated [2] 50/20 stop [5] 15/8 46/18 I 147/24 148/4
145/24 146/8 148/21 ISPecification [6] 168/12 58/15 64/11 73/14 I substantial [1] 1/10
4149/5 150/18 12/5 I 10/10 10/12 10/24 Istatement [66] 2/14 Istopped [1] 156/5 I substantiate [1]
487/14 187/17 187/25) 10/25 11/2 13/18 2/18 3/3 3/13 4/22 5/1Istopping [9] 10/23 I 113/6
462/22 165/1 1685/3 ISPecificity [1] 158/4 I 5/21 5/22 6/8 6/10 _I 56/8 71/5 87/19 141/8I substantiated [2]
466/13 171/11 172/15ISPecifics [3] 35/16 I 6/10 6/13 6/21 7/15 _I 155/11 161/18 162/5 I 113/22 113/25
81/1 81/1 7/21 9/16 13/21 13/22) 168/17 substantiating [1]
camobody [1] 7113 speed [1] 35/8 16/21 17/25 18/9 20/9) stores [1] 64/21 111/3
somehow [1] 83/4 Spelzini [1] 139/1 21/23 22/18 23/23 straight [1] 81/23 substantiation [1]
something [30] spend [5] 26/18 26/15 27/11 31/11 Istrained [1] 14/11 I 114/6
18/24 21/1 24/6 25/12 29/16 36/10 57/2 34/14 37/1 39/22 40/5Istrange [1] 48/5 substantive [1] 9/1
20/5 2a/24 30/19 174/23 55/9 73/25 131/22 _Istrategic [7] 11/8 _ Isubtopic [1] 54/21
51/22 54/15 55/21 spent [2] 17/25 25/9 I 136/6 137/11 137/16 I 12/2 12/6 34/16 85/22I success [2] 11/12
57/4 57/11 58/5 62/19 splits [1] 97/13 141/9 141/18 142/9 I 85/25 86/3 103/9
63/11 66/16 71/11 SPM [1] 115/3 142/11 143/5 145/10 Istreams [1] 153/21 successful [8] 43/6
79/25 83/22 84/12 SPMs [1] 115/4 146/10 148/10 148/23) Street [1] 163/14 45/2 45/13 46/5 51/8
99/19 102/13 112/5 ISPoke [5] 35/14 68/7 I 150/2 152/13 153/17 Istrengthened [1] 95/8 99/13 99/25
113/15 114/9 114/13 70/9 80/10 164/10 156/1 156/3 159/10 I 63/19 successfully [1] 44/6)
spoken [4] 44/20 159/23 160/5 161/14 Istress [1] 9/5 such [22] 6/3 16/7
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pia ea aal 151/19 7 teams [11] 18/22, I 163/13 166/23 167/6
78/10 86/14 98/21. ISUPPorting [13] 6/25 I—_ 59/3 59/4 67/24 87/24I 170/7 177/5 177/16
4141/5 142/11 1431. I 90/18 71/20 88/1 table [1] 172/19 97/10 120/3 130/22 I that [1136]
151/4 155/7 158/12 I 88/19 91/2 138/5 tackle [1] 15/19 130/23 133/18 155/5 Ithat's [118] 4/1 4/15
460/10 160/25 161/13I 138/8 155/3 155/5 __Itactical [2] 85/19 [technical [5] 26/19 I 5/1 5/20 6/17 7/6 7/20
161/16 166/23 155/19 156/13 165/17I 85/20 92/4 104/21 104/21 I 8/1 8/4 11/1 11/21
suddenly [1] 85/11 ISUPPose [2] 450/20 Itake [20] 12/11 29/8 I 161/10 11/23 12/13 12/18
suffered [2] 115/12 I 192/12 30/7 35/13 41/7 54/21] technically [1] 30/18 I 12/24 22/9 23/20 24/3
115/14 sure [16] 22/13 22/20I 65/2 66/24 67/2 84/23I telephone [3] 27/16 I 24/14 27/18 27/24
suffering [2] 8/13 9/4] 24/22 34/25 35/15 I 85/11 103/24 108/3 I 27/22 28/5 28/1 28/8 28/19 31/2
suffice [1] 114/22 I 38/12 71/5 80/20 126/3 128/21 145/22 Itell [7] 7/21 21/22 I 32/12 32/16 34/3
sufficient [7] 129/18 I 88/12 94/4 94/4 146/7 167/11 173/21 I 23/16 55/15 64/13 I 34/21 36/6 37/22 41/7
134/17 131/20 132/13) 109/25 122/24 130/10] 173/23 64/22 73/25 45/6 45/22 48/3 51/1
132/24 160/10 173/25I 131/21 145/16 taken [21] 18/16 ten [3] 58/16 87/11 I 51/11 51/19 53/20
sufficiently [1] 165/9 ISUrely [1] 151/23 24/17 25/5 25/21 116/22 55/14 56/3 56/8 56/11
