INQ00001195 - Transcript (11/10/2024): Post Office Horizon IT Inquiry - Nick Read [WITN0076]

Evidence on official site

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The Post Office Horizon IT Inquiry

Friday, 11 October 2024

(10.00 am)

NICHOLAS JAMES READ (continued)
Questioned by MR BEER (continued)

MR BEER: Good morning, sir. Can you see and hear us?

SIR WYN WILLIAMS: Yes, thank you very much.

MR BEER: Thank you.

Good morning, Mr Read.

A. Good morning.

Q._ Can I once again turn to the topic of whether the Post
Office did not wish to have ownership of, or administer,
any of the redress schemes. You remember we discussed
this on Day 1, and we addressed it again on Day 2 of
your evidence. I'd like you to consider, if we may,
an additional piece of evidence in the light of the
answers you gave. Can we see, please, WITN00200300.

You'll see that this is a witness statement of
Thomas Cooper, who you'll know.

A. Indeed.

Q. By way of reminder for others, he was the UKGI
Non-Executive Director on the Post Office Board for five
years ~ is that right —

A. Yes, that's correct,

Q. ~ between March 2018 until May 2023, when he was

replaced by Loma Gratton?
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proposal was the establishment of a unit within {the
Post Office] to handle all compensation related
matters."

Paragraph 30:

“UKGI's advice was discussed with [Post Office] and
[His Majesty's Treasury] as well as the Department.
[Herbert Smith Freehills] assisted {the Post Office] in
preparing its own paper on the topic, which was
discussed at the Board. The idea of separating the
compensation workstreams from [Post Office] received
little or no support. The Board determined that [the
Post Office] would take responsibility for the
compensation workstreams itself rather than pass it to.
[His Majesty's Government]. It was decided that,
an internal unit would be set up within {the Post
Office}, the Historical Matter Business Unit, now known
as the Remediation Unit. That was set up in July 2020
and had a remit to deliver the legal and compensation
workstreams flowing from the GLO proceedings.”

Just to complete this:

“Having reflected on this decision and reviewed the
advice that UKGI provided, as well as the Board paper,
one thing that is conspicuously missing from both
documents is the claimants’ perspective. Claimants were

not approached to give their view at the time and, in
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That's correct.

He gave evidence, by way of reminder for the transcript,

in Phases 5 and 6 of the Inquiry, on 10 June 2024.

Yes, that's correct.

This is a subsequent witness statement of his addressing
some Phase 7 issues. Can we look, please, at page 11,
under the heading "Operational resourcing", and this is
part of his statement which addresses the governance and
resourcing of the HSS. He says:

"During this phase, there were discussions at the
Board about how [the Post Office] would operationally
resource the compensation workstreams.

“In Spring 2020, the Shareholder Team contributed to
those discussions by providing advice to the Department
concerning the separation of historical liabilities and
compensation matters arising from the GLO from the
‘business as usual’ commercial operations of the
‘Company. One option that was suggested was to transfer
the management of [Post Office's] compensation-related
liabilities into a newly created separate company owned
wholly by [His Majesty's Government]. This would have
enabled [the Post Office] to focus on the strategic and
operational issues it faced, whilst in parallel having
a dedicated resource set up to deliver compensation to

victims of the Horizon scandal. The alternative to this
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hindsight, the lack of trust that claimants had in [Post
Office] should have been included as a factor in support
of separation. We now know that trust remains a major
issue for claimants, one example of which is the GLO
claimants’ refusal to have the GLO scheme administered
by {the Post Office]. Given that, as of today,
significant elements of the compensation being delivered
to [subpostmasters] are being administered by the
Department, as well as the very significant strain that
‘compensation has placed on [the Post Office's]
management which has lacked the bandwidth to handle the
multiple, complex issues in front of it, I believe that,
with the benefit of hindsight, the option of separating
the compensation from [Post Office] should have been
considered more seriously. However, at the time,
following the successful settlement of the GLO and the
participation of the GLO claimants in the design of HSS,
there was a perception at {the Post Office] that
a degree of trust in [Post Office] had been restored.
It is possible, therefore, that even if UKGI's advice
and the Board paper had identified the issue of trust
and captured it fully, the decision made may well have
been the same in any event.”

Just going back to paragraph 30, please.

In the third line, Mr Cooper says that:
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“The idea of separating compensation workstreams
from [Post Office] received little or no support. The
Board determined that [the Post Office] would take
responsibility for the compensation workstreams itself,
rather than pass it to [His Majesty's Government].”

Is that correct?
I think recollections do differ. I am very clear that
I have contemporaneous notes from May, June and July
where the notion ~
Sorry, that's 2020?
Yeah -- where the notion of a good bank and a bad bank
was put forward by myself and Carla Stent and Carla
Stent was the Chair of the Audit and Risk Committee, and
we were quite vociferous about the necessity to separate
good bank from bad bank, by which I mean how could we
ring-fence the different elements of these particular
schemes?

So I don't support the notion that it received
litle interest or little support from the Board,
I think the Board were very aware of the amount of work
that would be required, let alone the level of trust
that needed to be established. So I have a different
view and a different recollection
Given that, in any event, there appears not to have been

agreement with Government that Post Office should not
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Can we just briefly address a couple of issues on
Postmaster NEDs. We've done this a couple of times
already, a couple of points to clear up. You tell usin

your first witness statement ~- there's no need to turn

it up, it's paragraph 94 -- that they were not provided

all papers that went to the Board because of conflicts

or a conflict; is that right?

Yes, that's correct.

What was the conflict that the provision of papers to

the Postmaster NEDs -- that would have arisen?

I think, very specifically, we were conscious that,
Postmaster NEDs were, first and foremost, postmasters in
their own right and, therefore, by definition, there

were commercial sensitivities that may or may not have
determined a particular cause of action. We were making
decisions with banks, with Royal Mail Group, with travel
businesses, with our online business and, clearly,
postmasters would have been privy to particular
information that might have had a commercial sensitivity
that might well have impacted decision making that they
could have been involved in, as in on their own

accounts, and I think it wouldn't be unreasonable to
expect, given the duality of their role as both

a postmaster and an entrepreneur running their own

business, as well as determining and deciding what the
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participate in or administer the compensation schemes,
wouldn't that, therefore, present the ideal opportunity
to tell the Inquiry, when it was considering that issue,
Post Office's view?

Quite possibly. As I mentioned yesterday and I think,
indeed, as we discussed on Wednesday, this was very
clearly an instruction from the UKGI. It wasn’t

a "Shall we decide how to do this, what is the best
way?" So I'm very clear on that.

When you say it was an instruction from UKGI, the
instruction was to what effect?

To the effect that we would manage the compensation
schemes.

So it's almost precisely the opposite of what Mr Cooper
says?

Yes, I - as I say, I'm very clear that this was
something that wasn't a choice for the Board. The Board
didn't have a choice about whether or not it would
administer compensation schemes.

‘Again, given that that was, on your account,

a significant difference with Government, why wasn't
that ventilated or submitted to Sir Wyn in any of the
hearings that we had?

It's a good question. I can't answer that.

Thank you. That can come down
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direction of travel for the Post Office is, that they

would be privy to certain information that might have
put them in an advantageous place, or indeed in conflict
with the organisation.

Was a similar approach taken to the UKGI NED because
they had a duality of role, didn't they?

Yes, they did but they don't have a financial interest,
per se in the operation of their post offices, as the
postmasters themselves do.

No, they have a different dual role?

Yes, they have a different role, clearly.

Was information and papers kept from them?

Well, 'd probably put it in a slightly different way.

I'm -- as we saw, I think it was yesterday, we saw,
indeed in Project Pineapple, information that was shared
with the Non-Executive Directors by Henry, was not
shared with myself and Lorna. So there was a very
evident illustration of that point. I, for instance,

don't get the documents that go to RemCo because,
clearly, there would be potentially a conflict for me,

in that documentation. So I don't think it’s wholly
unusual to identify conflicts where people may or may
not have interests in the workings of the organisation.
So I didn't see that as a particular issue.

How did it affect, if any, their role, the Postmaster
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NEDs' role on the Board, by the non-provision of papers
and information?

Difficult for me to answer that, in the sense that you
would have to ask Elliot and Saf what they felt that

they were being excluded from. My sense is that it was
very little and very limited in terms of what they were
excluded from. If I think back over the last three

years, where we have been in a Board meeting where
either they've had to excuse themselves or leave the
room because of conflict, I genuinely wouldn't be able

to identify any specific issue ~ any specific time.

You tell us in the same statement, it's paragraph 98,
that both the current Postmaster NEDs were consulted on
how to approach the next round of NED recruitment and,
based on their input, the criteria for the role has been
“rebalanced and made more objective and clearer’. What
was unbalanced and/or unobjective about the previous
criteria?

I think what we've learnt, sort of specifically, in

terms of the first term that the Postmaster
Non-Executive Directors have done, is that there are
ways to improve both the process of recruitment, both
the expectations of the role, both the level of training
and support that we can provide. So there were a range

of different issues that we wanted to improve and it was
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determine what the criteria is for the selection
process. So that's obviously not a committee that I sit
on.
Mr Ismail says in his statement, same reference,
paragraph 150:

“I believe the timing and criteria were engineered
to exclude me and Mr Jacobs because we are too
challenging, too inquisitive and ask too many awkward
questions.”

Is that right?
I don't believe that's right.
They gave interviews to the press; that's right, isn't
it? I think you refer to one of the articles based on
what they had said in your witness statement, a Times
article in February 2024?
I think that was an article that you presented to me, as.
opposed to my presenting to you, if you see what I mean.
Yes.
I responded to it, yes.
Yes. So what would you say to the suggestion that they
were "too challenging, too inquisitive and asked too
many awkward questions"?
I would say that was their job. I made it very clear
yesterday that I championed Postmaster Non-Executives to

be on the Board for exactly that reason: I knew they
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those that we discussed with Saf and with Elliot: how
does the selection process work; what are the
expectations of the role?

So, for instance, we've talked quite extensively
here about the commitment that the Non-Executive
Directors, the NEDs, have made. So I don't think it was
anything particularly specific. It was about ~ it was
about refining and getting their view on how the job and
how the role could be done better, and I think that's
what we've taken forward.
Both of them - I'll give the crossreferences, no need
to display: Mr Jacobs WITN11180100, at paragraph 14, and
Mr Ismail, WITN11170100 at paragraph 150 -- say in their
written evidence, and they've repeated it in their oral
evidence, that the amended criteria mean that they have
not been shortlisted for reappointment when they applied
to stand again. Is that right: the change in criteria
meant that they were not shortlisted when they applied
to stand again?
I wasn't aware that it was a change in criteria that
stopped them from being shortlisted. I haven't seen the
analysis of all the participants who have come forward
to put their names forward. That's obviously something
that's managed and run by the Company Secretary and the

Nominations Committee will be the individuals that
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would bring a tactical focus and an operational focus
and an understanding of what was going on in the
business at the time. It would be uncomfortable at
times and I was very aware that that would be the case.
I had experienced it at Nisa, I knew what I was letting
myself in for and I think, certainly, my own expectation
was that it would bring the Board closer to postmaster
issues and it would bring the Board closer to what is
going on from a trading perspective, as well as from
a cultural perspective, in the organisation, and that
was an important way of trying to rebuild trust.

That was the ultimate aim of the objective, as well
as getting their unique experiences of being
a postmaster in the organisation around the boardroom
table.
What would you say to the suggestion that Post Office
did not listen to the Postmaster Non-Executive
Directors, marginalised them after it had appointed
them, they got frustrated and went to the press, and
Post Office, therefore, made it difficult for them to
effectively stand for re-election by amending the
criteria?
I disagree with that. I absolutely refute that
allegation.

I think it's right that exit interviews were conducted
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with Non-Executive Directors; is that right?
That's correct.

Can we look, please, at POL00448681. "NED Exit
Interviews — Written Summary", conducted by Emst &
Young, EY?

Yes, that's correct.

If we go, please, to page 5, I just want to look at some

of the things that were suggested. Top line:

“I have found it a challenge being on the [Post
Office] Board --it can feel like a puppet Board where
we don't have real decision making powers while actually
having a lot of responsibility."

Then further down, just under the line, in answer to
the question "What are the issues facing [Post Office]
that will likely consume the time of incoming NEDs?"
Answer:

“That they will be coming into a Board that is
actually not that influential as a whole, that it really
has no authority, it just rubber stamps decisions made
elsewhere.”

Then over the page to page 6, please. Just at the
bottom on the page that's being displayed at the moment,
two paragraphs up:

“The GE use the Board to rubber stamp things but

don't involve the Board as they might. I am not sure we
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The sort of broader challenge, I think, is around
the effectiveness and independence of the Board and
whether or not they have the levers and the power to
make the decisions that Post Office needs.

I think that is the underlying theme that is being
expressed here, certainly in the first two or three
bullet points that you were making, and there is
a challenge around that, and that is when you read the
context of the entire feedback, that is the underlying
theme of why, I think, individuals have found that they
would only stay for one term on the Board: because they
felt — I think it's in the first bullet that you
made -- that they have an enormous amount of
responsibility and accountability, but they have very
limited and little decision-making powers, primarily
because those decisions are either made by the
shareholder/UKGI or they are difficult to influence.
So what is described by these exiting NEDs is not your
experience at all of the Board?
Which particular bit?
Well, the three that I've read to you.
I
It's a puppet Board, we don't have any real
decision-making power; the Board isn't influential as

a whole, it rubber stamps decisions in fact made by the
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are respected or valued, we are all vested.

"There isn't the level of trust in the GE nor are we
trusted by them -- this has resulted in a lack of
‘commitment to minuted actions.”

Those comments — and I realised that I'm
selecting —

Yes.

~ from a large number - come during your tenure as
Chief Executive, doesn't it?

Yes, that's correct, although, I think Carla Stent in
particular, her tenure was six years, so it --

So it was partially pre-dated?

Indeed.

Do you accept the description of the role and function
of the Group Executive?

No, I don't think so. We have a -- this has been
discussed, I think, quite extensively by other
colleagues ~- the range of information that comes to the
Board and the issues that the Board has had to grapple
with over the last four or five years has been quite
unique, in the sense that there are just a range of
priorities that are very difficult to distinguish

between. And so it has been difficult to get that level
of genuine decision making, I think would probably be

the best way to describe it.
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GE; and the Board rubber stamps things for which it
isn't respected or valued?

No, I don't think I would agree with that. I think the

first two points you make are actually more references
to the influence and shape of the Board with regard to.
the shareholder, as opposed to with regard to the Group
Executive. It has been very tough, I think, for the

Board and the Group Executive, certainly at this
particular juncture but I don't think that is something

that is widely experienced, in terms of the Group
Executive just expecting the Board to rubber stamp
issues. I think it's more the volume of work that the
Board was having to deal with that meant they couldn't
give the level of attention to the specific issues and
topics that were being brought forward.

And, secondly, I think the nature of the business,
and I say this in my original witness statement, my
first witness statement, is that for the five years
certainly that I have been in the business, it has been
in crisis, and so many of the decisions that have come
to the Board have been tactical, short-term and
reactive, as opposed to long-term strategic, which you
would expect from a business that was perhaps under
the ~ less under the strain that the organisation has

been for the last five years.
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I think you've had your attention drawn to an email
exchange between Loma Gratton and Rachel Scarrabelotti
in October 2023 -- I'm not going to display it unless
it's necessary, in the interests of time ~ about the
SID appointment where she, Lorna Gratton, expressed the
view that it would be beneficial to appoint a woman to
give balance to the Post Office Board. Do you recall?
Yes, I do recall that. I thought ~ I think -- this is
the exchange where Lorna wanted, and I shared this view,
that we have an external SID appointed to the Board —
Did you agree that the Board lacked balance and
therefore needed balance brought to it by the
appointment of a woman SID, a female SID?
Yes, I think so. So Lisa and Carla and Zarin all left
within the space of four months, and I think the Board
would have benefited from an additional female, perhaps
a SID as well
Other people have raised concerns about your treatment
of women, and I must give you opportunity to respond to
the allegations that have been made. I am not going to
display them in the interests of time and, instead,
summarise them for you, Mr Read:

Firstly, Mr Staunton claiming in March 2024 that you
had overseen a culture of misogyny.

Mr Staunton saying that he was aware during his time
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against Henry Staunton and against the Post Office more
generally, having not had her job role and her probation
period converted into a permanent role. And so, having
left the organisation in June, it was then some two and

a half months later that she made a series of

allegations against me and -- including Henry.

Was that the first time that you became aware of
concems regarding views and approach towards women in
Post Office?

It was the first time that I was aware that allegations

had been suggested that I was fostering a culture of
misogyny or anything along those lines.

When you joined the Post Office, were you concemed
about any lack of diversity amongst the Senior Executive
Team or the Board?

Not at the Board. I think we were a diverse and
functioning Board. I think it was relatively well known

that the Group Executive was male dominated, certainly,
and we were keen to set ourselves some targets for the
Senior Leadership Group and also for the Group Executive
to introduce some diversity to that, to both of those

two forums.

You tell us in your witness statement — no need to turn

it up, it's the second witness statement, page 17,

paragraph 49 -- that a survey conducted by Post Office
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at the Post Office of a "high level of unhappiness.
amongst a number of the company's senior women",

a pattern developing where senior women were not
supported in challenging roles.

Ms Davies telling him that she had raised the issue
of the psychological safety of women in the organisation
directly with you but you were not prepared to take any
action.

Mr Staunton noting that Ms Davies was the fifth
Chief People Officer during your tenure, which gave him
concem about your ability to retain female talent, she
having expressed concems over a “job for the boys”
mentality within your team.

Ms Davies’ Speak Up report of September 2023, which
included allegations against you, which was subsequently
independently investigated by Marianne Tutin of Devereux
Chambers.

Firstly, did you become aware of concems regarding
your views and approach to women in senior roles in Post
Office?

Did I become aware?

Yes.

In what -- well, I became aware when Ms Davies, having
left the organisation in June 2023, in September 2023,

elected bring a series of grievances against me and
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showed that:
“The proportion of women experiencing comments that
felt offensive, embarrassing or hurtful was greater than
men and that that rose consistently and significantly
with seniority."
Following the results of that survey, what steps
were taken, if any, to address it?
We had an action plan, three things emerged, I think
from that, in particular, if it's the one that I recall
The first one was that disabled colleagues within the
business were suggesting that they didn't have the
opportunity to get on in the same way and weren't
supported in the way that some of their abled colleagues
were. We had an issue -- a cultural issue in that some
of our cultural minority colleagues felt that they were
not getting the level of promotion that they wanted and
warranted. And then the third piece, which quite
rightly you highlight, which was very, very
disappointing and surprising to a degree, was that
senior women within the organisation had experienced
more unwanted comments than their male counterparts
And so we established those three as the core
equity, diversity and inclusion elements to our strategy
and we advised the organisation that that is where we

were going to spend our time. We have recruited a new
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capability and inclusion director, and also a new
equity, diversity and inclusion director, to spearhead
the strategy, our EDI strategy, that we want to develop.

So we are very conscious of that feedback and have
been very transparent in the fact that this is something
we will be addressing over the next few months.

One miscellaneous topic, before I ask my final questions
to you. Can we look, please, at POLO0448381. This is
a letter you'll be familiar with: it's your letter to

the Lord Chancellor, 9 January 2024. You're familiar
with this?

I am indeed, that’s right.

I'm therefore going to skip over the first three
paragraphs, if we scroll down, please. That refers to
some work that's been done by extemal legal advisers,
which had identified 30 potential appellants, to whom
POL would write, because it would be highly likely that
POL would concede their appeals in the Court of Appeal.
The letter continues:

“A natural corollary of that exercise has been to
identify those cases in which, on the information
available to us and following the judgment in Hamilton,
we would be bound to oppose an appeal. Typically, these
cases involve convictions obtained by reliance on

evidence unrelated to the Horizon computer system. The
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the fact that we'd done this work and that we had shared
it with the Advisory Board, that we recognised that

there were challenges and, you know, clearly it was
important that we made ourselves, Peters & Peters, Simon
Baker, Jacqueline Carey -- the KCs that had conducted
the work on our behalf ~ made them aware of what we had
done and the challenges that we'd experienced.

You tell us that the Board held over 60 meetings
regarding the Post Office's responses to the CCRC and
criminal appeals, just in the period 2021 and 2022. Has
the Post Office similarly engaged with or held meetings

in respect of its response to the Scottish Criminal

Cases Review Commission and the Procurator Fiscal
Service in Scotland?

No, we haven't.

Why is that?

I think, when we first met in 2021 and went through

a series of Board meetings to look at individual cases,

we hadn't established our Remediation Committee, which
is the subcommittee of the Board that now oversees
remediation matters, and my understanding is that the
Remediation Committee are overseeing those matters as
opposed to the full Board.

In May 2024, the Lord Advocate made a statement to the

Scottish Parliament that, due to its conduct, the Post
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number of such cases is very much more significant, at
369, with a further 11 still under review. There are
another 132 in which we cannot determine the sufficiency
of evidence without more information. This clearly

raises acute political, judicial and communications.
challenges against the very significant public and
Parliamentary pressure for some form of acceleration or
bypassing of the normal appeals process.”

Was this essentially you, on behalf of the Post
Office, saying to the Government that it should not
legislate, in an exoneration bill or similar, because of
an assessment by Post Office that the vast majority of
convicted subpostmasters were, on its assessment,
unlikely to have their convictions quashed in a court?
No, I was making no value judgement, as I said in the
fifth paragraph, about what this meant or what you could
interpret from it. I was extremely conscious that we
discussed with the Advisory Board through the previous
autumn, actually in the summer, the real challenge that
we had, in light of Hamilton, of encouraging postmaster
victims to come forward

We discussed a range of different ways to try and
achieve this, and it was really to highlight that we
felt we had an obligation -- I was advised that we had

an obligation to let the Lord Chancellor become aware of
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Office was no longer trusted in Scotland and, as such,
had been stripped of its role as a Specialist Reporting
‘Agency in Scotland. What was the Post Office's response
to that?

I'm not sure we had a formal response, per se, at the
Board and I don't recall that happening. I think we had
and have been very clear that we will not be conducting
any form of prosecution, so I don't think it was of
enormous surprise that that was the decision that was
made. But it wasn't a formal discussion, certainly at

the Board. It may well have been something that was
considered at the Remediation Committee.

Has the Post Office carried out any formal review of its
previous performance in the role of a Specialist

Reporting Agency in Scotland?

Not that I'm aware of.

Lastly on this topic, can we turn up POLO0448701. If we
just look at the last page, please, this is a letter

from Mr Vamos, Partner and Head of Business Crime, if we
scroll down. We can see it's sent for and on behalf of
Peters & Peters Solicitors. If we just go back to the

first page, please, this was a letter that I think was
displayed on the Post Office's website?

Yes, I understand that, yes.

Do you know how that came about?
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How it was put on the website? No, I don't but I've
leamt during the course of this Inquiry that that was

the case.

Then it was taken down?

Quite possibly, yes.

Yes, do you know ~

don't know —

-- anything about why it was put on the Post Office's
website and then it was taken down?

Idon't. No, I can't give you that.

Do you know who instructed Mr Vamos, if anyone, to write
this?

‘A. No, I understand it was unsolicited, as in it came to us
unsolicited.

oP

So it's a Post Office criminal lawyer ~

Yes.

-- ie somebody instructed, expert in the criminal law,
writing to their client uninvited —-

Yes.

prop

~ unsolicited --

Yes.

-- or uninstructed —

Yes.

-- to do that, is your understanding?

PePrPeOProOP

That's my understanding.
25

A. No, I don't. I don't know the genesis, as you say, of
the letter itself or indeed how it then — and who
determined that it would be put onto the website.

SIR WYN WILLIAMS: It's addressed to "Dear all"; who are the
“all” there, Mr Read?

‘A. don't know, sir. I don't know who “all” is, I'm not
clear if this was a communication that went more broadly
to other all people, I'm not certain.

SIR WYN WILLIAMS: Normally, if it's sent electronically, we
get a kind of list of recipients on email, don't we?

Unless I'm wrong, I don't think the Inquiry knows to
whom it was actually sent.

A. We can obviously find out who that is and obviously help
the Inquiry, if that would make sense.

SIR WYN WILLIAMS: Thank you

MR BEER: Lastly, you have heard, I think, a series of
witnesses in the Inquiry within this phase suggest that

your own personal grievances about your own remuneration

became too significant a feature in your tenure and
interfered with your ability to carry out your role.

A. Yes, I've heard that.

Q. Are they right?

‘A. No, I don't believe that to be the case. However, I am
very aware that the furore around my pay and

remuneration — and I'm not in any way deaf to that --
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But then it's put on the Post Office's website?
So I've now subsequently discovered, yes.
In the third paragraph, the third on the page here, the
second substantive paragraph, Mr Vamos says:

“In reality, itis highly likely that the vast
majority of people who have not yet appealed were, in
fact, guilty as charged and were safely convicted.”

By posting this on the Post Office website, did the
Post Office ally itself to that view?
I don't know the detail of how and why it was posted to
the website. I think there is a question that we've got
to ask ourselves as to the governance of what it is we
put on our website and how it -- how material goes onto
the website. I think that's something that we've got to
review.
Was that the view within the General Executive?
No, I don't believe that is the case.
So looking at the matter generally and standing back, do
you know how it is that Post Office's principal criminal
lawyer wrote an unsolicited opinion for the Post Office,
which said that the vast majority of people who haven't
appealed were guilty as charged and safely convicted,
and the Post Office publishes that?
It looks pretty appalling,

I'm just asking: do you know how it happened?
26

looks very poor in light of many of the victims who are
still waiting for their compensation, and I very much

regret that the furore that has exploded as

a consequence of that has been a distraction for
everybody.

To be clear, I'm not asking you questions about whether
you thought you were underpaid or not and nor am

I asking you questions about your reflections on how it
looks that you were complaining repeatedly about your
pay, your salary and your remuneration package as

a whole. I'm asking you: did your repeated grievances
and complaints about remuneration become too significant
a feature of your tenure and interfere with your ability

to carry out your role?

No, I don't believe that to be the case.

‘And why?

Iwas frustrated at times but I don't believe that it

was a distraction. I don't

I'm sure if you discuss
with other colleagues, they would certainly corroborate
the fact that it's not something that I was perpetually
discussing. There's no question that two of the
individuals who have made these allegations have left
the organisation under somewhat of a cloud, and so I can
understand that that may well be the driver behind why

they have made these comments.
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To be clear, it's not simply Ms Davies or Mr Staunton,

I think the two people you're referring to ~

Yes.

~- there are contemporaneous materials with you making
complaints, saying, for example, "Am I prepared to make
a drama out of this? Yes, I am. I'm prepared to submit
a formal grievance. I'm prepared to make a claim for
destructive dismissal. My patience has expired”, and
the like?

Iwas frustrated. I was frustrated, Mr Beer, yes, I can
confirm that's the case. But I think many CEOs and many
individuals operating in ~- potentially in a role that,

as I described on Wednesday, bears no relation to the
one that I was recruited to do, and the complexity and
the leadership challenges associated with that role,
three years in, clearly was something that was
frustrating me, and I vented that frustration.

You sought legal advice on your position?

Support -- well, no, it wasn't specifically legal

advice. I did obviously --I discussed it with other
colleagues and friends — not colleagues within the
business but other colleagues.

You sought PR advice?

As I say, with other colleagues and friends.

I'm not going to go to the text messages that you
29

writer gets her usual break.

SIR WYN WILLIAMS: Fine. Thank you.
MR STEIN: Sir, I can confirm I have spoken to Mr Jacobs,

who will remind me to take that break at around that
time in about 25 minutes.

‘SIR WYN WILLIAMS: Thank you.

Questioned by MR STEIN

MR STEIN: Mr Read, I think you're aware that I represent

a large group of subpostmasters. I just want to break
that down so you've got an understanding of who it is
that's within that group.

The large group that I represent, includes people
from the GLO claimants at the High Court. It includes
people that have been convicted of offences by the Post
Office, or thereafter, once the Post Office stopped
prosecuting people itself. It includes people that were
branch managers, such as Peter Holmes, deceased,
represented by Marion Holmes, who appears in this
Inquiry and sits beside me today. It includes people
who were working in branches, Ms Falcon, who was one of
the last people convicted using Horizon data, who was
an employed people within a branch. It includes people
like Dr Linnell, a forensic accountant who, in fact, was
not a subpostmaster or working in a branch but has

devoted a considerable amount of her time and her
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exchanged with Ms Davies but in one of them you said,
“I've gained advice on my legal position and PR advice
‘on how I intend to handle this".

Did you threaten to resign as CEO unless you were
given higher remuneration?

A. No, as I say, I was very frustrated at that particular

time but I'm still very much in role now. So I didn't
offer my resignation or tender my resignation, or
anything of that nature.

MR BEER: Mr Read, those are my questions. Thank you very

much for answering them.
Sir, we've now got questions from four Core
Participants, starting with Mr Stein for about an hour,
then Mr Moloney for about 45 minutes, then questions by
Ms Allan for about ten minutes and then questions on
behalf of the NFSP for about 15 minutes.
So over to Mr Stein, for about an hour.

SIR WYN WILLIAMS: When you say for about an hour, we've

been going about three-quarters of an hour, so that
would be a fairly long session. Can we just confirm
that the transcriber is happy with that or will Mr Stein
need to take a break at some point?

MR BEER: I have already spoken to Mr Stein about it and

said that he should take a break at 11.30 or about 11.30

when a convenient moment arises so that the shorthand
30

partner's time in supporting postmasters.

And it includes importantly the families of those
people, who, although we don't, in a legal sense
represent, we support and we try and we speak to
whenever we can.

This is a large group of people, a broad church of
people; do you understand that?
I understand,
The final small group of people we represent are current
postmasters.

So that is the direction of travel that we take, in
relation to the questions I am asking you today,
Mr Read

Mr Read, shortfall money: where has the money gone,
Mr Read?
‘As you've heard in this Inquiry on a number of
occasions, there have been external forensic accountants
looking at this particular problem, trying to assess
what it is that has gone and where it has gone to. The
current piece of work on this topic has identified
a figure somewhere in the region of £36 million between
1999 and 2015,

The work itself was conducted mainly on
an assessment of the HSS and the OC schemes, in terms of

who has projected what by way of losses. The challenge,
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of course, is that monies that have been repaid into or
through suspense accounts, and the like, could easily
have been customer money, client money, as opposed to
necessarily specifically Post Office money, and so the
proportion that goes straight to the bottom line, for

want of a better word, within the Post Office, can be

quite obscured.

I guess what I'm trying to say is we think we have
got a figure of somewhere in the region of £36 milion
spread across those years. I don't think it is as
definitive as we would like it to be. I think the fact
that it is known as Project Boland within the Post
Office, I think KPMG were the last forensic accountants
to look at this problem.

You'll be fully aware that data going back a number
of years is extremely difficult in the Post Office to
identify very often, and that is our best endeavour, in
terms of where we've got to. As I understand, it is
going to be reviewed again but it is a frustration and
I appreciate it's a frustration. We've the talked about
this topic at the Inquiry on a number of occasions.
You're right, Mr Read. I've raised this time and time
again -

Indeed

-- witness after witness. I asked Mr Cameron on 17 May
33

clearly by definition, people have paid in losses
themselves and have not alerted the Post Office. We
don't have the level of data that goes back or the
accuracy of the data that goes back and, as everybody is
fully aware, that is a great frustration and, as I say,

this is predominantly based upon what victims of the
scandal have told us through the HSS, and indeed through
the OC, and our attempt to try and understand from that
mechanism. It isn't satisfactory.

Mr Read, the shortfalls and the paying off of shortfalls
continues. You know that the YouGov report that was
commissioned by the Inquiry has received consultation
responses, demonstrating that people are still paying

off shortfalls; do you understand that?

It's very frustrating that people feel —

Do you understand that, Mr Read? It's not about your
frustration. Do you know that to yourself?

I'm aware that people are paying for shortfalls. We've
made it very clear that the Review and Dispute button
and the Branch Support Centre will help individuals to
understand where discrepancies have occurred and, as

I said yesterday on a number of occasions, we are not
forcing individuals. There is a presumption of

innocence and it's really important that that message

lands.
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2024 the very question I asked you: where has the money
gone?
Yes.
I got told by Mr Cameron, after a number of other
questions, "Well, I think, you know, ask Nick Read.
He's the CEO". He said, "I mean, I'm not saying that
he's the one who's going to do the work but he’s the one
that can marshal the resources and make it a priority
and ascertain if itis possible at this time of day", he
said, "to go back as far to 2005 or indeed before”.

So these efforts to track down this money that
Sir Anthony Hooper, Sir Alan Bates, Kay Linnell -
Dr Linnell -- Second Sight, have been going on about for
‘so many years over the decades, when did they first
achieve a priority within the Post Office?
Trying to identify where the funds were, this project
has been running for some time and Mr Cameron is very
aware of it as well, under his tenure as the CFO,
clearly it fell within his remit. We reignited those in
light of the conversation that you had with Alisdair in
May and that's why the Project Boland has been
reignited.

