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The Post Office Horizon IT Inquiry
Thursday, 10 October 2024
(9.59 am)
NICHOLAS JAMES READ (continued)
Questioned by MR BEER (continued)
SIR WYN WILLIAMS: Mr Beer.
MR BEER: Yes. Thank you, sir.
A.
Qa
Good morning, Mr Read.
Good morning.
Can I ask, to begin, one set of questions arising from
something that you said in the course of your evidence
yesterday.
I think you'll recall that the Inquiry, the Chairman
held compensation hearings, ie hearings into the
schemes --
Yes.
-- that were set up to provide redress to postmasters,
and he held four such hearings: one on 6 July, one on
13 July 2022, one on 8 December 2022, and then one on
27 April 2023, which I suspect you'll remember
particularly because you attended it, you sat alongside,
I think, Ms Gallafent KC --
Yes.
-- with Mr Staunton, the then Chairman of the Post
Office sitting behind you.
So in none of those four hearings was it said by the
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been caused", ie it should have involvement in and be
involved in the administration of the schemes.
You went on to say that, by contrast, it was your
firmly held view that, for a range of reasons, the Post
Office should have nothing to do with the provision of
redress to wronged subpostmasters, certainly in terms of
financial compensation.
Was that a personal view that you held?
It is a personal view that I hold but I think it's also
a view that is held by others within the Post Office.
Certainly, just to confirm your earlier comments, we
have done everything that we can to build independence
into the schemes, but I think the start point of this,
and it's -- it will be Simon Recaldin's view, I'm sure,
when you speak to him next week, as well, that there was
always going to be difficulty with the Post Office
administering compensation because of the level of trust
and confidence that many of the victims will have in the
Post Office. So I don't think it's a particularly
controversial position.
Was it the corporate view, essentially, of the Post
Office?
Yes, it was and has been for some time.
If that was the corporate view of the Post Office, why
was it not communicated to the Inquiry in any of those
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Post Office that it was the Post Office's belief that
it, the Post Office, should not be administering the
schemes of redress or any of them; do you agree?
I can't recall the specifics of that. It may be the
case.
Nor was it said that the Inquiry should make
recommendations accordingly, whether in its progress
updates in its interim reports, saying that the Post
Office should not be administering any of these schemes.
Instead, the Post Office's position, and I summarise
greatly, was that it was properly administering the
schemes for which it had responsibility and that
sufficient elements of independence were either already
built into the schemes or could be built into them; do
you agree?
That's what I said yesterday, yes, indeed.
You said yesterday that you looked at some
contemporaneous notes of a conversation that you had
with the Government, Post Office's shareholder, and you
say:
"The way it was portrayed to me was that the
Treasury were of the opinion that the chaos -- I think
was the word that was used -- that had been was caused
by the Post Office, there was a desire for the Post
Office to experience some of the discomfort that had
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four hearings, ie "We do not want anything to do with
redress schemes. We think itis difficult for us to be
involved," for the reasons that you give, "Please make
recommendations to take this business away from us"?
It's a good question. I'm not sure specifically why we
didn't say that. It is a conversation that has been
‘ongoing with Government for some time. That's our
failure to do so.
The Inquiry was considering those very things, there
were subpostmaster groups who were saying, "Take the
function away from, or do not give the function to, the
Post Office", and the Chairman was considering making
recommendations about those very things. Again, I ask,
if that was the corporate view of the Post Office, why
did it not communicate it?
It's a good question. I'm unsure why we didn't make
that very explicit. Clearly, we should have done.
Or is it a view that you've now come to in the light of
the events which have happened?
No, it's a view that I've held for some time and it's
a view within the organisation that has been held for
some time.
‘SIR WYN WILLIAMS: I think I'd like a straight answer to the
question: was it a view held by the organisation at the
dates of each of those compensation hearings?
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A. It's been a view held by the organisation since the very
start of the schemes.
SIR WYN WILLIAMS: Right so it was, then?
A. Yes.
MR BEER: Can I continue, then, Mr Read, with the topic we
were addressing yesterday afternoon: the investigation
of postmasters and the engagement of the Post Office
with law enforcement agencies.
A. Yes.
Q. Can we look, please, at POL00448310. These are the
minutes of the SEG, the Strategic Executive Group, which
you mentioned and explained to us yesterday, held
relatively recently, 26 June 2024. You're shown,
amongst others, as present, along with Mr Brocklesby,
Mr Woodley, Nicola Marriott, Karen McEwan and Sarah
Gray. Do you recall that in this meeting, the SEG had
to consider, because it was tabled before it, a paper
concerning the passage of material to law enforcement
agencies?
A. I don't specifically -- do you have it in --
Q. Yes, let's look at the paper that was tabled before this
SEG and it might help you.
A. Yes.
Q. POL00448345. You can see that it's a SEG report, the
meeting date is 26 June 2024. The author was
5
Enforcement Policy (‘new Policy’). The draft new
Policy, amongst other investigative operational policy
changes, proposes a streamlining of the governance of
providing law enforcement with information: the Director
of A&Cl and the in-house criminal counsel would have to
agree to providing the information and, depending on the
age of the information, a caveat would also be
provider
Then "Report", paragraph 2:
"How the Investigations Policy was implemented in
respect of possible criminal matters relied upon its
interaction with the CLEP and Legal Play Book. These
were focused on limiting in a high-risk perception
environment how [Post Office] reported matters to, and
shared data with, law enforcement. Uniquely, sharing
data in a witness statement or as an exhibit required
the extraordinary permission of the Board.”
So that's talking about the past, isn't it?
A. Yes.
Q. Is that right, that in order for Horizon data in
a witness statement or Horizon data in an exhibit to be
passed to a law enforcement agency, that required the
permission of the full Post Office Board?
A. That's correct.
Q. That was the position, okay:
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Mr Bartlett, director of A&CI, the sponsor was Ms Gray,
Interim Group General Counsel. If we look at the
Executive -- sorry, we should look at the "Input
Sought":
"SEG approval is sought regarding the proposed
change in process in governing the passing of
information to law enforcement to assist them in
criminal investigations and any subsequent prosecutions
prior to this matter being discussed at Board in July
2024."
So it's seeking, is this right, the SEG, that
group's approval, to pass a policy for approval to the
full Post Office Board.
That's what it's suggesting, yes.
Yes. "Executive Summary":
"The current Group Investigations Policy,
Cooperation with Law Enforcement Policy (‘the CLEP’),
and Legal Play Book (collectively ‘the old Policies’)
are considered too unwieldy and unnecessarily complex as
well as being drafted before the existence of [A&Cl].
The CLEP has resulted in slower than needed provision of
information to law enforcement and the unnecessary
involvement of the Board in the authorisation process.
"The old Policies have been consolidated into a new
draft single Investigation and Cooperation with Law
6
"3. The old Policies are not enabling [Post Office]
to act in an agile way in monitoring forward with
reporting instances to law enforcement where [the Post
Office] suspects that they may have been a victim of
crime or promptly servicing lawful requests for
information to aid a police investigation. A&CI
recently took responsibility for being the only conduit
for witness statements to be provided to the police,
including relieving the Security team of this activity."
Then over the page.
"This has given us the first [pan-Post Office]
picture of the scale of these requests and what is
required to service them objectively and in
an evidence-based way. There are currently 22 police
forces requesting or awaiting Horizon-based evidence
across 33 police investigations. To provide this
information, A&CI will need to draw upon Horizon data
and often provide transaction analysis. The current
approach is that the Board will need to be approached in
the majority of these cases as and when the data is able
to be shared.
"A draft policy is attached with the proposed
replacement for the old Policies to reflect the enhanced
capabilities of the A&Cl and the improved governance
approach to investigations generally. In particular,
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the draft proposes a change in the governance of passing
material to law enforcement which we believe is risk
balanced."
Then an extract from the draft is set out,
paragraph 1, within paragraph 9:
"Proactively and reactively supplied information
will have differing profiles due to historic technology
issues. The version of Horizon that was considered at
fault in the Horizon IT scandal was replaced in October
2019. In 2020, known errors and bugs identified in the
Horizon Issues Judgment formed part of review by KPMG of
the system and found not to be prevalent in the system.
From 2021, a new collaborative approach was taken to
resolving reported Horizon issues in a dispute
resolution process. Due to the effect of these
developments, the following approach to data sharing
with [law enforcement agencies] is:
Then skipping:
"Any information originating from Horizon after
1 January may be passed as either intelligence or
evidence only after DA&CI ..."
I think that's the Director of A&CI; is that right?
That's correct.
'... (or their nominated deputy) and an in-house
[counsel] both give approval. A record of [the
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developed to work collegiately with Postmasters to
understand the causes [of] any shortfalls. Any Horizon
data that pre-dates January 2022 cannot be shown to have
benefited from all three of these checks and balances."
Then the SEG paper continues:
"There are significant differences between the
environment that existed at the time the old Policies
were formed and the current and future environment. The
current approach to dispute resolution and the
underlying technology could be seen as supporting a more
[business as usual] approach to passing information to
law enforcement. However, the most significant
difference between 2019 when the old Policies were
drafted and now is that A&CI exists and brings
significant criminal investigation experience to bear,
but more importantly, also considerably more objective
rigour to assessing evidence. Project Panther within
A&Cl is solely focused on testing the reliability of
data that [Post Office] investigators and law
enforcement will rely upon."
Then paragraph 9:
"SEG is asked to discuss the proposed change of
approach in advance of a proposal being presented at the
Board in July.”
Just stepping back, so the context is made clear by
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decision] must be recorded ...
"Where information is requested by LEAs that is
Horizon data originating from pre-1 January 2022, the
same process must be followed. In addition, the wording
included in the relevant section of the Investigator's
Manual covering the passing of information to LEAs must
be included in any witness statement for evidence or in
an accompanying email or letter to the LEA requesting
the information in a non-evidential format."
If we carry on, if we scroll down, please, and then back
to the paper itself, paragraph 6:
"The accompanying lines referenced above which
caveat the material passed to law enforcement is also in
draft and is ..."
So this seems to be some wording that that it was
proposed would caveat certain disclosures:
"From 31 December 2019, all post offices have worked
‘on a version of Horizon that the High Court case of
Bates & Others has been considered by the High Court to
be ‘relatively robust'.”
I think there are some extra words or words missing
from that sentence, but anyway:
"In 2020, Horizon was tested for the known errors
and bugs identified in the Horizon Issues Judgment and
found not to be prevalent. During 2021, a process was
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this paper, isn't it, that there were a large number of
forces, some 22 --
Yes.
-- requesting evidence or requesting data in quite
a large number of cases, 33 cases?
Mm-hm.
To summarise what we've just read there, would you
agree, the proposed new approach had two elements to it:
firstly, there would be no more need for Board approval
for sharing a witness statement about Horizon or sharing
Horizon data, instead, approval would come from the
Director of A&C! plus an in-house counsel; secondly,
when a witness statement or data was shared, if it
related to pre-January '22 data, it would be caveated in
the way that we saw.
Yes.
That form of words would be applied to it?
(The witness nodded)
Can we go back to the SEG minutes, please. POL00448310.
So this is the meeting at which this paper was
presented. If we go forwards to page 7, please, and
scroll down to paragraph 4.6 under the heading
"Disclosure to support police investigations", presented
by Ms Gray and Mr Bartlett:
"TABLED and NOTED was the paper on Disclosure to
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support police investigations/Passing of material to law
enforcement.
"SEG DECLINED to APPROVE the submission of the paper
on disclosure support for police investigations to the
Board, noting further work and assurance was required in
relation to Horizon data assurance."
So questions arising from these two documents:
looking at the position as it stood before the SEG
paper, why was the Board's permission required to share
Horizon data with law enforcement agencies in a witness
statement or as an exhibit?
I think we touched on this yesterday, and the view of
the Board was that they wanted to have visibility for
any kind of data that was being provided to law
enforcement agencies, and that they wanted sight of the
sort of scale of the requests and, indeed, how that was
being operated. And I think we described yesterday that
there was that effective trade-off between requests from
LEAs and the requirement to conform to those requests,
whilst at the same time visibility, quite rightly from
the Board, that they wanted to understand where we were
engaging with law enforcement agencies, what type of
issue was being displayed, and to continue with that.
And I think that is why the SEG declined to approve
the submission of the paper. I think there was some
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So yes, I think there were certainly questions over
data assurance but I think it was a broader assurance
that the SEG were also looking for.
You said, and one can understand why, the Board might
want to understand the scale of Horizon disclosure for
law enforcement purposes, and to have visibility?
Mm.
That is satisfied by the provision of information to the
Board.
(The witness nodded)
What this describes is that the Board had to give its
permission in order for a disclosure to occur. How did
the Board, in fact, go about determining whether to give
permission for disclosure or not?
Don't recall having specific cases come to the Board for
that particular -- to respond to that particular issue.
I think this is still fairly uncharted territory for the
organisation in its sort of modern guise, in terms of
how we supply information to LEAs. So I don't think
we'd had a breakdown, certainly at the Board not in my
time, of a specific case and then got under the skin of
how and what we are supplying and in what context.
So I think this is the start of that -- of that
journey, for want of a better word, in the sense that
this is the A&CI coming forward with a proposal.
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surprise -- my recollection from the meeting, there was
some surprise at the scale of requests in terms of the
22 law enforcement agencies and the 33 requests.
I think that came as a surprise to colleagues. I think
we were of the opinion that it was in the ones and twos,
in terms of requests for information on the sort of
scale, and I think that was -- the primary discomfort
was the size and the number of requests that were coming
forward. And, therefore, a better understanding of --
and a bigger understanding of the picture, was
requested.
Q. Well, in fact -- and we'll come to this in a moment --
what the minutes note is that "further work and
assurance was required in relation to Horizon data
assurance", not to know more about the number or nature
of requests. It's about assuring, presumably, the
quality, accuracy and integrity of Horizon data that
this I referring to?
A. That too, certainly, but I think it was more a case of
understanding the bigger picture. I think there wasn't
that level of understanding at the SEG and I think we
needed to understand more broadly, you know, what was
being requested, in what form, and how we were going to
supply that information, and what reassurance that we
had that we were doing this in an appropriate way.
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SIR WYN WILLIAMS: I'm sorry, Mr Read, I don't want to make
it sound as if Mr Beer and I are Starsky and Hutch, but
I just don't follow that because all those requests for
information from the police, the 33 of them, the vast
majority of them presumably couldn't have occurred
without the Board already having sanctioned a report to
the police.
A. Well, yes, the way that I understand it is that the
police have obviously requested information, there will
be a reason why the --
SIR WYN WILLIAMS: Yes, but what I mean is that, once the
Board are asked to sanction a report to the police, they
obviously know that there is a case which is now being
investigated by the police?
A. Yes.
MR BEER: The way that the paper put it was that:
"There are currently 22 police forces requesting or
awaiting Horizon-based evidence across 33 police
investigations, the current approach is that the Board
will need to be approached in the majority of these
matters as and when the data is able to be shared."
A. Yes.
Q. Was the organisation simply not processing these
requests --
A. Yes, I think that's --
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-- essentially you're paralysed?
I think that's the point that's being made.
Do you know whether the Post Office had disclosed what
Mr Cameron had summarised at that meeting that we looked
at yesterday -- do you remember the January 2023
meeting, the quarterly meeting with UKGI --
Mm.
-- and DBT, where he said that the Horizon data is not
sufficient to do an investigation in many cases; do you
know whether that kind of disclosure had been made to
the police service?
I'm not sure.
Do you know whether A&Cl had in fact provided, before
June 2024, Horizon data and transaction analysis to the
police?
I don't recall a specific case of that coming to the SEG
or to the Board, no.
How was, in the 33 cases, the Post Office ensuring that
the Horizon data that it proposed to provide to the
police service was sufficient and that the transaction
analysis that went with it was sound?
I don't have -- as I say, this is work that's in train.
I don't have the specific detail of that.
The proposal that Mr Bartlett and Ms Gray made, by way
of their SEG report, was to essentially devolve
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enforcement agencies would rely on in a prosecution?
No, I haven't seen how the testing process works.
Do you know what data, which data A&C! was testing?
No, I don't have access to that.
Did you agree with the SEG's decision to decline to
approve the submission of the Bartlett paper to the
Board?
I believe so, yes. It's -- I think we've found the
step, the step and the move, pretty significant, as
group, and we discussed it obviously as group.
Why did you find the step significant?
I think, as I mentioned a little earlier, I was
surprised at the number of law enforcement agencies that
were engaging with us, and the scale of the interest,
the 22 and the 33.
So it was the number of cases in which disclosure would
‘or could occur that caused pause for thought?
It caused pause for thought, primarily because the team
in A&Cl is stretched, massively stretched, as we
mentioned yesterday, both in terms of its response to
the variety of work, both internal investigations of
senior colleagues, the assurance work they're providing
‘on loss recovery and discrepancies, as well as the
engagement with law enforcement agencies and, in
addition to that, the work they're doing on Speak Up.
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responsibility for permission to in-house counsel and to
Mr Bartlett, and one of the reasons given was that the
A&CI bring "considerably more objective rigour to
assessing evidence". How do A&CI bring considerably
more objective rigour to assessing evidence?
I think the majority of the individuals who work within
the A&CI, which I think, as we discussed yesterday, is
a relatively new organisation. Within that team, there
are primarily individuals who have worked in law
enforcement outside of the Post Office and I think the
assumption is therefore being made that these are
individuals who have the right training and the right
experience of law enforcement, more specifically than
perhaps was the case in the past.
And I think what is being demonstrated here is
a transition from the old Security Teams that operated
within the Post Office historically, which were made up
of a variety of different individuals, and the more
professional approach that's now being adopted by A&Cl,
with better training, better skills and better
experience associated with law enforcement.
More specifically, you mention better training,
procedures and personnel. More specifically, do you
know how A&Cl was testing the reliability of Horizon
data that the Post Office and then subsequently law
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So I think the team was very stretched. This felt
like considerably large amounts of work and I think we
wanted to make sure that it was being thoroughly
administered.
Did anyone within the SEG disagree with the SEG
decision, ie they wanted to approve the submission of
the paper to the Board?
I don't recall the specifics but I don't think so.
I mean, presumably, Mr Bartlett --
Yes, clearly.
-- and Ms Gray --
Will have --
-- will have sponsored and written it and proposed it?
Correct, but they're not obviously members of the SEG.
The minutes of the SEG recorded that "Further work and
assurance was required in relation to Horizon data
assurance"; can you help, firstly, with what that means?
I think the methodology -- and I'm slightly speculating
but I think it's the methodology associated with how we
are testing Horizon data and how we are assuring
ourselves, both from an IT -- with the IT function but
also with colleagues at Fujitsu that we have
a methodology that is robust.
One reading of the note of the minutes is that "We've
got to satisfy ourselves in-house as to the quality and
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reliability of our Horizon data before we think about
passing it to law enforcement agencies and before we
downgrade from the Board to two other individuals the
permission to do so".
Yes.
Would that be a fair summary?
Yes, that would be a fair summary.
Okay. Has the further work and assurance in relation to
Horizon data assurance been undertaken, to your
knowledge?
Not to my knowledge. I'm unaware as to what progress
has been made over July, August and September.
Do you know who it was proposed should undertake that
Horizon data assurance?
No, I haven't got that detail.
I mean, we've seen, for example in Mr Patterson's
letters some things said by Fujitsu that would be
disclosable, or at least potentially disclosable, in
criminal proceedings. Certainly, as a defence lawyer,
I would want to see them.
Right.
Was that brought into account in any of this process,
ie what was going on at the higher level between Post
Office and Fujitsu and, in the course of such
correspondence, what Fujitsu felt unable to say in its
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scroll on, please, "Criminal Conduct: Reporting";
"Inducement to Act Contrary to the Rules"; then over the
page, "Theft by Strangers"; "Failures to Report
Dishonesty"; then the cross-heading, "Enquiries by
Officers of the Post Office Investigation Division",
POID, as it used to be known for many, many years. It
says, as subpostmasters are told:
"The main job of the Investigation Division is to
investigate, or help the police investigate, criminal
offences against the Post Office [and others]. The
Investigation Division does NOT enquire into matters
where crime is not suspected.
“Most of the crimes dealt with by the Investigation
Division are committed by outsiders. It follows
a common reason for Investigation Division officers
seeking interviews with persons employed is to get help
in clearing up such offences."
Then this, paragraph 14:
"although they comprise the minority of all
Investigation Division crime investigations, there are
many cases where the possibility (or even direct
suspicion) arises that persons employed by Post Office
business may be involved. Officers of the Investigation
Division conduct interviews about these suspected
offences and they are requiring to observe the same code
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correspondence as to Horizon reliability?
I think that was part of the debate that was had in June
certainly and I think we're all acutely aware of the
interactions that we've had with Fujitsu and clearly
that's something we discussed as part of this is
process.
Thank you. Can we turn to what subpostmasters are told
about who investigates them, and go to the subpostmaster
contract, please. POL00000254. Just so that you know,
this is the post-Horizon Issues Judgment contract.
Weill come back to it later today, or perhaps tomorrow,
for some other features of the contract?
Right.
Can we look at it in relation to what postmasters are
told about investigations of them, now, however, by
looking at pages 71 and 72. This is section 19 of the
new subpostmaster contract and it concerns, in broad
terms offences committed by subpostmasters, their
suspension, and "Enquiries by officers of the
Investigation Division". You can see that that's the
heading, underneath section 19.
Yes.
We can just can, if we go down slowly, so you can see
the context of what is going to be said on page 72:
arrests and convictions; immorality; suspension; if we
22
of conduct when obtaining evidence as that laid down for
police officers. This provides for an officer
investigating a criminal procedure offence to question
any person, whether suspected or not, from whom he
thinks that useful information may be obtained. As soon
as the Investigation Division officer has evidence which
would afford reasonable ground for suspecting that
a person has committed an offence, he must caution him
before asking any questions about that offence. The
caution must be in terms which make it clear that the
suspected person is not obliged to say anything unless
he misses to do so", et cetera.
Then 15:
"If a subpostmaster or Post Office branch assistant
is questioned as a suspected person by an officer of the
Investigation Division, on statements made by a third
person, and expresses a desire to be confronted by that
person, such confrontation will, if practicable, be
arranged. At the confrontation, the suspect will be at
liberty to question the third person on his evidence and
the questions and replies will be recorded by the
Investigation Division officer."
So this describes those conducting the investigation
as the Post Office Investigation Division, and officers
of the Investigation Division.
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Given the history of the scandal dealt with in the
judgments of Mr Justice Fraser and the Court of Appeal
Criminal Division, and indeed perhaps the Inquiry, is it
appropriate that Post Office maintains within the
contract the existence of the Post Office Investigation
Division?
I must say, I think the wording is heavy-handed in terms
of the way it's described and I don't think it reflects
the way that we conduct investigations. So I think
there is a misalignment and expression "Investigation
Division" is not consistent with A&CI. So I would agree
with you on that.
Again, given the history, is it appropriate that the
subpostmasters are told that the Investigation Division
retains investigative powers that include an evidential
interview process under caution?
No, I don't think it is.
So at least this section of the contract requires some
quite radical revision, properly to describe the system
for reporting and investigation of possible offences by
Post Office to the police, doesn't it?
I would agree.
Do you know why subpostmasters are told this --
admittedly on the basis of the Inquiry survey only
15 per cent have got the new contract —-
25
it would be entirely reasonable to conclude that this
section of the contract needs rewording, and it needs
addressing -- not just rewording but needs addressing.
We're clear that we have work to do on contracts in
terms of the specifics and I would say that, back in
2019, once we had the judgments handed down, the most
important element for me at that stage was to make sure
we changed the behaviours within the organisation and
then we changed the contract. So -- which is why we did
a restatement, rather than a recontracting completely
across the organisation. That is still outstanding and
that is work that needs to be done.
Can I turn back, in part, to Project Phoenix and the
Past Roles Project, for something that has been said in
the course of the undertaking of those two pieces of
work and, just by way of some fuller context than was
given yesterday, can we look, please, at your third
witness statement from paragraph 230 onwards.
I'm just going to read in some of the paragraphs of
your witness statement by way of context for Project
Phoenix and the Past Roles Project. You say in 230:
"The background to both Project Phoenix and Past
Roles is that in 2022 I raised the issue with Simon
Recaldin stating that it was a concern to me and
potentially very problematic that there may still be
27
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Yes.
-- but why subpostmasters are told this sort of five
years on after the judgments of the High Court?
I would agree with you that it's not consistent with the
way that the A&Cl team operate. It's not consistent
with the way that we conduct investigations in practice,
and it's not consistent with the way we support
postmasters when they have issues. So I think there is
a misalignment, I would agree with you, Mr Beer.
For a postmaster reading the contract, nothing has
changed, has it?
This would not -- as you say the language and the way
that it's constructed is not helpful and not reflective
of the way the Post Office is operating today.
So that raises the "why" question --
Yes, it does.
-- why is it still like this?
And I think that is an entirely reasonable question.
We've obviously done some work on contract restatement.
We've obviously done some work on addressing the issues
that have emerged from the ClJ and the HIJ and made sure
that the core tenets of that particular judgment,
particularly the duty of good faith and particularly the
presumption of innocence and particularly the addressing
issues around secrecy and lack of transparency, I think
26
colleagues in post who either needed to be investigated
themselves or be moved into different roles to ensure
confidence is maintained amongst both victims of the
scandal and serving postmasters. Some colleagues may
have been aware of wrongdoing, or indeed without there
being immediate proof of it, have contributed to the
wrongdoing. I initiated a piece of work in the
organisation to try to get a grip on what the scale of
this challenge was and the number of colleagues still
working in Post Office and to whom this might apply. We
would then need to determine what action to take.
"The process was and slow painstaking and to be
fair, this was not an easy task. We needed to be clear
who was doing what roles and when in the past. We had
incomplete HR records which, given this was a desktop
exercise to review [1,700] colleagues with over 10 years
history in the organisation was a significant challenge.
We needed to be clear whether, not only should they be
being investigated themselves but also whether even if
no evidence of wrongdoing, there were colleagues now
involved in activities, like disclosure or administering
the compensation schemes, where it would be more
sensitive for them to be moved -- anything where it
would be better that there was no Postmaster interface.
I did not want to cut across rebuilding confidence."
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Then 233:
"In terms of Project Phoenix, my own view, one which
I believe I share with others, is that for individuals
who were actually close to the investigations unit prior
to 2015 it is hard to conceive that they were unaware of
wrongdoing at that time. I am aware that there were
approximately 40 cases that were looked into further
following evidence which emerged at the restorative
justice meetings, the Human Impact Hearings, and from
evidence before the Inquiry. These are case studies not
numbers of individuals (ie the same individual could
have been involved in a number of cases). As far as
I am aware there are now only a handful of individuals
who worked in the Investigations Unit which was
disbanded in 2015 who are still employed by Post
Office -- they do remain in the organisation, but in
different roles. Mr Bartlett has provided further
information ... I am confident therefore that no one
from that era remains in the investigations or audit
sections of the business."
Then 234:
“I recognise, understand and on a personal level,
share the frustration that Post Office has not been able
to move quicker and go further in respect of Project
Phoenix and on Past Roles ... I would have preferred
29
POL00448308. This records, by way of context, that:
“After [this Inquiry] Compensation Hearing in
December 2022, it became apparent that [Post Office] had
recruited into its Remediation Unit (RU Team) employees
who had previously worked for Post Office in the
auditing, investigation, suspension or termination of
Postmasters connected to historic Horizon shortfall
cases. This risked undermining the integrity of, or the
public or postmaster confidence in, the work being done
by the [Remediation Unit]. It also put employees ‘at
risk."
Then:
"The aim of the project [and I'm only going to read
one] is to:
"Review the past roles conducted by colleagues
currently employed within the [Unit] and Inquiry teams,
to identify any that could be (for want of a better
word) potentially problematic. Examples of such roles
might include roles in the auditing, investigation,
suspension or termination of postmasters connected to
historic Horizon shortfall cases. They might be
‘problematic’ because they pose a risk to the integrity
or independence of work being done now, public or
postmaster confidence in that work, they create
conflict, or they place our employees at risk."
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Post Office to take more decisive action and said as
much at Board discussions. That is not where the
organised however and the collective decision was made
at Board not simply to dismiss anyone who was for
instance an investigator at the time, but against whom
there was no direct evidence of wrongdoing, rather to
transfer them to other departments, offer voluntary
redundancy where possible, but, where appropriate to
thoroughly investigate. The Board was and is
collectively concerned about a myriad of other
considerations including, importantly I should say, Post
Office not acting in a disrespectful way that might
resonate with behaviours [in] the past.”
Lastly, 235:
"Post Office understands that unless wrongdoing can
be formally and fairly established, it cannot simply
remove existing staff because they were in post when
miscarriages of justice were taking place. Those
individuals of course have employment and indeed human
rights themselves. This however is a deeply difficult
area and one which I am aware that the Postmaster NEDs
feel very strongly about. This is also relevant to
[something you say below].”
Can we look, please, with that background, to the
terms of reference for the Past Roles Project.
30
So is essentially this the result or product of the
idea which you were the genesis of?
That's correct.
And what was your principal concern? What was it at the
December 2022 compensation hearing?
Well, I think --
That lit the fire?
Well, I think there were a couple of triggers. I think
the first trigger was the reemployment of individuals
who had been in the business prior to 2015. I can't
specifically recall if that was something that was
raised at the compensation hearing, but it was about
that time, which was the first trigger for me of
concern, is that we were rehiring individuals who had
been in the business prior to 2015 in that work, and
I think the second element was that, on exploring that
with Simon Recaldin and then subsequently with Jane
Davies, it became an issue for me, as -- and I think it
was crystallised during the compensation hearings, that
this might be something that is problematic, and Simon
advised that there were individuals within the
Remediation Unit who may well have been involved
historically in auditing, investigation or activities
that were of relevance to this Inquiry.
That was a surprise to me, in terms of how we had
32
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determined and decided to staff the RU, and that was
something that, you know, for a myriad of reasons, most
of which are contained in the terms of reference here
and in the aims of the project, felt problematic for me.
So can we wind forwards, then, to see what had occurred
and the approach that was being taken once the project
was up and running, by looking at a Group Executive
report which you, I think, sponsored, of 17 January
2024. POL00448615.
I don't think you wrote this yourself.
No, and the sponsorship, this would have been -- Patrick
Quinn works for Karen McEwan, so I think there is some
confusion as to why this sponsorship would be me,
particularly, but as it's not a -- it's not a function
that works for me.
Right. So you didn't sponsor this report?
No. This report will have come to the Group Executive
but it won't have been something specifically sponsored
by me.
So did you have any role in its creation?
No, not in its creation. This report will have come to
the Group Executive and I will have been appraised of
it, and had an opportunity to pre-read it before the
meeting.
So you would have been a recipient —
33
So if we just go up, please. It speaks in paragraph 1
as a key theme being that the documentary or the
docudrama had generated a lot of focus, including that
Post Office continues to employ individuals who were, to
some extent, involved in historic suspension
investigation and prosecution.
Then in paragraph 3, having described in 2 the work
that was ongoing, the key theme is said to be:
"In carrying out this work we are acutely aware of
the duties we owe to our colleagues, and the views of
our trade unions."
That seems fair enough.
Yes.
"We also recognise that, in the vast majority of cases,
employees who have performed such roles in the past will
have carried out their duties according to instructions
given to them by the business at the time, and in the
belief that Horizon was robust."
Do you know the basis for that key theme for
communication?
What do you mean by the basis for it?
An assessment that, in the vast majority of cases,
employees within this cohort carried out their duties
according to instructions given to them by the business
and that they did so in the belief that Horizon was
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A recipient.
-- rather than the sender?
That's correct.
So that's just wrong?
Yes.
Okay. Might it because you have told us that you led on
the idea, you thought of the problem and you created the
work --
Possibly --
-- that led to the creation of the terms of reference?
Possibly. There is a broader question around the
concept of sponsor and line manager that I think is
still to be addressed as part of the way that we create
reports within the Post Office. The notion of
sponsorship and line management gets confused and
blurred and I think -- candidly, I think it's obviously
having my name in the sponsor's box.
I just want to ask you about something that's written as
the communications theme for the project and it's on
page 11 of this document, which is an appendix to it.
You can see that it says, "Key themes for comms", and if
you just go to the foot of the page you can see what
that means by way of footnote, a little bit further.
"These are themes for internal communications."
Okay? These are themes for internal communications.
34
robust?
As in: is the author of this document in a position to
make that statement; is that what you're inferring?
Yes, or --
Yes, I -- it doesn't look precise, from my perspective.
I don't know where the author would be able to make
that -- or make that assumption, perhaps.
Is this a reflection of a belief within the General
Executive at the time that, although we're undertaking
this Past Roles Project, in fact, the majority of the
people caught by it will have been doing their job
according to instructions, and in a belief that Horizon
was robust --
Yeah.
-- ie we can tell our people, "Although we've got to do
this, we know, in fact, that they were just doing their
jobs"?
I don't think there was any particular determination of
that view. I think one of the sort of themes that has
emerged amongst colleagues still working within the
organisation is that many of the leaders of the
organisation historically who have appeared before this
Inquiry, appear not to have been held to account if
indeed they were aware of and understood other issues
associated with Horizon in the past.
36
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I think there is -- there was very definitely a view
amongst the people community and the authors of this
note that people were going about doing their job and we
needed to be sensitive to the fact that people were
going about doing their job to the best of their ability
and with what they knew, as opposed to a specific belief
that the statement as has been written here around
Horizon being robust, as it's written.
At all events, was it your understanding that before the
Past Roles Project, there had been no internal
reflection within the Post Office as to potential
employee misconduct?
Reflections by the organisation on this?
Yes.
There hadn't been, as far as I was aware, certainly when
I - before I joined in 2019, any specific piece of work
that had looked into what I think you're suggesting in
terms of whether people were aware and what was -- of
what happened in the past, no.
I mean responsive to, for example, the findings of the
judge in the Horizon Issues Judgment?
Not in terms of a specific piece of work about who was
left within the organisation. I think this is the
genesis of that work, and -- of those thoughts, should
I say.
37
clearly that would be the trigger to take action if
necessary, in terms of further investigation; which is
indeed what we do.
Can I turn to a separate thread of correspondence
concerning the work on past roles involving the Horizon
Advisory Board, by looking at BEISO000846. This is
a separate thread of correspondence concerning the Past
Roles Project, disclosed to us by BEIS, involving the
Horizon Advisory Board members and Mr Recaldin.
Can we look at the top of page 5 and the bottom of
page 4, please. Thank you. You can see there an email
from Professor Christopher Hodges to Mr Recaldin and
others of 18 June this year. You're not on the copy
list. He, Professor Hodges, says:
"Morning Simon
"Hope you are well.
"We held a [Horizon Compensation Advisory Board]
meeting yesterday, at least semi-informally, and no
minutes will be published until a new Government is in
place. It is interesting that there are so many issues
continuing to require attention.
"We noted your letter [I'm not going to go to the
letter that triggered this]. Thank you for your kind
offer to brief us further ..
This is essentially a letter about the Past Roles
39
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Well, the genesis, you've explained, or the paper has
explained, that it was the compensation hearing in
December 2022. I'm talking about things that might have
been done following the Horizon Issues Judgment of
December '19.
Yes, we did -- there was no specific piece of work
looking into either individuals who left the
organisation or indeed specifically people who were in
the organisation at that stage.
Was that part of a culture that you maybe hinted at when
you were being appointed, or describing your
appointment, that the organisation should not look too
deeply into the past?
Possibly. I think it's more likely that the
organisation was conscious that this Inquiry would look
very, very explicitly into activities of the past and
very explicitly into issues that had occurred
historically, in a forensic and thorough manner, and
that we would be -- obviously allegations and evidence
would be presented that we, as I say and said yesterday,
would commit to investigate as a consequence of what
emerged.
So rather than running two pieces of work in
parallel I think the view was very much that explicitly,
we would see evidence emerging from the Inquiry, and
38
Project.
Yes.
"we didn't feel it necessary yesterday, not least in
the light of the electoral purdah. But we would be
grateful for a further update. We note your ongoing
review. The view was expressed that one might expect
the answer in relation to individuals (about previous
involvement and hence ongoing involvement on
subpostmasters and mistress matters) to be either yes or
no, So we're intrigued to know more about the substance
of the review, and its timing."
Then if we scroll up to page 3, please, Professor
Hodges continues:
"We have two concerns: one is about supporting trust
of the victims in the compensation arrangements (and
anything else relevant) but the other is about timing,
given the extensive ongoing bad publicity emanating from
the Inquiry at the same time as the ongoing and imminent
new compensation arrangements. Anything you can deliver
on the reassurance issue around the involvement of
individuals, but also swiftly, would be useful."
Were these concerns of the Horizon Compensation
Advisory Board raised with you?
I will have spoken to Simon about these issues, yes.
Were they discussed with the Board in the context of, at
40
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about the same time, concerns being raised by the
Subpostmaster NEDs about the involvement of some
individuals in the provision of redress and similar
activities?
A. As we discussed yesterday, this has been a topic of
conversation at the SEG and at the Board for some time.
This was -- certainly over the summer, this was, and
continues to be, a topic of the Board and of the SEG.
Q. So the Advisory Board's interest in and comments on the
Past Roles Project were fed back to the Board; is that
right?
A. I believe they will have been, yes. I mean, this
information, I think this is June, so I'm sure at the
July board meeting this will have been fed back.
Q. Similarly, is it right that Government was taking
an interest in the Past Roles Project?
A. Yes.
Q. Can we look, please, at BEISO000848. Go to page 3,
please, and scroll down. You'll see the Professor
Hodges email to Mr Recaldin. Then, if we scroll up, you
can see that Mr Cresswell shares that with a group of
people within DBT, yes?
A. Yes.
Q. Then scroll up, please, to page 2. In answer to the
question "Do we have a line on this?", answer in the
41
Q. Were the concerns raised by the Subpostmaster NEDs
passed on by you to Kevin Hollinrake?
A. I don't recall specifically. The conversations that
Minister Hollinrake wanted was reassurance that we were
doing work to ensure that there was no danger of
confidence from victims of the scandal, or indeed
postmasters, engaged in compensation. That was the
focus of the conversation.
Q. Does it give you concer or lingering doubts about the
effectiveness of the Past Roles Project and Project
Phoenix that neither of them are completed?
A. It's certainly been very frustrating for me that this
process has taken as long as it has. I've not hidden
from that frustration for the teams. I do recognise it
is an extremely complex area but, notwithstanding that,
finding suitable solutions has taken too long.
‘SIR WYN WILLIAMS: I This is just so that I can be clear I've
got the timescale right: the genesis for the work was
the December 2022 --
A. You're correct, sir.
‘SIR WYN WILLIAMS:
over the last few days is that it will be resolved
imminently, so we're talking about nearly two years?
A. Yes, that's correct.
MR BEER: Did you get a steer from Government as to how to
43
compensation hearing, and the evidence
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department, "Not that I can remember!" Suggestion:
"The Department has made it clear to the Post Office
in the past that it needs to take steps to remove those
with involvement in the scandal in any work dealing with
redress or appeals. It would be wrong to pre-judge any
individuals before the Inquiry has completed its work
but we would expect the Post Office to take action
against anyone found to have played any ... role in the
scandal.”
Then scroll up, please, some tweaks are made.
I have read the tweaks in already. The question raised:
"... as this is an HR-type process [would it be]
appropriate for Government to comment until [Post
Office] has done the work?"
Then keep scrolling please, some more discussion
about lines for Government and then, if we keep
scrolling to the top of the page, please,
Ms Brooks-White says in her second sentence:
"I assume it came up in monthly discussions between
NR [which I think is you] and [Mr] Hollinrake? Is that
right?"
Did this issue come up in discussions between you
and Mr Hollinrake?
Yes, my recollection is it did come up in discussions
with Mr Hollinrake.
42
approach this issue?
I think my reflection on this is that Simon Recaldin had
conversations with the Government team on the ability to
offer voluntary redundancy and redundancy payments to
try and move people from the Remediation Unit. Those
are still ongoing, as I understand it.
Can we look, please, at a record of one of the meetings
held between you and the Minister Kevin Hollinrake MP.
BEIS0000739. If we just go to the foot of the page,
I think it's the second page, actually, we can see this
is an email, I think sent to self, essentially, by
Mr Hollinrake's Deputy Head of Office and Private
Secretary, Mr Lucas. This is a record, if we go up,
please, to the top, of a meeting with you on 23 January
2024 and a record was made on 23 January 2024.
Now, presumably you won't have seen this?
Yes.
This is a departmental record made in the way that we've
seen by somebody sending an email to themselves, or
a corporate account being used to do so.
If we just look down the left-hand side we can see
some initials: "NR", obviously you: is that right?
That's correct.
"KH", Kevin Hollinrake?
Yes.
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"CFO"; can you see that?
Yes.
Is that a person or the person's initials, or it's the
Chief Finance Officer?
I think it will be Kathryn Sherratt, the Interim Chief
Financial Officer.
Okay. So they've been referred to by their job title
Job title.
-- rather than their initials?
It would seem so.
"LG", if we just scroll down a bit, you can see some LGs
towards the bottom of the page; is that Lorna Gratton?
Yes, that would be Lorna.
So she, I think, was at this time a senior civil servant
in UKGI and on the Post Office Board as the Shareholder
NED?
That's correct, and she still is, yes.
"SR", we see a bit of him coming into the discussion.
Can you see there, Simon Recaldin, presumably?
That's correct.
Some "CCs" there as well, Carl Creswell?
That's correct.
We know the function that he performed.
If we just go up, please, to the top, there's some
discussion about the Select Committee appearance and
45
Need to work through how the differences arose in the
first place. Do we wish to refine our review
internally, or do we want external support to pick up
where the prior review left off? Irrespective, we need
to be comfortable with the current process with this
type of difference with the current system. I get the
urgency.”
Then she continued:
“PwC are our current auditors. KPMG were brought in
for that particular review."
Mr Hollinrake wants to get something in the public
domain within a month.
You are recorded, and Ms Sheratt, to say: “We've got
to."
You say: "We've got 8 days before the end ... of the
Inquiry."
I'm just reading this incidentally by way of context
for the meeting, rather than just going into a bit of
it.
Right, sure.
"8 days before end of ... the Inquiry. We will have
to have a position before Phase 5."
Is that you saying that, "We, the Post Office, will
have to have a position on where the money went before
the beginning of Phase 5"?
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what Post Office will respond to the Committee.
Mr Hollinrake said:
"Get it is your job to look forward."
You: "Clear it is simply not my position to opine
and pass judgement on predecessors.
He says: "... there are things you could have
pointed out but I take your point."
You say: "Don't want to go out there celebrating
what we've done in the past 4 years, doesn't feel right.
Don't want to pontificate from the pulpit on what we've
done."
Mr Hollinrake: "Key thing we've got to do is
legislate for the convictions, not straightforward for
various different reasons. One commitment I've made to
various colleagues, is where the money went."
In context, is that a reference to the issue of
where money paid by subpostmasters --
That's correct.
-- in purported satisfaction of a shortfall ended up --
I think that's correct.
-- in Post Office accounts?
Indeed.
Ms Sheratt replies:
"KPMG had a look and that info has been passed to
the Inquiry. Some other analysis has been done as well.
46
I think it certainly reads that way, yes.
Was that your view?
I think I was frustrated, as many people are and have
been, at the inability to answer this question in a way
that was -- in a way that was accurate. This particular
challenge had been out there for some time, the sort of
"Where did the money go?", question, as it was described
in many of the media outlets, and I think we had
employed, I think, two or three external forensic
accountants over the years, certainly prior to my time,
to try and get under the skin of this, and it seemed
peculiar to me that we were unable to get a fix, even
with caveats around its level of accuracy, so that we
could at least in part give people some confidence that
we understood the size and scale of this issue, or got
to the bottom of it.
Lorna Gratton says: "Probably need to understand the
order of magnitude."
You are recorded as saying:
"Clearly the business employed Wilmington ..."
I think that's Ron Warmington:
and Second Sight to do some work on this
previous, may be some merit in speaking to them."
Then Mr Hollinrake recorded as saying:
“Real opportunity to draw a line under this more
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quickly. We've been asking for things from other parts
‘of Government for some time. Anything we can do to
accelerate payments we would like to do. Do still here
from AB ..."
Maybe --
Advisory Board?
Advisory Board, yes:
that lawyers are arguing about a few hundred
[that's probably ‘quid’] here and there. I do not want
lawyers on either side slowing it down. We are under
pressure to bring it back into DBT, we want you to
deliver on them. Give the benefit of the doubt to
postmasters.”
There's more discussion on the HSS and the
introduction of service level agreements, the use of
without prejudice in correspondence. Mr Hollinrake says
that he thinks it was a big mistake to keep Herbert
Smith Freehills involved in the scheme.
Mr Recaldin says: "We are proactively phasing them
out."
Then, if we go over the page, please, you are
recorded in the third line as saying:
"Robert Daily today ..."
Indeed, he was a witness on that day.
"... Post Office Investigator. Biggest question for
49
Mr Hollinrake says: "I'm not a big fan of paying
people off. Ideally we go through a process."
CFO: "What we are grappling with is create a bit of
distance from the people who are implicated somehow and
those that are still in the business and that is
tainting it."
Then Mr Hollinrake says:
“I don't mind if we end up in an Employment
Tribunal."
Was that him signalling the approach to be taken
here: that the Post Office should take robust action,
even if it meant ending up on the wrong end of
an Employment Tribunal claim, brought by a dismissed
employee?
It does sound like it.
Was that the approach taken?
No, I don't think we've been as robust as that.
Was this not the Government giving you the green light
to be robust?
Yes, I think itis and, as I mentioned before, I think
we've dragged our feet in terms of being very, very
specific about this.
I mean the issue is the potential for individuals who
still may be operating at the heart of Post Office who
were implicated in events in the past, isn't it?
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me is we need some autonomy in dealing with people,
rather than us coming back to you or [the Treasury], we
need a warchest, effectively.”
Can you help us as to what you were describing
there?
A. Yes, we needed some financial support and guidance in
terms of the ability to move individuals on from the
organisation who were involved in the scandal, and we
wanted to do that as quickly and efficiently as
possible. That might be through redundancy, that might
be through a settlement, that might be through some
other substantive reason to move people on, rather than
going into, potentially, issues where we might sort of
fall foul of the unions, or the like, and so I think the
point I was trying to make was that we wanted to move
more quickly without having to refer back to the
Government for funding to do such a thing.
Q. Lorna Gratton is recorded as saying:
"For those who appear publicly you might have
bringing the business into disrepute defence, but not
those that don't appear publicly.”
You're recorded as saying:
"There's reputational damage that could be done here
and we want to be able to signpost this to stakeholders
that we won't sit on the fence on these issues."
50
A. That is the case and, as I have been very clear, where
we get formal allegations, we will act. Pre-emptively,
we have struggled to move people on from the
organisation.
MR BEER: Thank you. Sir, I'm about to move to a separate
subtopic, could we break for 15 minutes until 11.40,
please.
(11.22 am)
(A short break)
(11.40 am)
MR BEER: Thank you, sir.
Mr Read, I suspect, with your familiarity with the
issues in the Inquiry and the time that you've spent
preparing to give evidence in this phase, you will know
that one of the issues explored by the Inquiry is the
facility for the Post Office and/or Fujitsu to have
remote access to branch accounts --
A. Correct.
Q. -- anda sub-issue, an exploration of what the Post
Office has said across time about its and Fujitsu's
facility to have access to branch accounts, yes?
A. Yes.
Q. A third area of exploration is, or has been, who knew
what about remote access and when?
A. Yes.
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No doubt you either heard, read or were briefed about
the evidence of Ms van den Bogerd, Angela van den
Bogerd, concerning her knowledge of remote access and
what she has said across time about the facility for
remote access to branch accounts?
Yes.
Can we look, please, at POL00294728. This is an email
from a long time ago, before you were in post, pre-dated
your appointment by more than eight years, and it's
an email from Tracy Marshall -- can you see --
I can, yes.
-- to Kevin Gilliland and Angela van den Bogerd about
Horizon system issues. It's 5 January 2011 and, if you
just look at the foot of the page, in fact, I think it's
‘on the second page, you'll see that it's signed off by
Tracy Marshall, Agents Development Manager within
Network & Sales.
If we just go to the top, please, she says that she
has made some pages on the outstanding questions. Then
the second of those is, "[Post Office] or Fujitsu having
remote access to individual Horizon systems", and she
says:
[Post Office] cannot remotely access systems and
make changes to specific stock units etc. Fujitsu can
remotely access systems and they do this on numerous
53
issue was quickly identified and a fix put in place but
it impacted around 60 branches and meant a loss/gain
incurred in a particular week in effect disappeared from
the system. One solution, quickly discounted because of
the implications around integrity, was for Fujitsu to
remotely enter a value into a branch account to
reintroduce the missing loss/gain. So [Post Office]
can't do this but Fujitsu can."
One of the issues that we've been exploring is the
consistency of the accounts, or accuracy or reliability
or truthfulness of the accounts that Ms van den Bogerd
has given, in light of the fact that she was provided
with this information, as, it seems, was Tracy Marshall.
We've seen what she said in the first email that
I have shown you, which, on one view, doesn't really
reflect what is set out here.
Mm.
You tell us in your witness statement -- this is
paragraph 238 of your third witness statement -- that
a person called Tracy Marshall, as the Postmaster
Engagement Director, was the person who briefed you
about the investigation of Elliot Jacobs?
Yes, I did, yes.
The email can come down. Thank you.
Is that the same Tracy Marshall that is engaged in
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occasions on a network wide basis in order to remedy
glitches in the system create as a result of new
software upgrades.
"Technically, Fujitsu could access an individual
branch remotely and move money around however this has
never happened yet. The authority process required
audit process are robust enough to prevent this activity
from being undertaken fraudulently."
Concluding:
"So although changes can be made remotely, they
would be spotted and the person making the change would
be identified.”
If we look, please, at POL00088956, we can see
an even earlier email, which email has secured some
significance in the Inquiry, an email from Mr Breeden to
Ms van den Bogerd, dated December 2010, and you can see
that Ms Marshall was a copyee, yes?
Yes, that's correct.
If we just scroll down, and a bit more please, we see
cut into this email chain an email sent previously by
Lynn Hobbs, in which it was said that:
"I found out this week that Fujitsu can actually put
an entry into a branch account remotely. It came up
when we were exploring solutions around a problem
generated by the system following migration ... This
54
these investigations and discussions about remote
access?
Yes, it is.
What position does she hold; is it Network Development
Director?
That's correct.
Can we look, please, at WITN11610100.
This is Ms Marshall's witness statement of 22 August
and it's a corporate witness statement, it's on behalf
of the Post Office. If we scroll down, she says that
she is, in fact, the Retail Engagement Director.
Yes.
Her areas of responsibility cover postmaster onboarding,
training, contract teams. If we scroll on, please, she
says that she is responding to two Rule 9 Requests
addressed to the Post Office. If we scroll down, and
keep going, we can just scan this. Then "Definitions",
then keep going.
So just going up, you can see the first question
that she addresses "current [subpostmaster] contract ...
set out in detail" changes made.
Then, if we scroll on, please. Keep going. It's
quite a long witness statement. I just want you to see
the coverage of it.
Right.
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If we keep going, please. We asked to identify relevant
changes made in the light of Mr Justice Fraser's Common
Issues Judgment, essentially.