suggest [3] 80/13 [SU"face [1] 100/17 I 36/20 39/17 61/6 ten-year [1] 58/16 I 57/11 58/3 58/18
1404/7 120/17 surpluses [2] 82/21 I 61/14 69/20 98/24 I tenor [1] 153/16 60/15 60/16 61/19
suggested [13] 1/10 I 117/19 105/23 110/23 113/6 Itension [4] 75/14 I 62/10 65/1 67/17
surprise [1] 150/7 I 141/10 141/15 149/6 Iterm [9] 8/23 11/12 I 69/24 70/23 72/19
ses Boe aoe surprised [4] 51/20 I 154/1 169/4 173/1 I 65/10 65/13 65/18 I 72/24 73/3 74/4 74/10
73113 72/14 Bg/1e I B4/19 135/15 150/18 I 174/19 176/12 65/21 81/16 81/17 I 74/14 76/20 76/23
101/23 168/8 surprising [3] 85/9 takes [2] 42/6 43/13 I 121/20 77/5 85/3 85/11 86/25
suggesting [4] 57/17I 118/18 119/6 taking [7] 13/5 42/25 Iterms [39] 17/9 17/19) 90/7 91/20 94/16
Tor10 129/10 148/21/Survey [14] 83/18 I 124/1 148/10 148/18 I 18/23 19/21 20/15 I 95/16 96/5 96/14
suggestion [13] 36/4I 115/2 115/3 119/12 I 154/17 161/22 20/25 21/8 35/19 100/2 102/1 105/11
45/11 51/5 51/14 52/2) 120/14 121/9 124/1_ I talk [4] 35/16 56/20 I 37/16 54/14 54/17 105/25 108/11 109/21
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60/18 69/2 95/6 126/6 126/10 134/4 Italked [2] 79/16 69/8 78/5 78/13 81/17I 119/8 119/8 121/7
17422 134/11 165/3 82/22 83/15 108/22 I 122/1 124/5 124/12
surveyed [5] 115/4 Italking [2] 18/1 89/14] 108/24 112/12 116/3 I 125/17 125/17 125/18
suagestions [1] 115/22 117/1 117/10 Itargets [6] 46/25 I 119/3 123/5 124/2 I 125/24 128/7 128/8
suggests [6] 44/1 117/17 47/1 48/18 52/2 52/3 I 130/22 131/2 134/5 I 129/5 129/7 130/1
122/5 146/9 151/9 [Surveys [5] 124/18 I 67/18 144/15 153/15 158/14] 130/3 130/8 1341/7
159/25 170/24 124/21 124/22 125/5 Itask [1] 91/18 159/4 162/22 162/25 I 132/16 132/20 132/22I
suicide [1] 45/5 135/21 Taylor [1] 63/5 163/5 164/12 1437/6 137/9 137/14
suitable [4] 73/8 suspect [1] 162/23 ITC [1] 129/5 terribly [2] 64/6 64/9 I 137/25 140/8 150/19
129/12 135/12 135/14I Suspected [1] team [90] 1/21 12/10 Itested [1] 129/2 152/4 154/4 154/7
sum [1] 138/6 107/17 14/19 20/19 20/21 __Itesting [2] 134/15 I 158/21 164/3 164/22
summaries [1] 10/9 suspicion [1] 136/23 I 24/5 24/9 26/11 47/3 I 134/25 167/19 170/13 170/19}
summarise [1] 57/15 ISuSPicious [1] 47/22 52/18 53/17 __Ithan [37] 4/94/13 I 177/6
summarises [1] 59/9] 125/10 58/22 59/4 59/23 60/1) 26/25 30/13 30/16 _Itheft [1] 106/10
summary [8] 19/4 sustainability [2] 60/21 62/12 62/16 33/21 38/19 48/25 —_—I their [38] 5/11 17/17
20/14 61/21 107/22 I 39/9 35/21 63/12 63/17 63/19 I 62/19 62/20 68/5 24/9 24/10 24/12
114/22 115/2 128/10 ISWorn [2] 2/6 178/2 I 64/1 64/10 73/23 78/6) 71/13 72/4 84/11 25/22 40/24 44/24
142/12 sympathies [1] 1/22 I 78/9 80/1 81/12 83/23I 89/20 91/4 92/6 93/13I 46/10 56/4 56/18
summer [2] 13/2 [S¥mpathy [1] 70/17 I 89/5 89/6 90/1 90/11 I 104/21 106/25 108/13] 63/20 72/19 74/18
37/14 system [45] 1/10 90/13 97/14 97/16 109/11 114/10 117/7 I 77/8 78/16 81/17
Sunday [2] 67/4 10/4 44/4 44/12 82/18I 97/17 97/18 98/3 98/4) 117/12 117/13 119/20I 85/11 100/14 101/2
72/17 114/18 115/5 118/3_ I 98/7 98/8 98/17 99/5 I 128/19 147/18 148/18] 106/11 106/25 116/1
suppliers [2] 160/25 I 118/5 121/21 128/9 I 105/10 108/9 109/5 I 153/18 163/11 164/14) 116/3 116/6 116/10
