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The Post Office Horizon IT Inquiry
Tuesday, 15 October 2024
(10.00 am)
MS HODGE: Good morning, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you very much.
MS HODGE: Thank you. Our first witness today is Mike
Young.
SIR WYN WILLIAMS: Yes.
MS HODGE: Please could the witness be sworn.
MICHAEL THOMAS YOUNG (sworn)
Questioned by MS HODGE
Q. Thank you. Please give your full name?
Michael Thomas Young.
Q. You should have in front of you a copy of your witness
statement dated 8 August 2024.
>
A. Ido.
Q. That statement runs to 63 pages. Could I ask you,
please, to turn to page 58.
A. Yes.
Q. Do you see your signature there?
A. Ido.
Q. Is the content of that statement true to the best of
your knowledge and belief?
A. Itis.
Q. Thank you. Mr Young, I'm going to begin by asking you
a few questions about your professional background,
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Q. In that role, you were responsible for IT development in
the Europe, Middle East, Africa and Asia and Pacific
regions; is that right?
A. IT operations and development, yes, that's correct.
Q. Thank you. Before taking up your role at Verizon, had
you undertaken any formal training or obtained any
qualifications in information technology?
A. I have a diploma in security management.
When did you obtain that?
A. I think that was whilst at Orange. I was studying for
a diploma in security management and that continued
after leaving Orange too.
Q. So far as that diploma is concerned, in security
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management, what aspects of information technology was
covered, do you recall?
A. Most parts of cyber -- what we would know as cyber
security today.
Q. Thank you. You say you left Verizon in June 2006 and
after spending a year running your own consultancy you
joined BT in July 2007 as their Vice President of Global
Services; is that right?
A. That is correct.
Q. Dealing then with your employment at the Post Office,
you joined Post Office as Operations Director in August
2008, initially reporting to the Managing Director, Alan
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before we go on to deal with some of the substantive
matters dealt with in you statement.
Firstly, on leaving school, you joined the British
Army in which you served for 11 years; is that correct?
That is correct.
After leaving the army you served as a police officer
for seven years, rising to the rise of Detective
Sergeant; is that right?
That is correct.
Between March 1995 and February 1998 you say you worked
for Orange Plc; is that the mobile network provider and
Internet service provider?
It was at the time, yes.
Forgive me, at the time, yes. You explain that you were
initially employed by Orange as an Investigations
Manager, responsible for fraud and security matters: is
that right?
Correct.
You were later promoted to the Group Head of Security
Management: is that correct?
That's correct.
Upon leaving Orange, you took up a role as the Chief
Information Officer and Vice President of International
IT for Verizon Business Solutions; is that correct?
That is correct.
Cook; is that right?
That's correct.
You describe your responsibilities as Operations
Director as being to develop and manage at an executive
level the partnership and relationship with suppliers.
Correct.
Is that how you saw your role at the time?
(The witness nodded)
In your role as Operations Director you had a number of
direct reports, which included the Head of Change and
IS, which was responsible for overseeing technology, is
that right —
That's right.
-- as well as the Head of Security?
Correct.
When you joined the Post Office, what did you understand
the remit of the Post Office Security Team to be?
It was an all-encompassing type mandate. It was all
areas of risk across the POL business. So making sure
that employees were aware of their security
responsibilities so, therefore, there was some form of
training for employees when they were brought on board
to the Post Office. That was supplied and supported by
the Security Team, right the way through to acting on
intelligence that may refer to security in the Cash
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Vehicles in Transit arena, which was a very large part
‘of my operational remit, and right the way through to
investigations.
When you say "investigations", can you clarify what you
mean by that: are you talking about criminal
investigations; did you understand that the Post Office
Security Team were responsible for investigating alleged
offences of fraud, theft and false accounting, for
example?
One aspect of John Scott, the Head of Security's, roles
and responsibilities was to look at criminal
investigations, yes.
In your statement, you say that you were not responsible
for investigations into potential criminality within the
Post Office Network and that you had no involvement with
prosecutions or civil litigation. Given that you had
oversight of a team which conducted criminal
investigations, do you think that that's entirely
accurate to say that you had no responsibility for the
investigation into potential criminality within the
network?
Ido.
Who did you think was responsible at an executive level
for managing and overseeing the criminal investigations
carried out by the Post Office Security Team?
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Group via my former career as a policeman and some of
the gaps in my understanding were either covered off in
the intro by Alan Cook or my introduction in my first
weeks of getting to know my team and, in particular,
John Scott as he told me about his roles and
responsibilities. And I knew that, in terms of
prosecutions within -- potential prosecutions within the
Post Office, that it was being handled under that Royal
Mail Group type mantle, with a strong emphasis coming
from the Legal Team.
I wonder if we could please take a look at an email
chain that took place in 2011 between John Scott, your
Head of Security, you, Mr Young, and Rob Wilson, the
Head of Criminal Law team, and it bears the POL00019281.
Thank you. If we could scroll down, at the top we have
the last email in the chain. If we could scroll down,
please, to the bottom of page 2.
This is an email from, we can see, Rob Wilson. If
we just scroll up to the bottom of page 1, please, it is
said to be from Monica Thompson but seems to be sent on
behalf of Rob Wilson, Head of Security. This is
addressed to John Scott and copied to Susan Crichton.
As you'll see, you're later copied into the email. It
relates to a letter from a Member of Parliament
requesting that the Post Office discontinue the
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There was an overlapping responsibility managed via
Royal Mail Group for all criminal prosecutions across
the group and John was the -- John Scott, the Head of
Security for POL, was the lead into that. In my
introduction, when arriving at the Post Office, it was
made clear to me that that process did not need my
supervision or my line management because that had been
in place over a number of years, and I was told not to
get involved and to leave it with both Legal and that
RMG, Royal Mail Group, type framework.
Who told you that?
Alan Cook, my boss, the CEO.
Upon joining the Post Office, what did you understand to
be the relationship between the Post Office Security
Team and the Royal Mail Group Security Team and those
who had responsibility for criminal prosecutions?
As a former policeman, I knew that Royal Mail Group had
a means of prosecuting people because I'd seen them in
my police career involved in certain aspects of
prosecutions. What I understood from talking to John,
as an introduction to John, as one of my direct reports,
was how the process worked, because I asked questions,
in relation to what had been described to me by Alan
Cook.
So I had some sense of how it worked at Royal Mail
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prosecution of a constituent. It reads:
"Dear John
"Please find enclosed a copy of a letter dated
18 July received in today's post. You will see from the
associated summons the allegation in this case concerns
the theft of over £53,000.
"My current instructions are that not all of the
money has in fact been repaid. My understanding is that
a total of £18,104.75 has been paid and that in any
event despite the comments made in the letter that this
case in the public interest to prosecute.
"Bearing in mind this letter has come from an MP and
has been forwarded to the Chairman, I have copied the
correspondence to you and will be grateful if my
instructions could be confirmed in due course.
"If I can be of any assistance, please do not
hesitate to contact me..."
So that penultimate paragraph, Mr Wilson is seeking
confirmation of instructions from John Scott; do you see
that?
Yes.
If we scroll up, please. Thank you. So the second
email in the chain is from Mr Scott to you. We see
various other recipients copied, including Susan
Crichton, Head of Legal, and others. It reads:
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"Mike.
"Please find attached a letter from the [Right
Honourable MP], in regards to Post Office Security
prosecuting one of his constituents ... and requesting
that we discontinue.
"The letter has been forwarded to the Chairman's
office [as we see below], so is likely to become a flag
case."
He says:
"I'll ensure that the case and prosecution is
reviewed and that any future action taken is appropriate
and proportionate, although you can see the initial
assessment from Rob Wilson below.
"We'll arrange a holding letter in the meantime ..."
My question is this: if you had no oversight of
these matters, why is it that in July 2011 Mr Scott
brings this to your attention and raises it with you?
So amongst my direct reports -- and there were number,
we've only covered two or three of them -- I made it
clear that anything that was likely to escalate to the
Board -- POL Board and the Royal Mail Group Board -- and
certainly anything that was coming from the shareholder,
I'd like to be copied in and made aware of. And I think
in part, John is making sure, on a rare occasion --
a very rare occasion -- that he is standing true to that
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My immediate answer to that would be I didn't think it
described quite what my job role was. My job role was
a small -- a small part of my job role was the IT, with
acClO or an IT director, as we'd know them today, in
situ and managing that on a day-to-day basis. I had, as.
we briefly covered earlier, responsibility for all of
the core programmes, change programmes -- and I'm not
talking about IT change here, I'm talking about changes
to the network, changes to the property portfolio -- all
of the change programmes reported to me at the executive
level with Neil Ennis, at the time, being my direct
report for that; I had CViT, the Cash Vehicles in
Transit. Post Office, I think, still remains the
largest mover of physical cash in the country. It's
a very, very large enterprise with depots right the way
through the UK, and some significant fleet that backs
that up on a day-by-day type basis: and then I had
a number of other elements that sat alongside that, so
it was quite a broad -- quite a broad remit.
And a small part of my time was spent on the IT, and
Ive talked about that in my statement. It did grow
with Horizon Online but it still relied very heavily on
my direct report chain to keep me abreast of anything
that they thought I should be aware of, so that I could
lend my support and supervision at POL Board, at the POL
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instruction.
Just to be clear, from this it's right to understand
that you were aware that your Head of Security, John
Scott, was giving instructions to the Criminal Law Team
about the conduct of cases; is that correct?
Well, I'm aware clearly through the disclosure of what
the Inquiry has brought forward. Having read that, I'm
aware of it in terms of the content. Was I aware that
John was doing something like that on a norm? The
answer to that is no.
You did not know that at the time; is that correct?
No.
Dealing then briefly with some changes in your job title
and your responsibilities during the course of your work
with the Post Office, you've said that in and around
April 2010, your job title changed to that of the Chief
Technology and Operations Services Director; is that
correct?
That is correct.
That didn't result in any changes in your roles and
responsibilities; is that right?
Throughout my time, I think, at the Post Office, my
roles and responsibilities didn't change.
I think you say you weren't happy with that title
though; is that right, and why is that?
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Executive Team, and across that large mandate.
Now, a few months later in October 2010, you were
promoted to the job of Chief Operations Officer; is that
correct?
Itis but, by way of an explanation, at the time when
Alan Cook left -- and for me, Alan Cook left relatively
quickly, to a point where I think most of the Executive
Team that were in situ didn't really have much of
an opportunity to say cheerio. As we all know David
Smith, former Parcelforce, came in as an interim
Managing Director and, at that time, you know, David --
he didn't explain it to me, though I asked -- had
promoted or given Paula Vennells the title of Chief
Operating Officer.
You can't be an Operations Director and have a Chief
Operating Officer without some people drawing
conclusions and looking at how that all works together.
So I had the debate with David Smith, and he said, "What
title do you want because, you know, Chief Operating
Officer is Paula's and frankly that's done", and I chose
what I thought would best get me through, if you like,
in the interim. But it wasn't truly reflective of the
role, as I've described.
Much later on, as David Smith leaves the Post Office
and then goes into group to pick up a new role in Royal
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Mail Group, Paula becomes the Managing Director.
I wasn't aware that that was going to happen but clearly
things had moved to a point where that took place, and
a little later down the road, Paula suggested that I've
then become the Chief Operating Officer. But through
that entire journey from Operations Director to Chief
Technology and Services Director, and even Chief
Operating Officer, my roles and responsibilities didn't
change. There was a significant programme that took the
best part of my final year at Post Office to complete,
which was essentially manage the negotiation on behalf
of the Post Office as it related to separation from
Royal Mail Group, and that was, you know, three or four
days a week to bring that to fruition over a 12-month
period.
And during that time, in that mainstay, that's when
I was the Chief Operating Officer.
Thank you. So just dealing briefly, then, with the
circumstances of your departure. In March 2012, you
were informed by Paula Vennells, then Managing Director,
that you would not be sitting on the Board
post-separation, you say, and that your title would no
longer remain Chief Operating Officer; is that correct?
That is correct.
You say you decided to leave at that stage as you
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I physically left in the second week of March but
contractually left, yes, around that date.
I'd like to rewind then to when you first joined the
Post Office in 2008 and your knowledge and understanding
of the Horizon system that was in place at the time. So
the version of Horizon which was running in the Post
Office at the time you joined was Legacy Horizon; is
that correct?
That is correct.
In your statement you make some general comments about
your attitude to Legacy Horizon. I wonder if we could
bring that up, please, at WITN11130100, at page 10,
paragraph 30, please. You say this:
"During my first three years I spent a lot of my
time visiting Post Office branches, getting a feel for
everyone's morale, and trying to see whether there were
strategies we could implement to help. Nothing in the
branches was reported to me that indicated that there
was something fundamentally wrong with Legacy Horizon or
Horizon Online. Still, to this day, I am unaware of
an identified part of the Horizon code that someone can
point to [to] show that Horizon is fundamentally flawed.
I believe an effective IT system requires not only good
technology, but that technology needs to be wrapped in
good processes and training for all users. Like any IT
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regarded that as a demotion?
It's difficult, in career terms, to go from one title,
to another title, to Chief Operations Officer, to then
go back to another title, which may very well have been
Operations Director. The mandate I'm going to presume
was not likely to stay the same. In fairness to Paula,
I had more than hinted that the separation negotiation
that I was undertaking was likely to be my last big
effort for the Post Office. So I think there were
a number of people that knew that it wasn't my intent to
say -- to stay. I think I'd given my all over four
years for Post Office and wanted to move on to something
different.
So when the dialogue took place in a one-to-one with
Paula, we rapidly, you know, came to an agreement on how
that might work. But, certainly, going from Chief
Operating Officer back to Operations Director, and then
some sort of restructure, which inevitably will have
taken -- would have taken place based on separation, it
would have seen less of a remit and, candidly, I wanted
to leave on a high, having delivered the Separation
Agreement and having that title.
Just to bring that summary of your roles and
responsibilities at Post Office to a conclusion you,
ultimately left in April 2012; is that right?
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system, they all have ..
You've used the term "BEDs", that's bugs, errors and
defects; is that right?
(No audible answer)
"... requiring fixes or updates."
Now, I just want to clarify, if I can, what it is
exactly that you're seeking to convey here. The first
comment you make, in effect, is that nothing was brought
to your attention in those early years that suggested
Legacy Horizon was fundamentally flawed; is that fair?
That's correct.
But you knew from your previous roles that all systems
have bugs, errors and defects; is that right?
That stands true today with any system.
Therefore, like any other system, you would have
expected Legacy Horizon to have some bugs that required
fixing; is that fair?
It's difficult to comment over something you're not
aware of. So if we just take a step back for a moment,
so on arriving at POL, I was taken through -- I think my
statement makes it clear -- about an hour's worth of
training and overview of Horizon and I was given
a fairly thorough brief by the then IT Director,
Mr Smith, or Dave Smith, on, you know, how it was
operating across The Branch Network, and, for those
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people that know Horizon, an hour is not a great deal of
time.
So no one in the course of that introduction in the
model office, within what was then the headquarters of
Post Office, indicated any flaws with the system.
Operating issues, I want to be clear of what I mean by
that. So no one mentioned any BEDs but they did mention
blue screens and network-related issues in branch which
caused particular problems. But, as part of that
dialogue, I was also briefed on the fact that Horizon
Online, HNG-x, in other terms, had already been planned
for and was already contractualised with Fujitsu, so
it's replacement was already in swing with Fujitsu
already undertaking to write the code for that new
system.
So I arrive, I'm given a brief overview of Horizon
and an hour's worth of training in the model office via
the IT Director. I'm told how the contract works to
a degree, in very short measure, and I'm told that the
future of Horizon has already been embedded into
a contract that lasts until 2015. But Horizon Online
sought to deal with the operating issues that were felt
across a number of branches in the network.
But at no time in that dialogue was there any
mention ~ I mean, the one that I think the Inquiry has
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a significant bug, it was addressed, this was the form
of it but, to date, since then, it's clean running.
I would have expected it but it didn't come.
Dealing with what Mr Smith did say to you, you addressed
this at paragraph 41, please, if we could turn to that
on page 14. Thank you. You refer at the top to two
issues, those are the hardware issues to which you've
just referred -- the blue screen freezes and the ISDN
Internet connection -- and you say that the two issues
described were not linked to criminal prosecutions.
You go on to say:
"However, I was aware of complaints about the
integrity of Legacy Horizon by some of the
[subpostmasters]. I recall speaking to Smith ..."
That's David Smith, Head of Change and IS; is that
right? There are, of course, two David Smiths, so we
want to be clear that -- is that correct, you're talking
about him?
Yes, that is correct. It was confusing for me at the
time.
You recall speaking to him about to him about the
allegations when you joined the Post Office. You say:
"From memory, I believe he assured me verbally that
there was nothing wrong with ... Horizon and nothing to
worry about (or words to that effect)."
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picked up on and I've seen since the Inquiry has come
about is the Callendar Square issue, as an example. No
‘one took me through that or made any indication that we
were suffering with any type of BED that was core to the
code of Horizon. And the fact that the network was very
expansive -- at that time, it isn't the size it is now,
it was 12,000/13,000 branches -- you know, if there were
significant issues in the Horizon code, they would have
aired themselves in some form or other in a more
expansive way across the entire network, and that
clearly wasn't the case when I arrived.
You have mentioned, Mr Young, the Callendar Square bug,
which you say wasn't brought to your attention during
your early briefings on Horizon; is that right?
In the introduction, yes.
Do you think you should have been told that there was
a known software bug in Legacy Horizon which was capable
of causing receipts and payments mismatches, of which
the Post Office was aware?
I'm hesitating only from the point of view that, clearly
in the eyes of the Post Office, certainly David Smith --
it was in his rearview mirror and had long gone by the
time I arrived two years later.
Would I have expected to have been told? Had I been
in his shoes, I would have said that there was
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I just want to explore with you briefly what you
understood Mr Smith to be saying about Legacy Horizon,
and I think there are two -- well, there may be more,
but two possible readings of this: one is that he was
telling you that there were no faults in Legacy Horizon,
which might explain the accounting errors about which
subpostmasters were complaining; another possibility is
he was saying that, like all systems, Legacy Horizon had
some faults but that these were being appropriately
managed.
What did you understand him to be saying to you at
the time: was it the first or second of these, or indeed
something else entirely?
So something slightly different. There wasn't
an in-depth discussion about some subpostmasters
complaining about Horizon. So, you know, it wasn't
a ten-minute/five-minute discussion around that,
I remember him saying that some subpostmasters have
historically complained about the system and I didn't
draw too much of a conclusion from that, other than
I thought it was related to both the ISDN issue the
network in branch, as well as the blue screen type
problems that occurred as part of that process.
So I asked -- I asked, "Are we talking about the
operational type issues that sometimes occur in branch?"
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He said "Yes and no, some people blame the system when
they're caught out". And I asked, "What do you know
what you mean by caught out?"
"When they may be stealing from the branch", was
where the conversation -- I think where the conversation
went. But it didn't -- I didn’t hang on that and,
candidly, neither did he.
What you said here was that he gave you a verbal
assurance that there was nothing wrong with Legacy
Horizon. But does not follow that that's not entirely
consistent with what you yourself understood about IT
systems at the time, which is that they're all liable to
have some bugs, errors and defects and, in your words,
the issue is how you deal with that?
So at the time that Dave Smith was taking me through
that process in the model office, there were no issues
with the system from a code point of view. So there was
nothing suggested that a coding error was causing
problems in branches. I want to be clear about that.
So we didn't go down that route. I've made already
clear that he didn't mention the Callendar Square issue.
He largely emphasised the operational frailties of the
Legacy Horizon system, and talked to some postmasters
suggesting the system was at fault when they were
prosecuted for theft.
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discrepancies?
To investigate what, sorry?
Accounting discrepancies.
I don't think I ever, in those early days -- in fact I'm
trying to think across the stretch of the 4 years -- did
we -- I'm sure we're going to come to the Horizon Online
early pilot issues -- but I don't think I ever went in
to a conversation with Dave Smith, looking at the
end-to-end process, or with Fujitsu, where the start of
the conversation was about accountancy or data
mismatches because it had been made clear to me by both
entities, both Fujitsu, Dave Smith and the support
teams, that Fujitsu/Horizon, were all working within the
limits of the contract, and within the limits of the
SLAs.
And so no one was raising their hand to suggest we
had a -- I'll call it a code issue on Horizon, or
an anomaly that might relate to code, that might be
causing a mismatch in some form or other.
You've just said that you were given assurances by
Fujitsu that there were no significant issues, coding
problems, that might lead to accounting discrepancies.
Who within Fujitsu gave you those assurances?
In order to answer that question, I think it's probably
best to frame how I elected to run the relationship with
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Did you make any enquiries of Mr Smith about the
end-to-end processes which were in place to manage any
bugs, errors and defects that were detected in Legacy
Horizon?
We did that much later on in the practicalities.
This -- in my first weeks at the Post Office, there were
a number of people I had to see and be introduced to,
including at Royal Mail Group. So as I became more
familiar with the architecture, as I got to grips with
some of the contractual arrangements with Fujitsu, they
were pieces of work that were done over a number of
months, as you start to get a sense of your whole
mandate and what that means. It was a very, very big
mandate and there were lots of calls on my time. So
invariably some of this homework, for want of better
words, was as I've suggested: homework. You took it
home and ran through it with a fine-toothed comb.
Did I understand the way the Helpdesk and other
functionality worked around Horizon? In broad terms,
the answer to that is yes.
So you say that that's a topic you dealt with a little
later, when you were dealing with practicalities. What
do you recall being told about the end-to-end processes
that were in place, within Fujitsu but also as between
Fujitsu and Post Office to investigate accounting
22
Fujitsu, and I think my statement makes it clear but
I'll spell it out. I didn't have the time, candidly --
the time it deserved, certainly -- to run down
everything in IT, that's largely why we had an IT
Director/ClO and a big team, a fairly sizeable team for
what essentially is an outsourced solution. It's
aservice. The contract made it clear that we didn't
own the IP to the code and some of the conversations
I had with a Gavin Bounds or a Duncan Tait at Fujitsu
made that quite clear, "The code is ours. You own the
service because you pay for that but you don't pay the
code". I had a particular view on that but I can't
argue that the contract supported their stance.
So I found it, you know -- I managed the
relationship on the basis that I would deal with the top
tier management when there was an escalation and I would
clearly get closer to Fujitsu as it related to Horizon
Online, which was coming down the road, and build
a relationship on that basis. But I wanted the IT
Director/CIO to have responsibility for running the day
to day and the day-to-day end to end.
So, you know, the CIO and IT Director didn't have
responsibility for training; that largely settled with
‘our network branch colleagues. But they did have
responsibility for some of the Helpdesk and technical
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type aspects of the service. And I wanted the IT
Director and the CEO to manage that because, candidly,
if I'd been in their shoes, that's the way I would have
wanted to run it.
So the way we had it framed very early on was that
I would basically ring the top echelon of Fujitsu if
leverage was required, to get things resolved, or to
talk through strategic type themes that the IT Director
and I were aligned to, but they were there to run the
relationship on a day-to-day basis, including any
operational impediments that may occur along the
journey. And I think the disclosure documents provided
as part of the Inquiry support that framework.
The answer you have just given suggests that you weren't
ever given any direct assurances by employees of Fujitsu
as to the robustness or integrity of the code in Legacy
Horizon; would that be correct?
Let me apologise, I should have answered your question
because I went off at a slight tangent there. I think
you have seen it in some of the documents but,
certainly, I had a bullish relationship with Fujitsu,
I demanded excellence and, if I thought there were
shortcomings, I wasn't immune from making it quite clear
that I was unhappy and, again, taking the discovery
document process as a whole, I think that theme comes
25
come to Horizon Online shortly -- but I understood your
evidence a short time ago to be that, so far as you were
concerned, you'd received assurances, both from David
Smith but also from Fujitsu, that Legacy Horizon was
operating fine. What I wanted to establish was whether
you were given any direct personal assurances by Fujitsu
concerning the operation of Legacy Horizon; do you
recall whether that is the case or not?
Two names that spring to mind in terms of that dialogue:
Stephen Long and Gavin Bounds. And it wasn't one
conversation; it was probably several over the tenure.
From those individuals, you understood that all was.
well?
I want to be clear. In the context of a conversation
with Fujitsu around where things were, I had, as part of
that conversation -- whether it was in their offices
visiting their sites, which I did periodically -- I had
a conversation as part of that process that asked about
the continuing integrity of Horizon Legacy and, even
after the delivery of Horizon Online, Horizon Online.
Thank you. So if we move on, please, to the pilot of
Horizon Online. You explain in your statement that you
became aware of several bugs, errors and defects that
were identified, that is to say the fault/the problems
manifested during the rollout of the pilot; is that
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through.
So I would regularly, where there was an operational
issue, if we go to Horizon Online as a classic example,
when I was made aware of the two Oracle issues, that we
know to be Oracle issues now and had to wait some time
to find them during the pilot, I'll use words my mother
would say: I gave Fujitsu pretty short shrift and said
"These need sorting out really, really quickly". And,
in between those times where there may have been
operational imperatives that we were dealing with,
change that went in badly, hardware failures that may
have happened in the data centre, I was constantly
asking the question, you know, "Does the system work the
way you would expect it to? The service seems to work
for us", et cetera, et cetera.
And, as the media played out around the integrity of
Horizon, those messages back to Fujitsu got sharper and
they got sharper. A lot of communication via the
telephone but also some communication, as you see in the
disclosure documents, by email and by letter, to ask
that very question and demand some sort of discovery
process over what, essentially, was two-thirds new code
in Horizon Online.
With respect to you, Mr Young, I don't think you have,
in fact, answered my question which was -- and we'll
26
correct?
Yes, that's correct.
These faults had caused service interruptions and delays
which required the rollout to be paused; is that right?
That is correct.
Now, you said on more than one occasion in your
statement that you were not concerned about the
existence of bugs, errors and defects per se, and that
the key issue for you was how they were being handled;
is that fair?
That's correct.
I think you say that's particularly so in a pilot
period, where you might expect to experience more
problems, more faults, than in live operation?
Correct.
Now, you explain in your statement that, for some
considerable time, Fujitsu were unable to identify the
underlying root cause of the problems that were being
experienced during the pilot; is that fair?
That is fair.
You say that you were sufficiently concerned about the
situation that you considered rolling back the pilot and
reverting to Legacy Horizon; is that right?
That's correct. I did say that. I would like to point
out that a rollback would have been extremely difficult
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and caused any number of problems. So a part of your
thinking when you're going through that process is, "Do
I cause more problems by rolling back than trying to
persist and roll forward?" And you're constantly
evaluating on what you're being told and the datasets
you've got to work with as a consequence.
But, certainly, had Horizon Online seen a more
elongated timeline around dealing with what we now know
as those Oracle bugs, we would seriously have had to
consider rolling back.
Do you recall when it was that the Oracle bugs -- well,
obviously, I think you didn't know initially that there
were Oracle bugs. We'll come on to look at when that
was discovered but, when the problems first manifested
themselves in the pilot, do you recall precisely when
that was brought to your attention -- I say "precisely",
in terms of months?
I mean, through the disclosure via the Inquiry process
and the documents that were provided to me, March 2010.
is around the time frame, so between February and March
a data mismatch was being aired and, as I understand
it -- and I knew it was small numbers -- in comparison
to the network as a whole, I think there were, at the
time, 62 affected branches.
We'll come on to some of that detail shortly but in your
29
I had a viewpoint that suggested, as it was coded
related, find the issue in the code and then someone
goes into that code and fixes it almost overnight. And,
as we know now today, digital systems are done that way
today right down to your iPhone. So I had a viewpoint
then that that should take days not weeks, and this took
too long. So I can't be specific about the date but my
general take at the time and I feeling I have now is
that it took way too long to address.
I would like to ask you, I just wish to clarify, please,
what you say about these two bugs at paragraph 46 of
your statement. So that's at the bottom of page 15 and
cover the page to page 16, please. If we could bring
that up.
You explain there that it was in March 2010 you
learnt that the faults causing the service interruptions
and delays during the pilot were two different Oracle
bugs, that being faults in the Oracle database software.
You then say this:
"The two Oracle [bugs, errors, defects] caused
a data mismatch; therefore, I still maintained that
there was nothing fundamentally wrong with the system.”
Can you just please explain what you mean by that?
Why is it that there being a data mismatch meant there
was nothing fundamentally wrong with the system?
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statement you say it was in March 2010 that you learnt
that the underlying root cause of the faults/the bugs,
were a fault in the Oracle database software. So that's
consistent with what you've just -- well, that's
slightly different, in the sense that March 2010 was
when the underlying root cause was identified. My
question to you was: do you recall how long it took
Fujitsu to identify that underlying root cause, from the
point at which it was brought to your attention that
these faults were manifesting to March 2010?
It was number of weeks, so can I be specific? No, but
it was number of weeks. In my world, it was too long,
and there was a lot of telephone communication from me
to the CEO at Fujitsu around, you know, where his sense
was on finding the issue and mitigating it. Again, as
you're evaluating the continuing rollout versus
a rollback, those conversations were pretty much
an imperative. There is no doubt about it that, from
the point it had been identified to the point that -- as
in "We've got an issue" -- to the point that we've got
“It looks like it's bug related" and some form of
potential resolution from Fujitsu, in my mind, it took
way too long, and not, in my world -- you know, in my
tech world, not the normal time frame for resolution
around a software bug.
30
I've been in the technology world for a long time.
So -- and I've rolled out probably thousands of systems.
So I guess the point I'm trying to make, as part of that
process, is: when you're in a pilot, you're going to
have problems. I've never known a pilot in any rollout
of any system not have some sort of associated issues
with it. And, again, I'm going to make the point: today
you can be given a new phone and within weeks it will
have a software update. It's dealing, essentially, with
bugs that have come to light that weren't seen or hadn't
come to light in a test type process.
This was no different on Horizon Online. I knew
that, providing we could identify the nature of the
bugs, that we could address that software. It's still
in pilot. It's not in main rollout and, at the point
the bugs were found, rollout stopped. So, you know, I'm
in a place, as the executive in charge of IT, with my
CIO, we're in charge of a process that, if you like, is
half pregnant and we've got to work out what we do next,
and part of my worry was that we needed to have some
assurety from Fujitsu that they could deal with the bugs
once they'd identified them and that we could get back
into smooth running.
I look at that process, rightly or wrongly, but
certainly from my point of view and experience, I look
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at that process as relatively the norm in rolling out
a pilot, and this was a pilot. It wasn't a great start
to a pilot, and there were lots of communications both
to the POL Board and my executive colleagues, and to
Royal Mail Group as a consequence. And there were
ramifications around some of that communication. But
I still felt relatively confident that having identified
the bugs, the mitigations would address it and we'd be
back to safe waters and, therefore, fundamentally, I had
faith in the system.
Just to be clear, because the way it's written perhaps
could be read in a number of different ways but I think
what you're saying is that the mere fact that a bug had
caused a data mismatch did not, in itself, mean that
there was something fundamentally wrong with the system:
is that what it is you're saying?
That would be a better way of interpreting my answer,
yes.
Now, I'd like, please, to look at some correspondence
that you had with Duncan Tait, who was then Managing
Director for the Private Sector Division at Fujitsu in
May 2010. That's FUJ00095658, please.
Thank you. This a letter from you -- we'll see when
we get to the bottom -- to Mr Tait, dated 10 May 2010.
It reads:
33
onerous and may be affecting the profitability of the
contract."
Just pausing there, what exactly did you mean by
that, the concern that Fujitsu were realising savings,
and --
There was a significant saving to the Post Office for
rolling out Horizon Online, 50 million. It was.
important to our cost base in the eternal endeavour of
the Post Office to get to self-supporting, and the
contract in place with Fujitsu had to not only deliver
Horizon Online but it had to deliver those efficiencies.
What I'm trying to convey, as part of that language in
there was I was worried that they had -- they didn't
have enough expert resources managing this important
programme. In other words, they'd leaned it out. In
order to realise efficiencies, they'd cut costs
themselves, and there weren't enough expert resources to
deal with the bugs or other related issues that may come
cout from pilot. And I'm making that point as part of
that process, and I'm asking him to go open book, which
is rare, but it’s -- it basically means, "Show me your
costs and your resource plan, so I can see what I'm
paying for". They're not duty bound to do that but
I thought it was a request worth putting to them.
I should emphasise that the issues related in the
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"Dear Duncan
"Recently, members of the Post Office Executive Team
met with some of our Group Executive colleagues to
review our current standing on our Fujitsu contract.
The purpose of this meeting was twofold, one to review
the current situation of the HNG-X Programme and,
secondly, to review the Fujitsu contract as a whole.
These types of review follow best practice and are
common within the Group where there is significant
reliance on a partner or a supplier."
You then say this, and this culminates in your
request for what you describe as an open-book approach,
you say:
"It was recognised during this review process that
our relationship with Fujitsu is of long standing, has
thus far proved fruitful to both parties and continues
to play a pivotal role in the successful delivery of
Post Office's products and services. There were several
areas where we believe there is room for improvement
that would allow us to follow best practice and further
reinforce confidence in delivery."
You then say this:
"There remains a concern that with the longer
running rollout of handling and the fact you are already
contractually realising our savings that this may be too
34
early pilot brought, you know, concerns -- not
significant concerns, but certainly concerns -- both to
my executive colleagues and the Board, and later on at
Royal Mail Group Board when Alan Cook was presenting
where the Post Office was with its strategy. He had to
update the Board with regards to where HNG-X was in
terms of its rollout and, as a consequence of that, Alan
and I had a conversation around the outputs from our own
Executive colleagues, some of the questions that were
asked in the Royal Mail Group-type process at that Board
meeting, and we agreed that I would sit down with the
Group's CIO at Royal Mail Group, and the General Counsel
of Royal Mail Group, just to discuss the Fujitsu
contract, where things were and what we might be able to
do collectively at a group level to bring pressure to
bear on Fujitsu to take us through a successful pilot
and subsequent rollout.
There's a big risk both in terms of being able to
deal with customers in the branch network with this new
programme and also that 50 million in inefficiencies.
Just to be clear, it was those discussions you just
described that led to the sending of this letter; is
that correct? We see that reference in the first
paragraph --
I think in the three of us sitting down, I agreed that
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I would take the overall concerns -- and we talked about
what those is might look like -- and write a letter to
Fujitsu. I probably ought to -- because it would
probably be helpful to, you know, to the Inquiry to.
know, if they don't already -- Fujitsu -- we were
Fujitsu's major client in the UK, I think their biggest
client in the UK, certainly one of the top two. They
had an ambition, a significant ambition, to grow the
account into Royal Mail Group. If you'll note in some
of the communication between POL and -- from Fujitsu to
POL, it's usually someone that signs off with "Royal
Mail Group Account Executive", or whatever the case may
be, and the reality is, Royal Mail Group wasn't taking
anything in terms of a service from Fujitsu: it was POL,
and it was Horizon.
But there was a drive to seek further revenues from
Royal Mail Group, and my sitting down with the General
Counsel and with the CIO of Royal Mail Group and then
formulating this letter and making clear the type of
entities that had been involved in the formulation of
the letter was a way of applying pressure to them that
suggested, you know, again, in the interests of keeping
it short and candid, "Get your act together here because
if you have got ambitions with Royal Mail Group, we as
a whole are very unhappy and we need you to show us that
37
a feeling that it was Royal Mail Group Board, POL Board
and POL Executive challenging Fujitsu to step up to the
plate.
Now, you don't receive a response from Mr Tait until
29 June 2010 and that comes into you by email. We can
see that at FUJ00096312, please. If we scroll down,
please, to the second page, we can see at the top the
date of the email, 29 June 2010, and the subject is
“Response to your letter". So that is the letter of
10 May we were just looking at a short time ago. He
says to you:
"Dear Mike,
"Thank you for your letter -- we have recently been
having similar meetings and have come to similar
conclusions in the governance area. We would like to
support your initiative and formalise into contract
a periodic ongoing senior level relationship review and
a more operational level board at which the current
governance relationships in the contract come together."
He then says that has been taken forward. If we
then look down, please, to the third paragraph, he says:
"Since your letter, I am extremely pleased with the
progress that has been made. We have located the source
of the troubles and taken steps to rectify the issues
and we have now recommenced the pilot. Currently
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you are manned up with the right resources to deliver
what we expect you to do and we want some assurance that
you're also going to give us our efficiencies and" as
the letter further states, "we want some assurance that
the code around Horizon Online works as it should do".
We see there, as you say, in addition to your request
for an open book, in the third paragraph, you say you'd
like access to Executive correspondence within Fujitsu
relating to a recent red alert. You go on to say:
"Additionally, we would like you to consider
bringing in a qualified independent party and asking
them to review and audit how the current programme is
run, as well as testing resource and skill levels both
on the programme ... and other key initiatives underway
at Fujitsu."
As you said just now, you explain in your statement
that the reason why you, in particular, I think, but
possibly others, felt it was necessary to request
an independent review was that you had concerns about
the quality of the code in Horizon Online; is that
correct?
Yes. It's one of the only times -- there may have been
‘one other time -- where I formally wrote a letter to
Fujitsu, rather than a phone call or even an email.
I wanted it -- you know, I wanted it to have a tone and
38
counters running on HNG-X stand at just under 20% of the
estate. We are now rolling out at about the maximum
levels originally envisaged with no further sign of the
problems that initiated our discussions."
He goes on to say:
"The cause of the issues [as you've already alluded
to] that delayed the High Volume Pilot was deficiencies
with the Oracle product code."
He says:
"Oracle has confirmed this and that the issue has
been resolved. I am sure this conclusion will have
restored your confidence in Fujitsu and both our teams’
ability to deliver this programme."
He then goes on to say this:
"As a result, I think it makes sense for our teams
to maintain focus on the remainder of the pilot and the
full rollout phase, as you appreciate, with all complex
major programmes there will be issues to deal with. At
this crucial phase, we can see no benefit and will not
be pursuing a third party review."
So, in essence, he rejects that proposal in your
letter of May 2010 to carry out a review.
We can see your response to him, please, at page 1.
You say this:
"Duncan
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"Thank you for your response to my letter.
"It won't surprise you to learn that I am somewhat
disappointed that it took so long to formally reply to
my correspondence of 10 May and with the apparent 'sea
change' on approach to some of our concerns."
So you effectively then go on to say:
"My understanding from our weekly calls was that you
had taken advice from KPMG as to how you could go ‘open
book’ with us and therefore didn't foresee a problem in
doing so. On the issue of having a qualified
independent party audit to evaluate Fujitsu programme
execution, along with staffing levels and skills base,
I have been briefed that you had spoken to several
entities to pursue this endeavour. Indeed, I was told
you were close to agreeing terms with one of these.
Additionally, in our calls you will recall I had asked
whether there was a possibility of the Post Office
‘owning’ the Terms of Reference and again this was
something you were going to strongly consider.
"As it stands now, I feel I have been led down,
a journey of a number of months, just so you can say
‘no’. This does not reflect well on our relationship.
and will not be well received in the next review."
It's quite clear, I think, from reading that email,
that you had understood from your conversations with
a
I thought, candidly, that we had a better
relationship than that. I had known Duncan in my job
when I was at Horizon as the CIO there, and I thought he
would recognise what I was having to deal with, in terms
of the pressure around Horizon Online and the oversight
that the whole thing was under from Royal Mail Group
through to the POL Board and, therefore, I was expecting
a little bit more of a collegiate attitude from Duncan
than I got.
There were several calls where I make that quite
clear, and Duncan made clear that he didn't think there
was anything wrong with Horizon, there wouldn't be
anything -- isn't anything wrong with Horizon Online.
I was getting the line of "We run algorithms against the
code, we're looking constantly looking for anomalies,
you should take assurance from that", et cetera,
et cetera, et cetera.
And my response would be, "If you went open book and
demonstrated some often that, I'd be able to see it.
I can't naturally -- having taken so long to deal with
the two Oracle issues, I can't take you at your word",
and they were pretty strong conversations and,
ultimately, the only take away I took from those
conversations and from this interchange was that, you
know, "It's our IP and we don't want to share it. We
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Mr Tait, firstly, that he was willing to undertake that
third-party review that you'd requested; is that
correct?
Yes.
And that you'd felt that you'd been rather strung along
by him, to only be told many weeks later that it
wouldn't be taking place?
I was pretty angry at the response.
Did you take any steps to escalate this issue and to
insist upon an independent review of Horizon Online at
that stage?
So certainly the POL Board, the Executive Team and Royal
Mail Group were aware of the interchange here, because
all those parties had played a part in bringing it
together. So what perhaps -- in order to be a little
bit more helpful, but perhaps what this letter and
response don't quite show is that there were two or
three phone calls that went between, you know, the
letter and the response.
Duncan and some of his team were of the view that we
had signed up to a service, and the service was working
in its given parameters within the contract -- and
I couldn't argue that -- and that Horizon Online was in
pilot and, again, his response of around 20 per cent of
the network starts to, you know, allude to that point.
42
own the intellectual property rights around the code,
you've no right to see it, and you've no right, really,
to insist that we review our own code".
I didn't agree with that. I've never agreed with
that but it gives you a sense of where Fujitsu were in
their thinking versus where I was, and several of my
time, including, in fairness to Lesley Sewell, the ClO
at the Post Office.
You know, if there's one overriding message: don't
see this as a one-off letter and reply. There was a lot
of communication that sat round it at all levels and,
whenever the opportunity allowed, I would interject
with, you know, "We need to start looking at the
system".
You'll note, I do want to draw a conclusion in case
we don't get there, I do want to make a point. One of
the last documents I provide, just before I exit Post
Office, is a noting paper, I think, to the POL Board,
and then there's a POL Board -- there's two documents --
where I actually ask, I think we're set for -- I'm sure
we'll get there but I think we're set for a proper
end-to-end review, and there were a lot of reasons
around that, but some of this was catch-up to that.
And then there's another point. Martin Moran, who
had been brought on to run the white label telecoms
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product that Post Office was marketing at the time, sat
down with me -- it was another one of my objectives, to
sit down with Fujitsu, to use Fujitsu as a means of
taking their pricing power to get a great telecoms
contract out of BT. They're a big entity, so they'd get
better discounts and we were trying to move away from
Talk Talk.
But in the course of that dialogue, one of the
things that I pushed was, "If we do this telephony
contract with you, Fujitsu, I want the rights and the IP
to the code for Horizon", and I asked for that
specifically to be written in so that issue around the
IP of Horizon could be taken off the table. If I owned
those rights, I now have a right to look at my code
because I've got those now contractualised as a side
product from agreeing a telephony contract with you.
And Martin Moran makes that clear in one of the
Board papers that was in the discovery process. But the
point I'm trying to make is: that was me at that
negotiating table with Martin saying, "We'd like the
IP". I just needed that final segment to take away the
point of, “You don't own the IP. We own the IP, you've
got a service".
Just to wrap up where we are at the end of June 2010,
you've been sufficiently concerned about the quality of
45
the marketplace to recruit a CIO that had financial
services experience -- that's where we were going with
some of our products and services set -- because
I didn't have it, and David Smith, the now retired IT
Director, didn't have it. So I went out and recruited
Lesley Sewell as part of that process. She was the
ex-Managing Director of IT for Northern Rock, the bank,
at the time.
So Mark Burley reported to Lesley and his job was to
rollout Horizon Online.
Now, he addresses his email to you and Sue Huggins, and
it's not necessary to go through the full chain but it
originates with a request from David Smith essentially
raising a series of questions prompted by the proposed
Channel 4 report, and Mark provides some answers to
those and, in this email, we see some additional points
that he wished to draw to your attention and the
attention of Sue Huggins. I just wanted to scroll down,
please, to look at a couple of those points.
Now, he refers at point 1 to the fact that the
system has been designed to retain integrity, even when
it fails and he said this is important, "as we could
never claim the system does not fail".
That's a point he makes further down in the email.
At point two, he refers to three cases of which he
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the Horizon code to request an independent review of
Fujitsu but Mr Tait, standing on his contractual rights,
has said, "It's not going to happen"?
Indeed.
So moving forward, then, please, one month later,
questions are raised in the press about the integrity of
Horizon, in reporting by Channel 4; do you remember
that?
Ido.
That reporting prompted David Smith -- so a different
David Smith, this is the Managing Director of Post
Office -- to request an internal investigation into
complaints about Horizon; is that correct?
You're referring to the Ismay Report?
Yes.
Yes.
I'd like to please look at some correspondence relating
to that request and which ultimately flowed into what we
know is the Ismay Report. It bears the reference
POL00120481, please. Thank you. This is an email from
Mark Burley to you and Sue Huggins. Just to clarify,
what was the relationship, in terms of reporting, as
between you and Mark Burley?
Mark reported to Lesley Sewell. You know, David Smith,
the CIO or IT Director, has retired. I went out into
46
is aware: Cleveleys, Castleton and Alderley Edge.
These goes on to say this at point 3:
"None of the subpostmasters dismissed for
discrepancies have -- to my knowledge -- produced any
hard evidence. However in the past [Post Office
Limited] hasn't always tabled the evidence from the
audit logs."
Now, dealing with that first point, as to the fact
that subpostmasters hadn't produced hard evidence that
accounting discrepancies for which they'd been held
liable had been caused by faults in Horizon, with your
police officer's hat on, did you think it was right that
the burden of proof would rest on subpostmasters to show
that Horizon was at fault in causing these accounting
discrepancies?
No.
Did that stand out to you at the time as an issue; do
you recall?
Did that -- can you repeat that, please?
Sorry. Did that jump out at you at the time as
a problem, that subpostmasters were being required to
produce evidence, that the onus was on them to do so?
I don't know, to be honest, at the time. You know,
I refreshed my memory, I guess like most witnesses, when
the discovery documents were given to me. So when I was
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refreshing my memory, did that spring out to me, but did
I know the Inquiry was ongoing? The answer is yes. But
I'm not sure whether I did at the time or not, I just
don't recall. I suspect it probably did.