Then if we keep going:
".., the process by which [subpostmasters] were
notified of relevant changes", section 2.
Then if we scroll on, please:
process by which new [subpostmasters] are
notified of the terms and conditions ..."
Scroll on, please, terms of the contract, and their
negotiation, whether that's permissible and what's the
process.
Scroll on, please. If we just scroll to get the
full heading of this section of the witness statement,
"Induction and Ongoing Support for Postmasters and
Assistants", ie "Please provide details of the training
now given to [subpostmasters]", et cetera.
If we scroll on, please. I think this is quite
along section, so we can scroll on quite fast:
"_. details of any key guidance, policies, training
or instructions given to those responsible for
delivering training."
Then carry on scrolling, please:
"which department(s) hold responsibility for [such]
policies and guidelines ..."
57
Scroll on, please:
"Which department(s) hold responsibility for [such]
policies ..."
Then a new section:
*... all the avenues available to [subpostmasters]
to raise queries or questions about Horizon", and about
the Business Support Centre.
Then scroll on, please:
"... current process [a subpostmaster] goes through
when they raise a balancing issue and seek assistance to
resolve it ...
"policies, guidance, training or introduction
for those operating the [centre] since the findings of
Mr Justice Fraser."
If we continue:
"Which department(s) hold responsibility for [those]
policies ..."
Then 18:
details of the experience [et cetera] of those
responsible for operating the helpline ...
"_. how... the advice provided by the helpline is
monitored, reviewed or checked ..."
Then carry on, please:
how ... calls raised with the helpline are
monitored, reviewed and/or checked to identify any
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Then 8:
". details of the experience, expertise and
qualifications of those currently responsible for
delivering training ..."
I'm not showing you or asking you to look at the
responses to these, just showing you the coverage.
10:
any key reports, reviews or investigations ..
which address quality of training provided ...”
Then scroll on, please:
"_. details of any feedback sought or engagement
undertaken ... in relation to their training on the use
and operation of Horizon ..."
Scroll on, please:
"To what extent are [subpostmasters] expected to
train their own managers and assistants ..."
13:
"[Any] provision within [Post Office] for
[postmasters], managers and/or assistants to raise
issues about the provision or efficacy of training ..."
Then scroll on, "Contractual liability for
Shortfalls":
"Key policies and [guidance] relating to the
liability of [postmasters under the contract] and other
end users for shortfalls ..."
58
potential issues in branches", in relation to
particularly shortfalls, bugs, errors and defects.
Then carry on:
“To what extent ... are branches proactively
notified of [bugs, errors and defects]?"
Then carry on, please:
"... sources of advice or assistance made available
to [subpostmasters], managers and assistants ...
... any ... reports, reviews or investigations ...
which address the quality of the advice and assistance
provided via the helpline ...
"_. the means by which [a subpostmaster,
et cetera], can provide feedback on their experiences
[of] using the helpline ...
".., measures ... in place to ensure that
[postmasters, et cetera] who contact [Post Office] for
assistance ... receive useful, tailored advice."
Asection on "Suspension, Reinstatement and
Termination", and then continue; and continue; and
continue; and continue.
That's it, keep going, thank you.
Thank you. Stopping there.
Ms Marshall is providing the Inquiry with
information, the retention of subpostmasters, retention
of Post Office employees, including in relation to their
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potential association of past wrongdoing. She's
essentially the Post Office witness that's speaking to
that issue.
She is a person who, on one view, is involved or
implicated in the remote access issue, and yet she's
a corporate witness for the Post Office; do you see
a problem?
The issue emerged in the summer, which was the first
time, I think. The last time we -- the last time the
Inquiry was sitting and these emails emerged, we invited
Tracy to step back from her day-to-day role while we
tried to understand the significance of and the extent
of any involvement that she had. She was very clear
that she was unaware of remote access being actioned.
She said she was aware that remote access was possible
but not whether or not it was enacted in any way.
There were, I think, a couple of emails that we've
just been through and a line manager suggested to her
that she take a step back from postmaster-facing
activity so that confidence could be retained, and
indeed provide the opportunity for us to examine any
further whether or not there was something substantive
with which she had to -- to respond to.
She hasn't really taking a step back though, she's taken
a step forwards, hasn't she, because she's provided
61
of issues that I've just quite slowly taken you through?
Yes, I can see the point you're trying to make. I think
the point I'm trying to make is that my desire was that
she wasn't involved in activity that was specifically
postmaster facing, so running of forums, listening
groups, engagement with postmasters, as opposed to, and
by definition therefore, the day-to-day running of her
role. However, she had spent the previous four years in
that role and had created a lot of the change that has
been initiated by the Post Office and, therefore, she is
best placed to speak to it, and clearly the Inquiry will
speak to her, given that that is her role.
I don't think it is inconsistent to remove her from
coming to the Inquiry to give evidence on the work that
she's done and, you know, if you have questions about
other elements of her role going back over time, I'm
sure the Inquiry will explore that. As I said earlier,
we have been very clear that, where allegations are
made, we will investigate those and we will do that.
But it is a presumption of innocence in the same way as
it would be now for a postmaster as well, and I think
it's important that we continue to maintain that.
I certainly have a responsibility to all my
colleagues, as well as to postmasters, and I think it's
appropriate that the balance -- and it's a fine
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a corporate witness statement to us and is giving
evidence, I think, next week?
Well, my point at this stage was that there is no
concrete evidence of any wrongdoing and, as.
a consequence of that, we want to obviously treat her in
exactly the same way as we would anybody else, which is
explore any allegations that are being made but, in
reality, she is the individual who is best placed to
write that corporate witness statement and that is
exactly what she's done. But, at the same time, we're
clear that, for the confidence of postmasters, both past
at present, it's inappropriate for her to be involved in
activity that is postmaster facing while the Inquiry is
still ongoing, and while we can and will explore whether
there is anything that she needs to answer to.
Is there anything more postmaster facing than giving
evidence in the Inquiry on behalf of the Post Office as
a corporate witness?
I'm not quite sure I understand what you're getting at.
You said you invited her to take a step back from
postmaster-facing activity?
Yes, correct.
Is it not postmaster-facing activity to come along and
sit in the seat that you're sitting in, give evidence on
behalf of the Post Office in relation to a whole range
62
balance -- that we have adopted in terms of asking her
to step back from day-to-day activity, maintaining the
fact that she has done and has spent the last four years
involved in activity which will be explored by this
Inquiry, and then giving her the chance to come and
speak to that well, which I think is a sensible way to
progress. And we've been very clear that where people
have been invited to step back at the conclusion of the
Inquiry, and whenever allegations, if they are made, are
made, we will continue to act.
Thank you. Can I turn to, again, a sub-issue we
addressed previously yesterday: namely, having
subpostmasters as NEDs on the Board?
Yes.
You address this with a sort of qualitative assessment
in paragraph 83 of your third witness statement --
Right.
-- if we can turn that up and have a look at it. So
WITN00760300, thank you, page 46. It's paragraph 83.
You say:
"In respect of the Board, Postmaster Non-Executive
Directors have been an important part of trying to
invert this dynamic. They bring a detailed and relevant
understanding of current day matters to Board meetings
in a uniquely creditable way. This ensures
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a transparency of issues and an agreed and collective
understanding across the organisation of the most
important priorities.”
Then you go on to consider something slightly
separate.
Yes.
You give the impression, would you agree, that having
the Postmaster NEDs on the Board has been a positive
thing?
I think it's been very positive and I've been very
consistent with that. I think it's an important part of
the change that we've been trying to bring about at the
Post Office. I was the champion of bringing Postmaster
NEDs onto the Board. It is and was a feature of the
role that I had at Nisa where I had a combination of
independent Non-Executive Directors and Member
Directors -- Non-Executive Directors, and that makes --
worked well.
Can we look, please, at BEISO000753. This is a readout
of a meeting between you and other members of the Post
Office Executive. So Ms Sheratt, Mr McInnes and, on the
other side, Lorna Gratton, Carl Creswell, Jamie Lucas --
and I should say Mr Hollinrake too.
Yes.
We can see his private secretary is also recorded as
65
“Anything else you think we need to make it easier?"
You say you're looking to Lorna Gratton:
"Need as much support as you can get from Ben
Tidswell to try to get the Board functioning properly.
We need to try and find a way through the Project
Pineapple memo."
That's the inadvertently disclosed email?
Yes, that's correct, yes.
You're recorded as saying:
"We'll have a Board meeting tomorrow and see where
we can get to. Postmaster NEDs may use tomorrow as
an [opportunity] to criticise on funding and
anti-postmaster sentiment. Need to avoid tomorrow
morning being a proper road crash."
Ms Sheratt: "Had a bit of a flavour of it on Monday,
they think it did not do enough for postmasters. Elliot
mentions where the investment for the future of the
business and postmaster rem is front and centre, costs
are rising, and this has been a theme of theirs for
a while."
Then you're record as saying:
"This goes back to whether the postmaster directors
are playing a role of a director, or of a trade union
rep. I don't know where that is going to go. They are
extremely exposed as a result of Project Pineapple. Not
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being present. I just want to, again, read a little bit
of context. You say:
“Pleased with our session ..."
Is that referring to the session before the Select
Committee? Just look at the date at the top.
Yes, I think there were two Select Committee meetings,
‘one in January and one in February, and I think this one
is referring to the --
To the second?
-- to the February one, yes.
You say you were pleased with your session:
"... and felt a bit like the rug got pulled from
beneath us."
Mr Hollinrake is reported as saying:
"It's fair to say, at a certain point in time, have
to take the gloves off and try to manage the
[information]. I think the Select Committee were weak
with him, apart from Antony Higginbotham. Sorry it was
so messy. Keen to support in any way we can to make
sure we get passed [sic] this. Hope he's discredited."
Is that a reference to Henry Staunton?
That's correct, yes.
So the Minister was saying that he supposed Henry
Staunton was discredited?
That's correct, yes.
66
sure to patch this up. In a slight stand off."
Then Ms Gratton: "They are not in a good place and
aren't operating in a way appropriate for the business."
You ask: "How can they ensure their own
self-interest doesn't cut across their role in
supporting [Post Office] as a business?"
This doesn't seem to record such a rosy picture of
yours of the Subpostmaster NEDs.
I think it's a moment in time and I think we've heard
a lot about Project Pineapple in this environment. What
I would say is the point of the postmaster directors on
the Board is to be challenging, is to bring a tactical
view of what is going on the ground, and I went into
this with my eyes open, fully knowledgeable that this
would be uncomfortable. The big challenge for the
Postmaster NEDs, of course, is that they are elected to
the Board, unlike anybody else, who is appointed to the
Board. So as an elected representative on the Board,
voted for by other postmasters, they've got a very dual
challenge of, on the one hand feeling that they are
representing postmasters, whilst, at the same time,
recognising they have duties as Directors of Post
Office, and that provides conflict.
Not unsurprisingly -- and you heard from both Saf
Ismail a couple of weeks ago, I think Saf suggested he
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was working anything up to ten days a month on this --
not unsurprisingly, many postmasters were looking to
them and constantly looking to them to say, "What have
you done? What have you done? What are you doing?"
And I think that is the challenge we have had, and Saf
and Elliot have faced considerable pressure from their
peer group, whilst at the same time having to recognise
that they have got to -- and they have duties directors
of the Post Office. And so it is a tricky play.
There is no question that this time -- and you'll be
very familiar with this -- that this time was a very
difficult pod for the Post Office, the departure of
Henry, the exposure of the Project Pineapple email, the
challenges that the Postmaster Non-Executive Directors
felt, but also they were coming to the end of their term
at this stage. This is the three years, and I think
they felt very keenly that they wanted to be able to
demonstrate they'd made a real difference and I do
believe that to be the case but I think it was something
that was playing on their minds as well.
When did you start becoming concerned that they may not
be acting as directors but instead as trade union reps?
I mean, I don't think we should make too much of this.
I don't think that is a major issue. I think one of the
challenges that this role has, it's exactly what
69
described it, is an additional matter?
Itis an additional matter, but I think the primary
matter that is being discussed in this email is, and was
from my perspective, how do we bring some stability and
cohesion to the Board, given we'd lost the Chairman and
we had two main Board Directors who were
disenfranchised? Less about what they were
disenfranchised with and more about the personal
circumstances they were in.
It was my interpretation of what was going on and
what I wanted to try to create was an environment where
we had got a sense of collegiality and a sense of
stability at a Board level. It was quite apparent that
this was causing a disquiet, amongst the organisation,
it was being played out in public, and it was, as
I think I mentioned before, pretty unedifying and
unhelpful for the direction of business.
At this time the Post Office was putting at a public
message that it was putting subpostmasters at the heart
of its business, including by having Subpostmaster NEDs
on the Board, wasn't it?
I don't think it was necessarily at this particular
moment doing that. I think postmasters had been on the
Board for almost three years before to this -- prior to
this particular situation. So I'm not sure that's
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I experienced, that Nisa was trying to get that balance
between representing postmasters, as I've mentioned, and
actually fulfilling a role as a director. It's
an ongoing issue, an ongoing challenge and very
difficult, in fact virtually impossible, to draw a line
between the two, and I think it requires very sensitive
navigation from them, very sensitive navigation from
other Board members and, indeed, obviously, from me, in
terms of making sure that we get the best from the
Postmaster Non-Executive Directors.
What did you understand to mean by "trying to find a way
through the Project Pineapple memo"?
My understanding of that, and what was on my mind at the
time, was we'd just lost our Chairman in very difficult
circumstances. I think the -- I think everybody was.
acutely conscious of the manner of Henry's departure,
and the publicity that was associated with that. We had
two Non-Executive Directors who were concerned about the
exposure of the Project Pineapple email.
I think before that, they were concerned about the
conduct of three member of the General Executive?
They were.
That was the substance of their concern?
That was the substance.
The inadvertent disclosure of the email, as you
70
necessarily a fair characterisation.
To what extent were the Board, including the
Non-Executive Directors, updated on the contact that you
and other members of the Executive were having with the
shareholder?
I report back on the detail of the shareholder meeting,
and when there are specific issues that emerge,
l invariably take my Corporate Affairs Director with me
to these meetings on a monthly basis and notes of those
meetings are then shared with either the Chairman or
indeed with the entire Board, depending on the content
that is required.
So that would happen after each of the ministerial
meetings and, of course, I would refer to the
ministerial meetings in my CEO reports to the Board, of
which many have been displayed.
You'll remember that one of Grant Thornton's criticisms
was the extent to which the shareholder's input was
diving decision making and performance of Post Office?
Yes.
So to what extent were the Board, including the
Non-Executive Directors, sighted on exchanges such as
this?
On the sort of mechanics of what is going on in here,
probably less about the mechanics. If there are things
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that are matters of substance then, of course, those are
issues that we would share with the Board.
Q. Did you share the view that Ms Gratton expressed that
the Subpostmaster NEDs were not operating in a way
appropriate for the business?
Did I share that with?
Did you share that view?
Oh, sorry, did I share that view?
Yes, did you hold that view?
No, I think my experience of the Postmaster NEDs is
that, you know, they are naturally challenging,
challenging of me and I'm open to that challenge.
Q. Mr Ismail has given evidence to us that he believed,
after the departure of Mr Staunton, that responsibility
to heal the rifts in the Board after Project Pineapple
was placed upon the two Subpostmaster Executives; Is
that correct?
PppPropr
A. I don't think explicitly that was necessarily the case.
I think clearly, as main Board Directors, they have
an opportunity to engage with members of the Group
Executive and, by definition, you know, I think they
share some responsibility to try to move that agenda
forward. I don't think it's necessary that the Chairman
has to do it, or that the SID has to do it. I think
everybody has a responsibility to try to ensure that we
73
surrounding Henry's departure clearly didn't help.
Q. Thank you. Can we move to a new topic --
SIR WYN WILLIAMS: Before we do, Mr Beer, just to clear my
mind.
I think you were present when Ms Scarrabelotti gave
evidence, yes?
A. I was, sir.
‘SIR WYN WILLIAMS: In relation to Postmaster Non-Executive
Directors, she was asked some questions about that.
A. Yes.
SIR WYN WILLIAMS: I I'm not pretending that these were her
words, all right, but she seemed to be suggesting,
I think, that the current serving postmasters had a very
important role to play but perhaps not as members of the
Board? Do you remember her giving that --
A. Yes.
‘SIR WYN WILLIAMS: _ I just wondered what your view of that
was, if you have one?
A. Yes, I do, Sir Wyn. I do believe that they have a role
to play on the Board. I think we were in a situation
with no other operators/retailers on the Board, other
than effectively myself and the two Non-Executive
Directors, and I think it gave reassurance to other
Board members that they had a tactical understanding of
what is going on, on the ground, in that forum, and that
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get a sense of stability and cohesion back on to the
Board. So I don't think it was any one person's
responsibility.
Q. Did you leave it to them, the two Subpostmaster NEDs, to
build bridges with Mr Foat and Mr Richards?
A. Onreflection, I probably did give them too much of
the -- too much of the onus was placed upon them.
I think that's probably a fair reflection. I think at
this time, not unsurprisingly, we were under enormous
amounts of pressure as an organisation, and my
reflection is that I probably could have done more.
Q. It was your actions that, in particular, had left them
exposed to a response or reprisals from those against
whom they made allegations, wasn't it?
A. Well, as we discussed yesterday, it was an inadvertent
mistake, and we've been through the mechanics of how
that mistake occurred. I also expressed my apology to
them within 12 hours of the event occurred. So I don't
think it's fair to characterise it in that way. I think
it was -- as I say, an inadvertent mistake. It was
disappointing that it had occurred, I was keen to make
sure that we moved on and it obviously didn't -- we
obviously didn't move on as quickly as that would
have -- as would have been helpful. But,
notwithstanding that, I think that the scenarios
74
they would challenge me in particular on issues that we
were implementing.
So I think it was a really important part of the
development that we've had over the last three years to
have the Postmaster Non-Executive Directors being in
a position where they could challenge the change that
was being implemented into our business.
‘SIR WYN WILLIAMS: All right, thank you.
Sorry, Mr Beer.
MR BEER: In fact, on that topic, we could go back and look
at BEISO000753.
This was the note of the meeting you held with
Mr Hollinrake and others on 29 February and, if we just
scroll down -- and a bit more, please, stop there --
I left off examining the memo with Lorna Gratton saying:
"They are not in a good place and aren't operating
in a way appropriate for the business”.
You said: "How can they ensure their own
self-interest doesn't cut across their role in
supporting [Post Office] as a business."
Then if we scroll on, please, six paragraphs from
the bottom, eight paragraphs from the bottom, Lorna
Gratton says:
"I don't think postmaster oversight of the Board is
worth it, I think there's good mileage for more
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postmaster input in the retail [side] of the business."
Did you understand it to be her view that having
postmasters on the Board was not worth it but there was
more value in having them have some other input, as it's
called, in retail?
Not quite. I think what we were -- or what was being
described here is the Voice of the Postmaster and the
NFSP, as I recall, were progressive a concept of an
oversight Board that sat above the main Board of the
Post Office, and played a strategic role in shaping the
direction of travel. So I think that is what the
oversight of the Board, which would be populated by
people from the CWU, ministerial colleagues, potentially
postmasters as well. So I think that is what is being
described here by way of postmaster oversight of the
Board.
From a retail perspective, I think what Lorna is
referring to here is, is there a more, I wouldn't say
executive role, but I think is there a role of oversight
within the retail business of the Post Office that the
Postmaster Non-Execs can play, which I think is quite
a complicated concept. You heard Mr Ismail say he did
ten days a month anyway. I was trying to wrestle in my
own mind what a Postmaster Non-Executive Director, with
more role in retail, that then starts to blur, I think,
77
Yes.
-- for postmasters, a summary of the effect of the
Common Issues Judgment on the postmaster contract. I'm
not going to engage in an exercise of comparing what it
said versus the judgment, but instead go straight to the
contract itself, POL00000254.
Can we look please at page 32. This is, would you
agree, one of the key clauses, section 12.
Yes.
“Responsibility for Post Office Limited Stock and Cash",
if we scroll down, please, to 12, "Losses", so
section 12.12:
“The subpostmaster is responsible for all losses
caused through his own negligence, carelessness or
error, and also for all losses caused by the negligence,
carelessness or error of his or her assistants.
Deficiencies due to such losses must be made good
without delay."
I think you'll recognise that there's a change
there --
Yes.
-- from the past contract, in that it introduces the
qualifier negligence, carelessness or error in relation
to assistants --
Yes, that's correct.
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the boundaries of what an executive does and what
a non-executive does. So it is a difficult concept.
I think what Lorna is quite rightly pointing out is,
certainly where the Post Office is now, there is
an opportunity for more input from the broader
postmaster community and I buy that completely and I do
believe that, which is certainly why we have a serving
postmaster as part of the Senior Leadership Team.
I think trying to fashion the role, as described
here, could be complicated, in terms of
accountabilities.
So we shouldn't read this to mean that Ms Gratton's view
as expressed here was that having postmasters on the
board was not worth it?
That's certainly not how I read it, no.
Thank you. I only raise that because it is linked to
the question that the Chairman asked.
Right.
Can we move to the new topic, then, which is the
post-Group Litigation postmaster contract.
Yes.
We have looked at the front page and a bit of it,
section 19, already. The crossreference, no need to
turn it up, is POL00000254, and I think the Post Office
produced a guide, do you remember ~
78
-- rather than an absolute liability --
Correct.
-- for losses caused by assistants.
Then clause 13:
"Subject to clauses 12 and 13A ... the financial
responsibility of the subpostmaster does not cease when
he relinquishes his appointment and he will be required
to make good any losses incurred during his term of
office which may subsequently come to light.”
Then some new clauses, 13A:
"Post Office shall not seek recovery from the
subpostmaster unless and until:
"[1] it has complied with its duties under clause 20
... (or some of them) ...”
We'll look at them in a moment:
"[2] it is established that the shortfall represents
a genuine loss to it; and
"[3] it has carried out a reasonable and fair
investigation as to the cause and reason for the alleged
shortfall and whether it is properly attributed to the
subpostmaster under the terms of this contract.
"Gains
“Surpluses may be withdrawn provided that any
subsequent charge up to the amount withdrawn is made
good immediately."
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Then if we go to 20, "Post Office Duties":
"Post Office shall:
"[1] provide the Horizon system [which is defined]
which shall be reasonably fit for purpose, including any
or adequate error repellency.
[2] provide adequate training and support, through
the provision of training materials, to the
subpostmaster, particularly if and when Post Office
imposes new working practices or systems or requires the
provision of new services.”
Then 3, I'm going to ask some questions about this
in a moment:
"Properly and accurately effect, record, maintain
and keep records of all transactions effected using
Horizon.
"[4] Properly and accurately produce all relevant
records and/or explain all relevant transactions and/or
any alleged or apparent shortfalls attributed to the
Subpostmaster;
"[5] Cooperate in seeking to identify the possible
or likely causes of any apparent or alleged shortfalls
and/or whether or not there was indeed any shortfall at
all;
"[6] ... identify the causes of any apparent or
alleged shortialls, in any event;
81
carelessness or error by a subpostmaster or their staff
approached, in practice?
In practice? In practice, we do a number of things.
Certainly from an investigative point of view or from
a ~ trying to work out whether a discrepancy or a loss
has occurred, we have a completely different approach to
that that we adopted prior to 2019. We have -- as
I mentioned yesterday, we have created a number of
different teams with different responsibilities. That
starts with the network monitoring team, who identify
and look for, and monitor the network on a day-to-day
basis, to identify where there are different issues and
different problems emerging and, indeed, if they are
doing so.
Clearly, we have the Branch Support Team in terms of
the Assurance Team who do the stock and reconciliation
issues, and we have a Support and Reconciliation Team as
well, that is also ring-fenced to help support
postmasters. But I think the most important principle
is that we start from a position of innocence and it is
our objective to help postmasters to understand how, if
and when discrepancies have occurred, how do we work
with them?
And we have a tiered process for doing this. The
Branch Support Centre is clearly the first port of call
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"[7] disclose possible causes of apparent or alleged
shortfalls (and the cause thereof) to the Subpostmaster
candidly, fully and frankly;
[8] make reasonable enquiry, undertake reasonable
analysis and even handed investigation, and give fair
consideration to the facts and information available as
to the possible causes of the appearance of alleged or
apparent shortfalls
9, I'm going to ask some questions about this too:
“communicate, alternatively, not conceal known
problems, bugs or errors in or generated by Horizon that
might have financial (and other resulting) implications
for the Subpostmaster;
"[10] communicate, alternatively, not conceal the
extent to which other subpostmasters of branches are
experiencing problems relating to Horizon and the
generation of discrepancies and alleged shortfalls;
"[11] not conceal from the Subpostmaster Post
Office's ability to alter remotely data or transactions
upon which the calculation of the branch accounts ...
depend; and
"[12] properly, fully and fairly investigate any
alleged or apparent shortfalls.”
So with these additional obligations imposed on Post
Office, how is the question of the negligence,
82
for any postmaster who may or may not have an issue that
might emerge. We have a second line team, which is the
Branch Support and Reconciliation Team, which are there
to aid and support postmasters with more complex issues
and, clearly, we have an IT Team who is and who do go
out to branches very specifically to help postmasters
identify and resolve issues that may or may not be well
understood by those particular postmasters.
So it's a very different approach to the one that we
adopted pre-2019.
In terms of negligence, carelessness or error, for
instance, if a subpostmaster says that the loss arose
because of a lack of training in undertaking this
process, "I admit I pressed these buttons and I admit
that it caused a loss of £500 but that was because the
process I was undertaking, I wasn't properly trained
upon it, and that's what's caused the loss".
Where we --
Is that negligence, carelessness or error?
I haven't personally been in to do investigations of
that nature but I think that the principle that is
important at this stage is where there is a disagreement
between a branch and the Post Office over a discrepancy
or over an issue, we are not -- other than going into
a dispute resolution process, and a further level of
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investigation, and a degree of assurance process -- we
are not enforcing that loss on a postmaster.
And I think that is an important principle at this
stage: we don't think it is appropriate and we are not
enforcing it.
So it’s possibly not answering the specifics of your
question but I think the principle that I'm trying to
describe is that we start with a presumption of
innocence and we also start with the fact that, if we
cannot resolve an issue, we are not imposing a solution
‘on a particular branch.
The evidence from one of the Subpostmaster NEDs was to
the effect that the button on the Horizon keyboard, on
the branch terminal, for paying in was proximate to the
button for paying out --
Yes.
-- and it was therefore easy to press the wrong button.
Is that something that would be classified as postmaster
error and, therefore, something for which they were
responsible, ie pressing the wrong button?
Again, I am not sure I'm able to describe that
specifically but on the principal point you make, we've
obviously spent quite a lot of time looking at the
keyboard itself so that where there are specific issues,
as that you've just described, that are manual issues,
85
Yes, I think that's fair.
At paragraph 20.3 provides that the Post Office will:
"properly and accurately effect, record, maintain,
and keep records of all transactions effected using
Horizon."
Does this mean that a mechanism exists for
monitoring the identification and payment of any
shortfalls by subpostmasters?
Yes, it does.
So is there a mechanism for recording the payment of
shortfalls by subpostmasters?
There is now, yes.
When was that introduced?
Certainly post-2019. I have had discussions with
Melanie Park, who I think you're speaking to next week
and, indeed, around this very topic, which is: is there
a record of all payments that are made by postmasters,
and a reason code and a payment vehicle that it
describes what it is that they are paying for, whilst at
the same time, is there a problem impact database that
describes all the bugs, errors and defects that have
emerged, what we've done about them, whether they've
been fixed, what potential detriment they may or may not
have thrown up and that will be -- that is obviously
a database with which the Branch Support Teams and the
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we have tried to move buttons and change buttons to make
sure that it is more intuitive and easier and less
manual, in terms of some of the mistakes that are being
made.
Does the Post Office provide some sort of guidance,
either to its investigators or to its subpostmasters, as
to what negligence, carelessness or error means, and
what it looks like, in practice?
I don't know whether that is specifically the case. We
do have, online and e-learning tools around the
investigative process, around what we do and why we do
it, and examples of where, you know, issues could or may
emerge.
So sort of case studies of --
Yes. That's --
-- what would and would not fit within this type of
subpostmaster liability?
That's my understanding, yes.
The purpose of asking you those questions, those two
examples that I gave, wasn't to get definitive answers
for use in the future. Would you agree that it's
necessary to have some sort of guidance so that
subpostmasters are clear, beyond the three bare words
themselves, as to in what circumstances they will be
liable for shortfalls and which they may not?
86
Stock and Reconciliation Teams, who do -- Support and
Reconciliation Teams who do engage with postmasters
obviously have access to, so that when postmasters
describe issues that they may be experiencing, we now
have a database of all the issues that have emerged, and
that is certainly -- I think it is since 2019, I could
be wrong, and all the payments and more importantly the
way that reconciliation has occurred in terms of
resolving those issues.
Is that function run and maintained by Fujitsu?
No, that's run and maintained by Melanie Park's
Operation Team in Chesterfield.
Paragraphs 4, 5 and 6, would you agree, taken together,
require the Post Office to identify the reason for
shortfalls, in particular, 6?
Yes, the onus -- as I have stated, the onus is very much
‘on the Post Office to identify where these problems have
occurred, and the onus is very much on the Post Office
to ensure that if there are any fixes that need to be
made that they make them so, yes, I would agree with
that.
That duty, to identify the cause of a shortfall, exists
irrespective of whether the shortfall is settled by the
subpostmaster?
That's correct.
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MR BEER: Thank you.
Sir, it's 12.45 now; could I invite you to break
until 1.45?
SIR WYN WILLIAMS: Yes. Certainly.
MR BEER: Thank you very much.
(12.44 pm)
(The Short Adjournment)
(1.45 pm)
MR BEER: Thank you, sir.
Good afternoon, Mr Read.
A. Good afternoon.
Q. Can we turn to the topic of shareholder priorities,
please. There is no need to turn it up but, in
paragraph 246 of your first witness statement, you say:
"The postmaster sentiment survey showed that
remuneration is the top priority for postmasters.
Despite some increases, it remained a top priority for
many postmasters and the area with the lowest perceived
improvement."
Can we look at a letter that you reference in the
same witness statement, in your paragraph 169, from
Kevin Hollinrake to Mr Staunton, outlining the
shareholder priorities that the Department would like
you to focus on. UKGI00044317. You will see this is
from Mr Hollinrake to Mr Staunton. It's dated 29 June
89
Office, a state-owned business?
A. I think it's one of a number of priorities. I think the
major priority, as you'll probably see from the 23/24
letter to Henry is very much around compensation and
support to the Inquiry. They are clearly priorities,
but your point is correct in that the last four
postmaster surveys we have conducted, remuneration has
been, on each occasion, been the number 1 concern for
current serving postmasters.
Q._ If we go to page 2 of the letter and look at the first
priority:
"Effective financial management and performance,
including management of legal costs, to ensure medium
term viability.”
If you see at the fourth bullet point, this includes
maintaining "stringent cost control" and maintaining
a “clear focus on value for money and efficient
delivery, across the cost base, including", and then
some subpoints.
Would you agree that effective financial management
and performance, including stringent cost control, is in
conflict with the fair remuneration of postmasters?
A. Potentially.
Q. So not only is the fair remuneration of subpostmasters
not listed as a priority, a priority that is listed is
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2023 and contains the strategic priorities for 2023 to
2024.
I suspect you're familiar with this letter, are you?
Yes, I am.
I don't want to spend time scrolling through it, but
would you agree that postmaster remuneration,
ie ensuring that today's postmasters are able to make
a living, and the viability of the network as
a consequence, are not included in the list of
properties set out by the Government?
Yes.
Do you know why?
I assume it's because they take that as given, as that
being the core element of the job.
You've said that remuneration is, according to the
postmaster sentiment survey, the top priority for
postmasters. It's not listed as any priority by the
Government.
That's correct.
Aside from what is formally written down by the
Government, in your interactions with the Department,
with UKGI and with ministers, would you say it is
a priority for the Government to ensure that
subpostmasters are remunerated fairly and are able to
make a living through their partnership with the Post
90
potentially in conflict with it?
Yes, I think that's fair to say.
You tell us in your witness statement, paragraph 273 --
no need to turn it up -- that you have:
"... committed that Post Office will work towards
sharing 50 per cent of branch generated revenue with
postmasters which represents a significant change to
their remuneration and, in the last financial year, the
Post Office achieved 45.6 per cent, and would continue
to drive the fixed upwards."
Would you agree that if branch generated income is
low, then the amount available to be shared with
subpostmasters is low?
That's one part of the equation. The other part of the
equation is the central costs associated with running
the Post Office which, obviously, if we reduced those
central costs then the proportion of revenue that's
available to be distributed increases.
Would you agree that the Government and Post Office is
not doing enough to ensure that branches can offer
sufficient services to ensure sufficient
branch-generated income?
I think we're trying hard to do that but that comes to
the core of the purpose of the Post Office, which, you
know, ultimately -- and we've discussed this over the
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last couple of weeks in this forum -- is getting clear
‘on what the purpose, the vision and the strategy of the
Post Office is: is it about generating new sources of
income and, indeed, what are those new sources of
income; is it about market failure and, from
a Government perspective, being clear what market
failure the Post Office is there to address; or is it
about looking for new avenues?
And that's very much what we have tried to do, which
I said in my personal statement quite extensively, about
the plans that we've had to drive the four key
activities that the Post Office is engaged in, mails and
parcels, cash and banking, what we're doing with our
travel business and how we're driving our platform
products as well, which is where we're looking for new
commercial opportunities for postmasters to --
ultimately to drive their revenue.
A member survey by the National Federation found that
70 per cent of postmasters who responded to the survey
were taking home personal drawings of less than the
national minimum wage, at that time £8.91 an hour.
Would you agree that it is shocking that the Post Office
and their sole shareholder, the Government, would allow
the remuneration of postmasters to fall to such a low
level and then not make it a priority to rectify it?
93
dated 16 April 2018. Have they been updated since then?
Not as far as I'm aware.
Can you tell us what the entrustment requirements are,
please -- I mean, not a list of what they are but,
generically, what do you understand the entrustment
requirements to be?
This is the services of general economic interest in
terms of what it is that we are expected to provide by
way of running the Post Office.
If we scroll down, please, and keep going. The last
sentence on the top of the previous page:
"That network must meet the following minimum access
requirements ..."
That's correct, yes, the SGEls, yes.
The first:
"Nationally, 99% of the UK population to be within
3 miles and 90% of the population to be within 1 mile of
their nearest post office outlet.
"[Secondly] 99% of the total population in deprived
urban area across the UK to be within 1 mile of their
nearest post office outlet.
"95% of the total urban population across the UK to
be within 1 mile of their nearest post office outlet.
"[Fourthly] 95% of the total rural population across
the UK to be within 3 miles of their nearest post office
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It hasn't appeared, as you say, in the shareholder's
letter to the Chairman. However, it's a clear priority
for the organisation. I think we spend a great deal of
time focused on how do we generate more revenue for the
existing postmaster population. By way of example,
I think in the first year, in 1920 (sic), we increased
postmaster remuneration by 10 per cent. The following
year by 7 per cent, and the subsequent two years, we've
obviously not been as successful as we were in those
first two years, it's tended to be inflation led.
What we've done, particularly with the mails and
parcels element of the revenue that is generated by
postmasters, is to link that to CPI, so that at least it
increases every single year by the same -- well, by CPI
so some 65 per cent of all the mails and parcels
products that we sell.
But your point is well made, which is there is more
to do to take cost out of the business and there is more
to do to address the underlying operating model that
allows postmasters to simplify their relationship with
Post Office and obviously simplify what it is they are
doing.
Can we look at the entrustment requirements set by
Government. POL00027887. You'll see that these are
contained in a letter addressed to your predecessor,
94
outlet."
Then:
"In addition, the following criterion will apply at
the level of each and every individual postcode district
"95% of the population of the postcode district to
be within 6 miles of their nearest post office outlet."
Then:
"Post Office is required to provide this network of
post office branches to make available the services of
general economic interest detailed in annex A ..."
Do you agree that these are requirements are those
that currently exist in relation to the post office?
Yes, they do.
Do you agree they impose upon the Post Office
an obligation to public service?
Yes, they do.
But do you agree they impose an obligation on Post
Office to public service that impacts upon the
profitability of Post Office as a business?
Undoubtedly.
Would you agree that the public service requirements, as
I'm going to call them, tend to fall more heavily on
smaller branches with a lower footfall in areas of lower
population density --
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Largely, yes, that's fair.
-- or lower income areas, which mean that branches in
such areas are less profitable than branches typically
are in wealthy urban districts?
I think that's fair.
Can you also confirm the branches that bear the greater
weight of these public service obligations tend not to
be those run by what I think are called strategic
partners, ie Co-op, WHSmiths and similar?
That's correct.
Does the Post Office have an enduring commitment from
Government to maintain public service duties of the Post
Office into perpetuity?
I don't think we've had a long commitment to do that.
The expectation is that we will fulfil the SGEls and, on
a yearly basis, that's exactly what these are. The
policy, or the entrustment, as set out hasn't changed
since 2010 and we are, and have been, in discussion
since 2021 with the Government around a policy review
for the Post Office, and that is not something that has
yet come to fruition but it is something that we have
been very keen to encourage the shareholder to take part
in or, in fact, to lead.
The point being is that the market has changed
dramatically since 2010. I mean, not least we've had
97
that -- this particular letter that we've just read
implies.
Can you assist us: in practice, how do branches in low
population density or deprived areas, as compared to
branches in higher population density or wealthier
areas, receive, if they do, appropriately weighted
compensation for delivery of the public service
requirements?
Yes, I can. So we receive a subsidy from the Government
for the provision of services in areas where, to your
point, it may not be economically possible to run
abranch. We have some 1,300 SPSO branches, which are
traditional legacy branches, which tend to operate, as
you quite rightly point out, in rural, or isolated, or
inner urban areas, that may not have the level of
economic activity that -- or footfall indeed, that you
would expect.
That subsidy, to the tune of £50 million, has been
static since 2018, in terms of its funding. I think it
was 210 million a year, back in 2012/2013, at the time
of separation. It is, as I say, and has been, static
for the last six years at 50 million but, to my earlier
observation, the changing shape of the landscape and the
changing shape of footfall on the high street has meant
that, in essence, costs have increased while the subsidy
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separation of Royal Mail from the Post Office, we've had
the right of digitisation, we've had the growth in
e-commerce and we've had a massive change in consumer
behaviours and habits and there is a reason why the high
street is closing at the speed with which it is closing,
there is a reason why 5,000 banks have closed since
2015. The face-to-face delivery of services has
changed, which therefore makes the question around --
the question that needs to be answered -- very, very
clear as to the long-term purpose and vision of the Post
Office and, by that, I mean long-term.
We describe here in the -- or in the letter that
you've just shown us the strategic priorities for the
Post Office. My personal view is strategic priorities
aren't for a year; strategic priorities imply five to
ten years, at least in terms of vision. So they're
tactical priorities, as opposed to strategic priorities.
What the Post Office is in need of, and certainly
the work that the incoming Chair has initiated with
Teneo from its strategic -- in its strategic review, is
a joined-up vision between the Post Office and the
shareholder for the long-term future of the Post Office,
and by that I mean five to ten years minimum, such that
we can start to plan more strategically, as opposed to
tactically, which is very much the nature of the letters
98
has remained static but, in real terms, lost value. So
there is a mismatch between those two.
Is the subsidy distributed to post offices by reference
to the extent to which the public service requirements
are disproportionately borne by then, ie --
Yes, I understand. Yes. It tends to be footfall/
transaction driven, in terms of how we support -- with
fixed payments to specific branches.
I think it's right that in the summer of this year,
Grant Thornton delivered an important report for the
Post Office?
One of many, yes.
Yes. Let's look at the report to make sure we're --
I was going to say —-
-- looking at the same one. POL00446476. This one
concerned the effectiveness of the Board.
Yes.
It's dated 19 June 2024. Can you explain, please,
firstly, the circumstances in which Grant Thornton came
to be commissioned to undertake this review and write
this report?
Yes, I can. I think Rachel Scarrabelotti mentioned this
last week. In effect, the sort of business code
suggests that you should have a Board Effectiveness
Review on a yearly basis and I think every three years
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the effectiveness review should be done and conducted by
an external party, and Grant Thornton were commissioned
to do the external review.
Thank you. If we go over the page, you'll see the
partner at Grant Thornton delivering the report. If we
scroll forwards, please, an idea of the length of the
thing. Then forwards, please. If we can perhaps skip
to page 8, I think this is the first part of substance
to the report that we will find. It's an executive
summary or key findings section. Under "Overview", the
first key finding was:
“Lack of clarity on the purpose of the Board, with
the Shareholder relationship inhibiting the Board's
effectiveness due to perceived interference in [Post
Office's] work and limited visibility around the
longer-term funding and objectives of the organisation.”
Was that a finding with which you agreed?
Yes, it was, and I would say that the findings did get
Board endorsement.
There's three parts to it. Firstly, a lack of clarity
on the purpose of the Board; what does that mean?
I think perhaps the way I would describe it is that,
given that there is ambiguity over the strategy, purpose
and vision of the Post Office, it is quite difficult to
ensure that the level of governance that is supporting
101
made around the control of the shareholder without
consequence or without accountability and the general
influence that the shareholder has over the direction of
the business.
You'll also notice, certainly in my first witness
statement, I made reference to some of the Non-Executive
Directors who'd left after a single term, feeling that
independence has and was eroded, if that's the right
word, by the -- well, by the obligations and by the
constraints that are part of being a publicly-owned
organisation.
The third element is limited visibility around the
longer term funding and objectives of the organisation;
was this essentially recording that the Post Office
needed to know whether it had the backing of its owner
long term?
Yes.
Why did it take the expense of an outside organisation
to report to be able to state the fairly obvious truth
that the Post Office needs to know whether it has the
backing of its owner long term?
I think, as Alisdair Cameron said a couple of weeks ago,
this has been a constant struggle for members of the
Board. This isn't something that has sort of emerged
relatively in the near term. When it comes to funding,
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that misaligned strategy, if that's the right word, is
quite difficult to articulate. And I think what the
Board have struggled with in terms of governance
challenges is, without real clarity about the purpose
and direction of the Post Office long term it's quite
difficult to establish the right levels of governance,
and I think that's the clarity issue that's being
described here, and the reference being made to what the
Board has wrestled with.
The shareholder relationship inhibiting the Board's
effectiveness due to perceived interference; in what way
did the Government inhibit your Board's effectiveness by
interfering in your work?
I think it's more the lack of clarity over matters that
are for the Board and matters that are for the
shareholder. There are certain areas in which the
shareholder has and takes a particular standpoint and
view. I think it would be obvious to point out that we
have a single source of funding, which is the
Government, and we are therefore completely and utterly
reliant on our funding from the Government, and this, by
definition, causes challenges, certainly from
a strategic point of view.
You will have seen in the verbatims associated with
this particular report that there are many observations
102
in particular, that is a challenge for the business.
I think we are subject to spending reviews, Government
spending reviews, which could be one, two or even three
years in duration. There are many issues associated
with determining how funding is derived. I will use
a similar analogy or similar example to the one that Al
used, which was the 21/22 funding round, where the Post
Office identified a need for £450 million, which was
a combination of subsidy and investment, and we were
offered 202 million and, eventually, after five months
of toing and froing, the Government gave us 335 million,
which was still obviously 80 million less than had been
asked for.
That has happened at each of the funding rounds that
the business have had and that obviously makes the idea
of long-term planning very difficult. Funding is
obviously driven by budget, rather than by need, and
I think, again, a long-term strategy, with an underlying
funding model to support that, is what I think is
required and, clearly, that's one of the outputs, I'm
sure, that Teneo will be discussing with the Government
over the next two or three weeks when the final Teneo
review is put forward.
I'm going to come to Teneo in a moment.
Right.
104
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Would you agree that the confirmation of the
Government's commitment to Post Office's public service
and the number and spread of branches must be a basic
requirement for the continuation of the Post Office as
an institution?
My sense is that the policy review that is required by
the Government, 15 years since its last policy review,
should look at all elements of the public sector service
that is provided by the Post Office, and be very clear
on what it is that it is expecting the Post Office to
deliver.
Clearly, at present, we have a fairly uncodified
social contract. Yes, you described the service of
general economic interest and the entrustment elements
of it, but I think it's broader than that and it's wider
than that. When you look at the role that postmasters
play in communities up and down the country, when you
look at the trust at a local level between consumers and
customers, the communities and their postmasters, it is
quite extraordinary.
And when you look at the social value associated
with that commitment from postmasters, it is that that
I think needs to be more heavily examined in terms of
the contribution that is being made by postmasters and
how the Government sees, over the next 5, 10, 15 years,
105
up - that the issues that you identified with the
culture within the Post Office included, from the
outset, a perception that "the organisation had lost
sight of the postmasters".
Is the failure by the Government to ensure the
future of the Post Office and a commitment to its social
purpose and consequential funding another example of
such a cultural behaviour?
Yes, I think that's fair.
Would you accept that the very same issues of obtaining
decisions and support from Government have also affected
and afflicted the compensation, redress and financial
restitution?
No, I don't think that's fair to say that. My sense is,
and I think from a DBT perspective, not unsurprisingly,
a great deal of focus has been on redress, certainly in
the five years that I've been in the organisation, and
perhaps less time has been spent on developing the Post
Office of today for tomorrow. And I think that the
Government would -- and officials in DBT, would
recognise that that is the case. It is complicated to
manage both but I think it is important, certainly for
today's Post Office, that there is more clarity.
You tell us in your first witness statement -- no need
to turn it up, it's page 22, paragraph 38 -- that:
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that continuing to evolve but, more importantly, that
postmasters are recognised for that contribution, which
they currently aren't.
How is it possible that these questions -- the long-term
backing of the owner, the continuation of the social
purpose commitment -- have not been answered for the
future?
I think that's a question you'll need to discuss with
the Government. As I say, we've been keen to have
a policy review for some time. We make this desire very
clear to Government: that this is what we are expecting
and what we need because there is, as I said,
a determination to have a unified purpose, a unified
vision and a long-term strategy from the Post Office,
from which everything else should flow.
Do you agree that, in the meantime, the continuation of
the Post Office, coupled with the support of Government,
goes hand in hand with the projected life of Post Office
branches and, consequentially, the individual
investment, mortgages and family financial decision
making that has to be undertaken by postmasters on
a daily basis?
Yes, I do.
You tell us in your third witness statement -- it's
paragraphs 31 to 46, but there's no need to turn them
106
"The external strategic review that the Post Office
is undertaking led by Teneo will be complementary to the
work being undertaken by the Department, as it intends
to set out a future model for the Post Office to deliver
sustainably against the stakeholder requirements."
You add that that review was expected to conclude in
September 2024, the month just gone. What's the current
position?
The current position: two years ago, the Department
invited, as it happens, Grant Thornton, again, to do
an initial strategic review of the Post Office, and
I think that that was primarily associated with the sort
of commercial long-term future of the Post Office.
The output of that piece of work was a second
review, which I understand is what is ongoing at the
moment, again, commissioned by DBT. I've not had sight
or visibility of the scope or of the content of that
review, or indeed of its findings, and, clearly, from my
perspective, it's quite important that we are included
in that piece of work.
I hope that, and am reassured, certainly by the
current Chair, that he has had those conversations with
the incoming administration, whereby we can dovetail the
Teneo Strategic Review and the independent work
conducted by the Department to ensure that the output is
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something consistent and something that everybody can
buy into.
Can we look at the scope of the review, POL00448624.
Can we look at page 109, please. This was a Board paper
and an update for the Board on the Strategic Review.
It's dated 4 June 2024. If we can go to the next page,
110, please, we see the scope of the review but, by way
of background first:
"Post Office has invited Teneo to carry out
a comprehensive Strategic Review of the business and
develop a clear plan for the future."
Then the equivalent passage on the right-hand side:
"Teneo will undertake a through review of the Post
Office to understand its current position, clarify its
core objectives, identify opportunities and risks,
prioritise initiatives and develop a clear [path] to
realise the chosen strategy.”
Then a plan. Then if we go over the page:
"We aim to address a range of key questions for the
Post Office to develop a clear plan for the business
cover the next five years.”
One of them on the far right is "Stakeholder
Management":
"How do we ensure stakeholder support for the
strategy?
109
businesses, with large logistics players, with other
retailers, or is it there to fulfil a particular social
purpose for the isolated, for the elderly, for
Government services, in terms of providing some form of
Government service around benefits and the like?
I think it's a pretty fundamental question that the
Government needs to ask and, with that and from that,
flow many of the issues that are on this single slide.
My recollection was that this is Teneo's first
engagement with the Board and this was their sort of
first initial starter for ten. Things have evolved
since then from a scope perspective, in terms of how
they go about doing that piece of work and ...
Why has it taken five years since the judgments of the
High Court for the Post Office to consider these most
basic of propositions, given the scrutiny given over to
the Post Office in those judgments?
I don't think that's necessarily how I would
characterise it. We conducted, when I first started at
the Post Office -- which I say from my evidence -- a not
dissimilar review to this particular one with McKinsey
which looked at the purpose and looked at the strategy
and looked at the vision of the Post Office.
Clearly, in the following five years an enormous
amount has changed, not just consumer behaviour as
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"How do we ensure that subpostmasters' interests are
properly reflected?
"Is the current ownership structure appropriate?
"What is the most appropriate funding model?"
Left-hand side, "Reputation, Trust & Brand":
"How is the Post Office viewed in the wake of the
Horizon scandal?
"What actions must be taken to restore public
confidence?
"What do stakeholders want to see from the Post
Office (eg make money vs serve the community)?
"Does the Post Office's purpose and vision need to
evolve to balance societal vs economic benefits?”
Some of these questions are, would you agree, rather
fundamental but also rather basic, ie "What do
stakeholders want to see from the Post Office (ie make
money vs serve the community?" How is it that question
needs to be asked and answered now?
Well, I think the long-term purpose of the Post Office
is pretty critical. I think we've got to understand and
ask ourselves what is the purpose of the Post Office,
what is it for, and, alongside that, will go questions
of ownership, in terms of where does it sit? So is it
designed as a commercial entity that is competing in
markets with the banks, with financial services
110
a consequence of Covid, not just some of the issues
associated with the cost of living crisis, but also the
revelations of some of the practices that we have been
uncovering in the Inquiry, and so I think strategy is
always dynamic, there are always things occurring.
I think, probably, the last five years in the Post
Office's history have been more dynamic than any other
time in recent memory, and I think that's something that
needs to be build into the particular strategic review
that has been triggered by the arrival of the new Chair.
I think it also needs to be brought -- there is
a natural time frame for this exercise. First and
foremost, the Inquiry will come up with its set of
recommendations, following the four years that it's been
engaged looking at what is gong on in Post Office; there
is a new administration, in terms of the Labour
Government, and therefore there will be a shift and
change in its perspective on what the future of the Post
Office may look like; and, at the same time, we are
producing our own internal strategic review.
And I think, bringing together all of these
elements, it's a very natural time for the organisation
to take stock and to, I hope, find real clarity about
the purpose, the vision and the long-term strategy for
the Post Office.
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In the meantime, how can subpostmasters and their small
to medium businesses possibly make plans when the Post
Office itself and the Government are asking such
fundamental questions as these, looking around for ideas
and answers?