We've been immensely frustrated. We've all been
frustrated that there isn't a simple answer to this.

question. It's an extremely complex issue because,
34

We have struggled to engage more broadly and
communicate more broadly with many postmasters, as we
discussed yesterday, going through the YouGov survey.
But I'm very, very clear, and you can hear it from me in
this forum, that we are not enforcing people to make
good losses. We are suggesting that, where there is
an issue that they do not understand, we help them to
try and understand and, if we can't understand, then we
move on.
Currently, when a subpostmaster pays off a shortfall, is
it investigated? Now, be careful about the answer to
this. There's the Dispute button, yes?
There is a Review and Dispute button
Right, if somebody presses the Dispute button, or Review
and Dispute button, then it seems that the current
policies mean there is an investigation; do you agree?
When you press the Review and Dispute button, it goes
through to the Branch Support Centre and we try and work
out with the postmaster what is the issue.
Right, so the answer is actually yes, you could have
done that with a "Yes"

Okay, next one. When a subpostmaster calls the
helpline and says, "Look, I'm having a problem with the
account, I'm trying to balance, and there seems to be

a discrepancy’, is that investigated? Yes, or no, if
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you can please, Mr Read?
Yes, itis.
Right. Let's look at the other type of shortfall, then.
‘So where someone does not press the Review and Dispute
button, where someone does not phone the helpline, for
whatever reason, is that investigated? So a shortfall
that is paid off by a subpostmaster which is not the
subject of pressing the button and not the subject of
calling the helpline, is that investigated?
If it isn’t brought to the attention of the Branch
Support Centre then it won't be investigated because we
would be unaware of what had occurred —
Now --
-- unless I'm misunderstanding you.
--a system within a branch —

Forgive me, Mr Read, you finish.
Unless I'm misunderstanding you, we would have to have
the discrepancy or the loss brought to our attention for
us to be able to investigate it. If people are still
paying in because they have done a branch -- done an end
of day, end of week, or a trading period reconciliation
and found that they've got cash and stock that doesn't
match what's on the Horizon, and they determine that
they want to pay that money in, then it's very

difficult, I think, as my understanding goes, for the
37

discrepancies that occur, and we start to address them
by theme, so that those that are occurring more
regularly — and we discussed this yesterday, in terms
of moving keys or the like ~ we address.

Let's go back a couple of minutes into your evidence.
You agree that if the situation is that someone within

a branch pays off a shortfall that they don't bring to

the attention of the wider Post Office, maybe because
they're afraid to do so, maybe it's because the history
of this very scandal has affected them so that they

don't feel they can, or maybe it is because it's

a smallish amount of money and they just want to keep
trading without interruption, maybe for any one of those
reasons that they don't bring it that way to the

attention of the Post Office, the Post Office could be
monitoring this but isn't; do you agree?

No, I don't. I don't really understand your point
because we're very clear that, if you have a discrepancy

and you don't understand the genesis of that
discrepancy, then you must ring the Branch Support
Centre, you must press the Review and Dispute button and
we will help to understand why that is the case.

I'm very clear that it's a presumption of innocence
here and we will get on and support people and we are

doing considerably different work to understand the root
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Post Office to be aware of that particular situation
When individuals within a branch account find they have
a shortfall, they're doing so based upon the data that
they have, which is also on the Horizon system; do you
agree?

Yes, that's correct.

Right. So is it possible for the Post Office to start
looking at shortfalls that occur within branches that

are then paid off? What I mean is this: individuals who
are currently paying off discrepancies that they find,

that you know about through the YouGov report, at least,
that is still happening. Why doesn't the Post Office
actually start to analyse the shortfalls that are

‘occurring on their accounts?

Well, we have a discrepancy report and shortfall report.
Every single investigation that now occurs into

a shortfall and/or a discrepancy is recorded. So we
have an impact ~ a branch impact -- sort of, programme,
I think it’s called BIP, which identifies all the

shortfalls and identifies all the discrepancies, so that
that database is available for anybody in the Branch
Support Centre or anybody in the Support and
Reconciliation Centre to look into to see if there is

a commonality or a theme.

And what we do is obviously we look at the range of
38

cause of the issues and make sure we fix them, so I ~
Mr Read that's ~

Maybe we're at different ~ at cross purposes here.

No, I don't think we are, Mr Read. That's the corporate
message you're spouting. The corporate message is,
“Were trying to change, we're trying to be different

from what we used to be, we're trying not to browbeat
the subpostmasters, we're hoping we are not prosecuting
anybody"; those are the messages you're essentially
trying to get out, okay? But itis clear from the

YouGov report that particularly long-term subpostmasters
are still paying off shortfalls. You know that, don't

you, Mr Read?

I would be very concerned if people were paying off
shortfalls that they felt were not as a consequence of

an action that may have taken -

What do you mean concerned, Mr Read? That is
essentially what the YouGov report has identified: that
people are still paying off shortfalls themselves. It's

not just a concern: this is happening. Do you dispute
that, Mr Read?

No, I don't dispute it.

Right

They need to, as I've mentioned before, get in touch

with the Branch Support Centre if they believe that the
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discrepancies that are being generated in branch bear no
relation to activity that they have been deployed in.

Q. Look at it from the subpostmaster point of view.

Yes.

Q._I'llturn at the end of my questions to what has

happened through your visits as part of reparations, as

part of meeting people that have been affected by the

scandal. You I know have gone on those visits and you

have done that and you have shown empathy, yes?

Yes.

>

And they have affected you —
Very much so
- we can see that.

- yes.
You know that the long history of this scandal --

Yes.

has affected people working in brands currently, yes?
I agree.

You're essentially saying, "We're trying to change and
we're trying to get that information across"?

pPrPOPOPrPO POP

Yes.

oP

You understand that the YouGov report is highlighting
the fact that people are still paying off using their
own money ~

A. Ido.
41

some of the post masters who have had long service within
the Post Office, for perhaps some of the reasons you've
described, which is the level of trauma and the level of
mistrust. That is of great concern to me and that is
something that we need to address.

Q._I'm going to turn to a document that is called one of
the Postmaster Support Policies, of which there are
many, and it's the Postmaster Account Support document,
POL00448000. Now, Mr Read, you may have some
familiarity with these documents. On the original
they're bright red, as they come on to the screen they
appear to be rather dark —

A. Right.

Q. —and we can see this one is version 4.0. In fact,
there's a slightly later version but they don't appear
to differ. This one is postmaster support policy,
Postmaster Account support. Can we go, please, to
page 8 of this document.

Sir, for your assistance, these are documents from

this year, 2024.

SIR WYN WILLIAMS: Yes.

MR STEIN: If you scroll down to on that page, I think the
title is "The risk", which is paragraph 2.5. If we read
through that:

“Post Office can recover losses from a postmaster
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~ and perhaps there's a trend towards it being the
longer-term subpostmasters?

I think that's fair,

So you understand that the message that you've been
trying to get across, perhaps it's not been received,
perhaps it's not even welcome, that the message is

a difficult one to get across?

Yes, and that was very much what I said yesterday: that,
we are struggling to engage with the longer-term
postmasters, for the reasons that I think that you have
articulated very clearly.

Mr Read, how much longer have you got at the Post
Office?

To the end of March.

End of March. It's clear, I think you'll agree, that
there's work to be done in this area of shortfalls?

I would agree with that.

Will you rededicate your remaining period of time, not
exclusively, but at least a part of it, to working on

the shortfalls, to making sure that people know and
understand that they don't have to pay it off, that,
there is a way of sorting it out without having to use
their own money; will you do that?

I will certainly do that. More importantly, and I think

what, even more importantly is, we're just not reaching
42

when such losses are caused through negligence,
carelessness or error and Post Office has carried out
a reasonable and fair investigation, as set out in the
Postmaster Accounting Dispute Resolution policy, as to
the cause and reason for the loss and whether it was
properly attributed to the postmaster. Postmasters are
also responsible for losses caused by their assistants.”
Let's start with the last sentence. That seems to
be an echo of the past, with postmasters being asked to
account for the losses caused by their assistants; is
that quite right?
I think it needs further clarity, in terms of what does
that specifically mean. I think what we — my
interpretation of this is that the postmaster must be
responsible, obviously, for the assistant, the level of
training, the level of responsibility and the conduct of
the individual. I think the inference here is not quite
appropriate.
No.
Itneeds tightening.
Itneeds a bit of work, you might say, Mr Read. The
starting point of this part at 2.5 is:
"Post Office can recover losses from a postmaster,
when such losses are caused through negligence,

carelessness or error...”
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So the system is still saying to subpostmasters that
what can happen is that we may pursue you for losses.
The tenor of your evidence yesterday was that perhaps we
don't do that. What do you think about this policy?
Well, I think, as we said yesterday, one of the first
things that we need to do is make sure that negligence,
careless and/or error is described very clearly as in
what does it mean? So, as an example, negligence might
be leaving the safe door open during the middle of
trading in a busy branch. As an example, that could be
considered or deemed negligent.

But I think it needs a lot more clarity in terms of
what is it that these statements actually mean, and how
and who is interpreting them, and what are the
implications of those interpretations? So I think ~
I think - or I'd agree with you, in that sense, that
there's more work to be done.
I asked a whole series of questions this morning about
shortfalls and people paying them off, what may be the
cause of it. It's this type of messaging which says
that "We may still go after you", that still exists this
year within the Post Office. It doesn't exactly help,
does it, Mr Read?

The tone is inappropriate.

I'll go to a different document, please. This is
45

Okay,
It should come up as "Repudiatory breach” ~- right okay,
4.5, "Immediate termination”. In fact, on the document
I've got, which is slightly later it's called

"Repudiatory breach”, okay. So 4.5, "Immediate
termination":

“Post Office may only terminate a contract
immediately without notice where ...”

Then 4.6, and then further down, please. So 4.6, so
this is about immediate termination, okay, and these are
the sorts of breaches that can cause immediate
termination. 4.6, fifth bullet point down:

“Where discrepancies of a significant value have
been caused by the negligence, carelessness or error of,
the postmaster, resulting in a loss to Post Office, and
which have been fully investigated by Post Office.”

Okay?

Mr Read, my suggestion is that if we follow through
the documents that are in existence, that are live
today, that essentially the same message is going out,
even to the point of essentially saying, "You might be
sacked without notice"?

Well, I think a couple of points on that. What I'm
very, very clear about is there is no — and there is no

termination without the Dispute Resolution Committee,
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a document which is another Postmaster Support Policy.
Sir, there are quite a few of these.
This one is “Contract termination", and the
reference is POL00448206.

SIR WYN WILLIAMS: Are all these documents 2024, Mr Stein?

MR STEIN: They are, sir. I can show the dates on these
things.

SIR WYN WILLIAMS: No, I will assume they are all 2024
unless you tell me otherwise.

MR STEIN: That's right, sir. You might at some stage ask
the Inquiry Team for copies of these but they are
changing so frequently, to be fair to the Post Office,
that it's difficult to identify the ones. The ones that
I've got, in fact, are slightly later ones than the ones
that I can find on Relativity.

THE WITNESS: Just for a point of help, the Postmaster
Support Policies, I think there are 12 in total, they go
through a yearly cycle of review and revision. The Risk
and Compliance Committee and the Board committee, which
is the ARC committee, which is - upon which actually
postmasters sit, so Postmaster Non-Executives sits on
that committee, in terms of Elliot Jacobs in
particular —

Q_ Can we go to paragraph 4.5, please. I'm conscious,

Mr Read, obviously of time. That's all
46

which -- upon which sit two ex-postmasters, one of which
is the Chair of that committee, that oversees whether or
not we can dismiss or can close down an individual post
office or postmaster. So we've been very explicit that
we do have an independent postmaster or ex-postmaster
who sits on that committee.

@._ Your understanding, though, from my questions, is,
I believe, that you accept that there's work that needs
to be done, the tenor of these documents is still
saying, essentially, "We may go after you if we find
that there are losses to the Post Office through Horizon
shortfalls". That's still a message that's out there,
Mr Read. Do you accept that this needs, perhaps, at the
very least, a bit of rework?

A. I think there is some rework that needs to be done. We
can agree on that, Mr Stein.

Q._ We know that, in relation to shortfalls, and I quote
here from the statement of Melanie Park -- for those
that wish to make a note, it's paragraph 97, page 46 of
her statement. Her statement for anyone's notetaking
purposes is WITN11600100. I do not need to go to the
document.

Ms Park, who will be giving later in this Inquiry,

says:

“However a branch is prevented from completing the
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trading period end process and moving into the
subsequent trading period if it has not actioned all
transaction corrections, either by accepting them or
using the R&D function in Horizon and/or has a balance
remaining in the local suspense account.”

Now, as I understand it, what Ms Park is going to be
telling us, therefore, is that unless you sort out the
shortfalls, you can't keep on going.

No, she's not going to tell you that.

Okay. We'll ask her those questions.

Yes, you can.

All right. One of the contractual requirements ~ and

if we need to, we can go to it in the policy

documents —-is that the branches, the subpostmasters,
comply with visits from the Branch Assurance Team?
That's correct.

Ms Park says about that, paragraph 55 this time:

“I would also like to make clear that no member of
any team that might ultimately investigate a discrepancy
arising from a Branch Assurance Visit will be present
during the Branch Assurance Visit.”

Okay?

Mm.
Shall I repeat that?

Yes, please.
49

today that again need work, which appear to be saying,
“Look”, to the subpostmasters, "we may still go after
you for losses", yes?

(The witness nodded)

Again, all needs work?

Yes, we've got more to do. There's always work to be
done.

From the subpostmaster point of view, it might be said
that whatever you call the Branch Assurance Team, you
could call them the "Butterfly Club", Mr Read, it would
still be seen as being part of an investigation by the
Post Office into shortfalls that may lead to their
contract being terminated. That is the message that
comes across if you look at the system, Mr Read, and
that's the message which I think you're saying you don't
in fact want to come across to subpostmasters?

I certainly don't want that message to come across to
subpostmasters. I'm also very clear that the Branch
Assurance Team do one thing and one thing only: and
that's basically a stock check. They will count the
stock and they will count the funds. They won't do
anything else. They won't investigate anything. They
have no accountabilities, they have no job role
associated with anything other than a cash and stock

check. If we haven't made that clear for folk then we
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Irather mangled it. She's saying this:

"I would also like to make clear that no member of
any team that might ultimately investigate a discrepancy
arising from a Branch Assurance Visit will be present
during the Branch Assurance Visit."

Of course?
That's correct.
So she's talking about, essentially, separation of
teams?
She is.
So let's add this all up together. We've got
subpostmasters who are subject to a contractual
requirement to cooperate with visits from the Branch
Assurance Team, yes?
That's correct.
The Branch Assurance Team may refer matters to
an Investigation Team within the Post Office?
Yes, to the Branch Support and Reconciliation Team.
Mr Beer yesterday asked a number of questions about the
contract and about whether the terms used within that
contract, "Investigation Teams", was appropriate, and
you said yesterday, again, that needs work; you agree
and you recall that?
Ido recall that, yes.

Then we have the policies that we've been looking at
50

need to be much clearer in doing so.

The other point, I think, that is important to make
is the presumption of innocence still pervades, and that
is really very important. We are here to try and
resolve discrepancies, not to insist upon people making
them up, if they believe that not to be the case.

And you touched on the importance of not being able
to trade or move into the next trading period. If the
Review and Dispute button is pressed, if there's any
disagreement or misalignment associated with
a discrepancy, then it gets placed into, effectively,

a local suspense account, and you move on, and you
trade, and you trade the following week, and you trade
the following week after that. And we will then try and
resolve what the issue is and, if we can't resolve it,

then we have a dispute process that we can go through.
But we are not at any stage forcing people to make good
losses that they do not agree with.

Now, we may well have more to do in terms of our
engagement and communication, we've talked about that,
and I would agree that we still have pockets of
postmasters who are deeply, deeply troubled by what has
occurred historically and we need to address that.
"Pockets" may be a slight understatement, Mr Read.

Looking at the figures you get through the YouGov
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report, you've got significant numbers of people that
are still doing this, they may be doing it in £10, £20,
£50 or £100 but they're still doing it —

A. (The witness nodded)

Q. ~and those £10, £20, £50 adds up to millions, as you
accept, over the years?

A. Absolutely, it does.

Q._ Your figure of 36 million is growing, Mr Read.

Now, my time has been set. I've asked Mr Jacobs to

give me a note to say itis break time and it now is
break time,

A. Okay.

MR STEIN: Fifteen minutes, please, sir

SIR WYN WILLIAMS: All ight, certainly. So we resume at
11.30, yes?

MR STEIN: Thank you, sir.

SIR WYN WILLIAMS: Fine.

(11.16 am)
(A short break)
(11.31 am)
MR BEER: I think Mr Stein will notice that the Chairman has
reappeared

MR STEIN: I thank Mr Beer for pointing that out
Mr Read, the background to this Inquiry, the

background to the scandal, it's all been about the
53

“it should not be relying on Horizon data as the
basis for such shortfall enforcement."
Okay?
Now, you went through this correspondence with
Mr Beer, and I won't redo that. So we know that there
was further communication between yourself and
Mr Patterson, all right. We know that Mr Railton gave
evidence and says that he’s going to take up this
particular cudgel or this particular stream of
correspondence with Mr Patterson and he's going to
attempt to deal with it as well, all right?
A. (The witness nodded)
Q. Okay. You'll recall that yesterday Mr Beer was asking
you questions about a meeting of the SEG, that's the
Strategic Executive Group. That was a meeting on
Wednesday, 26 June 2024, starting at 11.00 am, and it
was a discussion document put forward by Ms Gray and
Mr Bartlett, which was disclosure to support police
investigations.
Yes.
Do you recall that?
1 do recall that.

prop

Now, let's ask the specific question: had you, by
26 June 2024, disclosed to Ms Gray and Mr Bartlett the

correspondence that you received from Mr Patterson on
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withholding by the Post Office of information that would
have assisted subpostmasters, that would have assisted
people that were being investigated, that would have
assisted people that were going through the criminal
courts or the civil courts or through audits, that's the
background; do you understand that ~

Yes, of course.

— from —-if I call them the Fraser judgments —

Yes.

— I hope Lord Justice Fraser will forgive me.

Yes.

Have you ever kept back information that would assist in
the investigation of matters, either through the

criminal courts or through audits?

No.

No? Because you no doubt understand the ramifications
of doing such?

That's correct.

Yet we know that Mr Patterson wrote a letter.

Mr Patterson, I think, who is the European Director of
Fujitsu, worldwide company, wrote a letter on 17 May
this year saying that Fujitsu will not support any

pursuit of any enforcement action, civil or criminal,
against subpostmasters. It was a pretty clear letter,

finishing with the line:
54

17 May 2024?

Yes, she was aware of it, yes.

Had it gone to the Board?

I said yesterday, it was discussed with Mr Tidswell, who
was the Acting Chair at the time, and with Lorna

Gratton, who was ~ as you know, is the shareholder
representative. I don't think the full Board had seen

it. It was, as I say at the time, it was correspondence
between two CEOs, as opposed to a board level decision
Now, Mr Railton gave evidence saying that he had seen
this correspondence as part of his pack, his evidence
pack, before giving evidence. He clearly hadn't seen
this document and this correspondence that you'd had
with Mr Patterson at Fujitsu. How come the new Chair of
Post Office hadn't been told about the correspondence
with Mr Patterson where the Fujitsu company supporting,
creating, essentially, and running the Horizon system is
saying, "Don't use our data"? How come that hadn't got,
to Mr Railton?

I don't think we saw the engagement with Mr Patterson in
quite the same way as you have, and I think the point
that I was trying to explain to Mr Beer and to Sir Wyn
was that this was more of a spat than anything else.

I don't believe that it was the degree that you're

suggesting here and now. I think we were quite
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affronted, obviously, by the communication that we
received from Mr Patterson, and that was something that
Owen Woodley and Neil Brocklehurst have continued to
take on over the summer.

That's not actually the answer to my question. How come
Mr Railton hadn't seen the document until he had it from
the Inquiry in his evidence pack before he gave
evidence?

don't know.

Because Mr Railton's evidence, by that point, is that

he's coming in, he's suggesting that there's going to be

a tumaround of this particular ship and it's going to

be to rework the entire Post Office in relation to the
questions that concer subpostmasters, a good phrase he
used, he's going to reverse the polarity ~

Yes.

-- of the Post Office, so it's subpostmaster centric

rather than the other way round, rather than executive
centric, is the way I understand it. He's also looking

into the question of the Horizon system and whether NBIT
should go ahead, whether it should be replaced. It
seems that it should have been information that should
have gone to Mr Railton, and you don't know how it was
missed?

Quite possibly.
57

King's Counsel? I don't ask for what the content of
that advice was, I ask you whether you went to her,

Ms Gallafent; Nicola Greany, King's Counsel; Simon
Baker, King's Counsel. They are all King’s Counsel
instructed by the Post Office and dealing with different
aspects of this Inquiry. Did you go to them and say,

“I've had this letter from Mr Patterson at Fujitsu, it
concems me about disclosure, what should we do with
it’, or something similar?

I don't know whether the email trails have been

disclosed in their entirety, but they may well have been
and, therefore, what guidance that General Counsel took,
I can't tell you that.

When you get to the June meeting, the June meeting which
is the SEG meeting, which is a meeting that is

discussing the question of disclosure to support police
investigations, when a document has been put forward in
relation to that, did you or anyone around you, say to
themselves, "We'd better have a word with those police
investigations and make sure that they're aware of this
correspondence"?

No, I don't believe we did that. I think,

I go back to my question. Have you been involved in the
withholding of information that may be relevant to

investigations that are ongoing?
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Now, you've explained in one of your answers just given
that, well, you thought this was a bit of a spat, that
was your word, a spat between, and you go on to say,
however it came about, maybe between two CEOs. Did you,
regarding that correspondence, take advice from

a criminal lawyer?

I took advice from my General Counsel, and ~

That's not the answer to my question, unless General
Counsel turns out to be a criminal lawyer.

It could possibly be that her training is in criminal

law, I'm not sure.

Right. Did you purposefully decide, "Well, this is
something that has a relevance to investigations, this
is something that may be important to what's going on
with the police", which you're learning about through
the SEG meeting on 26 June?

Mm.

Did you decide, "I'd better run this by a criminal
lawyer"?

No, I didn't decide that at all. I decided that I would
take the guidance of my Interim Chair, who is a lawyer,
and also the General Counsel and the shareholder
representative, and describe what it was that I was
communicating with Mr Patterson because ~

Did you take advice on this document from Ms Gallafent,
58

No, I haven't
Well, it seems that the answer is a "Yes, Mr Stein,
Ihave",

Well, I don't believe that to be the case, Mr Stein

Now, there are things called entrustment requirements
that are set by the Government in relation to the
operation of the Post Office, you agree?

Services of general economic interest.

So the Post Office has a wider community service aspect
that is the subject of extra funding from Government?
Very much so.

Just describing one of those, by way of example:
nationally, 99 per cent of the UK population to be
within 3 miles and 90 per cent of the population to be
within 1 mile of their nearest post office outlet. Yes?
That sounds correct

So using those as my example in relation to the
requirements set, we know there is, if you like, this
outreach by the Post Office that is directed into
‘communities, whereby it might not be economically
sensible to open up a post office if you want to make
money.

That's correct.

The Government provides, essentially, compensation,

which I think is the word used, to the Post Office, to
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allow the support for such branches; do you agree?
The expression I used was "subsidy"
Fine. Now, in your statement, you refer to a review by
the Government to undertake a review of its policy for
the Post Office, and you refer to a letter from
Mr Kwarteng, a Member of Parliament -- I can't remember
whether he's still elected or not ~ who was then the
Secretary of State for BEIS, dated 11 March 2022. Can
we go to that letter, please, it is POLO0448435,
Thank you. We see the date of this letter. We see
who it is from, Secretary of State for Business, as it
was then called, and we see the recipients, it's you and
Mr Parker, the date is 11 March '22. Now, some of this
letter, in fact, confirms the commitment to the
requirements, essentially that the Government is asking
the Post Office to continue to commit to those
requirements, all right?
To the SGEls, yes.
I'm very grateful. So the particular part I'd like to
refer to, then, is not so much that, but at the bottom
of page 2 and top of page 3, please. Thank you.
Keeping in our minds the date 11 March 2022, we've got
this, "Future policy framework for the Post Office”
“Finally, I recognise the need to consider the

policy framework in the context of the changes to the
61

this policy review on the back of a strategic review
that we did ourselves in 2019/2020. So I'm not entirely
clear on your point other than, as I made the point
yesterday, the policy team within the Department has
been very focused on compensation. I think it would be
fair to say that their resources have been split between
doing compensation and initiating a policy review. I'm
as frustrated as anyone that we don't have a policy
review from the Government that we can build around
and --
Mr Read, you may get the direction of my travel wrong
It's not an attack upon the Post Office necessarily.

Why has it taken so long for the Government to
actually start thinking about the strategic direction o
Post Office, in terms of the way that Mr Railton was
talking about, the funding commitment, the long-term
funding commitment; why has it taken Government so long
to wake up?
I think you'll need to address those questions to
Government.
Mr Read, you have been in post now for five years?
Yes.
Tell us what you think has been happening with
Government. Why has there been a Government failure to

essentially support the subpostmasters to make sure that
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wider environment and the new challenges you face, on
top of Covid-19, and ongoing work to resolve historical
matters. Itis crucial we develop a sustainable,
long-term approach for the network, and I look forward
to working with you on this review."

Okay?
Yes.
Now, that appears to be, from what I understand, the
review you're referring to in your statement, which was
requested by the Post Office.
Looks like it, yes.
Yes, it does. We're now getting close to the end of
2024 and we learn from Mr Railton that the Post Office
is, in fact, saying to the Government, "Look,
Government, Post Office needs your long-term commitment
for long-term support. It needs money to be able to
provide a new system, IT system, to continue operation"
That's happening now. That seems to be all Mr Railton
is saying since he’s come in.

Why has it taken so long, Mr Read, for anyone to
think about the result of this sort of review back in
22; why has it taken so long, Mr Read?
I'm not entirely sure I'm clear with your point. The
Government's policy review is for the Government to

initiate. We pushed the Government in ‘21 to initiate
62

they understand that there is a long-term life for the
Post Office; why didn't you sell it that off to Amazon,
as Sir Alan suggests?
I think, looking back to the comments that Henry
Staunton made when he was in front of this Inquiry,
there was — and there was a determination to get
through to the election and then, from the election, to
reset the Post Office. And I think that was certainly
the direction of travel that was indicated by the
Permanent Secretary 18 months ago. So I think that is
probably the underlying driver behind this.

1am very confident that Mr Railton’s enthusiasm and
sense of purpose is going to drive the Government hard
on this, and he made that point very clearly earlier in
the week, and I fully expect that the Government will
obviously get hold of the Strategic Review and I hope
that they will dovetail that in, as we discussed
yesterday, to their own policy review and that we come
up with a sustainable strategy, long-term sustainable
strategy, for the Post Office

Mr Railton implied on Tuesday that that would be in
the next two or three weeks, that the Department would
respond to that and I look forward to —
You see that evidence from Mr Railton was remarkably

tight to the timing of his evidence and indeed yours.
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So it seems that just before he was giving evidence that
something was done. Was it a letter that was sent to
Government saying that we need a commitment from
Government to fuller funding? Who compiled the document
that was sent to Government: was it another
organisation; was it the Post Office working with

another organisation; where did this impetus come from,
just before giving evidence by Mr Railton?

Mr Railton has been very clear that the terms of taking

on the chairmanship of the Post Office was that we would
do a strategic review. He was very clear about that and
that was part and parcel with his signing up to be

Interim Chairman. As a consequence of that commitment
from the Government, he engaged with Teneo to do a full
Strategic Review of the organisation, they said it would
take four months. The conclusion of that four months is,
literally about now, so the timing is not unique, in

that sense. It's exactly what was laid out in the Teneo
work that started back in June.

So the timing and the question of the timing relates to

Mr Railton's appointment?

Correct.

Since he's come in, he’s provided that extra impetus,
essentially to rattle the Government cage, to say what's

going on for the future of the Post Office?
65

of such documents. It is important that people working
within an organisation do, in fact, respect each other
and do trust each other, these are fundamental to any
organisation. But one of the matters that was marked
out, and I asked questions of Ms McEwan about these
documents, they don't mention subpostmasters. There
were two documents I asked her about, the People Plan
and then the Behaviours Plan, clearly directed at
internal employees.

How come under your watch, Mr Read, that there'd
been the production of these sorts of documents that
don't refer to subpostmasters in the way that frankly
you would expect after all of this scandal; how come,

Mr Read?

I think, as Ms McEwan referenced, you were talking
specifically about behaviours and about the importance
of how the Post Office internally transformed its
behaviours, and I think that was ~ and remains --

a very valid and important part of the work that we need
to do to develop our ways of working and to develop our
behaviours. The explicit reference or explicit

inclusion of the postmasters, I can understand the
concem -- if that's the right word -- of you and your
clients. The objective of the People Plan, the

Strategic People Plan, was very much to shift the
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Yes.

What you can't say is why it's taken so long for the
Government to actually come up with anything itself to
guarantee the long-term work of the Post Office; you
don't know the answer to that?

Well, as I say, I think the policy team has been very
focused on driving compensation and that is why they
have not taken the policy review forward in the way that,
I'd articulated yesterday and the day before, which was
the first time we would have had a policy review since
2010.

Right. Well, we've got some Government witnesses coming
along, and past ministers --

Indeed.

~ so I look forward to asking them questions about

that,

Now, we've had various references to strategic
plans, we've had various references to Chief People
Officers and to reviews that relate to outside
organisations drafting up something that comes back with
corporate speak saying that everyone needs to be nice to
each other and everyone needs to remember that there are
other people working in a collegiate way within the
organisation.

Now, I don't in any way seek to undermine the value
66

culture internally, such that it was supporting
postmasters.

It isn't our place to -- and certainly isn't my
place ~ to instruct postmasters on how we behave.
I think it is our place to communicate to postmasters
what we're trying to achieve and that's what we will be
doing through our behaviours documents and through our
ways of working documents.
Ihave asked you questions about shortfalls, about the
policy questions.
Yes.
You agree that they need review.
(The witness nodded)
I'm now asking you questions about these sorts of people
plans and the fact that they miss out references to
subpostmasters.
(The witness nodded)
There still appears to be a trend within the Post Office
to miss out subpostmasters as being a group that the
Post Office is, in fact, dedicated towards. Will you
again, in the remaining months of your period of time at
the Post Office, review these sorts of documents, ask
the people within the Post Office "Why aren't we
referring to subpostmasters where we should be?" Again,

will you deal with that?
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I will
Thank you,

Now, Mr Railton’s evidence was something that was
set out so that we understand and we await the result of
the review and the discussions with Government, whereby
there's going to be this recommitment, rededication of
the Post Office towards subpostmasters. We have
messages from people we represent who are current
subpostmasters to say that they're not feeling the love,
Mr Read. Let me read one:

“As a person who is still working behind the Post
Office Counter, acting postmaster at the same branch,
that broke me as an individual. We have had no sight of
any increase but only decrease to say that if we do not
meet certain targets on services we will lose them.
That's all we've had. I'd be extremely concerned of
what the Post Office has to offer in this new strategy
[the one that's being discussed with Mr Railton], as I'm
sure it's any going to be in benefit for Post Office
Limited and the staff that actually work for Post
Office, rather than people on the actual ground who earn
them the money and pay their wages while we get the
crumbs."

The message goes on to say:

“I'd definitely push for this plan to have been seen
69

three days.
I don't recognise your closing of branches notion.

I's not something that we have been doing recently, so

I don't follow that particular train of thought. We're

not seeing churn numbers as dramatic as might be implied

and, indeed, the stability of the network and the desire

of people to open branches is frankly, given the last

nine months, surprisingly robust.

Notwithstanding what you're saying, Nigel's
commitment to a new deal for postmasters, his words,
polarity, I think we've tried, and this is the next
phase of that. We have been engaging, and I know that
Nigel made that point with the NFSP and with the Voice
of the Postmaster, and with other postmaster groups, to
discuss the issues that they think need to be addressed,
so that we can bring those into our Strategic Review and
that's absolutely what has been done and is ongoing.

Mr Read, what it appears to be is that there is

a considerable and too far distance between the office
of the CEO, probably the Board as well, and the
individual subpostmasters working perhaps in small
branches in small or low density population areas.

That's what it appears to be, that this message that you
keep on wanting to say ~ I understand why and must get

out — it is not getting out. We've seen that from the
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before Government agree, as these people are only pencil
pushers sitting behind a desk with a massive income.
They have no idea of the struggles we have on the
ground."