If it did, what, if anything, would you have done about
that?
I didn't do anything, I don't think. I -- you know,
it's just a suspicion. To your point, my previous
employment as a police officer would have taken me down
that road. It's not, by no means, an excuse but when
you're inundated with 300 or 400 emails a day and you've
got the world before you in terms of what you've got to
deliver, you can't pick up on every nuance in an email,
if I'm being candid.
He goes on to say at point 3, we've looked at:
"... in the past POL hasn't always tabled the
evidence from the audit logs."
Was that something that you were aware of at the
time?
No. So it's through a number of iterations of emails
that, again, were part of the disclosure, or I start to
piece together, you know, since the Inquiry has been
underway just how some of these things were coming to,
you know -- were coming into being. How some of the
prosecutions were working through. I'm not trying to
49
some subpostmasters were being done for false accounting
as opposed to theft. And, you know, from my policeman
days I understand the difference between both and the
proof of evidence that's required to prove both.
So I gradually got to realise the system is playing
a more integral part in the prosecution process than
I perhaps originally might have known in my first year
of service at the Post Office, as an example.
You attribute that understanding to reading the Ismay
Report; is that right?
Some of it but there were -- you got -- the best way of
describing it is you got glimpses of it perhaps in
a Board meeting, in an executive meeting, where
a particular prosecution was being talked about because
it had raised a flag in some form or other. You're not
party to the conversation, other than you're a set of
ears around the table and you pick up a little bit of
what might be going on.
As you do that, you start to see the email flow
where some of this starts to eke itself out. You're
starting to get a better sense of what is happening.
And then, of course, the Ismay Report is the first time
for me, personally, you sit there and you start to see
a large component of that talking about, in some detail,
some of the prosecutions and the nature of those
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avoid it; candidly, I didn't know that that's what we
were doing.
What Mr Burley appears to be conceding at this point is
that, although postmasters hadn't been able to prove
that the discrepancies are caused by Horizon, Post
Office hasn't bothered to check whether that's, in fact,
the case -- sorry, in every case, it isn't the case that
Post Office has checked that the audit --
One or the things that I - sorry.
No, sorry.
One of the things I'm aware of within the Fujitsu
contract is the retrieval of data from Fujitsu was
a cost service, it was an additional cost type service,
and there was -- as part of the contract that
I inherited, there was a set sum put to one side to draw
data from Fujitsu, as and when, and then when you
exceeded that amount in a given year, you then paid
more.
So I'm not sure whether that point is related to,
you know, we don't do it in every prosecution because
there's a cost associated to it and it's not required.
I didn't -- I simply, when I read that part of the
email, I didn't know we had got down to audit logs. In
fact, it wasn't until later on, and some of that through
the Ismay report, that I took on board the point that
50
prosecutions, and the sensitivity, as such, was such
that I didn't, other than through -- with Lesley Sewell,
I didn't pass to anyone else in my DR team because
I thought it was very sensitive -- very sensitive data.
But it’s through a drip-drip-drip type process that
you start to get a sense of what's being done on the
prosecution side because I wasn't being told, and
I wasn't seeking -- because I'd been told not to -- via
John Scott or Susan Crichton or via the Royal Mail Group
process, which is even further away from where I might
sit.
So is it right to understand that, from reading the
Ismay Report, you understood, firstly, that Horizon data
was being used by the Post Office to support and to
evidence, for example, an offence of false accounting in
the prosecutions that were being brought against
postmasters? That is to say that data from Horizon had
a role in the prosecutions brought against
subpostmasters --
Yes.
-- and that you also understood that the integrity of
that data was therefore essential to the safety of those
prosecutions; would that have been apparent to you from
reading Mr Ismay's report?
Yes, and I do think my statement does say in some part
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that having a statement from a distinguished engineer or
someone from Fujitsu that talks about data that's under
their management, even with an audit log, is, you know,
in my view, not independent. I would have expected to
see, in prosecutions of this nature, an independent
expert commenting on Horizon data and audit logs. It
felt a little -- as you're drawn into it from the edges,
it felt a little like poachers turned gamekeepers, and
it didn't fit well with me as a former police officer.
It wasn't truly independent.
Just to be clear, are you saying that you understood
from Mr Ismay's report that Fujitsu were providing
expert evidence in support of ~
I understood that there was some -- I can't remember if
it was directly from the Ismay Report but it's on that
drip-drip-drip type basis. One of my conclusions was
that some of the evidence that was being provided around
Horizon and consequent prosecutions wasn't, in my
opinion, an independent expert that knew the system and
therefore could talk to it to any great degree. It was
someone in Fujitsu and, for me, that's not independent.
Having identified that as a concern, did you raise that
with anybody within the Executive Team of the Post
Office or indeed raise concerns with your Head of
Security, who was giving instructions to the Criminal
53
I had very few levers that I could pull, contractually
or otherwise, with Fujitsu. There wasn't anything
I could see, and when I talked to my direct report team,
the specifics of those, candidly, that might be working
in Service Delivery, Lesley, those that might be working
in other aspects of IT, that have sight of some of the
end-to-end Horizon-type pieces, when I talked to them,
they were in a place where the system was doing what it
needed to do, and prescribed -- as per described by the
contract.
And every time there was something new, either laid
out in the media or otherwise, I would do that round --
I would do that round robin. Invariably there would
also be a call or an email that would go in to Fujitsu,
Duncan/Gavin Bounds/whoever, usually one of those two --
to ask questions.
And so I sit here, you know, despite the backwards
and forwards communication with Duncan saying "This is
all I can do, I can't see anything happening on the
system as we're now going into main rollout, and
actually the feedback from The Branch Network is really
positive. I'm not sure what we do next, with regards to
Horizon". So I want to make that point.
Then the Ismay Report lands, and I saw the Ismay
Report as a next best endeavour, if you can't get into
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Law Team?
I just -- I can't recall. The likelihood is no. I was,
you know, I was clearly told "Let the process be the
process".
I'd like to briefly look at what you say your reaction
was on reading the Ismay Report. That's at paragraph 92
of your statement, please. You say this:
"The Ismay Report confirmed that the system was not
flawed. The report analysed some of the more
high-profile prosecutions that were highlighted in the
media, and his report determined that the information
and evidence used in these cases were reliable. At the
time, the Ismay Report solidified my view that there was
not a technical problem with Horizon."
Now, that report was sent to you in August in 2010;
is that right?
Itis.
So that's really barely a month or less than two months
after your exchanges with Mr Tait have concluded, rather
unsatisfactorily, concerning a review of the code of
Horizon Online. It might be thought surprising that you
took such great comfort from the Ismay Report, given the
extent of concerns you had about Horizon Online and its
code?
So the reason I took comfort from the Ismay Report was
54
the code or an end-to-end investigation around the
system itself. So -- and I drew from it, as my
statement makes clear, some comfort that, in Product
Branch & Accounting, in Chesterfield and -- you know,
I knew Rod Ismay fairly well, as well as I knew anyone
at the Post Office, I found him to be quite balanced and
a fair-minded individual, I took some confidence from
his analysis of the whole thing.
And it didn't take any -- it didn't mitigate all of
my concerns but it gave me a boost that, okay, we're not
seeing anything on the system, my DR is not seeing
anything on the system, the challenge and response
process written or otherwise with Fujitsu says that the
system is fine now we're through the Oracle type
problems, okay, we're in a better place. It also gave
me a window into some of that prosecution type piece.
So I did, I drew some comfort from that. Did I have
something in the back of my mind that, you know, would
say, you know, are we ever going to get to a point where
we can, you know, get into that code? Then the answer
is, you know, it was always there. So I think it should
be. But I was always keeping a close eye, via Lesley
and the team, on where the system was systematically,
and there was nothing in that process that would draw
you to a conclusion, having dealt with the Oracle bugs,
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that there was a problem.
And Ismay's report was more or less saying the same
thing to a degree, but adding other parts to the
process: training, the process itself and then the
prosecution type -- small window into the prosecution
type piece.
So it gave me some measure of comfort going forward,
despite the backdrop from the Duncan Tait interplay on
looking at the system in detail.
MS HODGE: Thank you, sir. That may be a good time to take
‘our morning break, I'm conscious we've been going for
an hour and a half now.
SIR WYN WILLIAMS: Yes, by all means. So what time shall we
resume?
MS HODGE: Shall we resume at 11.45, please?
SIR WYN WILLIAMS: Yes, fine.
(11.30 am)
(A short break)
(11.45 am)
MS HODGE: Good morning, sir -- yes, still the morning.
Good morning, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes, I can thank you.
MS HODGE: Thank you.
Mr Young, I'm going to move on now, please, to
another topic, concerning your knowledge of a bug we
57
conversation with Mr Ismay; do you recall whether you
spoke to him orally about the issue?
A. lagree, it does intimate that but I can't recall it.
Q. When you say in your statement that he downplayed it, is
that a fair reading, do you think, of this short email
exchange?
A. Well, it's the feeling I had, so yes.
Q. Do you recall reading the report that was attached to
his email?
A. No.
Q. Do you think that you would have read it at the time you
received it?
A. Yes.
Q. I wonder if we could pull it up, please, just to see if
you recognise it. I believe it is POL00188387. Do you
recognise that document as something which you read at
the time?
A. Ido.
Q. MrIsmay alerted you to the last two paragraphs on
page 1. If we could scroll down to those, please. This
is in relation to the cause of the problem. It reads:
"The problem occurs as part of the process of moving
Discrepancies into Local Suspense.
"When Discrepancies are found when rolling an SU
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know as the receipts and payments mismatch bug. You say
in your statement you first became aware of this bug in
February 2011 and you attribute your discovery of it to
a conversation you had with Lesley Sewell, who, by then,
had taken over from David Smith as Head of Change and
IS; is that right?
Yes.
Forgive me, you're nodding but, for the purposes of the
transcript -- thank you.
Yes, I have been warned. I should have realised that.
Yes.
You also refer to an email you received from Mr Ismay,
which you describe as downplaying the issue; is that
right?
Yes.
I wonder if we could take a quick look at that, please.
It's FUJ00081545. Thank you. If we could scroll down
to the very bottom, please. It's page 4. Thank you.
This is dated 18 February 2011, the subject "Receipts &
Payments Issue", from Mr Ismay to you, reading:
"Mike -- please find attached the paper from Fujitsu
that I referred to.
“In particular please see the last 2 [paras] of
page 1 and the trial balance on page 13."
This suggests that there may have been a prior
58
That is presumably a stock unit, is that what you
would have understood that to be a reference to, SU?
Not sure?
I don't know what "SU" stands for.
So:
"When Discrepancies are found when rolling an SU
over into anew TP..."
Do you know what "TP" stands for?
I don't know what that is either.
"... then the User is asked if they should be moved to
Local Suspense. Should they Cancel at this point the
Discrepancy is zeroised in the Local Cache ..."
Do you know what was?
Yes, a cache is a data depository, so ...
"Note that there is no corresponding Balancing
Transaction generated in the Local Cache and so the
Local Cache is in an Unbalanced state."
So that's obviously quite a technical report. If we
go back to the email chain we can see you that some
discussion with a Will Russell. If we could return to
FUJ00081545, please. Thank you. That's at the bottom
of page 3. Thank you.
So, following on from Mr Ismay's report, you write
to Will Russell, later the same day, saying you want to
sit down with him and possibly several others to:
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"... understand these latest issues on Horizon and
where we are with them. This is very important as there
is a lot of media interest in Horizon at the moment."
You say:
"What would be helpful is if you could send me
a written summary on what the integrity issues are and
what has been done about them."
Why is that request being directed to Will Russell
at that stage?
I don't know. I can't be sure what Will's role is.
I can't remember what his job description was. Clearly,
he was in the mix on this but, being able to describe
what his actual job role was and how that related to me,
I can't.
If we just scroll up, please, we can see at the bottom
he was Commercial Advisor; does that assist you?
(No audible answer)
So he emails then, if we go to the top of his email,
I believe it’s later the same day. If we scroll up to
the -- no, this is two days later, so 2 February.
Mr Russell emails you back to say:
"Mike,
"I will pull you together a summary on Monday.
"The issue Rod refers to, and outlined in the paper,
was an issue that occurred in September 2010, post Go
61
the February and March time frame. So why this didn't
reach me before then, I've no idea.
Sorry, my question was: when it did come to your
attention in February, do you recall the context as to
why or whether there was any background to that specific
issue being raised with you at that stage?
No. Just that it was a bug.
So Will's email goes on to say:
"This issue affected 62 branches and a PEAK was
raised and quickly closed by Fujitsu. The issue only
affected branches that followed a set sequence of button
depressions, and this sequence was not a normal action
that branches would have followed. The resultant error
arising from the unusual events caused the receipts and
payments line on the branch accounts to mismatch
(eg they were not as equal as they should be). This can
be seen in the reports in the attached document."
He goes on to say:
“Letters to branches had been prepared, and signed
off by Legal, and the team were looking to issue these
shortly, as we need to communicate to the branches
involved what has happened. However, these letters have
been held back, pending Rod's intervention."
He then says this:
"Fujitsu are confident that they can show and prove
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Live of HNG. The issue was not encountered interesting
testing, model office or pilot, and came to light in
live through Fujitsu alerting. As per the normal
process, Fujitsu reported the issue into the SD live
Service Desk once the discrepancies were identified by
the HNG system. SD pulled together a team of
stakeholders to assess the issue and track through to
resolution, this included; Fujitsu, [Product and Branch
Accounting, IT and Change], Security, Network and
Legal."
Just pausing there, what this appears to show, what
Mr Russell told you at the time, was that several months
before you'd been notified about the existence of this
bug, it had been reported to stakeholders in IT and
Change and Security for which you had oversight; would
you agree?
Yes.
Do you know why there was an apparent delay of many
months in bringing this bug to your attention?
I don't, no.
Do you recall the context in which the integrity issues
were raised with you by Mr Ismay and Ms Sewell in
February 2011?
Well, I think I've said in previous evidence that
I first became aware of them in March. So February --
62
that nothing has been lost on the system, as events have
been generated to show what has happened for each
individual branch. However I have escalated the
concerns into Fujitsu at senior level."
Now, in your statement you say that, to you, the
receipts and payments mismatch bug echoed the complaints
from JFSA about reconciliation issues; is that correct?
That's correct.
Was that something that occurred to you at that time
that it was brought to your attention or was this
something that you've reflected on in hindsight?
In time. Not at the time.
Sorry, that didn't occur to you at the time?
No.
It has since?
Yes.
Is that because the bug was capable of causing
a discrepancy to appear in the subpostmaster's branch
accounts?
Yes.
Why do you think it is that that didn’t occur to you at
the time?
It's pilot, and I would expect bugs to occur. I took
some -- if you look at the second sentence down in that
email:
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"This issue was not encountered during testing,
model office or pilot and came to light [through] live
through Fujitsu alerting.”
So that algorithmic approach to looking for the data
and looking for anomalies highlighted the issue, and
that gave me -- you know, that gave me some sense of
confidence that we had the right countermeasures in,
even in early pilot, to find any anomalies -- let's call
them anomalies, as opposed to bugs.
So I took some confidence from that as it was aired.
And, in essence, in the description given to me by
Fujitsu on how they managed the day-to-day code to look
for anomalies, this proved that they were capable of
doing it, and that gave me some confidence.
Did you discuss the bug with your Head of Security at
the time it was brought to your attention?
I don't recall. What I would say is, generally, when we
were firefighting some of these issues in pilot, we
invariably came together as a team. So when I ran my
management teams, we all came together. Was John -- can
I categorically say John Scott was aware of this level
of detail? I can't. But he certainly will have been
aware that there were bugs in the early rollout of HNG-X
and he'll have been aware that there will have been
a mismatch too.
65
because, in my view of the original Oracle issues in
Horizon rollout, it was 62 branches that were impacted.
So it can't be that we've got two 62 branches impacted.
That's the anomaly.
I follow that point. So, on the
assumption that the Oracle defect is a different problem
to this, you're pointing out that there's a huge
coincidence in two defects, I'll call them, affecting 62
branches and, therefore, you're querying whether, in
fact, there's just one defect; is that it?
That's it, yes.
SIR WYN WILLIAMS: Right. Okay. But I think you'd agree
A
with counsel that the second paragraph, read as
a paragraph would certainly suggest that this happened
after the rollout and not in testing?
I agree that that second paragraph sounds like that's
the case.
SIR WYN WILLIAMS: Yes.
A.
I'd like to make a point, because it may be where
counsel is coming from, if that is the case, as in we're
past pilot and Horizon Online is in play, properly
online, and Legacy is condemned to history, this would
be something new to me.
SIR WYN WILLIAMS: = Right. All right.
MS HODGE: Just to be clear, when you say this would be new
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Q. Your response, Mr Young, was that this was a bug
identified in pilot. What Mr Russell's email suggests
is that it wasn't identified during testing, model
office or pilot and that it had come to light in the
live running of Horizon Online. Can you see that in the
second paragraph to which I referred you?
That's what he told you at the time; is it your
evidence that that is incorrect?
A. Well, my view of that was it was the new system not the
old one and you're suggesting that it was the old system
in the run-up to the new system.
SIR WYN WILLIAMS: Well, I don't think that's correct,
Mr Young. I was confused by your answer. What this
document says to me -- and please contradict me if I've
got it wrong -- that this manifested itself after
Horizon Online had been rolled out and it had not
manifested itself in the testing process, if I can put
it in that way. Having manifested itself, Fujitsu then
dealt with it because they discovered it. Now is that
the proper reading of this document?
A. Well, my immediate answer to that, sir, is I'm not sure.
So I'm just running that through and reading this again.
SIR WYN WILLIAMS: Yes, if you would, please.
A. The drilling noise isn't helpful.
It's the 62 branches that cause me to think about it
66
to you, as in at the time it was brought to your.
attention, you didn't understand this to be a bug that
had been detected in the live operation of Horizon
Online?
A. After main rollout, yes.
Q. That seems surprising, given what Mr Russell said to you
in this email in terms, that this has been discovered in
the live operation of the system?
A. I would make the point that, again, in the discovery
process, looking at the documents, particularly those
where I have to report some of the issues around where
we are with Horizon and the subsequent rollout, and so
‘on and so forth, including operational failures and
change failures, I don't think there's anything in those
reports that talks about a bug or a data mismatch bug,
in that time frame after rollout. And I would have been
obliged to notify the Board and the Executive Team that
that was the case.
Q. So what you're saying is, by reason of the fact that you
did not notify the Board of this bug, it follows, in
your view, that you can't have understood it to be a bug
that was affecting the live operation or had affected
the live operation of Horizon Online?
A. Past pilot, yes.
Q. Can we look, please, at a little later in the chain.
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I think it must follow from what you've just said that
you accept that you didn't bring the bug to the
attention of the Senior Executive Team of the Post
Office; is that correct?
Well, not if this is a pilot, which I think is the way
it's being read. I agree that second paragraph suggests
something in main roll -- it's done and it's now the
live system, then end-to-end and everyone's on it.
I won't have done that if I haven't been told that
there's a bug in the main rollout. So no, I won't have
notified anyone. That doesn't suggest that Lesley or
part of the team generally will have done that. It
follows on that, usually, something of this nature also
would end up very quickly from me on Duncan Tait's radar
screen. And there's nothing in the disclosure process,
and nothing I recall, that would suggest I had
conversations with him about a bug after Horizon Online
was delivered in full rollout.
So if I don't know, I can't tackle the vendor,
I can't inform, as I normally would, my executive
colleagues in the POL Board and, more importantly, in
main rollout, this would have been classed as a major
incident. Despite the fact that it's only 62 branches
that are impacted, this would have caused a major
incident report and there's nothing I've seen in the
69
the Post Office. I thought this, the way I read this
was that this was the catch-up following those two bug
related issues in rollout, not anything else.
Do you accept, Mr Young, that's not what the email says
in terms?
Do I accept, sorry?
That that's not what the email says. It says this was
a bug detected in September, in the live operation of
Horizon Online. It appears it wasn't reported to you,
as you say, in September but it is here being brought to
your attention in February 2011?
Yes, I do accept that; post-Go Live Horizon Online.
Now, if that is correct, that is to say that in February
2011 it was brought to your attention that a bug had
been detected in the live operation of Horizon Online,
which caused discrepancies in the branch accounts of 62
Post Office branches, is that something which you ought
to have bought to the attention of your Head of
Security, who had responsibility for overseeing the
investigations of suspected offences of fraud, theft and
false accounting?
Had I known, the answer to that is, yes.
Had you known what, Mr Young?
I'm making the point that I didn't associate what this
says to a new bug post-rollout of Horizon Online.
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disclosure process and nothing I recall that indicates
a major incident process has kicked in, beyond those
that I have described as part of the pilot.
Now, your evidence, as I understand it, is, because you
didn't report it, you must have understood at the time
that it was a bug that had been detected in pilot. Now,
an alternative hypothesis is this: that you were
notified in February 2011, as evidenced by this email,
that a bug had been detected in the live operation of
Horizon Online and you simply failed to bring that to
the attention of your more senior colleagues?
No, you misunderstand me. I was aware of two Oracle
bugs and those Oracle bugs were eventually identified
and mitigated by Fujitsu as part of the pilot, and they
were part of a major incident process. They went to the
both Boards: POL and Royal Mail Group, and essentially
necessitated that letter to Duncan Tait that we've
already gone through. I'm saying I didn't know about
this other bug, if indeed that is the case -- I'm not
suggesting you're wrong but I'm not suggesting I'm wrong
either -- if indeed there was one in September, I'm not
aware of it, and certainly no one escalated it to me.
This email reads to me like the catch-up on payments
to subpostmasters, that they can keep the money they may
have made, as about this and we'll take the writedown in
70
Let's go on a little bit please in --
So I want to make the point that that's really clear.
Had I known this was a bug, we're past -- it's in --
Horizon Online is in and it's running and we've got
a payment mismatch. This is in addition to the two
Oracle bugs and we're in this situation where there's
another bug that's been, let's call it illuminated, and
it's caused this issue miraculously across the same
sized branch network, okay. Like I said, this would
have caused a major incident review and it would have
caused an update to the POL Board and to Royal Mail
Group, as a consequence.
I would have sat down with my direct report team to
talk about the input to those the various reportings, to
ensure that we are all aligned and we had the right
messaging in place, that it was accurate. I don't
recall going through any of that at all and I don't see
anything in the disclosure process to me, as part of the
Inquiry, that indicates that other than this email.
You say, Mr Young, it would have caused a major incident
review and that, because you haven't seen one, it must
follow that it wasn't a fresh or a new bug. But what we
can see, the explanation that Mr Russell gives, is that
Fujitsu reported it to the Service Desk, and the Service
Desk notified relevant stakeholders.
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So is that not the way in which this bug was brought
to the attention of the Post Office?
A. Yeah.
Q. Could we please look at a slightly later email chain ~
SIR WYN WILLIAMS: Before we do, can I just ask you, this
email begins with a reference to the writer pulling
together a summary on Monday; do we have that document?
MS HODGE: Sir, I don't believe we do but what we do have is
another email exchange about, I think, a further
briefing that took place.
‘SIR WYN WILLIAMS: Fine.
MS HODGE: That's the one to which I propose to take the
witness.
SIR WYN WILLIAMS: Yes. That's fine, Ms Hodge, yes.
MS HODGE: So it's POL00029611. Thank you. If we scroll
down, please, it's an email from Will Russell, dated
4 March 2011. It's addressed to Lesley Sewell, your
direct report as Head of IS and Change.
So this is a couple of days, probably about ten days
or so, after Will's email to you. He updates Lesley:
“Quite a lot of info here but I will outline what we
agreed on this issue."
There are Word documents attached, he says, and the
Word documents attached are letters going out to
branches on Monday. These have been approved by Legal,
73
logs in Data Centre and Event alerting meant we picked
this up, and we can demonstrate through reports what
happened. We can generate reports for each branch if
challenged.”
So what this indicates, does it not, is that you
approved the decision to write off the losses and repay
the gains via subpostmaster pay, that was something you
discussed and approved at the time?
I agreed with it yeah, I did. I wouldn't say
"approved". That would probably go through Mike Moores.
Forgive me. There's also a reference in the paragraph
beginning "Matt Hibbard". It reads:
“Andy Mac has taken action from Mike Y to ensure we
maintain closer links with [Product and Branch
Accounting)/Rod."
Do you recall why it was that you gave an action to
Andy to maintain closer links with Product and Branch
Accounting and Rod Ismay, as a result of what had
occurred?
I mean Andy was in charge of Service Delivery, so trying
to make sure that Andy and Rod Ismay were aligned, and
continued to be aligned, in Service Management would not
be an alien thing.
Were you concerned that to maintain closer links because
this hadn't been brought to your attention in September
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Product and Branch Accounting and SD. He says:
"I ran Mike G, Mike Y, and Andy M through the detail
last week. We have agreed to write off the losses and
repay the gains via subpostmaster pay. We have
a document from Fujitsu on what happened. This
[includes] audit trail and shows what happened for
a branch, as well as events generated and logged by
Fujitsu, plus what the branch saw on their reports.
I am just awaiting clearance from Network (Anita Turner)
re how to approach NFSP (propose to finalise that on
Monday for 62 branches affected as shown on Excel
spreadsheet)."
If we just scroll down, please, the penultimate
paragraph reads:
"Both Mikes ..."
By which presumably Mr Russell is referring to Mike
Granville and you, Mr Young? Is that a fair --
It's either Mike Granville or Mike Moores, the CFO, and
me. I agree it's me.
You agree that it's you in this context?
Yes.
That being because he's referred to a previous
discussion with the two of you and with Andy:
"Both Mikes were keen we use this as a positive,
eg Old Horizon would not have picked this up, yet the
74
2010?
I don't know, is the answer to that. The other thing
that's thrown me, as part of this, you know, pilot
versus post-Horizon Online, is the same process was
applied then around the losses and the repay of gains to
the 62 branches in pilot. So there were gains made and
the subpostmasters were allowed to keep them, and the
losses, which I think amounted to about £20,000, the
Post Office took. So -- and, you know, I'm not
suggesting it's wrong. All I'm pointing out is, if
you're reading it, there's a lot of similarities to this
and the exact same issue, or the bug issue that we had
in pilot.
If we look a little further down at the final paragraph,
Mr Russell says:
"We are writing to branches, and following up with
call from to NBSC/[Product and Branch Accounting], with
walkthrough of the detail as required. We have
commitment from Fujitsu to visit any branches to run
them through what happened ... We have had receipt and
payment mismatches before, so this is not something new
to manage, albeit this issue was very complicated in how
it was reported, and evident to the branch."
That would tend to suggest, would it not, this was
a fresh issue that was being raised?
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lagree.
Now, you say in your statement that, so far as the
reporting of this particular matter was concerned, you
considered that it was the responsibility of Rod Ismay,
as Head of Product and Branch Accounting, to bring this
information, by which I understand you to mean the
existence of the bug, to the attention of Susan
Crichton?
To what, to Susan Crichton?
To Susan Crichton; is that correct?
In terms of the financial aspects and the fact that it
was going to involve allowing subpostmasters to keep the
upside and the Post Office to take the downside, yes.
I think what you're alluding to is: because it questions
the integrity of Horizon, did I see it as Rod's -- Rod
Ismay's responsibility to keep Susan Crichton aware that
there's been an issue that now would play into that
integrity? The answer to that is clearly yes.
Why did you consider it was Mr Ismay's responsibility to
bring that to the attention of Ms Crichton?
He has clearly been -- he has clearly been dealing with
it. What I don't know from this outlay, and I've not
seen from this outlay, is how the issue was resolved
from Fujitsu, and I've not seen anything in the
disclosure document that articulates that, and that's my
77
we're going to do about it? Yeah.
So far as you are aware, were there any systems in
place, whilst you were in your role, to ensure that
information about the operation and integrity of Horizon
was routinely communicated to those who had
responsibility?
Can you repeat the question, please? Certainly the
beginning part.
So far as you were aware, were there any systems in
place to ensure that information about the operation and
integrity of Horizon was communicated to those within
Post Office who had responsibility for conducting
criminal investigations?
Well, I've described it, because it went to everyone.
So major incidents, if you're really alluding to was
Susan Crichton aware of any major incident like a bug on
the system, as this might suggest, then the answer to
that is she's part of the Executive Team and the POL
Board. She'll have seen the major incident report. And
the same with the briefs to the POL Board. If there was
any, let's call it “discontinuity” in the operation of
Horizon in the branch network that may have affected
footfall, may have affected revenues, whatever the case
may be, that would have been reported either through
noting, or in some other way, written to the Board, and
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problem with the whole process.
There's nothing in the disclosure process that's
revealed any communication to Fujitsu at a senior level.
There may have been some documents that I'm not copied
on or seen, and there's nothing that's come back the
‘other way. So -- and yet, dealing with a bug of this
nature, both sides have -- POL and Fujitsu will have
been aware of the sensitivities, which is why it would
have been raised up to the flag, and you'd expect to see
something that that travels by way of communication
between the two entities, and I haven't seen that.
I haven't been copied on or seen anything in relation to
that.
Now, bearing in mind that Mr Ismay, in early February,
has escalated this matter to you, why did it rest on his
shoulders to then take it forward and bring it to the
attention of Legal?
I don't know. You'd have to ask Rod that. More
importantly, I would have expected a Lesley -- I would
have expected, in normal practice, Lesley would have
raised this with me and I may very well have said to
Lesley "Please go see Susan", because of the point
around the question marks it leaves around integrity.
And I would have also put an action plan together to say
how do we approach this from Fujitsu and what is it
78
Susan sat on the Board.
So is your evidence that the systems in place to
disseminate this information were perfectly adequate; is
that what you're saying?
Yes, and there were examples of that in some of my
documents.
I'd like to move on, please, Mr Young, to I think what
will be our penultimate topic, that relates to your
knowledge of what's described rather loosely as "remote
access". You deal with this at paragraphs 52 to 54 of
your statement. I wonder if we could bring that up,
please.
Now, just before we look at what you say in those
paragraphs, I think you say that, as a matter of
generality, you would have expected there to be some
form of remote access to a system such as Horizon from
your prior experience in working in IT; is that right?
There is in every system but yes.
But you say that, specifically in relation to this
system, you did not know that Fujitsu could insert, edit
or delete transaction data or data in branch accounts
without the knowledge or consent of subpostmasters,
managers or assistants, nor that such action could not
leave a robust audit trail.
From where had you obtained that understanding,
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please?
It's come from a number of arenas. So having spent time
around the Helpdesk, having spent time with Fujitsu in
their offices, where they support the Horizon product
and spent time with my own team, I'm aware of what the
process was. And access into the system remotely -- so
remotely might be, you know, from the offices in Fujitsu
through to where the system resides in a data centre,
you know, you're not -- there's not a cable, you're
doing a remote access, you're doing that knowing that
there is a full audit log, right down to the keystroke
of everything that happens at that point and then there
is a checksum process that goes through, that can't be
changed. It's very, very secure, to ensure that, if
anything does go wrong or if there is a disagreement
‘over what happened, that log can be used -- that audit
log can be used to describe the actions that were taken,
right down to the keystroke.
But my understanding of how the whole end-to-end
support process worked was that, at the point
a subpostmaster was having a problem in branch, and it
required some form of reset, some form of change to the
data, though I don't think that happened very, very
often, it was done with the permission of the -- it was
meant to be done with the permission of the
81
having to remote in and fix it, okay, they should be
doing that with my authority and my purview as to what
they're doing. And, at the end of the exercise, my
agreement that they've done it. And then the access
should conclude. Okay?
Again, I think there have been examples given where
that's not been the process that's been followed
through. But that's the process I understood from
a Post Office -- you know, and Fujitsu, "Let's help the
subpostmaster because there's an issue".
So I just want to be clear, you've given evidence about
your understanding at the time and what you've learnt
subsequently in the Inquiry. At the time you were in
post, you understood that, firstly, remote access was
possible because it had to be for a system such as
Horizon, correct?
Yes.
Secondly, that if it was used or if changes were made to
data, they would be done with the consent of the
postmaster?
Yes.
Thirdly, that there would be a clear audit trail to
evidence any such remote access?
An uncorruptible audit trail.
Now, it came to your attention in 2011 that there were
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subpostmaster, and that audit log was to stand true over
that whole process. So, of course, the Second Sight
investigation has proved that that wasn't always the
case.
I do want to make the point because I've heard the
language in the Inquiry having seen some of the other
evidence that's been given: for me, backdoor access is
an access that's usually attributed to the person that
has written the code and he or she uses it as a quick
entrance into the data or into the code in order to
change something almost on the fly, and the summary is
it's usually not an auditable process. Okay?
And I'd like to think that modern day systems -- and
I would include Horizon Online as part of that
process -- was much more robust than that. So where
someone is dealing with the code that may have
ramifications to a subpostmaster or The Branch Network
as a whole, they're testing it first and validating it,
and when they're accessing it through, there are
a number of parties that have oversight to that process.
It's clear, through some of the evidence process that
I've seen in the Inquiry that that level of due
diligence frankly was missing.
And the basic one that subpostmasters would worry
about is, if I am asking for support and someone is.
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concerns about the system controls in place in relation
to privileged access rights; is that correct?
Following the Ernst & Young audit report, yes.
What did you understand to be the nature of Ernst &
Young's concerns about those privileged access rights?
There were several, so one, I think, talked about some
of the change control type process which should be --
you know, from an operating point of view, should be
really tight. But the one I think my statement latches
on to and talks about, is the user access/privilege
access type process. So that identified what I thought
were some fairly rudimentary issues, right? So not --
and, again, my statement says the same thing, you
know -- not the type of issues you would expect a blue
chip technology company like Fujitsu to have in play.
Now, I'm sure part of the process, from the Fujitsu
point of view might be, you know, we were moving from
Horizon to Horizon Online and things had to change quite
quickly and we were still playing catch-up. I don't
hold to that, candidly, I think privileged access in all
its various facets needs to be buttoned down throughout,
and it’s clear from the Ernst & Young report that wasn't
the case. And it's also clear that there were one or
two super-users that had access to everything, and that
that wasn't supervised in the way I would expect it to
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be. It might have an audit log associated to it but it
wasn't supervised.
There were, as an example -- and I do make this
point in my statement but I'll make it here again -- in
most corporates now, when you're deploying
a multiplicity of systems, you have an automated process
that's tied to the exit of an individual from a company.
Even through HR, you have a process that where you may
have someone suspended and suspended from your back-end
systems, that there's an automated process that takes
their rights, their log-in rights, password and log-in
rights, to certain systems away. Maybe forever, maybe
for a set point in time.
And some of that -- the sophisticated ones cover
leaves of absence when people are on holiday, and so on
and so forth, just to apply an additional layer of
security. I was surprised, from the Ernst & Young
report, that they didn't have anything like that in play
and, when I became aware of the output, via Lesley and
via Ernst & Young, there were a lot of phone calls with
Fujitsu as to why some of the basics on security
management with privileged access were missing.
Did you consider at the time that the inadequate
controls over privileged access had implications for the
integrity of the data process by Horizon?
85
have, and you're also concerned this has data integrity
implications. Did you consider at the time that there
might be a necessity for a backward looking review of
how privileged access rights had been used and what
implications that might have for the complaints being
made by subpostmasters?
The reason I'm hesitating is my sense is -- and it's,
upon a review with Fujitsu, you know, in a visit - that
they had it reasonably buttoned down, certainly better
than the E&Y type report might suggest, on Horizon,
Legacy Horizon, but I believe the shift to Horizon
Online and some of the dynamics associated with that may
have caused some of what we saw in the Ernst & Young
report. Did I look back at the time as I'm doing
Horizon Online? You know, if I'm being candid, I've got
a whole wealth of stuff I've got to deliver against.
I'm not getting into the weeds of what would be other
people's responsibilities.
Might I have -- in hindsight, and knowing where we
are today, might I have taken a step back from
everything else I was doing and said, "Hold on a minute
here, we need to look at privileged access?", the answer
to that is yes, but hindsight is a wonderful thing.
I'm conscious of the time. What I'd like to do,
Mr Young, is just seek some brief clarification on
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Yes, I considered that, yes.
Now, bearing in mind that you believed all privileged
access rights were audited, did you give any
consideration to requesting a full audit of privileged
access rights be carried out by Fujitsu?
Well, we again, it's in the disclosure process, we set
up an Audit Board that was going to audit following
through on the audit report from Ernst & Young, to
ensure that we got those issues resolved as quickly as
possible. And I deliberately made a push via Lesley,
who is very competent, to get that done and marshal it
under her leadership, which she did. I think, by the
time we got to the end of October of that year, and it's
reflected in the Board paper, we had addressed that
privileged access type issue.
I think it would be fair to say that that was a forward
looking approach, that is to say that you wished to shut
down or to reduce the extent of privileged access rights
which Ernst & Young had raised concerns about.
What I'm asking you about now is a backward looking
review, so bearing in mind you know that subpostmasters
are complaining about discrepancies in their accounts,
and you're conscious that, from Ernst & Young's audit,
that privileged access rights have been granted to
a much broader number of employees than they should
86
a number of points with you relating to your sort of
knowledge and awareness of discussions around private
prosecutions. So at paragraph 111 of your statement --
I wonder if we could bring that up, please, page 36 --
you say this:
"Occasionally, in [Board] meetings, discussions
regarding prosecutions would be had between the Chair,
the [Managing Director, Alan Cook or David Smith],
[Paula] Vennells, and Susan Crichton, General Counsel.
I did not have anything to contribute and did not stray
into these discussions, as I had no direct knowledge of
responsibility for or involvement in these cases."
What I'd like to do is test if your recollection of
that is correct. We have reviewed the minutes of the
Post Office Board and we haven't found evidence of your
attendance, beyond an original meeting in 2008. Do you
think you're right in recollecting that these matters
were discussed in your presence at Board level by these
individuals?
So I want to be clear about the point I'm trying to make
there because, based on the question that was poised to
me in the preparation of the statement, I cannot say
that I was at a Board meeting and didn't hear a side
conversation or some element of a conversation that
might be associated with -- let me draw an example --
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you know, the Legal Counsel having an issue with
a particular prosecution.
And there may have been, on occasion, a passing
conversation between, you know, the Legal Counsel, Alan
Cook, or Paula, or whatever the case may be.
Now, if you're there, I can't say -- I didn't
listen. They were partial conversations. They
weren't -- there was never, in my view, anything done of
any great note -- which is an anomaly, candidly --
around prosecutions in Board papers. It was never
a topic of conversation that the Board or the Executive
Team at the time would get their chairs round and talk
to, to some degree, some familiarity that Susan, or the
General Counsel, whoever it may have been at the time,
may have chosen to brief the Executive on.
But I am aware, and that's why it's in the
statement, that there were, you know, one or two
occasions where something may have been said and,
because you've got nothing to contribute, you know, you
switch off in those types of conversations and they're
relatively sensitive and confidential by nature, but
anything minuted -- I mean, in fairness to both Alan
Cook and certainly Dave Smith, anything said according
to an agenda in the Post Board was minuted. If it
wasn't minuted, it wasn't an agenda item.
89
a prosecution, at the point you've lost integrity around
access via Fujitsu, to help the Post Office, without the
subpostmaster being present to say, "Yes or no", and
without an audit log that validates what has happened,
then you've lost integrity.
And my understanding from looking in on some of what
Second Sight said -- because I was deeply interested in
where their investigation went because, candidly,
I think I started that process off -- but I was also,
you know, interested in what our Distinguished Engineer
at Fujitsu said around auditable logs. And there is
clearly a window there where it's not nailed down the
way it should do and, therefore, you cannot
categorically say that data was altered with the
subpostmaster's permission at each and every stage.
So you've lost integrity and, at the point you've
got that, you can't prosecute against it, in my view.
Now, you say in your statement that you began to
question the integrity of Horizon after you received
a further call from -- forgive me, you've mentioned
an earlier call but you received two calls from Computer
Weekly, asking you to comment on Horizon's integrity; is
that correct?
That is correct.
The second of which you can date to late 2011, early
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On the topic of prosecutions, you say in your statement
that the Post Office should have stopped prosecuting
subpostmasters after they'd received Second Sight's
Report. Does that reflect your view as to the timings
of this, that is to say that, once Post Office was in
possession of that report, the prosecutions should have
stopped? What I want to ask you is, why do you date it
to the Second Sight Report and not, for example, to the
discovery that you had in February 2011 of a bug which
could cause accounting discrepancies?
So a code issue, a bug issue, can get resolved. You've
got some aftermaths that you've got to resolve and some
of which we've talked about. But the issue that I think
makes the difference from the Second Sight Report is, my
understanding, from what I've learnt, not having seen
the report but certainly seen their evidence, is they've
found that Fujitsu -- Post Office, Fujitsu, largely --
had an -- you know, there was an -- potentially
an unauditable access into the system. At the point you
don't have an audit log that you can validate, you've
lost your evidential trail, if you're relying on the
data in Horizon.
There may have been other prosecutions that didn't,
but the point I'm trying to make is, you know, where
largely Horizon is featured as the evidential layer for
90
2012; is that right?
Yeah, it's somewhere in a three to four-month window,
yes.
Which you say coincided with significant negotiations
cover the separation of Royal Mail Group and Post Office?
Yes.
It's to that second conversation that you date your
significant concerns about Horizon's integrity; is that
fair?
I want to just give you a sense where I was at this
point in time because I think that's pertinent to where
we are. So I'm working three or four days a week on
separation. The nearer you get to separation, you're
now writing a contract between you and Royal Mail Group,
and it wasn't easy aligning, you know, your own
Executive Team with Royal Mail's Executive Team, and
there was a lot of toing and froing, to be candid, and
we -- the team that pulled that together with a little
bit of help from me, you know, did a good job because it
stood the test of time for 10 years.
But I want to make the point that it was -- in the
last three or four months of my service at Post Office,
I lived and breathed delivering that contract. It was
probably every working hour that I could apply to it.
So I'm in the negotiation when my phone rings, just
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as we're finishing up. I excuse myself, I go into
an anteroom and it's a journalist from Computer Weekly,
right? So it's been a bad day. So I take the call,
it's quite a courteous call and, in fairness to the
journalist whose name I can't remember, he says in
summary the JFSA now has a much larger group -- and it
was, it was hundreds -- of subpostmasters that are
disputing the integrity of Horizon and, more
importantly, they're engaging with lawyers -- later on
it was established that it was Shoosmiths -- to start
pulling together a case -- you know, to take a case to
court.
I emphasise what I had right the way through and
still believed, at that time: that Horizon, in my view
worked as prescribed, I didn't see any issues. There
was maybe a chosen few words I'd used, which have been
repeated in Private Eye and elsewhere.
But, nonetheless, that's what I did. I finished the
call up as courteously as I could. It couldn't have
lasted more than five minutes. And to the point I think
you're now alluding to, I was -- I'd got to the point
where, frankly, I'd had enough. And I rang Duncan Tait
up -- you know, it's like a continuous drib drab with
Fujitsu -- and just said, "Look, I've just had this call
with Computer Weekly, this is where he says things are.
93
rightly or wrongly -- I said, "I'm expecting Fujitsu to
pay for this audit but I want it to be under Post
Office's leadership", and he agreed to that.
As soon as I'd finished that call, I rang Paula and
repeated the conversation I had with Computer Weekly and
the conversation I had with Duncan, and she said,
"Right, okay then". I said, "I've got to get you into
other room with Duncan, so we can take this forward”.
She asked for his phone number, I gave her the phone
number and my presumption -- again, I'm still doing
separation and I'm writing down the contract -- is that
there was some form of telephone call between the two of
them, which I know took place because I think in Paula's
evidence she suggests there were phone calls that took
place.
But that's how I left it and, you know, that's why
my belief is, carrying that through to June when Second
Sight are brought on Board, from when I left in March,
you know, it was clearly followed through and my noting
paper in March to the Board, you know, before I left,
March 2012, talks about a full evaluation of the system
and that it should be a shared process between ourselves
and Fujitsu with execs from both companies, and it talks
about what that might mean.
I expected that to expand, and the one thing I think
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This is reflecting badly on all of us, your brand and
our brand in POL, and we need to address it, and there's
no two ways about it, Duncan, you know, we're going to
have to investigate this system thoroughly".
Now, I'm conscious at this point that there are --
and you'll ask me who and I won't be able to name
them -- but there were one or two people saying at the
point you do that you now question past prosecutions and
other bits of -- but I'd got to the point where, you
know, the wealth of subpostmasters that appeared to have
been affected and the media outlay that was now coming
more and more to the fore, where I felt we needed to be
much more proactive and, albeit I was dispirited by
Duncan's reply to my letter, I had continued to knock on
that door and more or less got the same apply each and
every time.
Every time there was a media outlay, I used it as
a mechanism to say, "Are we sure about the system, are
you sure you won't have look at it". You know, we'd had
those conversations. This time around, I'd got to
a point where I'd had enough and said, "We're going to
do it and, more importantly, I want your support". And,
in fairness to Duncan, he took a minute or two to think
about that and calmly replied "Okay, I think you're
right". And I said, which was an important point,
94
that still hasn't happened and should have happened, in
my view -- and I know this is a long-winded answer --
okay, you can't look at the system in isolation. Right,
the system is one thing and certainly the code needs
reviewing to see what anomalies there are and the
practices they apply to keeping that code where it needs
to be, but you need to look at the process mapping that
sits round that system and the training that's applied
to the Branch Network and the use of that system. I see
too often, even today, with digital systems, where
people buy a digital system and somehow expect the
digital system to make their life easier, without
changing the process that they have, and that all three
need to work in perfect harmony: process, training,
system.