I think it's a very reasonable question in the sense
that this will have been an extremely difficult time for
postmasters and -- and for post offices more broadly,
not just because of the changing shape of the macro
conditions in which they operate, which you've just
described, but also as a consequence of the fact that we
need to get much, much clearer on what the long-term
future looks like.
When I go into branches, and have done over the last
six to eight months, the questions that postmasters put
to me most explicitly are around: what are we doing for
remuneration; what are we doing by way of innovation, in
terms of what other products and services can we sell
and can we deliver from our post offices; but then the
sort of third and fourth questions are what is happening
to the brand as a consequence of this scandal; and, more
importantly, what is happening to my long-term
investment in a post office?
I'd say they were the four top questions that are
asked of me when I go into post offices today.
113,
Only 35 per cent of them reported that they had
confidence in their senior leadership in the 2024 Post
Office Colleague Engagement Survey, and you tell us that
that has fallen 5 per cent since the 2023 survey and
4 per cent since the 2022 survey. That's in
paragraph 252 of your first witness statement.
Are postmasters included in the Colleague Engagement
Survey?
We do a dedicated survey for postmasters, which is
a postmaster survey, and we do an internal survey for
those people who are --
So the survey that I'm talking about, the Colleague
Engagement Survey, that's for Post Office employees?
That's for the employees, correct.
Given the initiatives that you've told us about
throughout your four witness statements, why is it that
the confidence in senior leadership within the Post
Office is falling?
I think there are a number of reasons for that. I don't
think it'll come as a great surprise that the survey
itself was conducted, I think, in February and March, at
the time of Henry's departure from the business, and the
enormous focus that was provided by that, in terms of
the perceived dysfunctional nature, I guess, of the
Board and, to a degree, of the Group Executive, and
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I hope that we can answer those in the next few
weeks, as we go through the Strategic Review. I think
that is going to be a really very important part of
providing confidence to postmasters about the long-term
direction of the business. Will we answer all the
questions? I doubt it. But I think we will be able to
give people much greater clarity on what the next five
to ten years look like and I hope that, from
a governmental point of view, we can look at the funding
model to make sure that it is reflective of a five to
ten-year strategy rather than a one to two-year tactical
engagement.
Put bluntly, who would buy a post office under these
conditions?
Strangely, now you say it, we don't see the level of
churn that you would expect. Had you asked that
question to both Saf and Elliot two weeks ago, you would
have found that they are both looking for additional
post offices. There is and there are a number of
individuals who are keen to buy post offices. So
I think -- you know, I don't think it's quite as stark
as you are perhaps suggesting. As I say, there are
entrepreneurial postmasters who are still keen to run
a post office and, you know, I think people should take
confidence in that.
114
I think that has had a profound impact on colleagues and
senior team members.
It obviously occurred after the four-part
dramatisation, literally a few weeks after that and, of
course, the subsequent and quite rightly media outrage
and consumer outrage at what had happened historically
within the Post Office. And I think these are important
elements to factor into the sentiment of colleagues,
whose pride, clearly, has been, not unsurprisingly,
hugely damaged and whose confidence, having seen a level
of dysfunction as perceived in the media, rather than it
being conveyed to colleagues through normal internal
channels, was obviously being seen in the media. And
I think that put a big dent in the confidence that
colleagues had in senior leadership.
Would you agree that the fall in confidence in the
Senior Leadership Team could, in part, be due to the
high turnover of senior leadership, perhaps giving the
impression of a rudderless ship?
In part, I think high turnover has been a feature of the
Post Office for many, many years. It's a difficult
place to work, it's a difficult place to achieve success
and I think, at the moment, it's probably at its most
difficult, given the overarching implication of the
scandal, as well. So, yes, I think that's certainly
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something that is a major factor, is -- and, as
I mentioned before the lunch break, the importance of
stability at a Board and Group Executive level and the
importance of stability and confidence in the
individuals who are occupying those roles, is paramount
to the long-term success of the business, and that's
something that I think is needed and needed urgently.
Do you think it could, in part, be due to the revelation
of a scandal, upon a scandal, being the awarding of
bonuses to senior Post Office leadership in relation, in
particular, to an Inquiry-based metric?
I think the challenges in the business certainly stem
back to that particular period. There's no question
that the Transformation Incentive Scheme and the bonus
metric associated with it, and the perception that the
organisation was blind or deaf to what was occurring
within the scandal, certainly will have dented people's
confidence for sure.
Would you agree that the dent or diminution in senior
leadership's confidence could, in part, be due to the
allegations of bullying and sexism made against
individuals in senior leadership positions, including,
in fact, yourself and Mr Staunton?
Yes, I guess that's probably fair, that that image that
will have been conveyed by those allegations will, of
117
last four years, that is materially different from where
the Post Office has been historically, notwithstanding
the perhaps heavy-handed way in which Elliot had been
treated.
In the light of these issues, and each of them, what
confidence should the Inquiry have that the Post Office
has or will put in place a Senior Leadership Team that
deserves the confidence of Post Office employees,
postmasters and the public?
I think the energy and enthusiasm and drive of the new
Chair should give the Inquiry great confidence that
Nigel will ensure that: (a) the Strategic Review is
conducted in the right way; (b) that the Board and its
colleagues will be aligned behind that Strategic Review
and that subsequently we will have a Strategic Executive
Group and Senior Leadership Team that will support what
we're trying to do.
So I feel confident that that will happen. I think
we have a number of capable -- and very capable
executives who have joined the business reasonably
recently, and I think the Board, as well, is -- and
I mentioned it before sort of six months ago -- the need
for sort of stabilisation. I think Nigel has brought
that to the organisation and to the Board. So, yes,
I do have confidence that the wheels are in motion to
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course, have had an impact on colleagues. However, in
defence of that, I would say that a degree of confidence
will have been taken by colleagues that no one is above
the law in the Post Office, and those whistleblowing
allegations that were made against me, as an example,
were followed through with a fairly comprehensive
investigation. None of the allegations, I may hasten to
at, were upheld but, by definition, colleagues will have
taken confidence that it was possible to investigate the
Chief Executive and the Chairman, irrespective of what
else was going on in the organisation and, more
importantly, that those investigations went through to
their natural conclusions.
Would you agree that the diminution in the confidence in
the senior leadership of the organisation could, in
part, be due to postmasters, including Elliot Jacobs,
a Board member, facing a harsh and non-transparent
investigation, suggesting to subpostmasters that perhaps
nothing has changed since the GLO?
I don't think that particular isolated incident of
Elliot, disappointing though it was -- and as I said
yesterday, I don't think it was conducted in the way
that I certainly would have wanted, I think. But I also
do believe that when you look in the round at the way
that we have changed to support postmasters over the
118
ensure that the business can come through this very,
very difficult period and, you know, emerge stronger.
In your first witness statement at paragraph 214 --
perhaps we'd better have it up on the screen,
WITN00760100, page 105, please. Paragraph 214, you tell
us that:
"In April 2021, Post Office launched a behavioural
framework called ‘Ways of Working’ (‘WOW’) to replace
the Post Office's previous values and strategic pillars
of: Care, Challenge and Commit. [Ways of Working] was
intended to describe ‘how an individual should act in
Post Office, to define behaviours that were expected of
all Post Office personnel when interacting internally
and externally with both Post Office colleagues and with
postmasters.”
You tell us in paragraph 220 on page 107:
"The Colleague Engagement Survey ... asks colleagues
‘whether they see the Ways of Working demonstrated
across the business’. In 2021 this was 41%, in 2022,
50%, in 2023, 58%, in 2024, 53%. Colleagues were also
asked to indicate their agreement to the following
statement: 'Where I work people are held accountable for
their performance and behaviours'."
In 2022, 38 per cent agreed; '23, 59 per cent; and
in'24, 63 per cent.
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Are postmasters included in this survey?
A. No, notin this survey.
Q. As they're not included, how can the Post Office measure
whether the Ways of Working are being demonstrated in
interactions with subpostmasters?
A. We have a separate postmaster survey, which gives the
opportunity for all postmasters to take part. That
happens at a very similar time, and we also then do
a pulse survey every six months with postmasters, just
to check on whether or not we are making progress on the
commitments that we made following that survey.
I think it's quite important just to touch on the
postmaster survey. It is conducted usually in February
and March with results in April, and that tends to
provide me with the opportunity to speak to the
postmasters at our annual postmaster conference, where
we will share the results of the survey itself. We will
post those results on to Branch Hub and by email to all
postmasters, and we'll then have a series of workshops
which postmasters are invited to, and they can take part
in if they want to, which allows us to work through the
results themselves, so that postmasters can bring to
life for the team what it is that is being said, and
interpret the surveys themselves, so that we can then
build an action plan.
121
that.
SIR WYN WILLIAMS: Right, so I've got that right.
A. Yeah.
‘SIR WYN WILLIAMS: That has either gone, or is imminently
going to, Government for their, in inverted commas,
"approval",
A. That's correct.
‘SIR WYN WILLIAMS: But am I also right in thinking that at
the same time, the Government has been working on their
‘own strategic --
A. That is correct.
‘SIR WYN WILLIAMS: Has there been any crossover between
those two keys of work?
A. There has been interaction between the Teneo team and
DBT, as I understand it.
SIR WYN WILLIAMS: = Right. I did get it right at least.
MR BEER: Can you tell us what "interaction" means?
A. That's a good question. The -- as I understand it,
Teneo have obviously got a number and a range-off
stakeholders that they've engaged with and clearly DBT
is one of those, and my understanding is that Teneo and
DBT have discussed the specific piece of work, the
specific policy work that DBT Phase 2 have initiated,
and we obviously want to make sure that these pieces of
work come together.
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And then, towards the middle of the autumn, and
it'll be sometime this month, I think -- yes, it'll be
sometime this month or maybe early in November -- we
will have a pre-Christmas conference where we will
present the results of the pulse survey but also the
action plans associated with the survey that was
conducting in March, and people can hold us to account
for whether or not they've seen any improvement or any
change in, or indeed whether or not the commitments that
we've made and the action plans that we've promised,
we've actually made any progress at all.
So there is a difference between the two surveys,
clearly there are different things to measure, and
different things to gain and get feedback on.
MR BEER: Thank you, Mr Read.
Sir, can we take the afternoon break now.
SIR WYN WILLIAMS: Yes, we can but can I just clarify one
thing that I want to be sure I've got the right end of
the stick. My understanding of Mr Railton's evidence
was that, as a consequence, at least in part of the
Teneo work, a strategic plan had now been formulated at
Post Office; is that correct?
A. The final version of the strategic plan has been
completed by Teneo and the main Board have signed it
off, in the sense that they agree with the findings of
122
There's absolutely no point in doing a Strategic
Review of the Post Office internally, if the shareholder
is off doing its own piece of work and never the two
should meet. That would be a very unfortunate outcome.
‘SIR WYN WILLIAMS: I love the way we use the word "The
Inquiry" but I'm thinking a bit more personally because
I'm the one who is supposed to make these
recommendations and, if we have a state of affairs where
the Post Office has got Plan A, shall we say, and the
Government has got Plan B, I think it's a bit optimistic
to think that Wyn Williams can produce the all-embracing
Plan C.
But, anyway, there we are. Let's have a break.
MR BEER: Sir, the plan is to break until 3.00 and then
we'll switch to Core Participant questions. I haven't
finished by questions yet.
‘SIR WYN WILLIAMS: No, no, I understand that.
MR BEER: Because I think you know, and some of the Core
Participants know, that Mr Henry can't be here tomorrow.
SIR WYN WILLIAMS: No, no, that's fine by me.
MR BEER: He is going to ask questions between 3.00 and
4.00.
(2.45 pm)
(A short break)
(3.03 pm)
124
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Questioned by MR HENRY
‘SIR WYN WILLIAMS: Mr Henry.
MR HENRY: = Thank you, sir.
A
a
oP
prop,
Good afternoon, Mr Read.
Good afternoon.
Together with Ms Page, I represent a small cohort of
broken people who are yearning for justice, hoping
against bitter disappointment that they can move on and
find some resolution, and I'm sure you understand that.
Ido.
You would accept, would you not, that the wrongful
prosecution of the subpostmasters is an atrocious
chapter in the Post Office's history?
Unquestionably.
Convictions were procured, it seems, on a fraudulent
basis --
Yes.
-- material non-disclosure?
That's correct.
Of course, even if subpostmasters weren't prosecuted,
there was a culture of prejudice that then existed,
a rush to judgement or a default setting that Horizon
was never at fault, that the shortfalls were always in
some way connected to the stupidity or incompetence of
the subpostmaster?
125
agree, is an attempt to restore a person's human dignity
and to put them in a position which they might have
reached, a level they might have attained, had they not
had their lives stolen from them?
That is the objective of redress, yes.
So it should not be a box ticking exercise but should
fairly assess and properly reflect the many varieties of
loss that these appalling injustices have inflicted on
the subpostmasters?
Yes, I would agree.
Now, that is a very important factor, would you not
agree: the life that they might have led without
dishonour or disgrace, that can't be brushed under the
carpet by the Post Office, can it?
No, it can't.
You would agree that, if the subpostmasters and their
dependents are treated unfairly during this compensation
process, then the Post Office's own reputation, perhaps
even its future, is doomed?
Yes, I think that's fair.
Yes, because it would be the most appalling irony or the
most dreadful repetition of past history if the Post
Office in the past, having exploited the law to its
wrongful advantage, did so again, to find some way of
evading its proper responsibility to the people it
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Yes, that's absolutely what we've learnt.
Of course, this protracted episode, now well over two
decades in length, represents, as I'm sure you will
agree, the most shameful, brutal and sustained breach of
trust in the company's history?
Yes, that's fair.
You would agree that it's a nadir that the Post Office
will not even begin to recover from until full and fair
compensation is paid to its victims?
That's absolutely correct.
Now, wrongful accusation leading to conviction brings
a person's life to a shuddering halt. I'm sure we can
all agree on that.
Yes, we can.
The trajectory of their lives thereafter is either
flattened or crushed by that injustice but you would
accept that, even when that wrongful accusation is
removed, some wounds never heal and some injuries can
never properly be compensated for?
That's certainly my experience from the restorative
justice meetings that I have attended.
The long-term impact is profound.
And it spreads across the family?
I agree.
Yes. Compensation, insofar as possible, you would
126
wronged?
Yes, I would agree.
Of course, if the Post Office drags its heels, the same
applies?
Yes, that's correct.
So it follows that the most important thing that the
Post Office under your stewardship should be doing, is
to facilitate the speeding up of meaningful
compensation, to avoid the postmasters living in penury
or, as we heard at the very beginning of your evidence,
in fact before you gave evidence, Mr Read, dying before
receiving proper redress?
Yes, that's correct.
Now, I think we can still rely on The Times Newspaper.
Data obtained by The Times under Freedom of Information
laws revealed that 263 subpostmasters and
subpostmistresses had died since being wrongly accused
of stealing money because of the computer accounting
errors and, of that 263, 251 died before receiving
compensation. That's a terrible statistic, isn't it,
Mr Read?
It is a terrible statistic. Yes, it is.
251 never receiving an apology or recompense, and I am
sure you would struggle to find words to convey the
injustice of that?
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No, it's a terrible situation.
Each death, during this process, before compensation has
been made, is an obviously serious matter, you would
accept that?
Yes.
It could show that the process isn't fit for purpose or
it isn’t working properly if the claims take so long
that, unfortunately, people die before they receive
compensation?
I think that's a fair conclusion.
Now, I want to now concentrate on something slightly
more specific than the vagaries of fate because,
obviously, people can die for a variety of reasons at
any time. But do you know how many of those dead
subpostmasters' claims were delayed or denied on
technical legal grounds?
No, I don't know that.
Has the Post Office made any study of why the process is
so slow and whether its lawyers are to some extent
responsible for the delays?
I don't think I would call it a study but we are acutely
conscious, as you'll have seen over the last two days,
and particularly the compensation meetings that I've had
with the Government and with the Minister, we spend
a lot of time trying to work out how do we improve and
129
are in a dispute, whether that's in the HSS scheme or
the OC scheme, we do pay interim payments up to that
particular level, and then we have a debate about, and
a discussion about, how we can come to a conclusion.
That is my understanding.
I see. Now, I wonder, and there are so many cases, but
I'm going to take you to the case of Mr Sivasubramaniam
Jayakanthan, and you may not have heard of him but he
was a subpostmaster in Putney. He was audited,
interviewed and suspended on 4 March 2005. His Post
Office was peremptorily shut down that very same day
before a full investigation had taken place -- 4 March
2005 -- and later that night, he hanged himself, and his
wife Gowri found his lifeless body in the loft. His
fate earlier that day was probably the same as described
my Mr Justice Fraser in the Common Issues Judgment at
paragraph 886, and I quote:
“Suspended subpostmasters are not only entirely
excluded from the Post Office part of their premises,
they appear to be excluded, in some cases, from the
entire premises and also are completely denied access to
any information or records.”
Now, no wrongdoing was ever established against that
man, and although the shortfall was on the automatic
telling machine or cashpoint, it was reported through
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speed up the process. That is a constant point of
conversation with myself and the Minister and others.
But returning to the issue I was raising: it would be
a terrible thing if claims were being derailed by clever
legal points, which right-thinking people might even
regard as chicanery.
Yes, it would be.
Would it ever be right, in your view, to reject a claim
‘ona technicality?
To reject an entire claim on a technicality? That would
seem the wrong thing to do. My understanding is that we
have learnt lessons in that particular respect and we
now, where there are disputes or where there are issues
associated with technical reasons, we have got ourselves
to a position where we pay interim payments and we try
and work out how we resolve those particular disputes.
That's my understanding of how we've evolved.
So to reject an entire claim on a technicality would be,
in your view, would it be fair to say, unconscionable?
It would seem -- it would certainly seem a strange
approach and I don't believe that we are doing that now.
It may well have been the case and we've learnt, and
we've listened and we've moved on but I didn't believe
that was the case now. As I said before, I think we've
got ourselves to a position where we have ~- and if we
130
Horizon. In November 2023, three years after she made
her application to the Horizon Shortfall Scheme, Gowri
Jayakanthan's application was rejected, and I'm just
going to tell you what the two stated reasons for that
rejection was, Mr Read.
The first was that the company that her husband had
used so many years before to contract with the Post
Office, had been dissolved; and the second reason was
that the loss was not a Horizon shortfall, because it
had arisen through use of the ATM, even though the data
in question was, and had been, processed via Horizon.
That can't be right, can it, Mr Read, to do that to
that woman?
That doesn't sound right, Mr Henry, I would agree with
you. I am not familiar with this case, as you rightly
point out. I don't specifically get into individual
cases. However, as you quite rightly say, the principle
seems peculiar, given that Horizon was clearly involved
in the ATM processing.
The people representing you, and I don't mean you
personally, I'm talking about the institution, but they
would have known that, at the time of the tragedy, she
was the mother of two young children, infants under the
age of five, whom she had to raise thereafter on her
own, having suffered years of financial hardship and
132
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insecurity because she lost her livelihood, as well as
her husband.
So you outright reject, it could never be acceptable
for the Post Office's lawyers to take a technical point
like that, blocking her path to closure and
compensation?
I think, in the context of where we have gone over the
last three or four years, it does seem, in the way that
you describe, to be a -- a desperate situation, I agree.
Now, leaving aside the issue of the three-year delay,
I want to now deal -- very, very briefly because we're
going to touch on it a little bit later -- with the
inception of the schemes. I accept, of course, that you
were very, very recently in post and so, therefore, you
were very much dependent upon people to advise you.
But there isn't any question, is there, of extremely
tight restrictive eligibility criteria being used to
deter claims: narrow, legalistic criteria to reject
claims and claimants; you would reject that?
Sorry, as an accusation against the organisation?
The HSS scheme, for example. Take that as the focus.
Whether there were narrow legalistic criteria to reject
claims and claimants, I mean, you would be shocked if
that were the case, would you not?
Well, my understanding is that the bar for entry into
133
the damages should go up, or the compensation award
should go up; do you agree?
Yes, if suffering is being extended unnecessarily,
I think that's a fair assumption.
Yes. Now, given your research and the evidence that has
been given to this Inquiry, I am sure you're driven to
accept that the Post Office over many years strove to
delay the revelation of exculpatory material that would
have enabled criminal appeals to have been brought
swiftly?
I think we've certainly heard that, and we can agree
that that has been the case.
Yes. I mean, no need to go over old ground but it is
important to note: the non-disclosure of the Clarke
Advice from 2013 to 2020, concerning Mr Gareth Jenkins,
I mean, Mrs Misra could have brought an appeal in 2013
or 2014, had that not been suppressed; do you agree?
Yes.
Yes. Mr Butoy, Mr Moloney's client that I have
permission to mention, a Legacy Horizon case from 2007,
he went to prison in 2008 for 39 months. His appeal was
rejected in 2018 and the Court of Appeal Criminal
Division had the Horizon mantra put before it, and the
Horizon mantra -- I mean no disrespect, Mr Read, but
it's: no evidence that the Horizon system was shown to
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the HSS scheme was as low as it could be, it was
certainly lower than any legal metric, so we were trying
to encourage people to come forward. So, yes, I would
suggest that wasn't how it was set up or designed to be.
Now, the implications of the scheme and the errors
that we have made subsequently, I would -- and I'm sure
we'll discuss them a little later -- but certainly the
principle of establishing the scheme was to ensure that
we gave fair redress.
Now, there's another dimension that I want to address,
and that's whether the compensation sums being offered
are adequate. That, of course, would depend on many
variables, which you would not be necessarily familiar
with in each individual case ask but, as a general
principle, would you agree that the misconduct of the
Post Office causing and prolonging the suffering of the
subpostmasters over many years, that would be a relevant
factor?
Yes, I would.
So if the Post Office deliberately delayed, denied or
obstructed appellate rights, it should pay more,
shouldn't it?
Yes, that would make sense.
Because, of course, it would thereby be wrongly
prolonging the suffering of its victims and so therefore
134
be unreliable or open to errors; whilst as with any
computer system errors from time to time may crop up;
Horizon is largely reliable; the proportion of alleged
and detected defects related to the Post Office branch
accounting is minuscule, in comparison with the overall
operation of the system; used in 11,600 Post Office and
multiple in-branch users daily to provide financial
services and counter operations on a national scale.
So his appeal was rejected in 2018 but he was
cleared in April 2021 as part of the Hamilton judgment.
Now, I think, with a degree of understatement, that it's
fair to say, is it not, Mr Read, that the Court of
Appeal in 2018 didn't get the full picture, did they?
It sounds like that was the case.
I mean, without pulling any punches, they were misled
because the truth about Legacy Horizon, as was held by
Mr Justice Fraser, was very different from that which
was put before the Court of Appeal?
Yes.
Yes. So that mantra was a slogan to finesse what very
senior management by then in 2018 ought well to have
known: that Horizon, leaving aside its commercial
application, was wholly unreliable and unfit for
forensic purpose, in other words to bring a case in
court to deprive a person of their liberty; you would
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agree with that?
Yes, I would.
Right. So given this history of obviously meritorious
appeals being delayed and the appeal procedure being
unnecessarily prolonged, you would accept, and in fact
you were very candid about this in your witness
statements, that the Board, the Senior Executive Team,
historically the institution, prioritised its commercial
and reputational interests as opposed to doing justice
to the subpostmasters?
I said there was very definitely a focus on
profitability and commercial sustainability, rather than
‘on the wellbeing and the development of the postmaster
contract. Absolutely I did, yes.
Now, again, just dealing with the mindset and accepting
the fact that you were only just in post, the Post
Office was even being advised in 2019 that the Criminal
Cases Review Commission might never make a referral. To
use a colloquialism -- and these aren't the words used
by the learned counsel who was advising the Post
Office -- but the CCRC might blink. Would you accept
that, given what this Inquiry has established, the Post
Office ought to have been banging on the door of the
CCRC, the DPP and the CPS, saying, "You've got to refer
these cases, they're unsafe"?
137
criminal appeals, they should pay more, and you may have
been advised on this already, and I don't seek to know
your advice because that's privileged, but when
a wrongdoer causes harm intentionally, or recklessly, or
with gross negligence, then a court can award punitive
‘or exemplary damages and, on any fair consideration, you
would agree that this scandal qualifies as an obvious
case, in which such punitive or exemplary damages might
be eligible?
Agreed.
Can you help me: does the Post Office advise claimants
of this potential claim in the schemes you administer?
I can't help you with that. I don't know the specific
details of that.
I suggest that the Post Office does not.
Okay.
The forms are silent on exemplary damages and,
specifically in relation to the HSS form, there is no
box for an applicant to claim exemplary damages.
Now, I'm going to come to that form in a little bit
more detail later but there is an appendix to the form
which gives some guidance to potential claimants and
there is no mention of exemplary damages anywhere in the
appendix. Now, you're not aware about that?
I'm aware of the appendix and I'm aware of the fact that
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When are we describing? Do you mean in 2018 or do you
mean subsequently?
I'm talking about as soon as it came to pass that there
were serious problems with Horizon and certainly by
2019, after the receipt of the Horizon Issues Judgment,
the Post Office ought to have been banging on the door
of the CCRC saying, "You've got to refer these cases".
Yes, I can see where you're coming from.
You agree?
Yes, I can see that.
But you were being advised by your General Counsel, and
it's paragraph 23, page 12 of your third witness
statement, words to the effect "Don't dig into the
past".
Yes, the guidance that I received at that stage was that
my focus was very much on today's Post Office for
tomorrow and moving the business forward. So I think
that's fair.
You know Santayana's famous dictum: those who do not
learn the errors of the past are condemned to repeat
them?
Yes, I didn't specifically learn that but I understand
where you're getting at.
But, anyway, you have very candidly and properly
accepted that, if the Post Office prolonged and delayed
138
it's effectively a review and a guidance about how
a decision is made and what has been considered, but
lam --
You weren't aware of the omission about exemplary
damages?
Sorry, yes, I wasn't aware of the omission, yes.
Yes. Now, given the array of legal advice you
receive -- and I emphasise I'm not criticising you
because you are dependent obviously on legal advice --
but shouldn't exemplary damages have been mentioned in
the form?
You would have thought so, in the way that you
described: that the potential heads of loss, which
I know there is no cap on any of those potential heads
of loss, or indeed on the specifics, they are considered
irrespective, but guidance would have been sensible and
I think that was the objective of the appendix.
Yes. Now, it follows, your not being aware of it, but
something is being done in the name of the Senior
Executive Team, the General Executive, the Board,
something is being done on your behalf which is not
candid and which is not forthcoming because exemplary
damages ought to have been itemised as a potential head
of claim; do you accept that?
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SIR WYN WILLIAMS: Well, I'm not sure that it's fair to ask
a non-lawyer about when exemplary damages may be
payable, Mr Henry.
MR HENRY: But the possibility --
SIR WYN WILLIAMS: No, let me finish.
MR HENRY: Sorry, sir.
SIR WYN WILLIAMS: The exemplary or aggravated damages in
strict legal terms -- and I don't mean that in terms of
a technicality but when they would be awarded by a court
in England and Wales -- are clearly defined, are they
not, and they're not the sort of damages that are
necessarily payable for all tortious conduct, let alone
breach of contract. So I think one has to be careful in
what one is putting to Mr Read about this. I'm
perfectly prepared to accept substantial submissions
about this where there's a proper legal framework, so to
speak.
MR HENRY: So be it, sir.
SIR WYN WILLIAMS: But I think getting Mr Read to agree or
disagree about things about which he's really competent
to answer -- I'm not sure it's helping me, put it like
that.
MR HENRY: I'll try to be more helpful.
A lot of the people filling in these forms don't
have legal representation; you would accept that?
141
happen. I think it would be very fair to say that we
set out on the journey of the HSS, and I can remember
quite explicitly speaking with Alan Bates about the need
to get a very simple application form -- so you're quite
right -- and the guidance that we discussed at that time
was that a lot of individuals had suffered enormous
trauma, a lot of individuals were deeply concerned about
the relationship with the Post Office and, as
I discovered on my restorative journey -- justice
journey, people didn’t even want to open letters from
the Post Office, people didn't want to engage with the
Post Office, they were so traumatised.
So the guidance was very much let's find a way to
make sure that people don't need to engage in a legal
process but they can submit a claim, and I think what
I've learnt and I think what you're describing now, is
the principle of doing that was probably right, in the
sense that I think people were deeply troubled by the
notion of engaging with the legal system, they wanted
a way to submit a claim and receive redress.
And we didn't get there, for a multitude of reasons.
Perhaps we may discuss this later but we didn't get
there and I think that is of some regret from my
perspective. That's for sure.
Q. No doubt it would be a matter of regret to you if that
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I would accept that.
You don't pay for legal representation for people to
fill in the forms, do you?
Correct.
Yes. Now, I want to just ask you to consider this:
candour and transparency from now on -- or not from now
‘on but it ought to have been the touchstone about what
people could claim and certainly in the advice document,
particularly given the fact that you're dealing with
people who don't have legal representation. Right.
Can you see history repeating itself because,
admittedly, a lot of this occurred before you came on
board, Mr Read, but there were years of delay subverting
the appeal process, which you've accepted, and fighting
the GLO tooth and claw, weren't there, before you came
on board.
That's correct.
Now, echoing the past, we've got five years of delay
and, I suggest, attrition in the compensation process,
and that history is repeating itself; what do you say to
that?
I think the visibility that has been shone on the
compensation schemes by Parliament, through the Select
Committee, by the Inquiry itself, and by the general
media would suggest to me that that is not going to
142
supposedly simple and non-legalistic process -- and, in
fact, the Chairman of the Inquiry, on 8 December 2022,
actually was concentrating on that, that it should be
a non-legalistic process -- you would be deeply
concerned, wouldn't you, if it was mutating into
a legalistic or adversarial process?
I would.
You have already touched upon the potential, as it were,
conflict or impossibility or unwisdom, to use that word,
of the Post Office being involved in these schemes
because, as you've rightly pointed out, the former
subpostmasters want to have no interaction with the Post
Office at all, some of them, because of the deep trauma
they have suffered. But also, does it not place you in
a state of conflict because, if you were candid and
transparent and saying, "You've got to claim this,
you've got to claim that, you've got to claim the
other", then of course you would be racking up the
amount of money you would have to pay in compensation,
wouldn't you?
That's an inevitable conflict, yes, you're right.
Yes. You've already said, not in so many words, that
the Post Office's role in administering two out of the
three schemes is both wrong and untenable?
Mm-hm. I probably didn't use those words but I think it
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was inappropriate and I've said that many, many times.
Yes. The delay and discreditable disputes concerning
compensation would exacerbate that lack of trust, would
it not?
Yes, it would.
It would continue to poison the relationship that exists
with the victims and further besmirch the character of
the Post Office?
Ive been very clear that speedy and fair redress is
essential to protect the long-term interests of the Post
Office and, obviously, the relationship between the Post
Office and the victims of the scandal. We haven't lived
up to that and that, as I say, is of deep regret.
Yesterday you said this:
"I've looked at my contemporaneous notes ..."
That would be of conversations with the shareholder
and the Government:
"... and I think I may well have disclosed something
to this effect, that the way it was portrayed to me was
that the Treasury were of the opinion that the chaos --
I think was the word they 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."
That's what I said, yes.
Now, I don't dispute that that was said to you but
145
occasionally we can speak to the Department who, in
turn, will speak with the Treasury.
So there is an obfuscation, I think, by definition
of me as the personification, I guess, for want of
a better word, of the Post Office and the funder.
Yes. Whoever was calling the shots, however, the
decision that you should be involved -- the Post Office,
that is -- in two out of the three schemes was thereby
exposing a teetering institution, which is virtually
insolvent, to further reputational damage and criticism.
I do hold that view, yes.
Yes. The Government is using the Post Office as
a shield or fire curtain, isn't it?
That could be a description, yes.
The fact that you're administering two out of the three
schemes gives the Government a degree of protection,
being at one remove gives it room for plausible
deniability, where they can detach themselves from
criticisms levelled at the Post Office, can't they?
That's true.
They might even be instructing you to minimise or
suppress compensation claims whilst avoiding public
scrutiny?
No, I don't think they've asked us to do that, but
I think they are one step removed but, at the same time,
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somewhat odd for a shareholder to want that, isn't it?
Well, I think you're raising an interesting question
about the shareholder. The shareholder has many guises,
and I think it would be fair to say that is the
ministers, that is the Department, that is UKGI, that is
the Treasury. I think this idea that this notion of
“the shareholder" is quite confused, in the sense that
there are competing and different objectives from
different elements of "the shareholder", as you put it,
and I say that in my witness statement: that one of our
challenges is to define very clearly who is the
shareholder and are their objectives aligned because
ministers, departments, UKGI, Treasury, have different
objectives, and that is a challenge for us all.
So was the Treasury calling the shot when you gave that
evidence yesterday?
That -- well, ultimately, we have a single source of
funding, whether that's for the long-term future of the
Post Office or whether that indeed is for compensation
and that is from the Treasury, and I don't understand or
know about the inner workings of how departments
interact with the Treasury. What I do know is that
an arm's-length body isn't allowed to interact with the
Treasury. One goes through either the shareholder
representative, in this sense UKGI, or indeed
146
hold the levers of funding.
Have they expressed concerns about the bill?
No, I think it would be fair to say that there is
an inevitability about it. I don't believe the
Department has expressed a concern. I think they
recognise that freeing up the funds from Treasury is
never easy and, therefore, determining what that
business case could look like and how it works, again,
is a question for the Department and for UKGI. But, no,
I would say that there is recognition that the bill is
significant and they must get on and deal with it.
So that there's no quibbling about the bill, this could
all be wrapped up quickly if the money were put on the
table?
Well, my sense is that, with the intervention of the
previous Secretary of State, back in September '23, and,
again, with the mass exoneration and the availability of
the £600,000 fixed fee for the overturned convictions
and the £75,000 for the HSS, they have put their mouth
where their money is, would be my suggestion.
I'm going to suggest that the 600,000 is woefully
inadequate for some cases, as is the 75,000. So can
I just ask you, then, what is the cause of the delay: if
the Government says, or you have been told, that there's
no quibbling about the bill, there's a realisation that
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the money has to be paid, what are the reasons for the
delay?
A. Well, I think agreement has now been reached, certainly
in HSS, for the 75,000 fixed back and the 75,000 fixed
forward. We will be writing out to 25,000 additional
postmasters to make them available -- to make the scheme
available. So I think that process, I think, is
happening and will happen this month. So I think one
should be confident that we will get on and execute as
a consequence of that. I think that there is definitely
progress now in the overturned convictions. I think
principles have been established. I think the process
has been firmly agreed. I think the 600,000 is starting
to work. So that is happening.
And my sense -- and you'll be able to speak, I know,
to Simon Recaldin when he comes next week on the
specifics of some of these issues -- that having taken
an inordinate length of time, particularly in OC, to
establish some of the principles, that is now done and
I think I would like to think that we will see
compensation flowing -- I use that word advisedly -- in
a way that it hasn't been to date.
SIR WYN WILLIAMS: Do you mind if I ask a question a moment,
Mr Henry?
MR HENRY: Of course, sir.
149
the right word, then the Government needs to sign off.
So the principles that have been established in terms of
the early neutral -- the ENE process, they have been
established with some guidelines for heads of loss, and
ranges. If those ranges are -- and the agreement is
from the panel that actually it should be outside of
those ranges, then that has to be signed off by the
Government.
SIR WYN WILLIAMS: Right. So even though there is
an independent panel, which has agreed what the sums
should be --
A. Correct, sir.
SIR WYN WILLIAMS: I -- it is at least, in theory, possible
that the Government could say no.
A. In theory, that is possible, yes.
SIR WYN WILLIAMS: So the next question is: has that ever
happened?
A. I'm not aware but others may have a view. I don't --
SIR WYN WILLIAMS: = You don't know?
A. I don't know.
SIR WYN WILLIAMS: All right. Thank you.
Sorry, Mr Henry.
MR HENRY: No, no. Thank you, sir.
So just dealing with the £600,000, that could never
be appropriate for a high-value case, could it?
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‘SIR WYN WILLIAMS: Take the HSS --
A. Yes.
‘SIR WYN WILLIAMS: -- and truncating it, so we can give
Mr Henry his full time allowance, it gets to a point --
and I'm talking about the high-value cases in HSS, all
right?
A. Yes, yes.
SIR WYN WILLIAMS: = There gets to a point in time where
an independent panel has said, "We think the value of
this is X". Right?
A. Correct.
‘SIR WYN WILLIAMS: Let's assume there's a happy state of
affairs and the postmaster is likely to agree that sum,
all right, because you're not really far apart.
A. Okay.
SIR WYN WILLIAMS: At any point in this process, does
Government authority have to be obtained for individual
settlements?
A. Yes, it does.
‘SIR WYN WILLIAMS: = Right. Thank you.
A. Every time -- would you like me to explain that a bit
more?
SIR WYN WILLIAMS: Yes, please.
A. So every time that the guidelines associated with
individual heads of loss are either breached, if that's
150
A. No, I think you're right. We both know that in the
600,000 for the overturned convictions but also the 75
for the HSS, there will be plenty of individuals for
whom this will not be appropriate. But it will be
a good medium for many and I think that the point ~
that is the point.
Q. What do you say to Mrs Blakey's widower, who stated that
he had to accept the £600,000 because he was worn out
and that he didn't have the energy to fight on because
it had been so drawn out and so painful that he just
decided, "I just have to accept the £600,000"?
A. I think that's desperately sad and my understanding was
that the -- is that the interim payment would cover that
specific cost and, if there was a need to go above and
beyond 600, then that would be possible. So I'm sad
that he felt unable to continue with that process.
That's not what the process was designed to do. We were
keen to ensure that people got closure, which, by
definition, means there will be many who will want to go
above and beyond 600,000, and we would want them to be
in a position where they can come to a point of closure
with the Post Office and with the Government.
Q. So you reject any suggestion that the Government has
been tight with the purse strings?
A. No, I don't believe it has been tight with the purse
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strings. I think the process is overly bureaucratic.
I would fully acknowledge that. I think the
establishment of principles in -- as an example, the
establishment of principles in HSS, when it was first
set up, took an inordinate length of time. There are
many examples, I think, where bureaucracy got in the
way, things have gone wrong. I don't think that is
necessarily borne out by people, you know, being
malicious in any way. I just think that is a poor
process, rather than it being anything more than that.
You know, certainly I know there will be people in
this room who have had dealings with the Post Office and
I'm sure they've been deeply frustrated by it but
I wouldn't -- it's not because the purse strings are
being closed tight.
You've talked about bureaucracy and you've said,
"I don't think it's about anybody being malicious",
"malicious" is a very strong word but what about
old-fashioned attitudes? Has the delay been caused
because of the Post Office's historic, dyed in the wool
prejudice against subpostmasters?
No, I don't believe that. I don't believe that.
I think that would be an unfair conclusion to come to.
I think it genuinely is a case of old-fashioned
bureaucracy, if that's a different way to put it.
153
to engage with them, getting the CCRC to help us, and it
‘was a source of great concern, certainly to me, back in
the summer of 2023, when we were discussing this with
the Advisory Board, that we couldn't find a way to get
people to come forward. And we sought the CCRC's help,
we sought other's support, we even enquired of the CCRC
if we could bring cases forward to the CCRC without
postmasters necessarily being aware of it, as in to try
and get those convictions overturned, which is something
that we did, but was rejected by the CCRC and the Court
of Appeal, obviously, because postmasters need to be
involved in that process.
So it was, a -- and remains a -- clear frustration
and a clear recognition, I think, that the Post Office
role in this particular process of remediation and of
redress, you know, first and foremost is the wrong one,
and we shouldn't be involved in that process.
Yes. Earlier on you've denied that there is or was
a deliberate policy of delay and deterrence based on the
design of the forms. But! want to deal with this
perplexing question of trying to get people to come
forward. Have you heard of complaints about the
complexities of the compensation process and the forms
itself from subpostmasters?
Yes, we have.
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You say it's unfair, but you can understand the concern
surely --
Of course.
-- typified, I regret to say, by your letter to the Lord
Chancellor, which might have caused people enormous
concern, that letter to the Lord Chancellor, which was
reflective of an old-fashioned view, I suggest, Mr Read?
No, I don't believe that. I can see why people will
have been frustrated by it. We had an obligation,
I believe, to alert the Lord Chancellor to the work that
we'd done and I think we worked quite extensively with
the Advisory Board trying to work out and trying to
understand how do we get more people to come forward,
which is exactly what we tried to do. And, you know,
you can see, I think, that there are minutes from the
Advisory Board meeting that articulate that challenge.
How do you get people to come forward, Mr Read, when
your letter to the Lord Chancellor was in the terms it
was, and also Mr Vamos' unsolicited letter -- I'm going
to call it the "They must be guilty" letter -- which was
inexplicably posted on the Post Office's website earlier
this year. How can you get people to come forward if
that is happening on your watch?
Well, we tried it many, many times, to engage with the
700 convicted postmasters, both writing to them, trying
154
Have you heard, apart from what I've just mentioned
about Mrs Blakey's husband, of subpostmasters settling
for less because they didn't have the energy or the
means to pursue their just entitlements?
No, I haven't, until you've mentioned that example.
So you haven't heard about subpostmasters who sell
themselves cheap, deterred by red tape or intimidated by
the process?
I didn't get that sense and, certainly, if I look at the
HSS scheme in particular, that wasn't my takeaway from
that process.
If the application forms have misinformed people as to
their rights, or deterred them from applying -- but
let's concentrate on if they have misinformed people as
to their rights, that would be appalling, would it not?
I agree.
Again, I have to be careful in light of the Chair's
earlier observations but let's just concentrate on the
Historic Shortfall Scheme very, very quickly. It's
supposed to compensate subpostmasters who are not
actually convicted of theft but were accused of theft.
That's correct.
They lost their jobs, many were threatened with
prosecution and forced to repay cash shortfalls, which
were entirely fictitious and all of that, the stress,
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the suffering, the damage to their reputation, that
should be compensated for, should it not?
That's correct.
You know, from the evidence that we have heard, about
subpostmasters being called thieves, spat at or shunned
in their community, even in one case being attacked.
All because of that false accusation.
Yes, I am aware of that.
You know also, of course, about the fact that some of
them had to move house because they had become pariahs
in their locality?
Yes, I sadly met many.
Now, as at June 2023, there have been about 2,500 HSS
claims settled and the average settlement payment was
only £32,000. Does that strike you as being rather low?
I think there's a very long -- I was going to say --
tale is the wrong word. I think there's a long -- let
me put it another way: I think where fatalities or
bankruptcies or others, obviously there are a smaller
number of those, but there are a lot of very low claims,
which I suspect is why the overall average is what
you're suggesting. My point, I guess, is that, where
they are more complex and where they are involving
bankruptcy or fatality or anything of that nature, or
indeed bigger claims, they're larger.
157
said, he has stated and suggested that the HSS form is
designed to deter claims for damages to reputation; what
do you say to that?
I mean, he's clearly entitled to his view. I think what
we have done as a consequence is that we have
reconstructed the application form, so now that if you
want to apply in the HSS scheme for 75,000 forward,
I think it's now reduced to a mere 20 questions, and
we've also recut the application form for those who
don't want to apply for 75,000 but may have a more
complex claim.
So I think we've learnt and listened quite
extensively to the Select Committee, to this committee,
to the commentary that has been run by postmasters and
by others, and I would argue that -- not argue, I would
state that we have made changes to the tax position,
we've made changes to the complexity, we've reduced the
scheme application form, and we've also spoken at length
with DBT about an appeals process because we are very
concerned, for exactly the reason you've just described,
that we may find ourselves in a position where people
were disadvantaged, we would say, you know,
inadvertently, but if they have been, we clearly need to
address that, and that is something that I'm alive to.
I won't go into the argument about how the form is
159
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So I'm not sure the average necessarily paints the
picture that —-
Well, anyway, let's return to the form. Would you agree
that the form is lengthy, complex and legalistic?
Yes, I would.
I don't know if you're familiar, but you may have been
aware of the criticism by Mr Dan Neidle of Tax Policy
Associates in respect of it?
I'm aware of his criticism, yes.
Taking it quickly: the form and appendix, 14 pages in
length but with other supplementary documents it's over
20 pages of material, and, as you've already said, no
legal advice, no payment of legal costs for completing
the form. You would realise, as an institution, that
you're dealing with a number of unrepresented
applicants, correct?
Correct.
Right. So, therefore, you must be assiduously careful
to ensure that they're not misled?
Yes.
Right. You've accepted the importance of a person's
reputation and the stigma of false accusation, haven't
you?
'have.
Right. Mr Neidle, and you're familiar with what he
158
misleading because I believe that would be better for
submissions. So I will move on and ask you to just help
me with a document which is POL00155397. I think you've
been shown this document, have you not, Mr Read?
I'm not sure. If you could scroll down, I could see.
By all means. It was provided to you earlier this week.
Can we scroll down, just so I can see it? Thank you.
We'll take it --
Sorry, which piece are you taking me to?
Yes, of course. Well, if we go to page 1, it's entitled
"GLO Post Settlement GE" -- that's General Executive?
Group Executive.
“Group Executive" -- forgive me -- "Paper", and
presumably, therefore, you would have seen the paper
itself?
Yes, I was in the organisation at this time, yes.
Yes. This is what Mr Underwood says at page 1:
"... Lam not sure Nick wants me to lead the
Historical Claims workstream owing to my prior
involvement in the Complaint & Mediation Scheme,
Chairman's Inquiry and the GLO."
It goes to:
“lam not sure the workstream leads set out in
Appendix 1 are set in stone yet", and then the words
that I have just taken you to that have been
160
(40) Pages 157 - 160
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highlighted.
Can you help me: weren't entry fees mooted at one
point before access to the HSS was allowed?
A. Entry fees, sorry?
Q. Yes, fees for applicants.
A. Sorry, I'm not sure what that means, actually, to be
honest.
Q. Well, in other words --
SIR WYN WILLIAMS: Mr Henry is suggesting that, before you
could enter the scheme, you had to pay a fee.
A. Oh, really? Okay.
SIR WYN WILLIAMS: As you do in court, in some instances,
for example. That's what he's asking you about.
Yes, Mr Henry?
A. I don't recall that being the case. It may well be but
I don't recall that.
MR HENRY: Could we go to page 2 of 5, and could we scroll
up, please -- maybe down, in fact. I'm sorry, when
I say up, I mean down.
If we keep going, yes, "Fees", exactly. Thank you.
So we've got Mr Underwood there saying:
"My strong view is that you cannot seek payment from
applicants -- however small and regardless of the
rationale behind it. Optically this would be extremely
challenging and would be a position that I believe the
161
A. Possibly.
Q. Yes. It's a more subtle and insidious method of doing
it but it makes it difficult for subpostmasters to
apply, to reduce the Post Office's disclosure. I mean,
for example, in the forms, they talk about the provision
of contemporaneous documents. How are you going to get
contemporaneous documents when many years have passed
and where the Post Office had seized them and, as in
Mr Lee Castleton's case, never returned them? It's
a hurdle, isn't it? Not a low hurdle, but it's actually
a high bar. That was the design, wasn't it?
A. It's certainly -- you could certainly draw that
conclusion from this paragraph.
Q. [remind you, we've dealt with it very briefly already,
paragraph 886 of the Common Issues Judgment:
"Suspended SPMs are not only entirely excluded from
the Post Office, part of their premises, they appear to
be excluded in some cases from entire premises and also
are completely denied access to any information or
records."
Then Mr Justice Fraser said this:
"Given the severe effect upon a subpostmaster of
having their appointment terminated, it is not only
important, but I would go so far to say crucial, that
they're given a reasonable opportunity to meet a case
163
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business would struggle to maintain under political and
media pressure. I think you can achieve the same
desired outcome [through] having [it says 'though’]
a very tight and clearly communicated set of eligibility
criteria and requirements in terms of the documentation
applicants have to provide in order to be accepted into
the Scheme.”
Now, that's an atrocious line of thinking, is it
not, that, at one point, the Post Office would seem to
have been discussing charging fees to be paid by the
wronged victims of the Post Office before they would be
allowed to enter into the scheme?
It does seem a bizarre --
Yes. I suggest, as is clear from what Mr Underwood was
saying, was that the same desired effect, the same
‘outcome, would be strict -- very tight, in other
words -- eligibility criteria, very tight and clearly
communicated set of eligibility criteria and, of course,
the documentation subpostmasters would have to provide
before being accepted into the scheme. He suggested
this would have the same desired outcome, didn't he?
It's clear --
It does look as though that's what is implied.
I suggest that was to restrict access to the scheme and
to deter applicants, isn't it?
162
being brought against them by the Post Office. It is
difficult to see how they can have such an opportunity
if they are denied access even to copies of information
or records."
That judgment came out on 15 March 2019. This email
is January 2020. By that time, the people in this
email, one of whom, of course, was Mr Williams, Rodric
Williams, would all have known the difficulties for
subpostmasters of obtaining contemporaneous documents,
when these were historic events that had occurred many,
many years before and where they had been subjected to
such unfairness; do you agree?
That's a concerning conclusion, yes.
You all knew -- and I don't mean that pejoratively to
you, Mr Read -- but those advising you all knew, when
this demand for contemporaneous document was hatched,
that subpostmasters would have great difficulty in
complying with it; that must be right?
That's a disturbing conclusion, yes.
Yes. Now, Mr Read, I realise you were, to some extent,
put in this job to a degree under false pretences
because you had no idea -- no idea -- what you were
letting yourself in for, but you would agree that you
were not the solution you promised to be, despite
everything you did?
164
(41) Pages 161 - 164
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A. Not the solution I promised to be; what do you mean?
Q. Well, the compensation process is not being dealt with
fully, fairly and quickly. That must be right?
A. I think, to a degree, that's fair.
Q. Yes. It's the same, I suggest, dyed in the wool
inability of the Post Office to treat those it
destroyed, or very nearly destroyed, with dignity,
respect and justice?
A. I would like to think we've learned the lessons of this.
I think it has been slow and painful for the Post Office
to do so. I think, culturally, we've had to come a long
way to do that but I would it argue that those lessons
have been learned. I think the changes that we have
made, certainly over the last few months, particularly
to the schemes, to the approach that we've adopted, to
the way that we've engaged with victims, has changed.
I would hope that people in the room had identified
that but we're obviously open to feedback accordingly.
But I think, certainly since the compensation hearings
and since the drama at the start of this year and since
the Select Committee, I think we've learnt those
lessons, I think the shareholder has too and I think
there is a great deal more understanding.
This process has hugely helped in shining a light on
some of the practices of the past. I think we are
165
MR BEER: I will, sir.
SIR WYN WILLIAMS: Yes, thank you.
(4.08 pm)
(The hearing adjourned until 10.00 am the following day)
167
ONOaARWN
10 October 2024
genuinely open and moving towards a better system.
There are proper appeals processes, proper
independent panels now working, there is a commitment,
certainly from the Shareholder, from a funding
perspective, and there is a commitment from the Post
Office to get this right.
I do believe some of the principles are now in
place. I do believe that the process is such that
things will start to flow but I would also acknowledge,
and I think you've been very generous in pointing it out
today, that mistakes have certainly been made, and
I would agree with that.
SIR WYN WILLIAMS: = Thank you, Mr Henry.
MR HENRY: Thank you, sir.