161/3 128/12 133/2 133/23 I 109/12 111/5 111/14 I 174/3 175/23 176/3 I 117/23 121/2 122/9
139/11 140/1 1146/3 I 111/23 112/13 112/14] 1476/8 126/6 128/21 142/21
supply [1] 171/13
support [28] 36/1 146/5 147/16 148/14 I 112/15 112/19 114/14Ithank [46] 2/2 2/23 I 146/4 148/12 150/16
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sory traps tron I 189/24 160/6 160/13 I 121/8 121/10 122/21 I 5/10 5/12 7/3 9/16 I them [45] 5/25 6/15
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jo2I8 123/20 122/01 I 165/20 168/22 165/24] 139/2 139/18 142/8 I 42/3 45/20 47/11 50/9] 53/24 55/4 57/8 57/12
toad 198/19 135/20) 1065/4 171/2 171/17 I 142/15 143/19 144/10] 54/23 72/11 81/5 I 58/8 63/22 68/10
taeoe tage Lava I 171/19 173/18 17414 I 144/11 145/3 145/5_ I e519 94/17 94/20 I 68/13 77/9 77/10
Taal tara iagie. I 17416 174/16 175/9 I 145/7 147/13 147/17 I o4/24 10/3 100/3 I 77/18 77/24 77/25
445/20 188/14 158/20I 175/12 176/3 176/7 I 151/13 151/17 159/20I 124/17 127/13 127/20I 80/10 80/19 81/11
17713 165/17 165/22 16/5 I 1365/2 137/18 138/17 I 88/22 91/5 91/17
(72) such... - them
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T 51/14 56/8 56/16 30/16 34/9 36/17 43/7Ithis [329] throughout [2] 18/5
them...[20] 10171 58/15 59/1 60/6 60/7 I 47/7 48/25 51/8 55/16) this’ [1] 64/13 33/17
101/4 113/8 119/13 I 60/11 62/14 63/13 56/5 56/20 56/21 Thomas [11] 43/15 ITidswell [1] 149/7
119/14 120/21 123/4 I 64/17 64/18 64/23 57/13 59/13 60/15 48/18 49/5 49/17 Tim [10] 18/1 27/6
124/25 126/11 131/8 I ©4/25 66/1 66/6 67/6 I 60/22 60/23 62/17 49/24 51/3 53/5 54/3 I 27/8 27/14 28/19 29/9
133/9 133/18 133/19 I 69/25 71/5 71/11 63/20 64/2 68/10 95/3 97/17 99/21 29/11 53/11 53/12
73/11 73/14 75/1 68/11 68/12 68/20 I Thomas' [2] 46/15 I 53/12
tear? tea tee 80/16 82/2 82/17 74/16 74/18 77/8 47/15 time [48] 13/2 13/25
475/17 82/21 84/21 85/12 78/14 80/5 80/13 thoroughly [1] 75/22 I 17/4 17/25 26/18
theme [2] 175/19 87/12 87/19 88/5 80/16 80/25 81/13 Ithose [84] 2/14 4/21 I 26/24 29/16 31/13
175/25 88/10 89/23 89/25 81/16 81/18 81/20 5/10 7/22 8/2 8/8 16/2I 32/1 32/17 33/23 45/2
90/16 92/21 92/22 82/6 82/7 87/15 87/16) 16/12 18/8 18/14 46/21 47/25 50/13
themes [1] 19/22 93/5 93/15 94/2 95/6 I 87/25 88/12 88/13 19/16 20/7 21/1 21/4 I 50/16 52/24 53/14
themselves [12]
24/11 41/4 87/15 98/20 99/6 99/12 88/13 88/14 88/24 21/7 21/12 24/19 57/10 61/14 62/10
87/18 93/9 93/21 99/13 99/18 99/24 88/25 89/8 89/13 25/20 25/24 27/22 66/19 66/25 71/24
117/24 118/12 120/21I 100/1 102/16 104/20 I 90/22 91/1 91/3 91/4 I 27/25 30/7 30/11 71/25 78/6 78/10 83/2
1241/2 123/19 126/12 I 18/7 108/20 108/25 I 91/18 93/9 103/16 31/23 33/13 38/8 86/9 91/22 95/7
then [96] 4/10 11/3 109/6 111/21 112/4 I 103/20 103/21 106/1 I 40/10 40/19 40/20 105/18 112/6 112/22
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48/19 48/23 49/21 1341/1 134/8 137/4 121/24 123/17 123/19I 75/12 78/21 79/5 times [6] 71/8 82/10
50/14 54/11 54/13 138/4 141/8 143/23 I 125/10 126/12 127/21I 85/24 88/4 88/11 112/5 117/3 117/6
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64/16 70/22 72/6 149/14 151/25 153/21] 135/17 135/18 135/19] 97/16 100/5 100/17 Itoday [12] 41/18 74/1