So people in branches are not feeling the love,
Mr Read

There are still plans -- as we learnt from the
current Chair of the NFSP, the West Linton branch ~ to
close these Hard to Place branches.

Surely, if there is this root and branch review that
is ongoing to discuss the future of the Post Office,
with a change of polarity for the Post Office to
recentre itself towards subpostmasters, surely all of
these closures, these branch closures, should stop?
Surely there should be a moratorium on actions taken in
relation to subpostmasters? Draw a line, Mr Read, to
say, “If we're going to be changing, let's make sure
that the subpostmasters understand there's going to be
a change", what do you think, Mr Read?
Well, I think Mr Railton made it very clear yesterday —
sorry, on Tuesday -- that at the core of the Strategic
Review is the relationship with postmasters but a new
deal, I think, was the expression he used, for
postmasters, and a new deal is absolutely central to

moving forward. We've talked about that over the last
70

YouGov report, we see it from such correspondence.
You need to close that distance. You need to make

to sure that the communication is effective; do you

accept that?

Well, as I said, we do need to get closer to it

Let me turn, then, to the schemes, the compensation

schemes. I'm just going to describe what they are to

make sure that we've got the sheer number of them.
There is the Group Litigation scheme, the GLO

scheme. That one is run by the Department for Business

and Trade. There is the Horizon Convictions Redress

Scheme, which the Department for Business and Trade is

also administering, which deals with redress for people

whose criminal convictions are overturned by

legislation. Yes?

Correct.

There is the Overturned Convictions Scheme ~ the Post

Office runs this one -- dealing with redress for people

whose Horizon-related criminal convictions have been

overturned by the courts, yes?

That's correct.

There is the Horizon Shortfall Scheme -- Post Office is

administering that one -- administering the Horizon

shortfalls. That was established in 2020 to provide

redress for postmasters who were not claimants in the
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Group Litigation?
That's correct.

Okay. So two schemes being run by the Department of
Business and Trade and two being run by the Post Office?
That's correct.

Okay. In addition to that, we also have a Suspension
Remuneration Review being run by the Post Office, yes?
Yes, that's correct,

That's for individuals who have been essentially
highlighted by Lord Justice Fraser's judgments, those
people that have been suspended whilst investigations
were carried on and its redress being considered in
relation to those suspensions; is that correct?

That's correct.

There is also an Adequacy of Payments under the
Shortfall Scheme, a review of the shortfall scheme
payments, because it is being considered that some
payments were inadequate; do you agree?

That's correct.

Then, unless you're going to tell me there's another

one, there is a Stamp Compensation Scheme that is
ongoing as well; is that correct?

That's correct.

So the evidence in relation to stamps was given,

I think, by the NEDs in part. That was because another
73

reason he has been given, and I quote, is:

“.. evidential uncertainty as a result of gaps
within the supporting evidence provided.”

Okay?

Now, in the questions being asked yesterday by
Mr Beer, he took you to a document whereby one of the
ministers at the department was concemed about the
question of evidential support and essentially saying,
that's Mr Hollinrake, that give the people the benefit
of the doubt, in relation to evidence.

Do you, Mr Read, believe that subpostmaster
claimants should be given the benefit of the doubt
across all schemes?
I don't have the detail to be able to comment across all
schemes but I've been very clear that the evidential bar
must remain low and the evidential bar must be such that
the benefit of the doubt is for postmasters, and I've
been very clear about that and I've said that here on --
in this Inquiry and I do believe that. And that is
exactly what should happen. That --

It needs to be believed, doesn't it, Mr Read? I'm.
butting in because of something you said earlier in your
evidence. You're explaining about the real difficulties
for the Post Office in looking at shortfalls because of

the amount of time it goes back through, back through
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debacle committed by the Post Office was in relation to
stamps, how it was dealt with and interference in branch
accounts. Have I missed any schemes?

Yes, there are other schemes.

Right. Are they schemes that are dealing with financial
redress to individuals?

That's correct.

What are they?

There is a Process Scheme that is currently in pilot as
well, at the moment and there are, I don't recall off

the top ~

Help us understand what a Process Scheme means?
Again, it's a pilot to try and understand if there are
other areas of discrepancy that people have come forward
and said, "We have areas where we think there may be
detriment". So we're looking at all of those. We want
to be very open and transparent and, if there are people
who come forward and say that they have experienced some
form of detriment, we want take sure that we are
addressing it head on

Let me give you an example of the experience of one
individual we represent. It's Mr Peter Worsfold. He

has finally had his offer on his GLO scheme claim last
week. Across multiple heads of loss, he has been

offered only 70 per cent of what he claimed, and the
74

into the early 2000s, and indeed, there are questions
being asked about another electronic scheme called
Capture, so it may go even earlier than that.

Those evidential difficulties in trying to analyse
shortfalls are the same sorts of problems that some
people are also experiencing with trying to get their
way through these schemes.

Mm.

So's a common problem that you understand from the Post
Office point of view and the subpostmaster point of
view, don't you?

Yes, I do understand that.

Which is why the benefit of the doubt should be given,

if a subpostmaster —

lagree.

~ says "This is what's happened, I'm afraid I can't

find the document, I buried it, I lost it, I didn't want

to think about it", that can affect whether they have

the documentation, can't it?

Of course it can, yes.

Now, the Horizon Convictions Redress Scheme, which is
there to deal with criminal convictions overturned by
legislation, as we understand it, 335 letters have been
sent out to roughly a cohort of well over 1,000 people

that were convicted over the years through the Post
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Office's prosecutions and the scandal. 335 letters
doesn't seem to be the right number, Mr Read?
A. Is this the scheme that's run by the Government or is it
the scheme that's run by
Q. That's the Government —
A. Yes.
Q. ~and it's a scheme that relates to the convictions
that are being quashed through legislation?
A. Understood.
Q. 335 letters only have been sent out. So, essentially,
it seems as though there have been identified 33 people
to get letters that deal with their convictions, telling
them that they've been cleared. More work needs to be
done in this area, itis clear; do you accept that?
A. This is the Government scheme so it's difficult for me

to comment on the detail of --

SIR WYN WILLIAMS: Well, I was going to ask you, Mr Read,
does the Post Office have any involvement in
administering that scheme, and I use the word "any": for
example, is it incumbent upon the Post Office to try and
identify people which it prosecuted?

A. We obviously ~

SIR WYN WILLIAMS: That's just by way of an example.

A. [ mean, I was about to come on to tracing. I think

that's clearly what we're discussing here, is the
77

SIR WYN WILLIAMS: Fine.
MR STEIN: So what this means, Mr Read, is this: that it
seems almost five months from the passing of the Act,
which is the Post Office Horizon System Offences Act
2024, more than 60 per cent of the victims of this
scandal do not know that they've been vindicated
That's what appears to be the current situation.
A. If that’s what you're telling me. I'm not familiar with
those statistics, to be fair. It's a—
Q._ On the giving of information, so that the scheme can
have its operation, so that people can know that they've
been vindicated, so that they know they're entitled to
have compensation, you've just answered the questions
from the chair in relation to information going from
Post Office. That's clearly a job that the Post Office
needs to do.
Have you considered this with the NFSP because they
will also have lists of individuals that have been
members over the years? Have you considered that
possibility of joint working with the NFSP, get the
message out, but also whether they have names that could
assist?
A. I don't know whether that's been considered. It may
well have been considered. This isn't specifically

an accountability that I'm particularly close to, to be
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ability to trace and, clearly, we have an accountability
for that because many of the records will be held by
Post Office. But, as we've already discovered, records
aren't, and data isn't, as —

‘SIR WYN WILLIAMS: But what's interesting me, following

>

Mr Stein's questions, is whether there is a process, as
between the Post Office and a government department, and
again, I'm using the words "a government department”
because there's the possibility that the Department of
Trade is involved, there's the possibility that the

Ministry of Justice is involved. What is the process

for trying to track down alll these people?

I don't have the specific details but you're absolutely
right that there is an operational agreement between the
Post Office and the Department for Business and Trade
because the Department for Business and Trade is
obviously responsible for this particular scheme. The
mechanics of how that scheme works and what the
operational KPIs, in terms of the sort of time it takes

to do disclosure, and the time that it takes to do the
tracing, and the investigation -- or not the

investigation, but the ability to diagnose those
databases is obviously something that is part of the
operational agreement between the two parties. I don't

have the specifics behind that.
78

fair.
But it's work that needs doing?

Oh, clearly it is, yes.

Would you join with making a request to the Chair that
the Chair himself would, if he would be so kind, send

a message out to all media outlets ~ and I think it's
sometimes called a blog these days, I don't know whether
we'll do a blog -- but it would assist if this Inquiry

set itself out and made a very clear message to all of
those people that are being dealt with so harshly by the
Post Office, that are being convicted, to come forward,
yes?

I absolutely want that to occur. We've talked to the
CCRC, we've talked to the Advisory Board, we've talked
to the Inquiry, we've talked to the drama that was.

played at Christmas, in an attempt to try and get
‘communication out for people to come forward. We have
tried numerous and multiple attempts at tracing and
we've used Citizens Advice, we've used many other
outlets to try and do this. I agree with you, Mr Stein,

it's very, very frustrating but we must continue to try

and push this.

Do you accept that there's more joined-up work to be
done in relation to this, with the NFSP. There are

three firms of solicitors that represent number of
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people ~
Absolutely.

-- before this Inquiry. They should be tapped for their
expertise?

Absolutely.

They're conveniently all starting with the letter H:
Howe+Co, Hudgells and Hodge Jones & Allen

I agree.

Okay, so use their expertise, I respectfully suggest, in
making sure that the message goes out?

I agree.

Lastly, as mentioned earlier, you and others within the
Post Office have been meeting with our clients ~
That's correct.

-- and taking part in meetings that I know have been
difficult for you, obviously incredibly difficult for

the people that meet with you?

Indeed.

You're leaving the Post Office, other people that have
been taking part in those schemes are also leaving the
Post Office. How are you going to make sure that the
Post Office keeps its ~ the term used is "corporate
memory" ~- keeps its memory of the effect of what
happened to people?

What are you going to do to make sure that people
81

and I asked him questions about whether Fujitsu, the
company, broad shoulders financially, is prepared to
support people that have been affected through this
scandal. What I mean is the family members, the
children who watched their parents go through hell, that
have had their education disrupted, that may have been
put off an entrepreneurial career through this scandal.
There is no scheme that deals with those individuals at
the moment whatsoever.

Have you had any communication from Fujitsu to the
Post Office saying, "What a good idea, let's get
something done for the families, those people affected
in that way"; have you had any communication from
Fujitsu to that line?
don't believe I have. I ~
Has the Post Office set up any schemes that are looking
in the direction of support of providing educational
support, bursaries and the like, in relation to those
people affected in that way, who are not currently
affected by the schemes?

We are still having conversations with DBT about this.

I can assure you, and you'll be able to talk to Simon
Recaldin next week, that both of us are absolutely clear
that the family of — the families of victims need to be

considered in this process. And there are two lines of
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working in the Executive Team, the Directors that are
not postmasters, actually understand the depth of hurt
and feeling of this scandal?
We're doing a number of things. I think, as you
mentioned, I've done a number of restorative justice
meetings over the past couple of years, I think 37
Ihave attended. I speak at great length to the
organisation, at my town halls and at my 10@10 meetings,
to try and convey the trauma and the harm -- is the word
that I tend to use -- that had been inflicted upon many
of the families involved. I have spoken to Government
about it and, obviously, encouraged my Board members and
my Group Executive members to attend the restorative
justice meetings. I think it helps shape the solutions
that we should come up with and help people in the
organisation to understand the implications of this.

We've recently instigated, as Ms McEwan mentioned,
online and e-training for all colleagues in the Post
Office to help people understand just what the Post
Office has put many of your clients through.
Let me square a particular circle. You've mentioned
families.
Yes.
Mr Patterson, the European Director of Fujitsu, when he

gave evidence before this Inquiry, answered my questions
82

investigation for us here: one is working with DBT to
bring this to life. We do believe it is very important,

and I mentioned it in my witness statement, that it's
something that I personally am very engaged in. And,
secondly, we've obviously discussed, and at the
restorative justice meetings as well, just precisely

what — some form of memorial, some form of ability to
remember what has occurred, and how do we put that into
practice. So those are the two lines of investigation
that I am pursuing with DBT.

I have asked you on a number of occasions through the
questions I asked you within what is, I'm afraid, sadly
over an hour, in the remaining post that you have at the
Post Office, to take on particular tasks. I ask you one
more.

There are going to be communications with Fujitsu
regarding the question of how they're dealing with the
Horizon system.

Yes.

We know that. Mr Railton is committed to that; you have
had past communications. In whoever is conducting the
communications with Fujitsu, can this topic again be
raised: support making good the positive answer that we
have from Mr Patterson, that Fujitsu does think it's

a good idea to try and assist those people, the family
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members, that are outside all these schemes?
Perhaps by working hand in hand with the Post

Office, something good can come out of this scandal to
support those family members that have also been
affected. Do you also commit to that as well?

A. [think it's a very good idea, Mr Stein

MR STEIN: Thank you. Excuse me one moment. I just need to
check -- thank you.

THE WITNESS: Thank you

SIR WYN WILLIAMS: Before the next questioner, Mr Read, can
I be clear on the list of schemes that you and Mr Stein
agreed were in existence, that the Suspension
Remuneration Scheme, that is administered by the Post
Office, I take it, and the decisions about how much to
offer are made by the Post Office, having taken advice;
is that the position?

A. That's correct, sir. Just to bring that to life, in
Fraser J's judgment, he noted that suspensions had not
been on full pay, so there were individuals who were
suspended with no pay at all. We're trying to address
that particular shortcoming.

SIR WYN WILLIAMS: Right. What was described as the
adequacy of HSS payments, if that is to be considered
a separate scheme from HSS, nonetheless, that is

administered by the Post Office, and who is the decision
85

MS WATT: Good afternoon, Mr Read. I'm over here if you can
see me. We do sometimes have a little difficulty with
this.

I ask questions on behalf of the NFSP. I am here
today with Tim Boothman who is the Chair of the NFSP,
you may be able to just about see him around the pillar.
can't. Hello to you.
I want to ask you some questions, a number of different
questions. I think you would agree, in the light of the
Horizon scandal, that one of the most important
initiatives for the Post Office is its replacement, and
getting confidence that nothing like Horizon can happen
again; would that be right?
That would be right.
At paragraph 11 of your witness statement, you say that
the Post Office has been unable yet to deliver a new and
bespoke IT system for post masters. It's understood that
that new system to be introduced is called NBIT, New
Branch IT; is that right?
That's correct.
Q._Isit the case that the NBIT system was originally due

to be in place in 2025, and that those postmasters in,

oP

>

for instance, what we know as the Hard to Place scheme,
were scheduled by the Post Office to leave the network

before NBIT went live?
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maker in relation to that?

A. The Remediation Committee oversees the schemes that we
manage and, clearly, as I discussed yesterday, the
funding will come from Government, and so they will be
involved from an operational perspective in terms of
what the parameters of those schemes are.

SIR WYN WILLIAMS: Yes. But can I take it, if it has been
fully formulated -- if it hasn't been fully formulated
please tell me -- but is the adequacy of HSS payments
effectively being determined -- I'm not saying by the
same people -- but by the same process as the HSS
payments themselves, namely, that an independent panel
look at it, and make a recommendation to the Post
Office?

A. The scheme itself hasn't been fully formed, sir. We —

SIR WYN WILLIAMS: All right, so stop there. There isi
yet a process which I can say, "Right, that's what
they're doing", sort of thing?

A. That's correct, sir.

SIR WYN WILLIAMS: Fine. Thank you. Next one, please.

MR BEER: Yes, due to the operation of Mr Stein's watch, we

are going to rejig things slightly for logistical
reasons. It's Ms Watt on behalf of the NFSP.
SIR WYN WILLIAMS: Right.

Questioned by MS WATT
86

A. That would be logical. I think we certainly, when we
set out in March '21, which was the original date for
initiating the programme of NBIT, we had envisaged that
the replacement for Horizon would be in place by '25.
Insofar as your link to the Hard to Place branches,
that’s obviously a scheme that was established during
Network Transformation. It's a scheme that has
extended, I think by nearly 10 years in total. So I'm
not quite sure the two necessarily dovetail together.

I don't think there is a particular link between those
two schemes.

Q._Isit the case that the Post Office has already
purchased at least some of the hardware and that by the
time NBIT eventually rolls out, that hardware could be
out of date?

A. We've certainly purchased some of the hardware. I don't
know the specifics of whether it'll be out of date or
not out of date but, yes, we have.

Q._ Are you familiar with and do you agree with the Computer
Weekly report that we've heard about which states that
the development of NBIT will cost taxpayers over
£1 billion, lacks quality, and could be unachievable?

A. It's quite a lot to unpack in that particular statement
by Computer Weekly. I think it's fair to say that the

replacement programme for NBIT has certainly increased
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in cost, in terms of our budget, and is certainly going
to take longer to deploy. I don't think, at this stage,

that it is realistic to suggest that it's not going to

be fit for purpose. Certainly, the 250 postmasters who
are involved in the IT forum that helps shape the
development of NBIT haven't provided that level of
feedback.

I would agree, it is definitely slower than we would
have anticipated and I would also agree that the
difficulty of getting off Horizon in 2015 that was
experienced by IBM, which was the first time that we, as,
I understand it, wanted to get off Horizon, those
challenges are just as prevalent today, and I think the
level of complexity associated -- the technical
complexity associated with getting off Horizon has been
underestimated, and that is one of the core reasons why
the delays have and the costs have increased.

Would you accept that the Post Office has not been fully
open and transparent about the development of NBIT as it
should be, especially in the light of Horizon?

No, I don't think that's the case. I think we have

wrestled with getting the delivery of the releases out

on time. As I mentioned before, we have number of
postmasters who are helping us with this in terms of the

IT forums, and we believe that we've been as open and
89

about where we'd got to with NBIT and the progress that
we were making. So I don't necessarily agree with that
statement, no.
I'd like to turn to a different topic now. In
paragraph 20 of your witness statement, you state that
around 4,000 Post Office's are loss-making and loss
making also for the postmasters who operate them, and
that is around one-third of the post offices in the UK.
I want to ask what you have done during your time, or
are you going to do, to reduce the central costs of Post
Office to improve the viability of postmasters in the
running of their post offices?
I think the central ~ there are two core drivers to
increasing remuneration for post masters. I think one is
to drive revenue and, therefore, to be innovative with
new products and services, and the second, obviously, is
to reduce the operating costs associated with the centre
but also, the operating costs associated with running
a Post Office in and of itself.

So just taking those one at a time, if we think
about the introduction of NBIT and the replacement for
Horizon, we believe that the operating cost of doing
such a thing will reduce by about 60 per cent and that
will be both for branches themselves, as well as for the

centre. So that will reduce a run rate of around
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transparent with them about what's going on and their
feedback has been instrumental in terms of trying to
shape things.

Well, I'm not going to call it up, you may have seen the
evidence, but at paragraph 277 of Calum Greenhow’s
witness statement, that was WITN00370100, he says that
‘on 29 May this year, he met with you and others at the
Post Office and the NFSP were asking about NBIT:

*... and we were provided with an update. However,
the following day Computer Weekly broke the story that
NBIT was unachievable. Whilst we knew it was running
late and over budget at no point in the meeting of the
previous day were we told it lacked quality, according
to the auditors for the Department for Business and
Trade, or that Post Office had asked for nearly
£1 billion to fund the project, or that the
Infrastructure and Projects Authority were now involved,
or that the project had been brought into the Government
major projects portfolio.”

Would you agree that the Post Office, which failed
to be transparent about Horizon, is now failing to be
transparent about NBIT?

No, I don't think that's the case. I do recall that
Calum -- and I think Tim did too -- came to the offices.

I think, amongst a range of different topics, we talked
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60 million a year to Fujitsu to anywhere between sort of
20 and 30. So that will be probably the main driver.

I think, secondly, we've been on a trajectory of
trying to reduce the headcount within the Post Office
since about 2016/2017. I think we were at 7,500 heads
in 2016/2017, we're now at 3,400. I would fully
recognise that we have further to go and I'm sure that
the Strategic Review will look closely at the central
costs to make sure that we continue to reduce those
central costs. So I think that would be my secondary
point.

The third point, obviously, is the way to increase
the revenue for these particular branches is to make
sure that we can drive footfall and ensure that the
products and services that we are selling in post
offices are relevant to today’s consumer. So we're
spending a lot of time thinking about how we are central
to cash and central to financial services, as well as
the major strategy that has been deployed by the Post
Office over the last 18 months, which is clearly
a multichannel, multiproduct strategy, employing the
likes of Amazon and DHL and DPD and Evri in our
branches.

So I think it's a two-pronged strategy, would be the

biggest way to describe this. One is to continue to
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innovate and deliver new products and services and
indeed allow postmasters to share in some of the digital
developments that we've made, particularly with our
savings products, but also to make sure we continue to
cut costs. It's the crucial way and the most obvious
way to drive profitability

Just going back to the Strategic Review that you
mentioned in part of that answer, given that Network
Urban Reinvention 2003, Network Change 2007, and Network
Transformation 2012, did not provide a Post Office that
was fit for purpose, nor did it improve viability or
security of postmasters’ investment, is it not the case
that the Strategic Review is just another way of
transferring risk and cost from the Post Office onto
postmasters?

I think I said on Wednesday that I had a great concern,
when I took over the Post Office in 2019, that
postmasters had been left behind in a drive for
profitability, commercial sustainability and the agenda
associated with both of those two from a Post Office
perspective. We've tried to address that. I think

Nigel is very, very alive to the desire to have a new
deal for postmasters and, as I mentioned earlier, the
polarity issue in terms of making sure postmasters are

front and centre.
93,

in the GLO, cultural change is important and, from your
perspective, has taken place at least in part; is that
correct?

That's correct.

I think your position is that the Past Roles Project is

an important one —

Yes, itis.

--not least to give subpostmasters confidence that the
culture and attitude towards them has indeed changed?
Absolutely.

So I would like to ask you about something specific in
respect of those two points and to suggest to you that
there is actually a direct effect between those two

things on subpostmasters and their representative body,
the NFSP. Now, in this phase, the Inquiry has heard
evidence from the two Postmaster NEDs and from Calum
Greenhow, the Chief Executive of the NFSP ~ and I think
you've said you heard at least some of that evidence, or
50 --

I did, yes.

-- as to how near impossible it is to get anything

done ~ that's done today -- which benefits
subpostmasters, such as remuneration. In his evidence,
Mr Greenhow put that down in large part to the culture

at the Post Office, that it has not, in fact, changed
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Given what you've said, I'm not that familiar with
the three or four specific strategic reviews that have
been conducted since the earlier 2000s. I think the
scrutiny and spotlight that this Inquiry has placed on
the Post Office is such that it would be impossible for
us, even if we wanted to, which we don't, to do anything
other than make sure that the Strategic Review is for
the benefit of postmasters. That is what the Post
Office is all about: serving 10 million customers every
single week in our post offices. It's not about the
centre.
Now, my final question ~- or it's a series of questions,
different topic. I'm going to do some summarising and
then I'l ask you some questions. I'm going to call up
a couple of documents.

You've been asked by Counsel to the Inquiry about
the continuing issues with the culture of the Post
Office, you've also been asked questions about the Past
Roles Project and its failure to conclude within the
almost two-year period it's been underway, and that's
with regard to those who were involved in the pre-2015
Horizon scandal issues. You probably remember those
questions.
Indeed.
I think your position is that, following the judgments

94

and needs to change, in order for there to be a real
difference for subpostmasters.

Now, under your five-year leadership, there are some
people who were there during the peak of the Horizon
scandal era and who today deal with postmasters and
postmaster issues. I'm just going to give a little list
and then I'm going to ask you some questions.

So there's Nick Beal, Head of Network, which we
understand includes the NBIT project and who gave
evidence on behalf of the Post Office to Mr Justice
Fraser; Martin Edwards, the former Chief of Staff to
Paula Vennells, who is now Network Strategy and Deliver
Director; Tracy Marshall, Head of Postmaster Engagement,
who we saw in the emails yesterday was providing
reassurance on the remote access issue back in 2011 and
has a senior and extensive role in relation to
postmasters and is, in fact, the very person that the
NFSP has had to deal with over a good number of years on
almost every aspect of subpostmaster discussions and
negotiations.

Would you accept that subpostmasters will likely
find it incredible that someone who assisted Angela van
den Bogerd in 2011 with reassurance on remote access is
the very person with whom their representative body has

to deal on all of the issues associated with
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subpostmasters?
First and foremost, as I said yesterday, I'm very clear
that we will not walk past allegations of wrongdoing, or
misbehaviour and, when they are presented to me, and
when they are present to the organisation, we will
address them, and that stands firm. And I explained how
that process was going, both with Past Roles and with
Project Phoenix yesterday, and I still stand by that.

Where there is ~ and this is materially
different - where there is an issue of confidence, then
clearly we need to have sensible conversations with
individuals to invite them to step back and to make sure
that the confidence of postmasters is sustained. That
is the single-most important thing and I absolutely
agree with you.

However, as I said before, where allegations are
made and when they are explicitly made, we will
investigate those individuals and make sure that anybody
who was involved in any activity in the past is
addressed.

Now, just to be clear, by questions were about the
confidence that subpostmasters and their representative
organisation can have, as opposed to any specific
allegations of wrongdoing. So just to be clear about

that.
97

Minister, and I would encourage them to continue to do
so if they felt that we were in some way failing,

I think it's important to highlight ~ and I said it
yesterday -- that we are frustrated that the Past Roles
Project has not gone as quickly as possible,
I mentioned that we had 1,700 colleagues in the
organisation who have been in the organisation for
in excess of 10 years. There's a lot of investigative
work to do, a lot of data to cover and a lot of people
to ensure that we are making the right decisions.

This is not something that we can follow some of the
practices of the past, should I say. It's very
important that we get this right, and that we give
people who have employment rights the right level of
opportunity to express precisely what it is they may or
may not have done. So the investigative work has been
slow and I would agree with that and I acknowledged that
yesterday,

I would have much preferred it to have been quicker
but, as I say, I can give you confidence that we will
not walk past any allegations, and we will not walk past
any wrongdoing by individuals who are in the
organisation today that may still be operating.
Mr Read, not just slow, too slow, would you not say?

I did say that, yes.
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I understand.
I'd like to call up a document, which is WITN00370106.

This is a letter from the NFSP, from Calum Greenhow,
to the then Postal Affairs Minister, Kevin Hollinrake,
of January. It is following the Mr Bates vs The Post
Office ITV drama. If we could control to page 2 and
look at the third paragraph, the one that begins "The
NESP has raised concems internally”. So this is
a letter to Mr Hollinrake about the various issues
arising from the drama:

"The NFSP has raised concerns internally with Post
Office that there are still employees of Post Office who
were involved in internal discussion about bugs, defects
or errors, where directions were given for minutes not
to be taken, or were part of the Investigation, Audit
and Contracts departments who hold roles that are still
postmaster facing. We are not confident that the
correct review has or will be taken.”

We can take that down.

Would you accept that the NFSP was right to bring
this issue to the attention of Minister Hollinrake?

I mean, that's a year on from you starting your Past
Roles project.
Of course, it's absolutely in the rights of the NFSP to

discuss anything about the Post Office with the
98

I'd like to call up another document, that's
NFSP00001471. This is an email from Calum Greenhow to
you of 29 April 2024. That's this year. He's sending

it on to you so that are you can send it to the Post

Office Board. He's saying he doesn't have all the
addresses of the Post Office Board, can you pass it on.

So he says:

"I write to the Post Office Board after watching the
events in the Horizon Inquiry over the last few days.

Ithas once again highlighted employees of the Post
Office who in the past were part of the obfuscation of

the truth in relation to the accuracy and reliability of

the Horizon system and its use in the victimisation of
postmasters, their assistants and Crown Office employees
and the ruining of their lives.

"Some of these employees of Post Office involved in
the past remain employees of the Post Office today,
where their present roles is very much postmaster facing
or indeed are in senior management positions.

“This information is not unknown to the Board, yet
as a group, there has not been any action taken to
remedy the situation. How many more current employees
will over the remainder of the Horizon Inquiry be
revealed to have been aware of the inaccuracy and

unreliability of the Horizon system, be involved without
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the Board of Post Office Limited taking the required
action ... This is not the first time I have raised this
with the Post Office.

“am sure you will appreciate that as a group of
postmasters ourselves, we are growing increasingly
concemed that we keep having to deal with those
individuals who have been involved in the most
reprehensible behaviour towards postmasters and indeed,
as has been repeatedly stated”, and he goes on to talk
about what was to said at the Inquiry.

“To be clear, it is imperative that the Board takes
the required governance remedial action to identify any
and all current Post Office employees..."

He goes on to say:

“ifthe ... Board fails to take such governance
action, then it will fall to the current Postmaster
Non-Executive Directors to resign”, on this point.

Now, if we take that document down, this is
Mr Greenhow raising directly with you in April this year
and asking you to take that to the Board. What did you
actually do with that email?

A. Itwas circulated to the Board. It certainly formed
part of the discussions that we as a Board have had
since that time on past roles, and I will refer to the

comments that were made by Karen McEwan last week in her
101

and disrespectful to subpostmasters that those involved
in the past, not about wrongdoing, but in front-facing
postmaster roles, are involved in so many matters that
affect the postmasters today?

A. No, I don't think it's a disgrace. As I said before, we
are not going to have a witch hunt unless allegations
are made very clearly, and that is still my position.
I've been very open and said that we will remove
individuals where there is a lack of confidence and that
is something that we are obviously working through and
Karen, as she mentioned last week, was doing exactly
that.

MS WATT: Thank you, Mr Read

MR BEER: Sir, we've got two sets of questions to come now:
45 minutes from Mr Moloney and ten minutes from Ms Allan
on behalf of Susan Sinclair.

SIR WYN WILLIAMS: Yes.

MR BEER: There are two options, one we could take
a ten-minute second break now, ie a second break for the
morning and then do those 55 minutes of questions and
not have lunch or we could do Ms Allan's questions for
now for ten minutes, take lunch and come back after
lunch for Mr Moloney's questions.

SIR WYN WILLIAMS: I am content with either course. Is

there a consensus amongst people present in the hall as
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evidence about how seriously this has been taken at the
Board, about how complicated it is and how much debate
and discussion is going on at a senior level.

As I said earlier, we would like this to be much
easier, and you'll have seen emails that have come up in
the evidence from me on this particular topic. It would
have been much easier if this was a very simple process.
Itisn't. We're trying to deal with confidence of
postmasters, we're trying to deal with individual rights
of colleagues, and we're also trying to deal with
an investigative work to find out if there are
allegations that are substantive to wrong behaviour or
past behaviours. So it is a complicated piece of work,
I agree, and it's not easy for us to come down on a left
or right decision. It's much more nuanced than that,

I'm afraid.

Q._ Did you know that after that email of 29 April, that the
Post Office intended to send those same people to the
NFSP's annual conference on behalf of the Post Office
until Mr Greenhow asked the Post Office not to send
them?

A. I wasn't aware of that, no.

Q. Justa final question, then. So would you agree that,
given the Past Roles Project, which you have said

started almost two years ago, it is, in fact, a disgrace
102

to what we should do?

MR BEER: I'm looking at the shorthand writer in particular.
She said option 2, so I think Ms Allan now, lunch —

SIR WYN WILLIAMS: Then lunch.

MR BEER: -- and then Mr Moloney.

SIR WYN WILLIAMS: Fine.

MR BEER: Over to Ms Allan, then.

Questioned by MS ALLAN

MS ALLAN: Good afternoon, Mr Read. I'll stand up so you
can see me. Obviously, Ill sit to do my questions.

My name is Christie Allan and I represent Core
Participant Susan Sinclair who is a wrongfully convicted
postmaster. She was the first to successfully appeal
her conviction in Scotland, which only happen as
recently as September last year, despite her being
convicted in 2024

You've provided evidence yesterday about the Post
Office's engagement with the CCRC, that being the
Criminal Cases Review Commission in England, and,
indeed, Mr Henry put it to you that, as soon as it came
to pass that there were serious problems with Horizon
and certainly upon receipt of the Horizon Issues
Judgment in 2019, the Post Office ought to have been
banging on the door of the CCRC and Crown Prosecution

Service in England and Wales, begging for them to come
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and review these cases as the convictions were unsafe,
to which you answered "Yes, I see where you're coming
from".

Notwithstanding this, you refer in your first
witness statement to a number of meetings with Post
Office's Board, which did eventually occur with the
CCRC, albeit two years later, regarding the criminal
appeals in England and Wales, and Post Office's role as
a prosecutor.

In response to Mr Beer's question to your earlier
today, you confirmed that, as far as you're aware, the
Board of Post Office has not engaged with the Scottish
Criminal Cases Review Commission or Crown Office, albeit
the Remediation Subcommittee was potentially overseeing
those matters.