SIR WYN WILLIAMS: You will know, Mr Read, that in each of
A.
my progress updates and in my interim report, I drew
attention to the oft-repeated phrase, both by Post
Office and Government, that "compensation would be full,
fair and prompt". Forget "prompt" for the moment. Can
you assure me that it is still the aim of Post Office to
provide compensation which is full and fair?
I can assure you.
SIR WYN WILLIAMS: Fine. Thank you.
Then we'll adjourn now until tomorrow morning when
you'll resume your questioning, Mr Beer.
166
INDEX
NICHOLAS JAMES READ (continued) .....
Questioned by MR BEER (continued) ....
Questioned by MR HENRY ..
168
(42) Pages 165 - 168
MR BEER: [16] 1/6
5/5 16/16 43/25 52/5
52/11 76/10 89/1 89/5
89/9 122/15 123/17
124/14 124/18 124/21
4167/1
MR HENRY: [9]
125/3 141/4 141/6
141/18 141/23 149/25]
151/23 161/17 166/14I
SIR WYN WILLIAMS:
[46] 1/5 4/23 5/3
16/1 16/11 43/17
43/21 75/3 75/8 75/11
75/17 76/8 89/4
122/17 123/2 123/4
123/8 123/12 123/16
124/5 124/17 124/20
125/2 141/14 141/5
141/7 141/19 149/23
150/1 150/3 150/8
150/12 150/16 150/20}
150/23 151/9 151/13
151/16 151/19 151/21
161/9 161/12 166/13
166/15 166/23 167/2
"19 [1] 38/5
"22 [1] 12/14
"23 [2] 120/24 148/16
"24 [1] 120/25
‘at [1] 31/10
‘how’ [1] 120/11
"new [1] 7/1
‘problematic’ [1]
31/22
*quid’ [1] 49/9
‘relatively [1] 10/20
‘the [2] 6/17 6/18
‘though’ [1] 162/3
"Ways [1] 120/8
‘Where [1] 120/22
‘whether [1] 120/18
"WOW' [1] 120/8
1 January [1] 9/20
1 mile [3] 95/17
95/20 95/23
1,300 [1] 99/12
4,700 [4] 28/16
1.45 [2] 89/3 89/8
10 [3] 58/7 82/14
105/25
40 October 2024 [1]
1/1
10 per cent [1] 94/7
10 years [1] 28/16
10.00 [1] 167/4
105 [1] 120/5
107 [1] 120/16
109 [1] 109/4
11 [2] 34/20 82/18
11,600 [1] 136/6
11.22 [1] 52/8
11.40 [2] 52/6 52/10
110 [4] 109/7
12 [5] 79/8 79/11
80/5 82/22 138/12
12 hours [1] 74/18
12.12 [1] 79/12
12.44 [1] 89/6
12.45 [1] 89/2
13 [2] 58/17 80/4
13 July [1] 1/18
13A [2] 80/5 80/10
14 [1] 23/18
14 pages [1] 158/10
15 [2] 24/13 52/6
15 March [1] 164/5
15 per cent [1] 25/25
15 years [2] 105/7
105/25
16 April [1] 95/1
169 [1] 89/21
17 January [1] 33/8
18 [2] 39/13 59/18
19 [3] 22/16 22/21
78/23
19 June [1] 100/18
1920 [1] 94/6
2,500 [1] 157/13
2.45 [1] 124/23
20 [3] 80/13 81/1
159/8
20 pages [1] 158/12
20.3 [1] 87/2
2005 [2] 131/10
131/13
2007 [4] 135/20
2008 [1] 135/21
2010 [3] 54/16 97/18
97/25
2011 [1] 53/13
2012/2013 [1] 99/20
4
2013 [3] 99/20
135/15 135/16
2014 [1] 135/17
2015 [5] 29/5 29/15
32/10 32/15 98/7
2018 [7] 95/1 99/19
135/22 136/9 136/13
136/21 138/1
2019 [12] 9/10 10/17
11/13 27/6 37/16 83/7,
84/10 87/14 88/6
137/17 138/5 164/5
202 million [4]
104/10
2020 [4] 9/10 10/23
135/15 164/6
2021 [6] 9/13 10/25
97/19 120/7 120/19
136/10
2022 [13] 1/18 1/18
10/3 11/3 27/23 31/3
32/5 38/3 43/19 115/5)
120/19 120/24 144/2
2023 [9] 1/19 17/5
90/1 90/1 115/4
120/20 132/1 155/3
157/13
2024 [14] 1/1 5/13
5/25 6/10 17/14 33/9
44/15 44/15 90/2
100/18 108/7 109/6
115/2 120/20
21/22 [1] 104/7
210 million [4] 99/20
214 [2] 120/3 120/5
22 [7] 8/14 12/2 14/3
16/17 19/15 104/7
107/25
22 August [1] 56/8
220 [1] 120/16
23 [1] 138/12
23 January [2] 44/14
44/15
23/24 [1] 91/3
230 [2] 27/18 27/21
233 [1] 29/1
234 [1] 29/21
235 [1] 30/14
238 [1] 55/19
24 [1] 91/3
246 [1] 89/14
25,000 [1] 149/5
251 [2] 128/19
128/23
252 [1] 115/6
26 June [2] 5/13 5/25
263 [2] 128/16
128/19
27 April [4] 1/19
273 [1] 92/3
29 February [1]
76/13
29 June [1] 89/25
3
3 miles [2] 95/17
95/25
3.00 [2] 124/14
124/21
3.03 [4] 124/25
31 [1] 106/25
31 December [1]
10/17
32 [1] 79/7
32,000 [1] 157/15
33 [7] 8/16 12/5 14/3
16/4 16/18 17/18
19/15
335 million [1]
104/11
35 per cent [1] 115/1
38 [2] 107/25 120/24
39 months [1]
135/21
4
4 June [1] 109/6
4 March [2] 131/10
131/12
4 per cent [1] 115/5
4 years [1] 46/9
4.00 [1] 124/22
4.08 [1] 167/3
4.6 [4] 12/22
40 [1] 29/7
41 [1] 120/19
45.6 [1] 92/9
450 million [1] 104/8
46 [2] 64/19 106/25
5
5 January [1] 53/13
5 per cent [1] 115/4
5,000 [1] 98/6
50 [2] 92/6 120/20
50 million [2] 99/18
99/22
500 [1] 84/15
53 [1] 120/20
58 [4] 120/20
59 [1] 120/24
So
6 July [1] 1/17
6 miles [1] 96/7
60 [4] 55/2
600 [1] 152/15
600,000 [8] 148/18
148/21 149/13 151/24}
152/2 152/8 152/11
152/20
63 [1] 120/25
65 per cent [1] 94/15
7 per cent [1] 94/8
70 per cent [1] 93/19
700 [1] 154/25
71 [4] 22/16
72 [2] 22/16 22/24
75 [4] 152/2
75,000 [6] 148/19
148/22 149/4 149/4
159/7 159/10
8 days [1] 47/21
8 December [2] 1/18
144/2
8.91 [1] 93/21
80 million [1] 104/12
83 [2] 64/16 64/19
886 [2] 131/17
163/15
9
9.59 [4] 1/2
90 [1] 95/17
95 [3] 95/22 95/24
96/6
99 [2] 95/16 95/19
A
AB [1] 49/4
ability [4] 37/5 44/3
50/7 82/19
able [12] 8/20 16/21
29/23 36/6 50/24
69/17 85/21 90/7
90/24 103/19 114/6
149/15
about [103] 4/13 7/18
12/10 14/15 14/16
15/13 21/1 22/8 22/15}
23/24 24/9 30/10
30/22 32/12 34/18
37/3 37/5 37/22 38/3
39/25 40/7 40/10
40/14 40/16 40/24
41/1 41/2 42/16 43/9
43/23 45/25 49/8
51/22 52/5 52/20
52/24 53/1 53/4 53/12)
55/22 56/1 58/20 59/6I
59/6 63/15 65/12
68/10 70/18 70/20
71/7 71/8 72/25 75/9
81/11 82/9 87/22 93/3
93/5 93/8 93/10 102/4
111/13 112/23 114/4
115/12 115/15 131/3
131/4 132/21 136/16
137/6 138/3 139/24
140/1 140/4 141/2
141/14 141/16 141/20)
141/20 142/7 143/3
143/7 146/3 146/21
148/2 148/4 148/12
148/25 150/5 153/16
153/17 153/18 155/22!
156/2 156/6 157/4
157/9 157/13 159/19
159/25 161/13 163/5
above [5] 10/12 77/9
118/3 152/14 152/20
absolute [1] 80/1
absolutely [4] 124/1
126/1 126/10 137/14
accelerate [1] 49/3
accept [14] 107/10
125/11 126/17 129/4
133/13 135/7 137/5
137/21 140/24 141/15)
141/25 142/1 152/8
152/11
acceptable [1] 133/3
accepted [5] 138/25
(43) MR BEER: - accepted
A
accepted... [4]
142/14 158/21 162/6
162/20
accepting [1] 137/15
access [21] 19/4
52/17 52/21 52/24
53/3 53/5 53/21 53/23
53/25 54/4 56/2 61/5
61/14 61/15 88/3
95/12 131/21 161/3
162/24 163/19 164/3
accompanying [2]
10/8 10/12
according [4] 35/16
35/24 36/12 90/15
accordingly [2] 2/7
165/18
account [6] 21/22
36/23 44/20 54/23
55/6 122/7
accountabilities [1]
78/11
accountability [1]
103/2
accountable [1]
120/22
accountants [1]
48/10
accounting [2]
128/18 136/5
accounts [7] 46/21
52/17 52/21 53/5
55/10 55/11 82/20
accuracy [3] 14/17
48/13 55/10
accurate [1] 48/5
accurately [3] 81/13
81/16 87/3
accusation [5]
126/11 126/17 133/20
157/7 158/22
accused [2] 128/17
156/21
achieve [2] 116/22
162/2
achieved [1] 92/9
acknowledge [2]
153/2 166/9
across [15] 8/16
16/18 27/11 28/25
52/20 53/4 65/2 68/5
76/19 91/18 95/20
95/22 95/24 120/19
126/23
act [5] 8/2 23/2 52/2
64/10 120/11
acting [2] 30/12
69/22
action [8] 28/11 30/1
39/1 42/7 51/11
121/25 122/6 122/10
actioned [1] 61/14
actions [2] 74/12
110/8
activities [5] 28/21
32/23 38/16 41/4
93/12
activity [10] 8/9 54/7
61/20 62/13 62/21
62/23 63/4 64/2 64/4
99/16
actually [10] 29/4
44/10 54/22 70/3
122/11 144/3 151/6
156/21 161/6 163/10
acutely [4] 22/3 35/9
70/16 129/21
add [1] 108/6
addition [3] 10/4
19/25 96/3
additional [5] 71/1
71/2 82/24 114/18
149/5,
address [8] 58/9
60/10 64/15 93/7
94/19 109/19 134/10
159/24
addressed [4] 34/13
56/16 64/12 94/25
addresses [1] 56/20
addressing [5] 5/6
26/20 26/24 27/3 27/3
adequate [3] 81/5
81/6 134/12
adjourn [1] 166/24
adjourned [1] 167/4
Adjournment [1]
89/7
administer [1]
139/12
administered [1]
20/4
administering [7] 2/2
2/9 2/11 3/17 28/21
144/23 147/15
administration [3]
3/2 108/23 112/16
admit [2] 84/14 84/14
admittedly [2] 25/24
142/12
adopted [5] 18/19
64/1 83/7 84/10
165/15
advance [1] 11/23
advantage [1] 127/24
adversarial [1] 144/6
advice [10] 59/21
60/7 60/10 60/17
135/15 139/3 140/7
140/9 142/8 158/13
advise [2] 133/15
139/11
advised [4] 32/21
137/17 138/11 139/2
advisedly [1] 149/21
advising [2] 137/20
164/15
Advisory [10] 39/6
39/9 39/17 40/23 41/9
49/6 49/7 154/12
154/16 155/4
affairs [3] 72/8 124/8
150/13
affected [1] 107/11
afflicted [1] 107/12
afford [1] 24/7
after [13] 9/19 9/21
26/3 31/2 72/13 73/14
73/15 103/7 104/10
116/3 116/4 132/1
138/5
afternoon [6] 5/6
89/10 89/11 122/16
125/4 125/5
again [13] 4/13 25/13
64/11 66/1 85/21
104/18 108/10 108/16
127/24 137/15 148/8
148/17 156/17
against [12] 23/10
30/5 42/8 74/13 108/5)
117/21 118/5 125/8
131/23 133/20 153/21
164/1
age [2] 7/7 132/24
agencies [11] 5/8
5/19 9/17 13/10 13/15
13/22 14/3 19/1 19/13)
19/24 21/2
agency [1] 7/22
agenda [1] 73/22
Agents [1] 53/16
aggravated [1] 141/7
agile [1] 8/2
ago [6] 53/8 68/25
103/22 108/9 114/17
119/22
agree [55] 2/3 2/15
7/6 12/8 19/5 25/11
25/22 26/4 26/9 65/7
79/8 86/21 88/13
88/20 90/6 91/20
92/11 92/19 93/22
96/12 96/15 96/18
96/22 105/1 106/16
110/14 116/16 117/19]
118/14 122/25 126/4
126/7 126/13 126/24
127/1 127/10 127/12
127/16 128/2 132/14
133/9 134/15 135/2
135/11 135/17 137/1
138/9 139/7 141/19
150/13 156/16 158/3
164/12 164/23 166/12
agreed [6] 65/1
101/17 120/24 139/10
149/13 151/10
agreement [3]
120/21 149/3 151/5
agreements [1]
49/15
aid [2] 8/6 84/4
aim [3] 31/13 109/19
166/20
aims [1] 33/4
Al [1] 104/6
Alan [1] 143/3
alert [1] 154/10
aligned [2] 119/14
146/12
Alisdair [1] 103/22
alive [1] 159/24
all [44] 10/17 11/4
16/3 22/3 23/19 37/9
59/5 63/23 75/12 76/8
79/13 79/15 81/14
81/16 81/17 81/23
87/4 87/17 87/21 88/5
88/7 94/15 105/8
112/21 114/5 120/13
121/7 121/18 122/11
124/11 126/13 141/12)
144/13 146/14 148/13}
150/5 150/14 151/21
156/25 157/7 160/6
164/8 164/14 164/15
all-embracing [1]
124/11
allegations [10]
38/19 52/2 62/7 63/18
64/9 74/14 117/21
117/25 118/5 118/7
alleged [9] 80/19
81/18 81/21 81/25
82/1 82/7 82/17 82/23)
136/3
allow [1] 93/23
allowance [1] 150/4
allowed [3] 146/23
161/3 162/12
allows [2] 94/20
121/21
almost [1] 71/24
alone [1] 141/12
along [2] 5/14 62/23
alongside [2] 1/20
110/22
already [9] 2/13 16/6
42/11 78/23 139/2
144/8 144/22 158/12
163/14
also [38] 3/9 7/7
10/13 11/16 15/3
20/22 28/19 30/22
31/10 35/14 40/21
65/25 69/15 74/17
79/15 83/18 85/9 97/6
103/5 107/11 110/15
112/2 112/11 113/11
118/23 120/20 121/8
122/5 123/8 131/21
144/14 152/2 154/19
157/9 159/9 159/18
163/18 166/9
alter [1] 82/19
alternatively [2]
82/10 82/14
although [5] 23/19
36/9 36/15 54/10
131/24
always [4] 3/16 1127/5]
112/5 125/23
am [19] 1/2 29/6
29/13 29/18 30/21
52/8 52/10 85/21 90/4
108/21 123/8 128/23
132/15 135/6 140/3
157/8 160/18 160/23
167/4
ambiguity [1] 101/23
amongst [6] 5/14 7/2
28/3 36/20 37/2 71/14
amount [4] 80/24
92/12 111/25 144/19
amounts [2] 20/2
74/10
analogy [1] 104/6
analysis [5] 8/18
17/14 17/21 46/25
82/5
Angela [2] 53/2 53/12
annex [1] 96/11
annual [1] 121/16
another [3] 107/7
134/10 157/18
answer [9] 4/23 40/7
41/24 41/25 48/4
62/15 114/1 114/5
141/21
answered [3] 98/9
106/6 110/18
answering [1] 85/6
answers [2] 86/20
113/5
anti [1] 67/13
anti-postmaster [1]
67/13
Antony [1] 66/18
any [63] 2/3 2/9 3/25
6/8 9/19 10/7 11/2
11/2 13/14 21/22 24/4)
24/9 31/17 33/20
36/18 37/16 42/4 42/5I
42/8 57/20 58/8 58/11
58/18 59/25 60/9
61/13 61/16 61/21
62/4 62/7 66/19 74/2
80/8 80/23 81/4 81/18)
81/21 81/22 81/24
81/25 82/22 84/1 87/7
88/19 90/17 112/7
122/8 122/8 122/11
123/12 129/14 129/18)
131/22 133/16 134/2
136/1 136/15 139/6
140/14 150/16 152/23)
153/9 163/19
(44) accepted... - any
A
anybody [3] 62/6
68/17 153/17
anyone [3] 20/5 30/4
42/8
anything [12] 4/1
24/11 28/23 40/16
40/19 49/2 62/15
62/16 67/1 69/1
153/10 157/24
anyway [5] 10/22
77123 124/13 138/24
158/3
anywhere [1] 139/23
apart [3] 66/18
150/14 156/1
apology [2] 74/17
128/23
appalling [3] 127/8
127/21 156/15
apparent [8] 31/3
71/13 81/18 81/21
81/24 82/1 82/8 82/23
appeal [10] 25/2
135/16 135/21 135/22)
136/9 136/13 136/18
137/4 142/14 155/11
appeals [6] 42/5
135/9 137/4 139/1
159/19 166/2
appear [5] 36/23
50/19 50/21 131/20
163/17
appearance [2]
45/25 82/7
appeared [2] 36/22
94/1
appellate [1] 134/21
appendix [7] 34/20
139/21 139/24 139/25)
140/17 158/10 160/24
Appendix 1 [1]
160/24
applicant [1] 139/19
applicants [5] 158/16
161/5 161/23 162/6
162/25
application [8] 132/2
132/3 136/23 143/4
156/12 159/6 159/9
159/18
applied [1] 12/17
applies [1] 128/4
apply [5] 28/10 96/3
159/7 159/10 163/4
applying [1] 156/13
appointed [2] 38/11
68/17
appointment [4]
38/12 53/9 80/7
163/23
appraised [1] 33/22
approach [18] 8/19
8/25 9/13 9/16 11/9
11/11 11/23 12/8
16/19 18/19 33/6 44/1
51/10 51/16 83/6 84/9
130/21 165/15
approached [3] 8/19
16/20 83/2
appropriate [14]
14/25 25/4 25/13 30/8)
42/13 63/25 68/3 73/5
76/17 85/4 110/3
110/4 151/25 152/4
appropriately [1]
99/6
approval [7] 6/5 6/12
6/12 9/25 12/9 12/11
123/6
approve [4] 13/3
13/24 19/6 20/6
approximately [1]
29/7
April [5] 1/19 95/1
120/7 121/14 136/10
are [191]
area [5] 30/21 43/15
52/23 89/18 95/20
areas [9] 56/13 96/24
97/2 97/3 99/4 99/6
99/10 99/15 102/16
aren't [5] 68/3 76/16
98/15 106/3 137/19
argue [3] 159/15
159/15 165/12
arguing [1] 49/8
argument [1] 159/25
arisen [1] 132/10
arises [1] 23/22
arising [2] 1/9 13/7
arm's [1] 146/23
arose [2] 47/1 84/12
around [21] 26/25
34/11 37/7 40/20
48/13 54/5 54/24 55/2
55/5 86/10 86/11
87/16 91/4 97/19 98/8
101/15 103/1 103/12
111/5 113/4 113/16
arranged [1] 24/19
arrangements [2]
40/15 40/19
array [1] 140/7
arrests [1] 22/25
arrival [1] 112/10
articulate [2] 102/2
154/16
as [226]
as successful [1]
94/9
aside [3] 90/20
133/10 136/22
ask [15] 1/9 4/13
34/18 68/4 81/11 82/9)
110/21 111/7 124/21
134/14 141/14 142/5
148/23 149/23 160/2
asked [11] 11/22
16/12 57/1 75/9 78/17
104/13 110/18 113/25
114/16 120/21 147/24)
asking [7] 24/9 49/1
58/5 64/1 86/19 113/3)
161/13
asks [1] 120/17
assess [1] 127/7
assessing [3] 11/17
18/4 18/5
assessment [2]
35/22 64/15
assiduously [1]
158/18
assist [2] 6/7 99/3
assistance [4] 59/10
60/7 60/10 60/17
assistant [1] 24/14
assistants [7] 57/16
58/16 58/19 60/8
79/16 79/24 80/3
associated [14]
18/21 20/19 36/25
70/17 92/15 102/24
104/4 105/21 108/12
112/2 117/15 122/6
130/14 150/24
Associates [1] 158/8
association [1] 61/1
assume [3] 42/19
90/13 150/12
assumption [3]
18/11 36/7 135/4
assurance [14] 13/5
13/6 14/14 14/15 15/2
15/2 19/22 20/16
20/17 21/8 21/9 21/14
83/16 85/1
assure [2] 166/20
166/22
assuring [2] 14/16
20/20
at [164] 2/17 4/24
5/10 5/21 6/2 6/3 6/9
9/8 11/7 11/23 12/20
13/8 13/20 14/2 14/21
15/20 17/4 17/5 19/13}
20/22 21/18 21/23
22/14 22/16 24/19
24/19 25/18 27/7
27/17 29/6 29/8 30/2
30/4 30/5 31/25 32/4
32/12 33/7 35/17 36/9
37/9 38/9 38/10 39/6
39/10 39/18 40/18
40/25 41/6 41/6 41/13
41/18 44/7 45/14 48/4
48/14 51/24 53/7
53/14 54/13 56/7 58/5
62/3 62/10 62/12
62/19 64/8 64/18
65/12 65/15 65/19
66/5 66/5 66/15 68/21
69/7 69/16 70/13
71/13 71/18 71/18
71/19 71/22 74/8
76/11 78/22 79/7
80/15 81/22 84/22
85/3 85/23 87/2 87/19)
89/20 91/10 91/15
93/21 94/13 94/23
96/3 98/5 98/16 99/20)
99/22 100/13 100/15
101/5 104/14 105/8
105/12 105/16 105/18}
105/18 105/21 108/15)
109/3 109/4 111/19
111/22 111/22 111/23
112/15 112/19 114/9
115/21 116/6 116/23
116/23 117/3 118/8
118/24 120/3 121/8
121/16 122/11 122/20}
122/21 123/8 123/16
125/23 128/10 129/13
131/16 132/22 138/15}
138/23 143/5 144/13
145/15 147/17 147/19}
147/25 150/16 151/13
156/9 157/5 157/13
159/18 160/16 160/17}
161/2 162/9 165/20
ATM [2] 132/10
132/19
atrocious [2] 125/12
162/8
attached [1] 8/22
attacked [1] 157/6
attained [1] 127/3
attempt [1] 127/1
attended [2] 1/20
126/21
attention [2] 39/21
166/17
attitudes [1] 153/19
attributed [2] 80/20
81/18
attrition [1] 142/19
audit [2] 29/19 54/7
audited [1] 131/9
auditing [3] 31/6
31/19 32/23
auditors [1] 47/9
August [2] 21/12
56/8
author [3] 5/25 36/2
36/6
authorisation [1]
6/23
authority [2] 54/6
150/17
authors [1] 37/2
automatic [1] 131/24
autonomy [1] 50/1
autumn [1] 122/1
availability [4]
148/17
available [8] 59/5
60/7 82/6 92/12 92/18)
96/10 149/6 149/7
avenues [2] 59/5
93/8
average [3] 157/14
157/21 158/1
avoid [2] 67/13 128/9
avoiding [1] 147/22
awaiting [2] 8/15
16/18
award [2] 135/1
139/5
awarded [1] 141/9
awarding [1] 117/9
aware [22] 22/3 28/5
29/6 29/13 30/21 35/9I
36/24 37/15 37/18
61/15 95/2 139/24
139/25 139/25 140/4
140/6 140/18 151/18
155/8 157/8 158/7
158/9
away [2] 4/4 4/11
B
back [27] 10/10
11/25 12/19 22/11
27/5 27/13 41/10
41/14 49/11 50/2
50/16 61/11 61/19
61/24 62/20 63/16
64/2 64/8 67/22 72/6
74/1 76/10 99/20
117/13 148/16 149/4
155/2
background [3]
27/22 30/24 109/8
backing [3] 103/15
103/21 106/5
bad [1] 40/17
balance [4] 63/25
64/1 70/1 110/13
balanced [1] 9/3
balances [1] 11/4
balancing [1] 59/10
banging [2] 137/23
138/6
banking [1] 93/13
bankruptcies [1]
157/19
bankruptcy [1]
157/24
banks [2] 98/6
110/25
bar [2] 133/25 163/11
bare [1] 86/23
Bartlett [7] 6/1 12/24
17/24 18/2 19/6 20/9
29/17
base [1] 91/18
based [5] 8/14 8/15
16/18 117/11 155/19
(45) anybody - based
B
basic [3] 105/3
110/15 111/16
basis [10] 25/24
35/19 35/21 54/1 72/9
83/12 97/16 100/25
106/22 125/16
Bates [2] 10/19 143/3
be [235]
bear [2] 11/15 97/6
became [2] 31/3
32/18
because [46] 1/20
3/17 5/17 16/3 19/18
30/17 31/22 34/6 55/4
61/25 78/16 84/13
84/15 90/13 106/12
113/9 124/6 124/18
127/21 128/18 129/12)
132/9 133/1 133/11
134/24 136/16 139/3
140/9 140/22 142/11
144/11 144/13 144/15)
146/12 150/14 152/8
152/9 153/14 153/20
155/11 156/3 157/7
157/10 159/19 160/1
164/22
become [1] 157/10
becoming [1] 69/21
been [136] 2/23 3/1
3/23 4/6 4/21 5/1 6/24,
8/4 10/19 17/10 21/9
21/12 27/14 28/5
29/12 29/23 32/10
32/15 32/22 33/11
33/18 33/22 33/25
36/11 36/23 37/7
37/10 37/15 38/4 41/5)
41/12 41/14 43/12
45/7 46/24 46/25 48/4)
48/6 49/1 51/17 52/1
52/23 55/9 61/18
63/10 63/18 64/7 64/8
64/22 65/8 65/10
65/10 65/12 67/19
71/23 72/16 74/16
74/24 84/20 87/23
91/8 91/8 94/9 95/1
97/18 97/22 99/18
99/21 103/23 104/12
106/6 106/9 107/16
107/17 107/18 112/3
112/7 112/10 112/14
113/7 116/9 116/20
117/25 118/3 119/2
119/3 122/21 122/23
123/9 123/12 123/14
129/3 130/22 132/8
132/11 135/6 135/9
135/12 135/17 137/23}
138/6 139/2 140/2
140/10 140/16 140/23
142/7 142/22 145/9
149/3 149/12 149/13
149/22 151/2 151/3
153/13 153/19 154/9
157/13 158/6 159/14
159/23 160/4 160/25
BEER [8] 1/4 1/5
16/2 26/9 75/3 76/9
166/25 168/4
before [44] 5/17 5/21
6/20 13/8 17/13 21/1
47/15 47/21 47/22
70/20 71/16 71/24
75/3 117/2 119/22
129/2 129/8 130/24
131/12 132/7 135/23
161/3 161/9 162/11
162/20 164/11
begin [2] 1/9 126/8
beginning [2] 47/25
128/10
behalf [4] 56/9 62/17
62/25 140/21
behaviour [2] 107/8
111/25
behavioural [1]
120/7
behaviours [4] 27/8
30/13 98/4 120/12
behaviours' [1]
120/23
behind [3] 1/24
119/14 161/24
being [76] 6/9 6/20
8/7 11/23 13/14 13/17
13/23 14/23 16/13
17/2 18/11 18/15
18/19 20/3 28/6 28/19
31/9 31/23 33/6 35/2
37/8 38/11 41/1 44/20
51/21 54/8 61/14 62/7,
66/1 67/14 71/3 71/15)
76/5 76/7 77/6 77/14
86/3 90/14 93/6 97/24
102/7 102/8 103/10
105/24 108/3 116/12
116/13 117/9 121/4
121/23 128/17 130/4
133/17 134/11 135/3
137/4 137/4 137/17
138/11 140/18 140/19)
140/21 144/10 147/17)
153/8 153/10 153/15
153/17 155/8 157/5
157/6 157/15 161/15
145/21 145/23 148/24,
152/10 152/24 152/25)
162/10 164/11 165/10)
165/13 166/10 166/11
21/2 24/9 29/10 33/23
36/22 37/9 37/16 42/6
47/24 51/20 53/8 66/4
128/11 128/11 128/19)
136/18 142/12 142/15)
162/20 164/1 165/2
BEIS [1] 39/8
BEIS0000739 [1]
44/9
BEIS0000753 [2]
65/19 76/11
BEIS0000846 [1]
39/6
BEIS0000848 [1]
41/18
belief [6] 2/1 35/18
believe [20] 9/2 19/8
29/3 41/12 69/19
75/19 78/7 118/24
130/21 130/23 148/4
154/8 154/10 160/1
161/25 166/7 166/8
believed [1] 73/13
below [1] 30/23
Ben [1] 67/3
beneath [1] 66/13
benefit [1] 49/12
benefited [1] 11/4
benefits [2] 110/13
111/5
besmirch [1] 145/7
best [4] 37/5 62/8
63/11 70/9
better [12] 14/9
15/24 18/20 18/20
18/20 18/22 28/24
31/17 120/4 147/5
160/1 166/1
between [19] 11/6
11/13 13/18 21/23
42/19 42/22 44/8
98/21 100/2 105/18
124/21 145/11
beyond [3] 86/23
152/15 152/20
big [4] 49/17 51/4
68/15 116/14
bigger [3] 14/10
14/20 157/25
Biggest [1] 49/25
bill [4] 148/2 148/10
148/12 148/25
bit [16] 34/23 45/11
45/18 47/18 51/3
54/19 66/1 66/12
67/15 76/14 78/22
124/6 124/10 133/12
139/20 150/21
bitter [4] 125/8
bizarre [1] 162/13
Blakey's [2] 152/7
156/2
blind [1] 117/16
blink [1] 137/21
blocking [1] 133/5
35/25 36/8 36/12 37/6)
152/25 153/22 153/22
65/20 70/2 70/6 84/23
122/12 123/12 123/14
bluntly [1] 114/13
blur [1] 77/25
blurred [1] 34/16
board [101] 6/9 6/13
6/23 7/17 7/23 8/19
13/21 15/4 15/9 15/11
15/13 15/15 15/20
16/6 16/12 16/19
17/17 19/7 20/7 21/3
30/2 30/4 30/9 39/6
39/9 39/17 40/23
64/13 64/21 64/24
68/12 68/17 68/18
68/18 70/8 71/5 71/6
71/13 71/21 71/24
72/2 72/11 72/15
72/21 73/2 73/15
73/19 74/2 75/15
75/20 75/21 75/24
76/24 77/3 77/9 77/9
77/12 77/16 78/14
101/19 101/21 102/3
102/9 102/15 103/24
109/4 109/5 111/10
115/25 117/3 118/17
119/13 119/21 119/24
122/24 137/7 140/20
142/13 142/16 154/12)
154/16 155/4
Board's [5] 13/9 41/9
101/13 102/10 102/12)
body [2] 131/14
146/23
Bogerd [5] 53/2 53/3
53/12 54/16 55/11
bonus [1] 117/14
bonuses [1] 117/10
Book [2] 6/18 7/12
borne [2] 100/5
153/8
both [16] 9/25 19/20
19/21 20/21 27/22
28/3 62/11 68/24
107/22 114/17 114/18
120/14 144/24 152/1
154/25 166/17
bottom [5] 39/10
45/12 48/16 76/22
76/22
boundaries [1] 78/1
box [3] 34/17 127/6
139/19
branch [22] 24/14
52/17 52/21 53/5 54/5)
54/23 55/6 82/20
83/15 83/25 84/3
84/23 85/11 85/14
87/25 92/6 92/11
92/22 99/12 121/18
11/24 12/9 13/5 13/13)
40/25 41/6 41/8 41/10
41/14 45/15 49/6 49/7
65/8 65/14 67/4 67/10
100/16 100/24 101/12)
136/4 136/7
branch-generated [1]
92/22
branches [19] 55/2
60/1 60/4 82/15 84/6
92/20 96/10 96/24
97/2 97/3 97/6 99/3
99/5 99/12 99/13
100/8 105/3 106/19
113/14
brand [2] 110/5
113/21
breach [2] 126/4
141/13
breached [1] 150/25
break [8] 52/6 52/9
89/2 117/2 122/16
124/13 124/14 124/24)
breakdown [1] 15/20
Breeden [1] 54/15
bridges [1] 74/5
brief [1] 39/24
briefed [2] 53/1
55/21
briefly [2] 133/11
163/14
bring [10] 18/3 18/4
49/11 64/23 65/12
68/12 71/4 121/22
136/24 155/7
bringing [3] 50/20
65/13 112/21
brings [2] 11/14
126/11
broad [1] 22/17
broader [4] 15/2
34/11 78/5 105/15
broadly [2] 14/22
113/8
Brocklesby [1] 5/14
broken [1] 125/7
Brooks [1] 42/18
brought [8] 21/22
47/9 51/13 112/11
119/23 135/9 135/16
164/1
brushed [1] 127/13
brutal [1] 126/4
budget [1] 104/17
bugs [6] 9/10 10/24
60/2 60/5 82/11 87/21
build [4] 3/12 74/5
112/9 121/25
built [2] 2/14 2/14
bullet [1] 91/15
bullying [1] 117/21
bureaucracy [3]
153/6 153/16 153/25
bureaucratic [1]
153/1
business [42] 4/4
11/11 23/23 29/20
32/10 32/15 35/17
35/24 48/20 50/20
(46) basic - business
B
business... [32] 51/5
59/7 67/18 68/3 68/6
71/17 71/20 73/5 76/7,
76/17 76/20 77/1
77/20 91/1 93/14
94/18 96/20 100/23
103/4 104/1 104/15
109/10 109/20 114/5
115/22 117/6 117/12
119/20 120/1 138/17
148/8 162/1
business’ [1] 120/19
businesses [2] 111/1
113/2
but [140] 3/9 3/13
10/22 11/16 14/19
15/2 16/2 16/11 20/8
20/14 20/19 20/21
26/2 27/3 28/19 29/16
30/5 30/8 32/12 33/14,
33/18 40/4 40/16
40/21 42/7 43/15 46/7)
50/20 55/1 55/8 61/16)
62/7 62/10 63/20
69/15 69/19 69/22
7112 74/24 75/12
75/14 77/3 77/19 79/5
83/19 84/15 84/21
85/7 85/22 89/13 90/5
91/6 92/23 94/17 95/4
96/18 97/21 99/22
100/1 105/15 106/1
106/25 107/22 109/7
110/15 112/2 113/11
113/19 114/6 118/8
118/23 122/5 122/17
123/8 124/6 124/13
126/16 127/6 129/14
129/21 130/3 130/23
131/6 131/8 132/21
133/16 134/7 134/14
135/13 135/24 136/9
137/21 138/11 138/22)
138/24 139/3 139/21
140/2 140/10 140/16
140/18 141/4 141/9
141/19 142/7 142/13
143/15 143/22 144/14
144/25 145/25 147/24}
147/25 148/9 151/18
152/2 152/4 153/13
153/18 154/1 155/10
155/20 156/13 156/18)
156/21 157/20 158/6
158/11 159/10 159/23
161/15 163/3 163/10
163/24 164/15 164/23)
165/12 165/18 165/19
166/9
Butoy [1] 135/19
button [4] 85/13
85/15 85/17 85/20
buttons [3] 84/14
86/1 86/1
buy [4] 78/6 109/2
114/13 114/20
c
calculation [1] 82/20
call [4] 83/25 96/23
129/21 154/20
called [5] 55/20 77/5
97/8 120/8 157/5
calling [2] 146/15
147/6
calls [1] 59/24
came [8] 14/4 42/19
54/23 100/19 138/3
142/12 142/15 164/5
Cameron [2] 17/4
103/22
can [134] 1/9 3/12
5/5 5/10 5/24 12/19
15/4 20/17 22/7 22/14
22/20 22/23 22/23
22/23 27/13 27/17
30/15 30/24 33/5
34/21 34/22 36/15
39/4 39/10 39/11
40/19 41/18 41/21
42/1 43/17 44/7 44/10
44/21 45/1 45/11
45/19 49/2 50/4 53/7
53/10 53/11 53/24
54/10 54/13 54/16
54/22 55/8 55/24 56/7,
56/17 56/19 57/19
60/13 62/14 63/2
64/11 64/18 65/19
65/25 66/19 67/3
67/11 68/4 75/2 76/18
77/21 78/19 79/7
89/12 89/20 92/20
94/23 95/3 97/6 98/24)
99/3 99/9 100/18
100/22 101/7 108/23
109/1 109/3 109/4
109/6 113/1 113/18
113/19 114/1 114/9
120/1 121/3 121/20
121/22 121/24 122/7
122/16 122/17 122/17)
123/17 124/11 125/8
126/12 126/14 126/18)
127/14 128/14 129/13)
131/4 132/12 135/11
138/8 138/10 139/5
139/11 142/11 143/2
143/15 147/1 147/18
148/22 150/3 152/21
154/1 154/8 154/15
154/22 160/7 160/7
161/2 162/2 164/2
166/19 166/22
can't [9] 2/4 32/10
55/8 124/19 127/13
127/15 132/12 139/13}
147/19
candid [3] 137/6
140/22 144/15
candidly [3] 34/16
82/3 138/24
candour [1] 142/6
cannot [5] 11/3 30/16
53/23 85/10 161/22
cap [1] 140/14
capabilities [1] 8/24
capable [2] 119/19
119/19
Care [4] 120/10
careful [3] 141/13
156/17 158/18
carelessness [7]
79/14 79/16 79/23
83/1 84/11 84/19 86/7
Carl [2] 45/21 65/22
carpet [1] 127/14
carried [3] 35/16
35/23 80/18
carry [6] 10/10 57/23
59/23 60/3 60/6 109/9
carrying [1] 35/9
case [32] 2/5 10/18
14/19 15/21 16/13
17/16 18/14 29/10
52/1 69/19 73/18 86/9
86/14 107/21 130/22
130/24 131/7 132/15
133/24 134/14 135/12
135/20 136/14 136/24
139/8 148/8 151/25
153/24 157/6 161/15
163/9 163/25
cases [24] 8/20 12/5
12/5 15/15 17/9 17/18
19/16 23/21 29/7
29/12 31/8 31/21
35/14 35/22 131/6
131/20 132/17 137/18}
137/25 138/7 148/22
150/5 155/7 163/18
cash [3] 79/10 93/13
156/24
cashpoint [1] 131/25
Castleton's [1] 163/9
caught [1] 36/11
cause [4] 80/19 82/2
88/22 148/23
caused [13] 2/23 3/1
19/17 19/18 79/14
79/15 80/3 84/15
84/17 145/21 145/23
153/19 154/5
causes [7] 11/2
81/21 81/24 82/1 82/7
102/22 139/4
causing [2] 71/14
134/16
caution [3] 24/8
24/10 25/16
caveat [3] 7/7 10/13
10/16
caveated [1] 12/14
caveats [1] 48/13
CCRC [7] 137/21
137/24 138/7 155/1
155/6 155/7 155/10
CCRC's [1] 155/5
CCs [1] 45/21
cease [1] 80/6
celebrating [1] 46/8
cent [13] 25/25 92/6
92/9 93/19 94/7 94/8
94/15 115/1 115/4
115/5 120/24 120/24
120/25
central [2] 92/15
92/17
centre [4] 59/7 59/13
67/18 83/25
CEO [1] 72/15
certain [3] 10/16
66/15 102/16
certainly [47] 3/6
3/11 14/19 15/1 15/20)
21/19 22/3 37/15 41/7,
43/12 48/1 48/10
63/23 78/4 78/7 78/15)
83/4 87/14 88/6 89/4
98/18 102/22 103/5
107/16 107/22 108/21
116/25 117/12 117/17]
118/23 126/20 130/20}
134/2 134/7 135/11
138/4 142/8 149/3
153/11 155/2 156/9
163/12 163/12 165/14
165/19 166/4 166/11
cetera [5] 24/12
57/17 59/19 60/13
60/16
CFO [2] 45/1 51/3
chain [1] 54/20
Chair [4] 98/19
108/22 112/10 119/11
Chair's [1] 156/17
Chairman [11] 1/12
1/23 4/12 70/14 71/5
72/10 73/23 78/17
94/2 118/10 144/2
Chairman's [1]
160/21
challenge [14] 28/9
28/17 48/6 68/15
68/20 69/5 70/4 73/12,
76/1 76/6 104/1
120/10 146/14 154/16
challenges [6] 69/14
69/25 102/4 102/22
117/12 146/11
challenging [4] 68/12!
73/11 73/12 161/25
champion [1] 65/13
chance [1] 64/5
Chancellor [4] 154/5
154/6 154/10 154/18
change [13] 6/6 9/1
11/22 54/11 63/9
65/12 76/6 79/19 86/1
92/7 98/3 112/18
122/9
changed [10] 26/11
27/8 27/9 97/17 97/24
98/8 111/25 118/19
118/25 165/16
changes [9] 7/3
53/24 54/10 56/21
57/2 57/6 159/16
159/17 165/13
changing [3] 99/23
99/24 113/9
channels [1] 116/13
chaos [2] 2/22
145/20
chapter [1] 125/13
character [1] 145/7
characterisation [1]
72/1
characterise [2]
74/19 111/19
charge [1] 80/24
charging [1] 162/10
cheap [1] 156/7
check [1] 121/10
checked [2] 59/22
59/25
checks [1] 11/4
Chesterfield [1]
88/12
chicanery [1] 130/6
Chief [3] 45/4 45/5
118/10
children [1] 132/23
chosen [1] 109/17
Christmas [1] 122/4
Christopher [1]
39/12
churn [1] 114/16
Cl [22] 6/1 6/20 7/5
8/6 8/17 8/24 9/21
9/22 11/14 11/18
12/12 15/25 17/13
18/3 18/4 18/7 18/19
18/24 19/3 19/19
25/11 26/5
Cl [4] 26/21
circumstances [4]
70/15 71/9 86/24
100/19
civil [1] 45/14
claim [14] 51/13
130/8 130/10 130/18
139/12 139/19 140/24)
142/8 143/15 143/20
144/16 144/17 144/17)
159/11
claimants [4] 133/19
133/23 139/11 139/22!