And, in my view, from an investigation point of
view, it should have been a big hitter like Ernst &
Young, okay, that came in and vetted everything because
I still don't think that's happened.
Finally, Mr Young, you say that in your conversations
with Mr Tait, in which you raised, I suppose, what was
a further request for an independent review of Horizon,
you pointed out that damage was being done to the brand
of the Post Office and to Fujitsu. Was that your
principal concern, damage to the brand, rather than the
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injustices that might have been caused to postmasters?
A. Itwas both. It was a conglomerate of a lot of things.
I think this was hurting a lot of people:
subpostmasters, clearly, former subpostmasters, and
subpostmasters. But, as I think my statement alludes
to, you know, I was very conscious that the one thing,
I would say about the Post Office is it has a lot of
long-term employees. It has people that have worked
20/30, in some cases occasionally, 40 years in the
company. To have this backdrop, this Inquiry backdrop,
and where we are today, you know, clearly, you know,
impacts those people too that have given -- you know,
everything they can to the job that they've done day in
and day out for 30/40 years, and I was conscious of that
type of portfolio.
There's some very loyal people across the Branch
Network and in headquarters and, amongst the support
teams, that were trying to do the best job they could
and this was going on in the background and people were
talking about it in the way they are today and, you
know, if you go to a party and say, "Who do you work
for?" And it's the Post Office, you know, that backdrop
doesn't really reflect their time in the job, over the
years they've been working for the Post Office, and the
same for the Branch Network.
97
well, I will not just try; I will keep within the
strictures.
Questioned by MR STEIN
MR STEIN: Mr Young, my name is Sam Stein, I represent
a large group of subpostmasters who have all been
affected by this scandal and a number of them were
involved in the GLO, that's the High Court litigation.
Okay?
Now, your evidence, as far as I can understand it,
has been this, and can I just summarise it: that when
you came into the Post Office, you were told that,
largely, the operation of the investigation and
prosecution section was being dealt with by a team and
that you shouldn't really interfere. That's a summary,
a paraphrase of what you said; is that about right?
A. Yeah, I think the words used were "You don't need to be
part of it".
Q. Yes, and, secondly, in similar lines, when you were
thinking about the question of what is Fujitsu up to,
regarding the operation of the system and its coherence
or its integrity, you were told, well, that's up to
Fujitsu because Fujitsu owns the data, and owns the
source code, and that therefore they're in control of
that; again that's about right, is it?
A. Well, they don't own the data. The data was always.
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It's left a litany of bad press behind that, you
know, some people probably deserve but others don't, and
I was conscious of that too.
MS HODGE: Thank you, Mr Young. I have no further
questions.
Sir, there are some questions from Core
Participants. I think those are likely to take us
beyond 1.00, but I'm sure that Mr Young would like to
finish his evidence. So it may be that if we canvas how
long those are likely to take, you can take a view as to
whether you'd be willing to take a slightly later lunch
break.
SIR WYN WILLIAMS: Yes, yes. So who wants to ask questions,
and how long are you going to take?
MS PATRICK: Sir, for the Hudgells team we have around
25 minutes.
MS PAGE: I'm afraid similar time from me as well, sir.
MR STEIN: Sir, on behalf of Howe+Co, five minutes.
SIR WYN WILLIAMS: Right. Well, let's use those few minutes
up to lunchtime to hear Mr Stein's questions and then
I think it's inevitable we'll have to have a break for
lunch.
So your five minutes could go to ten, Mr Stein, but
not longer than that. That's what it boils down to.
MR STEIN: Thank you very much. I will try to keep to ~
98
going to be the Post Office's, if it's generated by
branch. But they certainly owned -- they owned the code
of the system.
Q. Right, and the sense we get from your statement is that
it was only towards the end of your tenure, your years
at the Post Office, did you start to gain some concerns
regarding the system and, therefore, you wrote
a document to the Board, which was a noting document to
the Board, which was to say, “ought to be reviewed"?
A. Yes.
Q. Okay. Now, you've been asked a number of questions by
Ms Hodge about the mismatch bug, can we call it that,
just as a simple short version of it?
A. Yes.
Q. You've explained that, regarding the mismatch bug, and
this is what you put in your statement: you thought that
it had arisen in the testing environment, rather than
the full rollout, yes?
A. No, the testing environment is one thing. Just to make
sure we're all talking about this in the --
Q. Remember how little time I have.
A. Inthe pilot, right, you've tested it. You think it's
fit for purpose. You're now running a pilot over -- in
waves. You run a pilot and then you go to the next
wave, next wave and then, before you know where you are,
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there's a sitdown and "Let's now go out into main
rollout".
So let's make matters as simple as possible: you did not
think it was a bug that was operating in the live
environment. That's what you say throughout your
statement, that's as you've given your evidence
originally to Ms Hodge, yes?
Yes.
Right. So, by the time, in fact, in February 2011,
you're being made aware of this mismatch bug, did you
realise that it was important, particularly as against
the growing clamour in the public sphere, regarding the
reliability of Horizon?
It's the -- having listened to the -- you know, the
evidence and, more importantly, having, you know, looked
at that summary that talked about February 2011, if
in -- if it's not a -- because I'm a -- like I said,
there were certain facts that had symmetry to pilot: the
62 branches, the way the outfall was dealt with, the
gains were kept by the postmasters, the debts were
managed and kept by the Post Office, exactly the same
process, it would appear, have been carried out on both
mismatches but it's why I thought they were one and the
same.
Did you think that the mismatch bug at the time, in
101
important: this was very important, as against the media
issues that were current at that moment; do you accept
that, Mr Young?
Agreed.
Right. Now, let's try and work this through. There was
no mention in the document where, just before leaving
Post Office, you say to the Board that there needs to be
a review of the system. There's no mention of the
mismatch bug in that document?
No, there's not, no.
There's no reference by you to the Board of this very
important issue as against a lot of media interest going
on at the time. There's no reference by you to the
Board of this very important issue either, is there?
You don't take it up to the Board?
No, there's not, and equally, there's no reference to me
via Fujitsu or via Lesley or via my own team with that
regard.
So shall we just look at your own levels of personal
responsible to start off with
Okay.
-- because you appeared to be the person that people are
going to. They're saying, "Mike, look, there's this
problem, and it's a problem in the live environment".
Now, if we're talking about personal responsibility,
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2011, when it was raised with you, was important as
against the growing clamour regarding the integrity of
the Horizon system in the public?
Well, clearly the answer to that would be yes.
Right. Can we go then go, please, to FUJ00081545. It
should come up on the screen, and if we can go to
page 4, please, on the system, that would be very
helpful.
If we scroll up, please. Right. Stop there,
please.
Okay. So we can see here, this is from you,
18 February 2011, 7.58 in the evening, and it's to
Mr Russell and Mr McLean, and it says:
"Will
"I need to sit down with you and possibly several
others just to understand these latest issues on Horizon
and where we are with them. This is very important as
there's a lot of media interest in Horizon at the
moment."
Then you're asking:
“What would be helpful is if you could send me
a written summary on what the integrity issues are and
what's been done about them."
Okay? So we can see that, at that point in time,
there was no doubt in your mind that this wasn't just
102
you're someone that talks a fair bit in your statement
and your evidence about your experience, both in
background, in the armed forces, then the police and
then in systems and operations. Now, this is being
relayed to you as being an important issue in the live
environment outwith the Post Office. It was your
responsibility to take this to the Board, wasn't it,
Mr Young, and you didn't carry that out?
Yes.
You also were aware that there was an implication, you
must have been aware that there was an implication with
bugs in the system, the live system, that this could
impact upon investigations, and police cases that were
being considered, and cases that were being taken
through the court. You mentioned a couple of times
that, with your background police experience, things
were of interest to you on occasions, and you used that
experience to analyse matters. You must have been aware
that this was going to go to and implicate issues that
were related to police cases; it's true, isn't it,
Mr Young?
Possibly, and the only reason I'm hesitating to give
an affirmative to that is I probably was looking at this
purely from an IT standpoint, but does it have
implications around those people that have been
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prosecuted? The answer is yes, I understand that.
Q. You did nothing about that either?
Can we just take a step back?
Q. Well, did you or did you not do something about that,
Mr Young?
A. I'd like to take a step back, if that's all right?
Q._ I'd prefer you to answer the question but I'll let you
have your step back.
A. I will answer your question, if I can take a step back,
all right?
I thought this was tied to, and I'm wrong, clearly,
having gone through this now, I thought this was tied to
the original Oracle bug, which I thought had been dealt
with. Clearly, that's not the case. I'm going to come
back to the point I made before because I don't want
that to get lost. Usually -- and I don't know of any
other occasion, potentially, where this may have
‘occurred -- usually, when something like this happens,
a major incident is generated.
That's not by me. That's by the people operating
the system and they sit both sides of the fence, in IT
and in Fujitsu, and, at the point a major incident comes
out, the Executive Team and the Boards get those major
incidents, along with me, at the same time. That's
missing.
>
105
to the Board. You were one possible means of getting it
to the Board but there were others, the reality is it
didn't get to the Board: is that it, in summary?
A. From the disclosure documents, yes, sir, that's the
case.
‘SIR WYN WILLIAMS: = Thank you.
MR STEIN: So the position is, Mr Young, you and others all
failed to do your job properly as regards to this issue;
is that fair?
A. No.
Q. Okay.
A. I've said why it's not fair.
SIR WYN WILLIAMS: All right, thank you.
MR STEIN: The last question on this. The document I asked
to go on the screen says this:
"I need to sit down with you and possibly several
others just to understand these latest issues ..."
So, in fact, that reply, written by you, tells us
that these were the latest issues; they weren't the
previous issues. You knew these were separate to the
earlier ones, didn't you, Mr Young?
A. I'm not disputing that when I read that now but, in the
happening, in the operation, that's what I was seeing.
Iwas seeing something related to the original Oracle
bugs --
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Also, what's missing is any sort of executive
overlay from Duncan, Gavin Bounds or anyone in Fujitsu,
out of courtesy to me. That's missing too, okay?
So I am sat there, I think at the time, seeing this
as part of the original Oracle issue. It clearly isn't,
okay? Is ita miss by me? In answer to your question,
the answer is yes. Had I known that it was a new bug,
managed in the same way, in all its various facets, and
miraculously appearing to affect 62 branches like the
original one did, I would have had phone calls both to
Fujitsu and to my Board colleagues.
But there is a process that sits in IT from
a Service Delivery and IT point of view, that doesn't
need me in the link. If Mike Young is away on leave or
ill, it doesn't all fall flat on its face. There are
processes and procedures that kick in that allow this to
get escalated with all of the backdrop of how it's come
about and what's being done about it. I don't see any
of that in this, or in the disclosure process. That's
the only point I'm trying to make. So do I accept --
SIR WYN WILLIAMS: Can I summarise this, otherwise it won't
be five minutes, it'll be 15?
MR STEIN: Yes, sir.
SIR WYN WILLIAMS: The position is that you would have
expected that, one way or another, this should have got
106
MR STEIN: No further questions.
A. -- so! don't dispute that point.
‘SIR WYN WILLIAMS: = Right. Thank you. So we'll break for
lunch now.
Before we do, Ms Hodge, are you taking this
afternoon's witness as well?
MS HODGE: I am sir, yes.
SIR WYN WILLIAMS: So let's just have a minute of
an overview. We're obviously going to run significantly
into this afternoon still with Mr Young. So where does
that leave the next witness and the length of time that
that witness may take?
MS HODGE: I don't expect the witness to take anything like
as long as we've taken with Mr Young, in that I have
some questions for him but I can cut my cloth, and
I don't think there are a lot of questions from Core
Participants.
SIR WYN WILLIAMS: = Can I ask Core Participants to confirm or
contradict what Ms Hodge has just said about their
questioning?
MR STEIN: From our point of view, I think that’s right,
yes. Thank you, sir.
MS PATRICK: From ours too, sir. I think most of the
questions we wanted to cover are going to be covered by
Counsel to the Inquiry.
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(27) Pages 105 - 108
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‘SIR WYN WILLIAMS: = Right. Ms Page or Mr Henry?
MS PAGE: I'm just having a very quick look. Mr Henry is
not in the room and was going to deal with this witness
but I've just looked at the Rule 10 and I can confirm
that we don't have questions.
SIR WYN WILLIAMS: Right. Fine. Well, that's fine.
I'm prepared to sit, you know, reasonably this
evening to finish the witness but, as you all know by
now, by about 4.45, my powers to concentrate are waning,
shall we say. So I hope everyone will bear that in
mind.
So we'll start again at 2.00, yes?
MS HODGE: Yes. Thank you, sir.
(1.02 pm)
(The Short Adjournment)
(2.00 pm)
MS HODGE: Good afternoon, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes, I can, thank you.
MS HODGE: Thank you.
SIR WYN WILLIAMS: Who is going first?
MS HODGE: I believe it's Ms Page.
Questioned by MS PAGE
MS PAGE: Mr Young, you were Chief Operating Officer when
you left POL in April 2012 with Lesley Sewell Head of
Technology, one of your direct reports, yes?
109
Q. She has her own --
A. -- that the construct that I put in place per my
comments before the lunchtime break, allowed the
business to pursue, in hand with Fujitsu, a proper
investigation of the three elements I talked to: the
process, the training and the system itself.
Q. Well, let's go back a little bit and what you say about
the chain of command in 2010. You've told us in your
witness statement -- no need, I think, to go to it --
that after David Smith moved to Royal Mail Group in
October 2010, you say he continued to actually have
oversight of the Post Office and, in particular,
Ms Vennells continued to report to him until around
April 2011, yes?
A. That's my understanding, yes.
Q. What was the degree of oversight as far as you
understood; are you talking daily, weekly, monthly
interventions?
A. Between?
Q. Between Ms Vennells and Mr Smith.
A. I don't know, genuinely don't know.
Q. How do you know that she was still reporting to him?
A. It's a good question. I think some of that -- I can't
remember how but some of that has some through the
disclosure process and some of that has come through not
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Yes.
Yet you take no responsibility for the Horizon scandal:
is that right?
We all have a part to play in that tier around tech. If
the tech doesn't work as described and has caused the
failures that it's caused, then yes, we've got some
responsibility, and that includes me.
But you said that it was really other people's fault for
not telling you of the problems with Horizon, just like
Paula Vennells said that it was your fault for not
telling her.
I highlighted -- other than the last bug, which is
a misnomer that I'll have to come to terms with,
I highlighted all the issues we had with Horizon. As
we've heard, I challenged Fujitsu with regards to
looking at the system. I was reminded that it was
a service, we didn't own the IP. I think some of the
work I did got us to a point where we could demand it
because we would own the IP. I think I did, you know,
everything I could.
Paula's response was based, as I understand it, on
a conversation we had after the first Computer Weekly
call. Now, I actually left in the second week of March
2012 and Paula was there seven years later. So
I thought ~
110
talking with Paula but with other executives within POL,
the suggestion being that she had some handover with
Dave Smith and, as a consequence, he was a mentor/coach
as she went through this process. And I think my
statement talks to -- and down the road, Moya Greene
took on that more of that mantle.
Can we then just look at what Mr Smith says about your
involvement in the background to the Ismay Report. If
we could bring up his evidence, please. It's
1NQ00001128.
When we get there it's page 19, internal numbering,
page 76. Mr Smith said that there were no terms of
reference for the Ismay Report but, in effect, he said
that you were one of a few people who was giving
Mr Ismay instructions. So, if we look at the right-hand
side of this page -- sorry, yes, the right-hand of 76 ~~
it's an answer that he gives, a large answer in the
middle of page 76:
"I think the structure at the time was that Mike
Moores -- actually it was Mike I had charged with
writing the report, and that between Mike and myself and
Mike Young and Sue, we go back to that conversation, we
agreed that it would be appropriate for Rod to carry out
the actual activity, and Mike, myself and Mike Young,
all at various times, did have conversations with Rod to
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sort of set the tone of what we wanted and expected to
come back and also to help and review his progress.
That was more the two Mikes than myself but the three of
us -- it wasn't just one conversation, it was a set of
conversations.”
Then summarising that, the question is:
"So your evidence is that Mr Ismay was getting
instructions from would be people at multiple times?"
Would you agree with that?
I don't recall giving any instructions. I was asked
questions and I responded to those questions but
I didn't give instructions to Rod or to anyone else.
I actually saw the preparation of that statement going
across the whole tech team, not just me, but I responded
to questions as and when they came across my desk.
Let's go a little bit further down, then, see what else
Mr Smith says. At page 22, internal pages 87 to 88, on
the left, Mr Stevens quotes from his witness statement,
and it says:
At the time, I do not think that we thought that
there was any merit in commissioning a further report by
an IT expert or forensic accountant or similar to test
the reliability of Horizon as the report was clear-cut
in its position. There was nothing in it which
suggested we should investigate Fujitsu or Horizon
113
so those were the fundamental reasons."
Was the Seema Misra case part of the reasoning for
not pursuing an independent report?
I don't know. As I alluded to this morning, I wasn't
privy to the prosecution case, for want of better words,
the case prepared against Seema Misra. What little
I got in terms of prosecution data came via the Ismay
Report in itself.
Well, this is rather different, isn't it? What he's
suggesting, Mr Smith, is that, actually, in the
aftermath of the Ismay Report, when "we", the management
team that he has set out on the left-hand side of the
page, when "we" were considering whether or not to take
further action, whether the Fujitsu system was tamper
proof, whether it needed a forensic accountant or
similar to test that, one of the reasons not to do that
was that the Seema Misra trial had tested the Horizon
system and the Horizon system had come through that
test. So he's suggesting you were part of those
discussions.
So I can categorically say that's not the case.
Let's look at the email chain that we've already looked
at, the Mark Burley email chain. POL00424359. This is
a slightly different version of the same email chain,
which has a little bit more in it. If we could scroll
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further."
Then he asks:
“Who was the 'we' when you say that?”
“Answer: I'm talking about a combination of the
Post Office Senior Management Team."
Then further down:
“Paula Vennells, Mike Young, Mike Moores."
So, again, that’s suggesting you were part of
a small group of people responsible for what was going
to happen both in the Ismay Report and what was going to
happen as a result of the Ismay Report; do you dispute
that?
That's the way it reads, yes.
Do you agree with what he says there?
Yes.
All right. Well, let's just look at the right-hand
side, and this answer, the large-ish answer in the lower
half:
the fundamental piece was that we believed that
the system was tamper proof so the Fujitsu position that
was laid out was quite clear. We had not seen in any of
the recent cases any issues that would suggest a problem
and, in fact, a few weeks later, as we now know wrongly,
but at the time, we saw the Seema Misra case as a test
of the Horizon system, and it had come through that, and
114
down, please, to page 4, you'll recognise this from the
version that we saw earlier today. It's an email from
Mark Burley to you and Sue Huggins with various others
copied in. In Mr Burley's paragraph 2, he refers to the
three cases that he's aware of, and I'd just like to
pick up on the Castleton case, middle of the paragraph:
"Castleton where we presented a copy of the audit
log to the subpostmaster's solicitor who promptly agreed
there was no substance to the SPMR's claim and advised
him to settle the debt. The solicitor was sacked by the
subpostmaster who proceeded to court, lost the case and
liability of £300,000 but declared himself bankrupt.
The judge decided there was ‘no flaw in the Horizon
system and 'the logic of the system is correct’ and ‘the
conclusion is inescapable that the Horizon system was
working properly in all material aspects'."
You will have known, won't you, that what goes on
between a solicitor and their client is privileged,
wouldn't you?
Indeed.
So that summary there was nonsense, wasn't it? There
was no way Post Office could know what Castleton's
solicitor said to Castleton, was there?
Potentially, yes.
Was this malign rumour part of the commonplace lazy
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assumptions that Post Office Management made about
subpostmasters, that they were dishonest or incompetent,
that sort of baseless rumour mongering?
Within the Post Office or within the executive? I mean,
frame it.
Well, within your knowledge.
Look, I've seen this played out in the Inquiry before.
I can honestly say not that I'm aware of. Was there
a ~- to further just make a point, was there a view that
Horizon was secure and working as it should do? Yes.
And did people feel, including myself, that we should
defend it because we had no other datasets to suggest
otherwise? The answer to that is yes, too.
But I can't say there was a deliberate stream of
guidance, advice, however you want to term it, coming
from wherever, to -- you know, to do untold things to
the subpostmasters that might be going through or about
to go through a prosecution. That's not something that
1am aware of.
Let's turn, then, to the Misra trial again, and if
I could have POL00169170, please. This is the famous
bandwagon email, which was sent around after the Misra
trial, and what we see in this version of it is your
name as one of the people copied in. Can we scroll
down, please. There we are. The email from Marilyn
117
Seema Misra. I only became aware of this case after
seeing the Channel 4 programme and reading the Ismay
Report. I was not copied on the initial email dated
21 October 2010 regarding the conviction of Seema Misra.
(Email from Rod Ismay to Jarnail Singh [et cetera]).
I was not aware that as a result of a successful RMG/POL
prosecution a pregnant lady was imprisoned.”
That's not correct, is it?
No, on reflection, having looked at that discovery
document, the answer would be no. In fairness the email
doesn't talk about her personal circumstances but I take
your point.
Do you think you've made any other self-serving errors
of that nature in your evidence?
It's not self-serving, genuinely not self-serving.
What about the recollection of the second Computer
Weekly call and your subsequent very detailed
recollection of your conversation with Duncan Tait; is
that a little bit self-serving, Mr Young?
No, I was angry. So I remember it implicitly because
I knew what it would mean and it was me almost
passing -- you know, passing the ability to get the
system investigated onto the -- what would be, after
separation, the CEO of the Post Office. And I have made
the point -- there were a number of points to that and
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Benjamin in the bottom half of the page is the bandwagon
email, and we see here that it has been forwarded from
David Smith, that's the manager David Smith, to you,
Mr Ismay, Mr Moores and Ms Vennells:
"Rod
"Brilliant news. Well done. Please pass on my
thanks to the team.
"Regards
"Dave."
This was Post Office using a criminal trial for
improper collateral purposes, wasn't it?
That's not the way I see it. I actually think what Dave
‘Smith was trying to do was thank people for their
efforts to see it through. Now, we can argue about
whether it was right or wrong; that's the way I saw it.
I did nothing with that email. I think the intent
was -- the way I read this email from Dave Smith, the
intent was I was to pass my thanks on potentially to
John Scott. I didn't. I read through it and I left it
as it was. But I do think -- and I did see Dave Smith's
evidence -- I do think, you know, it's not a great
message, personally.
Could we have your witness statement up, please, at
page 35, paragraph 110:
"Further, I was not involved in the prosecution of
118
one of them was we didn't own the IP and, every time you
knocked on Fujitsu's door, you know, "You bought
a service, we're in the parameters of the service". And
it wasn't until quite late in the year that we had
secured the IP through the broadband contract.
So there were a number of actions that add
credibility to the action that happened after that call.
Well, let's go to some communications with Parliament.
I'll just actually go to one and perhaps give some
references for others in the interests of time.
POL00417094. If we could scroll down a little,
please. There's a lot of Mikes in this email chain, it
gets a bit confusing but this first Mike is actually
a draft directed to Mike Whitehead from Mike Granville.
It says to Mike Whitehead:
"In response to you query:
"The system is based on a user log-in, and all
actions have to be endorsed by the user. POL cannot
remotely control a branch's system. Any technical
changes by Fujitsu that impact the system have to go
through clearance processes which would prevent any
amendment to existing data. The independent audit file
is in place and can show all the system activity, down
to a single keystroke, in a particular branch."
So that was a draft. If we scroll up, Mike
120
(30) Pages 117 - 120
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Granville wants to run it past you, Mike Young. So he
sends it to you and he says:
“If it is helpful re your meeting with Paula --
please see below my draft response to BIS ...”
So do you know what became of that; are you aware
that that then did actually go as far, as we can tell,
to Mike Whitehead at BIS, that formulation about remote
access?
I don't know. Like you, I would presume it went to
where it was meant to go.
As I say, I wouldn't take you to it but in POL00120561,
we see a further briefing which includes that wording.
It goes again to you, it covers various issues to do
with the Seema Misra trial, it talks about the very
robust stance that Post Office wanted to take, did take,
continued to take and that BIS took up, therefore, with
Ed Davey following his meeting with Sir Alan Bates.
Now, you were obviously aware that these very robust
lines were going to Parliament, weren't you?
Well, I'm -- clearly, I'm aware of that. So as my
statement said, I didn't sit down. The only MP I sat
down with, which was an introductory meeting to the Post
Office, was with Ed Davey, and a number of the execs
were invited and that meeting lasted an hour and, as my
statement says, it didn't cover Horizon, Where I may be
121
Whether this was accurate.
I thought it was accurate.
On the basis of what you'd be told by Fujitsu?
Yes, and what my own team thought was in place.
Well, let's look at what happened further on down the
line because in November 2011 you were still giving the
same sort of robust lines to Parliament. POL00295067.
If we scroll down a little, please. As we can see, this
is from 18 November 2011. If we stay on the email from
Rod Ismay to you, if you're willing to take it from the
subject line "Parliamentary Questions about Horizon",
that's what we're dealing with. In the middle of the
first paragraph:
"It remains consistent with our robust stance but is
amore concise set of words."
Then if we scroll up to your reply:
"Sorry not to have got back to you sooner, been
stuck in MDA negotiations all day.”
So that confirms that at this point in time you're
very strongly tied up with that:
"I'm okay with the approach and the wording.”
So, by this time, you are aware of the EY reports,
you are aware of issues growing and yet you're still
content with this robust stance to go to Parliament.
I'm trying to work out the point. So are you pointing
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asked by someone, in this case from regulatory, or maybe
from PR for a sanity check around a statement, in this
particular case, audit controls on the data, you know,
I'll provide that.
I'm responding to an internal response. I never had
a direct conversation with a Member of Parliament or
with representatives of the Government that later on
joined the Board.
Did you not feel that, as Chief Operating Officer with
technology in your remit, it was your responsibility to
make sure that what was said to Parliament was
absolutely accurate?
Yes.
Yet you didn't, did you?
Why?
This was not accurate, was it? The EY findings are not
mentioned here, are they?
No.
SIR WYN WILLIAMS: Well, to be fair --
MS PAGE: To be fair, actually --
‘SIR WYN WILLIAMS: = -- (unclear).
MS PAGE: Quite, I withdraw. Thank you, sir, and
A
I apologise.
But you didn't bother to find out did you?
Bother to find out what specifically?
122
to the fact that E&Y had raised some issues associated
with user and privilege access because I didn't see
anything in the EY report that. Talked about audit
logs, checksum datas and keystrokes. So I'm trying
to -- I want to answer your question but I'm trying to
see what bent there is to it.
Well, at this point you've told us this morning that
you're starting to have some concerns about Horizon and
yet you're content for the robust position, the same
kind of robust language that's been going back now since
the previous year and you don't see any need to revisit
that approach?
So maybe your interpretation and mine are slightly
different but there was always a nagging doubt, okay, at
the point that you've got more and more subpostmasters,
you know, it grew, as we all know, in the JFSA, saying
the system was wrong.
If you didn't have that nagging doubt, okay, then,
you know, you've got a bit of a problem. So it acts
almost as a conscience check. I'm going to go back to
what I said and maintained, right. I saw nothing in the
Horizon system beyond what was in rollout, and then some
of the change activities and the hardware failures that
suggested Horizon was doing anything but what it was
prescribed to do, and it certainly was within its SLAs,
124
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and where there were failings, okay, they were
highlighted.
The issue associated with privileged access worried
me, right? I've no doubt about that because I thought
that might be better policed, but it was addressed in
a relatively short timescale. It's only with the
hindsight of this Inquiry and some of what I've learnt
from the Second Sight Report that, you know, I now know,
through that benefit, that some of the audit logging, as
I might have perceived it, okay, isn't -- wasn't as
locked down as best practice would indicate and it was
‘open to abuse.
But you tell us that, by the time you had that second
call with Computer Weekly, you were getting concerned
and, thereafter, you were determined to make sure that
there was a review of Horizon?
So one of the reasons why I was getting concerned is
there was more of this. There was more a push from, you
know, executives and from the Government Shareholder to
respond to letters they had had from some of their
parishioners, in which case must have been
subpostmasters, okay, and I was having to underwrite
some of that. And I did that quite deliberately because
I wanted to take the pressure off Lesley, so she could
do her job, which was the day-to-day management of the
125
ensure the Horizon computer system in branches
nationwide is fully accurate at all times."
We probably don't need to go through it all because
it's very much the line that was being taken by Post
Office at that time but, if we scroll up, we can see
that it's a debate about whether or not to send that
letter. It goes to Paula Vennells from David Simpson,
it goes to Susan Crichton, it goes to Mike Granville and
someone called Rebekah Mantle. Various other people are
copied in, including obviously you, Kevin Gilliland, Sue
Huggins, Rod Ismay.
Now, if we then go a little further up we see that
Paula Vennells responds to everyone and then you say in
the email above that that you're happy with the letter.
You and Susan have spoken about it and you're both
comfortable with it.
If we then go further up again, we see that Rod
Ismay has forwarded it to Angela van den Bogerd, and he
says:
".., thanks for our time this afternoon. [This is
the] response to Private Eye ...”
He attaches a pdf. If we scroll all the way up,
just for completeness, we can see that he also sends the
Private Eye pdf.
Now, what's interesting about the various people
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system.
At the point that you're having the conversation
with Computer Weekly, towards the end of 2011, you're at
a point where you're being told: litigators have been
appointed and there's now hundreds of subpostmasters.
Right? Did my mindset change at that point? The answer
is yes. Did my mindset significantly before then? The
answer is no because I couldn't point to anything on the
system. I still wanted something from Fujitsu that told
me the system, right down to a code level, was working
properly, and the response I got was, "It's a service,
our algorithms aren't bringing up any anomalies".
I mean, I'm not sure where else you'd like me to go
because the heat, if we can call it heat, is coming from
Parliament through parishioners and it's coming through,
you know, the media.
Let's just go to one last document, please. It's
POL00338400 and this relates to the letter that you
signed off on to go to Private Eye, following their
article.
Yeah.
If we start, please, at page 2.
If we scroll down a little bit we can see the
content of your letter, and it's the bit that starts:
"Sir, the Post Office takes meticulous care to
126
copied in on that is that an email -- which I won't
bring up for the benefit of time but which is
a well-known email now -- the Lynn Hobbs email, in which
she talks about the fact that Fujitsu does have the
capacity to go into branch accounts and amend the data,
that email from Lynn Hobbs went to pretty much all of
those people who I've just read out. They all therefore
knew that the claim that Horizon had no backdoors was
not correct, and they were all in on this email chain in
which it's proposed that you write a letter to Private
Eye saying there's absolutely nothing wrong with
Horizon, it's all perfect.
Do you feel that you were being set up here?
No. I do want to --I don't. So I had been asked
I think, once or twice before to put my name to
a statement that said the system is secure, in a set of
words, so I wasn't surprised when the Private Eye
article came up that I was being asked to do the same.
So I want to make sure, because I said this earlier
on in my evidence this morning, a backdoor -- we have to.
be careful about how we use our language -- a backdoor
is for me and it is for most people in tech --
We all heard your explanation.
Right, well, then there was no backdoor, okay, and
everything, as far as I was concerned, at this point,
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and even when I left, was an auditable checksum log,
okay, that was uncorruptible and no one could get into
it. So that was the case up until the day I left and
the only time that that changed in my viewpoint was when
I was seeing some of the outputs from the Inquiry and
particularly the comments from Second Sight.
Q. But you also told us that, when you had that second call
with Computer Weekly, that was when your concerns
started to really mount —-
A. And I've explained why.
Q. --and you've explained why. You also explained that
‘one of the reasons that your concerns mounted was that
the firm Shoosmiths had hundreds of people that they
were now acting for, yes?
A. Yes.
Q. If we could scroll down to the bottom of page 3,
please --
A. Can I just -- on the Shoosmiths issue, it wasn't the
fact that I was worried about the lawyers finding
something. I want to be clear about that. It was
the -- these were hundreds of subpostmasters that had
grouped together and now were bringing in lawyers,
presumably at their own expense, to pursue this. So it
brought real -- for me, it brought real -- it suggested
there was a real dynamic around having had system
129
Shoosmiths have taken up the cause of the subpostmasters
and yet you are willing to have your name put to the
letter to Private Eye. You have just explained to us at
length why it is --
A. Yeah.
Q. -- that Shoosmiths made your concerns more heightened.
Are you sure you are not suffering from more
self-serving memories here, Mr Young?
A. (The witness laughed) I just recall the phone call and
I recall that feeling that this thing had moved to
another level and we needed to change our -- you know,
we needed to change our perspective on having the system
looked at.
Q. Thank you.
A. So, you know, putting the two together, that's just
where my head was at.
MS PAGE: Thank you.
‘SIR WYN WILLIAMS: Ms Patrick?
Questioned by MS PATRICK
MS PRICE: Thank you, sir.
Mr Young, my name is Angela Patrick. I act for
a number of subpostmasters who were convicted and have
since had their convictions quashed. You might be glad
to hear I only want to look at two topics and, if we can
start with the Ismay Report. You've gone over that at
131
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issues. Okay? So the numbers growing and the
postmasters themselves bringing in a high-end law firm
to fight their fight suggested, you know, this wasn't
a group of disgruntled subpostmasters that just wanted
to blame the system as an out, potentially, this was --
They were taking it seriously?
-- something very different and, on the basis of that
notable difference, that's why, you know, I went back
to -- I didn't ask for permission, I went back to Duncan
and said, "No, we're going to have to do this".
Let's just look at the email at the bottom half of the
page from David Simpson to the same addressees I read
out earlier, you're copied in, and this is about the
letter that you're about to write to Private Eye.
If we pick it up:
"The names of the subpostmasters featured are very
familiar and the claims made against Horizon are the
same ones we've seen many times before. The article
also mentions Shoosmiths and a possible legal action the
firm may bring -- but Shoosmiths have been saying the
same thing since the early part of the year.
Disappointingly -- but perhaps not surprisingly --
Private Eye has not run in full the very short statement
we sent to them."
So at this point, Mr Young, you are on notice that
130
length this morning with Ms Hodge, and again just now
with Ms Page.
There's only one section I really want us to look at
but I just want to clarify what you've said. Now, in
early summer 2010, you'd been chasing Fujitsu, without
success, to ask for an independent third-party review of
Horizon Online, hadn't you?
Yes.
By the summer, Ms Page took you to the email thread
again, you knew that the then Managing Director, David
Smith, had been asking questions following the Channel 4
journalism reporting, and that you had been looped into
that process.
Yes.
You've told us that you were particularly assured on
reading the Ismay Report?
Sorry?
You were particularly assured on reading the Ismay
Report?
I was. It gave me some confidence around the system.
Indeed. Now, you would have read that about I presume
August 2010, I think it was finished?
I wouldn't be able to tell you, but I would imagine as
soon as it was circulated I was reading it.
Indeed, and that would have informed your approach,
132
(33) Pages 129 - 132
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The Post Office Horizon IT Inquiry
going forward, having been assured, having read the
Ismay Report, I assume that would have informed the tack
you were taking going forward?
Yes.
Now, the Inquiry has looked at the detail of the report
with Mr Ismay and lots of other witnesses. I don't want
to go into the nitty-gritty, I want to look at one part,
and if we could bring it up it's at POL00026572. The
part I want to look at is on page 19 and, if we could
scroll to the bottom of the page, I'd be very grateful.
We see there is a part there on media. This part
deals with the "Independent Review and Audit Angles".
I don't want to look at all the detail but you can see
that there in front of you but you can see in the first
paragraph there:
"POL has actively considered the merits of
an independent review. This has been purely from the
perspective that we believe in Horizon but that a review
could help give others the same confidence that we
have."
Now, the bit that I really want to look at is on the
next page, so if we could scroll over, I'd be very
grateful. If we could stop, it's that first paragraph
at the top which the Inquiry has seen a number of times
before. Can you see that there, Mr Young?
133
back to the Post Office as a request from me and them,
we would have some persuading to do with those that sat
doing the prosecutions. But, you know, I was tackling
it one bridge at a time.
Just pausing there, what you've said this morning, we
know pre-Ismay Report, you've given that in evidence,
from the start of your role you knew that the Royal Mail
Group and Post Office as part of that had been pursuing
individual prosecutions?
Yeah.
When you read this, did it cause you any concern?
Well, I recognise, I think the point you're trying to
make -- recognise -- the point you're asking me to
recognise -- do I recognise that this potentially shuts
the door on being even handed with regards to a review
on Horizon, basically saying, if you do go down that
particular road, we're going to have to go right the way
back through all the prosecutions and -- I recognise
what that means. I am -- I'm saying it wasn't changing
my approach with Fujitsu. So yes, I recognise that.
Okay, and you've given evidence, you were pushing in
summer 2010. I want to look on to the second issue now,
and I want to move forward to Shoosmiths, and you've
gone over it a little bit again just now with Ms Page.
‘So we're whizzing forward to back end of 2011 and
135
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I can.
Yes:
“It is also important to be crystal clear about any
review if one were commissioned -- any investigation
would need to be disclosed in court. Although we would
be doing the review to comfort others, any perception
that [the Post Office] doubts its own systems would mean
that all criminal prosecutions would have to be stayed.
It would also beg a question for the Court of Appeal
over past prosecutions and imprisonments."
Now, we've heard a lot about reading things with
your former policeman's hat. Did the inclusion of that
section and your reading of that section cause you any
concern?
Let me answer it this way. So it wasn't going to
dissuade me from pushing Fujitsu to have an independent
review of the system. So -- and indeed, it didn't. So
it was -- you know, Duncan may allude to the fact that,
you know, it usually came up in our conversations,
certainly when we were face to face, or it was a long
conversation, or when there was a media output, you
know, I would run the ground again around potentially
looking at the system.
So I wanted to get to a point where I'd got Fujitsu
to agree and I've no doubt, if I brought that ticket
134
the time the Post Office received number of letters of
claim from a number of subpostmasters, including Julian
Wilson. Mr Wilson died before his conviction could be
quashed and we represent Mrs Karen Wilson, his widow,
who is a Core Participant in this Inquiry.
I want to look at what your statement says -- and
you don't need to turn this up, you can if you want to,
it's at page 44, for the record it's WITN11130100, and
I want to look at page 44, starting at paragraph 143.
You say:
"Regarding proposed litigation, I was not aware of
the proposed Shoosmiths litigation until it was
mentioned via the second Computer Weekly call, where
they indicated that the JFSA instructed lawyers [and
there's a little bit of a grammatical issue there].
Computer Weekly did not refer to the litigation as the
Shoosmiths litigation."
You go on:
"During my tenure, I was unaware that the Post
Office took any particular approach to legal privilege,
how to manage confidential communication, and the
retention of documents generally and as it related to
the issues raised by the JFSA about Horizon or any
potential litigation ... I personally did not take any
legal advice."
136
(34) Pages 133 - 136
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Then the last paragraph:
"In late 2011 [this is paragraph 145] and early 2012
I was not involved in the potential litigation against
POL from [subpostmasters]. I did not have any
involvement or knowledge of the issues of litigation
until the second Computer Weekly call (as mentioned in
paragraph 143 above). During that time, I was focused
‘on the Separation", and so on.
You've already talked about this a little with
Ms Page.
Now, you've repeated again that the second call from
Computer Weekly, that's what changed your perspective,
yes?
Yeah, it was a combination of a lot of things but that
one call got me to a point where enough was enough, we
needed to do something, yes.
It was after that call that you remember calling Duncan
Tait?
Yes, immediately after.
Okay. Can we look at one document, please, for now.
It's POL00294928. If we can go to the bottom of the
second page of that document I'd be very grateful.
Can you see that there, Mr Young? There's an email
at the very bottom. I want to look at that first. Can
you see it?
137
and I don't want to spend a lot of time on it. But can
you see there there's an email from Emily Springford?
I can.
You can see the date there, 20 October, same day as the
email we just saw and, shortly after that email, so it's
at 3.51; can you see that?
Yeah.
Yes. You can see it goes to Ms Sewell, she's on the top
line of the addressees, and also, if we look at the
second line, it goes to you, doesn't it, Mr Young?
It does.
You can see there what the subject matter says. It's
the JFSA claims, disclosure and evidence gathering.
It's headed "Privileged and confidential’, it says:
"Dear all,
"As you are aware", suggesting there has been some
conversation in the business before that email, doesn't
it?
Yeah.
Yes:
"... [Post Office] has received", and it goes on to
talk about the letters of claim, the substance of the
claim being relative to training, to support, to their
use of the Horizon system and the Horizon system itself.
I'm sure you've seen this document, I think it's
139
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15 October 2024
You can see there's an email there from Paula
Vennells, at 13.48 on 20 October 2011. Can you see
there the heading, the subject matter of the email,
"Horizon independent assessment"; can you see it?
Yeah.
Yes, and she writes:
"Lesley, excuse me if I missed it -- did you get
back to me re confirmation as to how robust/reliable
[Pinterest] ..."
We think it might be Pintest.
Itis Pintest, yes.
"... (is the right name) were? le what other type of
validation work they have done on this scale/for whom?
"Also when do we expect the results?
"Kevin has heard today the BBC may be going for more
coverage."
We can see that's copied to you, isn't it, Mr Young?
Itis.
I just want to look at another document to see where we
are on this date because the Inquiry knows that, on that
day, a Royal Mail Group lawyer circulated direct advice
‘on legal privilege. So if we could look at that, it's
POL00176467, please. If we can go to page 2, and stop
there.
Now, the Inquiry has seen this email a lot of times
138
been provided to you, she goes on to advice on document
preservation, document destruction and matters of legal
privilege.
Now, do you recall this email being sent to you, and
legal professional privilege being drawn to your
attention for the circulation to your team?
I don't recall. So you're right, I did get this via
disclosure from the Inquiry. I didn't recall this email
and I think part and parcel of that rationale was, you
know, no change. Let me explain myself by that comment
or those comments. I mean, essentially, I think what
this is saying is, in relation to Horizon, its integrity
or otherwise, nothing was to be deleted or disposed of
and all matters related to that were to be kept. And
that was, you know, that was normal practice anyway.
But I take your point. That was my interpretation of
the letter.
So I mean, this is -- by this time, we're in 2011,
you've been talking about an independent review, the
year before, of Horizon Online, albeit. You've been
involved in the press coverage. Do you accept that, at
least at this point, in October 2011, you would have
known that there was litigation in contemplation?
Yeah. That said as such, yes.
If we can turn back to the document we were just looking
140
(35) Pages 137 - 140
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at I'd be very grateful. It's POL00294928, please.
If we go back to that last email at the bottom of
page 2, we can start there. Now, if we scroll up we can
see Ms Sewell replies. If we scroll up a little bit
further, so we can see the header, thank you.
We can see Ms Sewell replies, and she replies later
that afternoon at 5.39, and can you see that there
you're copied in, Mr Young, aren't you?
Yeah.
But she also copies in Emily Springford and Hugh
Flemington, doesn't she?
She does.
She changes the subject matter to "Legally privileged
and confidential". Now, the Inquiry has seen the advice
we just turned up. Part of the advice is, if you're
talking about these matters, can you copy in Legal and
can you head it "Legally privileged and confidential”.
Now, she writes to Ms Vennells, in her reply:
"Fujitsu have reviewed who they will use for the
review of HNG-X and as such will not be using Pen Test
Partners as they had originally intended. They have now
in engaged with KPMG to complete the review, which they
expect to take two months.
"There is a meeting tomorrow with Legal to discuss
the scope and timing of this review.”
144
going on with this Horizon independent assessment, isn't
she? You're nodding, Mr Young. You have to say "yes"
‘or "no" for the recording.
I'm -- can I read it? I'm conscious that we've got
a stenographer. So I just --
In that case, just to be absolutely -- not this part, if
we can go back to Ms Vennells' original email, that's
what I'm talking about. Her original email at the very
bottom, which she heads, "Horizon independent
assessment”, and then she says she wants to know who's
doing it, doesn't she, how robust and reliable they
are --
I can read that, yes.
-- and she wants to know what other kind of validation,
what they've done, what scale and by whom, doesn't
she --
Indeed.
-- and when can we expect the results, and she says, "We
know the BBC is going to have some more coverage".
So she wants to know because she knows there's going
to be more press coming up, doesn't she, and she wants
to know what the lay of the land is?
It would appear so. I mean, Paula will have to talk to
what she meant by the email. But I take your point in
the chain -- in the change of -- let's call it
143
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15 October 2024
Now, before we go up to the answer that comes next,
this is October 2011. Was there a plan at this point to
have an independent assessment of Horizon commissioned
by Fujitsu?
Well, this would suggest there was.
It would suggest that, given it's an exchange involving
both Ms Vennells and Ms Sewell, and copied to you, that
that plan was known both to the IT Team and to the
executive, wouldn't it?
It suggests that. What I would say is I'm trying to
correlate the call to Duncan after the Computer Weekly
piece and the time frame here. They may very well be in
the same time frame. But I, you know, I'm copied in
and, undoubtedly, I would have read it.
Indeed.
But I'm -- and the reason why it is worth making the
point, the reason why Lesley has come to the fore to do
this, my suspicion, she will have to speak for
herself -- was that I'm out finalising the MDA on
separation and, therefore, she's now taking the lead
with Fujitsu. But your point, yes, it would suggest
that.
But just looking at what Ms Vennells is saying for
amoment. Ms Vennells is writing to Ms Sewell and you
and she's expressing her view she wants to know what's
142
clarification or subject, she's put it under, later on
she puts it understanding legal privilege. I take your
point.
So if we can scroll up just to the next stage in the
conversation, we can see the longer reply at, if we keep
going. Thank you. Stop. We can see Ms Vennells'
replies to you the next day, Friday, 21 October -- can
you see that Mr Young --
Ican.