Can you therefore tell me about any proactive steps
that Post Office took, particularly in light of the
Horizon Issues Judgment in 2019, to immediately seek to
rectify the miscarriages of justice which occurred in
Scotland as a result of Post Office's failings in its
duties of disclosure?

A. [am not close enough to that particular issue that
you're describing. As you rightly point out, the
Remediation Committee has been engaged in those matters,

I don't sit on the Remediation Committee. Again, I am
105

SIR WYN WILLIAMS: I think there's quite a -- probably quite
a complex answer to that and it all occurred before
Mr Read was in post. So I think that I have as much
information as I am likely to get on that from the
previous phases of the Inquiry.

MS ALLAN: Thank you, sir. I will move on.

In your evidence on Wednesday, when asked by Mr Beer
whether Post Office's current investigative function is
fully compliant with all relevant legal standards, you
confirmed, "As far as I'm aware"; is that correct?

A. As faras I'm aware, yes, that's correct.

Q. You are aware, Mr Read, that Mr Beer asked you what your
response was to the Lord Advocate -- Scotland's most
senior law officer -- stripping the Post Office of its
role as a Specialist Reporting Agency in Scotland
earlier this year, and you confirmed that it's not
an enormous surprise that this decision has been made.
Why does that not come as a surprise?

A. Well, I think it’s in keeping with the direction of
travel of the last five years, since the HlJ and ClJ
were handed down. I don't think that would come as
a great surprise to me. That's my point.

Q._ Prior to this, Post Office in its role as a Specialist
Reporting Agency was an organisation who could

investigate and report crimes directly to the Crown
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11 October 2024

fairly certain that Simon Recaldin, who is a Subject

Matter Expert in this area, will be providing evidence

next week. I know ~ I think it's on November 4, in

fact. He's obviously going to be much better placed to
‘comment. I don't want to sort of muddy that water.

But to be clear, the Post Office's Board didn't engage

with the Scottish Criminal Cases Review Commission or
Crown Office —-

Not as a Board. It may well have been the case that the
Remediation Committee did or indeed that the Remediation
Unit did. I'm afraid I don't have that detail

You've repeated over the course of three days the fact
that, since before 2015, and indeed before your
appointment, the Post Office ceased to privately
prosecute postmasters in England and Wales. Remind me
again the reasons for this?

Sorry, do you want to repeat the question? Sorry.

Before 2015 and before your appointment, the Post Office
ceased to privately prosecute subpostmasters in England
and Wales; what were the reasons for that again?

Why did they cease to —

Yes.

~ to prosecute? I mean, clearly -

SIR WYN WILLIAMS: Can you answer that, Mr ~

A.

'm not sure I can, specifically.
106

Office and Procurator Fiscal Service, the independent
Public Prosecutor in Scotland, as opposed to having to
first report this to other law enforcement agencies to
investigate, such as the police; is that your
understanding?

I'm afraid I don't have the level of detail that you're
suggesting. Prosecutions haven't occurred since 2019,
since I've been in position. In fact, they haven't
occurred since 2015. So forgive me, but this level of
detail is not something that I am aware of.

Well, that would be what a Specialist Reporting Agency
does and that was Post Office's role prior to May
earlier this year, when it was stripped of that role.

The Lord Advocate, in deeming that the Post Office
is no longer fit to be a Specialist Reporting Agency,
also confirmed that, in light of the Post Office's
failures, work is now underway to strengthen the
guidance and safeguards that exist to ensure that all
Specialist Reporting Agencies abide by the essential
duties of disclosure and candour in Scotland, thus
inferring — and she went on to confirm -- that the Post
Office did not

Mr Read, is it really correct that Post Office does
not have an official response to being stripped of its

role as a Specialist Reporting Agency in Scotland?
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A. _I'mafraid I'm unable to answer that question. I don't
follow your train of thought in what you're trying to

ask me to answer. It's a little bit too nuanced for me,
I'm afraid

So there's not been any discussions in light of the Lord
Advocate's stripping —

No, there hasn't. Not that I'm aware of ~

Not at Board level ~

~- at Board level.

No, and there's no review work planned by the Post
Office to review this?

It's nothing that's come to the Board that I'm aware of.
As I mentioned before, Simon Recaldin is probably best
placed to discuss this when he comes on 4 November.
Q._ On the basis that, due to a failure in candour in

f)

>

reporting by the Post Office to the Crown Office and
Procurator Fiscal Service, how, therefore, if there's no
review and no discussion taking place, will Post Office
now ensure that it acts with candour, in providing
evidence of suspected criminality to other law
enforcement agencies, such as the police, if not now
directly to the Crown Office in Scotland?

‘A. I think Mr Bartlett, when he comes next week to
articulate and describe the role of the new

investigative function, which he will do, the Assurance
109

(1.40 pm)

Questioned by MR MOLONEY

MR MOLONEY: Good afternoon, sir, can you see and hear us,
as is the usual question?

SIR WYN WILLIAMS: Yes, I can thank you.

MR MOLONEY: Thank you, sir.

Good afternoon, my name is Tim Moloney, and I ask
questions on behalf of a number of Core Participants,
essentially postmasters, all of whom have been
prosecuted to conviction by Post Office and subsequently
have had their convictions quashed.

A. understand.

Q._ Quite close to the beginning of your evidence, Mr Beer
asked you about the appreciation at senior levels in
Post Office of the seriousness of the implications of
the Common Issues Judgment and the Horizon Issues
Judgment, and what that was not long after you took up
your post.

A. Yes, he did.

Q._ Yeah, and you agreed to his term that the leadership
team was living in a dream world, some of them, and
didn't seem to appreciate the implications of the
judgments?

A. Yes, I qualified that by saying that some were in denial

and some were in paralysis of the judgment that was made
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& Complex Investigations Team, he will be able to
articulate very clearly how the team is constructed, who
isin that team and what their objectives are,
particularly without engagement with law enforcement
agencies and I'm sure, as part of that, he will be
talking about the jurisdictions that you are referring
to.

Q. MrRead, I would say it's not just those jurisdictions,
it's reporting criminality to any law enforcement agency
in any jurisdiction. Can the Post Office now be trusted
to do that with candour, despite the fact it didn't do
that in Scotland?

A. Yes, I believe they can and, as I mentioned yesterday,
we are liaising with law enforcement agencies on
specific elements of organised crime and the like, and
clearly tying to support those agencies wherever we can,
in terms of the level of detail that we support and
supply.

MS ALLAN: Thank you.

SIR WYN WILLIAMS: So we'll break off for lunch now and
resume when, Mr Beer?

MR BEER: Sir, could I say 1.40?

SIR WYN WILLIAMS: Yes, certainly.

(12.47 pm)

(The Short Adjournment)
110

and limited contingency had been put in place for the
prospect of losing the litigation

Q. But the primary focus was on looking to the future,
without there being a real emphasis on rigorously
‘examining what had gone on in the past at that stage?

A. I think that's a fair conclusion, yes.

Q._ So, for example, you weren't directed towards the
examination of the propriety of previous convictions?

A. No, I wasn't, no

Q._ But you went on to say that the negotiation and
settlement process around the Common Issues Judgment in
the Horizon Issues Judgment gave you an opportunity to
more fully understand the implications of the judgments?

A. Yes, unquestionably, that that was my genuine
introduction to the victims, first and foremost, and
also, therefore, the understanding of the behaviours,
rather than necessarily the system, if that makes sense
I think that was my introduction to behaviours of the
past.

@. Yes. Can I just focus on your introduction to the
victims

A. Yes

Q. for these purposes. You were able to listen to
postmasters and hear the accounts of what had happened

to them?
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That's precisely how that process worked, yes.

Just as one example of that, did you take part in

a mediation meeting in respect of the GLO at which
postmasters were present?

Yes, the four or five days of mediation/settlement, that
process, I did speak and listen quite extensively.

I think there were five or six who brought their

narrative to life for me, yes, which was very helpful.

How that narrative was brought to life, Mr Read, was
that you, was it with Jane Davies, went into a room with
those five or six, just to hear their stories?

Yes, no, it wasn't with Jane but, yes, that is correct,

yes.

One of them was Jo Hamilton?

That's correct.

Another was a Scottish woman who'd been one of the lead
claimants in the GLO, a lady by the name of Louise Dar;
do you remember her?

Yes, Ido. Yeah

She'd been cross-examined during the course of the GLO?
Yes.

In that meeting, you told the postmasters that you would
do everything to transform the future of Post Office?
Yes, that was my commitment.

Yes. Importantly, Ms Dar ~ and she broke down as she
113

manager. The shortfalls continued. Katie had to stop
work because she was suffering from anxiety and
depression, as a result of the continuing shortfalls
and, ultimately, Mrs McDonald was prosecuted. Are you
aware of her being prosecuted as one of the people who
was prosecuted?
I don't remember the specific case. When was this, what
date was this?
It was in 2010/2011. So some time before the GLO, some
eight years before the ClJ and the HlJ.
I understand,
Now, she was 47 years old and the mother of teenage
children when she went to prison. She was sent to
prison for 18 months after pleading guilty to theft.
She went to Styal Prison to start with, which is near
Manchester, and then she was sent to Durham Prison, and
she spent her daughter's 18th birthday in Durham Prison.
Then she later went to a prison near York called Askham
Grange.

You may have seen during the evidence of
Mr Bradshaw, because Mr Bradshaw investigated
Mrs McDonald, that he recorded in a self-appraisal form,
after her conviction, how ensuring that a plea of guilty
to false accounting was not accepted but insisting on

a plea of guilty to theft was essentially one of his key
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told you this -- told you what had happened to her and
said -- and this may have been important to you in
appreciating what was needed -- that you needed to fix
the wrongs that had been done in the past, as well as
looking to the future; do you remember that?

I do, that's correct.

Was that an important meeting for you, in terms of the
understanding of, to use your term, the harm that
postmasters had suffered?

Yes, it was and, as I say and as I said a couple of

minutes ago, it brought to life the behaviours of the

Post Office, as opposed to necessarily my understanding
at that stage, which was it was purely system led.

Now, one of the people who had suffered harm a number of
years prior to that meeting was a woman by the name of
Jackie McDonald from Preston in Lancashire?

Okay.

Now, I have to just give a little bit of detail of

Jackie McDonald's case, in order to ask the question

that I'd like to ask about her case, if I may, Mr Read
Understood.

So Jackie McDonald had encountered shortfalls in her
Post Office. She reported them to management. She was
ultimately suspended after an audit, some £90,000 or so

shortfall, and her assistant Katie took over as the
114

achievements of the year; did you see that?
Don't recall it specifically but yes.

He recorded on the form that he had persuaded the
prosecution barrister to proceed with the allegation of

theft and not accept a plea of false accounting. Okay.

Mrs McDonald has explained her experience, described
her experiences, in a statement to this Inquiry. She
explained how traumatic the audit and investigation
process was and the Auditors asked her “What have you
done with the money? What tree have you squirrelled it
away in?", and her house was searched, and in front of
her, the searchers were asked, "Is she cooperating? Is
she answering questions?"

One of the people about whose behaviour Mrs McDonald
complained was a woman by the name of Caroline Richards.
Caroline Richards was a Business Development Manager,
who had called in the Auditors and attended the audit,
and she's the person that Mrs McDonald had been liaising
with.

As long as go as 2013 in her application to the
Mediation Scheme, Mrs McDonald said the following,

Mr Read:

"The Investigators for the Post Office were bullies.

and intimidated me the first time they came in with

their lies about my individual case being unique and
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uncommon. They returned once again when I was forced to
step down and Katie was running the Post Office under
someone else's name, and intimidated her with wage
deductions from monies missing and jail ime. My

husband eventually came downstairs after he heard the
news of the threats Katie was receiving, and told them

both, Steve Bradshaw and Caroline Richards, to get out

of the shop immediately and never come back.

“Katie had to leave early and had to take a leave of
absence because of anxiety and depression because of the
bullying that she took from those Post Office
Investigators.”

So the Post Office Investigators being Steve
Bradshaw and Caroline Richards.

You told the Inquiry -- and in fact, in answer to
questions from Ms Watt, you've reiterated this just
before lunch, Mr Read -- that you've been very clear
that “At no stage will we walk past allegations of
wrongdoing in the organisation", and you've made that
very clear publicly to all colleagues and postmasters
themselves.

You said specifically, on Wednesday -- and it's at
page 48 of the transcript ~ and you've repeated it this
morning, to be fair to you, Mr Read:

“With regard to the Remediation Unit, I'm very clear
17

Q. ~about that, then.

SIR WYN WILLIAMS: Can I take it, Mr Moloney, that you don't
wish to pursue that specific question?

MR MOLONEY: Sir, I think the question has been answered, to
be honest, and so —

SIR WYN WILLIAMS: I see ~

MR MOLONEY: I think there are — there are obviously ~ we
have to be responsible with questioning, sir, and —

SIR WYN WILLIAMS: I only asked you so that you didn't feel
inhibited on behalf of your client in going any further
if you thought that it was appropriate to go further.

If you're content with where we've got to, that's fine
byme.

MR MOLONEY: If I'm being told by a witness that he has real
reticence about going here, that there are particular
reasons why they can't go there, then I think it is only
responsible, because I can deal with this generally.

I've asked my question, I've received an answer and
can deal with this generally now, without causing
undue difficulties which may not be necessary at all in
order to make the points I need to make.

SIR WYN WILLIAMS: Fine. Thank you, Mr Moloney.

MR MOLONEY: Mr Read, without descending to the specifics
and recognising your qualification as to

postmaster-facing activity, would you accept that, as
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that we've conducted a piece of work which you've heard
a lot about at this Inquiry which is referred to as the
Past Roles piece of work. And, once again, I'm
confident that there are not individuals involved in
postmaster-facing activity that had roles in the past
where allegations of any wrongdoing has been brought to
my attention."

Is Caroline Richards still employed in the
Remediation Unit, Mr Read?
This is quite a difficult question because -- and I'm
looking to Sir Wyn -- I'm not sure I'm at liberty to
discuss some of the specifics about these individuals.
If you recall a couple of days ago we talked about
external agencies supporting us and there are a number
of individuals that I think it would be inappropriate

for me to mention and to give any insight into what is
specifically happening. I know that doesn't sound
particularly helpful but I

No, I understand, Mr Read, and I think it would be
unfair on all individuals if I were to not understand.
Yes.

Plainly there have to be parameters.

Correct.

Can I ask you some more general questions —

Yes.
118

a general principle, somebody about whom complaints had
been made of the nature that were made against
Ms Richards, should not be involved in the remediation
process?
I agree with that and I'll just bring a little colour,
if I may?
Yes.
The Project Phoenix work, which is ostensibly feedback
and narratives that we've received during Phase 1 of the
Inquiry, in terms of the Human Impact Hearings, as well
as what I have experienced through my restorative
justice meetings, and I received direct feedback during
those meetings on individuals, that was the genesis of
the Project Phoenix work. 47 particular cases, I think
as I mentioned previously ~- not 47 individuals but 47
cases -- six individuals who were involved in those
meetings.

We have interviewed many of the individuals again,
through their legal representatives, and sought to be
able to discuss with those individuals the names and the
issues that emerged during the Human Impact Hearings and
that emerged during the restorative justice meetings.

We've examined over 130,000 documents associated
with those particular case studies. The number of

individuals impacted is six, of which, as I mentioned
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I think on Wednesday, three are specific cases that
we've just touched on now that I would say we've got
external agencies helping have a look at that.

Can you understand that for postmasters who are making
a claim for compensation, the idea that the unit that is
dealing with claims for compensation might be somebody
who was involved in previous misbehaviour, would be
something that would concern them?

I think that would be very concerning for them, yes.
Because you have said, and it's perhaps likely that

Mr Recaldin will say, that, even as a first principle,
perhaps Post Office should not have been responsible for
administering the HSS?

Ihave said that and I'm sure Mr Recaldin will say the
same.

So to compound that with having a member of staff - and
I'm speaking in general terms now ~ against whom
complaints had been made for misbehaviour during the
investigation process, would be to add insult to injury,

in a sense, wouldn't it?

I understand that.

You talked this morning of rebuilding trust. It would

be integral to rebuilding trust to ensure that that

didn't happen, wouldn't it?

It would be essential, yes.
121

Then the second document is the Board minutes from
4 June this year.

Okay.

So if I could first go to the readout of the meeting

with Mr Hollinrake, and that's BEISO000653. Thank you
very much. This is, we can see, the introductions. We
don't need to go there but we can see the attendees, if
we scroll up, please. Thank you. We can see that
you're there, Mr Read, as is Mr Mcinnes from Post Office
and Lorna Gratton and also Minister Hollinrake.

Yeah.

Can I just go to some of the detail of this and, if we

could scroll up further now, please, so that we can get
the main body. That's great. That's spot on, thank

you.

We see at the start that you raise the fact that the
Permanent Secretary had made the decision to withhold
the funding and asked for Mr Hollinrake's opinion
Mr Hollinrake said that he, the Treasury and Permanent
Secretary are keen to see a plan from Post Office about
its funding ask, and know that the Horizon replacement
is a concem.

You said that the funding ask won't be ready/
approved by the Board until June and main issues are

Horizon replacement, POL underestimated the cost of
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That's all I'd like to ask you about that.

I'd now like to ask you about the Strategic Platform
Modernisation, SPM, and NBIT, and this is the only other
topic I'll ask you about, Mr Read.
I understand.

You understood from your early meetings, during the
mediation of GLO, the harm that had been caused, and
Horizon software lies at the root of all of that harm,
doesn't it?

Indeed.

Postmasters suffered enormous harm because of it?
That's correct.

For many other reasons as well but, at the core of it,
is the Horizon software and its unreliability?

That's right.

Plainly, you'd accept that dealing efficiently, dealing
with alacrity with the Horizon issue is something that
Post Office should face, given the harm that it has
caused to postmasters?

Yes.

I'd like to ask you, if I may, about the progress that
has been made with that, and I'd just like to look at
two documents, as please. One is a readout of

a minister with Minister Hollinrake in April 2023, and

Hl take you to it.
122

this, and then the Inquiry costs and the compensation
costs.

Then I'll go onto the rest of it. Did you, at this
stage, not have a firm plan as to what to do with
Horizon?

Yes, we did have a plan but, as we were overrunning, it
was important that we come back to Government, who
wanted to understand what they thought our revised plan
for Horizon was, in terms of the overall funding for
Horizon.

Then if we go down further, we see that, in the
penultimate bullet point of this, which is on the second
page, but we can see it here:

[Nick Read] said that another pressure was the
Inquiry, which is going to scrutinise the rollout of the
Horizon replacement; POL needs to ring-fence/
compartmentalise this piece of work.”

What did you mean by the Inquiry is going to
scrutinise the rollout of the Horizon replacement?

I think exactly that. I'd obviously made a commitment
in 2019 that we would get off Horizon, and there was

a twofold reason for that: one because Horizon was

30 years old, it was expensive to run, expensive to
manage and clearly had been associated with appalling

issues of the past.
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‘And the second reason ~- so that was the first
reason — the second reason was it was clearly a system
that was tarnished as a consequence of the past and
I wanted to make sure that we moved across — we got off
it

My point to talk about ring-fencing and
compartmentalising was that we submitted our funding
requests to the Department and the investment that was
required for the next phase of the Horizon work needed
to be very clearly understood by BEIS, and I wanted to
make sure that when we made that submission they
understood the extent and the necessity to get off
Horizon and what that looked like and, more importantly,
that they understood specifically why it was late and
why it would cost more.

You had had really quite significant delays in relation
to the replacement for Horizon?

We had at that stage, and I think what had happened
by--I think we said it was May '23, this meeting,

I seem to recall

April ‘23.

April '23.

Yes.

So by April '23 we had embarked on two very clear

‘streams of work: one was around the design and build of
125

replacement was 180 million or there or thereabouts, and
why that cost has obviously increased as a consequence
of what we have leamt through the Inquiry. But, more
importantly, that we want a system that more than just
a replacement, but actually is a wholescale
transformation of the way we do business in the Post
Office.
Can I just take you to the final paragraph on page 1 of
this document that I've brought up. It reads:

“[Kevin Hollinrake] asked how [Post Office] is going
to try to find a number that they are comfortable with
for the cost of replacing Horizon. [Nick Read] said
that they are considering more of a modest approach
rather than something transformative {for example] not
rolling it out to all 11,500 branches, and opting for
the minimum viable product. Another issue is that we
don't know what the future of [Post Office] will be and
designing a system that will work for POL in decades to
come is difficult.”

Is that reflective, Mr Read, of there being very
firm decisions about what this was going to look like in
April 20237
I think the issue here is that the Department had
decided to withhold funding. They were concemed about

the potential cost of the replacement system, and they
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the system; and the second piece of work, which was
initiated in January that year, was around the
deployment, training and rollout of the system. And
they were two very distinct pieces of work and so that
was the point I was trying to draw to the attention of
the Department.
So by April 2023, was the design and build of the system
pretty much set in stone or were there decisions still
to be taken?
We -- it's a difficult question to answer. I think we
had not got to the stage (unclear), we hadn't, at that
stage, developed the banking and total mail
functionality of NBIT, and so there was still a long way
to go, so it was still quite early in terms of its
evolution. We were still having conversations about is
this a replacement for Horizon or is this a modern
system development that is going to ensure that
postmasters are in a very different — are put in a very
different place?

And I think, if I look back to 2019, it was very
much we are replacing Horizon, as opposed to "This is
going to be a full-scale transformation of the
underlying EPOS system", which is very much the attitude
today. And I think that's one of the core distinctions

between why, when we set out on this journey, the
126

wanted us to consider other options and all options, in
fact and it was at this stage that we came back and had
a broader conversation around, well, what are those
options?

So there isn't any certainty here, is there; and you

were essentially considering something less than
transformative?

Yes, I mean that is -- that was one of the options that
was on the table.

Yes. So there was no certainty in April 2023 about what
the replacement for Horizon was going to look like?

Well, we thought we were on a particular journey, and
the Government were concemed about the increasing cost
and they wanted us to —- and they wanted to get
assurance from that, which is obviously why we've had
two external parties assure for the Government on their
behalf what exactly is being developed.

Can we go to the second document I'd like to look at,
please, which is POLO0448648. Before I ask you
questions about this document, Mr Read, we heard
evidence from Mr Railton on Tuesday that you've already
referred to.

Yes.

You were present when Mr Railton gave his evidence?

Iwas indeed, yes.
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Mr Railton has been Interim Chair since 24 May 2024?
That's correct.
These are Board minutes from 4 June 2024. So just over
a week after Mr Railton became Interim Chair. You're
present, obviously, as "NR", and Mr Railton is "NR" with
a lower case "a" - "NRa"?
That's correct.
Now, page 5 of 21, I'd like to look at please, because
this deals with the Strategic Platform Modernisation
Mr Blake took Mr Railton to a different section of this
document, the minutes, where Mr Railton was asked about
how he was the first to suggest a break clause in the
continuing contract with Fujitsu; do you remember that?
Ido remember that, yes.
That can be seen at page 11 of this document —
Okay.
-- but page 5 is the Strategic Platform Modernisation
and we can see here, and it should be under “Investment
Committee", so it should be down the page, yeah, there
itis. 3.5, "Investment Committee":

“Key points advised

“the [Investment Committee] met on 16 May and
focused on SPM [the Strategic Platform Modernisation].
There were uncertainties in respect of this project

across number of issues including funding.”
129

consistently throughout the business. [It was] noted
issues in respect of the copper stop project including
management of the contractor and communications."
There's still really quite a lot of uncertainty
around SPM, even in June 2024, isn't there?
Different uncertainty but, yes, there is uncertainty.
That's the new chair coming in essentially suggesting
there needs to be root and branch consideration of this?
That is correct. Yes
That's only four months ago?
Four months ago.
Yeah. Mr Railton was asked by Mr Blake, when he gave
evidence, the following, and this is at page 164 of his
evidence:
"We've seen in the YouGov report, for example, and
in evidence the Inquiry has heard, of issues still being
experienced by subpostmasters in relation to their use

of Horizor

That's the importance of it, Mr Read, isn't it?
Yes.
It's still ongoing.
“Is it possible, is it likely, that subpostmasters
are going to be using that same system into 2030?"
Mr Railton replied:

“itis possible. I don't think it's likely and
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So this was June 2024, Mr Read, only some five
months ago -- four months ago, in fact.
Four,
"Two external reviews had been completed in respect of
the project and both concluded red ratings. The build/
buy point had been considered, although the build
approach without the necessary inhouse expertise seemed
flawed. [Mr Railton] shared his view that the
conversation on buy/build was the wrong question and
thought that the question was build/build and then the
question was whether to build internally or externally.
There needed to be a number of conditions met for
a successful internal build however such as a stable
business, good governance and quick decision making.
With the Company not fulfilling this conditions the view
of [Mr Railton] was that a third party should be
commissioned to build. [Mr Railton] advised that he saw
3 options, firstly SPM could carry on as was, secondly
a third party could be engaged to build the new system,
and thirdly that Horizon could be brought in house. All
of these options needed to be carefully considered;

“the dashboard reporting to the [Investment
Committee] showed 17 red platinum projects. A number of
these were outside appetite although there was a lack of

clarity around the definition and terms were not used
130

certainly our intention and the intention of the new
team is to move away from Horizon to a new system that
can deliver ~ I'm sorry to go back to the strategic
review, but a system that's fit for the future as soon
as possible but to do that in a way that doesn't disrupt
postmasters' activities."

So that was the answer as to whether or not,
essentially in 2030 -- which is when the Fujitsu
contract is due to run out, isn't it?
Well, we haven't got agreement to a five-year
‘commitment, yes, but that was the plan.
Yes. That's the possibility. Is there a firm decision,
in the Strategic Review, as to how to do this? I'm not
asking you what the decision is. Is there a firm plan
now in respect of all of the replacement for Horizon in
the Strategic Review?
Ihave not yet seen the specifics of this. As you're
probably aware, for the last six weeks I've stepped back
to focus on the corporate statements associated with the
Inquiry, and that is something that I'm sure by the end
of this particular session I will be back involved in
that activity. So I can't give you that assurance at
the moment, Mr Moloney.
Has it taken too long to find a replacement for Horizon?

Yes, it has.
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Q. Do you bear any responsibility in how long it has taken,
Mr Read?

A. Yes, I mean, if you go back to my last statement that
I made, the very last pages on that statement, I have
number of regrets, I think, in my five years in the
business, and one of those regrets is the inability to

have the bandwidth to get involved in the SPM programme

and project, as much as I would have liked, having been
spread a bit too thinly. And that is a big regret of
mine and I wish that I'd had more time to do that - one
of number of regrets but that was certainly one of them
which I expressed in my statement.

MR MOLONEY: That's all I ask, Mr Read, thank you.

THE WITNESS: Thank you.

MR BEER: Sir, unusually, I've just got couple of questions
to ask which I've been asked to put to Mr Read, one by
way of correction of something that I said, and then
some supplementals that follow it

SIR WYN WILLIAMS: Sure, Mr Beer.

MR BEER: It will be less than five minutes.

Further questioned by MR BEER

MR BEER: Can we look please at POLO0448701.

Thank you. You remember I showed you this letter,
it's Mr Vamos' letter, the "Dear all” letter?

A. Yes, indeed.
133

consider relevant issues in advance of passing
legislation, without any value judgement on what the
correct course of action might be.

“The letter references a note provided by Post
Office's legal counsel. This note was not solicited by

the Post Office and, as can be seen, was sent to express

the personal views of its author.

"Post Office was in no way seeking to persuade.
Government against mass exoneration. Post Office are
fully supportive of any steps taken by Government to
speed up the exoneration of those with wrongful
convictions and to provide redress to the victims with
the information having been provided to them to inform
that consideration.”

So your letter of the 9th is published, Mr Vamos’
“Dear all" letter is published and then there is this
explanatory text alongside it, which says:

“Post Office was in no way seeking to persuade
Government against mass exoneration."

Can we look, please, at your letter of the 9th,
POL00448381. I drew your attention to the fourth
paragraph of this, if we scroll down, "A natural
corollary", et cetera, yes? We looked at that this
moming.

A. We did, yes.
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I drew your attention to the third paragraph, the fourth
line, in which it was said:

“In reality, itis highly likely the vast majority
of people who have not yet appealed were, in fact,
guilty as charged and were safely convicted.”

Yes?

You did, yes.

I'd suggested that this was put up on the Post Office's
website —

Yes, you did.

~ but it was no longer on the website. In fact, it has
been drawn to my attention that it is still on the Post
Office's website. The website, which I'm looking at
now, contains some text alongside it, ie the publication
of Mr Vamos' letter. It says:

"The Post Office has published, on 22 February 2024,
correspondence from 9 January [that's your letter to the
Lord Chancellor] sent by the Post Office to the Ministry
of Justice, copied to the Department for Business and
Trade. The purpose of the correspondence was to explain
the work that the Post Office had requested its legal
counsel, Peters & Peters, undertake to proactively
identify on the papers available any convictions that
could be unsafe. This was primarily to offer the

Government any support that might assist them as they
134

What I didn't do is go over the page. If we go over the
page, please, you wrote in the penultimate paragraph:

“In the meantime, I attach a note prepared by Peters
& Peters which covers this and other issues you may find
helpful in your deliberations.”

That's the Vamos "Dear all” letter. So whoever the
“Dear all" was sent to, it had certainly got to you by
this time, hadn't it?
It looks like it, yes
The covering text on the Post Office website, when it
speaks about the Peters & Peters note, essentially takes
two points: it says, firstly, Mr Vamos’ note was not
solicited
Yes.
Secondly, it says it expresses the personal views of its
author. Was that the Post Office distancing itself from
the content of Mr Vamos’ letter?
I think it was just trying to explain the letter.
That's my understanding.
You, in your letter, attached Mr Vamos’ "Dear all”
letter, didn't you?
Indeed.
Were you allying yourself with the contents of it by
doing so?

No, I'd been very clear that we weren't making any value
136

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judgements. We felt obliged to alert the Ministry of
Justice to exactly what work had been done and to aid
them in their deliberations.

MR BEER: Thank you.

SIR WYN WILLIAMS: Thank you, Mr Beer.

Thank you, Mr Read, for four witness statements, two
of which are very long and detailed, and for giving
evidence over three days before this Inquiry. I'm very
grateful to you.

THE WITNESS: Thank you, sir.
SIR WYN WILLIAMS: Right, we'll adjourn now and resume on
Tuesday moming at 10.00.
MR BEER: Thank you very much, sir.
(2.21 pm)
(The hearing adjourned until 10.00 am
on Tuesday 15 October 2024)

137

INDEX
NICHOLAS JAMES READ (continued)........

Questioned by MR BEER (continued)...

Questioned by MR STEIN

Questioned by MS WATT ......-....

Questioned by MS ALLAN ....

Questioned by MR MOLONEY ....

Further questioned by MR BEER ..