(47) business... - claimants
Cc
claims [12] 129/7
129/15 130/4 133/18
133/19 133/23 147/22)
157/14 157/20 157/25
159/2 160/19
clarify [2] 109/14
122/17
clarity [8] 101/12
101/20 102/4 102/7
102/14 107/23 112/23}
114/7
Clarke [1] 135/14
classified [1] 85/18
clause [2] 80/4 80/13
clause 13 [1] 80/4
clause 20 [1] 80/13
clauses [3] 79/8 80/5
80/10
clauses 12 [1] 80/5
claw [4] 142/15
clear [30] 11/25
24/10 27/4 28/13
28/18 42/2 43/17 46/4
52/1 61/13 62/11
63/18 64/7 75/3 86/23
91/17 93/1 93/6 94/2
98/10 105/9 106/11
109/11 109/16 109/20
145/9 155/13 155/14
162/14 162/22
cleared [1] 136/10
clearer [1] 113/12
clearing [1] 23/17
clearly [26] 4/17
20/10 22/4 39/1 48/20)
63/11 73/19 75/1
83/15 83/25 84/5 91/5
104/20 105/12 108/18}
111/24 116/9 122/13
123/20 132/18 141/10
146/11 159/4 159/23
162/4 162/17
CLEP [2] 6/21 7/12
CLEP" [1] 6/17
clever [1] 130/4
client [1] 135/19
close [1] 29/4
closed [2] 98/6
153/15
closing [2] 98/5 98/5
closure [3] 133/5
152/18 152/21
Co [1] 97/9
code [3] 23/25 87/18
100/23
cohesion [2] 71/5
74/1
cohort [2] 35/23
125/6
collaborative [1]
9/13
Colleague [4] 115/3
1415/7 115/12 120/17
colleagues [25] 14/4
19/22 20/22 28/1 28/4
28/9 28/16 28/20
31/15 35/10 36/20
46/15 63/24 77/13
116/1 116/8 116/12
116/15 118/1 118/3
118/8 119/14 120/14
120/17 120/20
collective [2] 30/3
65/1
collectively [2] 6/18
30/10
collegiality [1] 71/12
collegiately [1] 11/1
colloquialism [1]
137/19
combination [2]
65/15 104/9
come [30] 4/18 12/11
14/12 15/15 22/11
33/17 33/21 42/22
42/24 55/24 62/23
64/5 80/9 97/21
104/24 112/13 115/20)
120/1 123/25 131/4
134/3 139/20 152/21
153/23 154/13 154/17)
154/22 155/5 155/21
165/11
comes [3] 92/23
103/25 149/16
comfortable [1] 47/5
coming [8] 14/8
15/25 17/16 45/18
50/2 63/14 69/15
138/8
commas [1] 123/5
comment [1] 42/13
commentary [1]
159/14
comments [2] 3/11
41/19
commerce [1] 98/3
commercial [6]
93/16 108/13 110/24
136/22 137/8 137/12
Commission [1]
137/18
commissioned [3]
100/20 101/2 108/16
commit [2] 38/21
120/10
commitment [9]
46/14 97/11 97/14
105/2 105/22 106/6
107/6 166/3 166/5
commitments [2]
121/11 122/9
committed [4] 22/18
23/14 24/8 92/5
committee [9] 45/25
46/1 66/5 66/6 66/17
142/24 159/13 159/13}
165/21
common [5] 23/15
57/2 79/3 131/16
163/15
comms [1] 34/21
communicate [3]
4/15 82/10 82/14
communicated [3]
3/25 162/4 162/18
communication [1]
35/20
communications [3]
34/19 34/24 34/25
communities [2]
105/17 105/19
community [5] 37/2
78/6 110/11 110/17
157/6
company [1] 132/6
company's [1] 126/5
compared [1] 99/4
comparing [1] 79/4
comparison [1]
136/5
compensate [1]
156/20
compensated [2]
126/19 157/2
compensation [42]
1/13 3/7 3/17 4/25
28/22 31/2 32/5 32/12
32/19 38/2 39/17
40/15 40/19 40/22
43/7 43/21 91/4 99/7
107/12 126/9 126/25
127/17 128/9 128/20
129/2 129/9 129/23
133/6 134/11 135/1
142/19 142/23 144/19]
145/3 146/19 147/22
149/21 155/23 165/2
165/19 166/18 166/21
competent [1]
141/20
competing [2]
110/24 146/8
Complaint [1] 160/20
complaints [1]
155/22
complementary [1]
108/2
completed [3] 42/6
43/11 122/24
completely [6] 27/10
78/6 83/6 102/20
131/21 163/19
completing [1]
158/13
complex [6] 6/19
43/15 84/4 157/23
158/4 159/11
complexities [1]
155/23
complexity [1]
159/17
complicated [3]
77/22 78/10 107/21
complied [1] 80/13
complying [1] 164/18)
comprehensive [2]
109/10 118/6
comprise [1] 23/19
computer [2] 128/18
136/2
conceal [3] 82/10
82/14 82/18
conceive [1] 29/5
concentrate [3]
129/11 156/14 156/18
concentrating [1]
144/3
concept [4] 34/12
77/8 77/22 78/2
concern [10] 27/24
32/4 32/14 43/9 70/23)
91/8 148/5 154/1
154/6 155/2
concerned [8] 30/10
69/21 70/18 70/20
100/16 143/7 144/5
159/20
concerning [7] 5/18
39/5 39/7 53/3 135/15
145/2 164/13
concerns [6] 22/17
40/14 40/22 41/1 43/1
148/2
conclude [2] 27/1
108/6
Concluding [1] 54/9
conclusion [7] 64/8
129/10 131/4 153/23
163/13 164/13 164/19}
conclusions [1]
118/13
concrete [1] 62/4
condemned [1]
138/20
conditions [3] 57/9
113/10 114/14
conduct [7] 23/1
23/24 24/1 25/9 26/6
70/21 141/12
conducted [9] 31/15
91/7 101/1 108/25
111/19 115/21 118/22
119/13 121/13
conducting [2] 24/23
122/7
conduit [1] 8/7
conference [2]
121/16 122/4
confidence [27] 3/18
28/3 28/25 31/9 31/24,
43/6 48/14 61/20
62/11 110/9 114/4
114/25 115/2 115/17
116/10 116/14 116/16
117/4 117/18 117/20
118/2 118/9 118/14
119/6 119/8 119/11
119/25
confident [3] 29/18
119/18 149/9
confirm [2] 3/11 97/6
confirmation [1]
105/1
conflict [7] 31/25
68/23 91/22 92/1
144/9 144/15 144/21
conform [1] 13/19
confrontation [2]
24/18 24/19
confronted [1] 24/17
confused [2] 34/15
146/7
confusion [1] 33/13
connected [3] 31/7
31/20 125/24
conscious [3] 38/15
70/16 129/22
consequence [10]
38/21 62/5 90/9 103/2
4112/1 113/11 113/21
122/20 149/10 159/5
consequential [1]
107/7
consequentially [1]
106/19
consider [4] 5/17
65/4 111/15 142/5
considerable [1]
69/6
considerably [4]
11/16 18/3 18/4 20/2
consideration [2]
82/6 139/6
considerations [1]
30/11
considered [5] 6/19
9/8 10/19 140/2
140/15
considering [2] 4/9
42
consistency [1]
55/10
consistent [6] 25/11
26/4 26/5 26/7 65/11
109/1
consolidated [1]
6/24
constant [2] 103/23
130/1
constantly [1] 69/3
constraints [1]
103/10
constructed [1]
26/13
consumer [3] 98/3
111/25 116/6
consumers [1]
(48) claims - consumers
Cc
consumers... [1]
105/18
contact [2] 60/16
72/3
contained [2] 33/3
94/25
contains [1] 90/1
contemporaneous
[6] 2/18 145/15
163/6 163/7 164/9
164/16
content [2] 72/11
108/17
context [11] 11/25
15/22 22/24 27/16
27/20 31/1 40/25
46/16 47/17 66/2
133/7
continuation [3]
105/4 106/5 106/16
continue [12] 5/5
13/23 59/15 60/19
60/19 60/20 60/20
63/22 64/10 92/9
145/6 152/16
continued [5] 1/3 1/4
47/8 168/2 168/4
continues [4] 11/5
35/4 40/13 41/8
continuing [2] 39/21
106/1
contract [24] 22/9
22/10 22/12 22/17
25/5 25/18 25/25
26/10 26/19 27/2 27/9
56/14 56/20 57/10
58/24 78/20 79/3 79/6
79/22 80/21 105/13
132/7 137/14 141/13
contracts [1] 27/4
Contractual [1]
58/21
Contrary [1] 23/2
contrast [1] 3/3
contributed [1] 28/6
contribution [2]
105/24 106/2
control [3] 91/16
91/21 103/1
controversial [1]
3/20
conversation [5]
2/18 4/6 41/6 43/8
130/2
conversations [4]
43/3 44/3 108/22
145/16
convey [1] 128/24
conveyed [2] 116/12
117/25
convicted [2] 154/25
156/21
conviction [1] 126/11
convictions [7] 22/25)
46/13 125/15 148/18
149/11 152/2 155/9
Cooperate [1] 81/20
Cooperation [2] 6/17
6/25
copies [1] 164/3
copy [1] 39/13
copyee [1] 54/17
core [6] 26/22 90/14
92/24 109/15 124/15
124/18
corporate [10] 3/21
3/24 4/14 44/20 56/9
61/6 62/1 62/9 62/18
72/8
correct [44] 7/24
9/23 20/14 32/3 34/3
43/20 43/24 44/23
45/17 45/20 45/22
46/18 46/20 52/18
54/18 56/6 62/22
66/22 66/25 67/8
73/17 79/25 80/2
88/25 90/19 91/6
95/14 97/10 115/14
122/22 123/7 123/11
125/19 126/10 128/5
128/13 142/4 142/17
150/11 151/12 156/22)
157/3 158/16 158/17
correspondence [5]
21/25 22/1 39/4 39/7
49/16
cost [6] 91/16 91/18
91/21 94/18 112/2
152/14
costs [6] 67/18 91/13
92/15 92/17 99/25
158/13
could [41] 2/14 11/10
19/17 29/11 31/17
46/6 48/14 50/23 52/6
54/4 61/20 74/11 76/6)
76/10 78/10 86/12
88/6 89/2 104/3
116/17 117/8 117/20
118/15 129/6 133/3
134/1 135/16 142/8
147/14 148/8 148/12
151/14 151/24 151/25)
155/7 160/5 160/5
161/10 161/17 161/17)
163/12
couldn't [2] 16/5
155/4
counsel [7] 6/2 7/5
9/25 12/12 18/1
137/20 138/11
counter [1] 136/8
country [1] 105/17
couple [5] 32/8 61/17
68/25 93/1 103/22
coupled [1] 106/17
course [22] 1/10
21/24 27/15 30/19
68/16 72/14 73/1
116/5 118/1 125/20
126/2 128/3 133/13
134/12 134/24 144/18I
149/25 154/3 157/9
160/10 162/18 164/7
court [13] 10/18
10/19 25/2 26/3
111/15 135/22 136/12
136/18 136/25 139/5
141/9 155/10 161/12
cover [2] 56/13
152/13
coverage [2] 56/24
58/6
covering [1] 10/6
Covid [1] 112/1
CPI [2] 94/13 94/14
CPS [1] 137/24
crash [1] 67/14
create [5] 31/24
34/13 51/3 54/2 71/11
created [3] 34/7 63/9
83/8
creation [3] 33/20
33/21 34/10
creditable [1] 64/25
Cresswell [1] 41/21
Creswell [2] 45/21
65/22
crime [3] 8/5 23/12
23/20
crimes [1] 23/13
criminal [13] 6/8 7/5
7/11 11/15 21/19 23/1
23/9 24/3 25/3 135/9
135/22 137/17 139/1
crisis [1] 112/2
criteria [6] 133/17
133/18 133/22 162/5
162/17 162/18
crite
ing [1] 140/8
ism [3] 147/10
158/9
criticisms [2] 72/17
147/19
crop [1] 136/2
cross [1] 23/4
cross-heading [1]
23/4
crossover [1] 123/12
crossreference [1]
78/23
crucial [1] 163/24
crushed [1] 126/16
crystallised [1] 32/19]
cultural [1] 107/8
culturally [1] 165/11
3@
culture [3] 38/10
107/2 125/21
current [18] 6/16
8/18 11/8 11/9 16/19
47/5 47/6 47/9 56/20
59/9 64/24 75/13 91/9)
108/7 108/9 108/22
109/14 110/3
currently [6] 8/14
16/17 31/16 58/3
96/13 106/3
curtain [1] 147/13
customers [1]
105/19
cut [4] 28/25 54/20
68/5 76/19
Cwu [1] 77/13
D
DA [1] 9/21
daily [3] 49/23
106/22 136/7
damage [3] 50/23
147/10 157/1
damaged [1] 116/10
damages [13] 135/1
139/6 139/8 139/17
139/19 139/23 140/5
140/10 140/23 141/2
141/7 141/11 159/2
Dan [1] 158/7
danger [1] 43/5
data [35] 7/15 7/16
7/20 7/21 8/17 8/20
9/16 10/3 11/3 11/19
12/4 12/11 12/13
12/14 13/6 13/10
13/14 14/14 14/17
15/2 16/21 17/8 17/14}
17/19 18/25 19/3 19/3}
20/16 20/20 21/1 21/9
21/14 82/19 128/15
132/10
database [3] 87/20
87/25 88/5
date [3] 5/25 66/5
149/22
dated [6] 53/8 54/16
89/25 95/1 100/18
109/6
dates [2] 4/25 11/3
Davies [1] 32/18
day [13] 49/24 61/11
61/11 63/7 63/7 64/2
64/2 64/24 83/11
83/11 131/11 131/15
167/4
days [6] 43/22 47/15
47/21 69/1 77/23
129/22
DBT [11] 17/8 41/22
49/11 107/15 107/20
108/16 123/15 123/20
123/22 123/23 159/19}
dead [1] 129/14
deaf [1] 117/16
deal [6] 94/3 107/16
133/11 148/11 155/20)
165/23
dealing [6] 42/4 50/1
137/15 142/9 151/24
158/15
dealings [1] 153/12
dealt [4] 23/13 25/1
163/14 165/2
death [1] 129/2
debate [2] 22/2 131/3
decades [1] 126/3
December [9] 1/18
10/17 31/3 32/5 38/3
38/5 43/19 54/16
144/2
decided [2] 33/1
152/11
decision [8] 10/1
19/5 20/6 30/3 72/19
106/20 140/2 147/7
decisions [1] 107/11
decisive [1] 30/1
decline [1] 19/5
declined [2] 13/3
13/24
dedicated [1] 115/9
deep [2] 144/13
145/13
deeply [6] 30/20
38/13 143/7 143/18
144/4 153/13
default [1] 125/22
defects [4] 60/2 60/5
87/21 136/4
defence [3] 21/19
50/20 118/2
Deficiencies [1]
7917
define [2] 120/12
146/11
defined [2] 81/3
141/10
definitely [3] 37/1
137/11 149/10
definition [6] 63/7
73/21 102/22 118/8
147/3 152/19
Definitions [1] 56/17
definitive [1] 86/20
degree [7] 85/1
115/25 118/2 136/11
147/16 164/21 165/4
delay [10] 79/18
133/10 135/8 142/13
142/18 145/2 148/23
149/2 153/19 155/19
delayed [4] 129/15
134/20 137/4 138/25
delays [1] 129/20
deliberate [1] 155/19
deliberately [1]
(49) consumers... - deliberately
D
deliberately... [1]
134/20
deliver [5] 40/19
49/12 105/11 108/4
113/19
delivered [1] 100/10
delivering [3] 57/22
58/4 101/5
delivery [3] 91/18
98/7 99/7
demand [1] 164/16
demonstrate [1]
69/18
demonstrated [3]
18/15 120/18 121/4
den [5] 53/2 53/2
53/12 54/16 55/11
deniability [1] 147/18
denied [6] 129/15
131/21 134/20 155/18)
163/19 164/3
density [3] 96/25
99/4 99/5
dent [2] 116/14
117/19
dented [1] 117/17
department [14] 42/1
42/2 57/24 59/2 59/16)
89/23 90/21 108/3
108/9 108/25 146/5
147/1 148/5 148/9
departmental [1]
44/18
departments [3] 30/7
146/13 146/21
departure [5] 69/12
70/16 73/14 75/1
115/22
depend [2] 82/21
134/12
dependent [2]
133/15 140/9
dependents [1]
127/17
depending [2] 7/6
72/11
deprive [1] 136/25
deprived [2] 95/19
99/4
deputy [2] 9/24 44/12
derailed [1] 130/4
derived [1] 104/5
describe [8] 25/19
85/8 85/21 88/4 98/12
101/22 120/11 133/9
described [15] 13/17
25/8 35/7 48/7 71/1
77/7 77/15 78/9 85/25
102/8 105/13 113/11
131/15 140/13 159/20}
describes [4] 15/11
24/23 87/19 87/21
describing [4] 38/11
50/4 138/1 143/16
description [1]
147/14
deserves [1] 119/8
design [2] 155/20
163/11
designed [4] 110/24
134/4 152/17 159/2
desire [5] 2/24 24/17
63/3 106/10 145/22
desired [3] 162/3
162/15 162/21
desktop [1] 28/15
desperate [1] 133/9
desperately [1]
152/12
despite [2] 89/17
164/24
destroyed [2] 165/7
165/7
detach [1] 147/18
detail [5] 17/23 21/15
56/21 72/6 139/21
detailed [2] 64/23
96/11
details [6] 57/16
57/20 58/2 58/11
59/19 139/14
detected [1] 136/4
deter [3] 133/18
159/2 162/25
determination [2]
36/18 106/13
determine [1] 28/11
determined [1] 33/1
determining [3]
15/13 104/5 148/7
deterred [2] 156/7
156/13
deterrence [1]
155/19
detriment [1] 87/23
develop [3] 109/11
109/16 109/20
developed [1] 11/1
developing [1]
107/18
development [4]
53/16 56/4 76/4
137/13
developments [1]
9/16
devolve [1] 17/25
dictum [1] 138/19
did [36] 4/15 15/12
19/5 19/11 20/5 27/9
28/25 33/20 35/25
38/6 42/22 42/24
43/25 48/7 55/23
67/16 69/21 70/11
73/3 73/6 73/7 73/8
73/9 74/4 74/6 77/2
77/22 101/18 102/12
103/18 123/16 127/24I
136/13 137/14 155/10
164/25
didn't [19] 4/6 4/16
33/16 40/3 74/22
74/23 75/1 130/23
136/13 138/22 143/10
143/11 143/21 143/22
144/25 152/9 156/3
156/9 162/21
die [2] 129/8 129/13
died [2] 128/17
128/19
difference [4] 11/13
47/6 69/18 122/12
differences [2] 11/6
47/1
different [18] 18/18
28/2 29/17 46/14 83/6
83/9 83/9 83/12 83/13
84/9 119/1 122/13
122/14 136/17 146/8
146/9 146/13 153/25
differing [1] 9/7
ult [17] 4/2
30/20 69/12 70/5
70/14 78/2 101/24
102/2 102/6 104/16
113/7 116/21 116/22
116/24 120/2 163/3
164/2
difficulties [1] 164/8
difficulty [2] 3/16
164/17
dig [1] 138/13
isation [1] 98/2
dignity [2] 127/1
165/7
dimension [1] 134/10
diminution [2]
117/19 118/14
direct [2] 23/21 30/6
direction [5] 71/17
77/11 102/5 103/3
114/5
director [11] 6/1 7/4
9/22 12/12 55/21 56/5
56/11 67/23 70/3 72/8
77124
directors [20] 64/22
65/16 65/17 65/17
67/22 68/11 68/22
69/8 69/14 69/22
70/10 70/18 71/6 72/3
72/22 73/19 75/9
75/23 76/5 103/7
disadvantaged [1]
159/22
disagree [2] 20/5
141/20
disagreement [1]
84/22
disappeared [1] 55/3
disappointing [2]
74/21 118/21
disappointment [1]
125/8
disbanded [1] 29/15
disclosable [2] 21/18
21/18
disclose [1] 82/1
disclosed [4] 17/3
39/8 67/7 145/18
disclosure [13]
12/23 12/25 13/4 15/5}
15/12 15/14 17/10
19/16 28/21 70/25
125/18 135/14 163/4
disclosures [1]
10/16
discomfort [3] 2/25
14/7 145/23
discounted [1] 55/4
discovered [1] 143/9
discreditable [1]
145/2
discredited [2] 66/20
66/24
discrepancies [3]
19/23 82/17 83/22
discrepancy [2] 83/5
84/23
discuss [4] 11/22
106/8 134/7 143/22
discussed [11] 6/9
18/7 19/10 22/5 40/25}
41/5 71/3 74/15 92/25)
123/22 143/5
discussing [3]
104/21 155/3 162/10
discussion [6] 42/15
45/18 45/25 49/14
97/18 131/4
discussions [6] 30/2
42/19 42/22 42/24
56/1 87/14
disenfranchised [2]
71/7 7118
disgrace [1] 127/13
Dishonesty [1] 23/4
dishonour [1] 127/13
dismiss [1] 30/4
dismissed [1] 51/13
displayed [2] 13/23
72/16
disproportionately
[1] 100/5
dispute [5] 9/14 11/9
84/25 131/1 145/25
disputes [3] 130/13
130/16 145/2
disquiet [1] 71/14
disrepute [1] 50/20
disrespect [1]
135/24
disrespectful [1]
30/12
dissimilar [1] 111/21
dissolved [1] 132/8
distance [1] 51/4
distributed [2] 92/18
100/3
district [2] 96/4 96/6
districts [1] 97/4
disturbing [1] 164/19
iving [1] 72/19
Division [18] 22/20
23/5 23/8 23/11 23/14I
23/15 23/20 23/24
24/6 24/16 24/22
24/24 24/25 25/3 25/6I
25/11 25/14 135/23
do [126] 2/3 2/14 3/5
4/1 4/1 4/8 4/11 5/16
5/20 17/3 17/5 17/9
17/9 17/13 18/4 18/23)
19/3 21/4 21/13 24/12)
25/23 27/4 29/16
35/19 35/21 36/15
39/3 41/25 43/14
44/20 46/12 47/2 47/3)
48/22 49/2 49/3 49/3
49/9 50/9 50/17 53/25)
55/8 61/6 63/19 67/16I
69/18 71/4 73/24
73/24 75/3 75/15
75/19 75/19 78/6
78/25 83/3 83/16
83/22 84/5 84/20
86/10 86/11 86/11
88/1 88/2 90/12 92/23}
93/9 94/4 94/18 94/19)
95/5 96/12 96/14
96/15 96/17 96/18
97/14 99/3 99/6 101/3I
106/16 106/23 108/10)
109/24 110/1 110/10
110/15 115/9 115/10
117/8 118/24 119/17
119/25 121/8 125/10
129/14 129/25 130/11
131/2 132/12 135/2
135/17 138/1 138/1
138/19 140/24 142/3
142/20 146/22 147/11
147/24 149/23 152/7
152/17 154/13 154/14)
154/17 159/3 161/12
164/12 165/1 165/11
165/12 166/7 166/8
docudrama [1] 35/3
document [6] 34/20
36/2 142/8 160/3
160/4 164/16
documentary [1]
35/2
documentation [2]
162/5 162/19
documents [5] 13/7
158/11 163/6 163/7
164/9
does [24] 23/11
(50) deliberately... - does
D
does... [23] 26/16
43/9 51/15 56/4 78/1
78/2 80/6 86/5 87/6
87/9 97/11 101/21
110/12 110/23 133/8
139/11 139/15 144/14}
150/16 150/19 157/15
162/13 162/23
doesn't [8] 25/21
36/5 46/9 55/15 68/5
68/7 76/19 132/14
doing [25] 14/25
19/25 28/14 36/11
36/16 37/3 37/5 43/5
69/4 71/23 83/14
83/24 92/20 93/13
94/22 111/13 113/16
113/17 124/1 124/3
128/7 130/21 137/9
143/17 163/2
domain [1] 47/12
don't [75] 3/19 5/20
15/15 15/19 16/1 16/3}
17/16 17/22 17/23
19/4 20/8 20/8 25/8
25/17 33/10 36/6
36/18 43/3 46/8 46/10)
50/21 51/8 51/17
63/13 67/24 69/23
69/24 71/22 73/18
73/23 74/2 74/18
76/24 85/4 86/9 90/5
97/14 107/14 111/18
114/15 114/21 115/19}
118/20 118/22 129/17)
129/21 130/21 132/16)
132/20 138/13 139/2
139/13 141/8 141/24
142/2 142/10 143/14
145/25 146/20 147/24
148/4 151/18 151/19
151/20 152/25 153/7
153/17 153/22 153/22
154/8 158/6 159/10
161/15 161/16 164/14}
done [28] 3/12 4/17
26/19 26/20 27/12
31/9 31/23 38/4 42/14
46/9 46/11 46/25
50/23 62/10 63/15
64/3 69/4 69/4 74/11
87/22 94/11 101/1
113/14 140/19 140/21
149/19 154/11 159/5
doomed [1] 127/19
door [2] 137/23
138/6
doubt [4] 49/12 53/1
114/6 143/25
doubts [1] 43/9
dovetail [1] 108/23
down [23] 10/10
12/22 22/23 24/1 27/6
41/19 44/21 45/11
49/10 54/19 55/24
56/10 56/16 76/14
79/11 90/20 95/10
105/17 131/11 160/5
160/7 161/18 161/19
downgrade [1] 21/3
DPP [1] 137/24
draft [6] 6/25 7/1
8/22 9/1 9/4 10/14
drafted [2] 6/20
11/14
dragged [1] 51/21
drags [1] 128/3
drama [1] 165/20
dramatically [1]
97/25
dramatisation [1]
116/4
draw [4] 8/17 48/25
70/5 163/12
drawings [1] 93/20
drawn [1] 152/10
dreadful [1] 127/22
drew [1] 166/16
drive [4] 92/10 93/11
93/17 119/10
driven [3] 100/7
104/17 135/6
driving [1] 93/14
dual [1] 68/19
due [9] 9/7 9/15
79/17 101/14 102/11
116/17 117/8 117/20
118/16
duration [1] 104/4
during [5] 10/25
32/19 80/8 127/17
129/2
duties [8] 35/10
35/16 35/23 68/22
69/8 80/13 81/1 97/12
duty [2] 26/23 88/22
dyed [2] 153/20
165/5
dying [4] 128/11
dynamic [3] 64/23
112/5 112/7
dysfunction [1]
116/11
dysfunctional [1]
115/24
E
e-commerce [1] 98/3
e-learning [1] 86/10
each [9] 4/25 72/13
91/8 96/4 104/14
119/5 129/2 134/14
166/15
earlier [10] 3/11
19/12 54/14 63/17
99/22 131/15 154/21
155/18 156/18 160/6
early [2] 122/3 151/3
easier [2] 67/1 86/2
easy [3] 28/13 85/17
148/7
echoing [1] 142/18
economic [5] 95/7
96/11 99/16 105/14
110/13
economically [1]
99/11
effect [11] 9/15 55/3
79/2 81/13 85/13 87/3
100/23 138/13 145/19!
162/15 163/22
effected [2] 81/14
87/4
effective [3] 13/18
91/12 91/20
effectively [3] 50/3
75/22 140/1
effectiveness [7]
43/10 100/16 100/24
101/1 101/14 102/11
102/12
efficacy [1] 58/20
efficient [1] 91/17
efficiently [1] 50/9
eg [4] 110/11
eg make [1] 110/11
eight [3] 53/9 76/22
113/15
eight paragraphs [1]
76/22
either [13] 2/13 9/20
28/1 38/7 40/9 49/10
53/1 72/10 86/6 123/4
126/15 146/24 150/25}
elderly [1] 111/3
elected [2] 68/16
68/18
electoral [1] 40/4
element [5] 27/7
32/16 90/14 94/12
103/12
elements [8] 2/13
12/8 63/16 105/8
105/14 112/22 116/8
146/9
eligibility [4] 133/17
162/4 162/17 162/18
eligible [1] 139/9
Elliot [7] 55/22 67/16
69/6 114/17 118/16
118/21 119/3
else [6] 40/16 62/6
67/1 68/17 106/15
118/11
email [22] 10/8 39/11
41/20 44/11 44/19
53/7 53/10 54/14
54/14 54/15 54/20
54/20 55/14 55/24
67/7 69/13 70/19
70/25 71/3 121/18
164/5 164/7
emails [2] 61/10
61/17
emanating [1] 40/17
embracing [1]
124/11
emerge [4] 72/7 84/2
86/13 120/2
emerged [9] 26/21
29/8 36/20 38/22 61/8)
61/10 87/22 88/5
103/24
emerging [2] 38/25
83/13
emphasise [1] 140/8
employ [1] 35/4
employed [6] 23/16
23/22 29/15 31/16
48/9 48/20
employee [2] 37/12
51/14
employees [9] 31/4
31/10 31/25 35/15
35/23 60/25 115/13
115/14 119/8
employment [3]
30/19 51/8 51/13
emptively [1] 52/2
enabled [1] 135/9
enabling [1] 8/1
enacted [1] 61/16
encourage [2] 97/22
134/3
end [7] 47/15 47/21
51/8 51/12 58/25
69/15 122/18
ended [1] 46/19
ending [1] 51/12
endorsement [1]
101/19
enduring [1] 97/11
ENE [1] 151/3
energy [3] 119/10
152/9 156/3
enforcement [28] 5/8
5/18 6/7 6/17 6/22 7/1
7/4 7/15 7/22 8/3 9/2
9/17 10/13 11/12
11/20 13/2 13/10
13/15 13/22 14/3 15/6}
18/10 18/13 18/21
19/1 19/13 19/24 21/2
enforcing [2] 85/2
85/5
engage [7] 73/20
79/4 88/2 143/11
143/14 154/24 155/1
engaged [6] 43/7
55/25 93/12 112/15
123/20 165/16
engagement [12] 5/7
19/24 55/21 56/11
58/11 63/6 111/10
114/12 115/3 115/7
115/13 120/17
engaging [3] 13/22
19/14 143/19
England [1] 141/10
enhanced [1] 8/23
enormous [5] 74/9
111/24 115/23 143/6
154/5
enough [4] 35/12
54/7 67/16 92/20
enquire [1] 23/11
enquired [1] 155/6
Enquiries [2] 22/19
23/4
enquiry [1] 82/4
ensure [21] 28/2 43/5]
60/15 68/4 73/25
76/18 88/19 90/23
91/13 92/20 92/21
101/25 107/5 108/25
109/24 110/1 119/12
120/1 134/8 152/18
158/19
ensures [1] 64/25
ensuring [2] 17/18
90/7
enter [3] 55/6 161/10
162/12
enthusiasm [1]
119/10
entire [5] 72/11
130/10 130/18 131/21
163/18
entirely [5] 26/18
27/1 131/18 156/25
163/16
entitled [2] 159/4
160/10
entitlements [1]
156/4
entity [1] 110/24
entrepreneurial [1]
114/23
entrustment [5]
94/23 95/3 95/5 97/17
105/14
entry [4] 54/23
133/25 161/2 161/4
environment [5] 7/14
11/7 11/8 68/10 71/11
episode [1] 126/2
equation [2] 92/14
92/15
equivalent [1] 109/12)
era [1] 29/19
eroded [1] 103/8
error [9] 79/15 79/16
79/23 81/5 83/1 84/11
84/19 85/19 86/7
errors [11] 9/10
10/23 60/2 60/5 82/11
87/21 128/19 134/5
136/1 136/2 138/20
(61) does... - errors
E
essence [1] 99/25
essential [1] 145/10
essentially [9] 3/21
17/1 17/25 32/1 39/25
44/11 57/3 61/2
103/14
establish [2] 102/6
149/19
established [7] 30/16
80/16 131/23 137/22
149/12 151/2 151/4
establishing [1]
134/8
establishment [2]
153/3 153/4
et [5] 24/1257/17
59/19 60/13 60/16
et cetera [3] 57/17
59/19 60/13
etc [1] 53/24
evading [1] 127/25
even [20] 23/21
28/19 48/12 51/12
54/14 82/5 104/3
125/20 126/8 126/17
127/19 130/5 132/10
137/17 143/10 147/21
151/9 155/6 157/6
164/3
event [2] 74/18 81/25
events [4] 4/19 37/9
51/25 164/10
eventually [1] 104/10
ever [3] 130/8 131/23
151/16
every [6] 94/14 96/4
100/25 121/9 150/21
150/24
everybody [3] 70/15
73/25 109/1
everything [3] 3/12
106/15 164/25
evidence [38] 1/10
8/14 8/15 9/21 10/7
11/17 12/4 16/18 18/4}
18/5 24/1 24/6 24/20
28/20 29/8 29/10 30/6
38/19 38/25 43/21
52/14 53/2 62/2 62/4
62/17 62/24 63/14
73/13 75/6 85/12
111/20 122/19 128/10}
128/11 135/5 135/25
146/16 157/4
evidential [2] 10/9
25/15
evolve [2] 106/1
110/13
evolved [2] 111/11
130/17
exacerbate [1] 145/3
exactly [7] 62/6
62/10 69/25 97/16
154/14 159/20 161/20)
examine [1] 61/21
examined [1] 105/23
examining [1] 76/15
example [11] 21/16
37/20 94/5 104/6
107/7 118/5 133/21
153/3 156/5 161/13
163/5
examples [4] 31/18
86/12 86/20 153/6
exchanges [1] 72/22
excluded [4] 131/19
131/20 163/16 163/18)
exculpatory [1]
135/8
Execs [1] 77/21
execute [1] 149/9
executive [38] 5/11
6/3 6/15 33/7 33/17
33/22 36/9 64/21
65/16 65/17 65/21
69/14 70/10 70/18
70/21 72/3 72/4 72/22
73/21 75/8 75/22 76/5)
77/19 77/24 78/1 78/2
101/9 103/6 115/25
117/3 118/10 119/15
137/7 140/20 140/20
160/11 160/12 160/13)
executives [2] 73/16
119/20
exemplary [10] 139/6)
139/8 139/17 139/19
139/23 140/4 140/10
140/22 141/2 141/7
exercise [4] 28/16
79/4 112/12 127/6
exhibit [3] 7/16 7/21
13/11
exist [1] 96/13
existed [2] 11/7
125/21
existence [2] 6/20
25/5
existing [2] 30/17
94/5
exists [4] 11/14 87/6
88/22 145/6
exoneration [1]
148/17
expect [4] 40/6 42/7
99/17 114/16
expectation [1]
97/15
expected [4] 58/15
95/8 108/6 120/12
expecting [2] 105/10
106/11
expense [1] 103/18
experience [9] 2/25
11/15 18/13 18/21
58/2 59/19 73/10
126/20 145/23
experienced [1] 70/1
experiences [1]
60/13
experiencing [2]
82/16 88/4
expertise [1] 58/2
explain [3] 81/17
100/18 150/21
explained [3] 5/12
38/1 38/2
explicit [1] 4/17
explicitly [6] 38/16
38/17 38/24 73/18
113/16 143/3
exploited [1] 127/23
exploration [2] 52/19
52/23
explore [3] 62/7
62/14 63/17
explored [2] 52/15
64/4
exploring [3] 32/16
54/24 55/9
exposed [2] 67/25
74/13
exposing [1] 147/9
exposure [2] 69/13
70/19
expressed [6] 40/6
73/3 74/17 78/13
148/2 148/5
expresses [1] 24/17
expression [1] 25/10
extended [1] 135/3
extensive [1] 40/17
extensively [3] 93/10
154/11 159/13
extent [11] 35/5
58/15 60/4 61/12 72/2
72/18 72/21 82/15
100/4 129/19 164/20
external [5] 47/3 48/9)
101/2 101/3 108/1
externally [1] 120/14
extra [1] 10/21
extract [1] 9/4
extraordinary [2]
7/17 105/20
extremely [5] 43/15
67/25 113/7 133/16
161/24
eyes [1] 68/14
F
face [2] 98/7 98/7
faced [1] 69/6
facilitate [1] 128/8
facility [3] 52/16
52/21 53/4
facing [7] 61/19
62/13 62/16 62/21
62/23 63/5 118/17
fact [25] 14/12 15/13
17/13 36/10 36/16
37/4 53/14 55/12
56/11 64/3 70/5 76/10)
85/9 97/23 113/11
117/23 128/11 137/5
137/16 139/25 142/9
144/2 147/15 157/9
161/18
factor [4] 116/8
4117/1 127/11 134/18
facts [1] 82/6
failure [4] 4/8 93/5
93/7 107/5
Failures [1] 23/3
fair [37] 21/6 21/7
28/13 35/12 66/15
72/1 74/8 74/19 80/18
82/5 87/1 91/22 91/24,
92/2 97/1 97/5 107/9
107/14 117/24 126/6
126/8 127/20 129/10
130/19 134/9 135/4
136/12 138/18 139/6
141/1 143/1 145/9
146/4 148/3 165/4
166/19 166/21
fairly [9] 15/17 30/16
82/22 90/24 103/19
105/12 118/6 127/7
165/3
faith [1] 26/23
fall [4] 50/14 93/24
96/23 116/16
fallen [4] 115/4
falling [1] 115/18
false [3] 157/7
158/22 164/21
familiar [6] 69/11
90/3 132/15 134/13
158/6 158/25
familiarity [1] 52/12
family [2] 106/20
126/23
famous [1] 138/19
fan [1] 51/4
far [6] 29/12 37/15
95/2 109/22 150/14
163/24
fashion [1] 78/9
fashioned [3] 153/19
153/24 154/7
fast [1] 57/19
fatalities [1] 157/18
fatality [1] 157/24
fate [2] 129/12
131/15
fault [2] 9/9 125/23
feature [2] 65/14
116/20
features [1] 22/12
February [5] 66/7
66/10 76/13 115/21
121/13
fed [2] 41/10 41/14
Federation [1] 93/18
fee [2] 148/18 161/10
feedback [4] 58/11
60/13 122/14 165/18
feel [4] 30/22 40/3
46/9 119/18
feeling [2] 68/20
103/7
fees [5] 161/2 161/4
161/5 161/20 162/10
feet [1] 51/21
felt [7] 20/1 21/25
33/4 66/12 69/15
69/17 152/16
fence [1] 50/25
fenced [1] 83/18
few [5] 43/22 49/8
114/1 116/4 165/14
fictitious [1] 156/25
fight [1] 152/9
fighting [1] 142/14
fill [1] 142/3
filling [1] 141/24
final [2] 104/22
122/23
Finance [1] 45/4
financial [13] 3/7
45/6 50/6 80/5 82/12
91/12 91/20 92/8
106/20 107/12 110/25)
132/25 136/7
find [11] 19/11 67/5
70/11 101/9 112/23
125/9 127/24 128/24
143/13 155/4 159/21
finding [3] 43/16
101/11 101/17
findings [6] 37/20
59/13 101/10 101/18
108/18 122/25
fine [3] 63/25 124/20
166/23
finesse [1] 136/20
finish [1] 141/5
finished [1] 124/16
fire [2] 32/7 147/13
firmly [2] 3/4 149/13
first [27] 8/11 32/9
32/13 47/2 55/14
56/19 61/8 83/25
89/14 91/10 94/6
94/10 95/15 101/8
101/11 103/5 107/24
109/8 1114/9 111/11
111/19 112/12 115/6
120/3 132/6 153/4
155/16
firstly [4] 12/9 20/17
100/19 101/20
fit [3] 81/4 86/16
129/6
five [13] 26/2 98/15
98/23 104/10 107/17
109/21 111/14 111/24I
(52) essence - five
F
five... [5] 112/6 114/7
114/10 132/24 142/18}
fix [2] 48/12 55/1
fixed [6] 87/23 92/10
100/8 148/18 149/4
149/4
fixes [1] 88/19
flattened [1] 126/16
flavour [1] 67/15
flow [3] 106/15 111/8
166/9
flowing [1] 149/21
Foat [4] 74/5
focus [9] 35/3 43/8
89/24 91/17 107/16
115/23 133/21 137/11
138/16
focused [3] 7/13
11/18 94/4
follow [1] 16/3
followed [2] 10/4
118/6
following [12] 9/16
29/8 38/4 54/25 94/7
95/12 96/3 111/24
112/14 120/21 121/11
167/4
follows [3] 23/14
128/6 140/18
foot [3] 34/22 44/9
53/14
footfall [4] 96/24
99/16 99/24 100/6
footnote [1] 34/23
forced [1] 156/24
forces [3] 8/15 12/2
16/17
foremost [2] 112/13
155/16
forensic [3] 38/18
48/9 136/24
Forget [1] 166/19
forgive [1] 160/13
form [17] 12/17
14/23 111/4 139/18
139/20 139/21 140/11
143/4 158/3 158/4
158/10 158/14 159/1
159/6 159/9 159/18
159/25
formal [1] 52/2
formally [2] 30/16
90/20
format [1] 10/9
formed [2] 9/11 11/8
former [1] 144/11
forms [7] 139/17
141/24 142/3 155/20
155/23 156/12 163/5
formulated [1]
122/21
forthcoming [1]
140/22
forum [2] 75/25 93/1
forums [1] 63/5
forward [16] 8/2 14/9
15/25 46/3 73/23
104/23 134/3 138/17
149/5 154/13 154/17
154/22 155/5 155/7
155/22 159/7
forwards [5] 12/21
33/5 61/25 101/6
101/7
foul [1] 50/14
found [8] 9/12 10/25
19/8 42/8 54/22 93/18
114/18 131/14
four [13] 1/17 1/25
4/1 63/8 64/3 91/6
93/11 112/14 113/24
115/16 116/3 119/1
133/8
four years [1] 133/8
four-part [1] 116/3
fourth [2] 91/15
113/20
Fourthly [1] 95/24
frame [1] 112/12
framework [2] 120/8
141/16
frankly [1] 82/3
Fraser [5] 25/2 59/14
131/16 136/17 163/21
Fraser's [1] 57/2
fraudulent [1] 125/15:
fraudulently [1] 54/8
Freedom [1] 128/15
Freehills [1] 49/18
freeing [1] 148/6
froing [1] 104/11
front [2] 67/18 78/22
fruition [1] 97/21
frustrated [3] 48/3
153/13 154/9
frustrating [1] 43/12
frustration [3] 29/23
43/14 155/13
Fujitsu [13] 20/22
21/17 21/24 21/25
22/4 52/16 53/20
53/24 54/4 54/22 55/5)
55/8 88/10
Fujitsu's [1] 52/20
fulfil [2] 97/15 111/2
fulfilling [1] 70/3
full [9] 6/13 7/23
57/14 126/8 131/12
136/13 150/4 166/18
166/21
fuller [4] 27/16
fully [5] 68/14 82/3
82/22 153/2 165/3
function [6] 4/11
4/11 20/21 33/14
45/23 88/10
functioning [1] 67/4
fundamental [3]
110/15 111/6 113/4
funder [1] 147/5
funding [19] 50/17
67/12 99/19 101/16
102/19 102/21 103/13
103/25 104/5 104/7
104/14 104/16 104/19)
107/7 110/4 114/9
146/18 148/1 166/4
funds [1] 148/6
further [15] 13/5
14/13 20/15 21/8 29/7
29/17 29/24 34/23
39/2 39/24 40/5 61/22
84/25 145/7 147/10
future [13] 11/8
67/17 86/21 98/22
106/7 107/6 108/4
108/13 109/11 112/18}
113/13 127/19 146/18I
Go
gain [3] 55/2 55/7
122/14
Gains [1] 80/22
Gallafent [1] 1/21
Gareth [1] 135/15
gave [7] 75/5 75/23
86/20 104/11 128/11
134/9 146/15
GE [4] 160/11
general [12] 6/2 36/8
70/21 95/7 96/11
103/2 105/14 134/14
138/11 140/20 142/24]
160/11
generally [1] 8/25
generate [1] 94/4
generated [7] 35/3
54/25 82/11 92/6
92/11 92/22 94/12
generating [1] 93/3
generation [1] 82/17
generically [1] 95/5
generous [1] 166/10
genesis [4] 32/2
37/24 38/1 43/18
genuine [1] 80/17
genuinely [2] 153/24
166/1
get [38] 23/16 28/8
43/25 46/3 47/6 47/11
48/11 48/12 52/2
57/13 66/20 67/3 67/4
67/11 70/1 70/9 74/1
86/20 101/18 113/12
122/14 123/16 132/16}
136/13 143/4 143/21
143/22 148/11 149/9
154/13 154/17 154/22
155/4 155/9 155/21
156/9 163/6 166/6
gets [3] 34/15 150/4
150/8
getting [5] 62/19 93/1
138/23 141/19 155/1
Gilliland [1] 53/12
give [17] 4/3 4/11
9/25 15/11 15/13 43/9)
48/14 49/12 52/14
62/24 63/14 65/7 74/6
82/5 114/7 119/11
150/3
given [30] 8/11 18/2
25/1 25/13 27/17
28/15 35/17 35/24
40/17 55/12 57/17
57/21 63/12 71/5
73/13 90/13 101/23
111/16 111/16 115/15)
116/24 132/18 135/5
135/6 137/3 137/22
140/7 142/9 163/22
163/25
gives [4] 121/6
139/22 147/16 147/17I
giving [6] 51/18 62/1
62/16 64/5 75/15
116/18
glitches [1] 54/2
GLO [4] 118/19
142/15 160/11 160/21
gloves [1] 66/16
go [42] 12/19 12/21
15/13 22/8 22/23
29/24 34/22 35/1
39/22 41/18 44/9
44/13 45/24 46/8 48/7
49/21 51/2 53/18 65/4)
67/24 76/10 79/5 81/1
84/5 91/10 101/4
109/6 109/18 110/22
111/13 113/14 113/25}
114/2 135/1 135/2
135/13 152/14 152/19}
159/25 160/10 161/17}
163/24
goes [5] 59/9 67/22
106/18 146/24 160/22}
going [46] 3/16 14/23)
21/23 22/24 27/19
31/13 37/3 37/5 39/22,
47/18 50/13 56/17
56/18 56/19 56/22
57/1 57/4 60/21 63/16
67/24 68/13 71/10
72/24 75/25 79/4
81/11 82/9 84/24
95/10 96/23 100/14
104/24 114/3 118/11
123/5 124/21 131/7
132/4 133/12 139/20
142/25 148/21 154/19}
157/16 161/20 163/6
gone [4] 108/7 123/4
133/7 153/7
gong [1] 112/15
good [17] 1/7 1/8 4/5
4/16 26/23 68/2 76/16)
76/25 79/17 80/8
80/25 89/10 89/11
123/18 125/4 125/5
152/5
got [31] 15/21 20/25
21/15 25/25 36/15
43/18 46/12 47/13
47/15 48/15 66/12
68/19 69/8 71/12
110/20 122/18 123/2
123/19 124/9 124/10
130/14 130/25 137/24)
138/7 142/18 144/16
144/17 144/17 152/18)
153/6 161/21
governance [6] 7/3
8/24 9/1 101/25 102/3
102/6
governing [1] 6/6
Government [56]
2/19 4/7 39/19 41/15
42/13 42/16 43/25
44/3 49/2 50/17 51/18
90/10 90/18 90/21
90/23 92/19 93/6
93/23 94/24 97/12
97/19 99/9 102/12
102/20 102/21 104/2
104/11 104/21 105/7
105/25 106/9 106/11
106/17 107/5 107/11
107/20 111/4 111/5
111/7 112/17 113/3
123/5 123/9 124/10
129/24 145/17 147/12!