~ early in the morning. She says:
"This is very high profile. We have had lawyers'
advice about how mails etc are now handled ... so what
is happening here?
"Why do Fujitsu think they can change the test
company after they have to told us who they are using?
Why is there a meeting to discuss scope and timing --
when it was asked for 6 months ago and the scope must
have already been agreed when Pen Test were appointed?
"And re ‘timing in another two months’ -- Lesley,
the last comms you and I had was that we'd have it in
a couple of weeks!
"This is unsatisfactory -- it looks as though it is
not being taken seriously and [we] don't know where the
accountability lies -- in POL or in Fujitsu?"
The next part:
144
(36) Pages 141 - 144
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"A Class Action legal case against [Post Office]
would be hugely negative reputationally, it could cost
us a lot of money and this verification, which
presumably could be of enormous help is not even off the
blocks?
"I don't understand.
"How can it be independent if Fujitsu are choosing
and swapping suppliers? Is that sustainable evidence in
court -- independently verified by a company they
choose? KPMG are a good company -- are they qualified
to do this? And do they have initiation with Fujitsu?
"Finally, I know everyone is working very hard but
I'm a bit disappointed that I found out only by asking
as a result of potential BBC coverage.
"With this going on, I could have easily sent a note
in response to a Board query, saying not to worry
because there's a verification under way and the results
are due any day soon! It doesn't help our IT
credibility if I am on the back foot with what's going
on."
Now, she's sent that to you, Mr Young. It has come
from your Managing Director. Can I assume you would
have read it?
I don't recall it but, yes, if it was sent to me I would
have read it.
145
independent assessment and its relevance to the
litigation?
Right, first of all, it was where I was going to go.
I'm in a blind spot here. So I have no idea what
this -- I can see what it's about but I have no idea
about what the content has been between Fujitsu and Post
Office, what Lesley may have had by way of dialogue with
Paula and then what Lesley may have had with dialogue
with Fujitsu and vice versa. So I'm -- it was sent to
me in error, I saw it in the disclosure process, okay,
and I still don't know what it's about.
At the point I respond to Duncan and Paula after
that Computer Weekly meeting, I'm straight back into
finishing off the MDA on separation, which is why
I suspect -- I can't confirm but it's why I suspect
Paula was using Lesley to talk to Fujitsu and air out
the possibility of a full review of the system.
I had done a telephone introduction of sorts,
certainly spoken to Paula and Duncan and said, "You two
guys need to meet", and Paula had as much opportunity as
Lesley to reach for the phone and speak to Duncan or the
management team in Fujitsu to seek the clarity. So I'm
a bit bemused that I'm being asked about something I've
not really been involved in before that, up until that
initial call to Computer Weekly, and I don't have the
147
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Q. At this point, she is plainly aware of the possibly
devastating impact of litigation challenging the
integrity of Horizon, isn't she?
A. The email suggests that, yes.
Q. She was treating this, her original message about
an independent assessment, as significant and, in fact,
she says “potentially of enormous help", isn't she?
A. Yes, she is. I want to make a point here because I --
SIR WYN WILLIAMS: Well, hang on a minute. This is getting
a little too long-winded. What is the endpoint of this
line of questioning, Ms Patrick?
MS PATRICK: Sir, if I can just ask the next question, it
might help.
‘SIR WYN WILLIAMS: Fine.
MS PATRICK: We don't see a response. We haven't seen
a response from you, Mr Young, but, if we scroll up
we'll see a message from Ms Vennells. Again:
"Mike, I've realised I sent this to you and it was
intended for Lesley.
"But actually as her boss, would you mind looking
into. (Also, watch the tone", and she speaks about it
sounding cross while she's on holiday.
Now, we haven't seen a response but, having perhaps
in error raised this with you rather than Ms Sewell, did
you pick up the phone to Ms Vennells and talk about this
146
answers for you.
Q. You don't have the answers. I'm asking you if you did.
No.
Q. Now, what we know is that you were pushing for
an independent review the year before. We know that
>
this ended up in your inbox, and it's your evidence
that, between this point in October 2011 and in March
2012, by the time you leave, there's been no progress.
Nothing done to push forward this independent code level
review that you thought might be needed and that might
have been covered in your conversation with Duncan Tait,
and which ought to have been paid for by Fujitsu.
Nothing had happened, had it?
A. By the looks of it, no.
MS PATRICK: Okay. Thank you very much. We don't have any
other questions, Mr Young.
‘SIR WYN WILLIAMS: I Is that it, Ms Hodge?
MS HODGE: Yes, sir. That concludes the questioning of
Mr Young.
SIR WYN WILLIAMS: = Right. Well, Mr Young, first of all,
I owe you an apology for saying publicly that the
Inquiry could not trace you when that was palpably wrong
because they had traced you and you'd been in
communication with them. But I appreciate that that may
have caused you unnecessary distress, so I apologise for
148
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The Post Office Horizon IT Inquiry 15 October 2024
that.
Secondly, thank you for your witness statement and
giving evidence today.
THE WITNESS: Thank you.
SIR WYN WILLIAMS: Right. What next, Ms Hodge?
MS HODGE: Sir, I propose a short ten-minute break --
SIR WYN WILLIAMS: Yes.
MS HODGE: -- and then we can resume with Mr Oldnall and do
our very best to complete his evidence today.
SIR WYN WILLIAMS: All right. Jolly good. Thank you.
MS HODGE: Thank you.
(3.01 pm)
(A short break)
(3.14 pm)
MS HODGE: Hello again, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes, I can and I'm sorry if I kept you
waiting a few minutes.
MS HODGE: No, thank you, sir.
Our next witness is Simon Oldnall.
‘SIR WYN WILLIAMS: I I'll just go out of view for a moment or
two while I locate my hard copy of his statement. I'll
be with you in a second. (Pause)
MS HODGE: Thank you. Please can the witness be sworn.
SIMON GEOFFREY OLDNALL (sworn)
Questioned by MS HODGE
149
its exhibits. Could you turn to page 15, please.
Yes.
Do you see your signature there?
Ido, yes.
Is the content of that statement true to the best of
your knowledge and belief?
Itis, yes.
Your second statement, please, dated 30 April 2024.
That bears the reference WITN03680200.
A. Yes, that's correct.
prop
o>
Q. You have that before you, thank you. That's a long
statement running to 276 pages. Could I ask you,
please, to turn to page 255.
A. Yes.
Q. Do you see your signature there?
A. Ido, yes.
Q. Is the content of that statement true to the best of
your knowledge and belief?
A. Itis, yes.
Q. Thank you. The third statement, Mr Oldnall, bears the
reference WITN03680300. That's dated 2 September 2024;
do you have that in front of you?
A. Ido, yes.
Q. That's 46 pages in length. At page 41, do you see your
signature?
151
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MS HODGE: Please give your full name.
A. Simon Geoffrey Oldnall.
Q. Mr Oldnall, you've provided four statements to the
Inquiry, the first of which was a corporate statement,
which addressed a Teach-In session provided to the
Inquiry when it was constituted in non-statutory form;
is that correct?
A. That's correct.
Q. Your second, third and fourth statements you've given in
response to questions directed to Post Office Limited;
is that right?
A. That's correct.
Q. My questions to you today will be focused mostly on
actions and events which have occurred since you joined
the Post Office in December 2020 but before we turn to
that, please, I'd just briefly like to go through the
formality of confirming each of your statements. Do you
have a copy of the statements in front of you?
A. Ido.
Q. Thank you. If we deal with them in date order, can we
begin with your first statement to the Inquiry dated
20 July 2022, which bears the reference WITN03680100.
Do you have a copy of that in front of you?
A. Ido.
Q. That statement, I believe, runs to 20 pages, including
150
A. Yes, I do.
Q. Thank you. Is the content of that statement true to the
best of your knowledge and belief?
A. tis, yes.
Q. Thank you. Your fourth statement, which you gave
recently on 9 October 2024, it bears the reference
WITN03680400. It's seven pages long, your signature at
page 6, please.
A. Yes.
Q. Is the content of that statement true to the best of
your knowledge and belief?
A. Yes, itis.
Q. Thank you. You are currently employed as the branch
Technology Director at Post Office Limited; is that
right?
A. That's correct, yes.
Q. Before joining the Post Office, you worked, you say, for
20 years in the private sector for consultancy and
technology companies in the delivery of technology
change programmes?
A. Yes, that's correct.
Q. Prior to that, you were employed as a civil servant for
10 years in the Department for Work and Pensions,
including its predecessors?
A. That's correct, yes.
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Q. Thank you. As we've discussed already, you joined the
Post Office in September 2022 (sic). Your original
title was Horizon IT Director; is that right?
That's correct, yes.
Subsequently changed to Branch Technology Director --
In April this year, that's correct.
-- in April this year. What was the reason, please, for
the change in your title?
It was a broadening of my scope, it encompassed not only
Horizon but also a number of related technology elements.
within the branch.
MS HODGE: Thank you.
prop
>
‘SIR WYN WILLIAMS: I think you may have said, Ms Hodge,
"2022", but was it 2020 or 2022?
A. 2020, sir.
SIR WYN WILLIAMS: Yes, fine, okay. I may have misheard you
but I just wanted to be clear about that, thank you.
MS HODGE: One area of your responsibilities is the
management of the Post Office Branch Technology Team; is
that correct?
A. That's correct, yes.
Q. Now, you say in your statement the team is comprised of
various subteams; is that right?
A. That's correct.
Q. One of which is named Remediation and Change.
153
changes were made in the aftermath of the Group
Litigation?
A. Yes, very much so. That was my initial scope.
Q. You were appointed approximately ten months after the
Horizon Issues Judgment was handed down; is that right?
A. That's correct.
Q. What impression did you form upon joining the Post
Office as to the progress which had been made in
responding to the issues raised in that judgment?
A. I think my initial impression was that fairly limited
progress had been made by that point. I think the ClO
at that time had started to put in place the mechanism
to address the judgment findings but there had been
probably little substantive progress at that stage.
Q. What did you understand to be the reasons why limited
progress had been made in that 10-month period?
A. I don't think those reasons were particularly made clear
tome. By the time I joined, we had appointed
an independent audit firm that would help us understand
where we were currently but that work hadn't really
substantially started by that stage.
Q. That firm was KPMG; is that correct?
A. No, initially the firm was BDO, we later changed that to
KPMG.
Q. So that change took place during your tenure; is that
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The Remediation Programme was a programme within my team
scope, yes.
Could you please just briefly describe the role of that
team?
That team was set up in response to driving the
remediation activities that would address the findings
made in the Horizon Issues Judgment.
You also describe in your statement another subteam
known as Security Risks and Investigations; is that
correct?
That's correct, yes.
What's the role and function of that team?
That's effectively looking at where we need to support
issues with Horizon and making sure that Horizon remains
secure and reliable.
Can you describe the nature and extent of liaison
between your Branch Technology Team and the Network
Crime and Risk Support Team.
We effectively provide data to that team. That's
probably about the extent, and that data is normally
provisioned through what's called the ARQ process.
That's the principal extent of your --
That's the principal extent of our interaction, yes.
Would it be fair to characterise a key part of your role
upon joining the Post Office as to embed and ensure
154
right?
Very shortly afterwards, yes.
You explain in your statement that KPMG produced a draft
report in December -- so a couple of months after you
joined -- in which they noted that, in particular, no
progress had been made in relation to privileged or
elevated access controls within the Horizon environment,
is that correct --
That's correct, yes.
-- and that the Post Office used limited controls around
remote access.
(The witness nodded)
I think you say you made that one of your key priorities
upon --
Absolutely yes.
-- taking on responsibility for this area.
You also say in your statement that, in parallel
with that audit work that was ultimately commissioned
from KPMG, the Post Office was setting up a Forensic
Investigation Team within the IT function --
(The witness nodded)
-- to support the response to the Common Issues Judgment
and the Horizon Issues Judgment. Is that the Security
Risk and Investigations Team that you --
Yes.
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The Post Office Horizon IT Inquiry
Is that one and the same?
That's correct, yes, that's one and the same.
I think you say it was recognised in August 2020 that
capabilities were quite limited in that respect?
They were, yes.
They've since been scaled up, is that --
We have improved that capability, yes.
Now, during your tenure as Head of Branch Technology,
you have been required to deal not only with historic
Horizon issues but also current issues; is that fair?
That's correct, yes.
Do you consider you have sufficient resources to manage
both of those workstreams in parallel?
Yes, we effectively separated looking at historical and
remediation activity into a programme, whilst I created
a business as usual team to deal with the ongoing and
current management of Horizon.
So dealing firstly with the remediation aspect,
a programme was launched in late 2020; is that right?
That's correct, yes.
That coincided, I think, broadly with the draft findings
from KPMG; is that --
Yes, it did.
-- and built upon those?
Itdid. They were the basis for the programme.
157
Horizon?
Yes, we looked at the historical defects that were
highlighted in the judgment, and we went through them
methodically and checked whether they could be present
in the current version of Horizon and we tested and had
KPMG verify that testing, to ensure that they were no
longer present in the system.
I think the third example you explain that the Update
Horizon Technology Team -- that was part of your
remediation, team, was it --
Yes.
-- designed a new process for managing current defects
in the system; is that correct?
That is correct, yes.
I would just like to ask you briefly about that process,
so the processes you have in place for managing current
defects. So there are two aspects to this. You've
introduced new process and resource for capturing bugs,
errors and defects during testing; is that correct?
That is correct, yes.
Where and how is that testing of Horizon performed
please?
So that testing is Post Office led. We have created
a Test Team within Post Office. This is led by test
professionals and we effectively have created an overall
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In your statement you say there were, in effect, three
principal phases to that Remediation Programme.
(The witness nodded)
Would it be fair to say the first constituted what might
be thought often as quick fixes, which could be dealt
with fairly swiftly and at limited cost?
Yes, they were things which we should just get on with
and do fairly rapidly and quickly, yes.
You say that one of those was a pilot of a new dispute
mechanism for subpostmasters to improve the end-to-end
investigation processes. Can you describe that please
in a little more detail?
Yes. We effectively looked at the process whereby
postmasters could flag concerns to us around
discrepancy. This was done in conjunction with changing
a button on Horizon to make sure there was some way that
postmasters could report those discrepancies to us, that
then was backed off to a process, whereby we would look
into that discrepancy and work with postmasters to
understand what had happened.
That's a process that sits outside the trading and
balancing --
Effectively, yes.
-- function. You say that with the support of Fujitsu
you resolved 62 historical defects that were present in
158
testing approach that we don't just accept code and put
it into live. We test it, we ensure that we test it
against what's called a regression pack, and we give
a level of assurance that, actually, when we make
a change to Horizon, we don't introduce new bugs, errors
or defects.
So that code is provided to you by Fujitsu --
Itis, yes.
-- is that correct? You're performing testing,
including regression testing, on the code —~
(The witness nodded)
-- before it's released into the live environment?
That's correct, yes.
Can you please explain what systems do you now have in
place to monitor and detect defects in the live running
of the Horizon system?
There are number of steps we take. Obviously, if issues
are reported to us, we investigate and investigate
whether that is as a result of a defect. We have
a process whereby when a defect is reported to us, we
very rapidly convene a process around that defect and
determine what the impact might be, whether it is what
we describe as poor user experience or whether in fact
it's something that might impact the branch. If it's
all those defects are then reported out. Normally
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The Post Office Horizon IT Inquiry
within 48 hours to the branch, we would publish the list
of those defects and we engage with a broad range of
stakeholders to ensure that that impact is understood
and then prioritised for fixing.
In your statement, you say this about the reporting of
defects:
“Where a direct is detected in the live system it
will be reported to the IT Service Desk."
That assumption being by a postmaster, is that -—-
It can be by a postmaster or it can be by anybody who
determines there's a defect, yes. But, normally, we'd
expect the end user potentially to find that defect but
other ways do exist.
You say that analysts in the IT Service Desk are
provided with knowledge-based articles about the
identified defect. Who produces those, please?
They're produced by my team.
They can refer to those when they are dealing with
issues raised with them that might relate to the bug.
Do you have any systems in place to monitor the calls to
the Service Desk to ensure quality assurance in relation
to the application of those knowledge-based articles?
There are number of measures around the IT Service Desk
and its performance that's reporting out. It's
a separate part of the technology team, it's not
161
cooperation from third parties?
That's correct, yes.
You say that one key aspect of this phase related to
making improvements in the provision of transaction and
branch accounting data to subpostmasters --
That's correct.
-- addressing a problem identified in the Horizon Issues
Judgment concerning their access to branch accounting
data on their own system?
The direct access to branch accounting data by
postmasters, yes.
You say that there was a significant initiative planned
to remedy that problem but that the Post Office hasn't
been able to deliver that change into Horizon; is that
correct?
That's correct, yes.
Why is that?
Ultimately, that solution was dependent on another
technology programme, which was our migration away from
‘our physical data centres in Belfast. So the technology
that would have enabled us to get that data much more
readily available to postmasters was dependent on that
other programme, which was ultimately cancelled.
Now, I think you make quite clear in your statement
that, firstly, it was regrettable that that couldn't be
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15 October 2024
directly part of my team, but there are number of
systems in place to monitor the IT Service Desk and the
performance of the IT Service Desk, yes.
I think, essentially, what you say in your statement is
this is now a process which is led and owned by the Post
Office, rather than by Fujitsu as it was --
That's correct, yes.
You've said that the new testing processes identify
approximately four new defects every month?
I think four might be the current number of defects we
have, yes, so it is a very small number of defects
currently.
In the live environment?
Correct.
You have systems in place to notify postmasters of
those?
We too. We utilise number of communication channels,
including Branch Hub and bulletins out to postmasters,
yes.
Now, you discuss in some detail the third phase of the
Remediation Programme, which you explain was launched in
mid-2022; is that correct?
That's correct, yes.
This addressed some of the more tricky issues that
required both greater funding on the one hand but also
162
taken forward, particularly because the purposes of the
initiative was to give postmasters greater transparency
‘over their own accounting data.
What I'd like to ask you now relates to the approach
that is taken or has been taken in the course of the
last year in relation to the recovery of Horizon
shortfalls. Can you assist us, what is the Post
Office's current position in relation to the recovery of
shortfalls shown by Horizon?
I believe the current position is that we do not recover
shortfall unless the postmaster agrees with the reason
for that shortfall.
I wonder if we could take a look, please, at
POL00448362. Is this a document with which you're
familiar?
Not immediately, sorry.
If we scroll down, please, to page 3, so it’s called
“Loss Recovery Update". The document itself doesn't
have a date but the metadata suggests its date is
2 August 2024.
Okay.
It provides this by way of background, it says point 1:
“Following the recommendations made in the Group
Litigation Order and Common Issues Judgment, in 2018/19
[Post Office Limited] ceased action to recover
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Established Losses from [postmasters]. This activity
has been on hold since this time, except where
a postmaster both agrees to pay the established loss and
proceeds to repay.”
So that's consistent with your understanding as to
the current position. However, it goes on to say:
"To support implementation of associated [Common
Issue Judgment] recommendations, a new team (Network
Monitoring and Support) and target operating model was
set up in April 2021, its purpose being to support
[postmasters] to review and resolve discrepancies mainly
found during their trading period balancing process.”
It goes on at point 3:
"The process to review a discrepancy and identify
the cause is formally documented and regularly assured
by the Assurance and Complex [transaction] Team."
What is your understanding as to the role and
purpose of that team and your liaison, if any, with it?
So that is the team, I believe, that's led by John
Bartlett. That team, as the title suggests, would
provide assurance over a number of investigation-type
activities. So, in this context, I would suggest they
are probably looking at the way that the discrepancy has
been looked at by the Network Support Team, as opposed
to anything else.
165
with John Bartlett's team, the Assurance & Complex
Investigation Team, as they're known:
"This includes looking at Horizon transaction data
to ensure Horizon acted as expected and is therefore
unlikely to be the cause of the discrepancy."
It goes on to say there are a number of possible
outcomes: writing off a balance of below minimum value;
writing off the cause as not being established;
correcting with a transaction correction if the cause is
due to a processing error; or establish that the loss
has arisen, on the balance of probabilities, due to
negligence, carelessness or error.
What points 5 and 6 make clear is that, as indicated
above, if the postmaster, in a sense, disagrees with the
analysis as the underlying root cause, then the Post
Office essentially would leave the matter there.
Correct, yes.
But it goes on to make a series of recommendations.
I just want to establish with you your knowledge in
relation to those, and what enquiries were made of you.
If we could please scroll down to page 4. Thank you.
So it lists number of options and recommendations,
identifies there are risks associated with each one. So
the second point:
"Each of these options give rise to risk(s) below
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Now, you said earlier -- it may be a question of
terminology -- but the extent of your cooperation with
what we discussed earlier as the network crime -- let me
get my reference correct.
Yes, the Network Crime and Risk Support Team, that
you provide ARQ data to that team following a request to
Fujitsu Services.
(Unclear) -- the ARQ process.
Do you provide any support to the Assurance and Complex
Investigations Team in analysing that data to explain
what the underlying cause of a discrepancy might be?
I don't recall that we provide particularly regular
support. We would probably, on request, if asked about
a particular defect or a particular issue with the
system, we would provide that support.
Do you think that the analysis of, for example, ARQ
audit data is something which would probably fall within
the ambit of your team, bearing in mind their expertise
and their technical knowledge?
We can certainly support that analysis. We don't
habitually carry out that analysis though.
Do you think you should?
We could.
So we paused there to say that the process of reviewing
the discrepancy and identifying the root cause rests
166
The first being that the Post Office is not adopting
a consistent process for postmasters, presumably
because, if someone agrees, they pay up but, if they
don't, they do —-
That's correct, yes.
-- and, therefore, you've got a difference in treatment,
which isn't based on the Post Office's own analysis as
to the underlying cause of the discrepancy?
Correct.
Secondly, that the policy position is unclear; thirdly,
that there's significant reputational risk for the Post
Office; fourthly financial risk; fifthly that there's
a risk to the relationship with the Post Office's
shareholders, as the approach may be non-compliant with
the guidance around managing public money. What would
you understand the concern there to be?
I would be speculating but I would imagine, given the
guidance around the spending of public money, given that
Post Office already received a subsidy from Government
and that funds a number of activities, I would imagine
that that risk is being called out as potentially
non-compliant but I'd be speculating.
6, a concern that some of the options might be likely to
embed improper financial behaviours and practices in the
168
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The Post Office Horizon IT Inquiry
network of postmasters, if there are no sanctions or
proper consequences for failing to follow the proper
policies and procedures?
Finally, the Post Office might be failing in its
duty of care to postmasters?
So those various risks, some to Post Office and some
to postmasters. Then, please at page 5, please. Thank
you. So here, under "Actions", we see the
recommendation that:
".., the Post Office begins to recover losses
through civil action or deduction from remuneration
(where necessary), following an agreed process and the
approval of an external, independent board. All other
options give rise to significant [postmaster] and [Post
Office] risks across a range of factors."
Were you aware of that recommendation?
I believe I'm aware of some of this activity, yes.
If we scroll down to the bottom of page 6, please. So
these are under the heading "Actions", listed against
various stakeholders in the business, and we see against
"Technology" you are named, and the action is to:
"Confirm that as of today the data can be relied
upon to commence the loss recovery process (noting that
part of the process is to check Horizon)."
Do you recall being asked to confirm that ~
169
If we scroll down to the bottom of page 4, please.
Apologies, if we go up, thank you. We see this is
an email from you, if we scroll up a little further,
please. We see it is addressed Daniel Walton. Can you
confirm his role and your liaison with him?
Yes, so Dan Walton is the Fujitsu lead for the Post
Office Account.
It's copied to John Bartlett?
(The witness nodded)
So the title "Support to City of London Police
Investigation". It reads:
"Dan
“I understand from John that there have been some
challenges with supporting an ongoing police
investigation that involves a large sum of money.
"I obviously understand broader context, but wanted
reassure that [Post Office Limited] is supporting the
police investigation and offering any and all assistance
we can. Can I ask that you help with any conversations
that City of London Police need to have with Fujitsu
Services Limited."
Now, what is the nature of your involvement, if any,
with investigations carried out by Post Office Limited
Investigation Team, and any subsequent referral to the
police?
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Yes --
-- that Horizon data can be relied upon to support the
loss recovery process?
Yes, I do recall that, yes. This is part of a working
group and from memory, now, this paper was sent to me
I think probably around the time I was on annual leave
but yes, I do recall.
Can you assist as to when that was in terms of
timescale?
It would have been somewhere around the summertime,
so --
Over the course of the summer?
(The witness nodded)
Do you recall what you said when you were asked?
I don't believe I actually have actioned this as yet,
but what I will probably have to do is commission
a piece of work to effectively meet that action.
So that one, so far as you're concerned that's an action
that's pending?
Correct, yes.
I wonder if we can go on to look at an email chain
concerning the support that might be provided by the
Post Office and Fujitsu to a police force investigating
suspected criminal conduct. That chain dates from April
of this year, and it bears the reference FUJ00243203?
170
Yes. My role in this email chain was effectively
Mr Bartlett reached out to me, as I manage the Fujitsu
relationship on a day-to-day basis, and he asked me to
impress onto Fujitsu the need to cooperate with City of
London Police, and that was the extent of my engagement
in this conversation.
Now, bearing in mind that the Post Office hasn't, for
some time, sought to recover losses from postmasters
unless they agreed to repay them, did it strike you as
odd; were you at all concerned to be asked to lend your
support to this particular process?
Not particularly, no. My understanding from Mr Bartlett
was that this was -- this wasn't a simple case of
a postmaster that we were, in some way, pursuing over
a loss; that this was a much larger and very much
a police matter.
So the crucial difference here being, so far as you are
concerned, this is an investigation which has been
managed independently by the police?
That's correct, yes.
Now if we could just scroll up, please, thank you.
Mr Walton responds to your email?
(The witness nodded)
Saying this:
"Hi Simon
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"Thank you for your message below.
"As this is a legal matter, [Fujitsu] Legal are
communicating with the City of London Police.
"I am not involved in those communications, and in
any event, [Fujitsu] considers it to be inappropriate
for Post Office and [Fujitsu] to be discussing a police
investigation."
What did you make of that suggestion that it was
somehow inappropriate for there to be any discussions
between the Post Office and Fujitsu concerning
an ongoing police investigation?
I think my immediate reaction was probably something of
confusion, given that my request was simply to my
counterpart in Fujitsu to ensure that Fujitsu cooperate
with police. So probably slightly confused by the
response but, nonetheless, that was Fujitsu's response.
If we scroll up, please, we can see Mr Bartlett responds
to Mr Walton, and copies you in. We'll come to the
point shortly but, essentially, he says to Mr Walton
that one of his team has gone back to the City of London
Police to see how the contact you reference below was
progressing and have an open and objective engagement on
this matter:
[City of London] has informed [the Post Office]
that they have not had any additional information nor
173
the -- an unwillingness to be involved in any kind of
prosecution of postmasters, which I can understand.
So moving on briefly, you discussed the ongoing
relationship between Fujitsu Services and Post Office in
your statement and you comment that one of the concerns
raised in the Horizon Issues Judgment was the extent of
the Post Office's reliance upon Fujitsu, and I think
you've described -- forgive me, you're nodding, and I'm
conscious that --
Apologies, yes. I'll say, yes, when -~
But I didn't ask you a question, in fairness: is that
correct?
That is correct, yes.
Thank you. You describe number of steps which the Post
Office has taken to improve its oversight of Fujitsu.
We've discussed some of those already: regression
testing, for example, to check the quality of code; and
then also the developing your own capability for
monitoring and alerting capacity issues in relation to
performance of the system; and network statistics,
transaction processing, through what's called
an AppDynamics tool?
AppDynamics, yes, that's correct.
I think one of the areas you've sought to address in
particular, because you've made it a priority, is
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contact with Fujitsu after the single, exploratory and
inconclusive conversation."
He said:
"They left that conversation with the feeling that
they were indirectly being told that the Horizon system
was unreliable and so the case could not progress. We
really need to explore this as this is not the nuanced
impression Simon Oldnall has given me."
Now, you obviously were copied into that email.
What did you understand Mr Bartlett to be saying there
and what is this nuanced impression that you had as to
Horizon's reliability?
From memory, the conversation with Mr Bartlett was very
much around the fact that we obviously used Horizon data
in a number of contexts, both through the ARQ process
where we retrieve that data, and so I think I was again
confused by Fujitsu's position that the system was
unreliable, given that, obviously, they provide that
system to Post Office, it's our core trading platform,
and we rely on the data within that platform for
a number of purposes.
Do you have any sense as to why Fujitsu are taking that
position in this correspondence?
I don't have an immediate view on why they've taken that
position. I can only speculate that it was probably
174
privileged access. But you state there have been some
issues in relation to that --
(The witness nodded)
-- and the extent of cooperation you've received. Can
you explain those, please?
Yeah, we have made significant improvements around the
privileged and remote access process and I think it's
important to differentiate between privileged and remote
access. So we have tightened up particularly the
process whereby there's a role that I believe was
referenced in the Horizon Issues Judgment called APPSUP,,
where specifically that process now has very tight
controls around it where it requires input by three Post
Office employees, and the knowledge and consent of
a postmaster before we use that role.
We've also improved our reporting around privileged
access, so elevated or privileged access and the use of
that, and that is now reported and scrutinised monthly
through what's called the Information Security
Management Forum.
We have identified there's still additional
improvements we'd like to make to that reporting but it
is a significantly improved position to that which KPMG.
found when they looked at this in 2020.
I think you sought to review Fujitsu's management of
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privileged access and, indeed, to ensure there's
an ongoing audit of that?
(The witness nodded)
Have you found that Fujitsu have been cooperative in
that process?
So in terms of -- there has been number of audits we've
carried out, a number of audit activities. We did
commission an independent piece of work via Deloitte.
It was commissioned thorough our internal audit process
but, effectively, we had an external provider and
Fujitsu's cooperation with that particular audit didn't
go to the extent we would have liked. However, there is
an annual independent audit, particularly around the
controls around the Horizon system that's carried out by
Ernst & Young, EY, and Fujitsu fully cooperated with
that particular audit and we are currently reviewing
this year's output from that audit.
Forgive me, when was that audit concluded?
It was actually completed slightly late this year in
September this year.
In September but you found that cooperation in that
was --
Yes, there was full cooperation with that.
I'd like to move on, please, to another topic, which
you've mentioned already. This is ARQ or audit data in
177
directly.
Although you're not involved in the day-to-day
practicalities you have explained that, because you're
responsible for managing Post Office's contractual
relationship with Fujitsu, you have, on occasion, been
brought in to deal with these issues relating to ARQ
data; is that right?
That's correct, yes.
You explain that when a request is raised of Fujitsu,
Post Office is, in effect, exercising a contractual
right over which you have oversight, and that you've
been involved in managing discussions with Fujitsu, for
example, in relation to the reimbursement of the costs
associated with remediation requests; is that --
That's correct, yes.
So under the current processes, I think a great many
requests were made by the Remediation Unit; is that
right?
That's correct, yes.
In order to investigate historic shortfalls?
That's correct.
Do you know which other parts of the business are
currently involved in making requests for audit ARQ
data, Fujitsu and for what purpose?
I think the next sort of second biggest user is probably
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Horizon. You explain in your statement you're not
involved in the day-to-day practicalities, that is to
say the raising of requests and the processing of those
requests; is that right?
That's correct, yes.
You say that process is managed by the Network Crime and
Risk Support Team?
That is correct, yes.
Why does the responsibility for that process sit within
that team?
I think it's an historic thing, effectively. They've
been the conduit to access that process. That will
change over time but I think it's probably just
an historical piece at this stage.
Where do you think that process ought to sit -- you say
it's likely to change. Do you think it will better sit
elsewhere in the --
The process will change as we move away from the current
Horizon audit solution, to the inhouse Post Office
solution that we're building currently, where, actually,
the process will become much more self-service. So at
the moment it's very, very manual, you fill in a form,
it's transmitted, you get the data back. We're
currently building a solution whereby people who require
that audit data will be able to access it much more
178
the Branch Support Team who investigate discrepancies in
branch, and they probably consume the vast majority of
other requests. Some requests come directly from my
team, where we want to look at audit data as well but it
is largely Remediation Unit, and the Branch Support
Team.
Why would your own team be seeking audit data for
an investigation?
If a postmaster has flagged a problem with us, we will
look at all sources of data, and so we will look at
audit transaction data, we will look at data we've
extracted from a particular Horizon counter. We look at
number of sources to make sure there isn't a problem
with Horizon.
That would be, would it, to investigate a reported bug,
error or defect?
A bug, error or defect, effectively, yes.
When that data is extracted, whether by -- presumably if
it's extracted by your team, you would analyse that
data?
We would look at that data, yes.
If it's extracted by the Branch Support Team, they would
be responsible for analysing it?
That is correct, yes.
I'd like to ask you some very brief questions about
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changes which Fujitsu Services proposed to the ARQ
request form; do you recall that?
Yes, I do, yes.
So I think it was in mid-to-late May this year --
(The witness nodded)
- that Fujitsu submitted -- well, I think they
instructed that ARQ requests should henceforth be made
‘on a form which contained two new mandatory questions;
is that correct?
That is correct, yes.
Can we just bring a copy of that up, please. It's
FUJ00243223.
Thank you. So at the top, we see under the heading
"Mandatory", firstly the first question:
"Is this request related to either (i) the
investigation of or (ii) action being taken or intended
to be taken by the Post Office against a postmaster or
Post Office worker in connection with a potential fraud,
theft, breach of contract or any other potential
impropriety which is suspected to have occurred at
relevant Post Office branches?"
So seeking an answer yes or no to that.
Secondly:
"Will this information be used to support either
a postmaster or a Post Office worker to achieve
181
had been raised for that reason?
Well, I think the second leg of the question actually
talks about action being taken or intended to be taken
by the Post Office against a postmaster: Post Office
doesn't take action against postmasters. So it doesn't
really stand even as a question and then it goes on to
talk about any other Post Office worker with a potential
fraud, breach of contract. It felt very broadly worded,
and not actually relevant to the way Post Office
operates today.
As you've said a short time ago, the Post Office is
designing its own audit store for Horizon, enabling
storage of audit data for all branch transactions within
the Post Office, is that correct --
That is correct, yes.
-- and that the process of retrieving data from that
would henceforth be carried out by the Post Office.
That's the intention, is it?
That's the intention, yes.
Presumably Post Office will continue to use ARQ data
‘once it’s brought inhouse for investigations into the
cause of discrepancies, is that --
Absolutely, yes. ARQ, effectively, is the process to
retrieve audit data. So, yes, we will continue to use
audit data in support of a number of activities.
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financial redress, including under the combination
schemes such as the Horizon Shortfall Scheme established
or administered by either the UK Government or the Post
Office, for action ... taken against them by the Post
Office?"
Again, a yes or no answer.
Now, this came to you to deal with; is that right?
It was escalated to me to have a discussion with
Fujitsu, yes, as you say, Fujitsu effectively
unilaterally imposed these questions upon Post Office.
Why was there objection on the part of Post Office to
answering what, on the face of it, appeared some quite
straightforward questions as to the purpose to which the
information would be put?
I think we felt particularly the first question was
very, very broad; the second question, Fujitsu were well
aware of why we were requesting lots and lots of data
around redress. So, overall, we didn't feel the
mandatory changes were necessary.
In relation to the first question, you say that you were
concerned it was unduly broad. On the face of it, it
seems to be quite narrowly focused to investigations or
actions to be taken in relation to specific -- suspected
criminal activity. Would it -- why would it be
difficult for Post Office to confirm whether the request
182
What steps do you intent to take to ensure the accuracy
of that data is maintained for its use in investigations
and for related prosecutions, if that be the case?
So the solution with designing it, it's designed with
a similar level of rigour around an audit solution for
similar systems to Horizon. So, although it uses more
modern technology to the current, very physical storage,
it will maintain the same levels of integrity,
effectively, in the ability to audit how that data was
retrieved and found.
Thank you. Sorry, that can be brought down, thank you
very much.
There's one final topic I'd like to raise with you,
Mr Oldnall, relating to the New Branch IT programme.
Now, that's not a programme over which you have direct
management responsibility; is that right?
That's true. Yes, that's correct.
But is it right that it's one of the programmes you
sponsor under your -- you said that you have
responsibility for sponsoring number of change
programmes.
I have number of change programmes. New Branch IT
specifically refers to the replacement of the Horizon
counter software. Within my remit, I have things like
the new portable counter device and the new self-service
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device but not the replacement of the Horizon counter
device -- of the Horizon counter software, as such.
That's not to say that you don't have any awareness or
understanding of the issues that have been encountered
by the programme; is that right?
That's true. Yes, that's correct.
So you say in your statement that it was initially
proposed that the New Branch IT programme would be
deployed in a manner that would enable Post Office to
exit its contract with Fujitsu by March 2025.
That's correct.
Is that correct? But due to delays in the development
and rollout of the system, the deployment is now not due
to start until June 2026. Firstly, is it your
understanding that the system is currently still on
track to be deployed in June 2026?
I believe we're currently at a stage where we're
reviewing the current plan for the replacement of
Horizon and I think as others’ evidence have given that
that review is live right now, to work out what that
plan might look like.
What do you understand to have been the reasons for the
delay, the historic delays, in the programme, which
caused the original timetable to be relapsed?
So I've obviously seen a number of documents that have
185
From the documentation, I think, that's been shared with
me, I've seen some of those, yes.
Sorry, when you say that's been shared with you, do you
mean by the Inquiry?
By the Inquiry, yes, sorry.
But, absent that, it wasn't something of which you were
aware in your role as --
I was broadly aware of some concerns that had been
raised, particularly around the level of defect in the
new system, but not very specifically.
What can you tell us about --
I was broadly aware that there were concerns around the
volume and the levels of defects that were present in
the system and particularly the -- I'm going to
characterise it as the enthusiasm to get the new system
out there, potentially. Some of those defects were not
being controlled and managed in the way that I would
particularly have liked.
Did that cause a personal concern to you, to learn that
there was pressure to roll out a system with outstanding
bugs and defects?
Ata personal level, yes. We've spent quite a large
amount of time over the last four years trying to build
confidence and making sure that Horizon doesn't have
a volume of defects in it. So yes, rolling out a system
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been shared with me. I think there's been number of
issues around probably technical complexity, wanting to
ensure that the product itself is fit for purpose, and
so going through quite extended levels of testing and,
ultimately, I think building up an understanding of
a system that is quite diverse in its product nature,
has taken much longer than potentially Post Office
originally anticipated.
Q. To your knowledge, has the provision of sufficient
funding been an issue in achieving a design and
a solution that is fit for purpose?
A. I'm aware of some of the funding discussions and have
been involved in some of the funding discussions.
I think, as others have talked about, the iterative
nature of funding a programme of that scale probably
hasn't been particularly helpful but I also am aware
that the initial estimates for how much it would cost
replace Horizon have greatly increased, yes.
Q. Now, we know from other witnesses that concerns have
been raised internally within the Post Office and
particularly through the Post Office's internal Speak-Up
process.
A. (The witness nodded)
Q. Are you aware of the nature of those concerns that have
been raised?
186
that has a higher level of defects, it would definitely
cause me concern, yes.
Q. Now, obviously, that was a concer reported to you. Did
you have any knowledge as to whether there was any merit
or that there was any substance to that complaint?
A. Not directly, no.
Q. From where in the organisation did you understand the
pressure to be coming to get the system rolled out, even
if it had outstanding defects?
A. I couldn't specifically say from where in the
organisation. I know, obviously, there's -- as you've
highlighted, the ambition was to have this rolled out by
initially 2024 and then 2025.
Q. Are you personally concerned that the Post Office might
be repeating the mistakes of the past in its handling of
this particular programme?
A. Ata personal level, yes, I would be concerned if we
didn't face into those defects. I think the opportunity
that is being taken now is to take a step back and
ensure that the NBIT programme does deliver to the kind
of standard that our postmasters expect.
MS HODGE: Thank you very much, Mr Oldnall. I have no
further questions for you.
A. Thank you.
Questioned by MR STEIN
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MR STEIN: Mr Oldnall, a couple of questions. There's
rPOoOPrPSD
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a document which I'll ask to go on the screen. I just
want to ask you when you were first made aware of this
document, okay?
Yes.
So that's the question. FUJ00243199.
Thank you.
Sir, this is -- can I call it the "Fujitsu/Patterson
letter", 17 May this year.
Now, I think, Mr Oldnall, you should have had this
within the documents you had from the Inquiry.
Yes.
My question is not about when you got it through the
Inquiry: my question is when you got this document, if
you did, through your workplace?
Yes, I did. So Mr Walton alerted me this letter was
coming. I think I received a copy around about the
weekend it was issued, via Mr Brocklesby.
Right. Did this trigger a discussion internally about
where this letter should go to? In other words, should
it go to Legal, and if so, what their opinion of it was
and, in relation to police investigations, whether the
police should be kept informed of it and, indeed, other
parts of the system?
The discussion I was aware of internally was certainly
189
Have you got to the bottom of this letter yet?
Not me personally, no.
No. Has anyone?
I believe and I've seen, obviously, there's been
an exchange of letters in this same thread.
All right. Next question, slightly different. So can
I take the framing of a Post Office branch that's
experiencing shortfall, and I'm going to deliberately
use the figure of £115. I will come to the reason why
I'm using £115 in a moment, all right?
So I'm a subpostmaster at a branch and I can see on
my Horizon system that there is a shortfall of 115.
Okay?
Mm-hm.
All right. Now, we know that the R&D button will
trigger certain events within the Post Office system.
That there will be, putting it shortly,
an investigation, yes?
Yes.
Yes, okay. We also know that, if I'm the subpostmaster
and I call up the Helpline and say, "Look, I've got this
figure, I don’t understand it. What's going on? It's
a shortfall, £115", then as well, that should also
trigger some type of investigation, yes?
Yes, correct.
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led by Legal. I think the discussion I was involved in
was more around what would be Post Office's response to
the content of the letter.
Right. Did you have any dealings directly with
Mr Patterson or a subordinate of Mr Patterson's about
the content of this letter --
Not directly --
-- considering your Fujitsu relationship?
Correct. Not directly, no.
Does that mean one of your team did?
No. So my interaction with this letter sort of started
and ended with Mr Walton telling me the letter was
coming, and that was it.
Okay. The letter itself is from Fujitsu, obviously who
runs the system, and it's saying, you know, "Don't rely
upon our system". That seems to have quite an effect
upon the sorts of projects that you're engaged in?
It does. I think I've used the word "confusing",
a couple of times in my evidence so far today. I found
that particular letter quite confusing because, on one
hand, you're right, it says "Don't rely on our system",
which is an interesting position for a supplier and not
‘one I've experienced in my career; but, equally, says,
"Please use our data to sought redress". So it is
somewhat confusing.
190
Right. What if I pay off the shortfall without
notifying the Post Office, either via the R&D button or
the Helpline? Is there a way that the systems that you
are aware of can identify that I in my branch, with that
shortfall, have essentially identified the shortfall and
then paid it off, without notifying you through the two.
ways I've just identified?
So the system would identify -- if this is being done at
the trading period --
Yes.
-- so somebody has settled to cash, effectively, or
settled by cheque.
Yes, which is why I'm using the figure of 115. You'll
probably be able to explain why in a moment.
I assumed why. Then, yes, we would be able to identify
that that settled to cash had happened. What we would
not be able to identify is why. So we wouldn't be able
to understand that the postmaster went, "Actually, £115,
I remember that. I did that wrong", as opposed to "I've
no reason why that's happened".
So for us to get into the £115, we would need the
postmaster to press the R&D button.
Right. So the sheer fact that a subpostmaster
identifies 115 as being the shortfall and then pays it
off using cash, which is the reason for using 115 as my
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example, doesn't, in fact, of itself, trigger a Post
Office investigation?
Not an investigation as such, no. I think you'll
probably hear from Melanie Park tomorrow, where they
talk about they do look for patterns --
Yes.
-- and they do look to go, "Okay, that branch is
regularly doing that, let's go and talk to them and see
whether they need any additional help and support’.
The reason why I've used the figure 115 is?
I knew you were going to ask me that, Mr Stein.
Apologies, I can't remember.
Well, it's because what the system does also is it
accounts for cash in terms of the notes that's used.
used 115, so that we've got 20s, 10, 5 --
You've got a mixture of notes.
-- and that, therefore, there's a way of actually
understanding that the system has had that cash input if
you wanted to do it.
You jogged my memory, Mr Stein. Thank you. Yes.
MR STEIN: No further questions. Thank you, Mr Oldnall.
THE WITNESS: Thank you.
MS HODGE: Sir, I think that's all the questions we have
from Core Participants.
‘SIR WYN WILLIAMS: Right.
193
INDEX
MICHAEL THOMAS YOUNG (sworn)...
Questioned by MS HODGE ..
Questioned by MR STEIN . 99
Questioned by MS PAGE ... 109
Questioned by MS PATRICK ... 131
SIMON GEOFFREY OLDNALL (sworn) ... 149
Questioned by MS HODGE ... 149
Questioned by MR STEIN .. 188
195
Well, thank you very much, Mr Oldnall, for producing
four witness statements, one of which is extremely
detailed and two of which are quite detailed. I am very
grateful to you for doing that work and I expect you're
quite glad that your time in the witness box was
comparatively short. But, anyway, thank you very much.
THE WITNESS: § Thank you, sir.
SIR WYN WILLIAMS: = Right. We'll resume again at 10.00
tomorrow morning.
MS HODGE: Yes, sir. Thank you.