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Tel 78/18 79/15 nals} 158/16 160/11 160/12] 139/6 139/9 139/10 I 102/25 103/10 108/12I 88/15 108/4 113/14
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10716 107/22 109/17 I 162/16 163/4 165/2 I 148/9 148/16 150/15 I 119/20 124/6 127/12 Itoday's [1] 27/2
tor 110/23 113/4 I 165/14 165/14 166/17I 150/20 150/21 151/18] 129/20 133/7 134/6 Itogether [10] 3/19
alt ties 11a. I 168/17 170/22 174/24] 151/19 157/9 162/18 I 134/11 139/18 14518 I 3/21 15/15 24/17 25/5
122125 123/3 1023/8 [there'd [1] 61/7 162/21 162/23 162/25] 145/8 157/14 172/5 I 25/22 71/25 110/15
424/03 128/28 129/19Ithere's [14] 15/23 I 163/8 163/8 163/10 I 173/1 151/14 158/2
133/23 136/20 138/13] 55/9 65/24 65/25 71/3] 163/10 165/24 16/3 Ithough [6] 13/2 56/6 Itold [13] 15/17 21/23
t3a)o4 138/04 139/18] 88/10 108/9 1182 I 170/2170/3 170/3 I 60/16 93/24 119/24 I 22/7 77/10 94/10
140/15 141/5 144/15 I 119/24 127/10 147/3 I 173/9 175/10 120/7 94/14 132/2 132/21
144/17 147/22 148/6 I 162/21 164/24 175/19] they'd [4] 17/3 17/12 Ithought [11] 16/14 I 139/10 154/1 166/3
148/25 151/2 154/20 Ithereafter [2] 29/5 17/13 116/19 16/18 16/18 17/17 166/5 167/17
154/25 156/4 156/15 I 91/11 they're [4] 12/6 57/22) 29/16 56/23 58/19 I Tom [2] 56/20 129/5
158/5 161/6 163/20 Itherefore [17] 10/2 I 118/18 128/14 77/14 111/16 116/15 Itomorrow [2] 27/3
164/2 164/17 167/5 I 17/20 20/5 26/11 29/5Ithey've [1] 82/7 135/4 17719
467/23 171/5 171/11 I 99/23 67/25 84/21 thing [5] 56/6 56/8 I threaten [1] 49/8 tone [3] 51/20 79/23
171/20 172/24 174/2 I 101/14 126/4 152/6 I 76/16 132/1 144/25 Ithree [26] 3/15 4/21 I 143/9
174/8 174/11 17518 I 199/17 160/22 168/23Ithings [16] 6/13 11/16 13/23 25/24 —Itoo [7] 14/7 30/22
175/15 175/25 176/5 I 169/23 171/13 176/23] 15/17 15/21 34/24 34/21 67/24 70/4 70/4I 71/25 73/11 93/23
1476/9 these [37] 10/20 29/3I 56/17 60/16 62/6 71/3I 70/11 76/19 77/18 100/2 111/24
there [152] 1/10 3/15 34/16 42/4 44/23 45/4) 74/15 95/24 124/21 I 81/17 94/10 94/15 I took [16] 25/7 29/17
3/18 6/6 6/18 10/23 I 93/21 64/19 66/20 133/3 144/22 153/12 I 96/9 101/22 121/8 32/16 35/10 44/16
11/7 14/6 15/10 16/4 I 70/21 72/21 75/16 157/25 158/12 1271/5 140/2 157/7 44/17 62/20 71/24
16/19 16/22 16/24 76/19 77/11 80/3 think [283] 161/23 162/8 173/22 I 72/1 81/13 81/24
47/7 17/15 18/11 21/3I 80/21 84/24 84/25 _I thinking [3] 36/15 174/2 175/20 100/17 118/9 137/4
23/17 23/23 24/15 88/18 88/21 89/2 89/6) 57/7 83/6 through [28] 2/13 150/9 161/19
24/22 26/9 30/3 31/6 I 91/1 92/5 98/8 99/1 I third [21] 3/13 3/17 I 9/14 25/8 36/15 37/11Itool [2] 120/11
31/7 31/12 31/15 117/18 118/14 119/7 I 5/21 6/8 6/21 7/14 70/1 70/2 70/7 88/22 I 120/11
31/21 32/1 33/5 33/17I 119/24 120/16 129/2 I 13/21 55/9 79/11 91/7 97/22 100/14 —_Itools [1] 125/15
33/23 36/12 36/20 144/16 144/22 153/15) 117/19 127/17 131/15) 106/13 114/23 120/13) top [9] 26/16 28/1
36/22 38/4 38/8 38/15I 10/7 166/21 136/6 142/3 146/2 121/4 121/23 121/24 I 52/22 78/22 83/17
39/13 39/18 4012 [they [132] 3/2 3/12 I 154/23 155/6 155/8 I 122/8 125/16 125/17 I 95/23 131/24 148/6