147/16 148/24 150/17)
151/1 151/8 151/14
152/22 152/23 166/18)
Government's [1]
105/2
governmental [1]
114/9
Gowri [2] 131/14
132/2
Grant [6] 72/17
100/10 100/19 101/2
101/5 108/10
grappling [1] 51/3
grateful [1] 40/5
Gratton [9] 45/12
48/17 50/18 65/22
67/2 68/2 73/3 76/15
76/23
Gratton's [1] 78/12
Gray [5] 5/16 6/1
12/24 17/24 20/11
great [7] 94/3 107/16
115/20 119/11 155/2
164/17 165/23
greater [2] 97/6
1414/7
(63) five... - greater
G
greatly [1] 2/11
green [1] 51/18
grip [1] 28/8
gross [1] 139/5
ground [4] 24/7
68/13 75/25 135/13
grounds [1] 129/16
group [17] 5/11 6/2
6/16 19/10 19/10 33/7,
33/17 33/22 41/21
69/7 73/20 78/20
115/25 117/3 119/16
160/12 160/13
group's [1] 6/12
groups [2] 4/10 63/6
growth [1] 98/2
guess [4] 115/24
117/24 147/4 157/22
guidance [12] 50/6
57/20 58/23 59/12
86/5 86/22 138/15
139/22 140/1 140/16
143/5 143/13
guide [1] 78/25
guidelines [3] 57/25
150/24 151/4
guilty [1] 154/20
guise [1] 15/18
guises [1] 146/3
habits [1] 98/4
had [98] 2/12 2/18
2/23 2/25 5/16 12/8
14/25 15/11 15/20
17/3 17/4 17/10 17/13
22/2 22/4 27/6 28/14
31/3 31/5 32/10 32/14]
32/25 33/5 33/23 35/3
37/10 37/17 38/17
44/2 46/24 48/6 48/8
61/13 61/23 63/8 63/9)
65/15 65/15 67/15
69/5 70/17 71/6 71/12
71123 74/12 74/21
75/13 75124 76/4
87/14 93/11 97/14
97/25 98/1 98/2 98/3
103/15 104/12 104/15
107/3 108/16 108/22
114/16 115/1 116/1
116/6 116/15 118/1
119/3 122/21 127/3
127/4 128/17 129/23
131/12 132/6 132/8
132/10 132/11 132/24
135/17 135/23 143/6
145/21 145/23 152/8
152/10 153/12 154/9
157/10 157/10 161/10
163/8 164/10 164/11
164/22 165/11 165/17
hadn't [1] 37/15
halt [1] 126/12
Hamilton [4] 136/10
hand [6] 44/21 68/20
110/5
handed [4] 25/7 27/6
82/5 119/3
handful [1] 29/13
hanged [1] 131/13
happen [4] 72/13
119/18 143/1 149/8
happened [6] 4/19
37/19 54/6 104/14
116/6 151/17
happening [5]
113/20 113/22 149/8
149/14 154/23
happens [2] 108/10
121/18
happy [1] 150/12
hard [2] 29/5 92/23
hardship [1] 132/25
harm [1] 139/4
harsh [1] 118/17
has [114] 3/23 4/6
4/21 6/21 8/11 10/19
21/8 21/12 24/6 24/8
26/10 26/11 27/14
29/17 29/23 36/19
37/7 38/1 41/5 42/2
42/6 42/14 43/13
43/13 43/16 46/24
46/25 52/20 52/23
53/4 53/19 54/5 54/14
55/12 63/9 64/3 64/3
65/8 67/19 69/25
73/13 73/24 73/24
73/25 80/13 80/18
83/6 88/8 91/7 97/20
97/24 98/7 98/19
99/18 99/21 99/24
100/1 102/9 102/17
103/3 103/8 103/20
103/23 103/24 104/14)
106/21 107/16 107/18)
108/22 109/9 111/14
111/25 112/10 115/4
116/1 116/9 116/20
118/19 119/2 119/7
119/23 122/23 123/4
123/9 123/12 123/14
124/9 124/10 129/2
129/18 135/5 135/12
137/22 140/2 141/13
142/22 146/3 148/5
149/1 149/3 149/13
150/9 151/7 151/10
151/16 152/23 152/25)
153/19 159/1 159/14
165/10 165/16 165/22)
165/24
hasn't [5] 61/24
61/25 94/1 97/17
106/18 106/18 109/12,
149/22
hasten [1] 118/7
hatched [1] 164/16
have [250]
haven't [8] 19/2
21/15 84/20 124/15
145/12 156/5 156/6
158/22
having [20] 15/15
71120 72/4 7712 77/4
78/13 116/10 127/23
132/25 149/17 162/3
163/23
he [33] 1/17 17/8
45/23 46/6 49/17
49/24 66/23 68/25
108/22 124/21 131/8
131/9 131/13 135/21
136/9 149/16 152/8
152/8 152/9 152/10
152/16 158/25 159/1
162/20 162/21
he's [4] 66/20 141/20
159/4 161/13
head [2] 44/12
140/23
heading [4] 12/22
22/21 23/4 57/14
heads [4] 140/13
140/14 150/25 151/4
heal [2] 73/15 126/18
heard [11] 53/1 68/9
68/24 77/22 128/10
131/8 135/11 155/22
156/1 156/6 157/4
hearing [6] 31/2 32/5
32/12 38/2 43/21
167/4
hearings [9] 1/13
1/13 1/17 1/25 4/1
4/25 29/9 32/19
165/19
heart [2] 51/24 71/19
heavily [2] 96/23
105/23
heavy [2] 25/7 119/3
heavy-handed [2]
25/7 119/3
heels [1] 128/3
held [16] 1/13 1/17
3/4 3/8 3/10 4/20 4/21
4/24 5/1 5/12 36/23
39/17 44/8 76/12
120/22 136/16
help [15] 5/22 20/17
23/9 23/16 50/4 75/1
83/18 83/21 84/6
139/11 139/13 155/1
155/5 160/2 161/2
helped [1] 165/24
16/6 34/17 35/7 50/16
53/20 64/12 65/7 69/7
24/4 24/8 24/12 39/14
73/13 77/22 80/7 80/7
helpful [3] 26/13
74/24 141/23
helping [1] 141/21
helpline [5] 59/20
59/21 59/24 60/11
60/14
hence [1] 40/8
Henry [16] 66/21
66/23 69/13 91/4
124/19 125/1 125/2
132/14 141/3 149/24
150/4 151/22 161/9
161/14 166/13 168/6
Henry's [3] 70/16
75/1 115/22
her [25] 42/18 53/3
56/13 61/11 61/18
62/5 62/12 62/20 63/7,
63/12 63/12 63/13
63/16 64/1 64/5 75/11
75/15 77/2 79/16
132/2 132/6 132/24
133/1 133/2 133/5
Herbert [1] 49/17
here [17] 18/15 33/3
37/7 49/3 49/9 50/23
51/11 55/16 72/24
77/7 77/15 77/18
78/10 78/13 98/12
102/8 124/19
hidden [1] 43/13
Higginbotham [1]
66/18
high [12] 7/13 10/18
10/19 26/3 98/4 99/24I
111/15 116/18 116/20}
150/5 151/25 163/11
high-value [1] 150/5
higher [2] 21/23 99/5
highlighted [4] 161/1
HIJ [4] 26/21
him [6] 3/15 24/8
45/18 51/10 66/18
131/8
himself [1] 131/13
hinted [1] 38/10
his [15] 24/20 65/25
79/14 79/16 80/7 80/8
131/10 131/13 131/14,
131/14 135/21 136/9
150/4 158/9 159/4
historic [7] 9/7 31/7
31/21 35/5 153/20
156/19 164/10
Historical [1] 160/19
historically [7] 18/17
32/23 36/22 38/18
116/6 119/2 137/8
history [10] 25/1
25/13 28/17 112/7
125/13 126/5 127/22
137/3 142/11 142/20
hm [2] 12/6 144/25
Hobbs [1] 54/21
Hodges [4] 39/12
39/14 40/13 41/20
hold [9] 3/9 56/4
57/24 59/2 59/16 73/9
122/7 147/11 148/1
Hollinrake [19] 42/20
42/23 42/25 43/2 43/4)
44/8 44/24 46/2 46/12
47/11 48/24 49/16
51/1 51/7 65/23 66/14I
76/13 89/22 89/25
Hollinrake's [1]
44/12
home [1] 93/20
honest [1] 161/7
hope [7] 39/16 66/20
108/21 112/23 114/1
114/8 165/17
hoping [1] 125/7
Horizon [72] 7/20
7/21 8/15 8/17 9/8 9/9I
9/11 9/14 9/19 10/3
10/18 10/23 10/24
11/2 12/10 12/11 13/6)
13/10 14/14 14/17
15/5 16/18 17/8 17/14)
17/19 18/24 20/16
20/20 21/1 21/9 21/14)
22/1 22/10 31/7 31/21
35/18 35/25 36/12
36/25 37/8 37/21 38/4
39/5 39/9 39/17 40/22I
53/13 53/21 58/13
59/6 81/3 81/15 82/11
82/16 85/13 87/5
110/7 125/22 132/1
132/2 132/9 132/11
132/18 135/20 135/23}
135/24 135/25 136/3
136/16 136/22 138/4
138/5
Horizon-based [2]
8/15 16/18
hour [1] 93/21
hours [1] 74/18
house [6] 7/5 9/24
12/12 18/1 20/25
157/10
how [56] 7/10 7/14
13/16 14/23 15/12
15/19 15/22 17/18
18/4 18/24 19/2 20/19)
20/20 32/25 43/25
47/1 59/21 59/24 68/4
71/4 74/16 76/18
78/15 82/25 83/21
83/22 93/14 94/4 99/3
100/7 104/5 105/25
106/4 109/24 110/1
1410/6 110/17 111/12
111/18 113/1 121/3
129/14 129/25 130/16)
130/17 131/4 134/4
140/1 146/21 148/8
(64) greatly - how
H
163/6 164/2
however [11] 11/12
63/8 94/2 118/1
132/17 147/6 161/23
HR [2] 28/15 42/12
HSS [17] 49/14 131/1
133/21 134/1 139/18
143/2 148/19 149/4
150/1 150/5 152/3
153/4 156/10 157/13
159/1 159/7 161/3
Hub [4] 121/18
hugely [2] 116/10
165/24
127/1
hundred [1] 49/8
hurdle [2] 163/10
163/10
husband [3] 132/6
133/2 156/2
Hutch [1] 16/2
laccept [1] 133/13
I admit [2] 84/14
84/14
l agree [3] 126/24
133/9 156/16
also [3] 74/17
118/23 123/8
lam [13] 29/6 29/13
29/18 30/21 85/21
90/4 128/23 132/15
135/6 140/3 157/8
160/18 160/23
lare [1] 16/2
lask [3] 1/9 4/13
149/23
lassume [2] 42/19
90/13
I believe [6] 19/8
29/3 41/12 154/10
160/1 161/25
I buy [1] 78/6
lean [12] 42/1 43/17
53/11 63/2 99/9
100/22 138/8 138/10
143/2 154/8 160/7
166/22
I can't [3] 2/4 32/10
139/13
I certainly [2] 63/23
118/23
I continue [1] 5/5
I could [2] 88/6 160/5:
I did [4] 28/25 55/23
123/16 137/14
I didn't [3] 130/23
how... [6] 154/13
154/17 154/22 159/25
22/15 30/3 30/20 54/5)
human [3] 29/9 30/19)
138/22 156/9
I discovered [1]
143/9
Ido [13] 43/14 49/9
69/18 75/19 75/19
78/6 106/23 119/25
125/10 146/22 147/11
166/7 166/8
I don't [59] 3/19 5/20
15/19 16/1 17/16
36/6 36/18 43/3 51/8
51/17 63/13 67/24
69/24 71/22 73/18
73/23 74/2 74/18
76/24 86/9 90/5 97/14
107/14 111/18 114/21
132/20 139/2 139/13
141/8 145/25 146/20
147/24 148/4 151/18
151/20 152/25 153/7
153/17 153/22 153/22)
154/8 158/6 161/15
161/16 164/14
I doubt [1] 114/6
I drew [1] 166/16
I emphasise [1]
140/8
I experienced [1]
70/1
I feel [1] 119/18
I first [1] 111/19
I found [1] 54/22
I gave [1] 86/20
I get [1] 47/6
Igo [2] 113/14
113/25
I guess [4] 115/24
117/24 147/4 157/22
Thad [2] 65/15 65/15
Ihave [10] 42/11
52/1 55/15 87/14
88/16 126/21 135/19
156/17 158/24 160/25)
I haven't [5] 19/2
21/15 84/20 124/15
156/5,
Vhold [1] 3/9
I hope [4] 108/21
112/23 114/14 114/8
linitiated [1] 28/7
linvariably [1] 72/8
linvite [1] 89/2
I joined [1] 37/16
Ijust [9] 16/3 34/18
56/23 66/1 75/17
122/17 148/23 152/11
153/9
I know [3] 140/14
149/15 153/11
Heft [4] 76/15
17/22 17/23 19/4 20/8)
20/8 25/8 25/17 33/10
115/19 118/20 129/17)
129/21 130/21 132/16)
Hook [1] 156/9
love [1] 124/5
I made [1] 103/6
I may [2] 118/7
145/18
I mean [19] 16/11
20/9 21/16 37/20
41/12 51/23 69/23
95/4 97/25 98/11
98/23 133/23 135/13
159/4 161/19 163/4
I mentioned [6]
19/12 51/20 71/16
83/8 117/2 119/22
I must [1] 25/7
l only [1] 78/16
I pressed [1] 84/14
I probably [3] 74/6
74/11 144/25
I promised [1] 165/1
I quote [1] 131/17
I raised [1] 27/23
lread [1] 78/15
realise [1] 164/20
I recall [1] 77/8
I received [1] 138/15
I recognise [1] 29/22
I referring [1] 14/18
I regret [1] 154/4
I remind [1] 163/14
I report [1] 72/6
I represent [1] 125/6
I sadly [1] 157/12
I said [8] 2/16 63/17
93/10 106/12 118/21
130/24 137/11 145/24
I say [44] 17/22 37/25
38/20 74/20 99/21
106/9 111/20 114/22
145/13 146/10 161/19}
I see [1] 131/6
I share [3] 29/3 73/6
73/8
I should [2] 30/11
65/23
I suggest [6] 139/15
142/19 154/7 162/14
162/24 165/5
I summarise [1] 2/10
I suspect [4] 1/19
52/12 90/3 157/21
I take [1] 46/7
I think [260]
[turn [2] 27/13 64/11
l understand [9] 16/8
44/6 62/19 100/6
108/15 123/15 123/18}
124/17 138/22
luse [1] 149/21
I want [6] 122/18
129/11 133/11 134/10
142/5 155/20
I wanted [1] 71/11
135/16 135/24 136/15}
Iwas [12] 19/12
37/15 48/3 50/15
65/13 74/21 75/7
84/16 100/14 130/3
157/16 160/16
I wasn't [2] 84/16
140/6
I went [1] 68/13
I will [5] 33/22 40/24
104/5 160/2 167/1
I won't [1] 159/25
I wonder [1] 131/6
I work [1] 120/22
I would [36] 21/20
27/5 29/25 68/11
72/14 88/20 101/18
101/22 111/18 118/2
127/10 128/2 129/21
132/14 134/3 134/6
134/19 137/2 142/1
144/7 148/10 149/20
153/2 158/5 159/15
159/15 163/24 165/9
165/12 165/17 166/9
166/12
I wouldn't [2] 77/18
153/14
I'd [2] 4/23 113/24
Vil [4] 141/23
I'm [61] 3/14 4/5 4/16
16/1 17/12 20/18
21/11 27/19 31/13
38/3 39/22 41/13
AT7IN7 51/1 52/5 58/5
62/19 63/3 63/16
71/25 73/12 75/11
79/3 81/11 82/9 85/7
85/21 95/2 96/23
104/20 104/24 115/12)
124/6 124/7 125/9
126/3 126/12 131/7
132/3 132/21 134/6
138/3 139/20 139/25
139/25 140/8 141/1
141/14 141/21 148/21
150/5 151/18 152/15
153/13 154/19 158/1
158/9 159/24 160/5
161/6 161/18
I've [17] 4/20 43/13
43/17 46/14 63/1
65/10 70/2 107/17
108/16 122/18 123/2
129/23 143/16 145/1
145/9 145/15 156/1
idea [7] 32/2 34/7
101/6 104/15 146/6
164/22 164/22
Ideally [1] 51/2
Ideally we [1] 51/2
ideas [1] 113/4
identification [1]
87/7
25/11 25/22 26/4 26/9)
identified [7] 9/10
10/24 54/12 55/1
104/8 107/1 165/17
identify [12] 31/17
57/1 59/25 81/20
81/24 83/10 83/12
84/7 88/14 88/17
88/22 109/15
ie [14] 1/13 3/1 4/1
20/6 21/23 29/11
36/15 57/16 85/20
90/7 97/9 100/5
110/15 110/16
ie Co-op [1] 97/9
ie ensuring [1] 90/7
ie hearings [1] 1/13
ie it [4] 3/4
ie make [1] 110/16
ie pressing [1] 85/20
ie the [1] 29/11
ie they [1] 20/6
ie we [1] 36/15
ie what [1] 21/23
if [107] 3/24 4/14 6/2
10/10 10/10 12/13
12/21 16/2 22/23
22/25 24/14 24/18
28/19 32/11 34/21
35/1 36/23 39/1 40/12I
41/20 42/16 44/9
44/13 44/21 45/11
45/24 49/21 51/8
51/12 53/13 53/18
54/13 54/19 56/10
56/14 56/16 56/22
57/1 57/4 57/7 57/13
57/18 59/15 63/15
64/9 64/18 72/25
75/18 76/13 76/21
79/11 81/1 81/8 83/13}
83/21 84/12 85/9
88/19 91/10 91/15
92/11 92/16 95/10
99/6 101/4 101/5
101/7 102/1 103/8
109/6 109/18 121/21
124/2 124/8 125/20
127/16 127/22 128/3
129/7 130/4 130/25
133/23 134/20 135/3
138/25 143/25 144/5
144/15 148/13 148/23)
149/23 150/25 151/5
152/14 153/25 154/22)
155/7 156/9 156/12
156/14 158/6 159/6
159/23 160/5 160/10
161/20 164/3
image [1] 117/24
immediate [1] 28/6
immediately [1]
80/25
imminent [1] 40/18
imminently [2] 43/23
(65) how... - imminently
I
imminently... [1]
123/4
immorality [1] 22/25
impact [5] 29/9 87/20
116/1 118/1 126/22
impacted [1] 55/2
impacts [1] 96/19
implemented [2]
7/10 76/7
implementing [1]
76/2
implicated [3] 51/4
51/25 61/5
implication [1]
116/24
implications [3] 55/5
82/12 134/5
implied [1] 162/23
implies [1] 99/2
imply [1] 98/15
importance [3] 117/2
117/4 158/21
important [20] 27/7
63/22 64/22 65/3
65/11 75/14 76/3
83/19 84/22 85/3
100/10 107/22 108/19}
114/3 116/7 121/12
127/11 128/6 135/14
163/24
importantly [6] 11/16
30/11 88/7 106/1
113/22 118/12
impose [2] 96/15
96/18
imposed [1] 82/24
imposes [1] 81/9
imposing [1] 85/10
impossibility [1]
144/9
impossible [1] 70/5
impression [2] 65/7
116/19
improve [1] 129/25
improved [1] 8/24
improvement [2]
89/19 122/8
inability [2] 48/4
165/6
inadequate [1]
148/22
inadvertent [3] 70/25
74/15 74/20
inadvertently [2]
67/7 159/23
inappropriate [2]
62/12 145/1
Incentive [1] 117/14
inception [1] 133/13
incident [1] 118/20
incidentally [1] 47/17
include [2] 25/15
31/19
included [8] 10/5
10/7 90/9 107/2
108/19 115/7 121/1
121/3
includes [1] 91/15
including [13] 8/9
30/11 35/3 60/25
71/20 72/2 72/21 81/4
91/13 91/18 91/21
117/22 118/16
income [5] 92/11
92/22 93/4 93/5 97/2
incoming [2] 98/19
108/23
incompetence [1]
125/24
incomplete [1] 28/15
inconsistent [1]
63/13
increased [2] 94/6
99/25
increases [3] 89/17
92/18 94/14
incurred [2] 55/3
80/8
indeed [25] 2/16
13/16 25/3 28/5 30/19
36/24 38/8 39/3 43/6
46/22 49/24 61/21
70/8 72/11 81/22
83/13 87/16 93/4
99/16 108/18 122/9
140/15 146/19 146/25)
157/25
independence [4]
2/13 3/12 31/23 103/8
independent [5]
65/16 108/24 150/9
151/10 166/3
indicate [1] 120/21
individual [11] 29/11
53/21 54/4 62/8 96/4
106/19 120/11 132/16)
134/14 150/17 150/25)
individuals [26] 18/6
18/9 18/12 18/18 21/3
29/3 29/11 29/13
30/19 32/9 32/14
32/21 35/4 38/7 40/7
40/21 41/3 42/6 50/7
51/23 114/20 117/5
117/22 143/6 143/7
152/3
Inducement [1] 23/2
Induction [1] 57/15
inevitability [1] 148/4
inevitable [1] 144/21
inexplicably [1]
154/21
infants [1] 132/23
inferring [1] 36/3
inflation [1] 94/10
inflicted [1] 127/8
influence [1] 103/3
info [1] 46/24
informally [1] 39/18
information [30] 6/7
6/22 7/4 7/6 7/7 8/6
8/17 9/6 9/19 10/2
10/6 10/9 11/11 14/6
14/24 15/8 15/19 16/4
16/9 24/5 29/18 41/13}
55/13 60/24 66/17
82/6 128/15 131/22
163/19 164/3
inhibit [1] 102/12
inhibiting [2] 101/13
102/10
initial [2] 108/11
111/11
initials [3] 44/22 45/3
45/9
initiated [4] 28/7
63/10 98/19 123/23
initiatives [2] 109/16
115/15
injuries [1] 126/18
injustice [2] 126/16
128/25
injustices [1] 127/8
inner [2] 99/15
146/21
innocence [4] 26/24
63/20 83/20 85/9
innovation [1]
113/17
inordinate [2] 149/18
153/5
input [5] 6/3 72/18
77/1 77/4 78/5
Inquiry [42] 1/12 2/6
3/25 4/9 25/3 25/24
29/10 31/2 31/16
32/24 36/23 38/15
38/25 40/18 42/6
46/25 47/16 47/21
52/13 52/15 54/15
60/23 61/10 62/13
62/17 63/11 63/14
63/17 64/5 64/9 91/5
112/4 112/13 117/11
119/6 119/11 124/6
135/6 137/22 142/24
144/2 160/21
insecurity [1] 133/1
insidious [1] 163/2
insofar [1] 126/25
insolvent [1] 147/10
instance [2] 30/5
84/12
instances [2] 8/3
161/12
instead [4] 2/10
12/11 69/22 79/5
institution [5] 105/5
132/21 137/8 147/9
158/14
instructing [1]
147/21
instructions [4]
35/16 35/24 36/12
57/21
integrity [4] 14/17
31/8 31/22 55/5
intelligence [1] 9/20
intended [1] 120/11
intends [1] 108/3
intentionally [1]
139/4
interact [2] 146/22
146/23
interacting [1]
120/13
interaction [4] 7/12
123/14 123/17 144/12)
interactions [3] 22/4
90/21 121/5
interest [8] 19/14
41/9 41/16 68/5 76/19)
95/7 96/11 105/14
interesting [2] 39/20
146/2
interests [3] 110/1
137/9 145/10
interface [1] 28/24
interference [2]
101/14 102/11
interfering [1] 102/13
interim [7] 2/8 6/2
45/5 130/15 131/2
152/13 166/16
internal [7] 19/21
34/24 34/25 37/10
112/20 115/10 116/12}
internally [3] 47/3
120/13 124/2
interpret [1] 121/24
interpretation [1]
71/10
intervention [1]
148/15
interview [1] 25/16
interviewed [1]
131/10
interviews [2] 23/16
23/24
intimidated [1] 156/7
into [40] 1/13 2/14
2/14 3/13 6/24 21/22
23/11 28/2 29/7 31/4
37/17 38/7 38/13
38/16 38/17 45/18
47/18 49/11 50/13
50/20 54/20 54/23
55/6 68/13 76/7 84/24,
97/13 109/2 112/9
113/14 113/25 116/8
132/16 133/25 138/13}
144/5 159/25 162/6
162/12 162/20
intrigued [1] 40/10
introduced [1] 87/13
introduces [1] 79/22
introduction [2]
49/15 59/12
intuitive [1] 86/2
invariably [1] 72/8
invert [1] 64/23
inverted [1] 123/5
investigate [7] 23/9
23/9 30/9 38/21 63/19)
82/22 118/9
investigated [3]
16/14 28/1 28/19
investigates [1] 22/8
investigating [1]
24/3
investigation [35]
5/6 6/25 8/6 11/15
17/9 22/20 23/5 23/8
23/11 23/13 23/15
23/20 23/23 24/6
24/16 24/22 24/23
24/24 24/25 25/5
25/10 25/14 25/20
31/6 31/19 32/23 35/6I
39/2 55/22 80/19 82/5
85/1 118/7 118/18
131/12
investigations [22]
6/8 6/16 7/10 8/16
8/25 12/23 13/1 13/4
16/19 19/21 22/15
23/20 25/9 26/6 29/4
29/14 29/19 56/1 58/8
60/9 84/20 118/12
investigations/Passi
ng [1] 13/1
investigative [4] 7/2
25/15 83/4 86/11
investigator [2] 30/5
49/25
Investigator's [1]
10/5
investigators [2]
11/19 86/6
investment [4] 67/17
104/9 106/20 113/23
invite [1] 89/2
invited [6] 61/10
62/20 64/8 108/10
109/9 121/20
involved [18] 3/2 4/3
23/23 28/21 29/12
32/22 35/5 49/18 50/8I
61/4 62/12 63/4 64/4
132/18 144/10 147/7
155/12 155/17
involvement [9] 3/1
6/23 40/8 40/8 40/20
41/2 42/4 61/13
160/20
involving [3] 39/5
39/8 157/23
irony [1] 127/21
(66) imminently... - irony
irrespective [4] 47/4
88/23 118/10 140/16
is [500]
Ismail [3] 68/25
73/13 77/22
isn't [13] 7/18 12/1
51/25 103/24 128/20
129/6 129/7 133/16
146/1 146/23 147/13
162/25 163/10
isolated [3] 99/14
111/3 118/20
issue [25] 13/23
15/16 27/23 32/18
40/20 42/22 44/1
46/16 48/15 51/23
52/19 55/1 59/10 61/3
61/5 61/8 64/11 69/24
70/4 84/1 84/24 85/10
102/7 130/3 133/10
issues [50] 9/8 9/11
9/14 10/24 22/10 26/8
26/20 26/25 36/24
37/21 38/4 38/17
39/20 40/24 50/13
50/25 52/13 52/15
53/13 55/9 57/3 58/20
60/1 63/1 65/1 72/7
73/2 76/1 79/3 83/12
83/17 84/4 84/7 85/24
85/25 86/12 88/4 88/5
88/9 104/4 107/1
107/10 111/8 112/1
119/5 130/13 131/16
138/5 149/17 163/15
it [388]
itl [3] 115/20 122/2
122/2
it's [101] 3/9 3/14
3/19 4/5 4/16 4/20
4/20 5/1 5/24 6/11
6/14 14/16 19/8 20/19
25/8 26/4 26/5 26/7
26/13 33/14 33/14
34/16 34/19 37/8
38/14 43/12 44/10
45/3 53/9 53/13 53/14!
53/15 56/9 56/9 56/22
62/12 63/22 63/24
63/25 64/19 65/10
65/11 66/15 68/9
69/25 70/3 73/23
74/19 77/4 84/9 85/6
86/21 89/2 89/25
90/13 90/17 91/2 94/2
94/10 100/9 100/18
101/9 102/5 102/14
105/15 105/15 106/24
107/25 108/19 109/6
1141/6 112/14 112/22
113/6 114/21 116/21
116/22 116/23 121/12]
124/10 126/7 129/1
140/14 144/1 141/21
153/14 153/17 154/1
156/19 158/11 159/8
160/10 162/22 163/2
163/9 163/10 163/12
165/5
itemised [1] 140/23
its [42] 2/7 2/8 7/11
15/11 15/18 19/20
21/25 31/4 33/20
33/21 40/11 42/6
48/13 52/20 71/20
80/13 86/6 86/6 98/20
98/20 99/19 103/15
103/21 105/7 107/6
108/18 109/14 109/14)
112/13 112/18 116/23
119/13 124/3 126/9
127/19 127/23 127/25]
128/3 129/19 134/25
136/22 137/8
itself [11] 10/11 79/6
85/24 113/3 115/21
121/17 142/11 142/20)
142/24 155/24 160/15)
J
Jacobs [2] 55/22
118/16
JAMES [2] 1/3 168/2
Jamie [1] 65/22
Jane [1] 32/17
January [11] 9/20
10/3 11/3 12/14 17/5
33/8 44/14 44/15
53/13 66/7 164/6
Jayakanthan [1]
131/8
Jayakanthan's [1]
132/3
Jenkins [1] 135/15
job [9] 23/8 36/11
37/3 37/5 45/7 45/8
46/3 90/14 164/21
jobs [2] 36/17 156/23
joined [3] 37/16
98/21 119/20
journey [4] 15/24
143/2 143/9 143/10
judge [2] 37/21 42/5
judgement [2] 46/5
125/22
judgment [14] 9/11
10/24 22/10 26/22
37/21 38/4 57/3 79/3
79/5 131/16 136/10
138/5 163/15 164/5
judgments [5] 25/2
26/3 27/6 111/14
111/17
July [6] 1/17 1/18 6/9
11/24 21/12 41/14
135/25 136/11 138/12,
June [10] 5/13 5/25
17/14 22/2 39/13
41/13 89/25 100/18
109/6 157/13
just [64] 3/11 11/25
12/7 16/3 22/9 22/23
27/3 27/16 27/19 34/4
34/18 34/22 35/1
36/16 43/17 44/9
44/21 45/11 45/24
A47I17 47/18 53/14
53/18 54/19 56/17
56/19 56/23 57/13
58/6 61/18 63/1 66/1
66/5 70/14 75/3 75/17
76/13 85/25 98/13
99/1 108/7 111/25
112/1 113/9 113/10
121/9 121/12 122/17
132/3 137/15 137/16
142/5 148/23 151/24
152/10 152/11 153/9
156/1 156/4 156/18
159/20 160/2 160/7
160/25
justice [13] 25/2 29/9
30/18 57/2 59/14
125/7 126/21 131/16
136/17 137/9 143/9
163/21 165/8
K
Karen [2] 5/15 33/12
Kathryn [1] 45/5
KC [1] 1/21
keen [7] 66/19 74/21
97/22 106/9 114/20
114/23 152/18
keenly [1] 69/17
keep [13] 42/15
42/16 49/17 56/17
56/18 56/22 57/1 57/4
60/21 81/14 87/4
95/10 161/20
Kevin [5] 43/2 44/8
44/24 53/12 89/22
key [13] 34/21 35/2
35/8 35/19 46/12
57/20 58/8 58/23 79/8
93/11 101/10 101/11
109/19
keyboard [2] 85/13
85/24
keys [1] 123/13
KH [1] 44/24
kind [3] 13/14 17/10
39/23
knew [4] 37/6 52/23
164/14 164/15
know [55] 14/15
14/22 16/13 17/3
17/10 17/13 18/24
19/3 21/13 22/9 25/23}
33/2 35/19 36/6 36/16
40/10 45/23 52/14
63/15 67/24 73/11
73/21 86/9 86/12
90/12 92/25 103/15
120/2 124/18 124/19
139/2 139/13 140/14
151/19 151/20 152/1
153/8 153/11 153/11
154/14 155/16 157/4
157/9 158/6 159/22
166/15
knowledge [3] 21/10
21/11 53/3
knowledgeable [1]
68/14
known [7] 9/10 10/23)
23/6 82/10 132/22
136/22 164/8
KPMG [3] 9/11 46/24
47/9
L
Labour [1] 112/16
lack [6] 26/25 84/13
101/12 101/20 102/14}
145/3
laid [1] 24/1
landscape [1] 99/23
language [1] 26/12
large [4] 12/1 12/5
20/2 111/1
largely [2] 97/1 136/3
larger [1] 157/25
last [18] 43/22 61/9
61/9 64/3 76/4 91/6
92/8 93/1 95/10 99/22,
100/23 105/7 112/6
113/14 119/1 129/22
133/8 165/14
Lastly [1] 30/14
later [6] 22/11 131/13
133/12 134/7 139/21
143/22
launched [1] 120/7
law [30] 5/8 5/18 6/7
6/17 6/22 6/25 7/4
7/15 7/22 8/3 9/2 9/17)
10/13 11/12 11/19
13/1 13/10 13/14
13/22 14/3 15/6 18/9
18/13 18/21 18/25
19/13 19/24 21/2
118/4 127/23
lawful [1] 8/5
laws [1] 128/16
lawyer [2] 21/19
141/2
lawyers [4] 49/8
49/10 129/19 133/4
LEA [1] 10/8
lead [2] 97/23 160/18
103/20 114/21 114/24)
129/14 129/17 138/19}
146/21 146/22 149/15)
leaders [1] 36/21
leadership [11] 78/8
115/2 115/17 116/15
116/17 116/18 117/10)
117/22 118/15 119/7
119/16
leadership's [1]
117/20
leading [1] 126/11
leads [1] 160/23
learn [2] 138/20
138/22
learned [3] 137/20
165/9 165/13
learning [1] 86/10
learnt [6] 126/1
130/12 130/22 143/16)
159/12 165/21
LEAs [4] 10/2 10/6
13/19 15/19
least [11] 21/18
25/18 39/18 40/3
48/14 94/13 97/25
98/16 122/20 123/16
151/13
leave [1] 74/4
leaving [2] 133/10
136/22
led [5] 34/6 34/10
94/10 108/2 127/12
Lee [1] 163/9
left [8] 37/23 38/7
44/21 47/4 74/12
76/15 103/7 110/5
left-hand [2] 44/21
110/5
legacy [3] 99/13
135/20 136/16
legal [17] 6/18 7/12
91/13 129/16 130/5
134/2 140/7 140/9
141/8 141/16 141/25
142/2 142/10 143/14
143/19 158/13 158/13)
legalistic [6] 133/18
133/22 144/1 144/4
144/6 158/4
legislate [1] 46/13
length [7] 101/6
126/3 146/23 149/18
153/5 158/11 159/18
lengthy [1] 158/4
less [8] 71/7 72/25
86/2 93/20 97/3
104/12 107/18 156/3
lessons [4] 130/12
165/9 165/12 165/22
let [3] 141/5 141/12
157/17
let's [8] 5/21 100/13
124/13 143/13 150/12)
156/14 156/18 158/3
letter [17] 10/8 39/22
39/23 39/25 89/20
(67) irrespective - letter
L
letter... [12] 90/3 91/4
91/10 94/2 94/25
98/12 99/1 154/4
154/6 154/18 154/19
154/20
letters [3] 21/17
98/25 143/10
letting [1] 164/23
level [18] 3/17 14/21
21/23 29/22 48/13
49/15 71/13 84/25
93/25 96/4 99/15
116/10 117/3 127/3
131/3
levelled [1] 147/19
levels [1] 102/6
levers [1] 148/1
LG [1] 45/11
LGs [1] 45/11
liability [4] 58/21
58/24 80/1 86/17
liable [1] 86/25
liberty [2] 24/20
136/25
life [4] 106/18 121/23
126/12 127/12
lifeless [1] 131/14
light [9] 4/18 40/4
119/5 156/17 165/24
like [21] 4/23 20/2
26/17 28/21 49/3
50/14 51/15 66/12
86/8 89/23 111/5
112/19 113/13 114/8
133/5 136/14 141/21
148/8 149/20 150/21
165/9
likely [3] 38/14 81/21
150/13
limited [3] 79/10
101/15 103/12
limiting [1] 7/13
line [9] 34/12 34/15
41/25 48/25 49/22
61/18 70/5 84/2 162/8,
lines [2] 10/12 42/16
lingering [1] 43/9
link [1] 94/13
linked [1] 78/16
list [3] 39/14 90/9
95/4
listed [3] 90/17 91/25
91/25
listened [2] 130/23
159/12
listening [1] 63/5
lit [1] 32/7
literally [1] 116/4
Litigation [1] 78/20
little [6] 19/12 34/23
66/1 133/12 134/7
101/25 105/18 114/15}
51/18 55/12 57/2 80/9
lived [1] 145/12
livelihood [1] 133/1
lives [2] 126/15
127/4
living [4] 90/8 90/25
112/2 128/9
local [1] 105/18
locality [4] 157/11
loft [4] 131/14
logistics [1] 111/1
53/8 56/23 57/19
97/14 98/10 98/11
98/22 102/5 103/16
106/4 106/14 108/13
113/22 114/4 117/6
126/22 129/7 145/10
165/11
long-term [15] 98/10
98/11 98/22 104/16
106/4 108/13 110/19
114/4 117/6 126/22
145/10 146/18
longer [2] 101/16
103/13
longer-term [1]
101/16
look [45] 5/10 5/21
6/2 6/3 22/14 27/17
30/24 36/5 38/12
38/15 39/10 41/18
44/7 44/21 46/3 46/24
53/7 53/14 54/13 56/7,
58/5 64/18 65/19 66/5)
76/10 79/7 80/15
83/11 89/20 91/10
94/23 100/13 105/8
105/16 105/18 105/21
109/3 109/4 112/19
114/8 114/9 118/24
148/8 156/9 162/23
looked [9] 2/17 17/4
29/7 37/17 78/22
111/22 111/22 111/23)
145/15
looking [16] 13/8
15/3 22/16 33/7 38/7
39/6 67/2 69/2 69/3
85/23 93/8 93/15
100/15 112/15 113/4
114/18
looks [2] 86/8 113/13
Lord [4] 154/4 154/6
154/10 154/18
Lord Chancellor [3]
154/6 154/10 154/18
Lorna [10] 45/12
45/13 48/17 50/18
long [30] 43/13 43/16
103/21 104/16 104/18)
110/19 112/24 113/12)
146/18 157/16 157/17)
112/24 113/12 113/22
65/22 67/2 76/15
76/22 77/17 78/3
loss [15] 19/23 55/2
84/15 84/17 85/2
127/8 132/9 140/13
140/15 150/25 151/4
loss/gain [1] 55/7
losses [6] 79/11
79/13 79/15 79/17
80/3 80/8
lost [6] 70/14 71/5
100/1 107/3 133/1
156/23
lot [10] 35/3 63/9
68/10 85/23 129/25
141/24 142/12 143/6
143/7 157/20
love [1] 124/5
low [8] 92/12 92/13
93/24 99/3 134/1
157/15 157/20 163/10
lower [4] 96/24 96/24
97/2 134/2
lowest [1] 89/18
Lucas [2] 44/13
65/22
lunch [1] 117/2
Lynn [4] 54/21
machine [1] 131/25
macro [1] 113/9
made [50] 11/25 17/2
17/10 17/24 18/11
18/17 21/12 24/16
26/21 30/3 42/2 42/10
44/15 44/18 46/14
53/19 54/10 56/21
57/2 60/7 62/7 63/19
64/9 64/10 69/18
74/14 79/17 80/24
86/4 87/17 88/20
94/17 102/8 103/1
103/6 105/24 117/21
118/5 121/11 122/10
122/11 129/3 129/18
132/1 134/6 140/2
159/16 159/17 165/14
166/11
magnitude [1] 48/18
Mail [1] 98/1
mails [3] 93/12 94/11
94/15
main [5] 23/8 71/6
73/19 77/9 122/24
maintain [5] 63/22
81/13 87/3 97/12
162/1
maintained [3] 28/3
88/10 88/11
maintaining [3] 64/2
91/16 91/16
maintains [1] 25/4
major [3] 69/24 91/3
117/11
mass [1] 148/17
massive [1] 98/3
55/7 80/17 83/5 84/12)
majority [7] 8/20 16/5)
16/20 18/6 35/14
35/22 36/10
make [40] 2/6 4/3
4/16 16/1 20/3 24/10
27/7 36/3 36/6 36/7
50/15 53/24 63/2 63/3)
66/19 67/1 69/23
74/21 80/8 82/4 85/22,
86/1 88/20 90/7 90/25)
93/25 96/10 100/13
106/10 110/11 110/16)
massively [1] 19/19
material [7] 5/18 9/2
10/13 13/1 125/18
135/8 158/12
materially [1] 119/1
materials [1] 81/7
matter [6] 6/9 71/1
71/2 71/3 129/3
143/25
matters [9] 7/11 7/14
16/21 23/11 40/9
64/24 73/1 102/14
113/2 114/10 123/24
124/7 134/23 137/18
143/14 149/6 149/6
104/15 163/3
making [6] 4/12
54/11 70/9 72/19
106/21 121/10
malicious [3] 153/9
153/17 153/18
man [1] 131/24
manage [2] 66/16
107/22
management [6]
34/15 91/12 91/13
91/20 109/23 136/21
manager [3] 34/12
53/16 61/18
managers [3] 58/16
58/19 60/8
manner [2] 38/18
70/16
mantra [3] 135/23
135/24 136/20
manual [3] 10/6
85/25 86/3
many [39] 3/18 17/9
23/6 23/6 23/21 36/21
39/20 48/3 48/8 69/2
72/16 89/18 100/12
102/25 104/4 111/8
116/21 116/21 127/7
129/14 131/6 132/7
134/12 134/17 135/7
144/22 145/1 145/1
146/3 152/5 152/19
153/6 154/24 154/24
156/23 157/12 163/7
164/10 164/11
March [6] 115/21
121/14 122/7 131/10
131/12 164/5
market [3] 93/5 93/6
97/24
markets [1] 110/25
Marriott [1] 5/15
Marshall [7] 53/10
53/16 54/17 55/13
55/20 55/25 60/23
Marshall's [1] 56/8
makes [4] 65/17 98/8
102/15
may [39] 2/4 8/4 9/20
23/23 24/5 27/25 28/4I
32/22 48/23 51/24
67/11 69/21 80/9
80/23 84/1 84/1 84/7
84/7 86/12 86/25
87/23 87/23 88/4
99/11 99/15 112/19
118/7 130/22 131/8
136/2 139/1 141/2
143/22 145/18 151/18)
158/6 159/10 159/21
161/15
maybe [4] 38/10 49/5
122/3 161/18
McEwan [2] 5/15
33/12
McInnes [1] 65/21
McKinsey [1] 111/21
me [37] 2/21 27/7
27/24 32/13 32/18
32/25 33/4 33/13
33/15 33/19 43/12
48/12 50/1 70/8 72/8
73/12 76/1 113/16
113/25 118/5 121/15
124/20 139/11 141/5
141/21 142/25 145/19)
147/4 150/21 155/2
157/18 160/3 160/9
160/13 160/18 161/2
166/20
mean [31] 16/11 20/9
21/16 35/21 37/20
41/12 51/23 69/23
70/11 78/12 87/6 95/4I
97/2 97/25 98/11
98/23 101/21 132/20
133/23 135/13 135/16)
135/24 136/15 138/1
138/2 141/8 159/4
161/19 163/4 164/14
165/1
meaningful [1] 128/8
means [9] 20/17
34/23 60/12 86/7
123/17 152/19 156/4
160/6 161/6
meant [3] 51/12 55/2
(58) letter... - meant
meant... [1] 99/24
meantime [2] 106/16
113/1
measure [2] 121/3
122/13
measures [1] 60/15
mechanics [3] 72/24
72/25 74/16
mechanism [2] 87/6
87/10
media [6] 48/8 116/5
116/11 116/13 142/25}
162/2
Mediation [1] 160/20
medium [3] 91/13
113/2 152/5
meet [3] 95/12 124/4
163/25
meeting [17] 5/16
5/25 12/20 14/1 17/4
17/6 17/6 33/24 39/18
41/14 44/14 47/18
65/20 67/10 72/6
76/12 154/16
meetings [10] 29/9
44/7 64/24 66/6 72/9
72/10 72/14 72/15
126/21 129/23
Melanie [2] 87/15
88/11
member [4] 65/16
70/21 93/18 118/17
members [10] 20/14
39/9 65/20 70/8 72/4
73/20 75/14 75/24
103/23 116/2
memo [3] 67/6 70/12
76/15
memory [1] 112/8
mention [3] 18/22
135/20 139/23
mentioned [13] 5/12
19/12 19/20 51/20
70/2 71/16 83/8
100/22 117/2 119/22
140/10 156/1 156/5
mentions [1] 67/17
mere [1] 159/8
merit [1] 48/23
meritorious [1] 137/3
message [1] 71/19
messy [1] 66/19
met [1] 157/12
method [1] 163/2
methodology [3]
20/18 20/19 20/23
metric [3] 117/11
117/15 134/2
middle [1] 122/41
might [26] 5/22 15/4
28/10 30/12 31/19
31/21 32/20 34/6 38/3
40/6 50/10 50/10
50/11 50/13 50/19
82/12 84/2 127/2
127/3 127/12 130/5
137/18 137/21 139/8
147/21 154/5
migration [1] 54/25
mile [3] 95/17 95/20
95/23
mileage [1] 76/25
miles [3] 95/17 95/25
96/7
million [7] 99/18
99/20 99/22 104/8
104/10 104/11 104/12)
mind [5] 51/8 70/13
75/4 77/24 149/23
minds [1] 69/20
mindset [1] 137/15
minimise [1] 147/21
minimum [3] 93/21
95/12 98/23
Minister [5] 43/4 44/8)
66/23 129/24 130/2
ministerial [3] 72/13
72/15 77/13
ministers [3] 90/22
146/5 146/13
minority [1] 23/19
minuscule [1] 136/5
minutes [8] 5/11
12/19 14/13 20/15
20/24 39/19 52/6
154/15
misaligned [1] 102/1
misalignment [2]
25/10 26/9
miscarriages [1]
30/18
misconduct [2]
37/12 134/15
misinformed [2]
156/12 156/14
misleading [1] 160/1
misled [2] 136/15
158/19
mismatch [1] 100/2
Misra [1] 135/16
misses [1] 24/12
missing [2] 10/21
55/7
mistake [4] 49/17
74/16 74/17 74/20
mistakes [2] 86/3
166/11
mistress [1] 40/9
Mm [5] 12/6 15/7
17/7 55/17 144/25
Mm-hm [2] 12/6
144/25
model [5] 94/19
104/19 108/4 110/4
114/10
modern [1] 15/18
Moloney's [1] 135/19
moment [10] 14/12
68/9 71/23 80/15
81/12 104/24 108/16
116/23 149/23 166/19}
Monday [1] 67/15
money [13] 46/15
46/17 47/24 48/7 54/5
91/17 110/11 110/17
128/18 144/19 148/13
148/20 149/1
monitor [1] 83/11
monitored [2] 59/22
59/25
monitoring [3] 8/2
83/10 87/7
month [7] 47/12 69/1
77/23 108/7 122/2
122/3 149/8
monthly [2] 42/19
7219
months [6] 104/10
113/15 119/22 121/9
135/21 165/14
mooted [1] 161/2
more [61] 11/10
11/16 11/16 12/9
14/15 14/19 14/22
18/3 18/5 18/13 18/18
18/22 18/23 28/22
30/1 38/14 40/10
42/15 48/25 49/14
50/16 53/9 54/19
62/16 71/8 74/11
76/14 76/25 7/4
77/18 77/25 78/5 84/4
86/2 88/7 94/4 94/17
94/18 96/23 98/24
102/14 105/23 106/1
107/23 112/7 113/8
113/21 118/11 124/6
129/12 134/21 139/1
139/21 141/23 150/22
153/10 154/13 157/23
159/10 163/2 165/23
morning [5] 1/7 1/8
39/15 67/14 166/24
mortgages [1]
106/20
most [14] 11/12
23/13 27/6 33/2 65/2
83/19 110/4 111/15
113/16 116/23 126/4
127/21 127/22 128/6
mother [1] 132/23
motion [1] 119/25
mouth [1] 148/19
move [17] 19/9 29/24
44/5 50/7 50/12 50/15)
52/3 52/5 54/5 73/22
74/23 75/2 78/19 86/1
125/8 157/10 160/2
moved [4] 28/2 28/23
74/22 130/23
moving [2] 138/17
166/1
MP [1] 44/8
MR [103] 1/4 1/5 1/7
1/23 5/5 5/14 5/15 6/1
12/24 16/1 16/2 17/4
17/24 18/2 20/9 21/16}
25/2 26/9 29/17 39/9
39/12 41/20 41/21
42/20 42/23 42/25
44/12 44/13 46/2
46/12 47/11 48/24
49/16 49/19 51/1 51/7
52/12 54/15 57/2
59/14 65/21 65/23
66/14 73/13 73/14
74/5 74/5 75/3 76/9
76/13 77/22 89/10
89/22 89/25 89/25
117/23 122/15 122/19
124/19 125/1 125/2
125/4 128/11 128/21
131/7 131/16 132/5
132/12 132/14 135/15}
135/19 135/19 135/24}
136/12 136/17 141/3
141/14 141/19 142/13
149/24 150/4 151/22
154/7 154/17 154/19
158/7 158/25 160/4
160/17 161/9 161/14
161/21 162/14 163/9
163/21 164/7 164/15
164/20 166/13 166/15]
166/25 168/4 168/6
Mr Bartlett [6] 6/1
12/24 17/24 18/2 20/9}
29/17
Mr Beer [6] 1/5 16/2
26/9 75/3 76/9 166/25)
Mr Breeden [1] 54/15)
Mr Brocklesby [1]
5/14
Mr Butoy [1] 135/19
Mr Cameron [1] 17/4
Mr Cresswell [1]
41/21
Mr Dan [1] 158/7
Mr Foat [1] 74/5
Mr Gareth [1] 135/15
Mr Henry [10] 124/19
125/2 132/14 141/3
149/24 150/4 151/22
161/9 161/14 166/13
Mr Hollinrake [13]
42/23 42/25 46/2
46/12 47/11 48/24
49/16 51/1 51/7 65/23
66/14 76/13 89/25
Mr Hollinrake's [1]
44/12
Mr Ismail [2] 73/13
77/22
Mr Justice [4] 25/2
57/2 59/14 136/17
Mr Justice Fraser [2]
131/16 163/21
Mr Lee [1] 163/9
Mr Lucas [1] 44/13
Mr McInnes [1] 65/21
Mr Moloney's [1]
135/19
Mr Neidle [1] 158/25
Mr Patterson's [1]
21/16
Mr Railton's [1]
122/19
Mr Read [22] 1/7 5/5
16/1 52/12 89/10
122/15 125/4 128/11
128/21 132/5 132/12
135/24 136/12 141/14)
141/19 142/13 154/7
154/17 160/4 164/15
164/20 166/15
Mr Recaldin [4] 39/9
39/12 41/20 49/19
Mr Richards [1] 74/5
Mr SivasubramaniamI
[1] 131/7
Mr Staunton [5] 1/23
73/14 89/22 89/25
117/23
Mr Underwood [3]
160/17 161/21 162/14I
Mr Vamos' [1]
154/19
Mr Williams [1]
164/7
Mr Woodley [1] 5/15
Mrs [3] 135/16 152/7
156/2
Mrs Blakey's [2]
152/7 156/2
Mrs Misra [1] 135/16
Ms [21] 1/21 6/1
12/24 17/24 20/11
42/18 46/23 47/13
53/2 54/16 54/17
55/11 56/8 60/23
65/21 67/15 68/2 73/3I
75/5 78/12 125/6
Ms Brooks-White [1]
42/18
Ms Gallafent [1] 1/21
Ms Gratton [2] 68/2
73/3
Ms Gratton's [1]
78/12
Ms Gray [4] 6/1
12/24 17/24 20/11
Ms Marshall [2]
54/17 60/23
Ms Marshall's [1]
56/8
Ms Page [1] 125/6
Ms Scarrabelotti [1]
75/5
(69) meant... - Ms Scarrabelotti
47/13 65/21 67/15
Ms van [3] 53/2
54/16 55/11
67/3 69/23 74/6 74/7
93/9 98/25 113/12
113/12 114/7 133/15
138/16 143/13
multiple [1] 136/7
multitude [1] 143/21
must [15] 10/1 10/4
10/6 24/8 24/10 25/7
79/17 95/12 105/3
110/8 148/11 154/20
158/18 164/18 165/3
mutating [1] 144/5
my [59] 14/1 15/20
70/13 70/13 71/4
71/10 72/8 72/15
73/10 74/10 74/17
75/3 77/23 86/18
93/10 98/14 99/22
103/5 105/6 107/14
108/18 111/9 111/20
113/22 122/19 123/21
131/5 131/16 133/25
138/16 143/9 143/23
myself [2] 75/22
130/2
NO
nadir [1] 126/7
name [2] 34/17
140/19
namely [1] 64/12
narrow [2] 133/18
133/22
national [3] 93/18
93/21 136/8
Nationally [1] 95/16
natural [3] 112/12
112/22 118/13
naturally [1] 73/11
nature [5] 14/15
84/21 98/25 115/24
157/24
navigation [2] 70/7
70/7
near [1] 103/25
nearest [5] 95/18
95/21 95/23 95/25
Ms Sheratt [4] 46/23
much [18] 30/2 38/24
88/16 88/18 89/5 91/4
21/11 29/2 34/17 36/5)
42/24 44/2 46/4 48/10
62/3 63/3 63/23 68/14
126/20 130/11 130/17)
145/15 146/10 148/15)
148/20 149/15 152/12)
156/10 157/22 160/19}
161/22 166/16 166/16)
myriad [2] 30/10 33/2
96/7
nearly [2] 43/23
165/7
72/1 73/18 111/18
134/13 141/12 153/8
155/8 158/1
necessary [4] 39/2
40/3 73/23 86/22
NED [1] 45/16
67/11 68/8 68/16
85/12
need [34] 8/17 8/19
12/9 16/20 28/11 47/1
47/4 48/17 50/1 50/3
67/1 67/3 67/5 67/13
78/23 88/19 89/13
92/4 98/18 104/8
104/17 106/8 106/12
143/3 143/14 152/14
155/11 159/23
needed [10] 6/21
14/22 28/1 28/13
28/18 37/4 50/6
103/15 117/7 117/7
needs [14] 27/2 27/2
27/13 27/12 42/3 62/15
98/9 103/20 105/23
110/18 111/7 112/9
112/11 151/41
negligence [8] 79/14
79/15 79/23 82/25
84/11 84/19 86/7
139/5
negotiation [1] 57/11
Neidle [2] 158/7
158/25
neither [1] 43/11
network [8] 53/17
54/1 56/4 83/10 83/11
90/8 95/12 96/9
neutral [1] 151/3
never [11] 54/6 124/3
125/23 126/18 126/19)
128/23 133/3 137/18
148/7 151/24 163/9
new [24] 6/24 7/1
9/13 12/8 18/8 22/17
25/25 39/19 40/19
54/2 57/8 59/4 75/2
78/19 80/10 81/9
81/10 93/3 93/4 93/8
93/15 112/10 112/16
119/10
Newspaper [1]
128/14
next [11] 3/15 62/2
87/15 104/22 105/25
109/6 109/21 114/1
necessarily [9] 71/22
NEDs [14] 30/21 41/2
43/1 64/13 65/8 65/14
71/20 73/4 73/10 74/4
106/25 107/24 110/12)
113/12 119/22 135/13)
114/7 149/16 151/16
NEFSP [1] 77/8
NICHOLAS [2] 1/3
168/2
Nick [4] 160/18
Nicola [1] 5/15
Nigel [2] 119/12
119/23
night [1] 131/13
Nisa [2] 65/15 70/1
no [72] 4/20 12/9
25/17 28/20 28/24
29/18 30/6 33/11
33/17 33/21 37/10
37/19 38/6 39/18
62/3 69/10 73/10
75/21 78/15 78/23
88/11 89/13 92/4
117/13 118/3 121/2
124/1 124/17 124/17
129/1 129/17 131/23
141/5 143/25 144/12
147/24 148/3 148/9
151/23 151/23 152/1
152/25 153/22 154/8
156/5 158/12 158/13
164/22 164/22
nodded [2] 12/18
15/10
nominated [1] 9/24
non [22] 10/9 64/21
65/16 65/17 69/14
70/10 70/18 72/3
77/21 77/24 78/2
103/6 118/17 125/18
135/14 141/2 144/1
144/4
non-disclosure [2]
125/18 135/14
Non-Execs [1] 77/21
Non-Executive [13]
64/21 65/16 65/17
69/14 70/10 70/18
72/3 72/22 75/8 75/22
76/5 77/24 103/6
non-legalistic [1]
144/1
non-transparent [1]
118/17
none [2] 1/25 118/7
Nor [1] 2/6
normal [1] 116/12
not [174]
note [6] 14/13 20/24
37/3 40/5 76/12
135/14
17/17 19/2 19/4 21/15)
40/10 43/5 51/17 53/1
106/25 107/14 107/24
124/20 124/20 127/15}
135/13 135/24 135/25)
139/18 139/23 140/14
148/12 148/25 151/14
72/22 75/8 75/22 76/5)
notes [3] 2/18 72/9
145/15
118/19
notice [1] 103/5
60/5
noting [1] 13/5
notion [3] 34/14
143/19 146/6
notwithstanding [3]
43/15 74/25 119/2
November [2] 122/3
132/1
November 2023 [1]
132/1
now [58] 4/18 11/14
16/13 18/19 22/15
28/20 29/13 31/23
44/16 57/17 63/21
78/4 87/12 88/4 89/2
122/21 126/2 126/11
127/11 128/14 129/11
129/11 130/13 130/21
130/24 131/6 131/23
133/10 133/11 134/5
134/10 135/5 136/11
140/7 140/18 142/5
142/6 142/6 142/18
143/16 145/25 149/3
159/6 159/8 162/8
164/20 166/3 166/7
166/24
NR [2] 42/20 44/22
number [19] 12/1
12/5 14/8 14/15 19/13}
19/16 28/9 29/12 83/3}
83/8 91/2 91/8 105/3
114/19 115/19 119/19}
123/19 157/20 158/15)
number 1 [1] 91/8
numbers [1] 29/11
numerous [1] 53/25
[e)
obfuscation [1]
147/3
objective [6] 11/16
18/3 18/5 83/21 127/5}
140/17
objectively [1] 8/13
objectives [6] 101/16
103/13 109/15 146/8
146/12 146/14
obligation [3] 96/16
96/18 154/9
obligations [3] 82/24
97/7 103/9
obliged [1] 24/11
observation [1]
noted [2] 12/25 39/22!