(4.12 pm)
(The hearing adjourned until 10.00 am the following day)
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MR STEIN: [10]
98/18 98/25 99/4
106/23 107/7 107/14
108/1 108/21 189/1
193/21
MS HODGE: [31] 1/3
1/5 118 57/10 57/15
57/20 57/23 67/25
73/8 73/12 73/15 98/4
108/7 108/13 109/13
109/17 109/19 109/21
148/18 149/6 149/8
149/11 149/15 149/18
149/23 150/1 153/12
153/18 188/22 193/23}
194/10
MS PAGE: [6] 98/17
109/2 109/23 122/20
122/22 131/17
MS PATRICK: [5]
98/15 108/23 146/12
146/15 148/15
MS PRICE: [1]
131/20
SIR WYN WILLIAMS:
[43] 1/4 1/7 57/13
57/16 57/22 66/12
66/23 67/5 67/12
67/18 67/24 73/5
73/11 73/14 98/13
98/19 106/21 106/24
107/6 107/13 108/3
108/8 108/18 109/1
109/6 109/18 109/20
122/19 122/21 131/18
146/9 146/14 148/17
148/20 149/5 149/7
149/10 149/16 149/20}
153/13 153/16 193/25I
194/8
THE WITNESS: [3]
149/4 193/22 194/7
193/15
10 May [3] 33/24
39/10 41/4
10 years [2] 92/20
152/23
10-month [1] 155/16
10.00 [3] 1/2 194/8
194/12
11 years [1] 2/4
11.30 [1] 57/17
11.45 [2] 57/15 57/19
410 [1] 118/24
1114 [1] 88/3
115 [11] 191/9
191/10 191/12 191/23)
192/13 192/18 192/21
192/24 192/25 193/10)
193/15
12,000/13,000 [1]
18/7
13 [1] 58/24
13,000 [1] 18/7
13.48 [1] 138/2
14 [1] 19/6
143 [2] 136/9 137/7
145 [1] 137/2
15 [3] 31/12 106/22
151/1
15 October 2024 [1]
1
16 [1] 31/13
17 May [1] 189/9
18 February [2]
58/19 102/12
18 July [1] 8/4
18 November [1]
123/9
18,104.75 [1] 8/9
19 [3] 112/11 133/9
164/24
1995 [1] 2/10
1998 [1] 2/10
2
‘At [1] 113/20
"no [1] 116/13
‘no’ [1] 41/22
‘open [1] 41/8
‘owning’ [1] 41/18
"sea [1] 41/4
“the [2] 116/14
116/14
‘timing [1] 144/19
‘we’ [1] 114/3
/
[Rod [1] 75/15
1
1.00 [1] 98/8
1.02 [1] 109/14
10 [3] 15/12 109/4
2 August [1] 164/20
2 February [1] 61/20
2 September [1]
151/21
2.00 [2] 109/12
109/16
20 [2] 40/1 42/24
20 July [1] 150/22
20 October [2] 138/2
139/4
20 pages [1] 150/25
20 years [1] 152/18
20,000 [1] 76/8
20/30 [4] 97/9
2006 [1] 3/18
2007 [4] 3/20
2008 [3] 3/25 15/4
88/16
2010 [22] 10/16 12/2
29/19 30/1 30/5 30/10
31/15 33/22 33/24
39/5 39/8 40/22 45/24
54/15 61/25 76/1
111/8 111/11 119/4
132/5 132/22 135/22
2011 [27] 7/12 9/16
58/3 58/19 62/23 70/8
71/11 71/14 73/17
83/25 90/9 91/25
101/9 101/16 102/1
102/12 111/14 123/6
123/9 126/3 135/25
137/2 138/2 140/18
140/22 142/2 148/7
2012 [8] 13/19 14/25
92/1 95/21 109/24
110/24 137/2 148/8
2015 [1] 17/21
2018/19 [1] 164/24
2020 [6] 150/15
153/14 153/15 157/3
157/19 176/24
2021 [1] 165/10
2022 [5] 150/22
153/2 153/14 153/14
162/22
2024 [7] 1/1 1/14
151/8 151/21 152/6
164/20 188/13
2025 [2] 185/10
188/13
2026 [2] 185/14
185/16
20s [1] 193/15
21 October [2] 119/4
144/7
22 [4] 113/17
25 minutes [1] 98/16
255 [1] 151/13
276 [1] 151/12
29 June [2] 39/5 39/8
3
3.01 [1] 149/12
3.14 [1] 149/14
3.51 [1] 139/6
30 [2] 15/13 97/9
30 April [1] 15/8
30/40 years [1] 97/14
300 [1] 49/11
300,000 [1] 116/12
35 [1] 118/24
36 [1] 88/4
4
4 March [4] 73/17
4 years [1] 23/5
4.12 [1] 194/11
4.45 [1] 109/9
40 years [1] 97/9
400 [1] 49/11
41 [2] 19/5 151/24
44 [2] 136/8 136/9
46 [4] 31/11
46 pages [1] 151/24
48 [1] 1641/1
5
5.39 [1] 141/7
50 million [2] 35/7
36/20
52 [4] 80/10
53,000 [1] 8/6
54[1] 80/10
58 [4] 1/17
6
62 [13] 29/24 63/9
66/25 67/2 67/3 67/8
69/23 71/16 74/11
76/6 101/19 106/9
158/25
63 pages [1] 1/16
7
7.58 [1] 102/12
76 [3] 112/12 112/16
112/18
8
8 August [1] 1/14
87 [1] 113/17
88 [4] 113/17
9
9 October [1] 152/6
92 [1] 54/6
A
ability [3] 40/13
119/22 184/9
able [13] 36/14 36/18
43/19 50/4 61/12 94/6)
132/23 163/14 178/25
192/14 192/15 192/17
192/17
about [149] 1/25 5/5
7/5 10/5 11/8 11/8
11/21 15/10 16/21
18/2 19/12 19/18
19/21 19/21 19/25
20/2 20/6 20/15 20/16
20/19 20/24 21/11
21/19 22/1 22/23
23/10 27/18 28/7
28/21 30/18 31/7
31/11 37/1 38/19 40/2
45/25 46/6 46/13 49/5}
51/14 51/24 53/2
54/23 59/2 61/7 62/13
64/7 66/25 68/15
69/17 70/18 70/25
72/14 73/9 73/19 76/8
79/1 79/4 79/10 82/25
83/11 84/1 84/5 84/6
84/10 86/19 86/20
86/22 88/20 90/13
92/8 94/3 94/18 94/24
95/21 95/24 97/7
97/20 99/15 99/19
99/24 100/12 100/20
101/16 102/23 103/25}
104/2 105/2 105/4
106/18 106/18 108/19)
109/9 111/7 112/7
114/4 117/1 117/17
118/14 119/11 119/16
121/7 121/14 123/11
124/3 124/8 125/4
127/6 127/15 127/25
128/4 128/21 129/19
129/20 130/13 130/14)
132/21 134/3 134/11
136/23 137/9 139/22
140/19 141/16 143/8
144/12 146/5 146/21
146/25 147/5 147/6
147/11 147/23 153/17
154/20 159/15 161/5
161/15 166/13 180/25)
183/3 183/7 186/14
187/11 189/13 189/17)
189/19 190/5 193/5
above [3] 127/14
137/7 167/14
abreast [1] 11/23
absence [1] 85/15
absent [1] 187/6
absolutely [5] 122/12
128/11 143/6 156/15
183/23
abuse [1] 125/12
accept [8] 69/2 71/4
71/6 71/12 103/2
106/20 140/21 160/1
access [42] 38/8
80/10 80/16 81/6
81/10 82/7 82/8 83/4
83/14 83/23 84/2 84/5
84/10 84/11 84/20
84/24 85/22 85/24
86/3 86/5 86/15 86/18}
86/24 87/4 87/22
90/19 91/2 121/8
124/2 125/3 156/7
156/11 163/8 163/10
176/1 176/7 176/9
176/17 176/17 177/1
178/12 178/25
access/privilege [1]
84/10
accessing [1] 82/19
according [1] 89/23
account [3] 37/9
37/12 171/7
accountability [1]
144/24
accountancy [1]
23/10
accountant [2]
113/22 115/15
accounting [22] 5/8
(50) MR STEIN: - accounting
A
accounting... [21]
20/6 22/25 23/3 23/22
48/10 48/14 51/1
52/15 56/4 62/9 71/21
74/1 75/15 75/18
76/17 77/5 90/10
163/5 163/8 163/10
164/3
accounts [7] 63/15
64/19 71/16 80/21
86/22 128/5 193/14
accuracy [1] 184/1
accurate [7] 5/19
72/16 122/12 122/16
123/1 123/2 127/2
achieve [1] 181/25
achieving [1] 186/10
across [12] 4/19 6/2
12/1 16/25 17/23
18/10 23/5 72/8 97/16)
113/14 113/15 169/15
act [2] 37/23 131/21
acted [1] 167/4
acting [2] 4/24
129/14
action [19] 9/11
63/12 75/13 75/16
78/24 80/23 115/14
120/7 130/19 145/1
164/25 169/11 169/21
170/17 170/18 181/16)
182/4 183/3 183/5
actioned [1] 170/15
actions [7] 81/17
120/6 120/18 150/14
169/8 169/19 182/23
actively [1] 133/16
activities [6] 124/23
154/6 165/22 168/21
1477/7 183/25
activity [6] 112/24
120/23 157/15 165/1
169/17 182/24
acts [1] 124/19
actual [2] 61/13
112/24
actually [21] 44/20
55/21 110/23 111/11
112/20 113/13 115/10}
118/12 120/9 120/13
121/6 122/20 146/20
160/4 170/15 177/19
178/20 183/2 183/9
192/18 193/17
add [1] 120/6
adding [1] 57/3
addition [2] 38/6 72/5)
additional [6] 47/16
50/13 85/16 173/25
176/21 193/9
Additionally [2]
38/10 41/16
address [7] 31/9
32/14 33/8 94/2 154/6'
155/13 175/24
addressed [9] 7/22
19/1 19/4 73/17 86/14
125/5 150/5 162/24
171/4
addressees [2]
130/12 139/9
addresses [1] 47/11
addressing [1] 163/7
adequate [1] 80/3
adjourned [1] 194/12
Adjournment [1]
109/15
administered [1]
182/3
adopting [1] 168/2
advice [8] 41/8
117/15 136/25 138/21
140/1 141/14 141/15
144/12
advised [1] 116/9
Advisor [1] 61/16
affect [1] 106/9
affected [9] 29/24
63/9 63/11 68/22
74/11 79/22 79/23
94/11 99/6
affecting [3] 35/1
67/8 68/22
affirmative [1]
104/23
afraid [1] 98/17
Africa [1] 3/2
after [28] 2/6 3/12
3/19 27/20 54/19
66/15 67/15 68/5
68/16 69/17 73/20
90/3 91/19 110/22
111/10 117/22 119/1
119/23 120/7 137/17
137/19 139/5 142/11
144/15 147/12 155/4
156/4 174/1
aftermath [2] 115/11
155/1
aftermaths [1] 90/12
afternoon [4] 108/10
109/17 127/20 141/7
afternoon's [1] 108/6
afterwards [1] 156/2
again [30] 25/24
30/15 32/7 37/22
41/18 42/24 49/21
66/22 68/9 83/6 84/13
85/4 86/6 95/10 99/24
109/12 114/8 117/20
121/13 127/17 132/1
132/10 134/22 135/24)
137/11 146/17 149/15)
174/16 182/6 194/8
against [20] 43/14
52/16 52/18 87/16
91/17 101/11 102/2
103/1 103/12 115/6
130/17 137/3 145/1
160/3 169/19 169/20
181/17 182/4 183/4
183/5
agenda [2] 89/24
89/25
ago [4] 27/2 39/10
144/17 183/11
agree [12] 44/4 59/3
62/16 67/12 67/16
69/6 74/19 74/20 77/1
113/9 114/14 134/25
agreed [13] 36/11
36/25 44/4 73/22 74/3
75/9 95/3 103/4
112/23 116/8 144/18
169/12 172/9
agreeing [2] 41/15
45/16
agreement [3] 14/15
14/22 83/4
agrees [3] 164/11
165/3 168/4
air [1] 147/16
aired [3] 18/9 29/21
65/10
Alan [12] 3/25 6/12
6/23 7/3 12/6 12/6
36/4 36/7 88/8 89/4
89/22 121/17
albeit [3] 76/22 94/13
140/20
Alderley [1] 48/1
Alderley Edge [1]
48/1
alert [1] 38/9
alerted [2] 59/19
189/16
alerting [4] 62/3 65/3
75/1 175/19
algorithmic [1] 65/4
algorithms [2] 43/14
126/12
alien [1] 75/23
aligned [4] 25/9
72/15 75/21 75/22
aligning [1] 92/15
all [76] 4/18 4/18 6/2
8/7 11/6 11/9 12/9
12/17 14/11 15/25
16/1 16/12 20/8 21/12)
23/13 27/12 40/17
42/14 44/11 55/19
56/9 57/13 65/20
67/24 72/15 72/17
76/10 84/20 86/2 94/1
96/13 99/5 100/20
105/6 105/10 106/8
106/15 106/17 107/7
107/13 109/8 110/4
110/14 112/25 114/16
116/16 120/17 120/23}
123/18 124/16 127/2
127/3 127/22 128/6
128/7 128/9 128/12
128/23 133/13 134/8
135/18 139/15 140/14
147/3 148/20 149/10
160/25 169/13 171/18}
172/10 180/10 183/13}
191/6 191/10 191/15
193/23
all-encompassing [1]
4/18
allegation [1] 8/5
allegations [1] 19/22
alleged [1] 5/7
allow [2] 34/20
106/16
allowed [3] 44/12
76/7 111/3
allowing [1] 77/12
allude [2] 42/25
134/18
alluded [2] 40/6
115/4
alludes [1] 97/5
alluding [3] 77/14
79/15 93/21
almost [4] 31/3 82/11
119/21 124/20
along [4] 25/11 41/12
42/5 105/24
alongside [1] 11/18
already [17] 17/11
17/12 17/13 17/14
17/20 21/20 34/24
37/5 40/6 70/18
115/22 137/9 144/18
153/1 168/20 175/16
177/25
also [40] 17/10 22/24
26/19 27/4 36/20 38/3
52/21 55/14 56/15
58/12 69/13 75/11
78/24 84/23 87/1 91/9)
104/10 106/1 113/2
127/23 129/7 129/11
130/19 134/3 134/9
138/14 139/9 141/10
146/21 153/10 154/8
156/17 157/10 162/25}
175/18 176/16 186/16}
191/20 191/23 193/13
altered [1] 91/14
alternative [1] 70/7
although [5] 9/12
50/4 134/5 179/2
184/6
always [7] 48/6 49/16]
56/21 56/22 82/3
99/25 124/14
am [19] 1/2 15/20
39/22 40/11 41/2
57/17 57/19 74/9
82/25 89/16 106/4
108/7 117/19 135/19
145/19 173/4 186/16
194/3 194/12
ambit [1] 166/18
ambition [3] 37/8
37/8 188/12
ambitions [1] 37/24
amend [1] 128/5
amendment [1]
120/22
amongst [2] 9/18
97/17
amount [2] 50/17
187/23
amounted [1] 76/8
analyse [2] 104/18
180/19
analysed [1] 54/9
analysing [2] 166/10
180/23
analysis [6] 56/8
166/16 166/20 166/21
167/15 168/8
analysts [1] 161/14
Andy [6] 74/2 74/23
75/13 75/17 75/20
75/21
Angela [2] 127/18
131/21
Angles [1] 133/12
angry [2] 42/8 119/20
Anita [1] 74/9
annual [2] 170/6
177/13
anomalies [7] 43/15
65/5 65/8 65/9 65/13
96/5 126/12
anomaly [3] 23/18
67/4 89/9
another [15] 14/3
14/4 20/7 44/24 45/2
57/25 72/7 73/9
106/25 131/11 138/19)
144/19 154/8 163/18
177/24
answer [37] 10/10
11/1 16/4 22/20 23/24}
25/14 33/17 49/2
56/20 61/17 66/13
66/21 71/22 76/2
77/18 79/17 87/22
96/2 102/4 105/1
105/7 105/9 106/6
106/7 112/17 112/17
114/17 114/17 117/13)
119/10 124/5 126/6
126/8 134/15 142/1
181/22 182/6
answered [2] 25/18
26/25
answering [1] 182/12
answers [3] 47/15
148/1 148/2
anteroom [1] 93/2
(51)
accounting... - anteroom
A
anticipated [1] 186/8
any [82] 3/6 3/6 8/9
8/16 9/11 10/20 15/25
16/14 16/15 17/5 17/7
17/24 18/3 18/4 22/1
22/2 25/10 25/15 27/6
29/1 32/5 32/6 42/9
48/4 53/20 56/9 63/5
65/8 72/17 76/19 78/3,
79/2 79/9 79/16 79/21
83/23 86/3 89/9 93/15
105/16 106/1 106/18
113/10 113/21 114/21
114/22 119/13 120/19}
120/21 124/11 126/12
134/3 134/4 134/6
134/13 135/11 136/20
136/23 136/24 137/4
145/18 148/15 161/20}
165/18 166/9 171/18
171/19 171/22 171/24}
173/5 173/9 173/25
174/22 175/1 181/19
183/7 185/3 188/4
188/4 188/5 190/4
193/9
anybody [2] 53/23
161/10
anyone [6] 52/3 56/5
69/11 106/2 113/12
191/3
anything [29] 9/20
9/22 11/23 37/14
43/12 43/13 43/13
49/5 49/7 55/2 55/19
56/11 56/12 68/14
71/3 72/18 77/24
78/12 81/15 85/18
88/10 89/8 89/22
89/23 108/13 124/3
124/24 126/8 165/25
anyway [2] 140/15
194/6
Apologies [3] 171/2
175/10 193/12
apologise [3] 25/18
122/23 148/25
apology [1] 148/21
apparent [3] 41/4
52/23 62/18
AppDynamics [2]
175/22 175/23
Appeal [1] 134/9
appear [3] 64/18
101/22 143/23
appeared [3] 94/10
103/22 182/12
appearing [1] 106/9
appears [3] 50/3
62/11 71/9
application [1]
161/22
applied [2] 76/5 96/8
apply [4] 85/16 92/24
94/15 96/6
applying [1] 37/21
appointed [4] 126/5
144/18 155/4 155/18
appreciate [2] 40/17
148/24
approach [14] 34/12
86/17 123/21 124/12
160/1 164/4 168/15
appropriate [2] 9/11
112/23
appropriately [1]
20/9
approval [1] 169/13
approved [4] 73/25
75/6 75/8 75/10
approximately [2]
155/4 162/9
APPSUP [1] 176/11
April [9] 10/16 14/25
109/24 111/14 151/8
153/6 153/7 165/10
170/24
April 2021 [1] 165/10
architecture [1] 22/9
are [105] 5/5 8/7 19/7
19/16 20/3 20/24 31/4
34/8 34/24 37/25 38/1
40/2 45/24 46/6 50/5
53/11 56/19 59/24
60/6 61/2 61/6 63/25
68/12 69/24 72/15
73/23 73/24 76/16
79/2 82/19 85/15
86/22 87/20 92/12
93/7 93/25 94/5 94/18)
94/18 95/18 96/5
97/11 97/20 98/6 98/7
98/10 98/14 100/25
102/17 102/22 103/22)
106/15 108/5 108/16
108/24 109/9 111/17
117/25 121/5 122/16
122/17 123/22 123/23)
123/25 124/13 127/9
130/16 130/17 130/25)
131/2 131/7 131/7
138/20 139/16 143/12,
144/12 144/15 145/7
145/10 145/10 145/18)
152/13 159/17 160/17)
160/18 160/25 161/14,
161/18 161/23 162/1
165/23 167/6 167/23
169/1 169/19 169/21
172/17 173/2 174/22
177/16 179/22 186/24}
188/14 192/4 194/3
area [3] 39/15 153/18
156/16
41/5 65/4 74/10 78/25
132/25 135/20 136/20)
areas [3] 4/19 34/19
175/24
aren't [2] 126/12
141/8
arena [1] 5/1
arenas [1] 81/2
118/14
arisen [2] 100/17
167/11
arising [1] 63/14
armed [1] 104/3
army [2] 2/4 2/6
around [61] 10/15
15/2 20/17 22/19
26/16 27/15 29/8
29/20 30/14 30/25
33/6 36/8 38/5 42/24
43/5 44/1 44/23 45/12
51/17 53/17 56/1
68/11 76/5 78/23
78/23 81/3 88/2 89/10)
91/1 91/11 94/20
98/15 104/25 110/4
111/13 117/22 122/2
129/25 132/20 134/22
156/10 158/14 160/21
161/23 168/16 168/19}
170/6 170/10 174/14
176/6 176/13 176/16
177/13 177/14 182/18}
184/5 186/2 187/9
187/12 189/17 190/2
ARQ [12] 154/21
166/6 166/8 166/16
174/15 177/25 179/6
179/23 181/1 181/7
183/20 183/23
arrange [1] 9/14
arrangements [1]
22/10
arrive [1] 17/16
arrived [2] 18/11
18/23
arriving [2] 6/5 16/20
article [3] 126/20
128/18 130/18
articles [2] 161/15
161/22
articulates [1] 77/25
as [295]
Asia [1] 3/2
ask [23] 1/16 26/20
31/10 44/20 55/16
73/5 78/18 90/7 94/6
98/13 108/18 130/9
132/6 146/12 151/12
159/15 164/4 171/19
175/11 180/25 189/2
189/3 193/11
asked [24] 6/22
12/12 20/24 20/24
21/2 27/18 36/10
41/16 45/11 60/10
argue [3] 24/13 42/23}
95/9 100/11 107/14
113/10 122/1 128/14
128/18 144/17 147/23}
166/13 169/25 170/14,
172/3 172/10
asking [12] 1/24
26/13 35/20 38/11
82/25 86/20 91/22
102/20 132/11 135/13
145/13 148/2
asks [1] 114/2
aspect [3] 5/10
157/18 163/3
aspects [6] 3/14 6/19
25/1 55/6 77/11
159/17
aspects' [1] 116/16
assess [1] 62/7
assessment [7] 9/13
138/4 142/3 143/1
143/10 146/6 147/1
assist [3] 61/16
164/7 170/8
assistance [2] 8/16
171/18
assistants [1] 80/23
associate [1] 71/24
associated [11] 8/5
32/6 50/21 85/1 87/12,
88/25 124/1 125/3
165/7 167/23 179/14
assume [2] 133/2
145/22
assumed [1] 192/15
assumption [2] 67/6
161/9
assumptions [1]
4117/1
assurance [10] 21/9
38/2 38/4 43/16 160/4)
161/21 165/16 165/21
166/9 167/1
assurances [5] 23/20)
23/23 25/15 27/3 27/6)
assured [5] 19/23
132/15 132/18 133/1
165/15
assurety [1] 32/21
at [275]
at page 10 [1] 15/12
attached [6] 9/2
58/21 59/8 63/17
73/23 73/24
attaches [1] 127/22
attendance [1] 88/16
attention [24] 9/17
16/9 18/13 29/16 30/9)
A7IN7 47/18 62/19
63/4 64/10 65/16 68/2,
69/3 70/11 71/11
71/14 71/18 73/2
75/25 77/7 77/20
78/17 83/25 140/6
attitude [2] 15/11
43/8
attribute [2] 51/9
58/3
attributed [1] 82/8
audible [2] 16/4
61/17
audit [55] 38/12
41/11 48/7 49/17 50/8
50/23 53/3 53/6 74/6
80/24 81/11 81/16
82/1 83/22 83/24 84/3I
85/1 86/4 86/7 86/7
86/8 86/23 90/20 91/4I
95/2 116/7 120/22
122/3 124/3 125/9
133/12 155/19 156/18}
166/17 177/2 177/7
177/9 177/11 177/13
177/16 177/17 177/18)
177/25 178/19 178/25}
179/23 180/4 180/7
180/11 183/12 183/13)
183/24 183/25 184/5
184/9
auditable [3] 82/12
91/11 129/1
audited [1] 86/3
audits [1] 177/6
August [6] 1/14 3/24
54/15 132/22 157/3
164/20
authority [4] 83/2
automated [2] 85/6
85/10
available [1] 163/22
avoid [1] 50/1
awaiting [1] 74/9
aware [61] 4/20 9/23
10/3 10/6 10/8 10/8
11/24 13/2 16/19
18/19 19/12 26/4
27/23 42/13 48/1
49/18 50/11 58/2
62/25 65/21 65/23
65/24 70/12 70/22
77/16 78/8 79/2 79/9
79/16 81/5 85/19
89/16 101/10 104/10
104/11 104/18 116/5
117/8 117/19 119/1
119/6 121/5 121/18
121/20 123/22 123/23)
136/11 139/16 146/1
169/16 169/17 182/17)
186/12 186/16 186/24)
187/7 187/8 187/12
189/3 189/25 192/4
awareness [2] 88/2
185/3
away [8] 43/23 45/6
45/21 52/10 85/12
106/14 163/19 178/18)
(52) anticipated - back
B
back-end [1] 85/9
backdoor [4] 82/7
128/20 128/21 128/24}
backdoors [1] 128/8
backdrop [5] 57/8
97/10 97/10 97/22
106/17
backed [1] 158/18
background [7] 1/25
63/5 97/19 104/3
104/16 112/8 164/22
backs [1] 11/16
backward [2] 86/20
87/3
backwards [1] 55/17
bad [2] 93/3 98/1
badly [2] 26/11 94/1
balance [3] 58/24
167/7 167/11
balanced [1] 56/6
balancing [3] 60/15
158/22 165/12
bandwagon [2]
117/22 118/1
bank [1] 47/7
bankrupt [1] 116/12
barely [1] 54/18
Bartlett [7] 165/20
171/8 172/2 172/12
173/17 174/10 174/13}
Bartlett's [1] 167/1
base [2] 35/8 41/12
based [7] 14/19
88/21 110/21 120/17
161/15 161/22 168/8
baseless [1] 117/3
basic [1] 82/24
basically [3] 25/6
35/21 135/16
basics [1] 85/21
basis [10] 11/5 11/17
24/15 24/19 25/10
53/16 123/3 130/7
157/25 172/3
Bates [1] 121/17
BBC [3] 138/15
143/19 145/14
BDO [1] 155/23
be [225]
bear [2] 36/16 109/10
bearing [6] 8/12
78/14 86/2 86/21
166/18 172/7
bears [7] 7/14 46/19
150/22 151/9 151/20
152/6 170/25
became [7] 22/8
27/23 58/2 62/25
85/19 119/14 121/5
because [67] 6/7
6/18 6/22 12/19 23/11
24/11 25/2 25/19
33/11 37/3 37/23
42/13 45/15 47/3
52/8 64/17 66/19 67/1
67/19 70/4 72/21
74/22 75/24 77/14
78/22 79/14 82/5
83/10 83/15 88/21
89/19 91/7 91/8 92/11
92/19 95/13 96/18
99/22 101/17 103/22
119/20 123/6 124/2
125/4 125/23 126/8
126/14 127/3 128/19
146/8 148/23 164/1
168/4 175/25 179/3
190/20 193/13
become [3] 9/7 13/5
178/21
becomes [1] 13/1
BED [1] 18/4
BEDs [2] 16/2 17/7
been [152] 6/7 6/23
8/8 8/9 8/13 9/6 14/4
17/11 17/20 18/16
18/24 18/24 23/11
25/3 26/9 28/25 30/19)
32/1 37/20 38/22
39/13 39/20 39/23
40/11 41/13 41/20
42/5 44/25 45/25
47/21 48/10 48/11
49/22 50/4 52/8 52/23
57/11 58/10 58/25
61/7 62/13 62/14
63/19 63/23 64/1 64/2
65/22 65/24 65/24
66/16 68/3 68/7 68/16
69/9 69/22 70/6 70/9
71/15 72/7 73/25
75/25 77/17 77/21
77/21 78/4 78/8 78/9
78/12 79/24 82/7 83/6)
83/7 83/7 86/24 87/4
89/3 89/14 89/18
90/23 93/3 93/16
94/11 96/17 97/1
97/24 99/5 99/10
100/11 101/22 102/23)
104/11 104/18 104/25)
105/13 118/2 123/17
124/10 125/21 126/4
128/14 130/20 132/5
132/11 132/12 133/1
133/17 135/8 139/16
140/1 140/19 140/20
144/18 147/6 147/24
148/8 148/11 148/12
148/23 155/8 155/11
155/13 155/16 156/6
157/6 157/9 163/14
164/5 165/2 165/24
50/20 51/14 52/3 52/7
105/15 110/19 117/12)
138/20 143/20 145/17,
176/1 177/4 177/6
178/12 179/5 179/12
183/1 185/4 185/22
186/1 186/1 186/10
186/25 187/1 187/3
187/8 191/4
before [31] 2/1 3/5
44/17 49/12 62/13
95/20 100/25 103/6
105/15 108/5 111/3
117/7 126/7 128/15
130/18 133/25 136/3
139/17 140/20 142/1
147/24 148/5 150/15
176/15
beg [1] 134/9
began [1] 91/18
begin [2] 1/24 150/21
beginning [2] 75/12
79/8
begins [2] 73/6
169/10
behalf [3] 7/21 13/11
98/18
behaviours [1]
168/25
behind [1] 98/1
being [65] 4/4 7/8
11/11 20/9 22/23 28/9
28/18 29/5 29/21
31/18 31/24 36/18
48/21 49/14 49/24
51/1 51/14 52/6 52/7
52/14 52/16 53/17
61/8 61/12 63/6 69/6
71/10 74/22 76/25
87/5 87/15 91/3 96/23
99/13 101/10 104/4
104/5 104/14 104/14
106/18 112/2 126/4
127/4 128/13 128/18
135/15 139/23 140/4
140/5 144/23 147/23
161/9 165/10 167/8
168/2 168/22 169/25
172/17 174/5 181/16
183/3 187/17 188/19
192/8 192/24
Belfast [1] 163/20
belief [6] 1/22 95/17
151/6 151/18 152/3
152/11
believe [17] 15/23
19/23 34/19 59/15
61/19 73/8 87/11
109/21 133/18 150/25
164/10 165/19 169/17]
170/15 176/10 185/17
191/4
believed [3] 86/2
170/10 171/13 172/18}
186/13 186/16 186/20
63/2 73/5 76/21 80/13
151/11 152/17 160/12
93/14 114/19
below [7] 9/7 9/13
121/4 167/7 167/25
173/1 173/21
bemused [1] 147/23
benefit [3] 40/19
125/9 128/2
Benjamin [1] 118/1
bent [1] 124/6
best [15] 1/21 12/21
13/10 23/25 34/8
34/20 51/11 55/25
97/18 125/11 149/9
151/5 151/17 152/3
152/10
better [10] 22/15
33/17 43/1 45/6 51/21
56/15 87/9 115/5
125/5 178/16
between [26] 2/10
6/14 7/12 22/24 26/9
29/20 37/10 42/18
46/23 51/3 78/11 88/7
89/4 92/14 95/12
95/22 111/19 111/20
112/21 116/18 147/6
148/7 154/17 173/10
175/4 176/8
beyond [4] 70/2
88/16 98/8 124/22
big [6] 14/8 22/13
24/5 36/18 45/5 96/17,
biggest [2] 37/6
179/25
BIS [3] 121/4 121/7
121/16
bit [20] 42/16 43/8
51/17 72/1 92/19
104/1 111/7 113/16
115/25 119/19 120/13}
124/19 126/23 126/24}
133/21 135/24 136/15]
141/4 145/13 147/23
bits [1] 94/9
blame [2] 21/1 130/5
blind [1] 147/4
blocks [1] 145/5
blue [4] 17/8 19/8
20/22 84/14
board [54] 4/22 9/21
9/21 9/21 11/25 13/21
33/4 36/3 36/4 36/6
36/10 39/1 39/1 39/18
42/12 43/7 44/18
44/19 45/18 50/25
51/13 68/17 68/20
69/21 72/11 79/19
79/20 79/25 80/1 86/7,
86/14 88/6 88/15
88/18 88/23 89/10
89/11 89/24 95/18
95/20 100/8 100/9
103/7 103/11 103/14
103/15 104/7 106/11
107/1 107/2 107/3
122/8 145/16 169/13
Boards [2] 70/16
105/23
Bogerd [1] 127/18
boils [1] 98/24
book [4] 34/12 35/20
38/7 43/18
book' [1] 41/9
boost [1] 56/10
boss [2] 6/12 146/20
both [32] 6/9 20/21
23/11 23/12 27/3 33/3I
34/16 36/2 36/18
38/13 40/12 51/3 51/4
70/16 74/15 74/24
78/7 89/22 95/23 97/2I
101/22 104/2 105/21
106/10 114/10 127/15)
142/7 142/8 157/13
162/25 165/3 174/15
bother [2] 122/24
122/25
bothered [1] 50/6
bottom [18] 7/17
7/19 31/12 33/24
58/18 60/21 61/15
118/1 129/16 130/11
133/10 137/21 137/24I
141/2 143/9 169/18
171/1 191/1
bought [2] 71/18
120/2
bound [1] 35/23
Bounds [4] 24/9
27/10 55/15 106/2
Bounds/whoever [1]
55/15
box [1] 194/5
branch [58] 16/25
17/8 20/22 20/25 21/4)
24/24 36/19 55/21
56/4 62/8 63/15 64/3
64/18 71/16 72/9 74/1
TAIT 74/8 75/3 75/14
75/17 76/17 76/23
77/5 79/22 80/21
81/21 82/17 96/9
97/16 97/25 100/2
120/24 128/5 152/13
153/5 153/11 153/19
154/17 157/8 160/24
161/1 162/18 163/5
163/8 163/10 180/1
180/2 180/5 180/22
183/13 184/14 184/22)
185/8 191/7 191/11
192/4 193/7
branch's [1] 120/19
branches [26] 15/15
15/18 17/23 18/7
21/19 29/24 63/9
63/11 63/13 63/19
63/21 66/25 67/2 67/3
(53) back-end - branches
B
branches... [12] 67/9
69/23 71/17 73/25
74/11 76/6 76/16
76/19 101/19 106/9
127/1 181/21
brand [4] 94/1 94/2
96/23 96/25
breach [2] 181/19
183/8
break [8] 57/11 57/18
98/12 98/21 108/3
111/3 149/6 149/13
breathed [1] 92/23
bridge [1] 135/4
brief [5] 16/23 17/16
87/25 89/15 180/25
briefed [2] 17/10
41/13
briefing [2] 73/10
121/12
briefings [1] 18/14
briefly [9] 10/13 11/6
13/18 20/1 54/5
150/16 154/3 159/15
175/3
briefs [1] 79/20
Brilliant [1] 118/6
bring [17] 13/14
14/23 15/12 31/13
36/15 69/2 70/10 77/5
77/20 78/16 80/11
88/4 112/9 128/2
130/20 133/8 181/11
bringing [6] 38/11
42/14 62/19 126/12
129/22 130/2
brings [1] 9/17
British [1] 2/3
broad [6] 11/19
11/19 22/19 161/2
182/16 182/21
broadband [1] 120/5
broadening [1] 153/9
broader [2] 86/25
171/16
broadly [4] 157/21
183/8 187/8 187/12
Brocklesby [1]
189/18
brought [24] 4/22
10/7 16/8 18/13 29/16
30/9 36/1 44/25 52/16
52/18 64/10 65/16
68/1 71/10 71/14 73/1
75/25 95/18 129/24
129/24 134/25 179/6
183/21 184/11
BT [2] 3/20 45/5
bug [53] 18/12 18/17
19/1 30/21 30/25
33/13 57/25 58/1 58/2
62/14 62/19 63/7 64/6
64/17 65/15 66/1 68/2
68/15 68/15 68/20
68/21 69/2 69/10
69/17 70/6 70/9 70/19
71/2 71/8 71/14 71/25
72/3 72/7 72/22 73/1
76/12 77/7 78/6 79/16
90/9 90/11 100/12
100/15 101/4 101/10
101/25 103/9 105/13
106/7 110/12 161/19
180/15 180/17
bugs [32] 16/2 16/13
16/16 21/13 22/3
27/23 28/8 29/9 29/11
29/13 30/2 31/11
31/18 31/20 32/10
32/14 32/16 32/21
33/8 35/18 56/25
64/23 65/9 65/23
70/13 70/13 72/6
104/12 107/25 159/18)
160/5 187/21
build [2] 24/18
187/23
building [3] 178/20
178/24 186/5
built [1] 157/24
bulletins [1] 162/18
bullish [1] 25/21
burden [1] 48/13
Burley [6] 46/21
46/23 47/9 50/3
115/23 116/3
Burley's [1] 116/4
business [7] 2/24
4/19 111/4 139/17
157/16 169/20 179/22)
but [197]
button [5] 63/11
158/16 191/15 192/2
192/22
buttoned [2] 84/21
87/9
buy [1] 96/11
cable [1] 81/9
cache [4] 60/12
60/14 60/16 60/17
call [34] 23/17 38/24
55/14 65/8 67/8 72/7
76/17 79/21 91/20
91/21 93/3 93/4 93/19)
93/24 95/4 95/12
100/12 110/23 119/17)
120/7 125/14 126/14
129/7 131/9 136/13
137/6 137/11 137/15
137/17 142/11 143/25)
147/25 189/8 191/21
called [8] 127/9
154/21 160/3 164/17
168/22 175/21 176/11
176/19
Callendar [3] 18/2
18/12 21/21
calling [1] 137/17
calls [10] 22/14 41/7
41/16 42/18 43/10
85/20 91/21 95/14
106/10 161/20
calmly [1] 94/24
came [14] 12/10
14/15 62/2 65/2 65/19
65/20 83/25 96/18
99/11 113/15 115/7
128/18 134/19 182/7
can [145] 1/3 5/4
7/18 8/16 9/12 15/21
16/6 30/11 31/23 32/8
35/22 39/5 39/7 40/19)
40/23 41/21 48/19
55/19 56/20 57/21
57/22 60/19 61/15
63/16 63/25 65/20
66/5 66/17 68/25
70/24 72/23 73/5 75/2
75/3 79/7 81/16 81/17,
90/11 90/20 91/25
95/8 97/13 98/10 99/9
99/10 100/12 102/5
102/6 102/11 102/24
105/3 105/9 106/21
108/15 108/18 109/4
109/17 109/18 112/7
115/21 117/8 117/24
118/14 120/23 121/6
123/8 126/14 126/23
127/5 127/23 129/18
131/24 133/13 133/14
133/25 134/1 136/7
137/20 137/21 137/23
137/24 138/1 138/2
138/4 138/17 138/23
139/1 139/3 139/4
139/6 139/8 139/12
140/25 141/3 141/3
141/5 141/6 141/7
141/16 141/17 143/4
143/7 143/13 143/18
144/4 144/5 144/6
144/7 144/9 144/14
145/7 145/22 146/12
147/5 149/8 149/15
149/16 149/23 150/20}
154/16 158/11 160/14)
161/10 161/10 161/18}
164/7 166/20 169/22
170/2 170/8 170/21
171/4 171/19 171/19
173/17 174/25 175/2
176/4 181/11 184/11
187/11 189/8 191/6
191/11 192/4
can1[1] 189/8
can't [28] 12/15
24/12 31/7 43/20
43/21 49/13 53/14
54/2 55/19 55/25 59/3)
61/10 61/11 61/14
65/22 67/3 68/21
69/19 69/20 81/13
89/6 91/17 93/5 96/3
111/23 117/14 147/15)
193/12
Cancel [1] 60/11
cancelled [1] 163/23
candid [4] 37/23
49/14 87/15 92/17
candidly [10] 14/20
21/7 24/2 25/2 43/1
50/1 55/4 84/20 89/9
91/8
cannot [3] 88/22
91/13 120/18
canvas [1] 98/9
capabilities [1] 157/4
capability [2] 157/7
175/18
capable [3] 18/17
64/17 65/13
capacity [2] 128/5
175/19
capturing [1] 159/18
care [2] 126/25 169/5
career [4] 6/19 7/1
14/2 190/23
careful [1] 128/21
carelessness [1]
167/12
carried [7] 5/25 86/5
101/22 171/23 177/7
177/14 183/17
carry [4] 40/22 104/8
112/23 166/21
carrying [1] 95/17
case [40] 8/5 8/11
9/8 9/10 18/11 27/8
37/12 44/15 50/7 50/7
50/7 67/17 67/20
68/18 70/19 79/23
82/4 84/23 89/5 93/11
93/11 105/14 107/5
114/24 115/2 115/5
115/6 115/21 116/6
116/11 119/1 122/1
122/3 125/21 129/3
143/6 145/1 172/13
174/6 184/3
cases [10] 10/5
47/25 54/12 88/12
97/9 104/13 104/14
104/20 114/22 116/5
cash [8] 4/25 11/12
11/14 192/11 192/16
192/25 193/14 193/18}
Castleton [4] 48/1
116/6 116/7 116/23
Castleton's [1]
116/22
catch [4] 44/23 70/23
71/2 84/19
catch-up [4] 44/23
70/23 71/2 84/19
categorically [3]
65/21 91/14 115/21
caught [2] 21/2 21/3
cause [23] 28/18
29/3 30/2 30/6 30/8
40/6 59/21 66/25
90/10 131/1 134/13
135/11 165/15 166/11
166/25 167/5 167/8
167/9 167/15 168/9
183/22 187/19 188/2
caused [20] 17/9
28/3 29/1 31/20 33/14
48/11 50/5 63/14
69/24 71/16 72/8
72/10 72/11 72/20
87/13 97/1 110/5
110/6 148/25 185/24
causing [6] 18/18
21/18 23/19 31/16
48/14 64/17
ceased [1] 164/25
cent [1] 42/24
centre [3] 26/12 75/1
81/8
centres [1] 163/20
CEO [4] 6/12 25/2
30/14 119/24
certain [4] 6/19 85/12
101/18 191/16
certainly [24] 9/22
14/16 18/21 24/3
25/21 29/7 32/25 36/2I
37/7 42/12 65/22
67/14 70/22 79/7 87/9
89/23 90/16 96/4
100/2 124/25 134/20
147/19 166/20 189/25}
cetera [6] 26/15
26/15 43/16 43/17
43/17 119/5
CFO [1] 74/18
chain [18] 7/12 7/16
8/23 11/23 47/12
60/19 68/25 73/4
111/8 115/22 115/23
115/24 120/12 128/9
143/25 170/21 170/24!