413. 41/17 41/20 I 9/9. 7/2 16/23. 17/5 I 157/12 160/21 169/1 I 125/18 131/10 133/17] 154/6
42/41 48/24 49/7 17/7 17/12 17/17 __I third-party [1] 169/1 I 149/2 165/3 171/7 _I topic [8] 38/7 39/4
17/19 17/21 24/13 I thirdly [1] 4/10 174/23 54/20 55/3 57/25
(73) them... - topic
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T truly [1] 37/9 169/17 174/21 174/21) 72/2 87/23 89/3 89/4 I 69/24 71/1 73/25 76/4!
topic... [3] 100/4 trust [8] 19/22 40/11 Iunbiased [1] 89/14 I 89/7 89/13 91/12 79/21 94/10 94/14
1408/1 177/6 40/16 40/18 75/14 unclear [2] 35/9 91/15 104/23 105/2 I 101/13 103/6 106/8
total [2] 98/6 125/22 76/14 120/15 158/12 I 35/11 170/9 118/6 133/1 139/6
touch [1] 148/9 trusted [1] 63/11 uncovered [1] United [1] 11/6 154/1 167/17
touched [1] 1081 _Itruth [2] 38/10 159/15 units [4] 41/21 us' [1] 64/3
towards [4] 35/8 39/6) 105/23 under [26] 1/19 3/21 Iunjust [1] 101/3 use [9] 1/11 100/14
106/22 167/4 try [11] 8/23 27/8 23/11 23/15 40/23 unless [3] 148/4 120/10 120/11 134/23)
57/19 59/20 71/16 41/24 42/14 43/8 47/2I 152/21 177/9 135/19 152/23 155/1
towers [1] 161/1 =
track [2] 2/19 3/6 84/23 119/9 120/6 47/8 48/23 52/4 56/14I unlikely [1] 49/15 155/12
tracking [1] 3/23 120/15 121/10 133/13] 59/12 70/12 78/7 unreasonable [2] used [17] 65/10
traction [1] 120/7 trying [22] 17/8 17/18) 81/16 85/4 85/9 95/11) 91/13 126/4 65/13 65/18 66/2
Tracy [1] 82/4 21/2 22/2 24/14 25/11I 121/10 121/22 144/20] unreliable [2] 139/11 I 66/13 66/14 66/17
trading [4] 24/1 25/25 32/23 35/17 150/23 165/4 166/18 I 166/4 77/22 102/11 102/16
24/25 56/13 58/18 36/9 36/13 38/14 42/3I underestimation [1] Iunsure [1] 61/2 111/21 118/25 139/24}
traditional [1] 107/16 61/3 70/22 77/25 78/3I 16/19 unsurprisingly [1] 156/7 159/5 166/25
traffic [1] 146/8 88/5 132/18 152/3 underlining [2] 40/3 I 132/7 176/25
train [2] 47/4 170/4 162/2 162/3 40/10 until [11] 3/22 22/5 Iuser [1] 161/1
trained [4] 133/16 [tu [14] 5/3.39/4 underlying [2] 27/9 I 50/20 54/21 57/1 64/1Iusers [1] 160/19
training [12] 40/14 39/21 55/10 65/8 72/6) 119/10 68/2 78/10 137/1 uses [1] 64/10
109/3 115/9 133/5 72/8 100/4 104/23 underneath [1] 11/10) 175/17 177/18 using [5] 49/18
133/18 134/4 134/5 105/20 136/5 understand [32] 1/24Iuntouchable [3] 106/11 117/23 118/12)
134/7 134/14 135/19 turnaround [2] 9/1 14/10 18/19 21/2 25/3I 77/19 77/21 77/22 142/21
158/15 158/20 14/14 25/21 28/24 30/2 31/3/ untouchables [6] using/misusing [1]
tramlines [1] 95/22 turnarounds [1] 7/25I 38/10 38/21 51/18 65/6 65/13 66/1 66/15] 106/11
transacted [1] 59/13 turned [1] 135/5 51/24 60/18 70/11 66/16 90/7 usual [1] 168/7
transaction [5] turnover [1] 11/7 71/1 71/16 82/11 89/6I unusual [2] 54/11 utilised [1] 100/21
114/13 122/13 122/15ItW° [37] 5/14 7/21 90/17 91/24 102/18 I 152/14 utterly [2] 84/22
133/10 160/14 8/8 12/14 16/22 17/15] 116/12 119/10 121/12I unwilling [2] 150/15 I 120/10
transactional [4] 18/18 31/12 34/21 122/24 138/4 138/7 150/16 Vv
1450/6 57/16 57/19 62/16 141/8 145/14 161/19 Iup [49] 2/16 3/22 5/3 I*
65/14 66/5 66/10 163/6 23/6 43/24 43/25 value [1] 124/1
transactions [7] .