nothing [3] 3/5 26/10
notified [3] 57/6 57/9
110/18 114/15 122/16}
137/15 139/20 139/24)
149/11 149/19 157/13}
99/23
observations [2]
102/25 156/18
observe [1] 23/25
obstructed [1]
134/21
obtained [3] 24/5
128/15 150/17
obtaining [3] 24/1
107/10 164/9
obvious [3] 102/18
103/19 139/7
obviously [34] 16/9
16/13 19/10 20/14
26/19 26/20 34/16
38/19 44/22 62/5 70/8
74/122 74/23 85/23
87/24 88/3 92/16 94/9I
94/21 104/12 104/15
104/17 116/3 116/13
123/19 123/24 129/3
129/13 137/3 140/9
145/11 155/11 157/19)
165/18
OC [2] 131/2 149/18
occasion [1] 91/8
occasionally [1]
147/1
occasions [1] 54/1
occupying [1] 117/5
occur [2] 15/12 19/17
occurred [13] 16/5
33/5 38/17 74/17
74/18 74/21 83/6
83/22 88/8 88/18
116/3 142/12 164/10
occurring [2] 112/5
117/16
October [2] 1/1 9/9
odd [1] 146/1
off [12] 13/18 47/4
51/2 53/15 66/16 68/1
76/15 122/25 123/19
124/3 151/1 151/7
offence [3] 24/3 24/8
24/9
offences [5] 22/18
23/10 23/17 23/25
25/20
offer [4] 30/7 39/24
44/4 92/20
offered [2] 104/10
134/11
office [239]
Office's [16] 2/1 2/10
2/19 82/19 101/15
105/2 110/12 112/7
120/9 125/13 127/18
133/4 144/23 153/20
154/21 163/4
officer [6] 24/2 24/6
24/15 24/22 45/4 45/6I
officers [6] 22/19
23/5 23/15 23/23 24/2
(60) Ms Sheratt - officers
[e)
offices [7] 10/17
100/3 113/8 113/19
officials [1] 107/20
oft [1] 166/17
oft-repeated [1]
166/17
often [1] 8/18
Oh [2] 73/8 161/11
okay [8] 7/25 21/8
34/6 34/25 45/7
old [11] 6/18 6/24 8/1
154/7
old-fashioned [2]
153/19 153/24
omission [2] 140/4
140/6
on [226]
once [3] 16/11 27/6
33/6
one [61] 1/9 1/17
4/17 1/18 1/18 15/4
30/21 31/14 36/19
61/4 66/7 66/7 66/7
66/10 68/20 69/24
104/3 104/6 104/20
109/22 111/21 114/11
118/3 122/17 123/21
124/7 141/13 141/14
146/10 146/24 147/17)
147/25 149/8 155/16
157/6 161/2 162/9
164/7
ones [1] 14/5
ongoing [12] 4/7
35/8 40/5 40/8 40/17
40/18 44/6 57/15
62/14 70/4 70/4
108/15
online [1] 86/10
only [14] 8/7 9/21
25/24 28/18 29/13
31/13 78/16 91/24
115/1 131/18 137/16
157/15 163/16 163/23}
onto [1] 65/14
onus [4] 74/7 88/16
88/16 88/18
onwards [1] 27/18
op [1] 97/9
open [6] 68/14 73/12
officers... [1] 24/24
113/25 114/19 114/20)
139/16 150/15 161/11
8/23 11/7 11/13 18/16
135/13 153/19 153/24)
onboarding [1] 56/13
18/2 20/24 29/2 29/18}
40/6 40/14 44/7 46/14
52/15 55/4 55/9 55/15)
72/17 74/2 75/18 79/8
84/9 85/12 91/2 92/14
100/12 100/15 100/15}
136/1 143/10 165/18
166/1
operate [3] 26/5
99/13 113/10
operated [2] 13/17
18/16
operating [8] 26/14
51/24 59/13 59/20
operation [3] 58/13
88/12 136/6
operational [1] 7/2
operations [1] 136/8
operators [1] 75/21
operators/retailers
[1] 75/21
opine [1] 46/4
opinion [3] 2/22 14/5
145/20
opportunities [2]
93/16 109/15
opportunity [10]
33/23 48/25 61/21
67/12 73/20 78/5
121/7 121/15 163/25
164/2
opposed [5] 37/6
63/6 98/17 98/24
137/9
Optically [1] 161/24
optimistic [1] 124/10
or [200]
order [5] 7/20 15/12
48/18 54/1 162/6
organisation [38]
4/21 4/24 5/1 15/18
16/23 18/8 27/8 27/11
28/8 28/17 29/16
36/21 36/22 37/13
37/23 38/8 38/9 38/12
38/15 50/8 52/4 65/2
71/14 74/10 94/3
101/16 103/11 103/13)
103/18 107/3 107/17
112/22 117/16 118/11
118/15 119/24 133/20}
160/16
organised [1] 30/3
originating [2] 9/19
10/3
other [33] 7/2 21/3
22/12 30/7 30/10
36/24 40/16 46/25
49/1 50/12 58/24
63/16 65/20 65/22
68/19 70/8 72/4 75/21
75/21 75/23 77/4
82/12 82/15 84/24
92/14 111/1 112/7
113/18 136/24 144/18)
158/11 161/8 162/16
other's [1] 155/6
others [11] 3/10 5/14
10/19 23/10 29/3
68/3 73/4 76/16 94/19
39/13 76/13 130/2
ought [5] 136/21
137/23 138/6 140/23
142/7
our [20] 4/7 21/1
31/25 35/10 35/11
36/15 47/2 47/9 51/21
66/3 70/14 76/7 83/21
93/13 93/14 102/21
146/10
ourselves [6] 20/21
20/25 110/21 130/14
130/25 159/21
out [40] 9/4 35/9
48/6 49/20 54/22
55/16 56/21 71/15
78/3 80/18 83/5 84/6
85/15 90/10 94/18
97/17 99/14 102/18
108/4 109/9 129/25
130/16 132/16 143/2
144/11 144/23 147/8
147/15 149/5 152/8
152/10 153/8 154/12
160/23 164/5 166/10
outcome [4] 124/4
162/3 162/16 162/21
outlet [5] 95/18 95/21
95/23 96/1 96/7
outlets [1] 48/8
outlining [1] 89/22
output [2] 108/14
108/25
outputs [1] 104/20
outrage [2] 116/5
116/6
outright [1] 133/3
outset [1] 107/3
outside [3] 18/10
103/18 151/6
outsiders [1] 23/14
outstanding [2]
27/11 53/19
over [33] 8/10 15/1
21/12 23/2 28/16 41/7
43/22 48/10 49/21
63/16 76/4 84/23
84/24 92/25 101/4
101/23 102/14 103/3
104/22 105/25 109/18}
109/21 111/16 113/14
118/25 126/2 129/22
133/7 134/17 135/7
135/13 158/11 165/14)
overall [2] 136/5
157/21
overarching [1]
116/24
overly [1] 153/1
oversight [5] 76/24
7719 77/112 77/15
151/18 157/19 159/15}
112/20 113/19 121/16
35/16 35/23 46/7 46/8
77N9
overturned [4]
148/18 149/11 152/2
155/9
Overview [1] 101/10
owe [1] 35/10
owing [1] 160/19
own [11] 29/2 58/16
68/4 76/18 77/24
79/14 112/20 123/10
124/3 127/18 132/25
owned [2] 91/1
103/10
owner [3] 103/15
103/21 106/5
ownership [2] 110/3
110/23
Pp
page [36] 8/10 12/21
22/24 23/3 34/20
34/22 39/10 39/11
40/12 41/18 41/24
42/17 44/9 44/10
45/12 49/21 53/14
53/15 64/19 78/22
79/7 91/10 95/11
101/4 101/8 107/25
109/4 109/6 109/18
120/5 120/16 125/6
161/17
page 1 [1] 160/10
page 105 [1] 120/5
page 107 [1] 120/16
page 109 [1] 109/4
page 11 [1] 34/20
page 12 [1] 138/12
page 2 [3] 41/24
91/10 161/17
page 22 [1] 107/25
page 3 [2] 40/12
41/18
page 4 [1] 39/11
page 46 [1] 64/19
page 5 [1] 39/10
page 7 [1] 12/21
page 72 [1] 22/24
page 8 [1] 101/8
pages [4] 22/16
53/19 158/10 158/12
pages 71 [1] 22/16
paid [4] 46/17 126/9
149/1 162/10
painful [2] 152/10
165/10
painstaking [1] 28/12)
paints [1] 158/1
pan [1] 8/11
pan-Post [1] 8/11
panel [3] 150/9 151/6
151/10
panels [1] 166/3
Panther [1] 11/17
138/12 160/10 160/17)
paper [17] 5/17 5/21
10/11 11/5 12/1 12/20
12/25 13/3 13/9 13/25)
16/16 19/6 20/7 38/1
109/4 160/13 160/14
paragraph [26] 7/9
9/5 9/5 10/11 11/21
12/22 23/18 27/18
35/1 35/7 55/19 64/16
64/19 87/2 89/14
89/21 92/3 107/25
115/6 120/3 120/5
120/16 131/17 138/12)
163/13 163/15
paragraph 1 [2] 9/5
35/1
paragraph 14 [1]
23/18
paragraph 169 [1]
89/21
paragraph 2 [1] 7/9
paragraph 20.3 [1]
87/2
paragraph 214 [2]
120/3 120/5
paragraph 220 [1]
120/16
paragraph 23 [1]
138/12
paragraph 230 [1]
27/18
paragraph 238 [1]
55/19
paragraph 246 [1]
89/14
paragraph 252 [1]
115/6
paragraph 273 [1]
92/3
paragraph 3 [1] 35/7
paragraph 38 [1]
107/25
paragraph 4.6 [1]
12/22
paragraph 6 [1]
10/11
paragraph 83 [2]
64/16 64/19
paragraph 886 [2]
131/17 163/15
paragraph 9 [2] 9/5
11/21
paragraphs [5] 27/19)
76/21 76/22 88/13
106/25
paragraphs 31 [1]
106/25
Paragraphs 4 [1]
88/13
parallel [1] 38/24
paralysed [1] 17/1
paramount [1] 117/5
parcels [3] 93/13
94/12 94/15
(61) officers... - parcels
Pp
pariahs [1] 157/10
Park [1] 87/15
Park's [1] 88/11
Parliament [1]
142/23
part [29] 9/11 22/2
22/5 27/13 34/13
38/10 48/14 64/22
65/11 76/3 78/8 92/14,
92/14 97/22 101/8
103/10 114/3 116/3
116/17 116/20 117/8
117/20 118/16 121/7
121/20 122/20 131/19}
136/10 163/17
Participant [1]
124/15
Participants [1]
124/19
particular [30] 8/25
15/16 15/16 26/22
36/18 47/10 48/5 55/3
71/22 71/25 74/12
76/1 84/8 85/11 88/15)
99/1 102/17 102/25
104/14 111/2 111/21
112/9 117/11 117/13
118/20 130/12 130/16
131/3 155/15 156/10
particularly [13] 1/20
3/19 26/23 26/23
26/24 33/14 60/2 81/8
94/11 129/23 142/9
149/18 165/14
partner [1] 101/5
partners [1] 97/9
partnership [1] 90/25)
parts [2] 49/1 101/20
party [1] 101/2
pass [3] 6/12 46/5
138/3
passage [2] 5/18
109/12
passed [7] 7/22 9/20
10/13 43/2 46/24
66/20 163/7
passing [6] 6/6 9/1
10/6 11/11 13/1 21/2
past [35] 7/18 18/14
27/14 27/21 27/22
28/14 29/25 30/13
30/25 31/15 35/15
36/10 36/25 37/10
37/19 38/13 38/16
39/5 39/7 39/25 41/10
41/16 42/3 43/10 46/9
51/25 61/1 62/11
79/22 127/22 127/23
138/14 138/20 142/18
165/25
patch [1] 68/1
path [2] 109/16 133/5
Patrick [1] 33/11
pause [2] 19/17
19/18
pay [7] 130/15 131/2
134/21 139/1 142/2
144/19 161/10
payable [2] 141/3
141/12
paying [4] 51/1 85/14
85/15 87/19
payment [7] 87/7
87/10 87/18 152/13
payments [7] 44/4
130/15 131/2
peculiar [2] 48/12
132/18
peer [1] 69/7
pejoratively [1]
164/14
penury [1] 128/9
people [54] 36/11
36/15 37/2 37/3 37/4
37/18 38/8 41/22 44/5
48/3 48/14 50/1 50/12
51/2 51/4 52/3 64/7
77/13 114/7 114/24
115/11 120/22 122/7
125/7 127/25 129/8
129/13 130/5 132/20
133/15 134/3 141/24
142/2 142/8 142/10
143/10 143/11 143/14)
143/18 152/18 153/8
153/11 154/5 154/8
154/13 154/17 154/22)
155/5 155/21 156/12
156/14 159/21 164/6
165/17
people's [1] 117/17
per [13] 25/25 92/6
92/9 93/19 94/7 94/8
94/15 115/1 115/4
115/5 120/24 120/24
120/25
perceived [5] 89/18
101/14 102/11 115/24)
116/11
perception [3] 7/13
107/3 117/15
peremptorily [1]
131/11
perfectly [1] 141/15
performance [4]
72/19 91/12 91/21
120/23
performed [2] 35/15
45/23
perhaps [15] 18/14
22/11 25/3 36/7 75/14
101/7 101/22 107/18
114/22 116/18 118/18)
Patterson's [1] 21/16
157/14 158/13 161/22)
49/3 87/17 88/7 100/8
119/3 120/4 127/18
143/22
period [2] 117/13
120/2
permissible [1]
57/11
permission [8] 7/17
18/1 21/4 135/20
perpetuity [1] 97/13
perplexing [1]
155/21
person [13] 24/4
24/8 24/11 24/15
24/17 24/18 24/20
45/3 54/11 55/20
55/21 61/4 136/25
person's [5] 45/3
74/2 126/12 127/1
158/21
personal [7] 3/8 3/9
29/22 71/8 93/10
93/20 98/14
personally [3] 84/20
124/6 132/21
personification [1]
147/4
personnel [2] 18/23
120/13
persons [2] 23/16
23/22
perspective [10]
36/5 71/4 77/17 93/6
107/15 108/19 111/12
112/18 143/24 166/5
phase [4] 47/22
47/25 52/14 123/23
Phase 2 [1] 123/23
Phase 5 [2] 47/22
47/25
phasing [1] 49/19
Phoenix [6] 27/13
27/21 27/22 29/2
29/25 43/11
phrase [1] 166/17
pick [1] 47/3
picture [6] 8/12
14/10 14/20 68/7
136/13 158/2
piece [10] 28/7 37/16
37/22 38/6 108/14
108/20 111/13 123/22
124/3 160/9
pieces [3] 27/15
38/23 123/24
pillars [1] 120/9
Pineapple [7] 67/6
67/25 68/10 69/13
70/12 70/19 73/15
place [14] 30/18
31/25 39/20 47/2 55/1
60/15 68/2 76/16
116/22 116/22 119/7
131/12 144/14 166/8
7/23 13/9 15/12 15/14
placed [4] 62/8 63/11
73/16 74/7
plan [11] 98/24
124/9 124/10 124/12
124/14
Plan A [1] 124/9
Plan B [1] 124/10
Plan C [1] 124/12
planning [1] 104/16
plans [4] 93/11 113/2
122/6 122/10
platform [1] 93/14
plausible [1] 147/17
play [7] 6/18 7/12
69/9 75/14 75/20
77/21 105/17
played [3] 42/8 71/15
77/10
players [1] 111/1
playing [2] 67/23
69/20
please [59] 4/3 5/10
10/10 12/19 12/21
22/9 23/1 27/17 30/24,
35/1 39/11 40/12
41/18 41/19 41/24
42/10 42/15 42/17
44/7 44/14 45/24
49/21 52/7 53/7 53/18)
54/13 54/19 56/7
56/14 56/22 57/1 57/7,
57/10 57/13 57/16
57/18 57/23 58/10
58/14 59/1 59/8 59/23)
60/6 65/19 76/14
76/21 79/7 79/11
89/13 95/4 95/10
100/18 101/6 101/7
109/4 109/7 120/5
150/23 161/18
pleased [2] 66/3
66/11
plenty [1] 152/3
plus [1] 12/12
pm [5] 89/6 89/8
124/23 124/25 167/3
pod [1] 69/12
POID [1] 23/6
point [33] 3/13 17/2
46/7 50/15 62/3 63/2
63/3 66/15 68/11 83/4
85/22 91/6 91/15
94/17 97/24 99/11
99/14 102/18 102/23
114/9 124/1 130/1
132/16 133/4 150/4
150/8 150/16 152/5
152/6 152/21 157/22
161/3 162/9
pointed [2] 46/7
144/11
pointing [2] 78/3
109/11 109/18 109/20)
121/25 122/21 122/23)
166/10
points [1] 130/5
poison [1] 145/6
POL00000254 [3]
22/9 78/24 79/6
POL00027887 [1]
94/24
POL00088956 [1]
54/13
POL00155397 [1]
160/3
POL00294728 [1]
53/7
POL00446476 [1]
100/15
POL00448308 [1]
31/1
POL00448310 [2]
5/10 12/19
POL00448345 [1]
5/24
POL00448615 [1]
33/9
POL00448624 [1]
109/3
police [20] 8/6 8/8
8/14 8/16 12/23 13/1
13/4 16/4 16/7 16/9
16/12 16/14 16/17
16/18 17/11 17/15
17/20 23/9 24/2 25/21
policies [11] 6/24 8/1
8/23 11/7 11/13 57/20I
57/25 58/23 59/3
59/12 59/17
Policies’ [1] 6/18
policy [16] 6/12 6/16
6/17 7/1 7/2 7/2 7/10
8/22 97/17 97/19
105/6 105/7 106/10
123/23 155/19 158/7
Policy’ [1] 7/1
political [1] 162/1
pontificate [1] 46/10
poor [1] 153/9
populated [1] 77/12
population [10] 94/5
95/16 95/17 95/19
95/22 95/24 96/6
96/25 99/4 99/5
port [1] 83/25
portrayed [2] 2/21
145/19
pose [1] 31/22
position [21] 2/10
3/20 7/25 13/8 36/2
46/4 47/22 47/24 56/4)
76/6 83/20 108/8
108/9 109/14 127/2
130/15 130/25 152/21
159/16 159/21 161/25)
ions [1] 117/22
positive [2] 65/8
65/10
(62) pariahs - positive
P
possibility [2] 23/21
141/4
possible [15] 7/11
25/20 30/8 50/10
61/15 81/20 82/1 82/7
99/11 106/4 118/9
126/25 151/13 151/15
152/15
possibly [6] 34/9
34/11 38/14 85/6
113/2 163/1
post [270]
post-2019 [1] 87/14
post-Group [1] 78/20
post-Horizon [1]
22/10
postcode [2] 96/4
96/6
posted [1] 154/21
postmaster [53]
26/10 28/24 30/21
31/9 31/24 55/20
56/13 61/19 62/13
62/16 62/21 62/23
63/5 63/21 64/21 65/8
65/13 67/11 67/13
67/18 67/22 68/11
68/16 69/14 70/10
73/10 75/8 76/5 76/24
77/1 77/7 77/15 7/21
77/24 78/6 78/8 78/20
79/3 84/1 85/2 85/18
89/15 90/6 90/16 91/7
94/5 94/7 115/10
121/6 121/13 121/16
137/13 150/13
postmaster-facing
[3] 61/19 62/21
62/23
postmasters [78]
1/16 5/7 11/1 22/14
26/8 28/4 31/7 31/20
43/7 49/13 57/15
58/19 58/24 60/16
62/11 63/6 63/24
67/16 68/19 68/21
69/2 70/2 71/23 75/13
77/3 77/14 78/13 79/2
83/19 83/21 84/4 84/6
84/8 87/17 88/2 88/3
89/16 89/18 90/7
90/17 91/9 91/22 92/7
93/16 93/19 93/24
94/13 94/20 105/16
105/19 105/22 105/24
106/2 106/21 107/4
113/8 113/15 114/4
114/23 115/7 115/9
118/16 118/25 119/9
120/15 121/1 121/7
121/9 121/16 121/19
121/20 121/22 128/9
149/6 154/25 155/8
155/11 159/14
potential [11] 37/11
51/23 60/1 61/1 87/23
140/14 140/23 144/8
potentially [7] 21/18
27/25 31/18 50/13
77/13 91/23 92/1
powers [1] 25/15
practicable [1] 24/18
83/3 83/3 86/8 99/3
practices [3] 81/9
112/3 165/25
pre [9] 10/3 11/3
12/14 33/23 42/5 52/2
53/8 84/10 122/4
pre-1 January [1]
10/3
pre-2019 [1] 84/10
pre-dated [1] 53/8
pre-dates [1] 11/3
Pre-emptively [1]
52/2
pre-January '22 [1]
12/14
pre-judge [1] 42/5
pre-read [1] 33/23
precise [1] 36/5
predecessor [1]
94/25
predecessors [1]
46/5
preferred [1] 29/25
prejudice [3] 49/16
125/21 153/21
premises [4] 131/19
131/21 163/17 163/18)
prepared [1] 141/15
preparing [1] 52/14
present [6] 5/14
62/12 66/1 75/5
105/12 122/5
presented [4] 11/23
12/21 12/23 38/20
press [1] 85/17
pressed [1] 84/14
pressing [1] 85/20
pressure [4] 49/11
69/6 74/10 162/2
presumably [6]
14/16 16/5 20/9 44/16
45/19 160/14
presumption [3]
26/24 63/20 85/8
pretences [1] 164/21
pretending [1] 75/11
pretty [4] 19/9 71/16
110/20 111/6
prevalent [2] 9/12
10/25
prevent [1] 54/7
previous [6] 40/7
139/12 139/22 140/13)
practice [6] 26/6 83/2I
48/23 63/8 95/11
120/9 148/16
previously [3] 31/5
54/20 64/12
pride [1] 116/9
primarily [3] 18/9
19/18 108/12
primary [2] 14/7 71/2
principal [2] 32/4
85/22
principle [8] 83/19
84/21 85/3 85/7
132/17 134/8 134/15
143/17
principles [6] 149/12
149/19 151/2 153/3
153/4 166/7
prior [9] 6/9 29/4
32/10 32/15 47/4
48/10 71/24 83/7
160/19
priorities [11] 65/3
89/12 89/23 90/1 91/2
91/5 98/13 98/14
98/15 98/17 98/17
ioritise [1] 109/16
prioritised [1] 137/8
priority [11] 89/16
89/17 90/16 90/17
90/23 91/3 91/11
91/25 91/25 93/25
94/2
prison [1] 135/21
private [2] 44/12
65/25
privileged [1] 139/3
proactively [3] 9/6
49/19 60/4
probably [13] 48/17
49/9 72/25 74/6 74/8
74/11 91/3 112/6
116/23 117/24 131/15}
143/17 144/25
problem [4] 34/7
54/24 61/7 87/20
problematic [4]
27/25 31/18 32/20
33/4
problems [5] 82/11
82/16 83/13 88/17
138/4
procedure [2] 24/3
137/4
procedures [1] 18/23
proceedings [1]
21/19
process [55] 6/6 6/23
9/15 10/4 10/25 19/2
21/22 22/6 25/16
28/12 42/12 43/13
47/5 51/2 54/6 54/7
57/5 57/8 57/12 59/9
83/24 84/14 84/16
84/25 85/1 86/11
127/18 129/2 129/6
129/18 130/1 142/14
142/19 143/15 144/1
144/4 144/6 149/7
149/12 150/16 151/3
152/16 152/17 153/1
153/10 155/12 155/15)
155/17 155/23 156/8
156/11 159/19 165/2
165/24 166/8
processed [1]
132/11
processes [1] 166/2
processing [2] 16/23
132/19
procured [1] 125/15
produce [2] 81/16
124/11
produced [1] 78/25
producing [1] 112/20
product [1] 32/1
products [3] 93/15
94/16 113/18
professional [1]
18/19
Professor [4] 39/12
39/14 40/12 41/19
Professor
Christopher [1]
39/12
Professor Hodges
[1] 39/14
profiles [1] 9/7
profitability [2] 96/20)
137/12
profitable [1] 97/3
profound [2] 116/1
126/22
progress [7] 2/7
21/11 64/7 121/10
122/11 149/11 166/16}
progressive [1] 77/8
project [28] 11/17
27/13 27/14 27/20
27/21 27/22 29/2
29/24 30/25 31/13
33/4 33/6 34/19 36/10)
37/10 39/8 40/1 41/10)
41/16 43/10 43/10
67/5 67/25 68/10
69/13 70/12 70/19
73/15
projected [1] 106/18
prolonged [2] 137/5
138/25
prolonging [2]
134/16 134/25
promised [3] 122/10
164/24 165/1
prompt [2] 166/19
166/19
promptly [1] 8/5
proof [1] 28/6
proper [6] 67/14
127/25 128/12 141/16
166/2 166/2
properly [14] 2/11
25/19 67/4 80/20
81/13 81/16 82/22
84/16 87/3 110/2
126/19 127/7 129/7
138/24
properties [1] 90/10
proportion [2] 92/17
136/3
proposal [3] 11/23
15/25 17/24
proposed [8] 6/5
8/22 10/16 11/22 12/8I
17/19 20/13 21/13
proposes [2] 7/3 9/1
propositions [1]
111/16
prosecuted [1]
125/20
prosecution [4] 19/1
35/6 125/12 156/24
prosecutions [1] 6/8
protect [1] 145/10
protection [1] 147/16)
protracted [1] 126/2
provide [17] 1/16
8/16 8/18 17/19 57/16I
60/13 61/21 81/3 81/6
86/5 95/8 96/9 121/15
136/7 162/6 162/19
166/21
provided [14] 7/8 8/8
13/14 17/13 29/17
55/12 58/9 59/21
60/11 61/25 80/23
105/9 115/23 160/6
provides [3] 24/2
68/23 87/2
providing [6] 7/4 7/6
19/22 60/23 111/4
114/4
provision [10] 3/5
6/21 15/8 41/3 58/18
58/20 81/7 81/10
99/10 163/5
proximate [1] 85/14
public [17] 31/9
31/23 47/11 71/15
71/18 96/16 96/19
96/22 97/7 97/12 99/7
100/4 105/2 105/8
110/8 119/9 147/22
publicity [2] 40/17
70/17
publicly [3] 50/19
50/21 103/10
published [1] 39/19
pulled [1] 66/12
pulling [1] 136/15
pulpit [1] 46/10
pulse [2] 121/9 122/5
punches [1] 136/15
(63) possibility - punches
P
punitive [2] 139/5
139/8
purdah [1] 40/4
purported [1] 46/19
purpose [20] 81/4
86/19 92/24 93/2
98/10 101/12 101/21
101/23 102/4 106/6
106/13 107/7 110/12
110/19 110/21 111/3
111/22 112/24 129/6
136/24
purposes [1] 15/6
purse [3] 152/24
152/25 153/14
pursue [1] 156/4
put [19] 16/16 31/10
54/22 55/1 104/23
113/15 114/13 116/14}
119/7 127/2 135/23
136/18 141/21 146/9
148/13 148/19 153/25
157/18 164/21
Putney [1] 131/9
putting [3] 71/18
71/19 141/14
PwC [1] 47/9
Qu
qualifications [1]
58/3
qualifier [1] 79/23
qualifies [1] 139/7
qualitative [1] 64/15
quality [4] 14/17
20/25 58/9 60/10
quarterly [1] 17/6
queries [1] 59/6
question [34] 4/5
4/16 4/24 24/3 24/20
26/15 26/18 34/11
41/25 42/11 48/4 48/7
49/25 56/19 69/10
78/17 82/25 85/7 98/8
98/9 106/8 110/17
111/6 113/6 114/17
117/13 123/18 132/11
133/16 146/2 148/9
149/23 151/16 155/21
questioned [5] 1/4
24/15 125/1 168/4
168/6
questioning [1]
166/25
questions [25] 1/9
13/7 15/1 24/9 24/21
53/19 59/6 63/15 75/9
81/11 82/9 86/19
106/4 109/19 110/14
110/22 113/4 113/15
113/20 113/24 114/6
124/15 124/16 124/21
159/8
quibbling [2] 148/12
148/25
quicker [1] 29/24
quickly [10] 49/1
50/9 50/16 55/1 55/4
74/23 148/13 156/19
158/10 165/3
Quinn [1] 33/12
quite [29] 12/4 13/20
25/19 56/23 57/18
57/19 62/19 63/1
71/13 77/6 77/21 78/3)
85/23 93/10 99/14
101/24 102/2 102/5
105/20 108/19 114/21
116/5 121/12 132/17
143/3 143/4 146/7
154/11 159/12
quote [1] 131/17
R
Rachel [1] 100/22
racking [1] 144/18
radical [1] 25/19
Railton's [1] 122/19
raise [5] 58/19 59/6
59/10 78/16 132/24
raised [7] 27/23
32/12 40/23 41/1
42/11 43/1 59/24
raises [1] 26/15
raising [2] 130/3
146/2
range [4] 3/4 62/25
109/19 123/19
ranges [3] 151/5
151/5 151/7
rather [17] 27/10
30/6 34/2 38/23 45/9
47/18 50/2 50/12 80/1
104/17 110/14 110/15)
114/11 116/11 137/12)
153/10 157/15
rationale [1] 161/24
reached [2] 127/3
149/3
reactively [1] 9/6
read [34] 1/3 1/7 5/5
12/7 16/1 27/19 31/13
33/23 42/11 52/12
53/1 66/1 78/12 78/15
89/10 99/1 122/15
125/4 128/11 128/21
132/5 132/12 135/24
136/12 141/14 141/19}
142/13 154/7 154/17
160/4 164/15 164/20
166/15 168/2
reading [3] 20/24
26/10 47/17
readout [1] 65/19
reads [1] 48/1
real [5] 48/25 69/18
100/1 102/4 112/23
realisation [1]
148/25
realise [3] 109/17
158/14 164/20
reality [1] 62/8
really [7] 55/15 61/24
76/3 114/3 141/20
150/14 161/11
reason [10] 16/10
23/15 50/12 80/19
87/18 88/14 98/4 98/6
132/8 159/20
reasonable [8] 24/7
26/18 27/1 80/18 82/4]
82/4 113/6 163/25
reasonably [2] 81/4
119/20
reasons [11] 3/4 4/3
18/2 33/2 46/14
115/19 129/13 130/14
132/4 143/21 149/1
reassurance [4]
14/24 40/20 43/4
75/23
reassured [1] 108/21
rebuilding [4] 28/25
Recaldin [9] 27/24
32/17 39/9 39/12
41/20 44/2 45/19
49/19 149/16
Recaldin's [1] 3/14
recall [11] 1/12 2/4
5/16 15/15 17/16 20/8
32/11 43/3 77/8
161/15 161/16
receipt [1] 138/5
receive [6] 60/17
99/6 99/9 129/8 140/8
143/20
received [1] 138/15
receiving [3] 128/12
128/19 128/23
recent [1] 112/8
recently [4] 5/13 8/7
119/21 133/14
recipient [2] 33/25
34/1
recklessly [1] 139/4
recognise [7] 29/22
35/14 43/14 69/7
79/19 107/21 148/6
recognised [1] 106/2
recognising [1]
68/22
recognition [2]
148/10 155/14
recollection [3] 14/1
42/24 111/9
recommendations
[5] 2/7 4/4 4/13
112/14 124/8
recompense [1]
128/23
reconciliation [6]
83/16 83/17 84/3 88/1
88/2 88/8
reconstructed [1]
159/6
recontracting [1]
27/10
record [10] 9/25 44/7
44/13 44/15 44/18
67/21 68/7 81/13 87/3,
87/17
recorded [11] 10/1
20/15 24/21 47/13
48/19 48/24 49/22
50/18 50/22 65/25
67/9
recording [2] 87/10
103/14
records [8] 28/15
31/1 81/14 81/17 87/4
131/22 163/20 164/4
recover [1] 126/8
recovery [2] 19/23
80/11
recruited [1] 31/4
rectify [1] 93/25
recut [1] 159/9
red [1] 156/7
redress [14] 1/16 2/3
3/6 4/2 41/3 42/5
107/12 107/16 127/5
128/12 134/9 143/20
145/9 155/16
reduce [1] 163/4
reduced [3] 92/16
159/8 159/17
redundancy [4] 30/8
44/4 44/4 50/10
reemployment [1]
32/9
refer [4] 50/16 72/14
137/24 138/7
reference [9] 30/25
33/3 34/10 46/16
66/21 89/20 100/3
102/8 103/6
referenced [1] 10/12
referral [1] 137/18
referred [1] 45/7
referring [4] 14/18
66/4 66/8 77/18
refine [1] 47/2
reflect [3] 8/23 55/16
127/7
reflected [1] 110/2
reflection [6] 36/8
37/11 44/2 74/6 74/8
74/11
Reflections [1] 37/13
reflective [3] 26/13
114/10 154/7
reflects [1] 25/8
regard [1] 130/6
regarding [1] 6/5
regardless [1]
161/23
regret [4] 143/23
143/25 145/13 154/4
rehiring [1] 32/14
Reinstatement [1]
60/18
reintroduce [1] 55/7
reject [8] 130/8
130/10 130/18 133/3
133/18 133/19 133/22)
152/23
rejected [4] 132/3
135/22 136/9 155/10
rejection [1] 132/5
related [2] 12/14
136/4
relating [2] 58/23
82/16
relation [15] 13/6
14/14 20/16 21/8
22/14 40/7 58/12 60/1
60/25 62/25 75/8
79/23 96/13 117/10
139/18
relationship [6]
94/20 101/13 102/10
143/8 145/6 145/11
relatively [3] 5/13
18/8 103/25
relevance [1] 32/24
relevant [9] 10/5
30/22 40/16 57/1 57/6I
64/23 81/16 81/17
134/17
reliability [5] 11/18
18/24 21/1 22/1 55/10
reliable [1] 136/3
reliant [1] 102/21
relied [1] 7/11
relieving [1] 8/9
relinquishes [1] 80/7
rely [3] 11/20 19/1
128/14
rem [1] 67/18
remain [1] 29/16
remained [2] 89/17
100/1
remains [2] 29/19
155/13
remediation [5] 31/4
31/10 32/22 44/5
155/15
remedy [1] 54/1
remember [7] 1/19
17/5 42/1 72/17 75/15)
78/25 143/2
remind [1] 163/14
remote [9] 52/17
52/24 53/3 53/5 53/21
56/1 61/5 61/14 61/15}
remotely [7] 53/23
53/25 54/5 54/10
54/23 55/6 82/19
(64) punitive - remotely
R
42/3 63/13 147/17
removed [2] 126/18
147/25
remunerated [1]
90/24
remuneration [10]
91/22 91/24 92/8
93/24 94/7 113/17
rep [1] 67/24
repay [1] 156/24
repeat [1] 138/20
repeated [1] 166/17
repeating [2] 142/11
142/20
repellency [1] 81/5
repetition [1] 127/22
replace [1] 120/8
replaced [1] 9/9
replacement [1] 8/23
replies [2] 24/21
46/23
report [19] 5/24 7/9
33/8 33/16 33/17
33/21 72/6 100/10
100/13 100/21 101/5
101/9 102/25 103/19
166/16
reported [5] 7/14
9/14 66/14 115/1
131/25
reporting [3] 8/3 23/1
25/20
reports [5] 2/8 34/14
58/8 60/9 72/15
represent [1] 125/6
representation [3]
141/25 142/2 142/10
representative [2]
68/18 146/25
representing [3]
68/21 70/2 132/20
represents [3] 80/16
92/7 126/3
reprisals [1] 74/13
reps [1] 69/22
reputation [5] 110/5
127/18 157/1 158/22
159/2
reputational [3]
50/23 137/9 147/10
requested [4] 10/2
14/11 14/23 16/9
requesting [5] 8/15
10/8 12/4 12/4 16/17
requests [13] 8/5
8/12 13/16 13/18
13/19 14/2 14/3 14/6
14/8 14/16 16/3 16/24}
56/15
remove [4] 30/17
89/16 90/6 90/15 91/7
16/6 16/12 17/25 23/3)
require [2] 39/21
88/14
required [13] 7/16
7/22 8/13 13/5 13/9
14/14 20/16 54/6
72/12 80/7 96/9
104/20 105/6
requirement [2]
13/19 105/4
requirements [10]
96/12 96/22 99/8
100/4 108/5 162/5
requires [3] 25/18
70/6 81/9
requiring [1] 23/25
research [1] 135/5
resolution [4] 9/15
11/9 84/25 125/9
resolve [4] 59/11
84/7 85/10 130/16
resolved [1] 43/22
resolving [2] 9/14
88/9
resonate [1] 30/13
respect [6] 7/11
29/24 64/21 130/12
158/8 165/8
respond [3] 15/16
46/1 61/23
responded [1] 93/19
responding [1] 56/15
response [2] 19/20
74/13
responses [1] 58/6
responsibilities [1]
83/9
responsibility [15]
2/12 8/7 18/1 56/13
57/24 59/2 59/16
63/23 73/14 73/22
73/25 74/3 79/10 80/6
127/25
responsible [6]
57/21 58/3 59/20
79/13 85/20 129/20
responsive [1] 37/20
restatement [2]
26/19 27/10
restitution [1] 107/13
restorative [3] 29/8
126/20 143/9
restore [2] 110/8
127/1
restrict [1] 162/24
restrictive [1] 133/17
result [3] 32/1 54/2
67/25
resulted [1] 6/21
resulting [1] 82/12
results [5] 121/14
121/17 121/18 121/22)
122/5
resume [1] 166/25
94/23 95/3 95/6 95/13)
retail [6] 56/11 77/1
77/5 77/17 77/20
77/125
retailers [2] 75/21
111/2
retained [1] 61/20
retains [1] 25/15
retention [2] 60/24
60/24
return [1] 158/3
returned [1] 163/9
returning [1] 130/3
revealed [1] 128/16
revelation [2] 117/8
135/8
revelations [1] 112/3
revenue [5] 92/6
92/17 93/17 94/4
94/12
review [38] 9/11
28/16 31/15 40/6
97/19 98/20 100/20
100/25 101/1 101/3
104/23 105/6 105/7
106/10 108/1 108/6
108/24 109/3 109/5
109/7 109/10 109/13
111/21 112/9 112/20
114/2 119/12 119/14
124/2 137/18 140/1
reviewed [2] 59/22
59/25
reviews [4] 58/8 60/9
104/2 104/3
revision [1] 25/19
rewording [2] 27/2
27/3
Richards [1] 74/5
rifts [1] 73/15
right [59] 5/3 6/11
7/20 9/22 18/12 18/12
21/21 22/13 33/16
41/11 41/15 42/21
43/18 44/22 46/9
47/20 56/25 64/17
75/12 76/8 78/18 98/2
100/9 102/1 102/6
103/8 104/25 109/12
109/22 119/13 122/18I
123/2 123/2 123/8
123/16 123/16 130/5
130/8 132/12 132/14
137/3 142/10 143/5
143/17 144/21 150/6
150/10 150/14 150/20}
151/1 151/9 151/21
152/1 158/18 158/21
158/25 164/18 165/3
166/6
right-hand [1] 109/12
right-thinking [1]
130/5
40/11 47/2 47/4 47/10
108/11 108/15 108/18}
rightly [7] 13/20 78/3
99/14 116/5 132/15
132/17 144/11
rights [4] 30/20
rigour [3] 11/17 18/3
18/5
ring [1] 83/18
rising [1] 67/19
risk [4] 7/13 9/2
31/22 31/25
risk’ [1] 31/11
risked [1] 31/8
risks [1] 109/15
road [1] 67/14
Robert [1] 49/23
robust [9] 20/23
51/11 51/17 51/19
54/7
robust’ [1] 10/20
Rodric [1] 164/7
role [23] 33/20 42/8
63/16 65/15 67/23
68/5 69/25 70/3 75/14
75/19 76/19 77/10
77/19 77/19 77/25
78/9 105/16 144/23
155/15
roles [21] 27/14
27/21 27/23 28/2
28/14 29/17 29/25
30/25 31/15 31/18
31/19 35/15 36/10
37/10 39/5 39/8 39/25
41/10 41/16 43/10
117/5
Ron [1] 48/21
room [3] 147/17
153/12 165/17
rosy [1] 68/7
round [2] 104/7
118/24
rounds [1] 104/14
Royal [1] 98/1
RU [2] 31/4 33/1
rudderless [1]
116/19
rug [1] 66/12
Rule [1] 56/15
Rules [1] 23/2
run [6] 88/10 88/11
97/8 99/11 114/23
159/14
running [6] 33/7
38/23 63/5 63/7 92/15)
95/9
rural [2] 95/24 99/14
rush [1] 125/22
So
sad [2] 152/12
134/21 156/13 156/15)
ring-fenced [1] 83/18)
35/18 36/1 36/13 37/8
61/11 63/8 63/9 63/12,
152/15
sadly [1] 157/12
Saf [4] 68/24 68/25
69/5 114/17
said [41] 1/10 1/25
2/6 2/16 2/17 15/4
17/8 21/17 22/24
27/14 30/1 35/8 38/20
46/2 52/20 53/4 54/21
55/14 61/15 62/20
63/17 76/18 79/5
90/15 93/10 103/22
106/12 118/21 121/23)
130/24 137/11 144/22)
145/1 145/14 145/24
145/25 150/9 153/16
158/12 159/1 163/21
Sales [1] 53/17
same [28] 10/4 13/20
23/25 29/11 40/18
41/1 55/25 62/6 62/10
63/20 68/21 69/7
87/20 89/21 94/14
100/15 107/10 112/19)
123/9 128/3 131/11
131/15 147/25 162/2
162/15 162/15 162/21
165/5
sanction [1] 16/12
sanctioned [1] 16/6
Santayana's [1]
138/19
Sarah [1] 5/15
sat [2] 1/20 77/9
satisfaction [1]
46/19
satisfied [1] 15/8
satisfy [1] 20/25
saw [1] 12/15
say [62] 2/20 3/3 4/6
17/22 21/25 24/11
25/7 26/12 27/5 27/21
30/11 30/23 37/25
38/20 46/8 47/13
47/15 64/20 65/23
66/2 66/11 66/15 67/2
68/11 69/3 74/20
77/18 77/22 89/14
90/22 92/2 94/1 99/21
100/14 101/18 106/9
107/14 111/20 113/24I
114/15 114/22 118/2
124/9 130/19 132/17
136/12 142/20 143/1
145/13 146/4 146/10
148/3 148/10 151/14
152/7 154/1 154/4
157/16 159/3 159/22
161/19 163/24
saying [18] 2/8 4/10
47/23 48/19 48/24
49/22 50/18 50/22
66/14 66/23 67/9
67/21 76/15 137/24
(65) remove - saying
s
saying... [4] 138/7
144/16 161/21 162/15)
says [19] 23/7 34/21
39/14 42/18 46/6
48/17 49/16 49/19
51/1 51/7 53/18 53/22
56/10 56/15 76/23
84/12 148/24 160/17
162/3
scale [9] 8/12 13/16
14/2 14/7 15/5 19/14
28/8 48/15 136/8
scan [1] 56/17
scandal [15] 9/9 25/1
28/4 42/4 42/9 43/6
50/8 110/7 113/21
116/25 117/9 117/9
417/17 139/7 145/12
Scarrabelotti [2]
75/5 100/22
scenarios [1] 74/25
scheme [20] 49/18
117/14 1341/1 131/2
132/2 133/21 134/1
134/5 134/8 149/6
156/10 156/19 159/7
159/18 160/20 161/10}
162/7 162/12 162/20
162/24
schemes [18] 1/14
2/3 2/9 2/12 2/14 3/2
3/13 4/2 5/2 28/22
133/13 139/12 142/23
144/10 144/24 147/8
147/16 165/15
scope [4] 108/17
109/3 109/7 111/12
screen [1] 120/4
scroll [33] 10/10
12/22 23/1 40/12
41/19 41/20 41/24
42/10 45/11 54/19
56/10 56/14 56/16
56/22 57/7 57/10
57/13 57/13 57/18
57/19 58/10 58/14
58/21 59/1 59/8 76/14
76/21 79/11 95/10
101/6 160/5 160/7
161/17
scrolling [4] 42/15
42/17 57/23 90/5
scrutiny [2] 111/16
147/23
seat [1] 62/24
second [10] 32/16
42/18 44/10 48/22
53/15 53/20 66/9 84/2
108/14 132/8
secondly [2] 12/12
95/19
secrecy [1] 26/25
secretary [3] 44/13
65/25 148/16
section [14] 10/5
22/16 22/21 25/18
79/12 101/10
section 12 [1] 79/8
section 12.12 [1]
79/12
section 19 [3] 22/16
22/21 78/23
section 2 [1] 57/6
sections [1] 29/20
sector [1] 105/8
secured [1] 54/14
Security [2] 8/9
18/16
see [48] 5/24 21/20
22/20 22/23 33/5
34/21 34/22 38/25
39/11 41/19 41/21
44/10 44/21 45/1
45/11 45/18 45/19
53/10 53/15 54/13
54/16 54/19 56/19
56/23 61/6 63/2 65/25
67/10 89/24 91/3
91/15 94/24 101/4
109/7 110/10 110/16
114/15 120/18 131/6
138/8 138/10 142/11
149/20 154/8 154/15
160/5 160/7 164/2
seek [4] 59/10 80/11
139/2 161/22
seeking [3] 6/11
23/16 81/20
seem [8] 45/10 68/7
130/11 130/20 130/20;
133/8 162/9 162/13
seemed [2] 48/11
75/12
seems [5] 10/15
35/12 55/13 125/15
132/18
seen [12] 11/10 19/2
21/16 44/16 44/19
55/14 102/24 116/10
116/13 122/8 129/22
160/14
sees [1] 105/25
SEG [22] 5/11 5/16
5/22 5/24 6/5 6/11
11/5 11/22 12/19 13/3
13/8 13/24 14/21 15/3
17/16 17/25 20/5 20/5)
20/14 20/15 41/6 41/8
SEG's [1] 19/5
seized [1] 163/8
Select [7] 45/25 66/4
66/6 66/17 142/23
159/13 165/21
self [3] 44/11 68/5
27/2 57/6 57/14 57/19
59/4 60/18 78/23 79/8)
76/19
self-interest [2] 68/5
76/19
sell [3] 94/16 113/18
156/6
semi [1] 39/18
semi-informally [1]
39/18
sender [1] 34/2
sending [1] 44/19
senior [18] 19/22
45/14 78/8 115/2
115/17 116/2 116/15
116/17 116/18 117/10
117/19 117/22 118/15}
119/7 119/16 136/21
137/7 140/19
sense [15] 15/24
71/12 71/12 74/1
105/6 107/14 113/6
122/25 134/23 143/18}
146/7 146/25 148/15
149/15 156/9
sensible [2] 64/6
140/16
sensitive [4] 28/23
37/4 70/6 70/7
sent [2] 44/11 54/20
sentence [3] 10/22
42/18 95/11
sentiment [4] 67/13
89/15 90/16 116/8
separate [5] 39/4
39/7 52/5 65/5 121/6
separation [2] 98/1
99/21
September [3] 21/12
108/7 148/16
series [1] 121/19
serious [2] 129/3
138/4
servant [1] 45/14
serve [2] 110/11
110/17
service [15] 8/13
17/11 17/20 49/15
96/16 96/19 96/22
97/7 97/12 99/7 100/4
105/2 105/8 105/13
111/5
services [10] 81/10
92/21 95/7 96/10 98/7
99/10 110/25 111/4
113/18 136/8
servicing [1] 8/5
serving [4] 28/4
75/13 78/7 91/9
session [3] 66/3 66/4
66/11
set [17] 1/9 1/16 9/4
55/16 56/21 90/10
94/23 97/17 108/4
112/13 134/4 143/2
153/5 160/23 160/24
162/4 162/18
setting [1] 125/22
settled [2] 88/23
157/14
settlement [3] 50/11
157/14 160/11
settlements [1]
150/18
settling [1] 156/2
severe [1] 163/22
sexism [1] 117/21
SGEls [2] 95/14
97/15
shall [4] 80/11 81/2
81/4 124/9
shameful [1] 126/4
shape [3] 99/23
99/24 113/9
shaping [1] 77/10
share [10] 13/9 29/3
29/23 73/2 73/3 73/6
73/7 73/8 73/22
121/17
shared [6] 7/15 8/21
12/13 16/21 72/10
92/12
shareholder [26]
2/19 45/15 72/5 72/6
89/12 89/23 93/23
97/22 98/22 101/13
102/10 102/16 102/17,
103/1 103/3 124/2
145/16 146/1 146/3
146/3 146/7 146/9
146/12 146/24 165/22,
166/4
shareholder's [2]
72/18 94/1
shares [1] 41/21
sharing [5] 7/15 9/16
12/10 12/10 92/6
she [37] 45/14 45/17
47/8 53/4 53/18 53/18
53/21 55/12 55/14
56/4 56/10 56/11
56/14 56/15 56/20
61/4 61/13 61/13
61/14 61/15 61/15
61/19 61/23 61/24
61/25 62/8 62/15 63/4,
63/8 63/10 64/3 75/9
75/12 132/1 132/22
132/24 133/1
she's [6] 61/1 61/5
61/24 61/25 62/10
63/15
Sheratt [4] 46/23
47/13 65/21 67/15
Sherratt [1] 45/5
shield [1] 147/13
shift [1] 112/17
shining [1] 165/24
ship [1] 116/19
shocked [1] 133/23
shocking [1] 93/22
shone [1] 142/22
short [3] 52/9 89/7
124/24
shortfall [12] 31/7
31/21 46/19 80/16
80/20 81/22 88/22
88/23 131/24 132/2
132/9 156/19
shortfalls [17] 11/2
58/22 58/25 60/2
81/18 81/21 81/25
82/2 82/8 82/17 82/23}
86/25 87/8 87/11
88/15 125/23 156/24
shot [1] 146/15
shots [1] 147/6
should [38] 2/2 2/6
2/9 3/1 3/5 4/17 6/3
21/13 28/18 30/11
37/24 38/12 51/11
65/23 69/23 100/24
101/1 105/8 106/15
114/24 119/6 119/11
120/11 124/4 127/6
127/6 128/7 134/21
135/1 135/2 139/1
144/3 147/7 149/9
151/6 151/11 157/2
1657/2
shouldn't [4] 78/12
134/22 140/10 155/17)
show [1] 129/6
showed [1] 89/15
showing [2] 58/5
58/6
shown [6] 5/13 11/3
55/15 98/13 135/25
160/4
shuddering [1]
126/12
shunned [1] 157/5
shut [1] 131/11
sic [2] 66/20 94/6
SID [4] 73/24
side [6] 44/21 49/10
65/22 77/1 109/12
110/5
sight [4] 13/15 48/22
107/4 108/16
sighted [1] 72/22
sign [1] 151/4
signalling [1] 51/10
signed [3] 53/15
122/24 151/7
significance [2]
54/15 61/12
significant [8] 11/6
11/12 11/15 19/9
19/11 28/17 92/7
148/11
signpost [1] 50/24
silent [1] 139/17
similar [5] 41/3 97/9
(66) saying... - similar
Ss
similar... [3] 104/6
104/6 121/8
Similarly [1] 41/15
Simon [9] 3/14 27/23
32/17 32/20 39/15
40/24 44/2 45/19
149/16
simple [2] 143/4
144/1
simplify [2] 94/20
94/21
simply [4] 16/23 30/4
30/16 46/4
since [19] 5/1 59/13
88/6 95/1 97/18 97/19
97/25 98/6 99/19
105/7 111/12 111/14
115/4 115/5 118/19
128/17 165/19 165/20}
165/20
single [6] 6/25 94/14
102/19 103/7 111/8
146/17
sir [18] 1/6 43/20
52/5 52/11 75/7 75/19}
89/2 89/9 122/16
124/14 125/3 141/6
141/18 149/25 151/12)
151/23 166/14 167/1
Sir Wyn [1] 75/19
sit [3] 50/25 62/24
110/23
sitting [3] 1/24 61/10
62/24
situation [4] 71/25
75/20 129/1 133/9
Sivasubramaniam [1]
131/7
six [5] 76/21 99/22
113/15 119/22 121/9
six paragraphs [1]
76/21
size [2] 14/8 48/15
skills [1] 18/20
skin [2] 15/21 48/11
skip [1] 101/7
skipping [1] 9/18
slide [1] 111/8
slight [1] 68/1
slightly [3] 20/18
65/4 129/11
slogan [1] 136/20
slow [3] 28/12
129/19 165/10
slower [1] 6/21
slowing [1] 49/10
slowly [2] 22/23 63/1
small [3] 113/1 125/6
161/23
smaller [2] 96/24
157/19
Smith [1] 49/18
so [154] 1/25 3/19
4/8 5/3 6/11 7/18
10/15 11/25 12/20
13/7 15/1 15/19 15/23
19/8 19/16 20/1 20/8
21/4 22/9 22/23 24/12
24/23 25/9 25/11
25/18 26/8 26/15 27/9
32/1 33/5 33/12 33/16
33/20 33/25 34/4 35/1
35/25 38/23 39/20
40/10 41/9 41/13
43/17 43/23 44/20
45/7 45/10 45/14
48/13 50/14 54/10
55/7 56/19 57/19
61/20 63/5 64/18
65/21 66/19 66/23
68/18 69/9 71/25
72/13 72/21 74/2
74/18 76/3 77/11
77/14 78/2 78/12
79/11 82/24 83/14
84/9 85/6 85/24 86/14
86/22 87/10 88/3
88/20 91/24 94/13
94/15 98/16 99/9
100/1 110/23 112/4
114/20 115/12 116/25)
119/18 119/24 121/22)
121/24 122/12 123/2
127/6 127/24 128/6
129/7 129/19 130/18
131/6 132/7 133/3
133/14 134/2 134/3
134/20 134/25 136/9
136/20 137/3 138/17
140/12 141/13 141/16)
141/18 143/4 143/12
143/13 144/22 146/15)
147/3 148/12 148/22
149/7 149/8 149/14
150/3 150/24 151/2
151/9 151/16 151/24
152/10 152/10 152/15)
152/23 155/13 156/6
158/1 158/18 159/6
159/12 160/2 160/7
161/21 163/24 165/11
social [5] 105/13
105/21 106/5 107/6
111/2
societal [1] 110/13
software [1] 54/3
sole [1] 93/23
solely [1] 11/18
solution [4] 55/4
85/10 164/24 165/1
solutions [2] 43/16
54/24
some [83] 2/17 2/25
3/23 4/7 4/20 4/22
10/15 10/21 12/2
13/25 14/2 21/17
22/12 25/18 26/19
26/20 27/16 27/19
28/4 33/12 35/5 41/2
41/6 42/10 42/15
44/22 45/11 45/21
45/24 46/25 48/6
48/14 48/22 48/23
49/2 50/1 50/6 50/11
53/19 54/14 71/4
73/22 75/9 77/4 80/10)
80/14 81/11 82/9 86/3
86/5 86/22 89/17
91/19 94/15 99/12
103/6 106/10 110/14
111/4 112/1 112/3
124/18 125/9 125/24
126/18 126/18 127/24
129/19 131/20 139/22
143/23 144/13 145/23
148/22 149/17 149/19}
151/4 157/9 161/12
163/18 164/20 165/25}
166/7
somebody [1] 44/19
somehow [1] 51/4
something [29] 1/10
22/5 27/14 30/23
32/11 32/20 33/2
33/18 34/18 47/11
61/22 65/4 69/19
85/18 85/19 97/20
97/21 103/24 109/1
109/1 112/8 117/1
117/7 129/11 140/19
140/21 145/18 155/9
159/24
sometime [2] 122/2
122/3
somewhat [1] 146/1
soon [2] 24/5 138/3
sorry [13] 6/3 16/1
66/18 73/8 76/9
133/20 140/6 141/6
151/22 160/9 161/4
161/6 161/18
sort [20] 13/16 14/6
15/18 26/2 36/19 48/6
50/13 64/15 72/24
86/5 86/14 86/22
100/23 103/24 108/12
111/10 113/20 119/22
119/23 141/11
sought [5] 6/4 6/5
58/11 155/5 155/6
sound [4] 16/2 17/21
51/15 132/14
sounds [1] 136/14
source [3] 102/19
146/17 155/2
sources [3] 60/7 93/3}
93/4
spat [1] 157/5
speak [10] 3/15
19/25 63/11 63/12
64/6 121/15 141/17
147/1 147/2 149/15
speaking [4] 48/23
61/2 87/15 143/3
speaks [1] 35/1
specific [18] 15/15
15/21 17/16 17/23
37/6 37/16 37/22 38/6
51/22 53/24 72/7
85/24 100/8 123/22
123/23 129/12 139/13}
152/14
specifically [16] 4/5
5/20 18/13 18/22
18/23 32/11 33/18
38/8 43/3 63/4 84/6
85/22 86/9 132/16
138/22 139/18
specifics [6] 2/4 20/8
27/5 85/6 140/15
149/17
speculating [1] 20/18)
speed [2] 98/5 130/1
speeding [1] 128/8
speedy [1] 145/9
spend [3] 90/5 94/3
129/24
spending [2] 104/2
104/3
spent [5] 52/13 63/8
64/3 85/23 107/18
SPMs [1] 163/16
spoken [2] 40/24
159/18
sponsor [3] 6/1
33/16 34/12
sponsor's [1] 34/17
sponsored [3] 20/13
33/8 33/18
sponsorship [3]
33/11 33/13 34/15
spotted [1] 54/11
spread [1] 105/3
spreads [1] 126/23
SPSO [1] 99/12
SR [1] 45/18
stabilisation [1]
119/23
stability [5] 71/4
71/13 74/1 117/3
117/4
staff [3] 30/17 33/1
83/1
stage [7] 27/7 38/9
62/3 69/16 84/22 85/4,
138/15
stakeholder [3]
108/5 109/22 109/24
stakeholders [4]
50/24 110/10 110/16
123/20
stand [1] 68/1
standpoint [1]
102/17
stark [1] 114/21
Starsky [1] 16/2
start [10] 3/13 5/2
15/23 69/21 83/20
85/8 85/9 98/24
165/20 166/9
started [1] 111/19
starter [1] 111/11
starting [1] 149/13
starts [2] 77/25 83/10)
state [7] 91/1 103/19
124/8 144/15 148/16
150/12 159/16
state-owned [1] 91/1
stated [4] 88/16
132/4 152/7 159/1
statement [31] 7/16
7/21 10/7 12/10 12/13}
13/11 27/18 27/20
36/3 37/7 55/18 55/19
56/8 56/9 56/23 57/14I
62/1 62/9 64/16 89/14
89/21 92/3 93/10
103/6 106/24 107/24
115/6 120/3 120/22
138/13 146/10
statements [4] 8/8
24/16 115/16 137/7
static [3] 99/19 99/21
100/1
stating [1] 27/24
statistic [2] 128/20
128/22
Staunton [7] 1/23
66/21 66/24 73/14
89/22 89/25 117/23
stealing [1] 128/18
steer [1] 43/25
stem [1] 117/12
step [11] 19/9 19/9
19/11 61/11 61/19
61/24 61/25 62/20
64/2 64/8 147/25
stepping [1] 11/25
steps [1] 42/3
stewardship [1]
128/7
stick [1] 122/19
stigma [1] 158/22
still [18] 15/17 26/17
27/11 27/25 28/9
29/15 34/13 36/20
44/6 45/17 49/3 51/5
51/24 62/14 104/12
114/23 128/14 166/20)
stock [5] 53/24 79/10
83/16 88/1 112/23
stolen [1] 127/4
stone [1] 160/24
stood [1] 13/8
stop [1] 76/14
Stopping [1] 60/22
straight [2] 4/23 79/5
straightforward [1]
(67) similar... - straightforward
Ss
straightforward... [1]
46/13
strange [1] 130/20
Strangely [1] 114/15
Strangers [1] 23/3
strategic [27] 5/11
77/10 90/1 97/8 98/13
98/14 98/15 98/17
98/20 98/20 102/23
108/1 108/11 108/24
109/5 109/10 112/9
112/20 114/2 119/12
119/14 119/15 120/9
122/21 122/23 123/10}
124/1
strategically [1]
98/24
strategy [11] 93/2
101/23 102/1 104/18
106/14 109/17 109/25)
111/22 112/4 112/24
114/11
streamlining [1] 7/3
street [2] 98/5 99/24
stress [1] 156/25
stretched [3] 19/19
19/19 20/1
strict [2] 141/8
162/16
strike [1] 157/15
stringent [2] 91/16
91/21
strings [3] 152/24
153/1 153/14
strong [2] 153/18
161/22
stronger [1] 120/2
strongly [1] 30/22
strove [1] 135/7
structure [1] 110/3
struggle [3] 103/23
128/24 162/1
struggled [2] 52/3
102/3
studies [2] 29/10
86/14
study [2] 129/18
129/21
stupidity [1] 125/24
sub [2] 52/19 64/11
subject [2] 80/5
104/2
subjected [1] 164/11
submission [4] 13/3
13/25 19/6 20/6
submissions [2]
141/15 160/2
submit [2] 143/15
143/20
subpoints [1] 91/19
subpostmaster [31]
4/10 22/8 22/17 24/14
41/2 43/1 56/20 59/9
60/12 68/8 71/20 73/4
73/16 74/4 79/13 80/6
80/12 80/21 81/8
81/19 82/2 82/13
82/18 83/1 84/12
85/12 86/17 88/24
125/25 131/9 163/22
subpostmasters [48]
3/6 22/7 22/18 23/7
25/14 25/23 26/2 40/9)
46/17 57/5 57/8 57/17
58/15 59/5 60/8 60/24!