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[38] 1/6 27/4 2719 I180(2] 1013 11/5 I250 [1] 89/4 9th [2] 135/15 135/20) accepted [1] 115/24

16 May [1] 129/22 I26 June [3] 55/16 I accepting [1] 49/3
27/15 30/18 31/2 31/6
43/21 46/5 46/8 53/14I 164 [1] 131/13 55/24 58/16 abide (1) 108719 I access [2] 96/15

17 [2] 19/24 130/23 I277 [1] 90/5 abide [1] 96/23

S37 77117 77108 A oe laa T0217
78/5 79/1 85/10 86/22I47 May [3] foe
86/7 86/16 86/20 54/21 56 29 April [1] 100/3

ability [6] 18/11

27/20 28/13 78/1 according [1] 90/13

account [8] 6/20

78/22 84/7
86/24 103/17 103/24 I18 [3] 64/10 92/20 I29 May [1] 90/7 able [10] 9/10 37/19 I 36124 38/2 43/8 43/17

115/14 7 44/10 49/5 52/12
104/4 104/6 106/24 oe 3 52/7 62/16 75/14 oe

180 million [1] 127/1 IP accountabilities [1]
4107/1 110/20 110/23 - 83/22 87/6 110/1

48th [1] 115/17 3 miles [1] 60/14 51/23
111/5 119/2 119/6 112/23 120/20 a

19 [1] 62/2 3,400 [1] 92/6 accountability [3]
119/9 119/22 133/19 abled [1] 20/13

1999 [1] 32/22 3.5 [1] 129/20 15/14 78/1 79/25
4137/5 137/11 1999 [1] Seize about [126] 2/11 5/14

; 30 [4] 3/4 4/24 21/16 accountant [1] 31/23

THE WITNESS: [4] /2 92/2 6/18 9/17 10/5 10/7 tants [2
46/16 85/9 133/14 10/8 17/4 17/18 18/11 2ccountants [2]
137/10 2.24 [1] 137/14 30 years [1] 124/23 32/17 33/13
A870. 2] 43/23 44/22 [335 [4] 76/23 77/1 I 19/14 22/16 24/25 I Accounting [3] 44/4
' 20 [4] 53/2 53/5 91/5 I 77/10 77/11 ae ante ae 88 115/24 116/5
DID OO DERAD I 92/2 ili 32/21
24 [2] 62/25 88/2 36 million [3] 30/14 30/15 30/16 Iecounts [5] 7/22
: 61/1362/22 {2000s [2] 76/1 94/3 I 33/9 53/8 33/2 38/14 74/3
22 [2] 30/17 30/18 30/19
: 2003 [1] 93/9 369 [1] 22/2 112/24
23 (A) 125/19 125/21 I 9905 [1] 34/10 37 [1] 82/6 30/23 30/24 31/5 21 35/4
125/22 125/24 3711] 826 I 3390 34/13 35/16 [accuracy [2]
‘25 [1] 88/4 2007 [ty Be 4 36/11 38/11 45/4 100/12

2010 [1] 66/11 achieve [3] 22/23

‘business [1] 2/17 _ I>o10/2014 [1] 115/9 I4 June [2] 120/2 I 45/18.47/10 47/24 I") eae

: 96/15 96/23 I 129/3 49/17 50/8 50/19 ’
—E~EA—re—ee.I2012 [1] 93/10 109/14 55/14 56/15 58/4 a ccnowledged [1]
1 2013 [1] 116/20 4,000 [1] 91/6 te Oe eee 99/17
1 billion [2] 88/22 I2015 [6] 32/22 89/10 I4.0 [1] 43/14 across [12] 33/10
one 94/21 106/13 106/18 I4.5 [3] 46/24 47/3 I 65/17 GOI 6715 O7I7/Trpn Osa S144
1 mile [1] 60/15 108/9 47/5 87/16 67/16 68/9 68/9) S4746 54/47 74/24
4,000 [1] 76/24 2016/2017 [2] 92/5 I4.6 [3] 47/9 47/9 68/14 70/25 75/7 I 75743 75/14 12514
1,700 [1] 99/6 92/6 472 75118 75/23 76/2 I 49/95
4.40 [2] 110/22 1141/1 I2017 [2] 92/5 92/6 I45 [2] 30/14 103/15 I 76/18 77/24 82/12 _ I ace ty 70/3 79/4
40 [4] 53/2 53/5 82/8 I2018 [1] 1/24 46 [1] 48/19 83/1 83/21 85/14 87/6I ching [2] 56/5 69/12
82/8 2019 [6] 93/17 47 [3] 120/14 120/15 I 88/20 89/19 90/1 90/8) ction [40] 7/15 18/8
10 June [1] 2/3 104/23 105/18 108/7 I 120/15 90/21 90/22 91/1 20/8 40/16 54/23
10 million [4] 94/9 I 124/21 126/20 47 years [1] 115/12 I 91/21 91/23 92/5 400/21 101/2 101/12
40 years [2] 88/8  I2019/2020[1] 63/2/48 [1] 117/23 92/17 94/9 94/10 I 44/16 135/3
99/8 2020 [5] 2/133/17 I49 [1] 19/25 94/16 94/18 95/11 I o ctioned [1] 49/2
10.00 [3] 1/2 137/12 I 5/10 63/2 72/24 97/21 97/24 98/9 actions [2] 14/4
0.00 fs 2021 [2] 23/10 23/17 I9 98/13 98/25 101/10 {action

2022 [3] 23/10 61/8 I50 [2] 53/3 53/5 102/1 102/2 103/2 I activities [1] 132/6

(36) MR BEER: - activities
INQ00001195

INQ00001195

A 85/5 14/1 15/19 17/14 27/4I Amazon [2] 64/2 _ I appeal [3] 21/18

activity [5] 412 IAffronted [1] 67/1 _ I 27/5 27/6 27/8 34/23 I 92/22 21/23 104/13

97/19-118/5 119/25 Iafraid [8] 39/9 76/16 I 38/19 38/20 46/5 46/8/ amended [1] 10/15 I appealed [3] 26/6

132/22 84/12 102/16 106/11 I 46/25 49/2 49/12 amending [1] 12/21 I 26/22 134/4

acts [1] 109/19 108/6 109/1 109/4 I 50/1151/5 53/14 —_ Iamongst [4] 18/2 __ I appeals [4] 21/18
after [17] 12/18 33/25] 53/25 55/7 55/11 19/14 90/25 103/25 I 22/8 23/10 105/8

actual [1] 69/21
actually [17] 13/11 34/4 45/21 48/10 51/2I 58/20 59/4 61/17 amount [5] 5/20 appear [3] 43/12

13/18 16/4 22/19 52/14 67/13 100/8 62/18 67/13 69/16 15/13 31/25 39/12 43/15 51/1

27/12 36/20 38/13 102/17 103/22 111/17I 70/13 74/16 75/13 75/25 appears [7] 5/24
45/13 46/20 57/5 114/24 115/14 115/23) 75/14 78/12 80/6 80/9) analyse [2] 38/13 31/18 62/8 68/18
63/14 66/3 69/20 82/2 117/5 129/4 81/6 82/18 85/1 85/20) 76/4 71/18 71/23 79/7
95/13 101/21 127/5 afternoon [4] 87/1 86/16 94/9 96/25 analysis [1] 10/22 Iappellants [1] 21/16
acute [1] 22/5 104/9 111/3 111/7 100/5 101/13 107/2  IAngela [1] 96/22 appetite [1] 130/24
add [2] 50/11 121/19 again [23] 1/10 1/13 I 107/9 108/18 111/9 {annual [1] 102/19 application [1]

addition [1] 73/6 6/20 10/17 10/19 117/20 118/20 119/20) another [12] 22/3 116/20

additional [2] 1/15 33/19 33/23 50/22 122/1 122/8 127/15 I 46/1 65/5 65/7 73/20 Iapplied [2] 10/16
17/16 51/1 51/5 68/21 68/24) 128/1 130/20 132/15 I 73/25 76/2 93/13 10/18

address [10] 7/1 20/7I 74/13 78/8 84/22 133/13 133/24 135/16) 100/1 113/16 124/14 Iappoint [1] 17/6
39/1 39/4 43/5 52/23 87/13 100/10 105/25 I 136/6 136/7 136/20 I 127/16 appointed [2] 12/18
63/19 85/20 93/21 106/16 106/20 117/1 IAllan [7] 30/15 answer [21] 6/24 9/3 I 17/10

97/6 118/3 120/18 103/15 104/3 104/7 I 13/13 13/16 34/24 appointment [5] 17/5)
addressed [4] 1/13 against [11] 18/15 104/8 104/11 138/10 I 36/11 36/20 57/5 58/8) 17/13 65/21 106/14
27/4 71/15 97/20 18/25 19/1 19/1 19/6 IAllan's [1] 103/21 60/2 66/5 84/23 93/8 I 106/18

addresses [2] 2/8 I 22/6 54/24 120/2 allegation [2] 12/24 I 106/24 107/2 109/1 Iappraisal [1] 115/22
100/6 121/17 135/9 135/19 I 116/4 109/3 117/15 119/18 Iappreciate [3] 33/20
addressing [3] 2/5 [agencies [8] 108/3 allegations [13] 126/10 132/7 1041/4 111/22

e116 74/2 108/19 109/21 110/5 I 17/20 18/15 19/6 answered [4] 79/13 I appreciating [1]
adds [1] 53/5 110/14 110/16 118/14] 19/10 28/22 97/3 82/25 105/2 119/4 114/3

adequacy [3] 73/15 I 1213 97/16 97/24 99/21 Ianswering [2] 30/11 appreciation [4]
85/23 Bao agency [8] 24/3 102/12 103/6 117/18 I 116/13 111/14

adjourn [4] 137/11 I 24/15 107/15 107/24 I 11816 answers [2] 1/16 _ Iapproach [7] 8/5
adjourned [1] 137/15 108/11 108/15 108/25) Allen [1] 81/7 58/1 9/14 18/19 19/8 62/4
Adjournment [1] 110/9 allow [2] 61/1 93/2 IAnthony [1] 34/12 127/13 130/7

110/25 agenda [1] 93/19 ally [1] 26/9 anticipated [1] 89/9 Iapproached [1] 3/25
administer [3] 1/11 ago [8] 64/10 102/25 Iallying [1] 136/23 anxiety [2] 115/2 appropriate [3] 44/18)
6/1 6/19 114/11 118/13 130/2 Ialmost [5] 6/14 79/3 I 117/10 50/21 119/11
administered [4] 4/5 130/2 131/10 131/11 I 94/20 96/19 102/25 Iany [51] 1/12 4/23 I approved [1] 123/24
‘418 85/13 85/25 agree [34] 16/3 17/11\alone [1] 5/21 5/24 6/22 8/25 9/11 I April [10] 100/3

administering [5] 36/16 38/5 39/6 39/16Ialong [2] 19/12 66/13) 9/11 15/23 18/7 19/14) 101/19 102/17 122/24,
72/13 72/23 72/23 41/18 42/15 42/17 alongside [2] 134/14 I 20/7 24/8 24/13 27/25] 125/21 125/22 125/24
7719 124/13 45/16 48/16 50/22 135/17 39/13 49/19 50/3 52/9] 126/7 127/22 128/10

advance [1] 135/1 52/18 52/21 60/7 61/1Ialready [5] 7/3 30/23 I 52/17 54/22 54/23 IARC [1] 46/20

advantageous [1] 68/12 70/1 73/18 78/3 88/12 128/21 66/25 67/3 69/14 are [161]

8/3 76/15 80/20 81/8 also [27] 19/20 21/1 I 69/19 74/3 77/18 area [3] 42/16 77/14

advice [15] 2/14 3/5 81/11 87/9 88/19 89/8) 38/4 44/7 49/18 50/2 I 77/19 83/10 83/13 106/2
3/22 4/20 29/18 29/20I 89/9 90/20 91/2 97/15] 51/18 57/19 58/22 83/16 97/19 97/23 I areas [3] 71/22 74/14
29/23 30/2 30/2 58/5 I 99/17 102/14 102/23 I 72/13 73/6 73/15 76/6) 99/21 99/22 100/21 I 74/15

120/5 79/18 79/21 81/20 101/12 105/16 109/5 Iaren't [2] 68/23 78/4
eee 59/2 80/19) agreed [2] 85/12 85/4 85/5 89/9 91/7 I 110/9 110/10 118/6 arisen [1] 7/10
advised [4] 20/24 111/20 91/18 93/4 94/18 118/16 119/10 128/5 Iarises [1] 30/25
22/24 129/21 130/17 Iagreement [4] 5/25 I 102/10 108/16 112/16) 133/1 134/23 134/25 Iarising [4] 2/16 49/20)
advisers [1] 21/15 78/14 78/24 132/10 I 123/10 135/2 135/10 136/25 I 50/4 98/10
Advisory [3] 22/18 ahead [1] 57/21 alternative [1] 2/25 Ianybody [4] 38/21 Iaround [17] 12/14
23/2 80/14 aid [1] 137/2 although [4] 14/10 38/22 40/9 97/18 15/1 15/8 27/24 31/4
Advocate [3] 23/24 aim [1] 12/12 32/3 130/6 130/24 anyone [4] 25/11 59/18 63/9 87/6 91/6
107/13 108/14 alacrity [1] 122/17 Ialways [1] 51/6 59/18 62/20 63/8 91/8 91/25 112/11
Advocate's [1] 109/6 Alan [2] 34/12 64/3 Iam [24] 1/2 5/7 13/25/anyone's [1] 48/20 I 125/25 126/2 128/3
Affairs [1] 98/4 albeit [2] 105/7 17/20 21/12 27/23 anything [12] 10/7 130/25 131/5
affect [3] 8/25 76/18 105/13 28/7 29/5 29/6 32/12 I 19/12 25/8 30/9 51/22I article [2] 11/15
1403/4 alert [1] 137/1 53/18 53/20 55/16 51/22 51/24 56/23 11/16
affected [9] 39/10 alerted [1] 35/2 64/12 84/4 84/10 87/4I 66/3 94/6 95/21 98/25I articles [1] 11/13
A17 41/11 41/17 83/3) Alisdair [1] 34/20 101/4 103/24 105/22 Ianywhere [1] 92/1 Iarticulate [2] 109/24
83/12 83/19 83/20 alive [1] 93/22 105/25 107/4 108/10 Iappalling [2] 26/24 I 110/2
all [65] 3/2 7/6 10/22 I 137/15 124/24 articulated [2] 42/11

(7) activity - articulated
INQ00001195
INQ00001195

A

articulated... [1] 66/9
as [220]

ascertain [1] 34/9
ask [33] 9/4 11/8

68/22 77/17 84/14
87/4 87/8 91/9 94/14
95/11 96/7 109/3
111/7 114/19 114/20
118/24 122/1 122/2
122/4 122/21 123/21

133/16
asked [31] 11/21

107/7 107/12 111/14
116/9 116/12 119/9
119/18 123/18 127/10)
129/11 131/12 133/16}
Askham [1] 115/18
asking [12] 26/25
28/6 28/8 28/11 32/12
55/13 61/15 66/15
68/14 90/8 101/20
132/14
aspect [2] 60/9 96/19
aspects [1] 59/6
assess [1] 32/18
assessment [3]
22/12 22/13 32/24
assist [5] 54/12
79/22 80/8 84/25
134/25
assistance [1] 43/19
assistant [2] 44/15
114/25
assistants [3] 44/7
44/10 100/14
assisted [5] 3/7 54/2
54/2 54/4 96/22
associated [12]
29/15 51/24 52/10
89/14 89/15 91/17
91/18 93/20 96/25
120/23 124/24 132/19}
assume [1] 46/8
assurance [12] 49/15}
49/20 49/21 50/4 50/5
50/14 50/16 51/9
51/19 109/25 128/15
132/22
assure [2] 83/22
128/16
at [128] 2/6 2/10 3/9
3/25 4/15 4/18 10/12
10/13 12/3 12/3 12/5
13/3 13/7 13/21 13/22)

21/7 26/12 34/5 46/10

33/21 34/9 37/3 38/8
49/10 55/23 59/1 59/2 38/11 38/25 40/3 40/3 35/18 38/1 56/2 59/20I been [146]

41/3 41/5 42/12 42/19] 100/24 102/22 105/11

123/23 128/19 133/13I 99/7 61/20 67/8 68/21

33/25 34/1 44/9 45/18I 80/16 80/18 82/7 82/6

50/19 53/9 67/5 67/7 I 82/8 83/8 84/5 84/1

68/9 75/5 76/2 83/1 I 85/20 86/13 87/15
88/13 89/2 90/5 90/7

84/11 84/12 90/15

ba/t6 o4/18 ro/20 I 90/12.91/20 92/5 92/6
92/8 95/2 95/18 95/25

21/8 22/1 23/18 24/5
24/10 24/12 24/18
26/18 28/17 30/6
30/22 30/24 31/4
31/13 32/18 33/14

44/22 46/10 48/13
50/25 51/14 52/17
52/25 53/14 55/16
56/5 56/8 56/14 58/20

69/12 70/21 74/10
74/16 75/7 75/24

98/7 101/10 102/1
102/3 104/2 109/8
109/9 111/14 112/5
113/3 114/13 117/18
117/22 118/2 118/11
119/20 121/3 122/8
122/13 122/22 123/16)
124/3 125/18 126/11
128/2 128/18 129/8
129/15 131/13 132/22)
133/22 134/13 135/20)
135/23 137/12
attach [1] 136/3
attached [1] 136/20
attack [1] 63/12
attempt [3] 35/8
55/11 80/16
attempts [1] 80/18
attend [1] 82/13
attended [2] 82/7
116/17
attendees [1] 123/7
attention [12] 16/14
17/1 37/10 37/18 39/8)
39/15 98/21 118/7
126/5 134/1 134/12
135/21
attitude [2] 95/9
126/23
attributed [1] 44/6
audit [5] 5/13 98/15
114/24 116/8 116/17
auditors [3] 90/14
116/9 116/17
audits [2] 54/5 54/14
author [2] 135/7
136/16
authority [2] 13/19
90/17
autumn [1] 22/19
available [3] 21/22
38/21 134/23

15/19 16/8 18/1 19/16] await [1] 69/4

aware [32] 5/20
10/20 12/4 17/25
18/18 18/21 18/23

24/16 27/24 31/8
33/15 34/18 35/5

107/10 107/11 107/12
108/10 109/7 109/12
115/5 132/18

away [2] 116/11
132/2

awkward [2] 11/8
11/22

back [30] 4/24 9/7
24/21 26/18 33/15
34/10 35/3 35/4 39/5
54/12 59/23 62/21
63/1 64/4 65/19 66/20
75/25 75/25 93/7
96/15 97/12 103/22
117/8 124/7 126/20
128/2 132/3 132/18
132/21 133/3
background [3]
53/24 53/25 54/6
bad [2] 5/11 5/15
Baker [2] 23/5 59/4
balance [5] 17/7
17/11 17/12 36/24
49/4
bandwidth [2] 4/11
133/7
banging [1] 104/24
bank [4] 5/11 5/11
5/15 5/15
banking [4] 126/12
banks [1] 7/16
bar [2] 75/15 75/16
barrister [1] 116/4
Bartlett [3] 55/18
55/24 109/23
based [4] 9/15 11/13
35/6 38/3
basically [1] 51/20
basis [2] 55/2 109/15
Bates [2] 34/12 98/5
be [193]
Beal [1] 96/8
bear [2] 41/1 133/1
bears [1] 29/13
became [4] 18/23
19/7 27/19 129/4
because [37] 7/6 8/5
8/19 9/10 11/7 15/11
15/16 21/17 22/11
34/25 37/11 37/20
39/8 39/9 39/11 39/18
54/16 57/10 58/24
73/17 73/25 75/22

79/17 115/2 115/21

become [4] 18/18
18/21 22/25 28/12

BEER [17] 1/4 29/10
50/19 53/23 55/5
55/13 56/22 75/6
107/7 107/12 110/21
111/13 133/19 133/21
137/5 138/4 138/14

Beer's [1] 105/10

before [27] 21/7
34/10 40/24 56/12
57/7 65/1 65/8 66/9

87/25 89/23 97/16
103/5 106/13 106/13
106/18 106/18 107/2
109/13 115/9 115/10
117/17 128/19 137/8
begging [1] 104/25
beginning [1] 111/13
begins [1] 98/7
behalf [12] 22/9 23/6
24/20 30/16 86/23
87/4 96/10 102/19
103/16 111/8 119/10
128/17
behave [1] 68/4
behaviour [3] 101/8
102/12 116/14
behaviours [9] 67/8
67/16 67/18 67/21
68/7 102/13 112/16
112/18 114/11
behind [6] 28/24
64/11 69/11 70/2
78/25 93/18
being [40] 4/7 4/8 9/5
10/21 12/13 13/9
13/22 15/5 16/15 41/1
42/1 44/9 51/11 51/13
52/7 54/3 68/19 69/18
73/3 73/4 73/7 73/12
73/17 75/5 76/2 77/8
80/10 80/11 86/10
104/15 104/18 108/24)
112/4 115/5 116/25
117/13 119/14 127/20)
128/17 131/16
BEIS [2] 61/8 125/10
BEISO000653 [1]
123/5
believe [20] 4/12
11/6 11/11 26/17
27/23 28/15 28/17
40/25 48/8 52/6 56/24
59/22 60/4 75/11
75/19 83/15 84/2
89/25 91/22 110/13

75/24 78/2 78/9 78/16] believed [1] 75/21
117/10 117/10 118/10I benefit [7] 4/13 69/19)

119/17 121/10 122/11] 75/9 75/12 75/17
19/7 19/10 22/25 23/6I 124/22 129/8

70/1 81/3 82/25 85/10I 95/13 126/25

benefi [1] 17/6

76/13 94/8
benefited [1] 17/16
benefits [1] 95/22
beside [1] 31/19
bespoke [1] 87/17
best [4] 6/8 14/25
33/17 109/13
better [5] 10/9 33/6
58/18 59/19 106/4
between [17] 1/24
14/23 17/2 32/21 55/6)
56/9 58/3 58/4 63/6
71/19 78/7 78/14
78/24 88/10 92/1

bi

[1] 133/9
gest [1] 92/25
[1] 22/14
billion [2] 88/22
90/16
BIP [1] 38/19
birthday [1] 115/17
bit [7] 15/20 44/21
48/14 58/2 109/3
114/18 133/9
Blake [2] 129/10
131/12
blog [2] 80/7 80/8
board [78] 1/21 2/11
3/9 3/11 3/22 4/21 5/3)
5/19 5/20 6/17 6/17
7/6 9/1 9/8 11/25 12/7,
12/8 13/10 13/10
13/17 13/24 13/25
14/19 14/19 15/2
15/11 15/19 15/23
15/24 16/1 16/5 16/8
16/11 16/13 16/21
17/7 17/10 17/11
17/15 19/15 19/16
19/17 22/18 23/2 23/8)
23/18 23/20 23/23
24/6 24/11 46/19 56/3
56/7 56/9 71/20 80/14,
82/12 100/5 100/6
100/8 100/20 101/1
101/11 101/15 101/20)
101/22 101/23 102/2
105/6 105/12 106/6
106/9 109/8 109/9
109/12 123/1 123/24
129/3
boardroom [1] 12/14
body [3] 95/14 96/24
123/14
Bogerd [1] 96/23
Boland [2] 33/12
34/21
Boothman [1] 87/5
both [14] 3/23 7/23

(38) articulated... - both
INQ00001195

INQ00001195

B 130/17 130/19 58/4 90/24 104/20 116/25 120/24 129/6 IChambers [1] 18/17
hath 1491 9/13 9/99 IDuild/build [1] 116/24 117/5 128/2 Icases [12] 21/21 championed [1]
both. [12] one ae 130/10 Cameron [3] 33/25 I 21/24 22/1 23/13 11/24
83/23 91/24 93/20 bullet [4] 15/7 15/12 I 34/4 34/17 23/18 104/19 105/1 I Chancellor [3] 21/10
97/7 117/7 130/5 47/12 124/12 can [94] 1/5 1/10 105/13 106/7 120/14 I 22/25 134/18
bottom [3] 13/22 bullies [1] 116/23 1/16 2/6 6/25 7/1 9/24) 120/16 121/1 change [9] 10/17
33/5 61/20 bullying [1] 117/11 13/3 13/10 21/8 24/17I cash [3] 37/22 51/24 I 10/20 40/6 41/19

buried [1] 76/17 24/20 27/13 28/23 92/18 70/12 70/19 93/9 95/1

bound [1] 21/23 I
boys [1] 18/12 bursaries [1] 83/18 I 29/10 30/20 31/3 32/5Icause [5] 7/15 40/1 I 96/1

business [23] 3/16 I 33/6 34/8 36/4 37/1. I 44/5 45/2047/11 _Ichanged [2] 95/9
Bradshaw (4 aaa 7/7 7/25 12/3 16/16 I 39/11 41/13 43/14 Icaused [7] 44/1 44/7 I 95/25

branch [34] 31/17. I 1619 16/23 2011 I 43/17 49/25 44/23 I 44/10 44/24 47/14 I changes [1] 61/25
eel eaog I 2419291226111 I 45/2 46/6 46/15 46/24] 122/7 122/19 changing [2] 46/12
aeee srag sens I 72072112734 I 47/11 48/3 48/3 48/16Ieausing [1] 119/19 I 70/17

spo awrzane I 78/15 78/16 90114 I 49/11 49/13 52/16 CCRC [5] 23/9 80/14 Icharged [3] 26/7

38/21 39/7 39/20 116/16 127/6 130/14 I 61/8 63/9 67/22 71/16I 104/18 104/24 105/7 I 26/22 134/5

4025 41/1 45/10 1341/1 133/6 134/19 I 76/18 76/2079/10 Icease [1] 106/21 _I check [3] 51/20
48/28 49/15 49/20 [businesses [1] 7/17 I 79/11 83/22 84/22 ceased [2] 106/14 I 51/25 85/8

49/21 50/4 60/5 50/13) busy [1] 45/10 85/3 85/10 86/7 86/17) 106/19 Chief [5] 14/9 18/10

50/16 50/18 51/9 but [70] 8/7 13/24 87/1 87/12 92/14 cent [5] 60/13 60/14 I 66/18 95/17 96/11
51/18 69/12 70/8 15/14 16/9 18/7 24/10] 97/23 98/19 99/11 74/25 79/5 91/23 children [2] 83/5
70/10 70/14 74/2 25/1 26/1 28/17 29/11) 99/20 100/4 100/6 central [7] 70/24 115/13

87/19 131/8 29/22 30/1 30/7 31/24) 104/10 105/16 106/24) 91/10 91/13 92/8 choice [2] 6/17 6/18
branches [14] 31/20 33/19 34/7 36/4 39/16) 106/25 110/10 110/13) 92/10 92/17 92/18 Christie [1] 104/11
38/8 49/14 61/1 70/5. I 40/10 42/19 43/15 110/16 111/3 111/5  Icentre [11] 35/20 Christmas [1] 80/16
70/9 71/2 71/7 71/22 I 45/12 46/11 52/17 112/20 118/24 119/2 I 36/18 37/11 38/22 church [1] 32/6

88/5 91/24 92/13 53/3 59/11 61/20 67/4) 119/17 119/19 121/4 I 38/23 39/21 40/25 churn [1] 71/5

92/23 127/15 69/14 70/22 75/15 123/6 123/7 123/8 91/17 91/25 93/25 ClJ [2] 107/20 115/10
brands [1] 41/17 78/3 78/5 78/13 78/22) 123/12 123/13 124/13) 94/11 circle [1] 82/21
breach [2] 47/2 47/5 79/21 80/2 80/8 80/21) 127/8 128/18 129/15 Icentric [2] 57/17 circulated [1] 101/22
breaches [1] 47/11 86/7 86/9 86/11 88/18} 129/18 132/3 133/22 I 57/19 Citizens [1] 80/19

break [12] 30/22 90/5 91/18 93/4 99/20I 135/6 135/20 CEO [3] 30/4 34/6 [2] 54/5 54/23
30/24 31/1 31/4 31/9 I 1039/2 106/6 108/9 can't [13] 6/24 25/10 I 71/20 claim [3] 29/7 74/23
53/10 53/11 53/19 I 112/3 112/10 113/12 I 36/8 49/8 52/15 59/13ICEOs [3] 29/11 56/9 I 121/5
403/19 103/19 110/20) 115/24 116/2 118/18 I 61/6 66/2 76/16 76/19] 58/4 claimants [8] 3/24
4129/12 120/15 122/13 123/7 I 87/7 119/16 132/22 certain [4] 8/2 27/8 I 4/1 4/4 4/17 31/13

briefly [1] 7/1 124/6 124/13 127/3 Icandour [4] 108/20 I 69/15 106/1 72/25 75/12 113/17

bright [4] 43/11 127/5 129/17 131/6 I 109/15 109/19 110/11Icertainly [23] 12/6 _Iclaimants' [2] 3/24

bring [14] 12/1 12/7 I 132/4 132/5 132/11 Icannot [1] 22/3 15/6 16/8 16/19 19/18] 4/5
12/8 18/25 39/7 39/14I 133/11 134/11 capability [1] 21/1 I 24/10 28/19 42/24 I claimed [1] 74/25
7116 84/2 85/17 [Butterfly [1] 51/10 I Capture [1] 76/3 51/17 53/14 64/8 68/3I claiming [1] 17/23
98/20 120/5 butting [1] 75/22 captured [1] 4/22 _I 88/1 88/16 88/25 89/1Iclaims [1] 121/6

broad [2] 32/6 83/2 button [10] 35/19 [career [1] 83/7 89/4 101/22 104/22 I clarity [3] 44/12

broader [2] 15/1 36/12 36/13 36/14 _ I careful [1] 36/11 110/23 132/1 133/11 I 45/12 130/25
1283 36/15 36/17 37/5 37/8I carefully [1] 130/21 I 136/7 clause [1] 129/12

broadly [3] 27/7 36/1 I 39/21 52/9 careless [1] 45/7 _Icertainty [2] 128/5 Iclear [42] 5/7 6/9
36/2 buy [2] 130/6 130/9 I carelessness [3] 128/10 6/16 7/3 11/23 24/7

Brocklehurst [1] buy/build [1] 130/9 I 44/2 44/25 47/14 cetera [1] 135/23 I 27/7 28/6 29/1 35/19
S78 bypassing (t] 2A learia ta} 5/12 5/12 lenare(tay 5/13 48/2 I 40/tod2/t5.47/24

arla chair

broke [3] 69713900 I arto tz 56/5 56/14 58/21 70/8) 49/18 50/2 51/18

brought [14] 16/15 I°49° [1] 65/24 Caroline [5] 116/15 I 79/14 80/4 80/5 87/5 I 51/25 54/24 62/23
17/12 3710 37/18 (Call [7] $1/9.51/10 I 416/16 1147/7 117/14 I 129/1 1290/4 131/7 I 63/3 65/9 65/11 70/20
90/18 113/7 113/9 I 04/8 90/4 94/14 98/2 I 118/8 Chairman [2] 53/21 I 75/15 75/18 77/14
114/11 118/6 12719 I 100/71 carried [3] 24/13 65/13 80/9 83/23 85/11 97/2
430/20 called [10] 38/19 44/2 73/12 chairmanship [1] 97/21 97/24 101/11

browbeat [1] 40/7 I 43/6 47/4 60/5 61/12 Icarry [3] 27/20 28/14 I 65/10 4106/6 117/17 117/20

budget [2] 89/1 90/12I 76/2 80/7 87/18 130/18 challenge [5] 13/9 I 117/25 125/24 136/25

bugs [1] 98/13 115/18 116/17 case [21] 12/4 25/3 I 15/1 15/8 22/19 32/25I cleared [1] 77/13

build [12] 63/9 calling [1] 37/9 26/17 27/23 28/15 _Ichallenges [6] 22/6 Iclearer [2] 9/16 52/1
4125/25 126/7 130/5 Icalls [1] 36/22 29/11 39/22 52/6 60/4I 23/3 23/7 29/15 62/1 I clearly [28] 6/7 7/17
4130/6 130/9 130/10 [Calum [5] 90/5 90/24 I 87/21 88/12 89/21 89/13 8/11 8/20 22/4 23/3
430/10 130/11 130/13) 22/16 98/3 100/2 90/23 93/12 106/9 _I challenging [3] 11/8 I 29/16 34/19 35/1

came [8] 24/25 25/13I 114/19 114/20 115/7 I 11/21 18/4 42/11 45/7 56/12

(39) both... - clearly
INQ00001195

INQ00001195

Cc commissioned [2] Icomplex [4] 4/12 [consider [4] 1/14 I 26/7 26/22 31/14
Clearly... [16] 64/14 35/12 130/17 34/25 107/2 110/41 61/24 128/1 135/1 31/21 76/25 80/11
67/8 77/25 78/1 79/15 commit [2] 61/16 complexity [3] 29/14 Iconsiderable [2] 104/12 104/16 134/5
80/3 86/3 92/20 97/11 85/5 89/14 89/15 31/25 71/19 conviction [3] 104/14I
1403/7 106/23 110/2 commitment [12] Compliance [1] considerably [1] 111/10 115/23
410/16 124/24 125/2 10/5 14/4 61/14 62/15) 46/19 39/25 convictions [15]
425/10 63/16 63/17 65/3 compliant [1] 107/9 Iconsideration [2] 21/24 22/14 72/11
client [3] 25/18 33/3 65/13 71/10 113/24 I complicated [2] 131/8 135/14 72/14 72/17 72/19
119/10 124/20 132/11 102/2 102/13 considered [13] 4/15I 76/21 76/22 77/7
clients [3] 67/24 committed [2] 74/1 Icomply [1] 49/15 24/12 45/11 73/12 77/12 105/1 111/11
81/13 82/20 84/20 compound [1] 73/17 79/17 79/19 112/8 134/23 135/12
close [7] 48/3 62/12 committee [21] 5/13 I 121/16 79/23 79/24 83/25 Cooper [3] 1/18 4/25
70/9 72/2 79/25 10/25 11/2 23/19 computer [4] 21/25 I 85/23 130/6 130/21 I 6/14

105/22 111/13 23/22 24/12 46/19 88/19 88/24 90/10 considering [3] 6/3 Icooperate [1] 50/13
closely [1] 92/8 46/19 46/20 46/22 concede [1] 21/18 127/13 128/6 cooperating [1]
closer [3] 12/7 12/8 47/25 48/2 48/6 86/2 Iconcern [8] 18/11 consistently [2] 20/4 I 116/12