172/1
Chair [1] 88/7
Chairman [1] 8/13
Chairman's [1] 9/6
chairs [1] 89/12
challenge [1] 56/12
challenged [2] 75/4
110/15
challenges [1]
171/14
challenging [2] 39/2
146/2
change [35] 4/10
(64) branches... - change
Cc
change... [34] 10/23
11/7 11/8 11/10 13/9
19/15 26/11 58/5 62/9
62/15 68/14 73/18
81/22 82/11 84/7
84/18 124/23 126/6
131/11 131/12 140/10
143/25 144/14 152/20}
153/8 153/25 155/25
160/5 163/14 178/13
178/16 178/18 184/20
184/22
change' [1] 41/5
changed [6] 10/16
81/14 129/4 137/12
153/5 155/23
changes [10] 10/13
10/20 11/8 11/9 83/18
120/20 141/13 155/1
181/1 182/19
changing [3] 96/13
135/19 158/15
Channel [4] 46/7
47/15 119/2 132/11
Channel 4 [4] 46/7
47/15 119/2 132/11
channels [1] 162/17
characterise [2]
154/24 187/15
charge [3] 32/17
32/18 75/20
charged [1] 112/20
chasing [1] 132/5
check [5] 50/6 122/2
124/20 169/24 175/17)
checked [2] 50/8
159/4
checksum [3] 81/13
124/4 129/1
cheerio [1] 12/9
cheque [1] 192/12
Chesterfield [1] 56/4
Chief [15] 2/22 10/16
12/3 12/13 12/15
12/19 13/5 13/6 13/7
13/17 13/23 14/3
14/16 109/23 122/9
chip [1] 84/15
choose [1] 145/10
choosing [1] 145/7
chose [1] 12/20
chosen [2] 89/15
93/16
ClO [12] 11/4 24/5
24/20 24/22 32/18
36/12 37/18 43/3 44/7
46/25 47/1 155/11
circulated [2] 132/24
138/21
circulation [1] 140/6
circumstances [2]
13/19 119/11
City [6] 171/10
171/20 172/4 173/3
173/20 173/24
civil [3] 5/16 152/22
169/11
claim [6] 47/23 116/9
128/8 136/2 139/22
139/23
claims [2] 130/17
139/13
clamour [2] 101/12
102/2
clarification [2]
87/25 144/1
clarify [5] 5/4 16/6
31/10 46/21 132/4
clarity [1] 147/22
Class [1] 145/1
classed [1] 69/22
classic [1] 26/3
clean [1] 19/2
clear [39] 6/6 9/20
10/2 16/21 17/6 19/17)
21/19 21/21 23/11
24/1 24/7 24/10 25/23
27/14 33/11 36/21
37/19 41/24 43/11
43/11 45/17 53/11
56/3 67/25 72/2 82/21
83/11 83/22 84/22
84/23 88/20 113/23
114/21 129/20 134/3
153/17 155/17 163/24)
167/13
clear-cut [1] 113/23
clearance [2] 74/9
120/21
clearly [19] 10/6 13/2
18/11 18/20 24/17
54/3 61/11 77/18
77/21 77/21 91/12
95/19 97/4 97/11
102/4 105/11 105/14
106/5 121/20
Cleveleys [1] 48/1
client [3] 37/6 37/7
116/18
close [2] 41/15 56/22
closed [1] 63/10
closer [4] 24/17
75/14 75/17 75/24
cloth [1] 108/15
Co [1] 98/18
coach [1] 112/3
code [42] 15/21
17/14 18/5 18/8 21/17
23/17 23/18 24/8
24/10 24/12 25/16
26/22 31/2 31/3 38/5
38/20 40/8 43/15 44/1
44/3 45/11 45/14 46/1
54/20 54/24 56/1
56/20 65/12 82/9
82/10 82/16 90/11
96/4 96/6 99/23 100/2
126/10 148/9 160/1
160/7 160/10 175/17
coded [1] 31/1
coding [2] 21/18
23/21
coherence [1] 99/20
coincided [2] 92/4
157/21
coincidence [1] 67/8
collateral [1] 118/11
colleagues [8] 24/24
33/4 34/3 36/3 36/9
69/21 70/11 106/11
collectively [1] 36/15
collegiate [1] 43/8
comb [1] 22/17
combination [3]
114/4 137/14 182/1
come [29] 8/12 18/1
19/3 23/6 27/1 29/13
29/25 32/10 32/11
35/18 39/14 39/19
63/3 66/4 78/5 81/2
102/6 105/14 106/17
110/13 111/25 113/2
114/25 115/18 142/17
145/21 173/18 180/3
191/9
comes [4] 25/25 39/5
105/22 142/1
comfort [6] 54/22
54/25 56/3 56/17 57/7
134/6
comfortable [1]
127/16
coming [14] 7/9 9/22
24/18 49/23 49/24
67/20 94/11 117/15
126/14 126/15 143/21
188/8 189/17 190/13
command [1] 111/8
commence [1]
169/23
comment [5] 16/8
16/18 91/22 140/10
175/5
commenting [1] 53/6
comments [5] 8/10
15/10 111/3 129/6
140/11
Commercial [1]
61/16
commission [2]
170/16 177/8
commissioned [4]
134/4 142/3 156/18
177/19
commissioning [1]
113/21
commitment [1]
76/19
common [4] 34/9
156/22 164/24 165/7
commonplace [1]
116/25
comms [1] 144/20
communicate [1]
63/21
communicated [2]
79/5 79/11
communicating [1]
173/3
communication [12]
26/18 26/19 30/13
33/6 37/10 44/11
55/18 78/3 78/10
136/21 148/24 162/17)
communications [3]
33/3 120/8 173/4
companies [2] 95/23
152/19
company [6] 84/15
85/7 97/10 144/15
145/9 145/10
comparatively [1]
194/6
comparison [1]
29/22
competent [1] 86/11
complained [1] 20/19
complaining [3] 20/7
20/16 86/22
complaint [1] 188/5
complaints [4] 19/12
46/13 64/6 87/5
complete [3] 13/10
141/22 149/9
completed [1]
177/19
completeness [1]
127/23
complex [4] 40/17
165/16 166/9 167/1
complexity [1] 186/2
compliant [2] 168/15
168/23
complicated [1]
76/22
component [1] 51/24
comprised [1]
153/22
computer [17] 91/21
93/2 93/25 95/5
110/22 119/16 125/14}
126/3 127/1 129/8
136/13 136/16 137/6
137/12 142/11 147/13}
147/25
conceding [1] 50/3
concentrate [1]
109/9
concern [11] 34/23
35/4 53/22 96/25
134/14 135/11 168/17}
168/24 187/19 188/2
188/3
concerned [17] 3/13
27/3 28/7 28/21 45/25
75/24 77/3 87/1
125/14 125/17 128/25)
170/18 172/10 172/18)
182/21 188/14 188/17
concerning [6] 27/7
54/20 57/25 163/8
170/22 173/10
concerns [26] 8/5
36/1 36/2 36/2 37/1
38/19 41/5 53/24
54/23 56/10 64/4 84/1
84/5 86/19 92/8 100/6I
124/8 129/8 129/12
131/6 158/14 175/5
186/19 186/24 187/8
187/12
concise [1] 123/15
conclude [1] 83/5
concluded [2] 54/19
177/18
concludes [1] 148/18
conclusion [6] 14/24
20/20 40/11 44/15
56/25 116/15
conclusions [3]
12/17 39/15 53/16
condemned [1]
67/22
conduct [2] 10/5
170/24
conducted [1] 5/17
conducting [1] 79/12
conduit [1] 178/12
confidence [9] 34/21
40/12 56/7 65/7 65/10
65/14 132/20 133/19
187/24
confident [2] 33/7
63/25
confidential [5]
89/21 136/21 139/14
141/14 141/17
confirm [7] 108/18
109/4 147/15 169/22
169/25 171/5 182/25
confirmation [2] 8/19
138/8
confirmed [3] 8/15
40/10 54/8
confirming [1]
150/17
confirms [1] 123/19
confused [3] 66/13
173/15 174/17
confusing [5] 19/19
120/13 190/18 190/20}
190/25
confusion [1] 173/13
conglomerate [1]
97/2
conjunction [1]
158/15
connection [2] 19/9
(55) change... - connection
Cc
181/18
conscience [1]
124/20
conscious [9] 57/11
97/14 98/3 143/4
175/9
consent [3] 80/22
83/19 176/14
consequence [5]
29/6 33/5 36/7 72/12
112/3
consequences [1]
169/2
consequent [1]
53/18
consider [7] 29/10
38/10 41/19 77/19
85/23 87/2 157/12
considerable [1]
28/17
consideration [1]
86/4
considered [5] 28/22
77/4 86/1 104/14
133/16
considering [2]
115/13 190/8
considers [1] 173/5
consistent [5] 21/11
30/4 123/14 165/5
168/3
constantly [3] 26/12
29/4 43/15
constituent [1] 8/1
constituents [1] 9/4
constituted [2] 150/6
158/4
construct [1] 111/2
consultancy [2] 3/19
152/18
consume [1] 180/2
contact [3] 8/17
173/21 174/1
contained [1] 181/8
contemplation [1]
140/23
content [12] 1/21
10/8 123/24 124/9
126/24 147/6 151/5
151/17 152/2 152/10
190/3 190/6
context [6] 27/14
62/21 63/4 74/20
165/22 171/16
contexts [1] 174/15
continue [2] 183/20
183/24
continued [6] 3/11
75/22 94/14 111/11
111/13 121/16
connection... [1]
86/23 87/24 94/5 97/6
continues [1] 34/16
continuing [2] 27/19
30/16
continuous [1] 93/23
contract [26] 17/18
17/21 23/14 24/7
24/13 34/4 34/7 35/2
35/10 36/14 39/16
39/19 42/22 45/5
45/10 45/16 50/12
50/14 55/10 92/14
92/23 95/11 120/5
181/19 183/8 185/10
contractual [4] 22/10
46/2 179/4 179/10
contractualised [2]
17/12 45/15
contractually [3]
15/2 34/25 55/1
contradict [2] 66/14
108/19
contribute [2] 88/10
89/19
control [3] 84/7
99/23 120/19
controlled [1] 187/17
controls [7] 84/1
85/24 122/3 156/7
156/10 176/13 177/14)
convene [1] 160/21
conversation [33]
21/5 21/5 23/8 23/10
27/11 27/14 27/16
27/18 36/8 51/16 58/4
59/1 88/24 88/24 89/4
89/11 92/7 95/5 95/6
110/22 112/22 113/4
119/18 122/6 126/2
134/21 139/17 144/5
148/11 172/6 174/2
174/4 174113
conversations [14]
24/8 30/17 41/25
43/22 43/24 69/17
89/7 89/20 94/20
96/20 112/25 113/5
134/19 171/19
convey [2] 16/7
35/12
convicted [1] 131/22
conviction [2] 119/4
136/3
convictions [1]
131/23
Cook [10] 4/1 6/12
6/24 7/3 12/6 12/6
36/4 88/8 89/5 89/23
cooperate [2] 172/4
173/14
cooperated [1]
177/15
cooperation [6]
163/1 166/2 176/4
177/11 177/21 177/23}
cooperative [1]
177/4
8/13 8/24 9/23 78/4
78/12 116/4 117/24
119/3 127/10 128/1
130/13 138/17 141/8
142/7 142/13 171/8
174/9
copies [2] 141/10
173/18
copy [9] 1/13 8/3
116/7 141/16 149/21
150/18 150/23 181/11
189/17
core [8] 11/7 18/4
98/6 108/16 108/18
136/5 174/19 193/24
corporate [1] 150/4
corporates [1] 85/5
correct [110] 2/4 2/5
2/9 2/18 2/20 2/21
2/24 2/25 3/4 3/22 4/2
4/6 4/15 10/5 10/11
10/18 10/19 12/4
13/23 13/24 15/8 15/9
16/11 19/17 19/19
25/17 28/1 28/2 28/5
28/11 28/15 28/24
36/23 38/21 42/3
46/13 64/7 64/8 66/12
69/4 71/13 77/10
83/16 84/2 88/14
91/23 91/24 119/8
128/9 150/7 150/8
150/12 151/10 152/16
152/21 152/25 153/4
153/6 153/20 153/21
153/24 154/10 154/11
155/6 155/22 156/8
156/9 157/2 157/11
157/20 159/13 159/14]
159/19 159/20 160/9
160/13 162/7 162/14
162/22 162/23 163/2
163/6 163/15 163/16
166/4 167/17 168/6
168/10 170/20 172/20
175/12 175/13 175/23}
178/5 178/8 179/8
179/15 179/19 179/21
180/24 181/9 181/10
183/14 183/15 184/17I
185/6 185/11 185/12
190/9 191/25
correct’ [1] 116/14
correcting [1] 167/9
correction [1] 167/9
correlate [1] 142/11
correspondence [6]
8/14 33/19 38/8 41/4
46/17 174/23
corresponding [1]
60/15
copied [19] 7/22 7/23
cost [7] 35/8 50/13
50/13 50/21 145/2
158/6 186/17
costs [3] 35/16 35/22
179/13
could [74] 1/8 1/16
7/11 7/15 7/16 8/15
11/24 15/11 15/17
19/5 31/13 32/13
32/14 32/21 32/22
33/12 41/8 45/13
47/22 53/20 55/1 55/3}
58/16 58/17 59/14
59/20 60/20 61/5 73/4,
80/11 80/20 80/23
88/4 90/10 92/24
93/19 97/18 98/23
102/21 104/12 110/18)
110/20 112/9 115/25
116/22 117/21 118/23
120/11 125/24 129/2
129/16 133/8 133/9
133/19 133/22 133/23
136/3 138/22 145/2
145/4 145/15 148/22
151/1 151/12 154/3
158/5 158/14 158/17
159/4 164/13 166/23
167/21 172/21 174/6
couldn't [5] 42/23
93/19 126/8 163/25
188/10
counsel [9] 36/12
37/18 67/13 67/20
88/9 89/1 89/4 89/14
108/25
counter [5] 180/12
184/24 184/25 185/1
185/2
countermeasures [1]
65/7
counterpart [1]
173/14
counters [1] 40/1
country [1] 11/14
couple [7] 47/19
73/19 104/15 144/21
156/4 189/1 190/19
course [9] 8/15 10/14
17/3 19/16 45/8 51/22}
82/2 164/5 170/12
court [7] 93/12 99/7
104/15 116/11 134/5
134/9 145/9
courteous [1] 93/4
courteously [1]
93/19
courtesy [1] 106/3
cover [3] 85/14
108/24 121/25
coverage [4] 138/16
140/21 143/19 145/14}
covered [6] 3/15 7/2
9/19 11/6 108/24
148/11
covers [1] 121/13
created [3] 157/15
159/23 159/25
credibility [2] 120/7
145/19
Crichton [11] 7/22
8/25 52/9 77/8 77/9
77/10 77/16 77/20
79/16 88/9 127/8
crime [4] 154/18
166/3 166/5 178/6
criminal [15] 5/5 5/11
5/17 5/24 6/2 6/16
7/14 10/4 19/10 53/25
79/13 118/10 134/8
170/24 182/24
criminality [2] 5/14
5/20
cross [1] 146/22
crucial [2] 40/19
172/17
crystal [1] 134/3
culminates [1] 34/11
current [19] 8/7 34/4
34/6 38/12 39/18
103/2 157/10 157/17
159/5 159/12 159/16
162/10 164/8 164/10
165/6 178/18 179/16
184/7 185/18
currently [10] 39/25
152/13 155/20 162/12)
177/16 178/20 178/24}
179/23 185/15 185/17
customers [1] 36/19
cut [3] 35/16 108/15
113/23
CviT [1] 11/12
cyber [2] 3/16 3/16
D
daily [1] 111/17
damage [2] 96/23
96/25
Dan [2] 171/6 171/12
Daniel [1] 171/4
data [74] 23/10 26/12
29/21 31/21 31/24
33/14 50/12 50/16
52/4 52/13 52/17
52/22 53/2 53/6 60/14
65/4 68/15 75/1 80/21
80/21 81/8 81/23
82/10 83/19 85/25
87/1 90/22 91/14
99/22 99/25 99/25
115/7 120/22 122/3
128/5 154/19 154/20
163/5 163/9 163/10
163/20 163/21 164/3
166/6 166/10 166/17
167/3 169/22 170/2
174/14 174/16 174/20)
(66) connection... - data
D
data... [22] 177/25
178/23 178/25 179/7
179/24 180/4 180/7
180/10 180/11 180/11
180/18 180/20 180/21
182/17 183/13 183/16
183/20 183/24 183/25
184/2 184/9 190/24
database [2] 30/3
31/18
datas [1] 124/4
datasets [2] 29/5
117/12
date [12] 15/2 19/2
31/7 39/8 90/7 91/25
92/7 138/20 139/4
150/20 164/19 164/19
dated [9] 1/14 8/3
33/24 58/19 73/16
119/3 150/21 151/8
151/21
dates [1] 170/24
Dave [10] 16/24
21/15 23/8 23/12
89/23 112/3 118/9
118/12 118/17 118/20
Davey [2] 121/17
121/23
David [21] 12/9 12/11
12/18 12/24 18/21
19/15 19/16 27/3
46/10 46/11 46/24
47/4 47/13 58/5 88/8
111/10 118/3 118/3
127/7 130/12 132/10
day [35] 11/5 11/5
41/17 11/17 15/20
24/20 24/21 24/21
24/21 25/10 25/10
49/11 60/24 61/19
65/12 65/12 82/13
93/3 97/13 97/14
123/18 125/25 125/25
129/3 138/21 139/4
144/7 145/18 172/3
172/3 178/2 178/2
179/2 179/2 194/12
days [8] 13/14 23/4
31/6 51/3 61/20 73/19)
73/19 92/12
deal [18] 2/1 17/4
17/22 21/14 24/15
32/21 35/18 36/19
40/18 43/4 43/20
80/10 109/3 150/20
157/9 157/16 179/6
182/7
dealing [15] 3/23
10/13 13/18 19/4
22/22 26/10 29/8 32/9
48/8 77/21 78/6 82/16)
123/12 157/18 161/18}
dealings [1] 190/4
deals [1] 133/12
dealt [8] 2/2 22/21
56/25 66/19 99/13
101/19 105/13 158/5
Dear [4] 8/2 34/1
39/12 139/15
debate [2] 12/18
127/16
debt [1] 116/10
debts [1] 101/20
December [2] 150/15
156/4
December 2020 [1]
150/15
decided [2] 13/25
116/13
decision [1] 75/6
declared [1] 116/12
deduction [1] 169/11
deeply [1] 91/7
defect [12] 67/6
67/10 160/19 160/20
160/21 161/11 161/12)
161/16 166/14 180/16)
180/17 187/9
defects [28] 16/3
16/13 21/13 22/3
27/23 28/8 31/20 67/8)
158/25 159/2 159/12
159/17 159/19 160/6
160/15 160/25 161/2
161/6 162/9 162/10
162/11 187/13 187/16)
187/21 187/25 188/1
188/9 188/18
defend [1] 117/12
deficiencies [1] 40/7
definitely [1] 188/1
degree [5] 17/19
53/20 57/3 89/13
111/16
delay [2] 62/18
185/23
delayed [1] 40/7
delays [4] 28/3 31/17
185/12 185/23
delete [1] 80/21
deleted [1] 140/13
deliberate [1] 117/14
deliberately [3] 86/10)
125/23 191/8
deliver [8] 35/10
35/11 38/1 40/13
49/13 87/16 163/14
188/20
delivered [2] 14/21
69/18
delivering [1] 92/23
delivery [7] 27/20
34/17 34/21 55/5
75/20 106/13 152/19
Deloitte [1] 177/8
demand [2] 26/21
110/18
demanded [1] 25/22
demonstrate [1] 75/2
demonstrated [1]
43/19
demotion [1] 14/1
den [1] 127/18
Department [1]
152/23
departure [1] 13/19
dependent [2]
163/18 163/22
deployed [2] 185/9
185/16
deploying [1] 85/5
deployment [1]
185/13
depository [1] 60/14
depots [1] 11/15
depressions [1]
63/12
depth [1] 20/15
describe [11] 4/3
34/12 58/13 61/12
81/17 154/3 154/8
154/16 158/11 160/23
175/14
described [11] 6/23
11/2 12/23 19/10
36/22 55/9 70/3 79/14
80/9 110/5 175/8
describing [1] 51/12
description [2] 61/11
65/11
deserve [1] 98/2
deserved [1] 24/3
design [1] 186/10
designed [3] 47/21
159/12 184/4
designing [2] 183/12
184/4
desk [10] 62/5 72/24
72/25 113/15 161/8
161/14 161/21 161/23
162/2 162/3
despite [4] 8/10
55/17 57/8 69/23
destruction [1] 140/2
detail [10] 29/25
51/24 57/9 65/22 74/2
76/18 133/5 133/13
158/12 162/20
detailed [3] 119/17
194/3 194/3
detect [1] 160/15
detected [7] 22/3
68/3 70/6 70/9 71/8
71/15 161/7
Detective [1] 2/7
determine [1] 160/22
determined [2] 54/11
125/15
determines [1]
161/11
devastating [1] 146/2!
develop [1] 4/4
developing [1]
175/18
development [3] 3/1
3/4 185/12
device [3] 184/25
185/1 185/2
dialogue [7] 14/14
17/10 17/24 27/9 45/8}
147/7 147/18
did [100] 3/9 4/16 5/6
5/23 6/6 6/13 10/11
11/21 17/7 19/4 20/11
21/7 22/1 22/5 22/18
23/5 24/24 27/17
28/24 33/14 35/3 42/9)
48/12 48/17 48/19
48/20 49/1 49/1 49/3
49/4 49/5 53/22 56/17)
56/17 63/3 65/15
68/20 75/9 77/15
77/19 78/15 80/20
84/4 85/23 86/3 86/12,
87/2 87/14 88/10
88/10 92/19 93/18
100/6 101/3 101/10
101/25 105/2 105/4
105/4 106/10 110/18
110/19 112/25 117/11
118/16 118/20 121/6
121/15 122/9 122/14
122/24 125/23 126/6
126/7 134/12 135/11
136/16 136/24 137/4
138/7 140/7 146/24
148/2 155/7 155/15
157/23 157/25 172/9
173/8 174/10 177/7
187/19 188/3 188/7
189/15 189/16 189/19
190/4 190/10 192/19
didn't [64] 10/20
10/23 11/1 12/8 12/12}
13/8 19/3 20/19 21/6
21/6 21/20 21/21 24/2
24/7 24/22 29/12
35/13 41/9 43/11 44/4)
47/4 47/5 49/7 50/1
50/22 50/23 52/2 52/3}
53/9 56/9 56/9 63/1
64/13 64/21 68/2 69/2)
70/5 70/18 71/24
85/18 88/23 89/6
90/23 93/15 104/8
107/3 107/21 110/17
113/12 118/19 120/1
121/21 121/25 122/14}
122/24 124/2 124/18
130/9 134/17 140/8
175/11 177/11 182/18}
188/18
died [1] 136/3
difference [5] 51/3
90/14 130/8 168/7
172/17
different [13] 14/13
20/14 30/5 31/17
32/12 33/12 46/10
67/6 115/9 115/24
124/14 130/7 191/6
differentiate [1]
176/8
difficult [4] 14/2
16/18 28/25 182/25
digital [4] 31/4 96/10
96/11 96/12
diligence [1] 82/23
diploma [3] 3/8 3/11
3/13
direct [17] 4/10 6/21
9/18 11/11 11/23
25/15 27/6 55/3 72/13
73/18 88/11 109/25
122/6 138/21 161/7
163/10 184/15
directed [3] 61/8
120/14 150/10
directly [8] 53/15
162/1 179/1 180/3
188/6 190/4 190/7
190/9
director [32] 3/24
3/25 4/4 4/9 10/17
11/4 12/11 12/15 13/1
13/6 13/7 13/20 14/5
14/17 16/23 17/18
24/5 24/20 24/22 25/2I
25/8 33/21 46/11
46/25 47/5 47/7 88/8
132/10 145/22 152/14)
153/3 153/5
Director/ClO [2] 24/5
24/20
disagreement [1]
81/15
disagrees [1] 167/14
disappointed [2]
41/3 145/13
Disappointingly [1]
130/22
disclosed [1] 134/5
disclosure [17] 10/6
25/12 26/20 29/18
49/21 69/15 70/1
72/18 77/25 78/2 86/6I
106/19 107/4 111/25
139/13 140/8 147/10
discontinue [2] 7/25
9/5
discontinuity [1]
79/21
discounts [1] 45/6
discovered [3] 29/14
66/19 68/7
discovery [8] 25/24
26/21 45/18 48/25
58/3 68/9 90/9 119/9
(67) data... - discovery
D
discrepancies [18]
23/1 23/3 23/22 48/4
48/10 48/15 50/5
59/23 59/24 60/6 62/5
71/16 86/22 90/10
158/17 165/11 180/1
183/22
discrepancy [10]
60/12 64/18 158/15
158/19 165/14 165/23
166/11 166/25 167/5
168/9
discuss [5] 36/13
65/15 141/24 144/16
162/20
discussed [6] 75/8
88/18 153/1 166/3
175/3 175/16
discussing [1] 173/6
discussion [8] 20/15
20/17 60/20 74/23
182/8 189/19 189/25
190/1
discussions [10]
36/21 40/4 88/2 88/6
88/11 115/20 173/9
179/12 186/12 186/13}
disgruntled [1] 130/4
dishonest [1] 117/2
dismissed [1] 48/3
dispirited [1] 94/13
disposed [1] 140/13
dispute [3] 108/2
114/11 158/9
disputing [2] 93/8
107/22
disseminate [1] 80/3
dissuade [1] 134/16
distinguished [2]
53/1 91/10
distress [1] 148/25
diverse [1] 186/6
Division [1] 33/21
do [146] 1/15 1/19
1/20 3/15 5/18 5/22
8/16 8/19 12/19 18/16
21/2 22/23 27/7 29/2
29/11 29/15 30/7
32/19 35/23 36/15
38/2 38/5 44/15 44/16
45/9 46/7 46/9 48/17
48/22 49/7 50/20
51/19 52/25 55/9
55/12 55/13 55/19
55/22 59/1 59/5 59/8
59/11 59/15 59/18
60/8 60/13 62/18
62/21 63/4 64/21 71/4
7116 71/12 73/5 73/7
73/8 73/8 75/16 78/25
79/1 82/5 85/3 87/24
88/13 88/16 90/7
91/13 94/8 94/22
97/18 97/21 103/2
105/4 106/20 107/8
108/5 111/22 113/20
121/5 121/13 124/25
128/18 130/10 135/2
138/14 140/4 140/21
142/17 144/14 145/11
145/11 149/8 150/17
150/19 150/23 150/24)
151/3 151/4 151/15
151/16 151/22 151/23)
151/24 152/1 157/12
158/8 160/14 161/13
161/20 164/10 166/9
166/16 166/22 168/5
169/25 170/4 170/7
170/14 170/16 174/22)
178/15 178/16 179/22)
181/2 181/3 184/1
185/22 187/3 193/5
193/7 193/19
document [27] 25/25
59/16 63/17 66/14
66/20 73/7 74/5 77/25
100/8 100/8 103/6
103/9 107/14 119/10
126/17 137/20 137/22)
138/19 139/25 140/1
140/2 140/25 164/14
164/18 189/2 189/4
189/14
documentation [1]
187/1
documented [1]
165/15
documents [16]
25/12 25/20 26/20
29/19 44/17 44/19
48/25 68/10 73/23
73/24 78/4 80/6 107/4
136/22 185/25 189/11
does [20] 21/10
26/13 41/22 47/23
52/25 59/3 61/16 75/5)
81/15 90/4 104/24
108/10 128/4 139/11
141/12 178/9 188/20
190/10 190/18 193/13)
doesn't [18] 69/11
97/23 106/13 106/15
110/5 119/11 139/10
139/17 141/11 143/11
143/15 143/21 145/18)
164/18 183/5 183/5
187/24 193/1
doing [18] 10/9 41/10
50/2 55/8 65/14 81/10)
81/10 83/2 83/3 87/14)
114/11 114/14 115/16)
117/10 117/16 118/13)
118/20 118/21 119/13)
125/25 128/13 128/14,
135/14 135/16 137/16)
87/21 95/10 124/24
134/6 135/3 143/11
193/8 194/4
don't [77] 23/4 23/7
24/11 26/24 37/5 39/4
42/17 43/25 44/9
44/16 45/22 48/23
49/4 49/7 50/20 60/4
60/9 61/10 62/20
65/17 66/12 68/14
69/19 72/16 72/17
73/8 76/2 77/22 78/18
81/23 84/19 90/20
96/19 98/2 99/16
99/25 103/15 105/15
105/16 106/18 108/2
108/13 108/16 109/5
111/21 111/21 113/10
115/4 121/9 124/11
127/3 128/14 133/6
133/13 136/7 139/1
140/7 144/23 145/6
145/24 146/15 147/11
147/25 148/2 148/15
155/17 160/1 160/5
166/12 166/20 168/5
170/15 174/24 185/3
190/15 190/21 191/22
done [27] 12/20
22/11 31/4 49/5 51/1
52/6 61/7 69/7 69/9
69/12 81/24 81/25
83/4 83/19 86/11 89/8
96/23 97/13 102/23
106/18 118/6 138/13
143/15 147/18 148/9
158/15 192/8
door [3] 94/15 120/2
135/15
doubt [6] 30/18
102/25 124/14 124/18
125/4 134/25
doubts [1] 134/7
down [59] 7/15 7/16
13/4 21/20 24/3 24/18
31/5 36/11 36/25
37/17 39/6 39/21
41/20 45/2 45/3 47/18
47/24 49/9 50/23
58/17 59/20 60/25
64/24 72/13 73/16
74/13 76/14 81/11
81/18 84/21 86/18
87/9 91/12 95/11
98/24 102/15 107/16
112/5 113/16 114/6
116/1 117/25 120/11
120/23 121/21 121/22
123/5 123/8 125/11
126/10 126/23 129/16
135/16 155/5 164/17
167/21 169/18 171/1
184/11
downplayed [1] 59/4
downplaying [1]
58/13
downside [1] 77/13
DR [2] 52/3 56/11
drab [1] 93/23
draft [5] 120/14
120/25 121/4 156/3
157/21
draw [6] 20/20 44/15
47/17 50/15 56/24
88/25
drawing [1] 12/16
drawn [2] 53/7 140/5
drew [2] 56/2 56/17
drib [1] 93/23
drilling [1] 66/24
drip [6] 52/5 52/5
52/5 53/16 53/16
53/16
drip-drip-drip [1]
53/16
drive [1] 37/16
driving [1] 154/5
due [7] 8/15 82/22
145/18 167/10 167/11
185/12 185/13
Duncan [28] 24/9
33/20 34/1 40/25
42/20 43/2 43/8 43/11
55/15 55/18 57/8
69/14 70/17 93/22
94/3 94/23 95/6 95/8
106/2 119/18 130/9
134/18 137/17 142/11
147/12 147/19 147/21
148/11
Duncan's [1] 94/14
Duncan/Gavin [1]
55/15
during [17] 10/14
13/16 15/14 18/13
26/6 27/25 28/19
31/17 34/14 65/1 66/3)
136/19 137/7 155/25
157/8 159/19 165/12
duty [2] 35/23 169/5
dynamic [1] 129/25
dynamics [1] 87/12
E
each [7] 64/2 75/3
91/15 94/15 150/17
167/23 167/25
earlier [8] 11/6 91/21
107/21 116/2 128/19
130/13 166/1 166/3
early [14] 16/9 18/14
23/4 23/7 25/5 36/1
65/8 65/23 78/14
91/25 130/21 132/5
137/2 144/10
ears [1] 51/17
easier [1] 96/12
easily [1] 145/15
East [1] 3/2
easy [1] 92/15
echelon [1] 25/6
echoed [1] 64/6
Ed [2] 121/17 121/23
Edge [1] 48/1
edges [1] 53/7
edit [1] 80/20
effect [6] 16/8 19/25
112/13 158/1 179/10
190/16
effective [1] 15/23
effectively [16] 41/6
154/13 154/19 157/14)
158/13 158/23 159/25}
170/17 172/14 177/10
178/11 180/17 182/9
183/23 184/9 192/11
efficiencies [3] 35/11
35/16 38/3
effort [1] 14/9
efforts [1] 118/14
eg [2] 63/16 74/25
eg Old [1] 74/25
eg they [1] 63/16
either [12] 7/2 55/11
60/9 70/21 74/18
79/24 103/14 105/2
181/15 181/24 182/3
192/2
eke [1] 51/20
elected [1] 23/25
element [1] 88/24
elements [3] 11/18
111/5 153/10
elevated [2] 156/7
176/17
elongated [1] 29/8
else [8] 20/13 52/3
71/3 87/21 113/12
113/16 126/13 165/25}
elsewhere [2] 93/17
178/17
email [79] 7/11 7/16
7/18 7/23 8/23 26/20
38/24 39/5 39/8 41/24
46/20 47/11 47/16
47/24 49/13 50/23
51/19 55/14 58/12
59/5 59/9 60/19 61/18}
63/8 64/25 66/2 68/7
70/8 70/23 71/4 71/7
72/19 73/4 73/6 73/9
73/16 73/20 115/22
115/23 115/24 116/2
117/22 117/25 118/2
118/16 118/17 119/3
119/5 119/10 120/12
123/9 127/14 128/1
128/3 128/3 128/6
128/9 130/11 132/9
137/23 138/1 138/3
138/25 139/2 139/5
139/5 139/17 140/4
(58) discrepancies - email
E
email... [11] 140/8
141/2 143/7 143/8
143/24 146/4 170/21
171/3 172/1 172/22
174/9
emails [4] 49/11
49/20 61/18 61/21
embed [2] 154/25
168/25
embedded [1] 17/20
Emily [2] 139/2
141/10
emphasis [1] 7/9
emphasise [2] 35/25
93/13
emphasised [1]
21/22
employed [3] 2/15
152/13 152/22
employees [6] 4/20
4/22 25/15 86/25 97/8)
176/14
employment [2] 3/23
49/9
enable [1] 185/9
enabled [1] 163/21
enabling [1] 183/12
enclosed [1] 8/3
encompassed [1]
153/9
encompassing [1]
4/18
encountered [3] 62/1
65/1 185/4
end [30] 22/2 22/2
22/23 22/23 23/9 23/9
24/21 24/21 44/22
44/22 45/24 55/7 55/7
56/1 56/1 69/8 69/8
69/14 81/19 81/19
83/3 85/9 86/13 100/5I
126/3 130/2 135/25
158/10 158/10 161/12
endeavour [3] 35/8
41/14 55/25
ended [2] 148/6
190/12
endorsed [1] 120/18
endpoint [1] 146/10
engage [1] 161/2
engaged [2] 141/22
190/17
engagement [2]
172/5 173/22
engaging [1] 93/9
engineer [2] 53/1
91/10
Ennis [1] 11/11
enormous [2] 145/4
146/7
enough [6] 35/14
35/17 93/22 94/21
137/15 137/15
enquiries [2] 22/1
167/20
ensure [19] 9/10
72/15 75/13 79/3
79/10 81/14 86/9
127/1 154/25 159/6
160/2 161/3 161/21
167/4 173/14 177/1
184/1 186/3 188/20
enterprise [1] 11/15
enthusiasm [1]
187/15
entire [2] 13/6 18/10
entirely [3] 5/18
20/13 21/10
entities [4] 23/12
37/20 41/14 78/11
entity [1] 45/5
entrance [1] 82/10
environment [8]
100/17 100/19 101/5
103/24 104/6 156/7
160/12 162/13
envisaged [1] 40/3
equal [1] 63/16
equally [2] 103/16
190/23
Ernst [11] 84/3 84/4
84/22 85/17 85/20
86/8 86/19 86/23
87/13 96/17 177/15
error [8] 21/18 63/13
146/24 147/10 167/10)
167/12 180/16 180/17,
errors [11] 16/2
16/13 20/6 21/13 22/3
27/23 28/8 31/20
119/13 159/19 160/5
escalate [2] 9/20
42/9
escalated [5] 64/3
70/22 78/15 106/17
182/8
escalation [1] 24/16
essence [2] 40/21
65/11
essential [1] 52/22
essentially [11]
13/11 24/6 26/22 32/9)
47/13 70/16 140/11
162/4 167/16 173/19
192/5
establish [3] 27/5
167/10 167/19
established [5] 93/10)
165/1 165/3 167/8
182/2
estate [1] 40/2
estimates [1] 186/17
et [6] 26/15 26/15
43/16 43/17 43/17
119/5
et cetera [4] 26/15
26/15 43/16 43/17
etc [1] 144/12
eternal [1] 35/8
Europe [1] 3/2
evaluate [1] 41/11
evaluating [2] 29/5
30/16
evaluation [1] 95/21
even [14] 13/7 27/19
38/24 47/21 52/10
53/3 65/8 85/8 96/10
129/1 135/15 145/4
183/6 188/8
evening [2] 102/12
109/8
event [3] 8/10 75/1
173/5
events [5] 63/14 64/1
TAIT 150/14 191/16
eventually [1] 70/13
ever [4] 23/4 23/7
25/15 56/19
every [11] 49/13 50/7
50/20 55/11 80/18
91/15 92/24 94/16
94/17 120/1 162/9
everyone [4] 79/14
109/10 127/13 145/12
everyone's [2] 15/16
69/8
everything [8] 24/4
81/12 84/24 87/21
96/18 97/13 110/20
128/25
evidence [41] 27/2
48/5 48/6 48/9 48/22
49/17 51/4 52/15
53/13 53/17 54/12
62/24 66/8 70/4 80/2
82/7 82/21 83/11
83/23 88/15 90/16
95/14 98/9 99/9 101/6
101/15 104/2 112/9
113/7 118/21 119/14
128/20 135/6 135/21
139/13 145/8 148/6
149/3 149/9 185/19
190/19
evidenced [1] 70/8
evident [1] 76/23
evidential [2] 90/21
90/25
ex [1] 47/7
ex-Managing [1]
47/7
exact [1] 76/12
exactly [3] 16/7 35/3
101/21
example [13] 5/9
18/2 26/3 51/8 52/15
85/3 88/25 90/8 159/8
166/16 175/17 179/13
193/1
examples [2] 80/5
83/6
exceeded [1] 50/17
Excel [1] 74/11
excellence [1] 25/22
except [1] 165/2
exchange [4] 59/6
73/9 142/6 191/5
exchanges [1] 54/19
excuse [3] 49/10
93/1 138/7
execs [2] 95/23
121/23
execution [1] 41/12
executive [29] 4/4
5/23 11/10 12/1 12/7
32/17 33/4 34/2 34/3
36/3 36/9 37/12 38/8
39/2 42/12 51/13
53/23 68/17 69/3
69/20 79/18 89/11
89/15 92/16 92/16
105/23 106/1 117/4
142/9
executives [2] 112/1
125/19
exercise [1] 83/3
exel ing [1] 179/10)
exhibits [1] 151/14
exist [1] 161/13
existence [3] 28/8
62/13 77/7
existing [1] 120/22
exit [3] 44/17 85/7
185/10
expand [1] 95/25
expansive [2] 18/6
18/10
expect [15] 26/14
28/13 38/2 64/23 78/9)
84/14 84/25 96/11
108/13 138/14 141/23)
143/18 161/12 188/21
194/4
expected [11] 16/16
18/24 19/3 53/4 78/19)
78/20 80/15 95/25
106/25 113/1 167/4
expecting [2] 43/7
95/1
expense [1] 129/23
experience [8] 28/13
32/25 47/2 80/17
104/2 104/16 104/18
160/23
experienced [2]
28/19 190/23
experiencing [1]
191/8
expert [6] 35/14
35/17 53/6 53/13
53/19 113/22
expertise [1] 166/18
explain [18] 2/14
12/12 20/6 27/22
28/16 31/15 31/23
38/16 140/10 156/3
159/8 160/14 162/21
166/10 176/5 178/1
179/9 192/14
explained [6] 100/15
129/10 129/11 129/11
131/3 179/3
explanation [3] 12/5
72/23 128/23
exploratory [1] 174/1
explore [2] 20/1
174/7
expressing [1]
142/25
extended [1] 186/4
extent [11] 54/23
86/18 154/16 154/20
154/22 154/23 166/2
172/5 175/6 176/4
177/12
external [2] 169/13
177/10
extracted [4] 180/12
180/18 180/19 180/22)
extremely [3] 28/25
39/22 194/2
EY [4] 122/16 123/22
124/3 177/15
eye [10] 56/22 93/17
126/19 127/21 127/24I
128/11 128/17 130/14}
130/23 131/3
eyes [1] 18/21
F
face [6] 106/15
134/20 134/20 182/12)
182/21 188/18
facets [2] 84/21
106/8
fact [27] 8/8 17/10
18/5 23/4 26/25 33/13)
34/24 47/20 48/8 50/6
50/24 67/10 68/19
69/23 77/11 101/9
107/18 114/23 124/1
128/4 129/19 134/18
146/6 160/23 174/14
192/23 193/1
factors [1] 169/15
facts [1] 101/18
fail [1] 47/23
failed [2] 70/10 107/8
failing [2] 169/2
169/4
failings [1] 125/1
fails [1] 47/22
failures [5] 26/11
68/13 68/14 110/6
124/23
fair [18] 16/10 16/17
28/10 28/19 28/20
56/7 59/5 74/17 86/16I
(69) email... - fair
F
fair... [9] 92/9 104/1
107/9 107/12 122/19
122/20 154/24 157/10)
158/4
fairly [7] 16/23 24/5
56/5 84/12 155/10
158/6 158/8
fairness [7] 14/6 44/7I
89/22 93/4 94/23
119/10 175/11
faith [1] 33/10
fall [2] 106/15 166/17
false [4] 5/8 51/1
52/15 71/21
familiar [3] 22/9
130/17 164/15
familiarity [1] 89/13
famous [1] 117/21
far [13] 3/13 27/2
34/16 77/2 79/2 79/9
99/9 111/16 121/6
128/25 170/18 172/17
190/19
fault [6] 21/24 27/24
30/3 48/14 110/8
110/10
fault/the [1] 27/24
faults [9] 20/5 20/9
28/3 28/14 30/2 30/10
31/16 31/18 48/11
faults/the [1] 30/2
featured [2] 90/25
130/16
February [17] 2/10
29/20 58/3 58/19
61/20 62/23 62/25
63/1 63/4 70/8 71/11
71/13 78/14 90/9
101/9 101/16 102/12
feedback [1] 55/21
feel [6] 15/15 41/20
117/11 122/9 128/13
182/18
feeling [5] 31/8 39/1
59/7 131/10 174/4
felt [9] 17/22 33/7
38/18 42/5 53/7 53/8
94/12 182/15 183/8
fence [1] 105/21
few [8] 1/25 12/2
55/1 93/16 98/19
112/14 114/23 149/17)
fifthly [1] 168/13
ht [2] 130/3 130/3
figure [4] 191/9
191/22 192/13 193/10}
file [1] 120/22
fill [1] 178/22
final [4] 13/10 45/21
76/14 184/13
finalise [1] 74/10
finalising [1] 142/19
Finally [3] 96/20
145/12 169/4
financial [5] 47/1
77/11 168/13 168/25
182/1
find [9] 8/3 9/2 26/6
31/2 58/21 65/8
122/24 122/25 161/12)
finding [2] 30/15
129/19
findings [4] 122/16
154/6 155/13 157/21
fine [10] 22/17 27/5
56/14 57/16 73/11
73/14 109/6 109/6
146/14 153/16
finish [2] 98/9 109/8
finished [3] 93/18
95/4 132/22
finishing [2] 93/1
147/14
firefighting [1] 65/18
firm [6] 129/13 130/2
130/20 155/19 155/22)
155/23
first [32] 1/5 7/3 15/3
15/14 16/7 20/12 22/6
29/14 36/23 48/8 51/7
51/22 58/2 62/25
82/18 109/20 110/22
120/13 123/13 133/14)
133/23 137/24 147/3
148/20 150/4 150/21
158/4 168/2 181/14
182/15 182/20 189/3
firstly [8] 2/3 42/1
52/13 83/14 157/18
163/25 181/14 185/14)
fit [4] 53/9 100/23
186/3 186/11
five [5] 20/17 93/20
98/18 98/23 106/22
fix [1] 83/1
fixes [3] 16/5 31/3
158/5
fixing [2] 16/17 161/4
flag [4] 9/7 51/15
78/9 158/14
flagged [1] 180/9
flat [1] 106/15
flaw' [1] 116/13
flawed [3] 15/22
16/10 54/9
flaws [1] 17/5
fleet [1] 11/16
Flemington [1]
141/11
flow [1] 51/19
flowed [1] 46/18
fly [1] 82/11
focus [1] 40/16
focused [3] 137/7
150/13 182/22
follow [7] 21/10 34/8
34/20 67/5 69/1 72/22
169/2
followed [4] 63/11
63/13 83/7 95/19
following [12] 60/23
71/2 76/16 84/3 86/7
121/17 126/19 132/11
164/23 166/6 169/12
194/12
follows [2] 68/20
69/13
foot [1] 145/19
footfall [1] 79/23
force [1] 170/23
forces [1] 104/3
fore [2] 94/12 142/17
forensic [3] 113/22
115/15 156/19
foresee [1] 41/9
forever [1] 85/12
forgive [6] 2/14 58/8
75/11 91/20 175/8
177/18
form [15] 4/21 18/9
19/1 23/19 30/21
51/15 80/16 81/22
81/22 95/12 150/6
155/7 178/22 181/2
181/8
formal [1] 3/6
formalise [1] 39/16
formality [1] 150/17
formally [3] 38/23
41/3 165/15
former [6] 6/17 7/1
12/10 53/9 97/4
134/12
formulating [1] 37/19}
formulation [2] 37/20)
121/7
forth [2] 68/13 85/16
Forum [1] 176/20
forward [14] 10/7
29/4 39/20 46/5 57/7
78/16 86/16 95/8
133/1 133/3 135/23
135/25 148/9 164/1
forwarded [4] 8/13
9/6 118/2 127/18
forwards [1] 55/18
found [14] 24/14
32/16 56/6 59/24 60/6
88/15 90/17 145/13
165/12 176/24 177/4
177/21 184/10 190/19!