64/13 71/19 82/15
86/6 86/23 87/8 87/11
90/24 91/24 92/13
113/1 118/18 121/5
125/12 125/20 127/9
127/16 128/16 131/18)
134/17 137/10 144/12)
153/21 155/24 156/2
156/6 156/20 157/5
162/19 163/3 164/9
164/17
subpostmasters' [2]
110/1 129/15
subpostmistresses
[1] 128/17
subsequent [4] 6/8
80/24 94/8 116/5
subsequently [6]
18/25 32/17 80/9
119/15 134/6 138/2
subsidy [5] 99/9
99/18 99/25 100/3
104/9
substance [5] 40/10
70/23 70/24 73/1
101/8
substantial [1]
141/15
substantive [2] 50/12!
61/22
subtle [1] 163/2
subtopic [1] 52/6
subverting [1]
142/13
success [2] 116/22
117/16
successful [1] 94/9
such [21] 1/17 21/24
23/17 24/18 31/18
35/15 50/17 57/24
59/2 68/7 72/22 79/17)
93/24 97/3 98/23
107/8 113/3 139/8
164/2 164/12 166/8
suffered [3] 132/25
143/6 144/14
suffering [4] 134/16
134/25 135/3 157/1
sufficient [5] 2/13
17/9 17/20 92/21
92/21
suggest [9] 134/4
139/15 142/19 142/25)
148/21 154/7 162/14
162/24 165/5
suggested [4] 61/18
68/25 159/1 162/20
suggesting [7] 6/14
37/17 75/12 114/22
118/18 157/22 161/9
suggestion [3] 42/1
148/20 152/23
suggests [1] 100/24
suitable [1] 43/16
sum [1] 150/13
summarise [2] 2/10
12/7
summarised [1] 17/4
summary [5] 6/15
21/6 21/7 79/2 101/10
summer [4] 41/7
61/8 100/9 155/3
sums [2] 134/11
151/10
supplementary [1]
158/11
supplied [1] 9/6
supply [2] 14/24
15/19
supplying [1] 15/22
support [28] 12/23
13/1 13/4 26/7 47/3
50/6 57/15 59/7 66/19
67/3 81/6 83/15 83/17,
83/18 83/25 84/3 84/4
87/25 88/1 91/5 100/7
104/19 106/17 107/11
109/24 118/25 119/16
155/6
supporting [5] 11/10
40/14 68/6 76/20
101/25
supposed [3] 66/23
124/7 156/20
supposedly [1] 144/1
suppress [1] 147/22
suppressed [1]
135/17
sure [39] 3/14 4/5
17/12 20/3 26/21 27/7I
41/13 47/20 62/19
63/17 66/20 68/1 70/9
71/25 74/22 85/21
86/2 100/13 104/21
114/10 117/18 122/18}
123/24 125/9 126/3
126/12 128/24 134/6
135/6 141/1 141/21
143/14 143/24 153/13
158/1 160/5 160/18
160/23 161/6
surely [1] 154/2
Surpluses [1] 80/23
surprise [5] 14/1
14/2 14/4 32/25
115/20
surprised [1] 19/13
surrounding [1] 75/1
survey [25] 25/24
89/15 90/16 93/18
93/19 115/3 115/4
115/5 115/8 115/9
115/10 115/10 115/12}
115/13 115/20 120/17,
121/1 121/2 121/6
121/9 121/11 121/13
121/17 122/5 122/6
surveys [3] 91/7
121/24 122/12
suspect [5] 1/19
24/19 52/12 90/3
157/21
suspected [5] 23/12
23/24 24/4 24/11
24/15
suspecting [1] 24/7
suspects [1] 8/4
suspended [3]
131/10 131/18 163/16}
suspension [6] 22/19}
22/25 31/6 31/20 35/5
60/18
suspicion [1] 23/22
sustainability [1]
137/12
sustainably [1] 108/5
sustained [1] 126/4
swiftly [2] 40/21
135/10
switch [1] 124/15
system [14] 9/12
9/12 25/19 47/6 53/13
54/2 54/25 55/4 81/3
135/25 136/2 136/6
143/19 166/1
systems [4] 53/21
53/23 53/25 81/9
T
table [1] 148/14
tabled [3] 5/17 5/21
12/25
tactical [4] 68/12
75/24 98/17 114/11
tactically [1] 98/25
tailored [1] 60/17
tainting [1] 51/6
take [28] 4/4 4/10
28/11 30/1 39/1 42/3
42/7 46/7 51/11 61/19
62/20 66/16 72/8
90/13 94/18 97/22
103/18 112/23 114/24}
121/7 121/20 122/16
129/7 131/7 133/4
133/21 150/1 160/8
takeaway [1] 156/10
taken [16] 9/13 33/6
43/13 43/16 51/10
51/16 61/24 63/1
88/13 110/8 111/14
118/3 118/9 131/12
149/17 160/25
takes [1] 102/17
taking [6] 30/18
41/15 61/24 93/20
158/10 160/9
tale [1] 157/17
talk [1] 163/5
talked [1] 153/16
talking [7] 7/18 38/3
43/23 115/12 132/21
138/3 150/5
tape [1] 156/7
task [1] 28/13
tax [2] 158/7 159/16
team [24] 8/9 18/8
19/18 20/1 26/5 31/4
44/3 78/8 83/10 83/15)
83/16 83/17 84/2 84/3}
84/5 88/12 116/2
116/17 119/7 119/16
121/23 123/14 137/7
140/20
teams [8] 18/16
31/16 43/14 56/14
83/9 87/25 88/1 88/2
technical [3] 129/16
130/14 133/4
technicality [4] 130/9I
130/10 130/18 141/9
Technically [1] 54/4
technology [2] 9/7
41/10
teetering [1] 147/9
tell [11] 36/15 55/18
92/3 95/3 106/24
107/24 115/3 120/5
120/16 123/17 132/4
telling [1] 131/25
ten [7] 69/1 77/23
98/16 98/23 111/11
114/8 114/11
ten years [1] 98/23
ten-year [1] 114/11
tend [3] 96/23 97/7
99/13
tended [1] 94/10
tends [2] 100/6
121/14
Teneo [13] 98/20
104/21 104/22 104/24I
108/2 108/24 109/9
109/13 122/21 122/24)
123/14 123/19 123/21
Teneo's [1] 111/9
tenets [1] 26/22
term [27] 69/15 80/8
91/14 98/10 98/11
98/22 101/16 102/5
103/7 103/13 103/16
103/21 103/25 104/16
104/18 106/4 106/14
(68) straightforward... - term
T
term... [10] 108/13
110/19 112/24 113/12)
113/22 114/4 117/6
126/22 145/10 146/18
terminal [1] 85/14
terminated [1]
163/23
termination [3] 31/6
31/20 60/19
terms [47] 3/6 14/2
14/6 15/18 19/20
22/18 24/10 25/7 27/5
29/2 30/25 32/25 33/3,
34/10 37/18 37/22
39/2 50/7 51/21 57/9
57/10 64/1 70/9 78/10)
80/21 83/15 84/11
86/3 88/8 95/8 98/16
99/19 100/1 100/7
102/3 105/23 110/23
111/4 111/12 112/16
113/18 115/23 141/8
141/8 151/2 154/18
162/5
terrible [4] 128/20
128/22 129/1 130/4
territory [1] 15/17
tested [1] 10/23
testing [5] 11/18
18/24 19/2 19/3 20/20}
than [29] 6/21 18/13
27/10 27/16 34/2
38/23 45/9 47/18 50/2
50/12 53/9 62/16
75/22 80/1 84/24
93/20 97/3 104/12
104/17 105/15 105/16
4112/7 114/11 116/11
129/12 134/2 137/12
153/10 153/10
thank [29] 1/6 22/7
39/11 39/23 52/5
52/11 55/24 60/21
60/22 64/11 64/19
75/2 76/8 78/16 89/1
89/5 89/9 101/4
122/15 125/3 150/20
151/21 151/23 160/7
161/20 166/13 166/14}
166/23 167/2
that [1039]
that's [110] 2/16 4/7
6/14 7/18 7/24 9/22
9/23 16/25 17/2 17/2
17/22 18/19 22/5
22/20 32/3 34/3 34/4
34/18 43/24 44/23
45/17 45/20 45/22
46/18 46/20 48/21
49/9 54/18 56/6 57/11
60/21 61/2 66/22
66/25 67/7 67/8 71/25
74/8 78/15 79/25
84/17 86/15 86/18
87/1 88/11 88/25
90/19 92/2 92/14
92/17 93/9 95/14 97/1
97/5 97/10 97/16
102/1 102/7 102/7
103/8 104/20 106/8
107/9 107/14 111/18
112/8 115/5 115/13
115/14 116/25 117/6
117/24 123/7 123/18
124/20 125/19 126/1
126/6 126/10 126/20
127/20 128/5 128/13
128/20 129/10 130/17)
131/1 134/11 135/4
138/18 139/3 142/17
143/24 144/21 145/24)
146/18 147/20 150/25)
152/12 152/17 153/25)
156/22 157/3 160/11
161/13 162/8 162/23
164/13 164/19 165/4
theft [3] 23/3 156/21
156/21
their [62] 9/24 17/25
22/18 35/16 35/23
36/11 36/16 37/3 37/5)
37/5 45/7 45/9 57/10
58/12 58/16 60/13
60/25 68/4 68/5 69/6
69/15 69/20 70/23
76/18 76/19 83/1
90/25 92/8 93/17
93/23 94/20 95/18
95/20 95/23 95/25
96/7 105/19 111/10
113/1 115/2 118/13
120/21 120/23 123/5
123/9 126/15 127/4
127/16 131/19 136/25)
146/12 148/19 148/20)
156/4 156/13 156/15
156/23 157/1 157/6
157/11 163/17 163/23)
theirs [1] 67/19
them [50] 2/3 2/14
6/7 8/13 16/4 16/5
21/20 22/8 22/15
28/23 30/7 35/17
35/24 43/11 48/23
49/12 49/19 69/3 69/3
70/7 74/4 74/6 74/7
74/12 74/18 77/4
80/14 80/15 83/23
87/22 88/20 96/23
106/25 109/22 115/1
119/5 127/2 127/4
134/7 138/21 144/13
149/6 152/20 154/25
155/1 156/13 157/10
163/8 163/9 164/1
theme [5] 34/19 35/2
35/8 35/19 67/19
themes [4] 34/21
34/24 34/25 36/19
themselves [9] 28/2
28/19 30/20 44/19
86/24 121/22 121/24
147/18 156/7
then [97] 1/18 1/23
5/3 5/5 7/9 8/10 9/4
9/18 10/10 11/5 11/21
15/21 18/25 23/2 23/4
23/18 24/13 27/9
28/11 29/1 29/21
31/12 32/17 33/5 35/7
40/12 41/20 41/24
42/10 42/15 42/16
47/8 48/24 49/21 51/7
53/19 56/17 56/18
56/22 57/4 57/7 57/23}
58/1 58/10 58/21 59/4
59/8 59/18 59/23 60/3
60/6 60/19 64/5 65/4
67/21 68/2 72/10 73/1
76/21 77/25 78/19
80/4 80/10 81/1 81/11
91/18 92/12 92/17
93/25 95/1 96/2 96/8
100/5 101/7 109/12
109/18 109/18 111/12
113/19 121/8 121/19
121/24 122/1 124/14
125/21 127/18 131/3
136/21 139/5 144/18
148/23 151/1 151/7
152/15 160/24 163/21
166/24
theory [2] 151/13
151/15
there [141] 2/24 3/15
4/9 8/14 10/21 11/6
12/1 12/7 12/9 13/18
13/25 14/1 14/20 15/1
16/9 16/13 16/17 18/8
23/20 25/10 26/8
27/25 28/5 28/20
28/24 29/6 29/13 30/6
32/8 32/21 33/12
34/11 36/18 37/1 37/1
37/10 37/15 38/6
39/11 39/20 43/5
45/19 45/21 46/6 46/8
48/6 49/9 50/5 60/22
61/17 61/22 62/3
62/15 62/16 66/6
69/10 72/7 72/25
76/14 77/3 77/18
77/19 78/4 79/20
81/22 83/12 84/3
84/22 85/24 87/10
87/12 87/16 87/20
88/19 89/13 93/7
94/17 94/18 98/4 98/6
100/2 101/23 102/16
102/25 104/4 106/12
107/23 111/2 112/5
112/11 112/15 112/17]
114/19 114/19 114/22)
115/19 122/12 122/13}
123/12 123/14 124/13}
125/21 130/13 130/13}
131/6 133/16 133/16
133/22 137/11 138/3
139/18 139/21 139/23}
140/14 142/13 142/15}
143/21 143/23 145/22)
146/8 147/3 148/3
148/10 149/10 150/8
151/9 152/3 152/14
152/19 153/5 153/11
154/15 155/18 157/13}
157/19 157/20 161/21
165/23 166/2 166/3
166/5
there's [17] 45/24
49/14 50/23 76/25
79/19 101/20 106/25
117/13 124/1 134/10
141/16 148/12 148/24}
148/25 150/12 157/16}
187/17
thereafter [2] 126/15
132/24
thereby [2] 134/24
147/18
therefore [15] 14/9
18/11 29/18 63/7
63/10 85/17 85/19
98/8 102/20 112/17
133/14 134/25 148/7
158/18 160/14
thereof [1] 82/2
these [48] 2/9 5/10
7/12 8/12 8/20 9/15
11/4 13/7 16/20 16/23}
18/11 23/24 29/10
34/24 34/25 40/22
40/24 50/25 56/1 58/6
61/10 72/9 75/11
82/24 84/14 88/17
94/24 96/12 97/7
97/16 106/4 110/14
111/15 112/21 113/4
114/13 116/7 119/5
123/24 124/7 127/8
137/19 137/25 138/7
141/24 144/10 149/17)
164/10
they [126] 8/4 13/13
13/15 13/21 16/12
20/6 23/19 23/25 26/8)
28/18 29/5 29/16
30/17 31/21 31/22
31/24 31/25 35/25
36/16 36/24 37/6
40/25 41/12 53/25
54/10 59/10 64/9
64/23 67/16 67/24
68/2 68/4 68/16 68/20)
68/22 69/8 69/8 69/15
69/17 69/17 69/21
70/20 70/22 71/7 71/9I
73/11 73/19 73/21
74/14 75/19 75/24
76/1 76/6 76/16 76/18)
83/13 85/19 86/24
86/25 87/19 87/23
88/4 88/20 90/13 91/5
94/21 95/1 95/4 96/14)
96/15 96/17 96/18
99/6 106/3 111/13
113/10 113/24 114/18)
115/1 120/18 121/20
121/21 122/25 125/8
127/2 127/3 127/3
127/12 129/8 131/20
132/21 136/13 136/15)
139/1 140/15 141/9
141/10 143/12 143/15}
143/19 144/14 145/21
147/18 147/19 147/21
147/25 148/2 148/5
148/11 148/19 151/3
152/21 154/20 156/3
156/14 156/23 157/10}
157/23 157/23 159/23}
162/11 163/5 163/17
164/2 164/3 164/11
they'd [1] 69/18
they're [10] 19/22
19/25 20/14 98/16
121/3 137/25 141/11
157/25 158/19 163/25]
they've [7] 45/7
68/19 87/22 122/8
123/20 147/24 153/13)
thieves [1] 157/5
thing [8] 46/12 50/17
65/9 101/7 122/18
128/6 130/4 130/11
things [15] 4/9 4/13
21/17 38/3 46/6 49/1
72/25 83/3 111/11
112/5 122/13 122/14
141/20 153/7 166/9
think [300]
thinking [4] 123/8
124/6 130/5 162/8
thinks [2] 24/5 49/17
third [11] 24/16
24/20 27/17 49/22
52/23 55/19 64/16
103/12 106/24 113/20)
138/12
this [242]
Thornton [5] 100/10
100/19 101/2 101/5
108/10
Thornton's [1] 72/17
thorough [1] 38/18
thoroughly [2] 20/3
30/9
those [61] 1/25 3/25
(69) term... - those
T
those... [59] 4/9 4/13
4/25 13/19 16/3 24/23)
27/15 30/18 37/24
42/3 44/5 50/19 50/21
51/5 53/20 57/21 58/3)
59/13 59/16 59/19
63/19 72/9 73/1 74/13
84/8 86/19 86/19 88/9
92/16 93/4 94/9 96/12
97/8 100/2 108/22
411/17 114/14 115/11
117/5 117/25 118/4
118/12 121/18 123/13)
123/21 129/14 130/16}
138/19 140/14 144/25
151/5 151/7 155/9
157/20 159/9 164/15
165/6 165/12 165/21
though [5] 61/24
118/21 132/10 151/9
162/23
thought [4] 19/17
19/18 34/7 140/12
thoughts [1] 37/24
thread [2] 39/4 39/7
threatened [1]
156/23
three [17] 11/4 48/9
69/16 70/21 71/24
76/4 86/23 100/25
101/20 104/3 104/22
132/1 133/8 133/10
144/24 147/8 147/15
three-year [1] 133/10
through [27] 47/1
50/10 50/11 50/11
51/2 59/9 61/18 63/1
67/5 70/12 74/16
79/14 81/6 90/5 90/25)
109/13 114/2 116/12
118/6 118/12 120/1
121/21 131/25 132/10)
142/23 146/24 162/3
throughout [1]
115/16
thrown [1] 87/24
Thursday [1] 1/1
ticking [1] 127/6
Tidswell [1] 67/4
ed [1] 83/24
tight [7] 133/17
152/24 152/25 153/15}
162/4 162/16 162/17
time [68] 3/23 4/7
4/20 4/22 11/7 13/20
15/21 29/6 30/5 32/13}
35/17 36/9 40/18 41/1
41/6 45/14 48/6 48/10
49/2 52/13 52/20 53/4)
53/8 61/9 61/9 61/9
62/10 63/16 66/15
68/9 68/21 69/7 69/10
69/11 70/14 71/18
74/9 85/23 87/20 90/5)
93/21 94/4 99/20
106/10 107/18 112/8
112/12 112/19 112/22)
113/7 115/22 121/8
123/9 129/14 129/25
132/22 136/2 136/2
143/5 147/25 149/18
150/4 150/8 150/21
150/24 153/5 160/16
164/6
times [4] 128/14
128/15 145/1 154/24
timescale [1] 43/18
timing [2] 40/11
40/16
title [2] 45/7 45/8
today [6] 22/11 26/14
49/23 107/19 113/25
166/11
today's [3] 90/7
107/23 138/16
together [4] 88/13
112/21 123/25 125/6
toing [1] 104/11
told [9] 22/7 22/15
23/7 25/14 25/23 26/2
34/6 115/15 148/24
tomorrow [8] 22/11
67/10 67/11 67/13
107/19 124/19 138/17)
166/24
too [10] 6/19 14/19
38/12 43/16 65/23
69/23 74/6 74/7 82/9
165/22
took [2] 8/7 153/5
tools [1] 86/10
tooth [1] 142/15
top [11] 39/10 42/17
44/14 45/24 53/18
66/5 89/16 89/17
90/16 95/11 113/24
topic [8] 5/5 41/5
41/8 75/2 76/10 78/19)
87/16 89/12
tortious [1] 141/12
total [3] 95/19 95/22
95/24
touch [2] 121/12
133/12
touched [2] 13/12
144/8
touchstone [1] 142/7
towards [4] 45/12
92/5 122/1 166/1
Tracy [6] 53/10 53/16
55/13 55/20 55/25
61/11
trade [4] 13/18 35/11
67/23 69/22
trade-off [1] 13/18
traditional [1] 99/13
tragedy [1] 132/22
train [2] 17/22 58/16
trained [1] 84/16
training [15] 18/12
18/20 18/22 56/14
57/16 57/20 57/22
58/4 58/9 58/12 58/20
59/12 81/6 81/7 84/13
trajectory [1] 126/15
transaction [4] 8/18
17/14 17/20 100/7
transactions [4]
81/14 81/17 82/19
87/4
transfer [1] 30/7
Transformation [1]
117/14
transition [1] 18/16
transparency [3]
26/25 65/1 142/6
transparent [2]
118/17 144/16
trauma [2] 143/7
144/13
traumatised [1]
143/12
travel [2] 77/11 93/14
Treasury [11] 2/22
50/2 145/20 146/6
146/13 146/15 146/20
146/22 146/24 147/2
148/6
treat [2] 62/5 165/6
treated [2] 119/4
127/17
Tribunal [2] 51/9
51/13
tricky [1] 69/9
tried [5] 61/12 86/1
93/9 154/14 154/24
trigger [3] 32/9 32/13
39/1
triggered [2] 39/23
112/10
triggers [1] 32/8
troubled [1] 143/18
true [4] 147/20
truncating [1] 150/3
trust [6] 3/17 40/14
105/18 110/5 126/5
145/3
truth [2] 103/19
136/16
truthfulness [1]
55/11
try [12] 28/8 44/5
48/11 66/16 67/4 67/5
71/11 73/22 73/25
130/15 141/23 155/8
trying [19] 50/15 63/2
63/3 64/22 65/12 70/1
70/11 77/23 78/9 83/5)
85/7 92/23 119/17
129/25 134/2 154/12
154/12 154/25 155/21
tune [1] 99/18
turn [12] 22/7 27/13
39/4 64/11 64/18
78/24 89/12 89/13
92/4 106/25 107/25
147/2
turnover [2] 116/18
116/20
tweaks [2] 42/10
42/11
two [35] 12/8 13/7
21/3 27/15 38/23
40/14 43/23 48/9
56/15 66/6 70/6 70/18
71/6 73/16 74/4 75/22
86/19 94/8 94/10
100/2 104/3 104/22
108/9 114/11 114/17
122/12 123/13 124/3
126/2 129/22 132/4
132/23 144/23 147/8
147/15
two years [1] 94/10
two-year [1] 114/11
twos [1] 14/5
type [4] 13/22 42/12
47/6 86/16
typically [1] 97/3
typified [1] 154/4
U
UK [4] 95/16 95/20
95/22 95/25
UKGI [7] 17/6 45/15
90/22 146/5 146/13
146/25 148/9
UKGI00044317 [1]
89/24
ultimately [3] 92/25
93/17 146/17
unable [3] 21/25
48/12 152/16
unaware [3] 21/11
29/5 61/14
uncharted [1] 15/17
uncodified [1]
105/12
uncomfortable [1]
68/15
unconscionable [1]
130/19
uncovering [1] 112/4
under [18] 12/22
15/21 25/16 48/11
48/25 49/10 58/24
74/9 80/13 80/21
101/10 114/13 127/13}
128/7 128/15 132/23
162/1 164/21
underlying [3] 11/10
94/19 104/18
undermining [1] 31/8
underneath [1] 22/21
understand [27] 11/2)
13/21 14/22 15/4 15/5)
16/8 29/22 44/6 48/17)
61/12 62/19 70/11
77/2 83/21 95/5 100/6
108/15 109/14 110/20)
123/15 123/18 124/17)
125/9 138/22 146/20
154/1 154/13
understanding [18]
14/9 14/10 14/20
14/21 37/9 64/24 65/2)
70/13 75/24 86/18
122/19 123/21 130/11
130/17 131/5 133/25
152/12 165/23
understands [1]
30/15
understatement [1]
136/11
understood [3] 36/24I
48/15 84/8
undertake [4] 21/13
82/4 100/20 109/13
undertaken [5] 21/9
54/8 58/12 106/21
108/3
undertaking [5]
27/15 36/9 84/13
84/16 108/2
Underwood [3]
160/17 161/21 162/14)
Undoubtedly [1]
96/21
unedifying [1] 71/16
unfair [2] 153/23
154/1
unfairly [1] 127/17
unfairness [1]
164/12
unfit [1] 136/23
unfortunate [1] 124/4
unfortunately [1]
129/8
unhelpful [1] 71/17
unified [2] 106/13
106/13
union [2] 67/23 69/22
unions [2] 35/11
50/14
uniquely [2] 7/15
64/25
unit [7] 29/4 29/14
31/4 31/10 31/16
32/22 44/5
units [1] 53/24
unless [3] 24/11
30/15 80/12
unlike [1] 68/17
unnecessarily [3]
6/19 135/3 137/5
unnecessary [1] 6/22
Unquestionably [1]
125/14
(70)
those... - Unquestionably
U
unreliable [2] 136/1
136/23
unrepresented [1]
158/15
unsafe [1] 137/25
unsolicited [1]
154/19
unsure [1] 4/16
unsurprisingly [5]
68/24 69/2 74/9
107/15 116/9
untenable [1] 144/24
until [10] 39/19 42/13
52/6 80/12 89/3
124/14 126/8 156/5
166/24 167/4
unwieldy [1] 6/19
unwisdom [1] 144/9
up [49] 1/16 18/17
19/25 23/17 33/7 35/1
40/12 41/20 41/24
42/10 42/19 42/22
42/24 44/13 45/24
46/19 47/3 51/8 51/12)
54/23 56/19 64/18
68/1 69/1 78/24 80/24
87/24 89/13 92/4
98/21 105/17 107/1
107/25 112/13 120/4
128/8 130/1 131/2
134/4 135/1 135/2
136/2 144/18 145/13
148/6 148/13 153/5
161/18 161/19
update [2] 40/5 109/5I
updated [2] 72/3 95/1
updates [2] 2/8
166/16
upgrades [1] 54/3
upheld [1] 118/8
upon [13] 7/11 8/17
11/20 73/16 74/7
82/20 84/17 96/15
96/19 117/9 133/15
144/8 163/22
upwards [1] 92/10
urban [4] 95/20
95/22 97/4 99/15
urgency [1] 47/7
urgently [1] 117/7
us [32] 4/2 4/4 5/12
8/11 19/14 34/6 39/8
39/24 50/2 50/4 55/18
61/21 62/1 66/13
73/13 92/3 95/3 98/13
99/3 104/11 106/24
107/24 115/3 115/15
120/6 120/16 121/21
122/7 123/17 146/14
147/24 155/1
use [11] 49/15 58/12
67/11 86/21 104/5
124/5 132/10 137/19
144/9 144/25 149/21
used [9] 2/23 23/6
44/20 104/7 132/7
133/17 136/6 137/19
145/21
useful [3] 24/5 40/21
60/17
users [2] 58/25 136/7
using [4] 60/14 81/14
87/4 147/12
usual [1] 11/11
usually [1] 121/13
utterly [1] 102/20
Vv
vagaries [1] 129/12
value [8] 55/6 77/4
91/17 100/1 105/21
150/5 150/9 151/25
values [1] 120/9
Vamos' [1] 154/19
van [5] 53/2 53/2
53/12 54/16 55/11
variables [1] 134/13
varieties [1] 127/7
variety [3] 18/18
19/21 129/13
various [2] 46/14
46/15
vast [3] 16/4 35/14
35/22
vehicle [1] 87/18
verbatims [1] 102/24
version [3] 9/8 10/18
122/23
versus [1] 79/5
very [85] 4/9 4/13
4/17 5/1 20/1 27/25
30/22 37/1 38/16
38/16 38/17 38/24
43/12 51/21 51/21
52/1 61/13 63/18 64/7
65/10 65/10 68/19
69/11 69/11 69/17
70/4 70/6 70/7 70/14
75/13 84/6 84/9 87/16
88/16 88/18 89/5 91/4
93/9 97/22 98/9 98/9
98/25 104/16 105/9
106/10 107/10 112/22)
113/6 114/3 119/19
120/1 120/2 121/8
124/4 127/11 128/10
131/11 133/11 133/11
133/14 133/14 133/15)
136/17 136/20 137/6
137/11 138/16 138/24}
143/1 143/4 143/13
145/9 146/11 153/18
156/19 156/19 157/16)
157/20 159/19 162/4
162/16 162/17 163/14)
165/7 166/10
via [2] 60/11 132/11
viability [2] 90/8
91/14
victim [1] 8/4
victims [10] 3/18
28/3 40/15 43/6 126/9
134/25 145/7 145/12
162/11 165/16
view [42] 3/4 3/8 3/9
3/10 3/14 3/21 3/24
4/14 4/18 4/20 4/21
4/24 5/1 13/12 29/2
36/19 37/1 38/24 40/6
48/2 55/15 61/4 68/13)
73/3 73/7 73/8 73/9
75/17 77/2 78/12 83/4
98/14 102/18 102/23
114/9 130/8 130/19
147/11 151/18 154/7
159/4 161/22
viewed [1] 110/6
views [1] 35/10
virtually [2] 70/5
147/9
visibility [7] 13/13
13/20 15/6 101/15
103/12 108/17 142/22)
vision [9] 93/2 98/10
98/16 98/21 101/24
106/14 110/12 111/23
112/24
Voice [1] 77/7
voluntary [2] 30/7
44/4
voted [1] 68/19
vs [3] 110/11 110/13
110/17
Ww
wage [1] 93/21
wake [1] 110/6
Wales [1] 141/10
want [37] 4/1 15/5
15/24 16/1 21/20
28/25 31/17 34/18
46/8 46/10 47/3 49/9
49/11 50/24 56/23
62/5 66/1 90/5 110/10
110/16 121/21 122/18}
123/24 129/11 133/11
134/10 142/5 143/10
143/11 144/12 146/1
147/4 152/19 152/20
155/20 159/7 159/10
wanted [12] 13/13
13/15 13/21 20/3 20/6}
43/4 50/9 50/15 69/17,
71/11 118/23 143/19
wants [2] 47/11
160/18
warchest [1] 50/3
Warmington [1]
48/21
was [321]
wasn't [10] 14/20
63/4 71/21 74/14
84/16 86/20 134/4
140/6 156/10 163/11
watch [1] 154/23
way [66] 2/21 8/2
8/14 12/15 14/25 16/8)
16/16 17/24 25/8 25/9)
26/5 26/6 26/7 26/12
26/14 27/16 27/20
30/12 31/1 34/13
34/23 44/18 47/17
48/1 48/4 48/5 61/16
62/6 63/20 64/6 64/25)
66/19 67/5 68/3 70/11
73/4 74/19 76/17
77/15 88/8 94/5 95/9
101/22 102/11 109/7
113/17 118/22 118/24}
119/3 119/13 124/5
125/24 127/24 133/8
140/12 143/13 143/20}
145/19 149/22 153/7
153/9 153/25 155/4
157/18 165/12 165/16}
Ways [3] 120/10
120/18 121/4
we [374]
we'd [5] 15/20 70/14
71/5 120/4 154/11
we'll [9] 14/12 22/11
67/10 80/15 121/19
124/15 134/7 160/8
166/24
we're [14] 22/3 27/4
36/9 40/10 43/23
62/10 92/23 93/13
93/14 93/15 100/13
119/17 133/11 165/18}
we've [62] 12/7 19/8
20/24 21/16 22/4
26/19 26/20 36/15
44/18 46/9 46/10
46/12 47/13 47/15
49/1 51/17 51/21 55/9)
55/14 61/17 64/7
65/12 68/9 74/16 76/4,
85/22 87/22 92/25
93/11 94/8 94/11
97/14 97/25 98/1 98/2,
98/3 99/1 106/9
110/20 122/10 122/10}
122/11 126/1 130/17
130/22 130/23 130/23}
130/24 135/11 142/18}
159/9 159/12 159/17
159/17 159/18 161/21
163/14 165/9 165/11
165/15 165/16 165/21
weak [1] 66/17
wealthier [1] 99/5
wealthy [1] 97/4
website [1] 154/21
week [8] 3/15 54/22
55/3 62/2 87/15
100/23 149/16 160/6
weeks [7] 68/25 93/1
103/22 104/22 114/2
114/17 116/4
weight [1] 97/7
weighted [1] 99/6
well [46] 3/15 6/20
14/12 16/8 19/23 32/6I
32/8 32/22 38/1 39/16I
45/21 46/25 62/3
63/21 63/24 64/6
65/18 69/20 74/15
77/14 83/18 84/7
93/15 94/14 94/17
103/9 110/19 116/25
119/21 126/2 130/22
133/1 133/25 136/21
141/1 145/18 146/2
146/17 148/15 149/3
154/24 158/3 160/10
161/8 161/15 165/2
wellbeing [1] 137/13
went [7] 3/3 17/21
46/15 47/24 68/13
118/12 135/21
were [119] 1/16 2/13
2/22 4/10 4/10 5/6
7/13 11/8 11/13 12/1
13/21 14/5 14/8 14/23
14/25 15/1 15/3 18/17I
19/14 28/20 29/4 29/5)
29/6 29/7 30/17 30/18}
32/2 32/8 32/14 32/21
32/24 35/4 36/16
36/24 37/3 37/4 37/18I
38/8 38/11 40/22
40/25 41/10 43/1 43/4)
47/9 48/12 50/4 50/8
51/25 53/1 53/8 54/24)
57/5 61/17 66/6 66/11
66/17 69/2 69/15
70/18 70/20 70/22
71/6 71/7 71/9 72/2
72/4 72/21 73/4 74/9
75/5 75/11 75/20 76/2
77/6 77/8 85/19 93/20)
94/9 101/2 104/9
113/24 118/5 118/6
118/8 120/12 120/20
125/15 125/23 129/15)
130/4 133/14 133/15
133/22 133/24 134/2
136/15 137/6 137/16
138/4 138/11 142/13
143/7 143/12 143/18
144/8 144/15 145/20
148/13 152/17 155/3
156/21 156/23 156/25)
159/22 164/10 164/20)
164/22 164/24
weren't [4] 125/20
140/4 142/15 161/2
what [165] 2/16 6/14
(71) unreliable - what
Ww
what... [163] 8/12
12/7 13/22 14/13
14/22 14/23 14/24
15/11 15/22 15/22
16/11 17/3 18/15 19/3)
20/17 21/11 21/23
21/25 22/7 22/14
22/24 28/8 28/11
28/14 32/4 32/4 33/5
34/22 35/21 36/3 37/6
37/17 37/18 37/19
38/21 39/3 46/1 46/9
46/10 50/4 51/3 52/19)
52/24 53/4 55/14
55/16 56/4 58/15 60/4
62/10 62/19 68/10
68/13 69/3 69/4 69/4
69/25 70/11 70/13
71/7 71/10 71/11 72/2
72/21 72/24 75/17
75/25 77/6 77/6 77/11
77/14 77/17 77/24
78/1 78/1 78/3 79/4
86/7 86/8 86/11 86/16
86/24 87/19 87/22
87/23 90/20 93/2 93/4
93/6 93/9 93/13 94/11
94/21 95/3 95/4 95/5
95/8 97/8 97/16 98/18
101/21 102/2 102/8
102/11 104/19 105/10)
106/11 106/12 108/15
110/4 110/8 110/10
110/15 110/21 110/22)
112/15 112/18 113/12)
113/16 113/17 113/18}
113/20 113/22 114/7
116/6 117/16 118/10
119/5 119/16 121/23
123/17 126/1 132/4
136/20 137/22 140/2
141/14 142/7 142/20
143/15 143/16 145/24}
146/22 148/7 148/23
149/1 151/10 152/7
152/17 153/18 154/14}
156/1 157/21 158/25
159/2 159/4 160/17
161/6 161/13 162/14
162/23 164/22 165/1
what's [3] 57/11
84/17 108/7
wheels [1] 119/25
when [48] 3/15 8/20
11/13 12/13 16/21
24/1 26/8 28/14 30/17,
37/15 38/10 52/24
54/24 59/10 69/21
72/7 75/5 80/6 81/8
83/22 87/13 88/3
103/25 104/22 105/16)
105/17 105/21 111/19}
113/2 113/14 113/25
118/24 120/13 126/17)
138/1 139/3 141/2
141/9 146/15 149/16
153/4 154/17 155/3
161/18 163/7 164/10
164/15 166/24
whenever [1] 64/9
where [61] 8/3 10/2
13/21 17/8 23/12
23/21 28/22 28/23
30/2 30/8 30/8 36/6
46/15 46/17 47/4
47/24 48/7 50/13 52/1
63/18 64/7 65/15
67/10 67/17 67/24
71/11 76/6 78/4 83/12
84/18 84/22 85/24
86/12 88/17 93/15
99/10 104/7 110/23
119/1 121/16 122/4
124/8 130/13 130/13
130/15 130/25 133/7
138/8 138/23 141/16
147/18 148/20 150/8
152/21 153/6 157/18
157/22 157/23 159/21
163/8 164/11
whereby [1] 108/23
whether [32] 2/7
15/13 17/3 17/10
17/13 24/4 28/18
28/19 37/18 57/11
61/16 61/22 62/14
67/22 80/20 81/22
83/5 86/9 87/22 88/23
103/15 103/20 121/4
121/10 122/8 122/9
129/19 131/1 133/22
134/11 146/18 146/19)
which [417] 1/19
2/12 4/19 5/11 9/2
10/12 12/20 16/13
18/7 18/17 19/3 19/16
24/6 24/10 27/9 28/15
29/2 29/8 29/14 30/21
32/2 32/13 33/3 33/8
34/20 39/2 42/20
54/14 54/21 55/15
57/5 57/8 57/24 58/9
59/2 59/16 60/10
60/12 61/8 61/23 62/6
64/4 64/6 72/16 72/18)
77/12 77/21 78/7
78/19 80/9 81/3 81/4
82/15 82/20 84/2 84/3
85/19 86/25 87/16
87/25 92/7 92/16
92/24 93/9 93/15
94/17 97/2 98/5 98/8
98/25 99/12 99/13
100/4 100/19 101/17
102/16 102/19 104/3
104/7 104/8 104/12
106/2 106/15 108/15
111/20 111/22 113/10
113/10 115/9 119/3
121/6 121/20 121/21
127/2 130/5 134/13
136/17 139/8 139/22
140/13 140/21 140/22
141/20 142/14 147/9
151/10 152/18 154/5
154/6 154/14 154/20
155/9 156/24 157/21
160/3 160/9 166/21
while [5] 61/11 62/13
62/14 67/20 99/25
whilst [6] 13/20
68/21 69/7 87/19
136/1 147/22
whistleblowing [1]
118/4
White [1] 42/18
who [63] 4/10 18/6
18/9 18/12 21/13 22/8
28/1 28/14 29/4 29/14
29/15 30/4 31/5 32/10
32/14 32/22 35/4
35/15 36/22 37/22
38/7 38/8 50/8 50/19
51/4 51/23 51/24
52/23 55/21 60/16
61/4 62/8 68/17 70/18
71/6 83/10 83/16 84/1
84/5 84/5 87/15 88/1
88/2 93/19 114/13
114/20 114/23 115/11
117/5 119/20 124/7
125/7 137/20 138/19
142/10 146/11 147/1
152/7 152/19 153/12
156/6 156/20 159/9
who'd [1] 103/7
Whoever [1] 147/6
whole [1] 62/25
wholly [1] 136/23
whom [7] 24/4 28/10
30/5 74/14 132/24
152/4 164/7
whose [2] 116/9
116/10
WHSmiths [1] 97/9
why [26] 3/24 4/5
4/14 4/16 13/9 13/24
15/4 16/10 19/11
25/23 26/2 26/15
26/17 27/9 33/13 78/7
86/11 90/12 98/4 98/6
103/18 111/14 115/16
129/18 154/8 157/21
wide [1] 54/1
wider [1] 105/15
widower [1] 152/7
wife [1] 131/14
will [89] 3/14 3/18
8/17 8/19 9/7 11/20
16/9 16/20 20/12
20/13 24/18 24/19
24/21 33/17 33/21
33/22 35/15 36/11
39/19 40/24 41/12
41/14 43/22 45/5 46/1
47/21 47/23 52/2
52/14 62/14 63/11
63/17 63/19 63/19
64/4 64/10 80/7 86/24
87/2 87/24 89/24 92/5)
96/3 97/15 101/9
102/24 104/5 104/21
108/2 109/13 110/22
112/13 112/17 113/7
114/5 114/6 117/17
117/25 117/25 118/3
118/8 119/7 119/12
119/14 119/15 119/16}
119/18 121/17 121/17]
122/4 122/4 126/3
126/8 147/2 149/5
149/8 149/9 149/20
152/3 152/4 152/4
152/19 152/19 153/11
154/8 160/2 166/9
166/15 167/1
Williams [3] 124/11
164/7 164/8
Wilmington [1] 48/20
wind [1] 33/5
wish [1] 47/2
withdrawn [2] 80/23
80/24
within [35] 3/10 4/21
9/5 11/17 18/6 18/8
18/17 20/5 25/4 27/8
31/16 32/21 34/14
35/23 36/8 36/20
37/11 37/23 41/22
47/12 53/16 58/18
74/18 77/20 86/16
95/16 95/17 95/20
95/23 95/25 96/7
107/2 115/17 116/7
417/17
without [11] 16/6
28/5 49/16 50/16
79/18 102/4 103/1
103/2 127/12 136/15
155/7
WITNO0760100 [1]
120/5
WITN00760300 [1]
64/19
WITN11610100 [1]
56/7
witness [36] 7/16
7/21 8/8 10/7 12/10
12/13 12/18 13/10
15/10 27/18 27/20
49/24 55/18 55/19
56/8 56/9 56/23 57/14)
61/2 61/6 62/1 62/9
62/18 64/16 89/14
89/21 92/3 103/5
106/24 107/24 115/6
115/16 120/3 137/6
138/12 146/10
woefully [1] 148/21
woman [1] 132/13
won't [4] 33/18 44/16
50/25 159/25
wonder [1] 131/6
wondered [1] 75/17
Woodley [1] 5/15
wool [2] 153/20
165/5
word [13] 2/23 15/24
31/18 102/1 103/9
124/5 144/9 145/21
147/5 149/21 151/1
153/18 157/17
wording [3] 10/4
10/15 25/7
words [14] 10/21
10/21 12/17 75/12
86/23 128/24 136/24
137/19 138/13 144/22)
144/25 160/24 161/8
162/17
work [63] 11/1 13/5
14/13 17/22 18/6
19/21 19/22 19/25
20/2 20/15 21/8 26/19}
26/20 27/4 27/12
27/16 28/7 31/9 31/23}
31/24 32/15 34/8 35/7I
35/9 37/16 37/22
37/24 38/6 38/23 39/5
42/4 42/6 42/14 43/5
43/18 47/1 48/22
63/14 83/5 83/22 92/5
98/19 101/15 102/13
108/3 108/14 108/20
108/24 111/13 116/22)
120/22 121/21 122/21
123/13 123/22 123/23}
123/25 124/3 129/25
130/16 149/14 154/10)
154/12
worked [6] 10/17
18/9 29/14 31/5 65/18)
154/11
working [10] 28/10
36/20 69/1 81/9
120/10 120/18 121/4
123/9 129/7 166/3
Working’ [1] 120/8
workings [1] 146/21
works [4] 19/2 33/12
33/15 148/8
workshops [1]
121/19
workstream [2]
160/19 160/23
worn [1] 152/8
worth [3] 76/25 77/3
78/14
(72) what... - worth
Ww
wouldn't [4] 77/18
144/5 144/20 153/14
wounds [1] 126/18
wrapped [1] 148/13
wrestle [1] 77/23
wrestled [1] 102/9
write [2] 62/9 100/20
writing [2] 149/5
154/25
written [5] 20/13
wrong [11] 34/4 42/5
51/12 85/17 85/20
88/7 130/11 144/24
153/7 155/16 157/17
wrongdoer [1] 139/4
wrongdoing [9] 28/5
28/7 28/20 29/6 30/6
30/15 61/1 62/4
131/23
wronged [3] 3/6
128/1 162/11
wrongful [4] 125/11
wrongly [2] 128/17
134/24
wrote [1] 33/10
Wyn [2] 75/19 124/11
Y
Yeah [2] 36/14 123/3
year [13] 39/13 92/8
99/20 100/9 114/11
114/11 133/10 154/22
165/20
yearly [2] 97/16
100/25
yearning [1] 125/7
years [41] 23/6 26/3
28/16 43/23 46/9
48/10 53/9 63/8 64/3
69/16 71/24 76/4 94/8
94/10 98/16 98/23
99/22 100/25 104/4
105/7 105/25 107/17
108/9 109/21 111/14
111/24 112/6 112/14
114/8 116/21 119/1
132/1 132/7 132/25
133/8 134/17 135/7
142/13 142/18 163/7
164/11
yes [190]
yesterday [21] 1/11
2/16 2/17 5/6 5/12
13/12 13/17 17/5 18/7
19/20 27/17 38/20
39/18 40/3 41/5 64/12
74/15 83/8 118/22
145/14 146/16
would [191]
34/18 37/7 37/8 90/20
126/11 126/17 127/24}
94/6 94/8 94/14 98/15] 48/2 52/12 53/9 55/18
yet [5] 54/6 61/5
97/21 124/16 160/24
you [386]
you'll [15] 1/12 1/19
41/19 53/15 69/10
72/17 79/19 91/3
94/24 101/4 103/5
106/8 129/22 149/15
166/25
you're [31] 5/13 17/1
36/3 37/17 39/13
43/20 50/22 62/19
62/24 63/2 67/2 67/9
67/21 87/15 90/3
135/6 138/8 138/23
139/24 142/9 143/4
143/16 144/21 146/2
147/15 150/14 152/1
157/22 158/6 158/15
158/25
you've [25] 4/18 38/1
52/13 85/25 90/15
98/13 113/10 115/15
137/24 138/7 142/14
144/11 144/16 144/17)
144/17 144/22 153/16)
153/16 155/18 156/5
158/12 158/21 159/20)
160/3 166/10
young [1] 132/23
your [54] 1/10 3/3
3/11 21/9 27/17 27/20
32/4 37/9 38/11 39/22
39/23 40/5 46/3 46/7
55/19 64/16 66/11
74/12 75/17 85/6
89/14 89/21 90/21
91/6 92/3 94/17 94/25)
99/10 102/12 102/13
106/24 107/24 115/6
115/16 120/3 128/7
128/10 130/8 130/19
135/5 137/6 138/11
138/12 139/3 140/18
140/21 154/4 154/18
154/23 166/25
yours [1] 68/8
yourself [3] 33/10
117/23 164/23
(73) would - yourself