7215 105/24 105/25 106/10) 40/20 43/4 57/14 131/1 copied [1] 134/19
closing [1] 71/2 129/19 129/20 129/22] 67/23 93/16 121/8 _Iconspicuously [1] _ I copies [1] 46/11
closures [2] 70/14 I 130/23 123/22 3/23 copper [1] 131/2
70/4 common [3] 76/9 _ Iconcerned [8] 19/13 Iconstructed [1] core [9] 20/22 30/12
cloud [4] 28/23 111/16 112/11 40/14 40/17 69/16 110/2 70/21 89/16 91/13
Club [1] 51/10 commonality [1] 75/7 101/6 127/24 consultation [1] 104/11 111/8 122/13
Co [1] 81/7 38/24 128/13 35/12 126/24

cohort [1] 76/24 communicate [2] concerning [2] 2/15 Iconsulted [1] 9/13 [corollary [2] 21/20
colleagues [13] 36/2 68/5 121/9 consume [1] 13/15 I 135/23

14/18 50/10 20/13 Ie0Mmunicating [1] Iconcerns [7] 17/18 Iconsumer [4] 92/16 corporate [5] 40/4
20/15 28/19 29/21 58/24 18/12 18/18 19/8 59/8) contains [1] 134/14 I 40/5 66/21 81/22
29/21 29/22 29/24 Icommunication [8] I 98/8 98/11 contemporaneous I 132/19

82/18 99/6 102/10 I 27/7 52/20 55/6 57/1 Iconclude [1] 94/19 I [2] 5/8 29/4 correct [46] 1/23 2/1
117/20 72/3 80/17 83/10 concluded [1] 130/5 Icontent [4] 59/1 2/4 5/6 7/8 13/2 13/6
collegiate [1] 66/23 83/13 conclusion [2] 65/16 I 103/24 119/12 136/17] 14/10 38/6 49/16 50/7
colour [1] 120/5 communications [5] I 112/6 contents [1] 136/23 I 50/15 54/18 60/16
come [38] 6/25 10/22 22/5 84/16 84/21 conditions [2] context [2] 15/9 60/23 65/22 72/16
14/8 16/20 22/21 84/22 131/3 130/12 130/15 61/25 72/21 73/2 73/5 73/8
43/11 47/2 51/16 communities [1] conduct [2] 23/25 contingency [1] 73/13 73/14 73/19
51/17 56/14 56/18 60/20 44/16 112/1 73/22 73/23 74/7
87/5 62/19 64/18 65/7/coMMunity [1] 60/9 Iconducted [7] 12/25 Icontinue [7] 61/16 I 81/14 85/17 86/19
65/23 66/3 67/10 company [7] 2/18 13/4 19/25 23/5 32/23) 62/17 80/21 92/9 87/20 95/3 95/4 98/18)
67/13 74/14 74/18 2/20 10/24 54/21 94/3 118/1 92/25 93/4 99/1 107/10 107/11 108/23)
77/24 80/11 80/17 56/16 83/2 130/15 conducting [2] 24/7 Icontinued [6] 1/3 1/4I 113/12 113/15 114/6
82/15 85/3 86/4 102/5 company's [1] 18/2 I 84/21 57/3 115/1 138/2 118/23 122/12 129/2
102/14 103/14 103/22! compartmentalise [1]I conference [1] 138/4 129/7 131/9 135/3
1404/25 107/18 107/21 124/17 102/19 continues [2] 21/19 Icorrection [1] 133/17}
1409/12 117/8 124/7 compartmentalising Iconfidence [8] 87/12) 35/11 corrections [1] 49/3
1279 [1] 125/7 95/8 97/10 97/13 continuing [3] 94/17 Icorrespondence [12]
comes [5] 14/18 compensation [27] I 97/22 99/20 102/8 115/3 129/13 55/4 55/10 55/25
51/14 66/20 109/14 2/12 2/16 2/19 2/24 I 103/9 contract [7] 46/3 56/8 56/11 56/13
109/23 3/2 3/10 3/13 3/18 4/7I confident [3] 64/12 I 47/7 50/20 50/21 56/15 58/5 59/21 72/1
comfortable [1] 4/10 4/14 5/1 5/4 6/1 I 98/17 118/4 51/13 129/13 132/9 134/17 134/20

427/11 6/12 6/19 28/2 60/24 Iconfirm [4] 29/11 contractor [1] 131/3 I corroborate [1]
coming [5] 13/17 63/5 63/7 66/7 72/6 I 30/20 31/3 108/21 Contracts [1] 98/16 I 28/19
S711 BG/12 1085/2 I 73/21 79/13 121/5 I confirmed [4] 105/11Icontractual [2] 49/12Icost [10] 88/21 89/1
1314/7 121/16 124/1 107/10 107/16 108/16) 50/12 91/22 93/14 123/25
comment [3] 75/14 compensation-relate Iconfirms [1] 61/14 Icontributed [1] 2/13 I 125/15 127/2 127/12
77/16 106/5 d [1] 2/19 conflict [5] 7/7 7/9 Icontrol [1] 98/6 127/25 128/13
comments [6] 14/5 compiled [1] 65/4 8/3 8/20 9/10 convenient [1] 30/25 I costs [9] 89/17 91/10
20/2 20/21 28/25 64/4Icomplained [1] conflicts [2] 7/6 8/22 conveniently [1] 81/6] 91/17 91/18 92/9
101/25 116/15 conscious [4] 7/11 Iconversation [3] 92/10 93/5 124/1
commercial [4] 2/17 21/4 22/17 46/24 34/20 128/3 130/9 124/2
7/14 7/19 93/19 complaints [4] 28/12 Iconsensus [1] conversations [3] could [24] 5/15 7/21
Commission [4] 29/5 120/14 121/18 103/25 83/21 97/11 126/15 I 10/9 22/16 33/2 36/20
23/13 104/19 105/13 [complete [1] 3/20 consequence [5] converted [1] 19/3 39/15 45/10 51/10
1406/7 completed [1] 130/4 I 28/4 40/15 65/13 convey [1] 82/9 58/10 79/21 88/14
completing [1] 48/25I 125/3 127/2 convicted [10] 22/13 I 88/22 98/6 103/18

(40) clearly... - could
INQ00001195

INQ00001195
Cc 19/11 68/1 94/17 95/9I decades [2] 34/14 I 117/10 didn't [15] 6/18 8/6
could... [9] 103/21 I 99/24 127/18 depth [1] 82/2 8/24 20/11 30/7 58/20)
407/24 110/22 1423/4 current [11] 9/13 deceased [1] 31/17 Idescending [1] 64/2 76/17 106/6
423/13 130/18 130/19] 32/9 32/20 36/15 69/8) decide [4] 6/8 58/12 I 119/23 110/11 111/22 119/9
130/20 134/24 70/8 79/7 100/22 58/18 58/20 describe [5] 14/25 121/24 136/1 136/21
couldn't [1] 16/13 I 101/13 101/16 107/8 Idecided [3] 3/14 58/23 72/7 92/25 differ [2] 5/7 43/16
counsel [11] 58/7 ISurrently [5] 36/10 I 58/20 127/24 109/24 difference [2] 6/21
58/9 68/22 59/1 59/3 I 38/10 41/17 74/9 deciding [1] 7/25  Idescribed [6] 15/18 I 96/2
59/4 59/4 59/12 94/16I 83/19 decision [16] 3/21 I 29/13 43/3 45/7 85/22I different [22] 5/16
134/22 135/5 customer [1] 33/3 I 4/22 7/20 13/11 14/24) 116/6 5/22 5/23 8/10 8/11
count [2} 51/20 51/21Icustomers [1] 94/9 I 15/15 15/24 24/9 56/9I describing [2] 60/12 I 8/13 9/25 22/22 39/25}
Counter [1] 69/12. {cut [1] 93/5 85/25 102/15 107/17 I 105/23 40/3 40/6 45/25 59/5
counterparts [1] cycle [1] 46/18 123/17 130/14 132/12Idescription [1] 14/14] 87/8 90/25 91/4 94/13
20/21 D I 132/14 design [3] 4/17 97/10 126/18 126/19
couple [10] 7/1 7/2. I;>——> 7 decision-making [2] I 125/25 126/7 129/10 131/6
7/3 39/5 47/23 82/6 IDar [2] 113/17 15/15 15/24 designing [1] 127/18 I difficult [15] 9/3
94s 11410 118/13 I 113/25 decisions [10] 7/16 Idesire [2] 71/6 93/22 I 12/20 14/22 14/23
133/15 dark [1] 43/12 13/19 15/4 15/16 desk [1] 70/2 15/17 33/16 37/25
course [10] 25/2 39/1I4@hboard [1] 15/25 16/20 85/14 Idespite [2] 104/15 I 42/7 46/13 77/15
50/6 54/7 76/20 98/24I 130/22 99/10 126/8 127/21 I 110/11 81/16 81/16 118/10
data [9] 31/21 33/15 10 127/19

decrease [1] 69/14 [destructive [1] 29/8
103/24 106/12 113/20) 35/3 35/4 38/3 55/1

1435/3 dedicated [2] 2/24 detail [9] 26/10 75/14 / difficulties [3] 75/23

56/18 78/4 99/9 68/20 77/16 106/11 108/6 I 76/4 119/20
come 21/18 22/14) database [1] 38/21 Ideductions [1] 117/4I 108/10 110/17 114/18I difficulty [2] 87/2
courts [4] 54/5 54/5 databases [1] 78/23 Ideemed [1] 45/11 123/12 10

54/14 72/20 date [8] 61/10 61/13 Ideeming [1] 108/14 Idetailed [1] 137/7 ital [1] 93/2

4] 99/9 61/22 88/2 88/15 deeply [2] 52/22 details [1] 78/13 direct [2] 95/13

cover Ut] 4) 136/10 I 88/17 88/18 115/8 I 52/22 determination [4] I 120/12
Soyer Et ta6id I [dated [2] 14/12 61/8 Idefects [1] 98/13 I 64/6 directed [3] 60/19
Covid [1] 62/2 dates [1] 46/6 definitely [2] 69/25 Idetermine [3] 11/1 I 67/8 112/7
Govid-19 [1] 62/2 Idaughter’s [1] 89/8 22/3 37/23 direction [7] 8/1
created [1] 2/20 115/17 definition [3] 7/13 Idetermined [5] 3/11 I 32/11 63/11 63/14
creating [1] 56/17 IDavies [6] 18/5 18/9 I 35/1 130/25 5/3 7/15 27/3 86/10 I 64/9 83/17 107/19
crime tl 24/19 18/23 29/1 30/1 definitive [1] 33/11 Idetermining [1] 7/25 directions [1] 98/14
110/15 113/10 degree [3] 4/19 20/19Idetriment [2] 74/16 I directly [4] 18/7
crimes [1] 107/25 IDavies' [1] 18/14 56/24 74119 101/19 107/25 109/22

iminal [19] 23/10 I98¥(7] 1/13 1/13 Idelays [2] 89/17 I develop [4] 21/3 62/3I director [6] 1/21 21/1
Sate oe 2 7. I 34/9 37/21 66/9 80/10] 125/16 67/20 67/20 21/2 54/20 82/24
26/19 54/4 54/14 90/13 deliberations [2] developed [2] 126/12] 96/13

54/23 58/6 58/9 58/10/08 2[1]_1/13 136/5 137/3 128/17 Directors [7] 8/16
58/18 72/14 72/19 IayS [7] 71/1 80/7 _— I deliver [6] 2/24 3/18 Ideveloping [1] 18/3 I 9/21 10/6 12/18 13/1
76/22 104/19 105/7 I 100/9 106/12 113/5 I 87/16 93/1 96/12 development [5] 82/1 101/17

105/13 106/7 118/13 137/8 132/3 88/21 89/6 89/19 disabled [1] 20/10
criminality [2] 109/20] DBT [3] 83/21 84/1 I delivered [1] 4/7 116/16 126/17 disagree [1] 12/23
T10/9 84/10 delivery [1] 89/22 Idevelopments [1] _ I disagreement [1]
crisis [1] 16/20 deaf [1] 27/25 demonstrating [1] I 93/3 52/10

iteria [8] 9/15 9/18 I 42a! [18] 16/13 55/11) 35/13 Devereux [1] 18/16 I disappointing [1]
omens 10/20 I 08/25 70/23 70/24 den [1] 96/23 devoted [1] 31/25 I 20/19

44/4 11/6 12/22 71/10 76/22 77/12 Idenial [1] 111/24 IDHL [14] 92/22 disclosed [2] 55/24

93/23 96/5 96/18 density [1] 71/22 Idiagnose [1] 78/22 I 59/11

SO ined [17 9) 96/25 101/6 102/8 I department [19] 2/14Idid [43] 1/11 8/7 8/25I disclosure [6] 55/18
113/20 102/9 102/10 119/17 I 3/6 4/9 63/4 64/22 I 12/17 17/11 18/18 _I 59/8 59/16 78/20
crossreferences [1] I 112/19 72/10 72/12 73/3 75/7I 18/21 26/8 28/11 105/21 108/20

10/14 dealing [7] 59/5 78/7 78/8 78/9 78/15 I 29/20 30/4 34/14 58/4I discovered [2] 26/2
Grown [7] 100114 I 72/18 74/5 84/17 78/16 90/14 125/8 I 58/12 58/18 58/25 I 78/3 :

104/24 105/13 106/8 I 12/6 122/16 122/16 I 126/6 127/23 134/19 I 59/6 59/18 59/22 63/2I discrepancies [7]

deals [3] 72/13 83/8 Idepartments [1] 65/7 90/24 93/10 35/21 38/10 38/20
ue toy 02/3 oa. 129/9 98/16 93/11 95/20 99/25 I 39/1 41/1 47/13 52/5
crumbs [1] 69/23 I@e2tt [2] 74/2 80/10 I deploy [1] 89/2 101/20 102/17 105/6 I discrepancy [10]
cudgel [1] 55/9 Dear [6] 27/4 133/24 I deployed [2] 41/2 106/10 106/11 106/21] 36/25 37/18 38/15
cultural [4] 12/10 135/16 136/6 136/7 I 92/19 108/22 111/19 113/2 I 38/17 39/18 39/20
20/14 20/15 95/1 136/20 deployment [1] 113/6 116/1 124/3 I 49/19 50/3 52/11
culture [6] 17/24 debacle [1] 74/1 126/3 124/6 124/18 1134/7 I 74/14

debate [1] 102/2 depression [2] 115/3I 134/10 135/25 discuss [7] 28/18

(41) could... - discuss
INQ00001195
INQ00001195

D

discuss... [6] 70/11
71/15 98/25 109/14
118/12 120/20
discussed [16] 1/12
3/5 3/9 6/6 10/1 14/17,
22/18 22/22 29/20
36/3 39/3 56/4 64/17
69/18 84/5 86/3
discussing [3] 28/21
59/16 77/25
discussion [5] 24/10
55/17 98/13 102/3
109/18

discussions [6] 2/10
2/14 69/5 96/19
101/23 109/5
disgrace [2] 102/25
103/5

dismiss [1] 48/3
dismissal [1] 29/8
display [3] 10/12
17/3 17/21
displayed [2] 13/22
24/23
dispute [14] 35/19
36/12 36/13 36/14
36/15 36/17 37/4
39/21 40/20 40/22
44/4 47/25 52/9 52/16
disrespectful [1]
103/1

disrupt [1] 132/5
disrupted [1] 83/6
distance [2] 71/19
72/2

distancing [1] 136/16
distinct [1] 126/4
distinctions [1]
126/24

distinguish [1] 14/22
distraction [2] 28/4
28/18

diverse [1] 19/16
diversity [4] 19/14
19/21 20/23 21/2

do [102] 5/7 6/8 8/9
14/14 17/7 17/8 24/25)
25/6 25/11 25/24
26/18 26/25 29/14
32/7 34/7 35/14 35/16)
35/17 36/7 36/16 38/4,
38/25 39/9 39/16
40/17 40/20 41/25
42/23 42/24 45/4 45/4
45/6 48/5 48/13 48/21
50/24 51/6 51/19
51/21 52/18 52/19
54/6 55/21 55/22 59/8)
61/1 65/11 65/14 67/2
67/3 67/20 69/14
70/19 72/3 72/5 73/18)
75/11 75/19 76/12

77/14 78/20 78/20
79/6 79/16 80/8 80/20
80/23 81/25 84/2 84/8
85/5 87/2 88/19 90/23
91/10 94/6 94/13 99/1
99/9 101/21 103/20
103/21 104/1 104/10
106/17 109/25 110/11
110/11 113/18 113/19)
113/23 114/5 114/6
124/4 127/6 129/13
129/14 132/5 132/13
133/1 133/10 136/1
document [24] 43/6
43/8 43/18 45/25 46/1
47/3 48/22 55/17
56/13 57/6 58/25
59/17 65/4 75/6 76/17
98/2 100/1 101/18
123/1 127/9 128/18
128/20 129/11 129/15)
documentation [2]
8/21 76/19
documents [18] 3/24
8/19 43/10 43/19 46/5
47/19 48/9 49/14 67/1
67/6 67/7 67/11 68/7
68/8 68/22 94/15
120/23 122/23
does [13] 10/2 37/4
37/5 44/12 45/8 45/23
53/7 62/12 77/18
84/24 107/18 108/12
108/23
doesn't [10] 14/9
37/22 38/12 45/22
75/21 77/2 100/5
118/17 122/9 132/5
doing [16] 38/3 39/25
52/1 53/2 53/2 53/3
54/17 63/7 68/7 71/3
80/2 82/4 86/18 91/22
103/11 136/24
dominated [1] 19/18
don't [91] 5/18 8/7
8/19 8/21 10/6 11/11
13/11 13/25 14/16
15/23 16/3 16/9 24/6
24/8 25/1 25/7 25/10
26/10 26/17 27/1 27/1
27/6 27/6 27/10 27/11
27/23 28/15 28/17
28/18 32/3 33/10 35/3
39/7 39/11 39/14
39/17 39/17 39/19
40/4 40/12 40/22
42/21 43/15 45/4
51/15 51/17 56/7
56/18 56/20 56/24
57/9 57/23 59/1 59/10
59/22 60/4 63/8 66/5
66/25 67/6 67/12 71/2
71/4 74/10 75/14
76/11 78/13 78/24

79/23 80/7 83/15
88/10 88/16 89/2
89/21 90/23 91/2 94/6
103/5 105/25 106/5
106/11 107/21 108/6
109/1 115/7 116/2
119/2 123/7 127/17
131/25

done [28] 7/2 9/21
10/9 21/15 23/1 23/7
36/21 37/20 37/20
41/9 42/16 45/17 48/9
48/15 51/7 65/2 71/17
77/14 80/24 82/5
83/12 91/9 95/22
95/22 99/16 114/4
116/10 137/2

door [2] 45/9 104/24
doubt [5] 54/16 75/10!
75/12 75/17 76/13
dovetail [2] 64/17
88/9

down [23] 6/25 13/13
21/14 24/20 25/4 25/9
31/10 34/11 43/22
47/9 47/12 48/3 78/12
95/24 98/19 101/18
102/14 107/21 113/25
117/2 124/11 129/19
135/22

downstairs [1] 117/5
DPD [1] 92/22

Dr [2] 31/23 34/13
Dr Linnell [2] 31/23
34/13

drafting [1] 66/20
drama [4] 29/6 80/15
98/6 98/10

dramatic [1] 71/5
draw [2] 70/16 126/5
drawn [2] 17/1
134/12

dream [1] 111/21
drew [2] 134/1

135/21

drive [5] 64/13 91/15
92/14 93/6 93/18
driver [3] 28/24

64/11 92/2

drivers [1] 91/13
driving [1] 66/7

dual [1] 8/10

duality [2] 7/23 8/6
due [5] 23/25 86/21
87/21 109/15 132/9
Durham [2] 115/16
115/17

during [19] 2/10 14/8
17/25 18/10 25/2 45/9
49/21 50/5 88/6 91/9
96/4 113/20 115/20
120/9 120/12 120/21
120/22 121/18 122/6
duties [2] 105/21

108/20

E

e-training [1] 82/18
each [3] 66/22 67/2
67/3

earlier [10] 64/14
75/22 76/3 81/12
93/23 94/3 102/4
105/10 107/16 108/13)
early [4] 76/1 117/9
122/6 126/14

earn [1] 69/21
easier [2] 102/5
102/7

easily [1] 33/2
easy [1] 102/14
echo [1] 44/9
economic [1] 60/8
economically [1]
60/20

EDI [1] 21/3
education [1] 83/6
educational [1] 83/17I
Edwards [1] 96/11
effect [4] 6/11 6/12
81/23 95/13
effective [1] 72/3
effectively [3] 12/21
52/11 86/10
effectiveness [1]
15/2

efficiently [1] 122/16
efforts [1] 34/11
eight [1] 115/10
either [5] 9/9 15/16
49/3 54/13 103/24
elected [2] 18/25
61/7

election [3] 12/21
64/7 64/7
electronic [1] 76/2
electronically [1]
27/9

elements [4] 4/7 5/16)
20/23 110/15

Elliot [3] 9/4 10/1
46/22

else [2] 51/22 56/23
else's [1] 117/3
elsewhere [1] 13/20
email [6] 17/1 27/10
59/10 100/2 101/21
102/17

emails [2] 96/14
102/5

embarked [1] 125/24
embarrassing [1]
20/3

emerged [3] 20/8
120/21 120/22
empathy [1] 41/9
emphasis [1] 112/4
employed [2] 31/22

118/8

employees [8] 67/9
98/12 100/10 100/14
100/16 100/17 100/22)
101/13

employing [1] 92/21
employment [1]
99/14

enabled [1] 2/22
encountered [1]
114/22

encourage [1] 99/1
encouraged [1]
82/12

encouraging [1]
22/20

end [8] 37/20 37/21
41/5 42/14 42/15 49/1
62/12 132/20
endeavour [1] 33/17
enforcement [7]
54/23 55/2 108/3
109/21 110/4 110/9
110/14

enforcing [1] 36/5
engage [3] 36/1 42/9
106/6

engaged [6] 23/11
65/14 84/4 105/12
105/24 130/19
engagement [5]
52/20 56/20 96/13
104/18 110/4
engaging [1] 71/12
engineered [1] 11/6
England [5] 104/19
104/25 105/8 106/15
106/19

enormous [4] 15/13
24/9 107/17 122/11
enough [1] 105/22
ensure [6] 92/14
99/10 108/18 109/19
121/23 126/17
ensuring [1] 115/23
enthusiasm [1]
64/12

entire [2] 15/9 57/13
entirely [2] 62/23
63/2

entirety [1] 59/11
entitled [1] 79/12
entrepreneur [1]

entrepreneurial [1]
83/7

entrustment [1] 60/5
environment [1] 62/1
envisaged [1] 88/3
EPOS [1] 126/23
equity [2] 20/23 21/2
era [1] 96/5

Ernst [1] 13/4

error [4] 44/2 44/25

(42) discuss... - error
INQ00001195

INQ00001195
E exactly [8] 11/25 explain [3] 56/22 _I familiar [5] 21/9 121/11 123/4 125/1
error... [2] 45/7 47/14 45/22 65/18 75/20 134/20 136/18 21/10 79/8 88/19 94/1} 129/12
errors [1] 98/14 103/11 124/20 128/17Iexplained [4] 58/1 _I familiarity [1] 43/10 I firstly [4] 17/23 18/18I
especially [1] 89/20 137/2 97/6 116/6 116/8 families [5] 32/2 130/18 136/12
essential [2] 108/19 examination [1] explaining [1] 75/23 I 82/11 82/22 83/12 Fiscal [3] 23/13
121/25 112/8 explanatory [1] 83/24 108/1 109/17
essentially [22] 22/9 I@xamined [2] 113/20] 135/17 family [4] 83/4 83/24 Ifit [4] 89/4 93/11
40/9 40/18 41/19 120/23 explicit [3] 48/4 84/25 85/4 108/15 132/4
47/20 47/21 48/10 examining [1] 112/5 I 67/21 67/21 far [5] 34/10 71/19 I five [15] 1/21 14/20

50/8 56/17 60/24 example [13] 4/4 explicitly [1] 97/17 I 105/11 107/10 107/11] 16/18 16/25 63/21
61/15 63/25 65/24 29/5 45/8 45/10 60/12Iexploded [1] 28/3 _Ifeature [2] 27/19 79/3 96/3 107/20

60/17 74/21 77/20 Iexpress [2] 99/15 I 28/13 113/5 113/7 113/14
Oe oe ome ean 77/23 11217 113/2 I 135/6 February [2] 11/15 I 130/1 132/10 133/5
1432/8 136/11 127/14 131/15 expressed [4] 15/6 I 134/16 133/20
established [5] 5/22 I°xcess [1] 99/8 17/5 18/12 133/12 Ifeedback [6] 15/9 _ I five-year [1] 96/3
30122 23/19 72/24. \exchange [2] 17/2 Iexpresses [1] 136/15) 21/4 89/7 90/2 120/8 Ifix [2] 40/1 114/3
88/6 1719 expression [2] 61/2 I 120/12 flawed [1] 130/8
establishment [1] I@XChanged [1] 30/1 I 70/23 feel [4] 13/10 35/15 I flowing [1] 3/19
exclude [1] 11/7 __Iextended [1] 88/8 I 39/11 119/9 focus [6] 2/22 12/1
et [1] 135/23 excluded [2] 9/5 9/7 extensive [1] 96/16 Ifeeling [3] 69/9 70/5 I 12/1 112/3 112/20
et cetera [1] 135/23 I@xclusively [1] 42/19 Iextensively [3] 10/4 I 82/3 132/19
European [2] 54/20 [excuse [2] 9/9 85/7 I 14/17 113/6 fell [1] 34/19 focused [3] 63/5 66/7I
Boio4 executive [21] 1/21 Iextent[1] 125/12 I felt [8] 9/4 15/12 20/3I 129/23
even [8] 4/20.42/6 I 8/16 9/21 10/5 12/17 lexternal [7] 17/10 I 20/15 22/24. 40/15 folk [1] 51/25
42/25 47/21 76/3 94/6I 13/1 14/9 14/15 16/7 I 21/15 32/17 118/14 I 99/2 137/1 follow [5] 47/18 71/4
124/11 1341/5 16/8 16/11 19/14 121/3 128/16 130/4 Ifemale [3] 17/13 99/11 109/2 133/18
event [2] 4/23 5/24 I 19/18 19/20 26/16 externally [1] 130/11] 17/16 18/11 following [11] 4/16

events [1] 100/9 55/15 57/18 82/1 extra [2] 60/10 65/23 Ifence [2] 5/16 124/16] 20/6 21/22 52/13
eventually [3] 88/14 82/13 95/17 101/17 Iextremely [4] 22/17 Ifencing [1] 125/6 52/14 78/5 90/10

105/6 117/5 Executives [2] 11/24 I 33/16 34/25 69/16 —_Ifew [3] 21/6 46/2 94/25 98/5 116/21

ever [1] 54/12 46/21 EY [4] 13/5 100/9 131/13

every [3] 38/16 94/9 exercise [1] 21/20 rF.... Fifteen [1] 53/13 footfall [1] 92/14

96/19 exist [1] 108/18 ___Ififth [3] 18/9 22/16 Iforced [1] 117/1

everybody [2] 28/5 existence [2] 47/19 Iface [2] 62/1 122/18 I 47/12 forcing [2] 35/23

35/4 85/12 faced [1] 2/23 figure [3] 32/21 33/9 I 52/17

everyone [2] 66/21 exists [1] 45/21 facing [6] 13/14 53/8 foremost [3] 7/12

66/22 exit [2] 12/25 13/3 I 98/17 100/18 103/2 I figures [1] 52/25 97/2 112/15

everything [1] exiting [1] 15/18 118/5 119/25 final [5] 21/7 32/9 _ I forensic [3] 31/23

113/23 exoneration [4] fact [30] 15/25 21/5 I 94/12 102/23 127/8 I 32/17 33/13

evidence [45] 1/14 I 22/11 1356/9 135/11 I 23/1 26/7 26/20 31/23} finally [2] 61/24 forgive [3] 37/16

1/15 2/2 10/14 10/15 I 135/19 33/11 41/23 43/14 I 74/23 54/10 108/9

24/25 22/4 39/5 45/3 IexPect [4] 7/23 16/23] 46/14 47/3 51/16 I financial [3] 8/7 74/5 Iform [7] 22/7 24/8

55/8 56/10 56/11 64/15 67/13 61/14 62/14 67/2 92/18 74/19 84/7 84/7

56/12 57/7 57/8 57/10IexPectation [1] 12/6 I 68/15 68/20 95/25 financially [1] 83/2 I 115/22 116/3

64/24 64/25 65/1 65/8) xPectations [2] 96/17 102/25 106/4_Ifind [11] 27/13 38/2 I formal [4] 24/5 24/10
9/23 10/3 106/12 108/8 110/11 I 38/10 46/15 48/10 I 24/13 29/7

gan3. aoe aoe 5/10I expecting [1] 16/11 I 117/15 123/16 128/2 I 76/17 96/22 102/11 formed [2] 86/15

95/16 95/18 95/23 ~—«IexPensive [2] 124/23 130/2 134/4 134/11 I 127/11 132/24 136/4 I 101/22

96/10 102/1 102/16 I 124/28 factor [1] 4/2 fine [8] 31/2 53/17 __Iformer [1] 96/11
104/17 106/2 107/7_ I@xperience [3] 15/19 failed [1] 90/20 61/3 79/1 86/20 104/6I formulated [2] 86/8
409/20 111/13 115/20 74/21 116/6 failing [2] 90/21 99/2 I 119/12 119/22 86/8
128/21 128/24 131/13] experienced [8] 12/5 failings [1] 105/20 Ifinish [1] 37/16 forum [2] 36/5 89/5
131/14 131/16 137/8 I 16/10 20/20 23/7 fails [1] 101/15 finishing [1] 54/25 I forums [2] 19/22
evident [1] 8/18 74/18 89/11 120/11 Ifailure [3] 63/24 firm [5] 97/6 124/4 I 89/25
evidential [5] 75/2 I 131/17 94/19 109/15 127/21 132/12 132/14] forward [17] 5/12
75/8 75/15 75/16 76/4) experiences [2] failures [1] 108/17 firms [1] 80/25 10/10 10/22 10/23
evolution [1] 126/15 I 12/13 1167 fair [9] 42/3 44/3 first [28] 7/4 7/12 16/15 22/21 55/17
Evri [4] 92/22 experiencing [2] 46/12 63/6 79/9 80/1 I 9/20 15/6 15/12 16/4 I 59/17 62/4 64/23 66/8
ex [2] 48/1 48/5 20/2 76/6 88/24 112/6 117/24 I 16/18 19/7 19/10 66/15 70/25 74/14
ex-postmaster [1] I°xPert [2] 25/17 fairly [2] 30/20 106/1 I 20/10 21/13 23/17 I 74/18 80/11 80/17
mop Npenise [3] 81/4 [fal] 101716 I ecnosenteria teena ty BI 1410
expertise al found [3)
crepe otmasters (1 I s1/9 13017 false [2] 115/24 101/2 104/13 105/4 aria I ,
expired [1] 29/8 116/5 108/3 112/15 116/24 Ifour [12] 14/20 17/15

(43) error... - four
INQ00001195

INQ00001195
F future [8] 61/23 24/21 29/25 34/10 63/24 64/13 64/15 83/10 83/13 84/21
four...[10] 30/12 65/25 70/11 112/3 39/5 43/17 45/21 65/3 65/4 65/5 65/14 I 85/18 88/3 90/15
16 113/23 114/5 127/17 I 45/25 46/17 46/24 65/24 66/3 66/12 69/5I 90/18 93/16 93/18

65/16 65/16 94/2

1
1

13/5 130/2 130/3
31/10 131/11 137/6

fourth [2] 134/1

1
fr

35/21
‘amework [2] 61/23

61/25

fr

ankly [2] 67/12 71/7I

Fraser [4] 54/8 54/10
85/18 96/11

Fraser's [1] 73/10
Freehills [1] 3/7

fre

‘equently [1] 46/12

Friday [1] 1/1

fri
2

iends [2] 29/21
9/24

front [5] 4/12 64/5

9.

front-facing [1] 103/2I

fr
2
3

3/25 103/2 116/11

ustrated [9] 12/19
8/17 29/10 29/10
0/6 34/23 34/24 63/8)

99/4

fr
3
fr
3
3

ustrating [3] 29/17
5/15 80/21
ustration [5] 29/17
3/19 33/20 35/5
5/17

Fujitsu [15] 54/21
54/22 56/14 56/16

5!
8.