115/18 115/19 115/21] 69/13 76/9 78/17 __Iunderstanding [16] I 44/16 45/16 46/18 __IVamos [1] 47/18
80/21 81/8 83/1 85/17! 1/17 10/6 14/3 18/6 I 47/14 55/10 56/5 56/6I variable [2] 35/25
te, 145/24 145/24 90/8 108/18 119/20 I 21/9 30/10 36/16 51/9) 58/17 59/12 60/16 36/17
transcript [1] 105/20 123/22 124/21 124/21I 79/7 82/19 90/12 63/24 65/8 71/18 variant [2] 175/19
transformation [5] 124/22 133/3 151/22 I 102/21 132/25 135/16I 73/14 73/19 74/11 175/25
10/14 10/20 12/23. I 17/6 157/19 161/23 I 148/13 163/9 82/9 90/15 105/21 _I variations [1] 34/16
24/23 35/21 162/8 171/23 176/4_Iunderstood [5] 61/12I 107/6 108/10 116/24 Ivarious [4] 109/2
transparency [1] _ {tW© years [1] 119/20 I 72/20 129/24 151/21 I 18/1 122/12 125/1 I 109/2 129/23 161/2
78/1 two-page [1] 12/14 I 173/2 127/14 131/9 133/3 I varying [1] 103/8
transparent [2] two-way [1] 151/22 Iundertaken [7] 1/25 I 136/6 138/13 138/24 Ivast [5] 17/12 107/18
120/10 167/14 type [1] 84/25 105/13 137/7 157/18 I 147/8 148/19 149/13 I 117/9 122/16 122/16
transparently [1] [types [1] 125/5 161/13 167/15 172/13I 149/14 150/9 153/7_ Ivehicles [1] 125/15
167/8 typical [2] 117/11 Iundertaking [3] 84/1 I 163/1 170/10 171/5 I Venus [3] 55/12
Treasury [1] 102/14 {117/14 91/19 154/22 171/20 172/5 172/22 I 58/14 111/19
treating [1] 107/3 _ I*yPically [2] 98/1 undertook [1] 51/8 update [5] 47/19 86/7I Verbal [1] 86/6
treatment [4] 43/17. I_117/22 undervalued [1] 168/19 169/2 169/25 I verify [1] 170/18
112/17
55/17 93/9 154/11 Iy 116/8 upgraded [1] 11/18 Iversa [1]
trend [1] 125/1 ——__________Iunedifying [1] 84/9 Iupheld [1] 82/2 version [4] 152/17
UK [4] 9/5 9/6 9/13 I unexplained [7] uphold [1] 50/3 152/22 173/11 174/9
trial [4] 13/13 13/16 f
Toad ase 139/18 114/19 115/16 115/17Iupon [10] 16/17 20/6 I versions [1] 34/7
tried [2] 83/8 150/8 ara [3] 18/4 127/6 I 116/20 1117/2 117/5 I 32/2 34/1 36/7 98/12 Ivery [72] 3/3 4/25
; 117/40 113/7 118/20 121/11 I 5/10 8/12 8/19 12/22
trigger [4] 7500 5 (ultimately [7] 8/24 unfair [2] 11614 149/20 15/19 16/11 17/15
riggered [1] 9/7 13/16 33/15 58/21] 116/4 upset [2] 68/10 68/12I 20/10 21/1 22/13
trilateral [1] 139/20
troubled [1] 75/18 I 129/20 150/5
troubling [3] 124/15
unfairness [1] 96/20 Iurgent [2] 23/24 80/4I 22/13 24/25 25/15
unable [1] 67/25 unfamiliar [1] 66/10 Ius [35] 2/10 7/16 25/17 27/3 31/14
4126/14 126/17 unacceptable [3] _ I unfortunate [3] 80/20] 7/21 21/22 21/22 35/19 36/9 36/13 38/7
true [11] 228 310 I 4/14 79/24 168/9 I Bare 167/25 21/25 23/16 27/23 I 41/1 41/3 41/7 41/9
4/22 5/7 16/16 25/3 IUNannounced [1] unfortunately [1] _/ 28/2 28/15 29/20 54/23 66/23 66/23
34/3 104/68 104/7 59/19 107/13 29/20 29/22 34/21 I 67/20 68/18 69/3
unanswered [1] 68/4 I unit [16] 41/9 42/18 I 52/25 55/15 64/8 69/13 69/13 73/16