four [10] 13/13 14/11
92/2 92/12 92/22
150/3 162/9 162/10
187/23 194/2
four-month [1] 92/2
fourth [2] 150/9
152/5
fourthly [1] 168/13
frailties [1] 21/22
frame [8] 23/25 29/20)
30/24 63/1 68/16
117/5 142/12 142/13
framed [1] 25/5
framework [2] 6/10
25/13
framing [1] 191/7
frankly [3] 12/20
82/23 93/22
fraud [5] 2/16 5/8
71/20 181/18 183/8
freezes [1] 19/8
fresh [2] 72/22 76/25
Friday [1] 144/7
froing [1] 92/17
front [5] 1/13 133/14
150/18 150/23 151/22}
fruitful [1] 34/16
fruition [1] 13/14
FUJ00081545 [3]
58/17 60/21 102/5
FUJ00095658 [1]
33/22
FUJ00096312 [1]
39/6
FUJ00243199 [1]
189/6
FUJ00243203 [1]
170/25
FUJ00243223 [1]
181/12
Fujitsu [161] 17/12
17/13 22/10 22/24
22/25 23/9 23/12
23/13 23/21 23/23
24/1 24/9 24/17 25/6
25/15 25/21 26/7
26/17 27/4 27/6 27/15
28/17 30/8 30/14
30/22 32/21 33/21
34/4 34/7 34/15 35/4
35/10 36/13 36/16
37/3 37/5 37/10 37/14,
38/8 38/15 38/24 39/2,
40/12 41/11 44/5 45/3
45/3 45/10 46/2 50/11
50/12 50/16 53/2
53/12 53/21 55/2
55/14 56/13 58/21
62/3 62/4 62/8 63/10
63/25 64/4 65/3 65/12,
66/18 70/14 72/24
74/5 74/8 76/19 77/24
78/3 78/7 78/25 80/20)
81/3 81/7 83/9 84/15
84/16 85/21 86/5 87/8
90/17 90/17 91/2
91/11 93/24 95/1
95/23 96/24 99/19
99/22 99/22 103/17
105/22 106/2 106/11
110/15 111/4 113/25
114/20 115/14 120/20}
123/3 126/9 128/4
132/5 134/16 134/24
135/20 141/19 142/4
142/21 144/14 144/24)
145/7 145/11 147/6
147/9 147/16 147/22
148/12 158/24 160/7
162/6 166/7 170/23
171/6 171/20 172/2
172/4 173/2 173/5
173/6 173/10 173/14
173/14 174/1 174/22
175/4 175/7 175/15
177/4 177/15 179/5
179/9 179/12 179/24
181/1 181/6 182/9
182/9 182/16 185/10
189/8 190/8 190/14
Fujitsu's [6] 37/6
120/2 173/16 174/17
176/25 177/11
Fujitsu/Horizon [1]
23/13
Fujitsu/Patterson [1]
189/8
full [12] 1/11 40/17
47/12 69/18 81/11
86/4 95/21 100/18
130/23 147/17 150/1
177/23
fully [2] 127/2 177/15
function [3] 154/12
156/20 158/24
functionality [1]
22/19
fundamental [2]
114/19 115/1
fundamentally [7]
15/19 15/22 16/10
31/22 31/25 33/9
33/15
funding [5] 162/25
186/10 186/12 186/13}
186/15
funds [1] 168/21
further [26] 34/20
37/16 38/4 40/3 47/24
52/10 73/9 76/14
91/20 96/22 98/4
108/1 113/16 113/21
114/6 115/14 117/9
118/25 121/12 123/5
127/12 127/17 141/5
171/3 188/23 193/21
further.’ [1] 114/4
future [2] 9/11 17/20
Go
gain [1] 100/6
gains [5] 74/4 75/7
76/5 76/6 101/20
gamekeepers [1]
53/8
gaps [1] 7/2
gathering [1] 139/13
(60) fair... - gathering
G
95/9 132/20 152/5
Gavin [4] 24/9 27/10
55/15 106/2
general [6] 15/10
89/14
generality [1] 80/15
generally [3] 65/17
69/12 136/22
generate [1] 75/3
generated [5] 60/16
64/2 74/7 100/1
105/19
genuinely [2] 111/21
119/15
GEOFFREY [3]
149/24 150/2 195/12
get [41] 6/9 12/21
22/12 24/17 25/7
32/22 33/24 35/9
37/23 44/16 44/21
45/4 45/5 51/21 52/6
55/25 56/19 56/20
86/11 89/12 90/11
92/13 95/7 100/4
107/3 112/11 119/22
129/2 134/24 138/7
140/7 158/7 163/21
166/4 178/23 187/15
188/8 192/21
gets [1] 120/13
getting [9] 7/4 15/15
43/14 87/17 107/1
113/7 125/14 125/17
146/9
Gilliland [1] 127/10
give [13] 1/11 38/3
86/3 92/10 104/22
113/12 120/9 133/19
150/1 160/3 164/2
167/25 169/14
given [31] 5/16 12/13
14/11 16/22 17/16
23/20 25/14 25/15
27/6 32/8 42/22 48/25
50/17 54/22 65/11
68/6 82/7 83/6 83/11
97/12 101/6 135/6
135/21 142/6 150/9
168/18 168/19 173/13
174/8 174/18 185/19
gives [3] 44/5 72/23
112/17
giving [6] 10/4 53/25
112/14 113/10 123/6
149/3
glad [2] 131/23 194/5
glimpses [1] 51/12
gave [13] 21/8 23/23
26/7 56/10 56/15 57/7,
65/6 65/6 65/14 75/16
31/8 36/12 37/17 88/9
105/16 105/23 106/17;
GLO [1] 99/7
Global [1] 3/20
go [69] 2/1 14/2 14/4
19/11 21/20 26/3
35/20 38/9 41/6 41/8
47/12 55/14 60/19
61/18 61/25 71/12
72/1 75/10 78/22
81/15 93/1 97/21
98/23 100/24 101/1
102/5 102/5 102/6
104/19 107/15 111/7
1141/9 112/22 113/16
117/18 120/8 120/9
120/20 121/6 121/10
126/17 126/19 127/3
127/12 127/17 128/5
133/7 135/16 135/17
141/2 142/1 143/7
147/3 149/20 150/16
170/21 171/2 177/12
189/2 189/20 189/21
193/7 193/8
goes [23] 12/25 31/3
63/8 63/18 81/13
116/17 121/13 127/7
127/8 127/8 139/8
139/10 139/21 140/1
165/6 165/13 167/6
167/18 183/6
going [61] 1/24 13/2
14/5 14/16 23/6 29/2
32/4 32/7 38/3 41/19
46/3 47/2 51/18 55/20
56/19 57/7 57/11
57/24 72/17 73/24
77/12 79/1 86/7 94/3
94/21 97/19 98/14
100/1 103/12 103/23
104/19 105/14 108/9
108/24 109/3 109/20
113/13 114/9 114/10
117/17 121/19 124/10)
124/20 130/10 133/1
133/3 134/15 135/17
138/15 143/1 143/19
143/20 144/6 145/15
145/19 147/3 186/4
187/14 191/8 191/22
193/11
gone [6] 18/22 70/18
105/12 131/25 135/24)
173/20
good [11] 1/3 15/23
15/25 57/10 57/20
57/21 92/19 109/17
111/23 145/10 149/10)
got [51] 22/9 26/17
26/18 29/6 30/20
30/20 32/19 37/24
43/9 45/15 45/23
123/24 124/20 126/13)
136/18 137/21 138/23)
40/5 40/14 48/2 49/15
49/12 49/12 50/23
51/5 51/11 51/12
66/15 67/3 72/4 86/9
86/13 87/15 87/16
89/19 90/12 90/12
91/17 93/21 94/9
94/15 94/20 95/7
106/25 110/6 110/18
115/7 123/17 124/15
137/15 143/4 168/7
189/13 189/14 191/1
governance [2]
39/15 39/19
Government [4]
122/7 125/19 168/20
182/3
gradually [1] 51/5
grammatical [1]
136/15
granted [1] 86/24
Granville [5] 74/17
74/18 120/14 121/1
127/8
grateful [6] 8/14
133/10 133/23 137/22I
141/1 194/4
great [8] 17/1 33/2
45/4 53/20 54/22 89/9
118/21 179/16
greater [2] 162/25
164/2
greatly [1] 186/18
Greene [1] 112/5
grew [1] 124/16
grips [1] 22/9
gritty [1] 133/7
ground [1] 134/22
group [45] 2/19 6/2
6/3 6/10 6/15 6/17 7/1
7/9 9/21 12/25 13/1
13/13 22/8 33/5 34/3
34/9 36/4 36/10 36/12
36/13 36/15 37/9
37/12 37/13 37/17
37/18 37/24 39/1
42/13 43/6 52/9 70/16
72/12 92/5 92/14 93/6
99/5 111/10 114/9
130/4 135/8 138/21
155/1 164/23 170/5
Group's [1] 36/12
Group-type [1] 36/10
grouped [1] 129/22
grow [2] 11/21 37/8
growing [4] 101/12
102/2 123/23 130/1
guess [2] 32/3 48/24
guidance [3] 117/15
168/16 168/19
guys [1] 147/20
124/19 126/11 134/24
191/21 193/15 193/16
H
habitually [1] 166/21
had [173] 3/5 4/9
5/15 5/16 5/19 6/7
6/16 6/17 6/23 6/25
9/15 11/5 11/12 11/17
12/12 12/18 13/3 14/7I
17/11 18/22 18/24
20/8 22/7 23/11 23/17
24/4 24/9 24/12 25/5
25/21 26/5 27/15
27/17 28/3 29/7 29/9
30/19 31/1 31/5 33/9
33/13 33/20 35/10
35/11 35/13 36/5 36/8
37/8 37/20 38/19 41/8
41/13 41/16 41/25
42/14 42/21 43/1 43/2
44/25 47/1 48/11
50/23 51/15 52/17
54/23 55/1 58/4 58/5
59/7 62/14 62/15
63/19 65/7 66/4 66/16
66/16 68/3 68/22
69/16 70/6 70/9 71/14
TANG 71/22 71/23
72/3 72/15 75/18
76/12 76/20 79/5
79/12 80/25 83/15
84/18 84/24 85/24
86/14 86/19 87/4 87/9
88/7 88/11 90/9 90/18
93/13 93/22 93/24
94/14 94/19 94/21
95/5 95/6 100/17
101/18 105/13 106/7
106/10 110/14 110/22]
4112/2 112/20 114/21
114/25 115/17 115/18
117/12 120/4 122/5
124/1 125/13 125/20
125/20 128/8 128/14
129/7 129/13 129/21
129/25 131/10 131/23
132/11 132/12 135/8
141/21 144/11 144/20}
147/7 14718 147/18
147/20 148/13 148/13}
148/23 155/8 155/11
155/12 155/13 155/16
155/18 156/6 158/20
159/5 173/25 174/11
177/10 183/1 187/8
188/9 189/10 189/11
192/16 193/18
hadn't [6] 32/10 48/9
50/4 75/25 132/7
155/20
half [5] 32/19 57/12
114/18 118/1 130/11
hand [8] 23/16 111/4
112/15 112/16 114/16
115/12 162/25 190/21
handed [2] 135/15
155/5
handled [3] 7/8 28/9
144/12
handling [2] 34/24
188/15
handover [1] 112/2
hang [2] 21/6 146/9
happen [4] 13/2 46/3
114/10 114/11
happened [20] 26/12
63/22 64/2 67/14 74/5I
74/6 75/3 76/20 81/16I
81/23 91/4 96/1 96/1
96/19 120/7 123/5
148/13 158/20 192/16
192/20
happening [4] 51/21
55/19 107/23 144/13
happens [2] 81/12
105/18
happy [2] 10/24
127/14
hard [4] 48/5 48/9
145/12 149/21
hardware [3] 19/7
26/11 124/23
harmony [1] 96/14
has [78] 8/8 8/9 8/12
8/13 9/6 10/7 17/20
17/25 18/1 34/15
39/20 39/23 40/10
40/10 46/3 46/25
47/21 49/22 50/8 61/7
63/22 64/1 64/2 64/15
68/7 70/2 75/13 77/21
77/21 78/15 82/3 82/9I
87/1 91/4 93/6 97/7
97/8 99/10 108/19
110/5 111/1 111/24
111/25 115/12 115/25)
118/2 127/18 130/23
133/5 133/16 133/17
133/24 138/15 138/25)
139/16 139/21 141/14)
142/17 145/21 147/6
164/5 165/2 165/23
167/11 172/18 173/20)
173/24 174/8 175/15
176/12 177/6 180/9
186/7 186/9 188/1
191/3 192/11 193/18
hasn't [7] 48/6 49/16
50/6 96/1 163/13
172/7 186/16
hat [2] 48/12 134/12
have [300]
haven't [7] 69/9
72/21 78/11 78/12
88/15 146/15 146/23
having [31] 10/7
14/21 14/22 33/7
39/14 41/10 43/4
43/20 53/1 53/22
(61) gave - having
H
82/6 83/1 89/1 90/15
109/2 119/9 125/22
126/2 129/25 131/12
133/1 133/1 146/23
he [66] 7/5 9/9 9/25
12/12 12/18 19/23
20/4 20/8 21/1 21/7
39/10 39/20 39/21
63/24 65/22 66/7
73/20 73/23 74/1
93/25 94/23 95/3
111/11 112/3 112/13
112/17 114/2 114/14
115/12 116/4 121/1
121/2 127/18 127/22
127/23 172/3 173/19
174/3
he'll [1] 65/24
he's [4] 74/22 115/9
115/19 116/5
head [21] 2/19 4/10
4/14 5/10 6/3 7/13
7/14 7/21 8/25 10/3
19/15 53/24 58/5
65/15 71/18 73/18
77/5 109/24 131/16
141/17 157/8
headed [1] 139/14
header [1] 141/5
heading [3] 138/3
169/19 181/13
headquarters [2]
17/4 97/17
heads [1] 143/9
hear [8] 1/3 57/21
88/23 98/20 109/17
131/24 149/15 193/4
heard [5] 82/5 110/15
128/23 134/11 138/15)
hearing [1] 194/12
heat [2] 126/14
126/14
heavily [1] 11/22
heightened [1] 131/6
held [2] 48/10 63/23
Hello [1] 149/15
help [13] 15/17 83/9
91/2 92/19 113/2
133/19 145/4 145/18
146/7 146/13 155/19
171/19 193/9
having... [21] 56/25
66/18 81/2 81/3 81/21
101/14 101/15 105/12)
21/8 21/21 21/22 36/5
dan aap 4aint 47/11] M438 14605 146/20
here [21] 11/8 16/7
47/17 47/20 47/22
21/8 37/23 42/13
47/24 47/25 47/25
49/15 59/4 61/12 55/17 71/10 73/21
85/4 87/22 102/11
61/16 61/18 63/18
77/21 77/21 82/9 93/5)
Helpdesk [3] 22/18
24/25 81/3
61/5 66/24 102/8
102/21 121/3 186/16
Helpline [2] 191/21
192/3
henceforth [2] 181/7
183/17
Henry [2] 109/1
109/2
her [11] 86/12 95/9
110/11 111/14 119/11
118/2 122/17 128/13
131/8 142/12 144/13
146/8 147/4 169/8
172/17
herself [1] 142/19
hesitate [1] 8/17
hesitating [3] 18/20
87/7 104/22
Hi [4] 172/25
Hibbard [1] 75/12
high [6] 14/21 40/7
54/10 99/7 130/2
144/11
high-profile [1] 54/10)
higher [1] 188/1
highlighted [7] 54/10
65/5 110/12 110/14
125/2 159/3 188/12
him [17] 19/18 19/21
19/21 20/11 20/18
35/20 40/23 42/6 56/6
59/2 60/25 69/17
108/15 111/13 111/22)
116/10 171/5
himself [1] 116/12
hindsight [4] 64/11
87/19 87/23 125/7
hinted [1] 14/7
his [29] 7/5 9/4 18/22
18/25 30/14 42/20
42/24 46/2 47/9 47/11
54/11 56/8 59/9 61/11
61/13 61/18 78/15
95/9 98/9 112/9 113/2
113/18 121/17 136/3
136/4 149/9 149/21
171/5 173/20
historic [4] 157/9
178/11 179/20 185/23)
historical [4] 157/14
158/25 159/2 178/14
historically [1] 20/19
history [1] 67/22
hitter [1] 96/17
hm [1] 191/14
helpful [8] 37/4 42/16
125/25 141/18 142/25)
HNG [8] 17/11 34/6
36/6 40/1 62/1 62/6
65/23 141/20
36/6 40/1 65/23
141/20
Hobbs [2] 128/3
128/6
HODGE [13] 1/10
73/14 100/12 101/7
108/5 108/19 132/1
148/17 149/5 149/25
153/13 195/4 195/14
hold [3] 84/20 87/21
165/2
holding [4] 9/14
holiday [2] 85/15
146/22
home [1] 22/17
homework [2] 22/15
22/16
honest [1] 48/23
honestly [1] 117/8
Honourable [1] 9/3
hope [1] 109/10
Horizon [199]
Horizon's [3] 91/22
92/8 174/12
hour [4] 17/4 57/12
92/24 121/24
hour's [2] 16/21
1717
hours [1] 161/1
how [40] 4/7 6/22
6/25 12/17 14/15
16/24 17/18 21/14
23/25 28/9 30/7 38/12
41/8 49/23 49/24
61/13 65/12 74/10
76/22 77/23 78/25
81/19 87/4 95/16 98/9
98/14 100/21 106/17
111/22 111/24 128/21
136/21 138/8 143/11
144/12 145/7 159/21
173/21 184/9 186/17
Howe [1] 98/18
however [7] 19/12
48/5 63/22 64/3
117/15 165/6 177/12
HR [1] 85/8
Hub [1] 162/18
Hudgells [1] 98/15
huge [1] 67/7
hugely [1] 145/2
Huggins [5] 46/21
47/11 47/18 116/3
127/11
Hugh [1] 141/10
hundreds [4] 93/7
126/5 129/13 129/21
hurting [1] 97/3
hypothesis [1] 70/7
HNG-X [6] 17/11 34/6I
Horizon-type [1] 55/7
106/20
lact [1] 131/21
l actually [5] 44/20
170/15
69/6 74/19 77/1
l agreed [2] 36/25
75/9
I alluded [1] 115/4
lalso [1] 186/16
lam [14] 15/20 39/22
89/16 106/4 108/7
173/4 194/3
I apologise [2]
122/23 148/25
l appreciate [1]
148/24
larrive [1] 17/16
larrived [2] 18/11
18/23
lask [4] 1/16 108/18
151/12 171/19
lasked [7] 6/22
12/12 20/24 20/24
21/2 45/11 107/14
lassume [2] 133/2
145/22
l assumed [1] 192/15
l aware [1] 10/8
Ibe [1] 30/11
I became [2] 22/8
85/19
I been [1] 18/24
I believe [13] 15/23
19/23 59/15 61/19
87/11 109/21 150/25
164/10 165/19 169/17
176/10 185/17 191/4
I brought [1] 134/25
I call [4] 191/21
I can [23] 8/16 16/6
35/22 55/19 57/22
66/17 99/9 105/9
108/15 109/4 109/18
115/21 117/8 134/1
139/3 143/13 144/9
146/12 147/5 149/16
174/25 175/2 191/11
I can't [20] 24/12
31/7 43/20 43/21
53/14 54/2 55/19 59/3
61/10 61/11 61/14
65/22 69/19 69/20
89/6 93/5 111/23
117/14 147/15 193/12
I cannot [1] 88/22
I categorically [1]
65/21
laccept [2] 71/6
110/23 113/13 118/12)
l agree [5] 59/3 67/16)
40/11 41/2 74/9 82/25
117/19 135/19 145/19)
I cause [1] 29/3
I challenged [1]
110/15
I chose [1] 12/20
I considered [1] 86/1
I could [8] 11/24 55/1
55/3 92/24 93/19
110/20 117/21 145/15)
I couldn't [3] 42/23
126/8 188/10
I created [1] 157/15
I deliberately [1]
86/10
I demanded [1] 25/22
I did [16] 27/17 28/24
49/3 56/17 75/9 88/10)
93/18 110/18 110/19
118/16 118/20 125/23)
137/4 140/7 189/16
192/19
I didn't [22] 11/1
20/19 21/6 24/2 44/4
47/4 49/7 50/1 50/22
50/23 52/2 52/3 71/24)
89/6 93/15 113/12
118/19 121/21 124/2
130/9 140/8 175/11
Ido [24] 1/15 1/20
5/22 44/15 44/16 46/9I
52/25 59/18 71/12
82/5 85/3 113/20
118/20 118/21 128/14)
150/19 150/24 151/4
151/16 151/23 152/1
170/4 170/7 181/3
I don't [43] 23/4 23/7
26/24 48/23 49/7 60/4I
60/9 61/10 62/20
65/17 66/12 68/14
69/19 72/16 72/17
73/8 76/2 77/22 78/18)
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35/21 37/11 38/22
41/24 43/25 46/3
47/12 49/8 49/10
49/20 50/21 52/5
53/15 58/17 58/18
59/7 61/19 64/23
66/25 69/6 69/7 69/7
69/23 72/3 72/4 72/8
73/15 73/16 73/17
74/18 74/19 74/20
76/10 81/2 81/14
82/12 82/21 84/22
84/23 86/6 86/13 87/7
89/16 91/12 92/2 92/7
93/2 93/3 93/4 93/23
97/22 98/1 98/21
100/1 100/22 101/14
101/17 101/23 102/12
103/24 104/20 106/17
107/12 109/21 110/6
111/23 112/9 112/11
112/17 116/2 118/21
119/15 125/6 126/11
126/15 126/17 126/24)
127/4 127/6 128/10
128/12 133/8 133/23
136/8 136/8 137/21
138/22 139/5 139/12
139/14 139/25 141/1
142/6 147/5 147/11
147/15 148/6 152/7
160/12 160/24 160/24]
161/24 161/25 164/17
171/8 174/19 176/7
178/11 178/13 178/16}
178/22 178/23 180/19}
180/22 181/11 183/21
184/4 184/18 190/15
191/22 193/13
item [1] 89/25
iterations [1] 49/20
iterative [1] 186/14
its [26] 36/5 36/7
42/22 54/23 84/21
99/20 99/21 106/8
106/15 113/24 124/25}
134/7 140/12 147/1
151/1 152/24 161/24
164/19 165/10 169/4
175/15 183/12 184/2
185/10 186/6 188/15
itself [14] 33/14
51/20 56/2 57/4 66/15
66/17 66/18 111/6
115/8 139/24 164/18
186/3 190/14 193/1
J
Jarnail [1] 119/5
JFSA [6] 64/7 93/6
124/16 136/14 136/23
14/2 16/18 17/13 19/2
139/13
job [16] 10/13 10/16
11/2 11/2 11/3 12/3
43/2 47/9 61/11 61/13
92/19 97/13 97/18
97/23 107/8 125/25
jogged [1] 193/20
John [21] 5/10 6/3
6/3 6/20 6/21 7/5 7/12
7/22 8/2 8/19 9/24
10/3 10/9 52/9 65/20
65/21 118/19 165/19
167/1 171/8 171/13
joined [12] 2/3 3/20
3/24 4/16 15/3 15/7
19/22 122/8 150/14
153/1 155/18 156/5
joining [4] 6/13
152/17 154/25 155/7
Jolly [1] 149/10
journalism [1]
132/12
journalist [2] 93/2
93/5
journey [3] 13/6
25/12 41/21
judge [1] 116/13
judgment [12] 154/7
155/5 155/9 155/13
156/22 156/23 159/3
163/8 164/24 165/8
175/6 176/11
Julian [4] 136/2
July [4] 3/20 8/4 9/16
150/22
July 2007 [1] 3/20
jump [1] 48/20
June [7] 3/18 39/5
39/8 45/24 95/17
185/14 185/16
June 2010 [1] 45/24
just [108] 7/19 10/2
13/18 14/23 16/6
16/19 19/8 20/1 23/20}
25/14 30/4 31/10
31/23 33/11 35/3
36/13 36/21 36/21
38/16 39/10 40/1
41/21 44/17 45/21
45/24 46/21 47/18
49/3 49/8 49/23 53/11
54/2 59/14 61/15
62/11 63/7 66/22
67/10 67/25 69/1 73/5)
7AI9 74/13 80/13
83/11 85/16 87/25
92/10 92/25 93/24
93/24 99/1 99/10
100/13 100/19 102/16}
102/25 103/6 103/19
105/3 107/17 108/8
108/19 109/2 109/4
110/9 112/7 113/4
113/14 114/16 116/5
117/9 120/9 126/17
127/23 128/7 129/18
130/4 130/11 131/3
131/9 131/15 132/1
132/4 135/5 135/24
138/19 139/5 140/25
141/15 142/23 143/5
143/6 144/4 146/12
149/20 150/16 153/17)
154/3 158/7 159/15
160/1 167/19 172/21
178/13 181/11 189/2
192/7
K
Karen [1] 136/4
keen [1] 74/24
keep [8] 11/23 70/24
76/7 77/12 77/16
98/25 99/1 144/5
keeping [3] 37/22
56/22 96/6
kept [5] 101/20
101/21 140/14 149/16)
189/23
Kevin [2] 127/10
138/15
key [5] 28/9 38/14
154/24 156/13 163/3
keystroke [3] 81/11
81/18 120/24
keystrokes [1] 124/4
kick [1] 106/16
kicked [1] 70/2
kind [4] 124/10
143/14 175/1 188/20
knew [15] 6/17 7/6
14/10 16/12 29/22
32/12 53/19 56/5 56/5I
107/20 119/21 128/8
132/10 135/7 193/11
knock [1] 94/14
knocked [1] 120/2
know [161] 3/16 7/4
10/11 11/4 12/9 12/11
12/19 13/13 14/15
16/24 17/1 18/7 20/16
21/2 24/14 24/22 26/5
26/13 29/8 29/12
30/14 30/23 31/4
32/16 36/1 37/4 37/5
37/22 38/25 42/18
42/25 43/25 44/9
44/13 46/19 46/24
48/23 48/23 49/2 49/7)
49/22 49/24 50/1
50/20 50/23 51/2 53/3}
54/3 55/17 56/4 56/18
56/19 56/20 56/21
58/1 60/4 60/8 60/9
60/13 61/10 62/18
65/6 69/19 70/18 76/2
76/3 76/9 77/22 78/18
80/20 81/7 81/9 83/9
(65) intro - know
K
know... [88] 84/8
84/14 84/17 86/21
87/8 87/15 89/1 89/4
89/17 89/19 90/18
90/24 91/10 92/15
92/19 93/11 93/23
94/3 94/10 94/19
95/13 95/16 95/19
95/20 96/2 97/6 97/11
97/11 97/12 97/21
97/22 98/2 100/25
101/14 101/15 105/16}
109/7 109/8 110/19
111/21 111/21 111/22)
114/23 115/4 116/22
117/16 118/21 119/22)
120/2 121/5 121/9
122/3 124/16 124/16
124/19 125/8 125/8
125/19 126/16 130/3
130/8 131/11 131/15
134/18 134/19 134/22
135/3 135/6 140/10
140/15 142/13 142/25)
143/10 143/14 143/19}
143/20 143/22 144/23
145/12 147/11 148/4
148/5 179/22 186/19
188/11 190/15 191/15
191/20
knowing [2] 81/10
87/19
knowledge [21] 1/22
15/4 48/4 57/25 80/9
80/22 88/2 88/11
117/6 137/5 151/6
151/18 152/3 152/11
161/15 161/22 166/19}
167/19 176/14 186/9
188/4
knowledge-based [2]
161/15 161/22
known [14] 18/17
32/5 43/2 51/7 71/22
71/23 72/3 106/7
116/17 128/3 140/23
142/8 154/9 167/2
knows [2] 138/20
143/20
KPMG [10] 41/8
141/22 145/10 155/22)
155/24 156/3 156/19
157/22 159/6 176/23
L
label [1] 44/25
lady [1] 119/7
laid [2] 55/11 114/21
land [4] 143/22
lands [1] 55/24
language [4] 35/12
82/6 124/10 128/21
large [9] 5/1 11/15
12/1 51/24 99/5
187/22
large-ish [1] 114/17
largely [7] 21/22 24/4
24/23 90/17 90/25
99/12 180/5
larger [2] 93/6
172/15
largest [1] 11/14
last [15] 7/16 14/8
44/17 58/23 59/19
74/3 92/22 107/14
110/12 126/17 137/1
141/2 144/20 164/6
187/23
lasted [2] 93/20
121/24
lasts [1] 17/21
latches [1] 84/9
late [6] 91/25 120/4
137/2 157/19 177/19
181/4
later [25] 2/19 7/23
12/2 12/24 13/4 18/23
22/5 22/22 36/3 42/6
46/5 50/24 60/24
61/19 61/20 68/25
73/4 93/9 98/11
110/24 114/23 122/7
141/6 144/1 155/23
latest [4] 61/1 102/16
107/17 107/19
laughed [1] 131/9
launched [2] 157/19
162/21
law [4] 7/14 10/4 54/1
130/2
lawyer [1] 138/21
lawyers [4] 93/9
129/19 129/22 136/14)
lawyers’ [1] 144/11
lay [1] 143/22
layer [2] 85/16 90/25
lazy [1] 116/25
lead [4] 6/4 23/22
142/20 171/6
leadership [2] 86/12
95/3
leaned [1] 35/15
learn [2] 41/2 187/19
learnt [5] 30/1 31/16
83/12 90/15 125/7
least [1] 140/22
leave [9] 6/9 13/25
14/21 80/24 106/14
108/11 148/8 167/16
170/6
leaves [3] 12/24
78/23 85/15
leaving [5] 2/3 2/6
2/22 3/12 103/6
led [7] 36/22 41/20
112/17 114/17 171/15)
159/23 159/24 162/5
165/19 190/1
left [18] 3/18 12/6
12/6 14/25 15/1 15/2
95/16 95/18 95/20
98/1 109/24 110/23
113/18 115/12 118/19]
129/1 129/3 174/4
left-hand [1] 115/12
leg [1] 183/2
Legacy [20] 15/7
15/11 15/19 16/10
16/16 18/17 19/13
20/2 20/5 20/8 21/9
21/23 22/3 25/16 27/4
27/7 27/19 28/23
67/22 87/11
legal [23] 6/9 7/10
8/25 62/10 63/20
73/25 78/17 89/1 89/4
130/19 136/20 136/25
138/22 140/2 140/5
141/16 141/24 144/2
145/1 173/2 173/2
189/21 190/1
Legally [2] 141/13
141/17
lend [2] 11/25 172/10
length [4] 108/11
131/4 132/1 151/24
Lesley [27] 44/7
46/24 47/6 47/9 52/2
55/5 56/22 58/4 69/11
73/17 73/20 78/19
78/20 78/22 85/19
86/10 103/17 109/24
125/24 138/7 142/17
144/19 146/19 147/7
147/8 147/16 147/21
less [4] 14/20 54/18
57/2 94/15
let [7] 25/18 54/3
88/25 105/7 134/15
140/10 166/3
let's [21] 65/8 72/1
72/7 79/21 83/9 98/19
101/1 101/3 103/5
108/8 111/7 113/16
114/16 115/22 117/20}
120/8 123/5 126/17
130/11 143/25 193/8
letter [44] 7/24 8/3
8/10 8/12 9/2 9/6 9/14
26/20 33/23 36/22
37/2 37/19 37/21 38/4
38/23 39/9 39/9 39/13
39/22 40/22 41/1
42/16 42/19 44/10
70/17 94/14 126/18
126/24 127/7 127/14
128/10 130/14 131/3
140/17 189/9 189/16
189/20 190/3 190/6
190/11 190/12 190/14]
190/20 191/1
letters [7] 63/19
63/22 73/24 125/20
136/1 139/22 191/5
level [20] 4/5 5/23
11/11 36/15 39/17
39/18 64/4 65/21 78/3)
82/22 88/18 126/10
131/11 148/9 160/4
184/5 187/9 187/22
188/1 188/17
levels [8] 38/13 40/3
41/12 44/11 103/19
184/8 186/4 187/13
leverage [1] 25/7
levers [1] 55/1
liability [1] 116/12
liable [2] 21/12 48/11
liaison [3] 154/16
165/18 171/5
lies [1] 144/24
life [1] 96/12
light [5] 32/10 32/11
62/2 65/2 66/4
like [53] 9/23 10/9
12/21 15/3 15/25
16/15 20/8 28/24
30/21 31/10 32/18
33/19 37/2 38/8 38/10)
39/15 45/20 46/17
48/24 53/8 54/5 67/16)
67/19 70/23 72/9
79/16 80/7 82/13
84/15 85/18 87/24
88/13 93/23 96/17
98/8 101/17 105/6
105/18 106/9 108/13
110/9 116/5 121/9
126/13 150/16 159/15}
164/4 176/22 177/24
180/25 184/13 184/24)
185/21
liked [2] 177/12
187/18
likelihood [1] 54/2
likely [8] 9/7 9/20
14/6 14/8 98/7 98/10
168/24 178/16
limited [12] 48/6
150/10 152/14 155/10}
155/15 156/10 157/4
158/6 164/25 171/17
171/21 171/23
limits [2] 23/14 23/14
line [9] 6/7 43/14
63/15 123/6 123/11
127/4 139/9 139/10
146/11
lines [3] 99/18
121/19 123/7
link [1] 106/14
linked [1] 19/10
links [3] 75/14 75/17
75/24
list [1] 161/1
listed [1] 169/19
listen [1] 89/7
listened [1] 101/14
lists [1] 167/22
litany [1] 98/1
litigation [14] 5/16
99/7 136/11 136/12
136/16 136/17 136/24I
137/3 137/5 140/23
146/2 147/2 155/2
164/24
litigators [1] 126/4
little [29] 13/4 22/21
42/15 43/8 51/17 53/7
53/8 68/25 72/1 76/14
92/18 100/21 111/7
113/16 115/6 115/25
119/19 120/11 123/8
126/23 127/12 135/24I
136/15 137/9 141/4
146/10 155/14 158/12)
171/3
live [25] 28/14 62/1
62/3 62/4 65/2 66/5
68/3 68/8 68/22 68/23
69/8 70/9 71/8 71/12
71/15 101/4 103/24
104/5 104/12 160/2
160/12 160/15 161/7
162/13 185/20
lived [1] 92/23
Local [5] 59/23 60/11
60/12 60/16 60/17
locate [1] 149/21
located [1] 39/23
locked [1] 125/11
log [13] 53/3 81/11
81/16 81/17 82/1 85/1
85/11 85/11 90/20
91/4 116/8 120/17
129/1
log-in [3] 85/11 85/11
120/17
logged [1] 74/7
logging [1] 125/9
logic [1] 116/14
logs [7] 48/7 49/17
50/23 53/6 75/1 91/11
124/4
London [6] 171/10
171/20 172/5 173/3
173/20 173/24
long [20] 18/22 27/10)
30/7 30/12 30/23 31/7
31/9 32/1 34/15 41/3
43/20 96/2 97/8 98/10
98/14 108/14 134/20
146/10 151/11 152/7
long-term [1] 97/8
long-winded [1]
146/10
longer [6] 13/23
34/23 98/24 144/5
(66) know... - longer
L
186/7
look [62] 5/11 7/11
29/13 32/24 32/25
33/19 37/2 39/21
45/14 46/17 47/19
54/5 58/16 64/24
65/12 68/25 73/4
76/14 80/13 87/14
87/22 93/24 94/19
96/3 96/7 103/19
103/23 109/2 112/7
117/7 123/5 130/11
131/24 132/3 133/7
133/9 133/13 133/21
135/22 136/6 136/9
138/22 139/9 158/18
164/13 170/21 180/4
191/21 193/5 193/7
looked [11] 49/15
101/15 109/4 115/22
119/9 131/13 133/5
158/13 159/2 165/24
176/24
looking [25] 12/17
23/8 39/10 43/15
43/15 44/13 57/9
167/3
looks [3] 30/21
144/22 148/14
looped [1] 132/12
loosely [1] 80/9
loss [6] 164/18 165/3
167/10 169/23 170/3
172/15
losses [7] 74/3 75/6
76/5 76/8 165/1
169/10 172/8
lost [7] 64/1 90/21
91/1 91/5 91/16
105/16 116/11
lot [22] 15/14 26/18
30/13 44/10 44/22
61/3 73/21 76/11
85/20 92/17 97/2 97/3
97/7 102/18 103/12
108/16 120/12 134/11
137/14 138/25 139/1
145/3
lots [5] 22/14 33/3
133/6 182/17 182/17
lower [1] 114/17
loyal [1] 97/16
longer... [2] 159/7
112/15 114/16 115/22)
137/20 137/24 138/19)
180/10 180/10 180/11
180/12 180/21 185/21
63/20 65/4 65/5 68/10
86/17 86/20 87/3 91/6
104/23 110/16 134/23)
140/25 142/23 146/20)
154/13 157/14 165/23}
108/4
lunchtime [2] 98/20
111/3
made [39] 6/6 8/10
9/19 9/23 18/3 21/20
39/23 43/11 70/25
101/10 105/15 117/1
131/6 154/7 155/1
155/8 155/11 155/16
155/17 156/6 156/13
176/6 179/17 181/7
189/3
Mail [32] 6/2 6/10
6/15 6/17 6/25 7/9
9/21 13/1 13/13 22/8
36/13 37/9 37/12
37/13 37/17 37/18
92/14 111/10 135/7
138/21
Mail's [1] 92/16
mails [1] 144/12
main [7] 32/15 55/20
68/5 69/7 69/10 69/22
101/1
mainly [1] 165/11
mainstay [1] 13/16
maintain [5] 40/16
75/14 75/17 75/24
184/8
maintained [3] 31/21
124/21 184/2
major [14] 37/6 40/18)
69/22 69/24 70/2
70/15 72/10 72/20
79/15 79/16 79/19
105/19 105/22 105/23)
majority [1] 180/2
make [37] 15/10 16/8
22/1 32/3 32/7 43/10
44/16 45/19 55/23
67/19 68/9 72/2 75/21
82/5 85/3 85/4 88/20
90/24 92/21 96/12
100/19 101/3 106/20
117/9 122/11 125/15
128/19 135/13 146/8
158/16 160/4 163/24
167/13 167/18 173/8
176/22 180/13
makes [7] 16/21 24/1
40/15 45/17 47/24
56/3 90/14
lunch [3] 98/11 98/22
Lynn [2] 128/3 128/6
Mac [1] 75/13
23/11 24/7 24/10 26/4
76/6 83/18 86/10 87/6)
119/13 119/24 130/17)
164/23 167/20 175/25)
33/5 36/4 36/10 36/12
37/24 39/1 42/13 43/6)
52/9 70/16 72/11 92/5)
making [11] 4/19
9/24 25/23 35/19
37/19 71/24 142/16
154/14 163/4 179/23
187/24
malign [1] 116/25
22/2 25/2 76/22
136/21 157/12 172/2
managed [9] 6/1
20/10 24/14 65/12
101/21 106/8 172/19
178/6 187/17
management [20]
24/16 53/3 65/20
75/22 85/22 114/5
115/11 117/1 125/25
manager [2] 2/16
118/3
managers [1] 80/23
managing [18] 3/25
5/24 11/5 12/11 13/1
13/20 33/20 35/14
46/11 47/7 88/8
159/16 168/16 179/4
179/12
mandate [5] 4/18
mandatory [3] 181/8
181/14 182/19
manifested [5] 27/25
29/14 66/15 66/17
66/18
manifesting [1]
30/10
manned [1] 38/1
manner [1] 185/9
mantle [3] 7/9 112/6
127/9
manual [1] 178/22
many [4] 42/6 62/18
130/18 179/16
mapping [1] 96/7
March [18] 2/10
13/19 15/1 29/19
29/20 30/1 30/5 30/10)
31/15 62/25 63/1
73/17 95/18 95/20
95/21 110/23 148/7
185/10
March 2010 [2] 29/19]
31/15
March 2025 [1]
185/10
Marilyn [1] 117/25
Mark [7] 46/21 46/23
46/24 47/9 47/15
115/23 116/3
marketing [1] 45/1
marketplace [1] 47/1
manage [8] 4/4 13/11
2/20 3/8 3/11 3/14 6/7
147/22 153/19 157/17]
176/20 176/25 184/16
132/10 145/22 159/12
12/1 14/5 22/13 22/14
marks [1] 78/23
marshal [1] 86/11
Martin [3] 44/24
45/17 45/20
material [1] 116/16
Matt [1] 75/12
matter [10] 77/3
78/15 80/14 138/3
172/16 173/2 173/23
matters [9] 2/2 2/16
9/16 88/17 101/3
104/18 140/2 140/14
141/16
maximum [1] 40/2
may [52] 4/25 14/4
20/3 21/4 25/11 26/9
26/11 33/22 33/24
34/25 35/1 35/18
37/12 38/22 39/10
40/22 41/4 57/10
58/25 67/19 70/24
78/4 78/21 79/22
79/23 79/24 82/16
85/8 87/12 89/3 89/5
89/14 89/15 89/18
90/23 98/9 105/17
147/7 147/8 148/24
153/13 153/16 166/1
168/15 181/4 189/9
maybe [5] 85/12
85/12 93/16 122/1
124/13
McLean [1] 102/13
MDA [3] 123/18
142/19 147/14
me [102] 2/14 6/6
6/23 7/5 8/17 11/10
11/23 12/6 12/12
12/21 15/18 18/3
19/19 19/23 21/15
23/11 25/18 29/19
30/13 35/21 45/2
45/19 48/25 49/1 49/9)
51/23 53/9 53/21
56/10 56/16 57/7 58/8
61/5 61/13 63/2 65/6
65/6 65/11 65/14
66/14 66/14 66/25
67/23 69/14 70/12
70/22 70/23 72/18
74/19 74/19 75/11
76/3 78/21 82/7 88/22,
88/25 91/20 92/19
94/6 98/17 102/21
103/16 105/20 105/24}
106/3 106/6 106/14
110/7 113/14 119/21
125/4 126/10 126/13
128/22 129/24 132/20}
134/15 134/16 135/1
135/13 137/15 138/7
139/12 141/13 167/16)
108/12 121/25 130/20)
134/18 138/15 142/12)
138/8 140/10 145/24
147/10 155/18 166/3
170/5 172/2 172/3
174/8 175/8 177/18
182/8 186/1 187/2
188/2 189/16 190/12
191/2 193/11
mean [21] 5/5 17/6
17/25 21/3 29/18
31/23 33/14 35/3
75/20 77/6 89/22
95/24 117/4 119/21
126/13 134/7 140/11
140/18 143/23 187/4
190/10
means [8] 6/18 22/13
35/21 45/3 49/10
57/13 107/1 135/19
meant [5] 31/24 75/1
81/25 121/10 143/24
meantime [1] 9/14
measure [2] 17/19
57/7
measures [1] 161/23
mechanism [3] 94/18}
155/12 158/10
media [12] 26/16
54/11 55/12 61/3
94/11 94/17 102/18
103/1 103/12 126/16
133/11 134/21
meet [2] 147/20
170/17
meeting [13] 34/5
36/11 51/13 51/13
88/16 88/23 121/3
121/17 121/22 121/24I
141/24 144/16 147/13}
meetings [2] 39/14
88/6
Melanie [1] 193/4
Member [2] 7/24
122/6
members [1] 34/2
memories [1] 131/8
memory [6] 19/23
48/24 49/1 170/5
174/13 193/20
mention [5] 17/7
17/25 21/21 103/6
103/8
mentioned [8] 17/7
18/12 91/20 104/15
122/17 136/13 137/6
177/25
mentions [1] 130/19
mentor [1] 112/3
mere [1] 33/13
merit [2] 113/21
188/4
merits [1] 133/16
message [5] 44/9
118/22 146/5 146/17
173/1
(67) longer... - message
messaging [1] 72/16
met [1] 34/3
metadata [1] 164/19
methodically [1]
159/4
meticulous [1]
126/25
MICHAEL [3] 1/9
1/12 195/2
mid [2] 162/22 181/4
mid-2022 [1] 162/22
116/6 123/12
23/18 23/18 23/22
51/18 52/10 54/21
55/4 55/5 79/17 81/7
84/17 85/1 87/3 87/5
87/10 87/19 87/20
88/25 95/24 97/1
117/17 125/5 125/10
148/10 148/10 158/4
162/10 166/11 168/24}
169/4 170/22 185/21
188/14
migration [1] 163/19
Mike [31] 1/5 9/1
39/12 58/21 61/22
74/2 74/2 74/16 74/18
74/18 75/10 75/13
103/23 106/14 112/19)
112/20 112/21 112/22)
112/24 112/24 114/7
114/7 120/13 120/14
120/14 120/15 120/25)
121/1 121/7 127/8
146/18
Mikes [4] 74/15
74/24 113/3 120/12
million [2] 35/7 36/20
mind [12] 8/12 27/9
30/22 56/18 78/14
86/2 86/21 102/25
109/11 146/20 166/18
172/7
minded [1] 56/7
mindset [2] 126/6
126/7
mine [1] 124/13
minimum [1] 167/7
minute [7] 20/17
20/17 87/21 94/23
108/8 146/9 149/6
minuted [3] 89/22
89/24 89/25
minutes [8] 88/14
93/20 98/16 98/18
98/19 98/23 106/22
messages [1] 26/17
middle [4] 3/2 112/18
might [45] 14/16 20/6
28/13 36/14 37/2 51/7
131/23 138/10 146/13}
160/22 160/24 161/19)
149/17
miraculously [2]
72/8 106/9
mirror [1] 18/22
misheard [1] 153/16
mismatch [16] 23/19
29/21 31/21 31/24
33/14 58/1 63/15 64/6
65/25 68/15 72/5
100/12 100/15 101/10)
101/25 103/9
mismatches [4]
18/18 23/11 76/21
101/23
misnomer [1] 110/13
Misra [9] 114/24
115/2 115/6 115/17
117/20 117/22 119/1
119/4 121/14
miss [1] 106/6
missed [1] 138/7
missing [5] 82/23
85/22 105/25 106/1
106/3
mistakes [1] 188/15
misunderstand [1]
70/12
mitigate [1] 56/9
mitigated [1] 70/14
ing [1] 30/15
mitigations [1] 33/8
mix [1] 61/12
mixture [1] 193/16
Mm [1] 191/14
Mm-hm [1] 191/14
mobile [1] 2/11
model [7] 17/4 17/17
21/16 62/2 65/2 66/3
165/9
modern [2] 82/13
184/7
moment [9] 16/19
61/3 102/19 103/2
142/24 149/20 178/22)
191/10 192/14
Monday [4] 61/23
73/7 73/25 74/11
money [6] 8/8 70/24
145/3 168/16 168/19
171/15
mongering [1] 117/3
Monica [1] 7/20
monitor [3] 160/15
161/20 162/2
monitoring [2] 165/9
175/19
month [6] 13/14 46/5
54/18 92/2 155/16
162/9
monthly [2] 111/17
176/18
months [12] 12/2
22/12 29/17 41/21
54/18 62/12 62/19
92/22 141/23 144/17
155/4 156/4
months’ [1] 144/19
Moores [5] 74/18
75/10 112/20 114/7
118/4
morale [1] 15/16
Moran [2] 44/24
45/17
more [48] 14/7 18/9