9/7 82/24 83/1 83/10)
3/14 84/16 84/22

84/24 92/1 129/13

1

32/8

fulfilling [4] 130/15
full [5] 23/23 56/7

65/14 85/19 126/22
Her [1] 65/4

Hy [13] 4/22 33/15
5/5 47/16 64/15 86/8)
6/8 86/15 89/18 92/6)
07/9 112/13 135/10
nection [4] 14/14
9/4 107/8 109/25
inctionality [1]
26/13

inctioning [1] 19/17
ind [1] 90/16
indamental [1] 67/3
inding [12] 60/10
3/16 63/17 65/4 86/4
23/18 123/21 123/23)
24/9 125/7 127/24
29/25

nds [2] 34/16 51/21
rore [2] 27/24 28/3
rther [12] 13/13
2/2 44/12 47/9 55/6

ful
‘fu
3
8
1
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4
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1
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1
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2

92/7 119/10 119/11
123/13 124/11 133/21
138/14

132/4

G
gained [1] 30/2
Gallafent [2] 58/25
59/3
gaps [1] 75/2
gave [12] 1/16 2/2
11/12 18/10 55/7
56/10 57/7 82/25 96/9
112/12 128/24 131/12)
GE [3] 13/24 14/2
16/1
general [9] 26/16
58/7 58/8 58/22 59/12
60/8 118/24 120/1
121/17
generally [4] 19/2
26/18 119/17 119/19
generated [1] 41/1
genesis [3] 27/1
39/19 120/13
genuine [2] 14/24
112/14
genuinely [1] 9/10
get [33] 8/19 14/23
20/12 27/10 39/24
40/10 40/24 41/20
42/5 42/7 52/25 59/14
63/11 64/6 64/16
69/22 71/24 72/5 76/6
77/12 79/20 80/16
83/11 89/12 95/21
99/13 107/4 117/7
123/13 124/21 125/12)
128/14 133/7
gets [2] 31/1 52/11
getting [9] 10/8 12/13
20/16 62/12 71/25
87/12 89/10 89/15
89/22
give [16] 3/25 10/11
16/14 17/7 17/19
25/10 53/10 74/21
75/9 95/8 96/6 99/13
99/20 114/18 118/16
132/22
given [16] 4/6 5/24
6/20 7/23 30/5 58/1
TAIT 73/24 75/1 75/12
76/13 93/8 94/1 98/14
102/24 122/18
giving [6] 48/23
56/12 65/1 65/8 79/10
137/7
GLO [15] 2/16 3/19
4/4 4/5 4/16 4/17
31/13 72/9 74/23 95/1
113/3 113/17 113/20
115/9 122/7
go [38] 8/19 13/7

48/10 48/21 49/13
51/2 52/16 57/21 58/3
59/6 59/23 61/9 76/3
83/5 92/7 116/20
119/11 119/16 123/4
123/7 123/12 124/3
124/11 126/14 128/18
132/3 133/3 136/1
136/1
goes [11] 26/13 33/5
35/3 35/4 36/17 37/25
69/24 75/25 81/10
101/9 101/14
going [64] 4/24 12/2
12/9 17/3 17/20 20/25
21/13 29/25 30/19
33/15 33/19 34/7
34/13 36/3 43/6 47/20
49/6 49/8 49/9 54/4
55/8 55/10 57/11
57/12 57/15 58/14
64/13 65/25 69/6
69/19 70/17 70/18
72/7 73/20 77/17
79/14 81/21 81/25
84/16 86/22 89/1 89/3
90/1 90/4 91/10 93/7
94/13 94/14 96/6 96/7
97/7 102/3 103/6
106/4 119/10 119/15
124/15 124/18 126/17
126/22 127/10 127/21
128/11 131/23
gone [9] 32/14 32/19
32/19 34/2 41/8 56/3
57/23 99/5 112/5
good [20] 1/5 1/8 1/9
5/11 5/15 6/24 36/6
52/17 57/14 83/11
84/23 84/25 85/3 85/6
87/1 96/18 104/9
111/3 111/7 130/14
got [28] 12/19 26/11
26/14 30/12 31/10
33/9 33/18 34/4 37/22
42/12 46/14 47/4
50/11 51/6 53/1 56/18
61/22 66/12 72/8 91/1
103/14 119/12 121/2
125/4 126/11 132/10
133/15 136/7
governance [5] 2/8
26/12 101/12 101/15
130/14
government [47]
2/21 3/14 5/5 5/25
6/21 22/10 60/6 60/10
60/24 61/4 61/15
62/14 62/15 62/24
62/25 63/9 63/13
63/17 63/20 63/24

70/1 77/3 77/5 77/15
78/7 78/8 82/11 86/4
90/18 124/7 128/13
128/16 134/25 135/9
135/10 135/19
Government's [1]
62/24

Grange [1] 115/19
grapple [1] 14/19
grateful [2] 61/19
137/9

Gratton [5] 1/25 17/2
17/5 56/6 123/10
Gray [2] 55/17 55/24
Greany [1] 59/3
great [6] 35/5 43/4
82/7 93/16 107/22
123/14

greater [1] 20/3
Greenhow [6] 95/17
95/24 98/3 100/2
101/19 102/20
Greenhow's [1] 90/5
grievance [1] 29/7
grievances [3] 18/25
27/18 28/11

ground [2] 69/21
70/4

group [20] 7/16
14/15 16/6 16/8 16/10)
19/18 19/20 19/20
31/9 31/11 31/12 32/6
32/9 55/15 68/19 72/9)
73/1 82/13 100/21
101/4
groups [1] 71/14
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hall [1] 103/25
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96/18 96/24 98/8 36/7 39/22 45/22 123/18 husband [1] 117/5 33/10 39/17 39/17
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50/17 50/21 51/11 35/24 37/24 38/19  Ijudgment [9] 21/22 Ikeys [1] 39/4
54/13 78/21 78/22 39/9 39/11 39/23 85/18 104/23 105/18 Ikind [2] 27/10 80/5
84/1 84/9 98/15 116/8I 40/19 42/5 42/6 42/15] 111/16 111/17 111/25I King's [4] 59/1 59/3

i i 121/19 43/8 45/20 46/13 47/4) 112/11 112/12 59/4 59/4
instruction [3] 6/7 investigations [7] I 48/19 53/25 57/12 Ijudgments [5] 54/8 Iknew [3] 11/25 12/5
instrumental [1] 90/2I 95/19 5813 59/17 I S7/17 61/12 63112 I 73/10 94/28 111/23 I 90/11
insult [iy 121/19 I 99/2059/25 73/11 I 65/18 66/2 69/19 71/3) 112/13 know [46] 1/18 4/3
integral [1] 121/23 I 110/1 74/13 74/22 77/7 _Ijudicial [1] 22/5 23/3 24/25 25/6 25/7
intend [1] 30/3 investigative [5] 99/8I 77/15 79/9 80/2 80/6 IJuly [2] 3/17 5/8 I 25/11 26/10 26/19
intended [ty 102118 I 29/16 102/11 107/8 I 80/21 84/3 84/24 Bs /eljuncture [1] 16/9 I 26/26 27/1 27/6 27/6
intention [2] 132/1, I 109/25 86/23 87/17 88/7 __IJune [15] 2/3 5/8 —_I 34/5 35/11 35/17
weort Investigators [3] I 88/23 88/24 89/3 I 18/24 19/4 55/16 I 38/11 40/12. 41/8
interest (31 5/19 9/7 I 119/23 117/12 117/13] 92/24 9315 94/10 I 85/24 58/16 59/14 I 41/15 42/20 48/17
60/8 investment [6] 93/12I 94/12 94/20 98/24 I 59/14 65/19 123/2__I 54/19 55/5 55/7 56/6
interesting [1] 78/5. I 125/8 129/18 129/20 I 99/3 99/12 102/14 I 123/24 129/3 130/1 I 57/9 87/23 59/10
interests [3] 6/23 I, 129/22 130/22 102/15 103/5 106/3_ I 134/5 60/18 66/5 71/12 79/6
174 17/24 invite [1] 97/12 107/16 107/19 109/3 IJune 2024 [1] 130/1 I 79/11 79/12 79/23
interfere [1] 28/13 IiAvolve [2] 13/25 I 109/12 110/8 110/9 jurisdiction [1] 80/7 81/15 84/20
interfered [1] 27/20 I 21/24 117/22 121/10 126/10I 110/10 _ 87/23 88/17 102/17
interference [1] 74/2 involved [22] 7/21 131/21 131/25 133/24I jurisdictions [2] 106/3 118/17 123/21
59/23 78/10 78/11 its [25] 3/8 22/13 I 110/6 110/8 127117

Interim [4] 58/21
65/13 129/1 129/4
internal [4] 3/15 67/9
98/13 130/13
internally [5] 67/17
68/1 98/8 98/11

82/11 86/5 89/5 90/17) 23/12 23/25 24/2 just [55] 3/20 4/24 I known [3] 3/16 19/17
94/21 97/19 98/13 24/13 61/4 67/17 7/1 13/7 13/13 13/19 I 33/12

100/16 100/25 101/7 I 73/12 79/11 81/22 13/21 14/21 16/11 knows [1] 27/11
103/1 103/3 118/4 81/23 87/11 94/19 23/10 24/18 24/21 KPls [1] 78/19

120/3 120/16 121/7 I 100/13 105/20 107/14} 26/25 30/20 31/9 KPMG [1] 33/13

130/11 132/21 133/7 107/23 108/24 122/14I 39/12 40/20 42/25 I Kwarteng [1] 61/6
interpret [1] 22/17 involvement [1] 123/21 126/14 134/21) 46/16 58/1 60/12 65/1 lL...
interpretation [1] 7718 135/7 136/15 65/8 72/7 77/23 79/13)
44/14 is [393] itself [12] 3/13 5/4 I 82/19 84/6 85/7 85/17Ilack [5] 4/1 14/3

Ismail [2] 10/13 11/4 I 26/9 27/2 31/16 32/23) 87/6 89/13 91/20 93/7I 19/14 103/9 130/24

(47) initiating - lack
INQ00001195

INQ00001195
L 70/17 83/11 list [3] 27/10 85/11 Ilose [1] 69/15 91/7 93/24 99/10
aaa [letter [32] 21/9 21/9 I 96/6 losing [1] 112/2 121/4 130/14 136/25
raced 13) 411 17/11 749 24/18 24/22 listen [3] 12/17 loss [6] 37/18 44/5 male [2] 19/18 20/21
27/2 54/19 54/21 112/23 113/6 47/15 74/24 91/6 91/6I manage [3] 6/12 86/3}

lacks [1] 88/22 . a
lady tai? 54/24 59/7 61/5 61/9 Ilists [1] 79/18 loss-making [1] 91/6 I 124/24

laid [1] 65/18 61/10 61/14 65/2 81/6} literally [1] 65/17 losses [13] 32/25 managed [1] 10/24
Lancashire [4] 98/3 98/9 133/23 litigation [3] 72/9 35/1 36/6 43/25 44/1 Imanagement [5]

Tae 133/24 133/24 134/15] 73/1 112/2 44/7 44/10 44/23 I 2/19 4/11 100/19
lands [1] 35/25 134/17 135/4 135/15 Ilittle [11] 3/115/2 I 44/24 45/2 48/11 51/3I 114/23 131/3.
Larch tie a1i9 I 135/16 135/20 136/6 I sri9 s/19 916 15/15 I sari manager [2] 115/1
Boe ig one, I 136/17 136/18 136/20I 87/2 96/6 109/3 lost [1] 76/17 116/16

last [19] 9/7 14720 I 136/21 114/18 120/5 lot [9] 13/1245/12  Imanagers [1] 31/17
aes aia 31io1__ [letters [4] 76/23 77/1 Ilive [2] 47/19 87/25 I 88/23 92/17 99/8 99/9I Manchester [1]
Bens aaa vores rarrI 77/10 77/12 lives [1] 100/15 99/9 118/2 131/4 I 115/16

24103 92100 100/9 [letting [1] 12/5 living [1] 111/21 Louise [1] 113/17 Imangled [1] 50/1
Ors 103/14 104/15Ilevel [22] 5/21 9123 Ilocal [2] 49/5 52/12 Ilove [2] 69/9 70/5 Imany [17] 11/8 11/22
TOvD0 132/18 13313 I 14/2 14/23 16/14 18/1I logical [1] 88/1 low [2] 71/22 75/16 I 16/20 28/1 29/11
4133/4 20/16 35/3 43/3 43/3 Ilogistical [1] 86/22 Ilower [1] 129/6 29/11 34/14 36/2 43/8
Lastly [3] 24/17 44/15 44/16 56/9 89/6I long [23] 16/22 30/20Ilunch [7] 103/21 I 78/2 80/19 82/10
a 89/14 99/14 102/3 I 40/11 41/15 43/1 62/4) 103/22 103/23 104/3 I 82/20 100/22 103/3
late [2] 90/12 125/14 I 108/6 1089 1098 I 62/15 62/16 62/20 I 104/4 110/20 117/17 I 120/18 122/13

later [7] 19/5 43/15 I 109/9 110/17 62/22 63/13 63/16 I March [8] 1/24 17/23
46/14 47/4 48/23 levels [1] 111/14 63/17 64/1 64/19 66/2IMBE_ 42/14 42/15 61/8
105/7 115/18 levers [1] 15/3 66/4 111/17 116/20 Imade [42] 4/22 9/16 I 61/13 61/22 88/2

\ liabilities [2] 2/15 I 126/13 132/24 133/1 I 10/6 11/23 12/20 I marginalised [1]
jaw [8] 25/17 58/11 aig 13717 13/19 15/13 15/16 I 12/18

407/14 108/3 109/20

ttaa 1109 1tOr14 [liaising [2] 110/14 long-term [8] 16/22. I 15/25 17/20 19/5 23/4I Marianne [1] 18/16
lawyer [6] 25/15. I 116/18 40/11 62/4 62/15 I 23/6 23/2424110 I Marion [1] 31/18
aye eee sergiliberty [1] 118/11 I 62/16 63/16 64/19 I I 26/22 28/25 35119 I marked [1] 67/4
5B lies [2] 116/25 122/8 I 66/4 51/25 63/3 64/5 64/14I marshal [1] 34/8
lead [2] 51/12 119/16] life [6] 64/1 84/2 Itonger [7] 24/1 42/2 I 70/20 74/13 80/9 I Marshall [1] 96/13
leaderenip {4} 19/20 I 85/17 113/8 11379 I 42/9 42/12 e912 85/15 93/3 97/17 _IMartin [1] 96/11
59/18 96/3 111/20 I 114/11 108/15 134/11 97/17 101/25 103/7_Imass [2] 135/9
learn [1] 62/13 light [9] 1/15 22/20 Ilonger-term [2] 42/2 I 107/17 111/25 117/19I 135/19

learning (17 saris. I 28/1 34/20 87/9 89/20I 42/9 120/2 120/2 121/18 Imassive [1] 70/2
learnt [a] 9/10 2512 I 105/17 108/16 10916 Iiook [30] 2/6 13/3 I 122/22 123/17 124/20) match [1] 37/23
vor OHS like [34] 1/14 13/10 I 13/7 21/8 23/18 24/18) 125/11 133/4 material [1] 26/13

least [7] 38/11 42/19 I 29/9 31/23 33/2 33/11] 33/14 36/23 37/3 Imail [2] 7/16 126/12 I materially [1] 97/9
48/14 88/13 95/2 95/8I 29/4 49/18 50/2 60/18] 38/23 38/25 41/3 51/2Imain [3] 92/2 123/14 Imaterials [1] 29/4

95/18 61/19 62/11 83/18 51/14 62/4 62/14 123/24 matter [3] 3/16 26/18
leave [4] 9/9 87/24 87/12 91/4 95/11 98/2) 64/23 66/15 86/13 mainly [1] 32/23 106/2
4117/9 117/9 100/1 102/4 110/15 I 92/8 98/7 121/3 Majesty's [4] 2/21 matters [11] 2/16 3/3
leaving [3] 45/9 114/20 122/1 122/2 I 122/22 126/20 127/21 3/6 3/14 5/5 23/21 23/22 50/16
81/19 81/20 122/21 122/22 125/13I 128/11 128/18 129/8 Imajor [3] 4/3 90/19 I 54/13 62/3 67/4 103/3
led [1] 114/13 127/21 128/11 128/18] 133/22 135/20 92/19 405/15 105/24
left [6] 17/14 18/24 I 129/8 136/9 looked [2] 125/13 Imajority [4] 22/12 I may [54] 1/14 1/24
19/4 28/22 93/18 Iliked [1] 133/8 135/23 26/6 26/21 134/3 4/22 5/8 7/14 7/14
102/14 likely [9] 13/15 21/17 Ilooking [15] 26/18 Imake [33] 15/4 16/4 I 8/22 8/22 23/24 24/11
legal [10] 3/18 21/15 26/5 96/21 107/4 32/18 38/8 50/25 27/14 29/5 29/7 34/8 I 28/24 33/25 34/21
29/18 29/19 30/2 32/3 121/10 131/22 131/25I 52/25 57/19 64/4 36/5 40/1 45/6 48/19 I 40/16 43/9 45/2 45/19}
4107/9 120/19 134/21 I 134/3 74/16 75/24 83/16 I 49/18 50/2 52/2 52/17I 45/21 47/7 48/10
1435/5 likes [1] 92/22 104/2 112/3 114/5 59/20 60/21 63/25 50/16 51/2 51/12
legislate [1] 22/11 _ Ilimited [5] 9/6 15/15 I 118/11 134/13 70/17 72/2 72/8 81/21I 52/19 52/24 53/2

a 69/20 101/1 112/1 —_Ilooks [5] 26/24 28/1 I 81/25 86/13 92/9 54/21 56/1 58/14

legislation [4] 72/15
76/23 77/8 135/2
length [1] 82/7

line [8] 4/25 13/8 I 28/9 62/11 136/9 92/13 93/4 94/7 97/12) 59/11 59/24 63/11
13/13 33/5 54/25 —_ILord [9] 21/10 22/25 I 97/18 119/21 119/21 I 74/15 76/3 79/23 83/6

less [3] 16/24 128/6 70/16 83/14 134/2 23/24 54/10 73/10 125/4 125/11 87/6 90/4 90/7 99/15
133/20 lines [3] 19/12 83/25 I 107/13 108/14 109/5 Imaker [1] 86/1 99/16 99/23 106/9

let [6] 5/21 22/25 84/9 134/18 makes [1] 112/17 108/12 114/2 114/20
69/10 72/6 74/21 link [2] 88/5 88/10 _ ILord Justice [2] making [22] 7/15 115/20 119/20 120/6
82/21 Linnell [3] 31/23 54/10 73/10 7/20 13/11 14/24 15/7) 122/21 125/19 129/1
let's [7] 37/3 39/5 34/12 34/13 Lorna [7] 1/25 8/17 I 15/15 15/24 22/15 129/22 136/4

44/8 50/11 55/23 Linton [1] 70/8 17/2 17/5 17/9 56/5 I 29/4 42/20 52/5 80/4 I maybe [6] 39/8 39/9

Lisa [1] 17/14 123/10 81/10 84/23 91/2 91/6] 39/11 39/13 40/3 58/4

(48) lacked - maybe
INQ00001195

INQ00001195
M mention [2] 67/6 Imistrust [1] 43/4 I 107/7 107/12 110/21 I 71/18 75/11 75/21
Manausld RP d1aieI 118/16 misunderstanding 111/13 133/19 137/5 I 77/2 77/17 79/2 85/10
McDonald (7) anes mentioned [16] 6/5 I [2] 37/14 37/17 Mr Beer's [1] 105/10 I 87/1 99/24 103/13
tele 116/14 116/18 I 40/24 81/12 82/5 I Mm [3] 49/23 58/17 IMr Blake [2] 129/10 I 104/9 107/3 107/12
116/21 82/17 82/21 84/3 76/8 131/12 108/23 110/8 113/9
McDonald's [1] 89/23 93/8 93/23 99/6Imodern [1] 126/16 IMr Bradshaw [2] I 114/20 116/22 117/17
114/19 103/11 109/13 110/13IModernisation [4] I 115/21 115/21 117/24 118/9 118/19
McEwan [4] 67/5 I 120/15 120/25 122/3 129/9 129/17 IMr Cameron [3] 119/23 122/4 123/9
7/15 B27 101/25 IMessage [16] 35/24 I 129/23 33/25 34/4 34/17 127/20 128/20 130/1
Mcinnes [1] 12319 I 40/5 40/5 42/4 42/6 modest [1] 127/13 Mr Cooper [2] 4/25 I 131/19 133/2 133/13
47/20 48/12 51/13 IMoloney [9] 30/14 I 6/14 133/16 137/6

me [41] 8/20 9/3 11/7 7
1 Ee oe tore 51/15 51/17 69/24 I 103/15 104/5 1114/2 IMr Greenhow [3] _IMr Recaldin [2]

29/17 31/4 31/19 36/4) 1/23 79/21 80/6 80/9I 111/7 119/2 119/22 I 95/24 101/19 102/20 I 121/11 121/14

81/10 132/23 138/12 Mr Henry [1] 104/20 IMr Staunton [4]
ate an enon messages [3] 29/25 IMoloney's [1] 103/23)Mr Hollinrake [4] 17/23 17/25 18/9 29/1
69/13 72/6 73/20 40/9 69/8 moment [6] 13/22 75/9 98/9 123/5 Mr Stein [14] 30/13
74/21 77/15 78/5 79/8] Messaging [1] 45/20 I 30/25 74/10 83/9 85/7) 123/19 30/17 30/21 30/23
82/21 85/7 86/9 87/2 Imet [4] 23/17 90/7 132/23 Mr Hollinrake's [1] 31/7 46/5 48/16 53/21
97/4 102/6 104/10 129/22 130/12 money [15] 32/14 123/18 60/2 60/4 80/20 85/6
105/16 106/15 107/22! middle [1] 45/9 32/14 33/3 33/3 33/4 IMr Ismail [2] 10/13 I 85/11 138/6
1408/9 109/3 109/3 might [16] 7/19 7/20 I 34/1 34/11 37/24 11/4 Mr Stein's [2] 78/6
4113/8 116/24 118/16 8/2 13/25 44/21 45/8 I 39/12 41/24 42/23 Mr Jacobs [4] 10/12 I 86/21
119/13 46/10 47/21 49/19 60/22 62/16 69/22 11/7 31/3 53/9 Mr Tidswell [1] 56/4

mean [17] 5/15 10/15 50/3 51/8 60/20 71/5 I 116/10 Mr Justice [1] 96/10 IMr Vamos [3] 24/19
TH/17 34/6 36/16 36/9) 121/6 134/25 1356/3 Imonies [2] 33/1 Mr Kwarteng [1] 61/6) 25/11 26/4
40/17 44/13 45/8 (mile [1] 60/15 4117/4 Mr McInnes [1] 123/9IMr Vamos: [6]

45/13 77/24 83/4 miles [1] 60/14 monitoring [1] 39/16 IMr Moloney [8] 30/14) 133/24 134/15 135/15}
98/22 106/23 124/18 months [15] 17/15 103/15 104/5 111/2 I 136/12 136/17 136/20
128/8 133/3 53/8 92/1 94/9 127/1 I 19/5 21/6 64/10 65/16] 119/2 119/22 132/23 IMrs [6] 115/4 115/22

means [2] 74/12 79/2 millions [1] 53/5 65/16 68/21 71/8 79/3) 138/12 116/6 116/14 116/18

meant [3] 10/18 minds [1] 61/22 92/20 115/14 130/2 IMr Parker [1] 61/13 I 116/21
16/13 22/16 mine [1] 133/10 130/2 131/10 131/11 IMr Patterson [13] Mrs McDonald [6]

meantime [1] 136/3 jum [1] 127/16 Imoratorium [1] 54/19 54/20 55/7 115/4 115/22 116/6

mechanics [1] 78/18 minister [6] 98/4 70/15 55/10 55/25 56/14 116/14 116/18 116/21

mechanism [4] 35/9 98/21 99/1 122/24 more [33] 4/15 9/16 I 56/16 56/20 57/2 Ms [30] 18/5 18/9

media [1] 80/6 122/24 123/10 16/4 16/12 19/1 20/21) 58/24 59/7 82/24 18/14 18/23 29/1 30/1

mediation [4] 113/3 ministers [2] 66/13 I 22/1 22/4 27/7 36/1 I 84/24 30/15 31/20 48/23
4113/5 116/21 122/7 75/7 36/2 39/2 42/24 42/25IMr Peter [1] 74/22 49/6 49/17 55/17

mediation/settlement Ministry [3] 78/11 45/12 45/17 51/6 Mr Railton [27] 55/7 I 55/24 58/25 59/3 67/5
[yy 113/5 134/18 137/1 52/19 56/23 77/13 56/10 56/19 57/6 67/15 82/17 86/23

meet [2] 69/15 81/17 minority [1] 20/15 79/5 80/23 84/15 57/23 62/13 62/18 86/25 103/15 103/21
meeting [17] 9/8 41/7 minute [1] 103/19 100/22 102/15 112/13] 63/15 64/21 64/24 104/3 104/7 104/8
55/14 55/15 59/16 Iminuted [1] 14/4 118/24 125/13 125/15) 65/8 65/9 69/18 70/20) 113/25 117/16 120/3
59/14. 59/14 59/15 I Minutes [16] 30/14 I 127/3 127/4 127/13 I 84/20 128/21 128/24 I 138/8 138/10

59/15 81/13 90/12 30/15 30/16 31/5 39/5) 133/10 129/1 129/4 129/5 Ms Allan [4] 30/15
113/3 113/22 114/7_ I 93/13 98/14 103/15 Imorning [9] 1/5 1/8 I 129/10 129/11 130/8 I 103/15 104/3 104/7
114/15 123/4 125/19 I 193/15 103/20 103/22] 1/9 45/18 103/20 130/16 130/17 131/12IMs Allan's [1] 103/21

' 114/11 123/1 12913 I 117/24 121/22 135/24I 131/24 Ms Dar [1] 113/25
moctings (a 2a 129/11 133/20 137/12 Mr Railton's [4] Ms Davies [5] 18/5
B01 Bos Boia gale \misalignment [1]  Imost [5] 87/10 93/5 I 57/1064/12.65/21 I 18/9 18/23 29/1 30/1
TOSS 120/12 120/13 I 52/10 97/14 101/7 107113 I 69/3 Ms Davies’ [1] 18/14

120/17 120/22 122/6 Imisbehaviour [3] mother [1] 115/12 IMr Read [72] 1/8 Ms Falcon [1] 31/20
Melanie [1] 48/18 97/4 121/7 121/18 move [5] 36/9 52/8 I 17/22 27/5 30/10 31/8IMs Gallafent [2]

miscarriages [1] I 52/12 107/6 132/2 I 3213 32/14 32/15 I 58/25 59/3

reo A ge I 105/19 moved [1] 125/4 I 33/22 35/10 35/16 IMs Gray [2] 55/17

members [6] 79/19 I Miscellaneous [1] moving [3] 39/4 49/1 I 37/1 40/2 4014 403 I 55/24

rears I ea orn] 217 70/25 40/17 40/21 42/12 IMs McEwan [3] 67/5

Bela misogyny [2] 17/24 IMR [210] 43/9 44/21 45/23 I 67/15 82/17

mamorial 1 84/7 I 19112 Mr Bartlett [3] 55/18 I 46/25 47/18 48/13 IMs Park [3] 48/23

momen (181/25 Imiss [2] 68/15 68/19 I 55/24 109/23 51/10 51/14 52/24 I 49/6 49/17

81/23 missed [2] 57/24 Mr Bates [1] 98/5 53/8 53/24 62/20 Ms Richards [1]

men [1] 20/4 7413 Mr Beer [13] 29/10 I 62/22 63/11 63/21 I 120/3

mentatey [ty 18113 [missing [2] 3/23 I 50/19 59/23 56/5 I 67/10.67/14 69/10 [Ms Watt [4] 86/23
11714 55/13 56/22 75/6 I 70/6 70/16 70/19 ‘I 86/25 117/16 1386/8

(49) McDonald - Ms Watt
INQ00001195

INQ00001195
M near [3] 95/21 115/15] 90/8 95/15 95/17 _Inotetaking [1] 48/20 I 29/20 38/25 44/15
aon I 115/18 96/18 98/3 98/8 98/11) nothing [2] 87/12 I 46/25 57/1 64/16
ri nearest [1] 60/15 —_ I 98/20 98/24 109/12 77/22 78/17 78/23
42/8 42/12 52/1 60/11IMearly [2] 88/8 90/15 INFSP's [1] 102/19 _Inotice [3] 47/8 47/22 I 81/16 82/12 84/5 88/6
61/20 67/25 85/14. Necessarily [6] 33/4 INFSP00001471 [1] I 53/21 91/16 92/12 103/10
99/19 100/18 1092/2 I 83/12 88/9 91/2 100/2 noting [1] 18/9 104/10 106/4 119/7
02/4 102/7 102/15 I 112/17 114/12 nice [1] 66/21 notion [4] 5/95/11 I 124/20 127/2 128/15
t06/4 10713 1236 IRECessary [3] 17/4 INICHOLAS [2] 1/3 I 5/18 71/2 129/5
4126/8 126/21 126/23 I 119/20 130/7 138/2 Notwithstanding [2] IOC [2] 32/24 35/8
4133/8 137/113. necessity [2] 5/14 I Nick [4] 34/596/8 I 71/9 105/4 occasions [4] 32/17
muddy [1] 106/5 125/12 124/14 127/12 November [2] 106/3 I 33/21 35/22 84/11
multichannel [4] NED [3] 8/5 9/14 13/3INicola [1] 59/3 109/14 occur [4] 38/8 39/1
92/21 NEDs [9] 7/2 7/10 el [2] 71/13 93/22 Inow [64] 3/16 4/3 I 80/13 105/6
multiple [3] 4/12 7/12 9/13 10/6 13/15 INigel's [1] 71/9 23/20 26/2 30/7 30/12I occurred [8] 35/21
74/24 8018 15/18 73/25 95/16 —_Inine [1] 71/8 36/11 37/13 38/16 I 37/12 52/23 84/8
NEDs' [1] 9/1 Nisa [1] 12/5 43/9 49/6 52/19 53/9 I 105/19 107/2 108/7

multiproduct [1] need [26] 7/4 10/11 Ino [70] 3/11 5/2 7/4 I 53/10 55/4 55/23 4108/9

19/23 30/22 40/24 I 8/10 10/11 13/19 _I 56/10 56/25 58/1 60/5I occurring [2] 38/14
aa ee a7 I 4315 45/6 48/21 49/13) 14/16 16/3 19/23 I 61/3 61/13 62/8 62/12] 39/2 91]
sane rae goat I 81/1 52/1 82/23 61/24I 22/15 22/15 23/15 I 62/18 63/21 65/17 occurs [1] 38/16
my [ser O15 tii? [63/19.65/3 67/19 I 24/1 26/1 25/10 26/13] G6/17 66/25 68/14 I October [3} 1/1 17/3
oe erty oar7I 68/12 71/15 72/2 7212) 26/17 271 27/23 I 69/3 75/5 76/21 90/17) 137/16
Salo SeIDs Sing I I 7215 83/24 85/7 97/11) 28/15 28/21 29/13 I 90/21 91/4 92/6 94/12I off [23] 36/10 36/14

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prolect Ul oot pursuing [4] 84/10 I 88/23 107/1 107/1__I 127/12 127/20 128/20] reconciliation [3]

90/16 90/18 94/19 pursuit [1] 54/23 111/13 113/6 118/10 I 130/1 131/19 133/2 I 37/21 38/23 50/18
95/5 96/9 97/8 98/23 IPUSH [2] 69/25 80/22 I 125/16 126/14 131/4 I 133/13 133/16 137/6 I recorded [3] 38/17

pushed [1] 62/25 I quote [2] 48/17 75/1 I 138/2 115/22 116/3

fort 129/28 1308 pushers [1] 70/2 R________Ifeadout [2] 122/23 [records [2] 78/2 78/3
131/2 133/8 put [20] 5/12 8/3 8/13) S__________I 123/4 recover [2] 43/25
projected [1] 32/25 I 10/23 25/1 25/8 26/1 IRachel [1] 17/2 reads [1] 127/9 44/23

rojects [3] 90/17 I 26/13 27/3 55/17 Railton [27] 55/7 ready [1] 123/23 recruited [2] 20/25
ors 130723 59/17 82/20 83/7 84/8I 56/10 56/19 57/6 real [7] 13/11 15/23 I 29/14

romotion [1] 20/16 I 95/24 104/20 112/1 I 87/23 62/13 62/18 I 22/19 75/23 96/1 recruitment [2] 9/14
P dit) 92/24. I 126/18 133/16 134/8 I 63/15 64/21 64/24 I 4112/4 119/14 9/22