132/14 143/8 unaware [4] 56/21 I 44/22 52/18.68/17 I 64/13 65/10 67/24 _I 76/13 77/20 77/20
(74) topic... - very
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92/1 103/17 108/7 176/16 132/6 151/12 152/20 I 130/12 131/13 136/5 I 69/14 69/15 70/8
4113/9 115/6 115/7 way [45] 16/12 20/9 I 153/15 158/4 160/11 I 141/10 141/16 158/9 I 70/10 70/20 70/21
116/4 118/18 120/8 I 31/6 60/2 60/3 62/17 I 169/8 172/19 175/3_ I 168/20 169/5 169/17 I 71/23 75/7 76/22 82/5
4121/2 121/2 121/17 I 92/19 63/2 79/23 went [8] 64/20 104/4 I 169/19 171/17 83/14 84/2 85/5 85/24,
4122/4 126/10 144/24 I 80/15 80/18 83/3 88/2I 109/25 118/7 133/16 Iwhich [126] 1/18 85/25 87/10 87/13
144/24 145/3 151/16 I 88/15 88/17 92/6 149/10 149/18 152/6 I 3/22 4/5 5/15 6/18 8/5I 88/4 88/6 88/13 88/16)
151/18 152/17 158/11] 99/16 102/14 105/1_ I were [204] 8/6 8/19 9/11 9/12 90/15 90/22 91/1 92/5
161/25 162/14 162/18I 107/16 108/22 111/3 Iweren't [8] 15/21 9/19 20/23 21/6 25/16 93/7 93/9 109/1
162/19 163/1 164/10 I 111/16 113/19 114/20] 26/3 52/1 69/11 71/19) 27/22 27/23 28/2 28/9) 110/14 114/7 115/6
164/11 169/14 119/22 120/8 121/12 I 91/2 110/14 146/21 I 28/20 29/18 29/24 115/10 117/1 117/5
vice [1] 112/17 123/10 127/5 129/12 Iwhat [184] 30/19 33/1 33/18 117/10 117/12 117/17)
victim [2] 139/14 130/22 130/24 134/9 Iwhat's [5] 130/4 35/10 36/4 36/9 37/15] 117/25 119/19 119/20
148/17 135/12 135/14 135/18] 130/19 141/1 168/23 I 38/21 39/22 40/6 124/2 124/14 124/15
victims [4] 38/20 135/19 144/13 149/22) 169/23 40/10 40/24 41/10 126/5 127/18 129/20
69/24 71/23 106/13 151/18 151/19 151/22I whatever [2] 162/21 I 41/11 43/16 45/5 134/7 134/11 135/22
view [28] 30/14 31/10 151/22 175/11 163/2 45/12 50/14 50/23 137/23 138/15 139/19)
31/13 31/16 32/1 32/6I “ays [5] 16/22 18/18 Iwhen [53] 9/18 15/6 I 52/18 53/24 56/21 151/13 163/17 170/11
32/13 32/15 34/12 39/24 60/11 108/18 I 17/22 17/23 18/25 56/22 58/6 58/21 171/9 173/7 173/11
35/7 37/23 38/1 38/2 IWe [375] 20/23 23/18 29/21 59/18 61/8 61/8 61/20I whole [6] 37/10
39/9 39/13 54/6 57/3 IWe'd [1] 145/17 33/24 34/18 37/6 37/8I 61/24 62/5 67/10 68/2I 40/17 43/19 43/22
63/9 68/13 70/17 we'll [8] 12/1 35/15 I 41/17 42/17 52/12 69/21 71/9 71/12 44/9 131/12
770 101/15 101/21 I 43/22 43/23 47/14 55/16 65/9 68/3 76/3 I 73/17 74/6 75/6 75/21Iwhom [6] 32/24
420/11 128/11 135/15I 68/22 127/12 127/13 I 79/5 82/14 83/1 85/7 I 83/19 86/5 86/22 87/7I 47/16 48/11 70/4 70/4
156/24 157/21 we're [23] 42/4 42/8 I 86/14 90/1 100/19 87/8 87/21 87/25 92/22
viewed [1] 107/11 46/17 55/20 67/12 104/17 109/6 110/21 I 90/13 93/17 94/6 whose [1] 39/10
views [5] 62/23 63/5 83/5 108/5 119/18 112/8 112/9 112/10 I 95/20 96/9 97/17 why [38] 16/14 16/16
73/9 76/10 116/10 120/6 120/12 121/3 112/16 112/17 114/11) 99/18 107/3 111/16 20/20 25/2 38/10