Fone aie, [QT I S518 85/9 69/18 70120Irealised [1] 14/5 rectify [1] 108/19
proportion [2] 20/2 Qi) 84/20 128/21 128/24 I realistic [1] 89/3 red [3] 43/11 130/5
33/5 qualification [1] 129/1 129/4 129/5 reality [2] 26/5 134/3 I 130/23

proposal [1] 3/1 119/24 129/10 129/11 130/8 Ireally [8] 13/18 22/23Irededicate [1] 42/18
ropriety [1] 1128 IWalified [1] 111/24 I 130/16 130/17 131/12] 35/24 39/17 52/4 rededication [1] 69/6
a eooecute 13} 106/15 I quality [2] 88/22 131/24 108/23 125/16 131/4 Iredo [1] 55/5
POe/t9 106/23 90/13 Railton's [4] 57/10 Ireappeared [1] 53/22/redress [9] 1/12
prosecuted [5] 77/21 I Warters [1] 30/19 I 64/12 65/21 69/3 reappointment [1] I 72/11 72/13 72/18
111/10 115/4 1165/5 {Washed [3] 22/14 raise [1] 123/16 10/16 72/25 73/12 74/6
4115/6 7718 111/11 raised [7] 17/18 18/5 Ireason [8] 11/25 37/6] 76/21 135/12
prosecuting [2] question [30] 6/24 I 33/22 84/23 98/8 44/5 75/1 124/22 reduce [6] 91/10
31/16 40/8 13/14 26/11 28/21 I 98/11 101/2 125/1 125/2 125/2 I 91/17 91/23 91/25
prosecution [3] 24/8 I 24/1 34/25 55/23 57/5}raises [1] 22/5 reasonable [1] 44/3 I 92/4 92/9

104/24 116/4 57/20 58/8 59/16 raising [1] 101/19 Ireasons [9] 39/14 _Irefer [8] 11/13 50/16
prosecutions [2] 59/23 65/2075/8 —_I ramifications [1] 42/10 43/2 86/23 61/3 61/5 61/20 67/12
77/1 108/7 84/17 94/12 102/23 I 54/16 89/16 106/16 106/20 I 101/24 105/4
prosecutor [2] 105/9I 105/10 106/17 109/1 range [6] 9/24 14/18 I 119/16 122/13 reference [3] 11/4
10812 111/4 114/19 118/10 I 14/21 22/22 38/25 I reassurance [2] 46/4 67/21

prospect [1] 12/2 I 119/3 119/4 119/18 I 90/2 96/15 96/23, referenced [1] 67/15
provide [5] 9/24 126/10 130/9 130/10 Irate [1] 91/25 rebalanced [1] 9/16 Ireferences [5] 16/4
62/17 72/24 93/10 130/11 rather [9] 3/13 5/5 I rebuild [1] 12/11 66/17 66/18 68/15
135/12 questioned [12] 1/4 I 43/12 50/1 57/18 rebuilding [2] 121/22) 135/4
provided [9] 3/22 7/5I 21/7 86/25 104/8 57/18 69/21 112/17 I 121/23 referred [2] 118/2
BS )3 755 yore oor9 I (11/2 133/21 1388/4 I 127/14 Recaldin [5] 83/23 I 128/22

104/17 135/4 135/13 I 138/6 138/8 138/10 ratings [1] 130/5 106/1 109/13 121/11 Ireferring [4] 29/2
provides [1] 60/24 138/12 138/14 rattle [1] 65/24 121/14 62/9 68/24 110/6
providing [5] 2/14 _[destioner [1] 85/10 jre [4] 12/21 recall [14] 17/7 17/8 Irefers [1] 21/14
83/17 96/14 1068/2 Idestioning [1] re-election [1] 12/21 I 20/9 24/6 50/23 50/24I refining [1] 10/8
109/19 119/8 reaching [1] 42/25 I 55/13 55/21 55/22 _I reflected [1] 3/21
provision [2] 7/9 9/1 questions [51] 11/9 Ireactive [1] 16/22 74/10 90/23 116/2 _I reflections [1] 28/8

11/22 21/7 28/6 28/8 Iread [82] 1/3 1/8 15/8] 118/13 125/20 reflective [1] 127/20

(53) proceedings - reflective
INQ00001195

INQ00001195

R reminder [2] 1/20 2/2I 61/15 61/17 65/15 66/8 66/10 rollout [3] 124/15
refusal [1] 46 IFemit [2] 3/18 34/19 Ireset [1] 64/8 68/12 68/22 69/5 124/19 126/3
refute [1] 12/23 remote [2] 96/15 _Iresign [2] 30/4 70/10 70/22 71/16 I rolls [1] 88/14
regard [4] 16/5 16/6 96/23 101/17 73/7 73/16 92/8 93/7 Iroom [2] 9/10 113/10
94/21 117/25 remove [1] 103/8 resignation [2] 30/8 I 93/13 94/7 98/18 root [4] 39/25 70/10
regarding [6] 18/18 remuneration [9] 30/8 104/19 105/1 105/13 I 122/8 131/8
19/8 23/9 58/5 84/17 27/18 27/25 28/10 Resolution [2] 44/4 I 106/7 109/10 109/11 Irose [1] 20/4
4105/7 28/12 30/5 73/7 85/13) 47/25 109/18 132/4 132/13 Iroughly [1] 76/24
region [2] 32/21 33/9 91/14 95/23 resolve [4] 52/5 132/16 round [2] 9/14 57/18
regret [2} 28/3 133/9 IFePaid [1] 33/1 52/15 52/15 62/2 —_Ireviewed [2] 3/21 IRoyal [1] 7/16
regrets [3] 133/5  IFeParations [1] 41/6 Iresource [2] 2/12 I 33/19 rubber [5] 13/19
133/6 153/11 repeat [2] 49/24 2/24 reviews [3] 66/19 I 13/24 15/25 16/1
regularly [1] 39/3 106/17 resources [2] 34/8 I 94/2 130/4 16/11
reignited [2] 34/19 repeated [4] 10/14 I 63/6 revised [1] 124/8 ruining [1] 100/15
34/22 28/11 106/12 117/23 Iresourcing [2] 2/7 [revision [1] 46/18 run [11] 10/24 58/18
Reinvention [1] 93/9 I"ePeatedly [2] 28/9 I 2/9 rework [3] 48/14 72/10 73/3 73/4 73/7

01/9 respect [8] 23/12 48/15 57/13 77/3 77/4 91/25

reiterated [1] 117/16
rejig [1] 86/22

replaced [2] 1/25 I 67/2 95/12 113/3__IRichards [6] 116/15 I 124/23 132/9
relate [1] 66/19 7124

129/24 130/4 131/2 I 116/16 117/7 117/14 Irunning [7] 7/24

replacement [16] I 132/15 118/8 120/3 34/17 56/17 90/11
related [3] 2119 3/2 I 7111 g8/4 88/25 respected [2] 14/1 right [46] 1227/7 I 91/12. 9118 117/2
relates [2] 65/20 7717I 91/21 123/21 123/26 I 16/2 713 10/17 11/10 Iruns [4] 72/18
relation tat] 2orts. I 124/16 124/19 125/17]respectfully [1] 81/9 I 11/11 11/12 12128 I=
ante tety I 126/16 1271 12715 respond [2] 17/19 I 13M 211227122 IS_
cia coneeos — I 127/25 128/11 132/15) 64/23 33/22 36/14 36/20 _I sacked [1] 47/22
Cote cole sang I 132/24 responded [1] 11/19 I 37/3 38/7 40/23 43/13I sadly [1] 84/12
oOo Fa TENo. (replacing [2] 126/21 Iresponse [6] 23/12 I 44/11 46/10.47/2 I Saf [2] 9/4 10/1
aed bored gang I 127/12 24/3 24/5 105/10 I 49/12.53/14 55/7 I safe [1] 45/9
get dete toi \feplied [1] 131/24 I 107/13 108/24 55/11 58/1261/17 _I safeguards [1]
TOB/Ie 3 t/ty report [14] 18/14 responses [2] 23/9 I 66/12 67/23 74/5 77/2] 108/18

35/11 38/11 38/15 I 35/13 78/14 85/22 86/16 Isafely [3] 26/7 26/22

relationship [1] 38/15 40/11 40/18 responsibility [6] I 86/17 86/24.87/13 I 134/5

relatively [1] 19/17 41/22 53/1 72/1 88/20) 3/12 5/4 13/12 15/14 I 87/14 87/19 98/20 _I safety [1] 18/6

Relativity [1] 46/15 I 107/25 108/3 131/15 I 44/16 133/1 99/10 99/13 99/14 I said [43] 11/14 22/15
releases [1] 89/22 I@Ported [1] 114/23 responsible [6] 44/7 I 102/15 122/15 137/11] 26/21 30/1 30/24 34v6I
relevance [1] 56/13 I@Porting [11] 24/2 I 44/15 78/17 119/8 —_Irightly [2] 20/18 34/10 35/22 42/8 45/5
relevant [4] 59/24 I 24/15 107/15 107/24 I 119/17 121/12 105/23 50/22 51/8 56/4 65/15
92/16 10719 1365/1 I 108/11 108/15 108/19] rest [1] 124/3 rights [3] 98/24 72/5 74/15 75/18
reliability [1] 100/12 I 128/25 109/16 110/9 restorative [5] 82/5 I 99/14 102/9 75/22 93/16 94/1
reliance [1] 21/24 _ I 130/22 82/13 84/6 120/11 I rigorously [1] 112/4 I 95/18 97/2 97/16 99/3}
relying [1] 55/1 reprehensible [1] 120/22 ring [4] 5/16 39/20 I 101/10 102/4 102/24
remain [2] 75/16 101/8 restored [1] 4/19 124/16 125/6 103/5 103/8 104/3
100/17 represent [8] 31/8 Iresult [5] 62/21 69/4 Iring-fence [2] 5/16 I 114/2 114/10 116/21
remainder [1] 100/23] 31/12 32/4 32/9 69/8 I 75/2 105/20 15/3 I 124/16 117/22 121/10 121/14
remaining [4] 42/18 I 74/22 80/25 104/11 Iresulted [1] 14/3 __Iring-fencing [1] 123/19 123/23 124/14
49/5 68/21 84/13. IFepresentative [5] resulting [1] 47/15 I 125/6 125/19 127/12 133/17
remains [2] 4/3 67/18] 26/7 58/23 95/14 results [1] 20/6 risk [4] 5/13 43/23 I 134/2

remarkably [1] 64/24I 96/24 97/22 resume [3] 53/14 I 46/18 93/14 salary [1] 28/10
RemCo [1] 8/19 representatives [1] I 110/21 137/11 robust [1] 71/8 same [13] 4/23 9/12
remedial [1] 101/12 I 120/19 retain [1] 18/11 role [29] 7/23 8/6 11/4 20/12 47/20
remediation [14] represented [1] reticence [1] 119/15 I 8/10 8/11 8/259/1 I 56/21 69/12 76/5

3/17 23/19 23/21 31/18 returned [1] 117/1 I 9/15 9/23 10/3 10/9 I 86/11 86/11 102/18

23/22 24/12 86/2 Repudiatory [2] 47/2 Irevealed [1] 100/24 I 14/14 19/2 19/3 24/2 I 121/15 131/23
105/14 105/24 105/25I 47/5 revenue [2] 91/15 24/14 27/20 28/14 _I satisfactory [1] 35/9

request [1] 80/4 I 92/13 29112 29/15 3077 [savings [1] 93/4
$e a don» 7?5I requested [2] 62/10 Ireverse [1] 57/15 I 51/2396/16 1058 Isaw [5] 8/14 8/14
134/21 review [51] 22/2 I 107/15 107/23 108/12] 56/20 96/14 130/17

eee ty a2 requests [1] 125/8 I 23/13 24/13 26/15 108/13 108/25 109/24/say [44] 6/10 6/16

61/6 66/22 84/8 94/22ITeduired [4] 5/21 35/19 36/13 36/14 roles [14] 18/4 18/19 I 10/13 11/20 11/23

113/18 114/5 1115/7 I 1041/1 101/12 125/9 I 36/17 37/4 39/21 94/19 95/5 97/7 98/16I 12/16 16/17 27/1
429/13 129/14 133/23I"equirement [1] 46/18 52/9 61/3 61/4 I 98/23 99/4 100/18 29/24 30/6 30/18 33/8
50/13 62/5 62/9 62/21 62/24I 101/24 102/24 103/3 I 35/5 44/21 53/10 56/8

remind [2] 31/4 requirements [5] I 63/1 63/1 63/7 63/9 _ I 118/3 118/5 58/3 59/6 59/18 63/6

49/12 60/5 60/18 64/16 64/18 65/11 rolling [1] 127/15 65/24 66/2 66/6 69/9

(64) refusal - say
INQ00001195

INQ00001195

s scrutinise [2] 124/15 I 14/21 27/14 32/3 116/13 117/11 65/23 66/10 92/5 94/3
say... [20] 69/14. 124/19 45/16 64/13 65/18 She'd [1] 113/20 101/24 106/13 107/20)
69/24 70/17 71/24 scrutiny [1] 94/4 112/17 121/20 she's [4] 49/9 50/1 108/7 108/8 108/9
74/18 86/17 87/15 se [2] 8/8 24/5 sensible [2] 60/21 50/8 116/18 129/1

88/24 99/12 99/20 [Searched [1] 116/11 I 97/11 sheer [1] 72/8 Sinclair [2] 103/16
99/24 99/25 101/14 searchers [1] 116/12Isensitivities [1] 7/14 Ishift [1] 67/25 104/12

4110/8 110/22 112/10 second [12] 19/24  Isensitivity [1] 7/19 Iship [1] 57/12 single [3] 38/16
414/10 121/2 121/11 26/4 34/13 91/16 sent [12] 24/20 27/9 Ishop [1] 117/8 94/10 97/14

421/14 103/19 103/19 123/1 I 27/12 65/2 65/5 76/24I short [3] 16/21 53/19 Isingle-most [1]
saying [24] 17/25 124/12 125/1 125/2 I 77/10 115/13 115/16 I 110/25 97/14

22/10 29/5 34/6 41/19) 126/1 128/18 134/18 135/6 136/7 Ishort-term [1] 16/21 Isir [29] 1/5 6/22 27/6
45/1 47/21 48/10 50/1 secondary [1] 92/10 Isentence [1] 44/8 shortcoming [1] 30/12 31/3 34/12
51/1 51/15 54/22 secondly [5] 16/16 Iseparate [3] 2/20 85/21 34/12 43/19 46/2 46/6)
56/10 56/18 62/14 84/5 92/3 130/18 5/14 85/24 shortfall [13] 32/14 I 46/10 53/13 53/16
62/19 65/3 66/21 71/9 136/15 separating [3] 3/9 36/10 37/3 37/6 38/3 I 56/22 64/3 85/17
75/8 83/11 86/10 Secretary [6] 10/24 I 4/13 5/1 38/15 38/17 39/7 55/2) 86/15 86/19 103/14
1400/5 111/24 61/8 61/11 64/10 separation [3] 2/15 I 72/22 73/16 73/16 107/6 110/22 111/3
says [17] 2/9 4/25 123/17 123/20 4/3 50/8 114/25 1141/6 118/11 119/4
6/15 11/4 26/4 36/23 section [1] 129/10 ISeptember [3] 18/14 Ishortfalls [24] 35/10 I 119/8 133/15 137/10
45/20 48/24 49/17 security [1] 93/12 18/24 104/15 35/10 35/14 35/18 137/13

55/8 76/16 90/6 100/7IS°e. [29] 1/5 1/16 series [6] 18/25 19/5 I 38/8 38/13 38/20 Sir Alan [2] 34/12
134/15 135/17 136/12 4/17 8/24 11/17 24/20) 23/18 27/16 45/18 40/12 40/15 40/19 64/3

136/15 38/23 41/13 43/14 94/12 42/16 42/20 45/19 Sir Anthony [1]
scale [1] 126/22 61/10 61/10 61/12 serious [1] 104/21 48/12 48/17 49/8 34/12
Scandal [16] 2/25 _ I 64/24 72/1 87/2 87/6 Iseriously [2] 4/15 I 51/12 68/9 72/24 I Sir Wyn [3] 6/22
35/7 39/10 41/8 41/15 104/10 105/2 111/3 I 102/1 75/24 76/5 114/22 56/22 118/11

53/25 67/13 77/1 79/6 116/1 119/6 123/6 seriousness [1] 115/1 115/3 sit [5] 11/2 46/21
82/3 83/4 83/7 85/3 123/7 123/8 123/16 I 111/15 shorthand [2] 30/25 I 48/1 104/10 105/25
87/10 94/22 96/5 123/20 124/11 124/13] service [6] 23/14 104/2 sits [3] 31/19 46/21
Scarrabelotti [1] 129/18 43/1 60/9 104/25 shortlisted [3] 10/16 I 48/6

17/2 seeing [1] 71/5 108/1 109/17 10/18 10/21 sitting [1] 70/2
scheduled [1] 87/24 seek [2] 66/25 services [6] 60/8 should [29] 4/2 4/14 Isituation [4] 38/1
scheme [30] 4/5 72/9 105/18 69/15 91/16 92/15 5/25 22/10 30/24 47/2I 39/6 79/7 100/22
72/10 72/12 72/17 seeking [2] 135/8 92/18 93/1 55/1 57/21 57/21 six [6] 14/11 113/7
72/22 73/16 73/16 135/18 serving [1] 94/9 57/22 57/22 59/8 113/11 120/16 120/25)
73/21 74/9 74/12 seem [3] 77/2 111/22Isession [2] 30/20 68/24 70/14 70/15 132/18

74/23 76/2 76/21 77/3I 125/20 132/21 75/12 75/20 76/13 skip [1] 21/13

774 7717 T7145 77/19 /8eemed [1] 130/7 I set [14] 2/243/15 I 81/3 82/15 89/20 _I slight [1] 52/24
78/17 78/18 79/10 seems [9] 36/15 3/17 19/19 44/3 53/9 I 99/12 104/1 120/3 slightly [5] 8/13
83/8 85/13 85/24 36/24 44/8 57/22 60/2) 60/6 60/18 69/4 80/9 I 121/12 122/18 129/18) 43/15 46/14 47/4
86/15 87/23 88/6 88/7 62/18 65/1 77/11 79/3} 83/16 88/2 126/8 129/19 130/16 86/22

116/21 seen [15] 10/21 126/25 shoulders [1] 83/2 I slow [3] 99/17 99/24
schemes [23] 1/12 51/11 56/7 56/10 sets [1] 103/14 show [1] 46/6 99/24

B17 6/1 6/13 6/19 I 86/12 57/6 69/25 settlement [3] 4/16 Ishowed [3] 20/1 slower [1] 89/8
32/24 72/6 72/7 73/3 71/25 90/4 102/5 112/11 113/5 130/23 133/23 small [3] 32/9 71/21
74/3 74/4 74/5 75/13 115/20 129/15 131/15ISGEls [1] 61/18 shown [1] 41/9 71/22

75/15 76I7 81/20 132/17 135/6 Shall [2] 6/8 49/24 I SID [5] 17/5 17/10 I smallish [1] 39/12
83/16 83/20 85/1 SEG [3] 55/14 58/16 Ishape [4] 16/5 82/14 I 17/13 17/13 17/17 Smith [1] 3/7

85/11 86/2 86/6 88/11I 29/15. 89/5 90/3 sight [2] 34/13 69/13 Iso [154]
Scotland [12] 23/14 selecting [1] 14/6 share [1] 93/2 significant [10] 4/7 Iso1[1] 40/1

24/1 24/3 24/15 selection [2] 10/2 shared [5] 8/15 8/17 I 4/9 6/21 22/1 22/6 So's [1] 76/9

104/14 105/20 107/15 11/1 17/9 23/1 130/8 27/19 28/12 47/13 software [2] 122/8
1408/2 108/20 108/25 self [1] 115/22 shareholder [5] 2/13 I 53/1 125/16 122/14

409/22 110/12 sell [1] 64/2 15/17 16/6 56/6 58/22I significantly [1] 20/4 I solicited [2] 135/5
Scotland's [1] selling [1] 92/15 shareholder/UKGI [1]I signing [1] 65/12 136/13

107/13 send [4] 80/5 100/4 I 15/17 similar [3] 8/5 22/11 Isolicitors [2] 24/21
Scottish [5] 23/12 102/18 102/20 she [26] 17/5 18/5 59/9 80/25
23/25 105/12 106/7 sending [1] 100/3 18/11 19/5 50/10 56/2I similarly [1] 23/11 solutions [1] 82/14
113/16 senior [11] 18/2 18/3 I 103/11 104/3 104/13 ISimon [5] 23/4 59/3 Isome [47] 2/6 13/7
screen [1] 43/11 18/19 19/14 19/20 108/21 113/25 113/25) 83/22 106/1 109/13 I 19/4 19/19 19/21
scroll [6] 21/14 24/20 20/20 96/16 100/19 I 114/23 114/23 115/2 Isimple [2] 34/24 20/13 20/14 21/15
43/22 123/8 123/13 102/3 107/14 111/14 I 115/12 115/13 115/13) 102/7 22/7 30/22 34/17 43/1
435/22 seniority [1] 20/5 115/15 115/16 115/17Isimply [1] 29/1 43/2 43/9 46/10 48/15
sense [10] 9/3 9/5 115/18 116/7 116/12 Isince [12] 62/19 61/13 66/12 73/17

(55) say... - some
INQ00001195

INQ00001195
s 9/19 29/19 33/4 44/13] 132/19 137/6 struggled [1] 36/1 Isummarise [1] 17/22
some... [28] 74/18 67/16 79/24 106/25 Istates [1] 88/20 struggles [1] 70/3 I summarising [1]
T6/S bal? 4/7 87/8 I 116/2 117/22 118/17 Istatistics [1] 79/9 I struggling [1] 42/9 I 94/13
88/13 88/16 93/2 125/14 Staunton [6] 17/23 Istudies [1] 120/24 ISummary [1] 13/4
94/13 94/14 95/18 ISPecifics [5] 78/25 I 17/25 18/9 19/1 29/1 IStyal [1] 115/15 summer [2] 22/19
96/3 96/7 99/2 99/11 88/17 118/12 119/23 I 64/5 subcommittee [2] 57/4
100/16 111/21 111/24 132/17 stay [1] 15/11 23/20 105/14 supplementals [1]
411/25 114/24 115/9 speed [1] 135/11 Stein [14] 30/13 subject [5] 37/8 37/8 I 133/18
4115/9 118/12 118/24 spend [1] 20/25 30/17 30/21 30/23 50/12 60/10 106/1 supply [1] 110/18
423/12 130/1 133/18 ISPending [1] 92/17 I 31/7 46/5 48/16 53/21I submission [1] support [38] 3/11 4/2
134/14 spent [1] 115/17 60/2 60/4 80/20 85/6 I 125/11 5/2 5/18 5/19 9/24
somebody [4] 25/17 split [1] 63/6 85/11 138/6 submit [1] 29/6 29/19 32/4 35/20
36/14 120/1 121/6 SPM [5] 122/3 129/23I Stein's [2] 78/6 86/21/submitted [2] 6/22 36/18 37/11 38/22
someone [5] 37/4 130/18 131/5 133/7 I Stent [3] 5/12 5/13 125/7 38/22 39/20 39/24
37/5 39/6 96/22 117/3 spoken [3] 30/23 14/10 subpostmaster [11] I 40/25 43/7 43/8 43/16
something [32] 6/17 31/3 82/11 step [2] 97/12 117/2 I 31/24 36/10 36/22 43/17 46/1 46/17
10/23 16/9 21/5 24/11ISP°t [1] 123/14 stepped [1] 132/18 I 37/7 41/3 51/8 57/17 I 50/18 54/22 55/18
26/14 28/20 29/16 spotlight [1] 94/4 steps [3] 20/6 105/16I 75/11 76/10 76/14 59/16 61/1 62/16
43/5 57/2 58/13 58/14 spouting [1] 40/5 135/10 96/19 63/25 75/8 83/3 83/17
59/9 65/2 66/20 69/3 spread [2] 33/10 Steve [2] 117/7 subpostmasters [38] I 83/18 84/23 85/4
74/3 75/22 78/23 133/9 117/13 4/8 22/13 31/9 40/8 I 110/16 110/17 134/25
83/12 84/4 85/3 95/11 Spring [1] 2/13 still [39] 22/2 28/2 40/11 42/2 45/1 49/14/ supported [2] 18/4
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1421/8 122/17 127/14 squirrelled [1] 38/12 40/12 40/19 51/18 54/2 54/24 supporting [5] 32/1
1428/6 132/20 133/17 116/10 41/23 45/1 45/21 57/14 63/25 67/6 56/16 68/1 75/3
sometimes [2] 80/7 stability [1] 71/6 45/21 48/9 48/12 51/2I 67/12 68/16 68/19 118/14
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speaking [1] 121/17 98/22 129/9 129/17 129/23 I 114/14 122/11 suspended [3] 73/11
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24/14 107/15 107/23 IStatement [28] 1/17 I 69/17 92/19 92/21 81/9 89/3 95/12 Suspension [2] 73/6
108/11 108/15 108/19 2/5 2/8 7/4 9/12 11/4 I 92/24 96/12 129/12 85/12
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statements [3] 45/13] 109/6 suggests [1] 64/3 I system [34] 21/25

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take [29] 31253 I 1810271928113 I 81/14 85/17 86/17 I 102/23 103/20 104/4 I 68/22 70/1 70/9 70/14
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62/20 62/22 63/13 47/25 133/13 134/17 136/6 I 36/16 36/24 38/23 15/10 15/11 15/13
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101/11 136/11 110/17 114/7 120/10 I 10/14 10/23 11/23 71/18 72/9 72/11 39/11 39/12 39/14
taking [6] 65/9 81/15 121/17 124/9 126/14 I 12/13 20/13 20/21 7217 72/22 73/15 40/15 40/24 40/25
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109/18 text [4] 29/25 134/14 I 28/2 38/14 41/23 74/13 74/15 74/17 43/11 43/11 43/15
talent [1] 18/11 135/17 136/10 42/23 44/7 44/10 76/1 76/22 77/11 78/6I 46/6 46/8 46/11 46/17
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targets [2] 19/19 61/10 61/21 69/2 85/7I 10/11 10/21 12/18 119/16 123/7 123/9 I 106/21 108/8 110/13
69/15 85/8 85/9 86/20 12/19 12/20 14/3 124/21 126/8 126/13 I 116/24 117/1 119/16
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thing TA) 2/92 51/19 I 08/15 64/7 68/7 68/7 I 126/12 110/10 uncommon [1] 117/1
thing I eee 75/25 75/25 76/7 —‘Itouch [1] 40/24 truth [1] 100/12 under [12] 2/7 13/13
97/14 76/25 77/8 82/20 83/3Itouched [2] 52/7 try [15] 22/22 32/4 16/23 16/24 22/2
things [11] 13/8 83/5 83/7 84/11 121/2 35/8 36/8 36/18 52/4 I 28/23 34/18 67/10
13/24 16/1 20/8 45/6 103/10 120/11 120/19Itough [1] 16/7 52/14 74/13 77/20 73/15 96/3 117/2
46/7 60/5 82/4 86/22 127/3 towards [8] 19/8 42/1) 80/16 80/20 80/21 129/18

90/3 95/14 throughout [1] 131/1I 68/20 69/7 70/13 95/9I 82/9 84/25 127/11 underestimated [2]
think [162] thus [1] 108/20 101/8 112/7 trying [26] 12/11 89/16 123/25
thinking [2] 63/14 ITidswell [1] 56/4 town [1] 82/8 32/18 33/8 34/16 —_I underlying [4] 15/5
92/17 tight [1] 64/25 trace [1] 78/1 36/24 40/6 40/6 40/7 I 15/9 64/11 126/23
thinly [4] 133/9 tightening [1] 44/20 Itracing [3] 77/24 40/10 41/19 41/20 undermine [1] 66/25
third [10] 4/25 20/17 Tim [3] 87/5 90/24 78/21 80/18 42/5 56/22 68/6 76/4 Iunderpaid [1] 28/7
26/3 26/3 91/8 92/12 111/7 track [2] 34/11 78/12 I 76/6 78/12 85/20 90/2I understand [50]

98/7 130/16 130/19 time [45] 3/25 4/15 I Tracy [1] 96/13 92/4 102/8 102/9 24/24 25/13 28/24
1434/1 9/11 12/3 13/15 17/4 Itrade [12] 52/8 52/13 I 102/10 109/2 126/5 I 32/7 32/8 33/18 35/8

. 17/21 17/25 19/7 52/13 52/13 72/11 136/18 35/14 35/16 35/21

thirdly [1] 130/20

19/10 20/25 30/7 31/5I 72/12 73/4 78/10 Tuesday [5] 64/21 36/7 36/8 36/8 39/17

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those [70] 2/14 10/1 33/22 34/9 34/17 134/20 137/16 41/22 42/4 42/21 49/6
14/5 15/16 19/42 42/18 46/25 49/17 I trading [7] 12/9 turn [8] 1/10 7/4 54/6 54/16 57/19 62/8
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23/22 30/10 32/2 56/8 66/10 68/21 49/1 49/2 52/8 72/6 91/4 71/24 74/12 74/13
33/10 34/19 39/2 75/25 78/19 78/20 trails [1] 59/10 turnaround [1] 57/12) 76/9 76/12 76/23 82/2
39/13 40/9 41/8 45/151 88/14 89/11 89/23 train [2] 71/4 109/2 Iturns [1] 58/9 82/16 82/19 89/12
48/18 49/10 53/5 91/9 91/20 92/17 training [5] 9/23 Tutin [1] 18/16 96/9 98/1 111/12
59/19 60/12 60/17 101/2 101/24 115/9 I 44/16 58/10 82/18 two [37] 13/23 15/6 I 112/13 115/11 118/19)
61/16 63/19 71/16 116/24 117/4 133/10 I 126/3 16/4 19/4 19/22 28/21I 118/20 121/4 121/21
73/10 73/13 74/16 136/8 trajectory [1] 92/3 29/2 48/1 56/9 58/4 I 122/5 124/8

76/4 78/22 79/9 80/10! times [4] 7/2 11/14 Itransaction [1] 49/3 I 64/22 67/7 73/3 73/4 I understanding [12]
81/20 83/8 83/12 12/4 28/17 transcriber [1] 30/21 I 78/24 83/25 84/9 88/9I 12/2 23/21 25/24
83/18 84/9 84/25 85/4 timing [5] 11/6 64/25 I transcript [2] 2/2 88/11 91/13 92/24 25/25 31/10 37/25
86/6 87/22 88/10 65/17 65/20 65/20 117/23 93/20 94/20 95/12 48/7 108/5 112/16
89/12 91/20 92/9 title [1] 43/23 transfer [1] 2/18 95/13 95/16 102/25 I 114/8 114/12 136/19
93/20 94/21 94/22 today [14] 4/6 31/19 Itransferring [1] 103/14 103/18 105/7 Iunderstatement [1]
95/12 95/13 97/18 32/12 47/20 51/1 87/5) 93/14 122/23 125/24 126/4 I 52/24

101/6 102/18 1031 I 89/13 95/22 96/5 transform [1] 113/23 I 128/16 130/4 136/12 Iunderstood [7] 77/9
1403/20 105/15 105/24 99/23 100/17 103/4 Itransformation [4] 137/6 87/17 114/21 122/6
1410/8 110/16 113/11 105/11 126/24 88/7 93/10 126/22 two-year [1] 94/20 125/10 125/12 125/14)
417/11 120/13 120/16Itoday's [1] 92/16 12716 twofold [1] 124/22 I undertake [2] 61/4
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thought [9] 17/8 28/7 114/1 114/1117/6 —_Itransparent [6] 21/5 I~_________Iunfair [1] 118/20

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119/11 124/8 128/12 [tone [A] 45/24 90/21 90/22 UKGI [6] 1/20 3/22 18/1

430/10 too [14] 11/7 11/8 trauma [2] 43/3 82/9 I 6/7 6/10 8/5 15/17 uninstructed [1]

11/8 11/21 11/21 traumatic [1] 116/8 IUKGI's [2] 3/5 4/20 I 25/22
11/21 27/19 28/12 —_Itravel [6] 7/16 8/1 ultimate [1] 12/12 I uninvited [1] 25/18
71/19 90/24 99/24 I 32/11 63/11 64/9 ultimately [4] 49/19 I unique [4] 12/13

threaten [1] 30/4
threats [1] 117/6
three [15] 9/7 15/6

15/21 20/8 20/22 109/3 132/24 133/9 I 107/20 50/3 114/24 115/4 I 14/21 65/17 116/25
21/13 29/16 30119 {tok [9] 58/7 59/12 ITreasury [2] 3/6 unable [2] 87/16 I unit [8] 3/1 3/15 3/16
7516 93/17 105/17 I 123/19 109/1 3/17 106/11 117/25

64/22 71/1 80/25 94/2

114/17 114/25 117/11Itreatment [1] 17/18 Iunachievable [2] 118/9 121/5
threequarters [i]. 129/10 tree [1] 116/10 88/22 90/11 unknown [1] 100/20
30/19 top [4] 13/861/21 Itrend [2] 42/1 68/18 Iunaware [1] 37/12 Iunless [10] 17/3
through [40] 22/18 I 62/2 74/11 tried [3] 71/11 80/18 Iunbalanced [1] 9/17 I 27/11 30/4 37/14
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46/18 47/18 48/11 94/13 102/6 122/4 4/19 4/21 5/21 12/11 I 131/4 131/6 131/6 unobjective [1] 9/17
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