vision [1] 14/25 121/11 125/13 125/14) 114/12 114/12 117/21] 113/13 113/13 113/21] 38/21 40/19 50/23
visit [1] 144/25 131/13 133/5 135/7 I 118/7 120/9 120/10 I 114/18 118/5 119/15 I 53/24 58/7 58/19
visits [4] 59/19 133/6 145/11 158/13 158/21) 120/23 122/2 123/13 I 122/2 122/13 124/19 I 59/15 72/4 88/21
144/23 144/24 161/21 162/13 173/20] 123/15 124/2 145/17 I 125/15 125/15 133/15] 90/21 91/15 101/6
vital [1] 155/21 we've [21] 42/19 43/9) 145/21 155/25 158/2 I 134/1 136/6 136/18 I 101/10 102/19 110/18)
voice [2] 23/6 67/10 53/3 70/7 70/8 83/6 I 158/8 160/18 163/23 I 137/10 137/19 137/20) 119/8 119/9 120/22
volume [6] 14/6 60/8 104/17 114/24 119/25Iwhere [58] 29/15 140/16 141/2 144/19 I 120/25 121/11 130/9
60/8 95/7 95/8 118/16] 120/1 120/2 120/23 I 29/15 30/2 36/2 36/8 I 145/18 145/24 146/21) 131/19 132/1 132/7
voluntary [1] 47/2 121/2 123/12 130/22 I 39/2 41/4 41/15 42/5 I 147/1 147/21 150/21 I 132/15 132/19 132/20}
vs [1] 92/14 133/4 133/7 133/12 I 43/24 45/22 47/3 151/8 151/11 152/8 I 132/22 143/7 149/11
135/21 149/12 159/17I 51/19 51/21 63/16 152/13 152/23 153/3 I 152/8 162/12 171/1
Ww Wednesday [2] 1/1 I 73/4 75/2 86/13 86/18) 153/21 156/21 158/4 Iwide [1] 167/15
wait [1] 5020 I 85/22 87/2 87/15 91/9 93/5 I 159/19 160/16 161/15I widely [4] 26/12
walk [1] 41/1 week [2] 1/768/2 I 97/8 106/12 107/1__I 162/6 162/9 170/18 I 27/13 66/13 66/17
walking [1] 42/4 [weekly [2] 133/10 I 1085 113/13 113/17 I 170/23 17111 171/23 Iwider [4] 46/13 93/15
Walton [5] 137/23 I 133/21 113/17 118/4 118/24 I 172/9 174/15 175/4 I 94/2 106/25
138/14 143/19 147/19Iweeks [12] 14/18 I 118/24 118/25 119/1 I 176/24 wield [1] 77/8
459/20 21/1 24/5 21/7 30/12 I 119/16 120/6 120/24 Iwhile [3] 167/1 WIELDED [1] 63/25
want [14] 5/13 28/9 62/16 66/5 66/10 124/24 129/1 129/14 I 167/11 171/7 wife's [1] 2/1
29/4 29/25 58/23 83/19 85/6 89/22 130/25 131/1 140/8 Iwhilst [8] 37/4 49/5 Iwill [79] 1/25 1/25 7/9)
63/19 81/4 84/8 121/8 152/8 153/6 155/5 I 50/22 64/4 79/23 11/19 13/2 39/13
109/16 122/8 126/5 Iwelcome [1] 156/18 I 157/5 157/21 158/1 I 158/16 172/4 172/23 I 39/14 39/18 41/1 41/6
433/22 153/6 171/4 Iwelcomes [1] 167/20I 158/6 158/18 162/3 _Iwhistleblowing [3] I 41/7 41/8 42/4 46/12
wanted [13] 30/10 Iwell [53] 18/19 16/7 I 162/15 162/16 162/16] 49/25 108/9 108/10 I 46/19 46/21 46/22
29/24 30/18 33/4 33/6] 168/17 175/20 whiz [1] 114/23 46/25 49/10 50/1
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149/15 153/23 56/12 62/11 65/22 __Iwhereby [1] 133/23 I 17/23 18/3 21/14 _I 75/14 82/16 82/17
was [482] 65/24 71/14 72/4 79/5Iwhether [37] 20/6 I 21/14 22/7 28/18 —_I 82/20 82/25 90/22
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wonder [1] 136/5 I 69/8 70/15 71/15 155/23 156/18 156/24
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