20/3 22/8 28/6 28/13
54/9 57/2 69/21 70/11
78/18 82/15 93/8
93/20 94/12 94/12
94/13 94/15 94/22
101/15 112/6 113/3
131/6 131/7 138/15
143/19 143/21 158/12
162/24 163/21 178/21
178/25 184/6 190/2
morning [12] 1/3
57/11 57/20 57/20
57/21 115/4 124/7
128/20 132/1 135/5
144/10 194/9
most [6] 3/16 12/7
48/24 85/5 108/23
128/22
mostly [1] 150/13
mother [1] 26/6
mount [1] 129/9
mounted [1] 129/12
move [8] 14/12 27/21
45/6 57/24 80/7
135/23 177/24 178/18}
moved [4] 13/3 60/10)
111/10 131/10
mover [1] 11/14
moving [4] 46/5
59/22 84/17 175/3
Moya [1] 112/5
MP [3] 8/12 9/3
121/21
Mr [120] 1/24 7/13
8/18 8/23 9/16 16/24
18/12 19/4 20/2 22/1
26/24 33/24 39/4 42/1
46/2 50/3 52/24 53/12
54/19 57/24 58/12
58/20 59/1 59/19
60/23 61/21 62/12
62/22 66/1 66/2 66/13
68/6 71/4 71/23 72/20
72/23 74/16 74/17
76/15 77/19 78/14
80/7 87/25 96/20
96/21 98/4 98/8 98/20
98/23 99/3 99/4
102/13 102/13 103/3
104/8 104/21 105/5
28/14 29/3 29/7 39/18
42/16 43/8 50/18 51/6
115/25 123/15 124/15}
124/15 125/18 125/18}
107/7 107/21 108/10
108/14 109/1 109/2
109/23 111/20 112/7
112/12 112/15 113/7
116/4 118/4 118/4
119/19 130/25 131/8
131/21 133/6 133/25
136/3 137/23 138/17
139/10 141/8 143/2
144/8 145/21 146/16
149/8 150/3 151/20
172/2 172/12 172/22
188/22 188/25 189/1
190/5 190/5 190/12
193/11 193/20 193/21
194/1 195/6 195/16
Mr Bartlett [5] 172/2
172/12 173/17 174/10}
174/13
Mr Brocklesby [1]
189/18
Mr Burley [1] 50/3
Mr Burley's [1] 116/4'
Mr Henry [2] 109/1
109/2
Mr Ismay [10] 58/12
58/20 59/1 59/19
62/22 78/14 112/15
113/7 118/4 133/6
Mr Ismay's [4] 52/24
53/12 60/23 77/19
Mr McLean [1]
102/13
Mr Moores [1] 118/4
Mr Oldnall [9] 149/8
150/3 151/20 184/14
188/22 189/1 189/10
193/21 194/1
Mr Patterson [1]
190/5
Mr Patterson's [1]
190/5
Mr Russell [7] 61/21
62/12 68/6 72/23
74/16 76/15 102/13
Mr Russell's [1] 66/2
Mr Scott [2] 8/23
9/16
Mr Smith [9] 16/24
19/4 20/2 22/1 111/20}
112/7 112/12 113/17
115/10
Mr Stein [5] 98/23
188/25 193/11 193/20}
195/16
Mr Stein's [1] 98/20
Mr Stevens [1]
113/18
Mr Tait [6] 33/24 39/4I
113/17 113/18 115/10)
148/16 148/19 148/20}
173/17 173/18 173/19}
174/10 174/13 184/14)
189/10 189/16 189/18}
42/1 46/2 54/19 96/21
Mr Walton [5] 172/22
173/18 173/19 189/16)
190/12
Mr Wilson [2] 8/18
136/3
Mr Young [41] 1/24
18/12 26/24 57/24
66/1 66/13 71/4 71/23
72/20 74/17 80/7
87/25 96/20 98/4 98/8}
99/4 103/3 104/8
104/21 105/5 107/7
107/21 108/10 108/14)
109/23 119/19 130/25}
131/8 131/21 133/25
137/23 138/17 139/10)
141/8 143/2 144/8
145/21 146/16 148/16)
148/19 148/20
Mrs [1] 136/4
Mrs Karen [1] 136/4
MS [44] 1/10 62/22
73/14 77/20 100/12
101/7 108/5 108/19
109/1 109/21 109/22
111/13 111/20 118/4
131/18 131/19 132/1
132/2 132/9 135/24
137/10 139/8 141/4
141/6 141/18 142/7
142/7 142/23 142/24
142/24 143/7 144/6
146/11 146/17 146/24)
146/25 148/17 149/5
149/25 153/13 195/4
195/8 195/10 195/14
Ms Crichton [1]
77/20
MS HODGE [12] 1/10
73/14 100/12 101/7
108/5 108/19 132/1
148/17 149/5 149/25
195/4 195/14
Ms Page [8] 109/1
109/21 109/22 132/2
132/9 135/24 137/10
195/8
Ms Patrick [4]
131/18 131/19 146/11
195/10
Ms Sewell [7] 62/22
139/8 141/4 141/6
142/7 142/24 146/24
Ms Vennells [9]
111/13 111/20 118/4
141/18 142/7 142/23
142/24 146/17 146/25)
Ms Vennells’ [2]
143/7 144/6
much [28] 1/4 12/8
12/24 20/20 22/5
30/17 82/15 86/25
93/6 94/13 98/25
(68) messages - much
117/11 140/10
much... [17] 127/4
128/6 147/20 148/15
155/3 163/21 172/15
172/15 174/14 178/21
178/25 184/12 186/7
186/17 188/22 194/1
194/6
multiple [1] 113/8
multiplicity [1] 85/6
must [7] 69/1 70/5
72/21 104/11 104/18
125/21 144/17
my [163] 5/2 6/4 6/6
6/7 6/12 6/19 6/21 7/1
7/2 7/3 7/3 7/4 8/7 8/8
8/14 9/15 9/18 10/22
10/22 11/1 11/2 11/2
11/3 11/11 11/20
11/21 11/23 11/25
13/8 13/10 14/8 14/10)
14/11 15/14 15/14
16/20 22/6 22/14 24/1
26/6 26/25 30/6 30/12
30/22 30/23 30/23
31/7 32/17 32/20
32/25 33/4 33/17 36/3
37/17 41/1 41/4 41/7
43/2 43/18 44/6 45/2
45/14 48/4 48/24 49/1
49/8 51/2 51/7 52/3
52/25 53/4 53/16
53/18 54/13 55/3 56/2
56/10 56/11 56/18
63/3 65/19 66/9 66/21
67/1 69/20 72/13
77/25 80/5 81/5 81/19
83/2 83/2 83/3 84/9
84/13 85/4 87/7 89/8
90/14 91/6 91/17
92/22 92/25 93/14
94/14 95/10 95/17
95/19 96/2 96/16 97/5
99/4 103/17 106/11
108/15 109/9 111/2
111/15 112/4 113/15
118/6 118/18 121/4
121/20 121/24 123/4
126/6 126/7 128/15
128/20 129/4 131/16
131/21 135/20 136/19)
140/16 142/18 149/21
150/13 153/9 154/1
155/3 155/10 161/17
162/1 166/4 172/1
172/5 172/12 173/12
173/13 173/13 180/3
184/24 189/13 189/14}
190/11 190/19 190/23
191/12 192/4 192/25
193/20
myself [6] 93/1
112/21 112/24 113/3
N
nagging [2] 124/14
124/18
nailed [1] 91/12
name [10] 1/11 93/5
94/6 99/4 117/24
128/15 131/2 131/21
138/12 150/1
named [2] 153/25
169/21
names [2] 27/9
130/16
narrowly [1] 182/22
nationwide [1] 127/2
naturally [1] 43/20
nature [13] 32/13
84/4 89/21 119/14
154/16 171/22 186/6
186/15 186/24
NBIT [1] 188/20
NBSC [1] 76/17
nearer [1] 92/13
necessary [4] 38/18
47/12 169/12 182/19
necessitated [1]
70/17
necessity [1] 87/3
need [25] 6/6 26/8
37/25 44/13 63/21
87/22 94/2 96/7 96/14)
99/16 102/15 106/14
107/16 111/9 124/11
127/3 134/5 136/7
147/20 154/13 171/20}
172/4 174/7 192/21
193/9
needed [9] 32/20
45/21 55/9 94/12
115/15 131/11 131/12)
137/16 148/10
needs [5] 15/24
84/21 96/4 96/6 103/7
negative [1] 145/2
negligence [1]
167/12
negotiating [1] 45/20
negotiation [3] 13/11
14/7 92/25
negotiations [2] 92/4
123/18
Neil [4] 11/11
neither [1] 21/7
network [31] 2/11
5/15 5/21 11/9 16/25
17/8 17/23 18/5 18/10
20/22 24/24 29/23
36/19 42/25 55/21
62/9 72/9 74/9 79/22
82/17 96/9 97/17
97/25 154/17 165/8
165/24 166/3 166/5
51/25 53/5 69/13 78/7,
169/1 175/20 178/6
network-related [1]
17/8
never [6] 32/5 44/4
47/23 89/8 89/10
122/5
new [30] 12/25 17/14
26/22 32/8 36/19
55/11 60/7 66/9 66/11
67/23 67/25 71/25
72/22 76/21 106/7
158/9 159/12 159/18
160/5 162/8 162/9
165/8 181/8 184/14
184/22 184/25 184/25)
185/8 187/10 187/15
news [1] 118/6
next [17] 32/19 41/23
55/22 55/25 100/24
100/25 108/11 133/22}
142/1 144/4 144/7
144/25 146/12 149/5
149/19 179/25 191/6
NFSP [1] 74/10
nitty [4] 133/7
nitty-gritty [1] 133/7
no [97] 5/15 5/19
9/15 10/10 10/12
13/22 16/4 17/3 17/7
17/24 18/2 20/5 21/1
21/16 23/16 23/21
30/11 30/18 32/12
40/3 40/19 44/2 44/2
48/16 49/10 49/20
50/10 54/2 59/10
60/15 61/17 61/20
62/20 63/2 63/7 64/14
69/10 70/12 70/22
88/11 91/3 94/3 98/4
100/19 102/25 103/6
103/8 103/10 103/10
103/11 103/13 103/16}
103/16 107/10 108/1
110/2 111/9 112/12
116/9 116/22 117/12
119/9 119/10 119/20
122/18 125/4 126/8
128/8 128/14 128/24
129/2 130/10 134/25
140/10 143/3 147/4
147/5 148/3 148/8
148/14 149/18 155/23
156/5 159/6 169/1
172/12 181/22 182/6
188/6 188/22 190/9
190/11 191/2 191/3
192/20 193/3 193/21
nodded [12] 4/8
156/12 156/21 158/3
160/11 170/13 171/9
172/23 176/3 177/3
181/5 186/23
nodding [3] 58/8
143/2 175/8
noise [1] 66/24
non [3] 150/6 168/15
168/23
non-compliant [2]
168/15 168/23
non-statutory [1]
150/6
None [1] 48/3
nonetheless [2]
93/18 173/16
nonsense [1] 116/21
nor [2] 80/23 173/25
norm [2] 10/9 33/1
normal [5] 30/24
62/3 63/12 78/20
140/15
normally [4] 69/20
154/20 160/25 161/11
Northern [1] 47/7
not [172] 5/13 6/6 6/8
8/7 8/16 10/11 11/7
13/21 14/6 15/23
16/18 17/1 19/10
21/10 21/10 27/8 28/7,
30/23 30/24 31/6 32/6)
32/15 33/14 35/10
35/23 36/1 40/19
41/22 41/23 46/3
47/12 47/23 49/3 49/3)
49/10 49/25 50/19
50/21 51/15 52/8 53/4
53/21 54/8 54/14
55/22 56/10 56/11
60/3 62/1 63/12 63/16
64/12 65/1 66/9 66/16
66/21 67/15 68/20
69/5 70/19 70/20
70/21 71/3 71/4 71/7
73/1 74/25 75/5 75/22,
76/9 76/21 76/24
77/22 77124 78/4
80/20 80/23 81/9 81/9
82/12 83/7 84/12
84/14 87/17 88/10
88/10 90/8 90/15
91/12 98/24 99/1
101/3 101/17 103/10
103/16 105/4 105/14
105/20 107/12 107/22
109/3 110/9 110/10
111/25 113/14 113/20}
114/21 115/3 115/13
115/16 115/21 117/8
117/18 118/12 118/21
118/25 119/3 119/6
119/8 119/15 119/15
122/9 122/16 122/16
123/17 126/13 127/6
128/9 130/22 130/23
131/7 136/11 136/16
136/24 137/3 137/4
141/20 143/6 144/23
145/4 145/16 147/24
148/22 153/9 157/9
161/25 164/10 164/16
167/8 168/2 172/12
173/4 173/25 174/6
174/7 178/1 179/2
183/9 184/15 185/1
185/3 185/13 187/10
187/16 188/6 189/13
190/7 190/9 190/22
191/2 192/17 193/3
notable [1] 130/8
note [5] 37/9 44/15
60/15 89/9 145/15
noted [1] 156/5
notes [2] 193/14
193/16
nothing [25] 15/17
16/8 19/24 19/24 21/9)
21/18 31/22 31/25
56/24 64/1 69/15
69/16 69/25 70/1 78/2
78/5 89/19 105/2
113/24 118/16 124/21
128/11 140/13 148/9
148/13
notice [1] 130/25
notified [4] 62/13
69/11 70/8 72/25
notify [3] 68/17 68/20]
162/15
notifying [2] 192/2
192/6
noting [5] 44/18
79/25 95/19 100/8
169/23
November [2] 123/6
123/9
November 2011 [1]
123/6
now [118] 12/2 16/6
18/6 26/5 28/6 28/16
29/8 31/4 31/8 33/19
38/16 39/4 39/25 40/2
41/20 45/14 45/15
47/4 47/11 47/20 48/8)
54/15 55/20 56/14
57/12 57/24 64/5
66/19 69/7 70/4 70/6
71/13 77/2 77/17
78/14 80/13 83/25
84/16 85/5 86/2 86/20}
89/6 91/18 92/14 93/6I
93/21 94/5 94/8 94/11
99/9 100/11 100/23
101/1 103/5 103/25
104/4 105/12 107/22
108/4 109/9 110/23
114/23 118/14 121/18}
124/10 125/8 126/5
127/12 127/25 128/3
129/14 129/22 132/1
132/4 132/21 133/5
133/21 134/11 135/22)
135/24 137/11 137/20)
138/25 140/4 141/3
(69) much... - now
N
now... [33] 141/14
141/18 141/21 142/1
142/20 144/12 145/21
146/23 148/4 153/22
157/8 160/14 162/5
162/20 163/24 164/4
166/1 170/5 171/22
172I/7 172/21 174/9
176/12 176/18 182/7
184/15 185/13 185/20
186/19 188/3 188/19
189/10 191/15
nuance [1] 49/13
nuanced [2] 174/7
174/11
number [51] 4/9 6/8
9/18 11/18 14/10
17/23 22/7 22/11 29/1
30/11 30/12 33/12
41/21 49/20 81/2
82/20 86/25 88/1 95/9
95/10 99/6 100/11
119/25 120/6 121/23
131/22 133/24 136/1
136/2 153/10 160/17
161/23 162/1 162/10
162/11 162/17 165/21
167/6 167/22 168/21
174/15 174/21 175/14
177/6 177/7 180/13
183/25 184/20 184/22)
185/25 186/1
numbering [1]
112/11
numbers [2] 29/22
130/1
oO.
objection [1] 182/11
objective [1] 173/22
objectives [1] 45/2
obliged [1] 68/17
obtain [1] 3/9
obtained [2] 3/6
80/25
obviously [15] 29/12
60/18 108/9 121/18
127/10 160/17 171/16}
174/9 174/14 174/18
185/25 188/3 188/11
190/14 191/4
occasion [6] 9/24
9/25 28/6 89/3 105/17
179/5
occasionally [2] 88/6
97/9
occasions [2] 89/18
104/17
occur [5] 20/25 25/11
64/13 64/21 64/23
occurred [7] 20/23
61/25 64/9 75/19
105/18 150/14 181/20)
occurs [1] 59/22
October [12] 1/1 12/2
86/13 111/11 119/4
138/2 139/4 140/22
142/2 144/7 148/7
152/6
October 2011 [1]
142/2
odd [1] 172/10
off [21] 7/2 25/19
37/11 44/10 45/13
63/20 74/3 75/6 89/20
91/9 103/20 125/24
126/19 145/4 147/14
158/18 167/7 167/8
192/1 192/6 192/25
offence [1] 52/15
offences [2] 5/8
71/20
offering [1] 171/18
office [160] 3/23 3/24
4/16 4/17 4/23 5/6
5/15 5/25 6/5 6/13
6/14 7/8 7/25 9/3 9/7
10/15 10/22 11/13
12/24 13/10 13/12
14/9 14/12 14/24 15/4
15/7 15/15 17/4 17/5
17/17 18/19 18/21
19/22 21/16 22/6
22/25 34/2 35/6 35/9
36/5 41/17 44/8 44/18)
45/1 46/12 48/5 50/6
50/8 51/8 52/14 53/24
56/6 62/2 65/2 66/4
69/4 71/1 71/17 73/2
76/9 77/13 79/12 83/9
88/15 90/2 90/5 90/17)
91/2 92/5 92/22 96/24
97/7 97/22 97/24
99/11 100/6 101/21
103/7 104/6 111/12
114/5 116/22 117/1
117/4 118/10 119/24
121/15 121/23 126/25)
127/5 134/7 135/1
135/8 136/1 136/20
139/21 145/1 147/7
150/10 150/15 152/14)
152/17 153/2 153/19
154/25 155/8 156/10
156/19 159/23 159/24)
162/6 163/13 164/25
167/16 168/2 168/13
168/20 169/4 169/6
169/10 169/15 170/23}
1714/7 174/17 171/23
172/7 173/6 173/10
173/24 174/19 175/4
175/15 176/14 178/19)
179/10 181/17 181/18)
181/21 181/25 182/4
182/5 182/10 182/11
182/25 183/4 183/4
183/7 183/9 183/11
183/14 183/17 183/20
185/9 186/7 186/20
188/14 191/7 191/16
192/2 193/2
Office's [10] 34/18
95/3 100/1 164/8
168/8 168/14 175/7
179/4 186/21 190/2
officer [16] 2/6 2/23
12/3 12/14 12/16
12/20 13/5 13/8 13/17,
13/23 14/3 14/17 49/9
53/9 109/23 122/9
officer's [1] 48/12
offices [3] 27/16 81/4
81/7
often [4] 43/19 81/24
96/10 158/5
okay [39] 56/10
56/15 67/12 72/9
82/12 83/1 83/5 94/24]
95/7 96/3 96/18 99/8
100/11 102/11 102/24
103/21 106/3 106/6
107/11 123/21 124/14]
124/18 125/1 125/10
125/22 128/24 129/2
130/1 135/21 137/20
147/10 148/15 153/16}
164/21 189/4 190/14
191/13 191/20 193/7
old [3] 66/10 66/10
74/25
Oldnall [14] 149/8
149/19 149/24 150/2
150/3 151/20 174/8
184/14 188/22 189/1
189/10 193/21 194/1
195/12
on [237]
once [5] 32/22 62/5
90/5 128/15 183/21
one [87] 5/10 6/21
9/4 14/2 14/14 14/14
17/3 17/7 17/25 18/3
20/4 23/16 27/10 28/6
34/5 37/7 38/22 38/23
41/15 44/9 44/10
44/16 45/2 45/8 45/17,
46/5 50/9 50/11 50/15
53/16 55/15 66/10
67/10 70/21 70/22
72/21 73/12 82/24
84/6 84/9 84/23 89/17I
94/7 95/25 96/4 97/6
100/19 101/23 106/10
106/25 107/1 109/25
112/14 113/4 115/16
117/24 120/1 120/9
125/17 126/17 129/2
129/12 132/3 133/7
134/4 135/4 137/15
137/20 153/18 153/25}
156/13 157/1 157/2
158/9 162/25 163/3
167/23 170/18 173/20}
175/5 175/24 184/13
184/18 190/10 190/20}
190/23 194/2
onerous [1] 35/1
ones [3] 85/14
107/21 130/18
ongoing [7] 39/17
49/2 157/16 171/14
173/11 175/3 177/2
online [45] 11/22
15/20 17/11 17/21
23/6 24/18 26/3 26/23,
27/1 27/20 27/20
27/22 29/7 32/12 35/7,
35/11 38/5 38/20
42/10 42/23 43/5
43/13 47/10 54/21
54/23 66/5 66/16
67/21 67/22 68/4
68/23 69/17 70/10
71/9 71/12 71/15
71/25 72/4 76/4 82/14,
84/18 87/12 87/15
132/7 140/20
only [22] 9/19 15/23
18/20 35/10 38/22
42/6 43/23 63/10
69/23 100/5 104/22
106/20 119/1 121/21
125/6 129/4 131/24
132/3 145/13 153/9
157/9 174/25
onto [2] 119/23 172/4I
onus [1] 48/22
open [6] 34/12 35/20
38/7 43/18 125/12
173/22
operates [1] 183/10
operating [18] 12/14
12/16 12/19 13/5 13/8}
13/17 13/23 14/17
16/25 17/6 17/22 27/5}
84/8 101/4 105/20
109/23 122/9 165/9
operation [15] 27/7
28/14 68/3 68/8 68/22,
68/23 70/9 71/8 71/15)
79/4 79/10 79/21
99/12 99/20 107/23
operational [8] 5/2
20/25 21/22 25/11
26/2 26/10 39/18
68/13
operations [12] 3/4
3/24 4/3 4/9 10/17
12/3 12/15 13/6 14/3
14/5 14/17 104/4
opinion [2] 53/19
189/21
opportunity [4] 12/9
44/12 147/20 188/18
opposed [4] 51/2
65/9 165/24 192/19
options [4] 167/22
167/25 168/24 169/14I
or [156] 3/6 5/16 6/7
7/3 9/19 11/4 12/13
13/13 15/19 16/5
16/24 18/3 18/9 19/25I
20/12 20/12 23/9
23/10 23/17 23/19
24/9 25/7 25/16 27/8
32/10 32/24 34/10
35/18 37/12 38/24
42/17 46/25 49/3
49/11 49/21 50/9
51/15 52/9 52/9 53/1
53/24 54/18 55/2
55/12 55/14 56/1
56/13 57/2 62/2 63/5
64/10 65/2 66/4 68/15}
68/22 69/11 72/22
73/20 74/18 76/12
78/5 78/12 79/25
80/21 80/21 80/22
80/23 81/15 82/9
82/10 82/17 83/18
84/23 86/18 88/8
88/12 88/24 89/5 89/5
89/11 89/13 89/17
91/3 92/12 92/22 94/7
94/15 94/23 95/1
99/21 103/17 103/17
105/4 106/2 106/14
106/19 106/25 108/18}
109/1 113/12 113/22
113/22 113/25 115/13)
415/15 117/2 117/4
117/17 118/15 122/1
122/6 127/6 128/15
134/20 134/21 136/23)
137/5 140/11 140/13
140/13 143/3 144/1
144/24 147/21 149/20)
153/14 156/6 160/6
160/23 161/10 164/5
166/14 167/10 167/12)
169/1 169/11 176/17
177/25 180/16 180/17
181/16 181/16 181/17)
181/19 181/22 181/25)
182/3 182/3 182/6
182/22 183/3 185/3
188/5 190/5 192/2
192/11
Oracle [22] 26/4 26/5
29/9 29/11 29/13 30/3
31/17 31/18 31/20
40/8 40/10 43/21
56/14 56/25 67/1 67/6
70/12 70/13 72/6
105/13 106/5 107/24
orally [1] 59/2
Orange [5] 2/11 2/15
(70) now... - Orange
[e)
3/10 3/12
Orange Plc [1] 2/11
order [7] 23/24 35/16
42/15 82/10 150/20
164/24 179/20
organisation [2]
188/7 188/11
original [11] 67/1
88/16 105/13 106/5
106/10 107/24 143/7
143/8 146/5 153/2
185/24
originally [5] 40/3
51/7 101/7 141/21
186/8
originates [1] 47/13
other [48] 8/24 11/18
16/15 17/11 18/9
20/20 22/18 23/19
35/15 35/18 38/14
38/23 51/15 51/16
52/2 55/6 57/3 70/19
72/19 76/2 78/6 79/25)
82/6 87/17 90/23 94/9
95/8 105/17 110/8
110/12 112/1 117/12
119/13 127/9 133/6
138/12 143/14 148/16
161/13 163/23 169/13}
179/22 180/3 181/19
183/7 186/19 189/20
189/23
others [13] 8/25
38/18 60/25 98/2
102/16 107/2 107/7
107/17 116/3 120/10
133/19 134/6 186/14
others’ [1] 185/19
otherwise [6] 55/2
55/12 56/13 106/21
117/13 140/13
ought [5] 37/3 71/17
100/9 148/12 178/15
our [45] 1/5 24/24
34/3 34/4 34/4 34/15
34/25 35/8 36/8 38/3
40/4 40/12 40/15 41/5)
A1/7 41/16 41/22
43/25 44/3 47/3 57/11
80/8 91/10 94/2
108/21 123/14 126/12)
127/20 128/21 131/11
131/12 134/19 145/18)
149/9 149/19 154/23
163/19 163/20 174/19}
176/16 177/9 188/21
190/16 190/21 190/24
ours [2] 24/10 108/23)
ourselves [1] 95/22
out [65] 5/25 21/2
21/3 24/2 26/8 26/16
Orange... [3] 2/22
28/25 32/2 32/19 33/1
35/7 35/15 35/19 40/2
48/17 48/20 49/1
51/20 55/12 66/16
67/7 73/24 76/10 86/5
96/23 97/14 101/1
101/22 104/8 105/23
106/3 112/23 114/21
115/12 117/7 122/24
122/25 123/25 128/7
130/5 130/13 142/19
145/13 147/16 149/20)
160/25 161/24 162/18)
166/21 168/22 171/23)
172/2 17717 177/14
183/17 185/20 187/16)
187/20 187/25 188/8
188/12
outcomes [1] 167/7
outfall [1] 101/19
outlay [4] 77/22
77/23 94/11 94/17
outline [1] 73/21
outlined [1] 61/24
output [3] 85/19
134/21 177/17
outputs [2] 36/8
129/5
outside [1] 158/21
outsourced [1] 24/6
outstanding [2]
187/20 188/9
outwith [1] 104/6
over [29] 6/8 8/6
13/14 14/11 16/18
22/11 26/22 27/11
31/13 58/5 60/7 81/16
82/1 85/24 92/5 97/23)
100/23 131/25 133/22)
134/10 135/24 164/3
165/21 170/12 172/14)
178/13 179/11 184/15)
187/23
overall [3] 37/1
159/25 182/18
overlapping [1] 6/1
overlay [1] 106/2
overnight [1] 31/3
overriding [1] 44/9
overseeing [3] 4/11
5/24 71/19
oversight [9] 5/17
9/15 43/5 62/15 82/20
111/12 111/16 175/15)
179/11
overview [3] 16/22
17/16 108/9
owe [1] 148/21
own [26] 3/19 24/8
24/10 36/8 44/1 44/3
45/22 45/22 81/5
92/15 99/25 103/17
103/19 110/17 110/19)
40/22 45/5 46/25 47/5
111/1 120/1 123/4
129/23 134/7 163/9
164/3 168/8 175/18
180/7 183/12
owned [4] 45/13
100/2 100/2 162/5
owns [2] 99/22 99/22
P
Pacific [1] 3/2
pack [1] 160/3
page [54] 1/17 7/17
7/19 15/12 19/6 31/12
31/13 31/13 39/7
40/23 58/18 58/24
58/24 59/20 60/22
88/4 102/7 109/1
109/21 109/22 112/11
112/12 112/16 112/18}
113/17 115/13 116/1
118/1 118/24 126/22
129/16 130/12 132/2
132/9 133/9 133/10
133/22 135/24 136/8
136/9 137/10 137/22
138/23 141/3 151/1
151/13 151/24 152/8
164/17 167/21 169/7
169/18 171/1 195/8
page 1 [4] 7/19 40/23
58/24 59/20
page 13 [1] 58/24
page 14 [1] 19/6
page 15 [2] 31/12
151/1
page 16 [1] 31/13
page 19 [2] 112/11
133/9
page 2 [4] 7/17
126/22 138/23 141/3
page 22 [1] 113/17
page 255 [1] 151/13
page 3 [3] 60/22
129/16 164/17
page 35 [1] 118/24
page 36 [1] 88/4
page 4 [5] 58/18
102/7 116/1 167/21
171/1
page 41 [1] 151/24
page 44 [2] 136/8
136/9
page 5 [1] 169/7
page 58 [1] 1/17
page 6 [2] 152/8
169/18
page 76 [2] 112/12
112/18
pages [6] 1/16
113/17 150/25 151/12
151/24 152/7
pages 87 [1] 113/17
paid [4] 8/9 50/17
148/12 192/6
palpably [1] 148/22
61/24 86/14 95/20
170/5
papers [2] 45/18
89/10
paragraph [27] 8/18
15/13 19/5 31/11
66/6 67/13 67/14
67/16 69/6 74/14
75/11 76/14 88/3
116/4 116/6 118/24
136/9 137/1 137/2
137/7
paragraph 110 [1]
118/24
paragraph 111 [1]
88/3
paragraph 143 [2]
136/9 137/7
paragraph 145 [1]
137/2
paragraph 2 [1]
116/4
paragraph 30 [1]
15/13
paragraph 41 [1]
19/5
paragraph 46 [4]
31/11
paragraph 92 [1]
54/6
80/10 80/14
paragraphs 52 [1]
80/10
parallel [2] 156/17
157/13
parameters [2] 42/22
120/3
paraphrase [1] 99/15
paras [1] 58/23
parcel [1] 140/9
Parcelforce [1] 12/10
parishioners [2]
125/21 126/15
Park [1] 193/4
Parliament [8] 7/24
120/8 121/19 122/6
122/11 123/7 123/24
126/15
Parliamentary [1]
123/11
part [58] 5/1 9/24
11/3 11/20 13/10
15/21 17/9 20/23
25/13 27/15 27/18
29/1 32/3 32/20 35/12
35/19 42/14 47/6
49/21 50/14 50/22
51/6 52/25 59/22
69/12 70/3 70/14
paper [6] 44/18 58/21
36/24 38/7 39/21 54/6
123/13 133/15 133/23}
paragraphs [3] 59/19)
70/15 72/18 76/3 79/8
79/18 82/14 84/16
99/17 106/5 110/4
114/8 115/2 115/19
116/25 130/21 133/7
133/9 133/11 133/11
135/8 140/9 141/15
143/6 144/25 154/24
159/9 161/25 162/1
169/24 170/4 182/11
partial [1] 89/7
Participant [1] 136/5
Participants [4] 98/7
108/17 108/18 193/24)
particular [23] 7/4
17/9 24/12 38/17
51/14 58/23 77/3 89/2I
111/12 120/24 122/3
135/17 136/20 156/5
166/14 166/14 172/11
175/25 177/11 177/16)
180/12 188/16 190/20)
particularly [18]
28/12 68/10 101/11
129/6 132/15 132/18
155/17 164/1 166/12
172/12 176/9 177/13
182/15 186/16 186/21
187/9 187/14 187/18
parties [4] 34/16
42/14 82/20 163/1
partner [1] 34/10
Partners [1] 141/21
partnership [1] 4/5
parts [4] 3/16 57/3
179/22 189/24
party [7] 38/11 40/20
41/11 42/2 51/16
97/21 132/6
pass [3] 52/3 118/6
118/18
passing [3] 89/3
119/22 119/22
password [1] 85/11
past [9] 48/5 49/16
67/21 68/24 72/3 94/8
121/1 134/10 188/15
Patrick [5] 131/18
131/19 131/21 146/11
195/10
patterns [1] 193/5
Patterson [2] 189/8
190/5
Patterson's [1] 190/5)
Paula [23] 12/13 13/1
13/4 13/20 14/6 14/15)
88/9 89/5 95/4 110/10
110/24 112/1 114/7
121/3 127/7 127/13
138/1 143/23 147/8
147/12 147/16 147/19)
147/20
Paula's [3] 12/20
95/13 110/21
(71) Orange... - Paula's
Pp
Pause [1] 149/22
paused [2] 28/4
166/24
pausing [3] 35/3
62/11 135/5
pay [8] 24/11 24/11
74/4 75/7 95/2 165/3
168/4 192/1
paying [1] 35/23
payment [2] 72/5
76/21
payments [6] 18/18
58/1 58/20 63/15 64/6
70/23
pays [1] 192/24
pdf [2] 127/22 127/24
PEAK [1] 63/9
Pen [2] 141/20
144/18
pending [2] 63/23
170/19
Pensions [1] 152/23
penultimate [3] 8/18
74/13 80/8
people [30] 6/18
12/16 14/10 17/1 21/1
22/7 85/15 94/7 96/11
97/3 97/8 97/12 97/16
97/19 98/2 103/22
104/25 105/20 112/14}
113/8 114/9 117/11
117/24 118/13 127/9
127/25 128/7 128/22
129/13 178/24
people's [2] 87/18
110/8
per [5] 28/8 42/24
55/9 62/3 111/2
per se [1] 28/8
perceived [1] 125/10
perception [1] 134/6
perfect [2] 96/14
128/12
perfectly [1] 80/3
performance [3]
161/24 162/3 175/20
performed [1] 159/21
performing [1] 160/9
perhaps [8] 33/11
42/15 42/16 51/7
51/12 120/9 130/22
146/23
period [5] 13/15
28/13 155/16 165/12
192/9
periodic [1] 39/17
periodically [1] 27/17
permission [4] 81/24
81/25 91/15 130/9
persist [1] 29/4
person [2] 82/8
103/22
personal [7] 27/6
103/19 103/25 119/11
personally [5] 51/23
191/2
perspective [3]
persuading [1] 135/2
pertinent [1] 92/11
phase [4] 40/17
40/19 162/20 163/3
phases [1] 158/2
phone [12] 32/8
38/24 42/18 85/20
92/25 95/9 95/9 95/14
106/10 131/9 146/25
147/21
physical [3] 11/14
163/20 184/7
physically [1] 15/1
pick [6] 12/25 49/13
51/17 116/6 130/15
146/25
picked [3] 18/1 74/25
75/1
piece [8] 49/22 56/16
57/6 114/19 142/12
170/17 177/8 178/14
pieces [2] 22/11 55/7
pilot [43] 23/7 26/6
27/21 27/25 28/12
28/19 28/22 29/15
31/17 32/4 32/5 32/15)
33/2 33/2 33/3 35/19
36/1 36/16 39/25 40/7
40/16 42/24 62/2
64/23 65/2 65/8 65/18
66/2 66/4 67/21 68/24
69/5 70/3 70/6 70/14
76/3 76/6 76/13
100/22 100/23 100/24)
101/18 158/9
Pinterest [1] 138/9
Pintest [2] 138/10
138/11
pivotal [1] 34/17
place [31] 6/8 7/12
13/3 14/14 14/19 15/5)
22/2 22/24 32/17
35/10 42/7 55/8 56/15)
72/16 73/10 79/3
79/10 80/2 84/1 95/13
95/15 111/2 120/23
123/4 155/12 155/25
159/16 160/15 161/20}
162/2 162/15
plainly [1] 146/1
plan [6] 35/22 78/24
142/2 142/8 185/18
185/21
planned [2] 17/11
163/12
plate [1] 39/3
187/19 187/22 188/17)
118/22 136/24 188/14,
131/12 133/18 137/12)
platform [2] 174/19
174/20
play [6] 34/17 67/21
77/17 84/15 85/18
110/4
played [3] 26/16
42/14 117/7
playing [2] 51/5
84/19
please [98] 1/8 1/11
117 7/11 7/17 7/19
8/3 8/16 8/22 9/2
15/12 15/13 19/5
27/21 31/10 31/13
31/23 33/19 33/22
39/6 39/7 39/21 40/23
46/5 46/17 46/20
47/19 48/19 54/7
57/15 57/24 58/16
58/18 58/21 58/23
59/14 59/20 60/21
61/15 66/14 66/23
68/25 72/1 73/4 73/16
74/13 78/22 79/7 80/7
80/12 81/1 88/4 102/5
102/7 102/9 102/10
112/9 116/1 117/21
117/25 118/6 118/23
120/12 121/4 123/8
126/17 126/22 129/17)
137/20 138/23 141/1
149/23 150/1 150/16
151/1 151/8 151/13
152/8 153/7 154/3
158/11 159/22 160/14]
161/16 164/13 164/17
167/21 169/7 169/7
169/18 171/1 171/4
172/21 173/17 176/5
177/24 181/11 190/24
pleased [1] 39/22
plus [1] 74/8
pm [5] 109/14 109/16
149/12 149/14 194/11
poachers [1] 53/8
point [102] 12/7 13/3
15/22 18/20 21/17
28/24 30/9 30/19
30/19 30/20 32/3 32/7
32/15 32/25 35/19
42/25 44/16 44/24
45/19 45/22 47/20
47/24 47/25 48/2 48/8
49/8 49/15 50/3 50/19
50/25 55/23 56/19
60/11 67/5 67/19 68/9
71/24 72/2 78/22
81/12 81/20 82/5 84/8
84/17 85/4 85/13
88/20 90/19 90/24
91/1 91/16 92/11
92/21 93/20 93/21
94/5 94/8 94/9 94/21
94/25 96/16 102/24
105/15 105/22 106/13
106/20 108/2 108/21
110/18 117/9 119/12
119/25 123/19 123/25]
124/7 124/15 126/2
126/4 126/6 126/8
128/25 130/25 134/24}
135/12 135/13 137/15]
140/16 140/22 142/2
142/17 142/21 143/24}
144/3 146/1 146/8
147/12 148/7 155/11
164/22 165/13 167/24}
173/19
point 4 [1] 164/22
point 3 [1] 165/13
pointed [1] 96/23
pointing [3] 67/7
76/10 123/25
points [5] 47/16
47/19 88/1 119/25
167/13
poised [1] 88/21
POL [31] 4/19 6/4
9/21 11/25 11/25
16/20 33/4 37/10
37/11 37/14 39/1 39/2
42/12 43/7 44/18
44/19 49/16 69/21
70/16 72/11 78/7
79/18 79/20 94/2
109/24 112/1 119/6
120/18 133/16 137/4
144/24
POL00019281 [1]
7IN4
POL00026572 [1]
133/8
POL00029611 [1]
73/15
POL00120481 [1]
46/20
POL00120561 [1]
121/11
POL00169170 [1]
117/21
POL00176467 [1]
138/23
POL00188387 [1]
59/15
POL00294928 [2]
137/21 141/1
POL00295067 [1]
123/7
POL00338400 [1]
126/18
POL00417094 [1]
120/11
POL00424359 [1]
115/23
POL00448362 [1]
164/14
police [25] 2/6 6/19
48/12 49/9 53/9 104/3)
104/13 104/16 104/20)
170/23 171/10 171/14}
171/18 171/20 171/25)
172/5 172/16 172/19
173/3 173/6 173/11
173/15 173/21 189/22)
189/23
policed [1] 125/5
policeman [3] 6/17
7/1 51/2
policeman's [1]
134/12
policies [1] 169/3
policy [1] 168/11
poor [1] 160/23
portable [1] 184/25
portfolio [2] 11/9
97/15
position [14] 106/24
107/7 113/24 114/20
124/9 164/8 164/10
165/6 168/11 174/17
174/23 174/25 176/23)
190/22
positive [2] 55/22
74/24
possession [1] 90/6
possibility [3] 20/7
41/17 147/17
possible [7] 20/4
83/15 86/10 101/3
107/1 130/19 167/6
possibly [6] 38/18
60/25 102/15 104/22
107/16 146/41
post [171] 3/23 3/24
4/16 4/17 4/23 5/6
5/15 5/25 6/5 6/13
6/14 7/8 7/25 8/4 9/3
10/15 10/22 11/13
12/24 13/10 13/12
13/22 14/9 14/12
14/24 15/4 15/6 15/15)
17/5 18/19 18/21
19/22 22/6 22/25 34/2)
34/18 35/6 35/9 36/5
41/17 44/8 44/17 45/1
46/11 48/5 50/5 50/8
51/8 52/14 53/23 56/6
61/25 69/3 71/1 71/12I
7117 71/25 73/2 76/4I
76/9 77/13 79/12 83/9)
83/14 88/15 89/24
90/2 90/5 90/17 91/2
92/5 92/22 95/2 96/24
97/7 97/22 97/24
99/11 100/1 100/6
101/21 103/7 104/6
111/12 114/5 116/22
4117/1 117/4 118/10
119/24 121/15 121/22)
126/25 127/4 134/7
135/1 135/8 136/1
136/19 139/21 145/1
(72) Pause - post
P
post... [70] 147/6
150/10 150/15 152/14}
152/17 153/2 153/19
154/25 155/7 156/10
156/19 159/23 159/24}
162/5 163/13 164/7
164/25 167/15 168/2
168/8 168/12 168/14
168/20 169/4 169/6
169/10 169/14 170/23
17116 171/17 171/23
172I/7 173/6 173/10
173/24 174/19 175/4
175/7 175/14 176/13
178/19 179/4 179/10
181/17 181/18 181/21
181/25 182/3 182/4
182/10 182/11 182/25
183/4 183/4 183/7
183/9 183/11 183/14
183/17 183/20 185/9
186/7 186/20 186/21
188/14 190/2 191/7
191/16 192/2 193/1
post-Go [1] 71/12
post-Horizon [1]
76/4
post-rollout [1] 71/25]
post-separation [1]
13/22
postmaster [15]
83/20 161/9 161/10
164/11 165/3 167/14
169/14 172/14 176/15}
180/9 181/17 181/25
183/4 192/18 192/22
postmasters [24]
21/23 50/4 52/17 97/1
101/20 130/2 158/14
158/17 158/19 162/15
162/18 163/11 163/22)
164/2 165/1 165/11
168/3 169/1 169/5
169/7 172/8 175/2
183/5 188/21
potential [10] 5/14
5/20 7/7 30/22 136/24
137/3 145/14 181/18
181/19 183/7
potentially [12] 90/18)
105/17 116/24 118/18}
130/5 134/22 135/14
146/7 161/12 168/22
186/7 187/16
power [1] 45/4
powers [1] 109/9
PR [1] 122/2
practicalities [4]
22/5 22/22 178/2
179/3
practice [5] 34/8
34/20 78/20 125/11
140/15
practices [2] 96/6
168/25
pre [1] 135/6
pre-Ismay [1] 135/6
precisely [2] 29/15
29/16
predecessors [1]
152/24
prefer [1] 105/7
pregnant [2] 32/19
119/7
preparation [2] 88/22
113/13
prepared [3] 63/19
109/7 115/6
prescribed [3] 55/9
93/15 124/25
presence [1] 88/18
present [5] 91/3
158/25 159/4 159/7
187/13
presented [1] 116/7
presenting [1] 36/4
preservation [1]
140/2
President [2] 2/23
3/20
press [5] 46/6 98/1
140/21 143/21 192/22)
pressure [6] 36/15
37/21 43/5 125/24
187/20 188/8
presumably [7] 60/1
74/16 129/23 145/4
168/3 180/18 183/20
presume [3] 14/5
121/9 132/21
presumption [1]
95/10
pretty [5] 26/7 30/17
42/8 43/22 128/6
prevent [1] 120/21
previous [6] 16/12
49/8 62/24 74/22
107/20 124/11
pricing [1] 45/4
principal [4] 96/25
154/22 154/23 158/2
prior [3] 58/25 80/17
152/22
priorities [1] 156/13
prioritised [1] 161/4
priority [1] 175/25
private [12] 33/21
88/2 93/17 126/19
127/21 127/24 128/10)
128/17 130/14 130/23)
131/3 152/18
privilege [7] 84/10
124/2 136/20 138/22
140/3 140/5 144/2
privileged [24] 84/2
84/5 84/20 85/22
85/24 86/2 86/4 86/15
86/18 86/24 87/4
87/22 116/18 125/3
139/14 141/13 141/17!
156/6 176/1 176/7
176/8 176/16 176/17
177/11
privy [1] 115/5
proactive [1] 94/13
probabilities [1]
167/11
probably [29] 23/24
27/11 32/2 37/3 37/4
49/4 73/19 75/10
92/24 98/2 104/23
127/3 154/20 155/14
165/23 166/13 166/17]
170/6 170/16 173/12
173/15 174/25 178/13
179/25 180/2 186/2
186/15 192/14 193/4
problem [17] 41/9
48/21 54/14 57/1
59/21 59/22 67/6 78/1
81/21 103/24 103/24
114/22 124/19 163/7
163/13 180/9 180/13
problems [14] 17/9
20/23 21/19 23/22
27/24 28/14 28/18
29/1 29/3 29/14 32/5
40/4 56/15 110/9
procedures [2]
106/16 169/3
proceeded [1]
116/11
proceeds [1] 165/4
process [107] 6/6
6/22 20/23 21/16 23/9
25/25 26/22 27/18
29/2 29/18 32/4 32/11
32/18 32/24 33/1
34/14 35/20 36/10
45/18 47/6 51/6 52/5
52/10 54/3 54/4 56/13
56/24 57/4 57/4 59/22
62/4 66/17 68/10
69/15 70/1 70/2 70/15
72/18 76/4 78/1 78/2
81/6 81/13 81/20 82/2
82/12 82/15 82/20
82/21 83/7 83/8 84/7
84/11 84/16 85/6 85/8
85/10 85/25 86/6 91/9
95/22 96/7 96/13
96/14 101/22 106/12
106/19 111/6 111/25
112/4 132/13 147/10
154/21 158/13 158/18
158/21 159/12 159/15}
159/18 160/20 160/21
162/5 165/12 165/14
166/8 166/24 168/3
169/12 169/23 169/24]
170/3 172/11 174/15
176/7 176/10 176/12
177/5 177/9 178/6
178/9 178/12 178/15
178/18 178/21 183/16
183/23 186/22
processes [9] 15/25
22/2 22/23 106/16
120/21 158/11 159/16
162/8 179/16
processing [3]
167/10 175/21 178/3
produce [1] 48/22
produced [4] 48/4
48/9 156/3 161/17
produces [1] 161/16
producing [1] 194/1
product [13] 40/8
45/1 45/16 56/3 62/8
74/1 75/14 75/17
76/17 77/5 81/4 186/3I
186/6
products [2] 34/18
47/3
professional [2] 1/25
140/5
professionals [1]
159/25
profile [2] 54/10
144/11
profitability [4] 35/1
programme [26] 13/9)
34/6 35/15 36/20
38/12 38/14 40/13
41/11 119/2 154/41
154/1 157/15 157/19
157/25 158/2 162/21
163/19 163/23 184/14,
184/15 185/5 185/8
185/23 186/15 188/16}
188/20
programmes [8] 11/7
11/7 11/10 40/18
152/20 184/18 184/21
184/22
progress [9] 39/23
113/2 148/8 155/8
155/11 155/14 155/16
156/6 174/6
progressing [1]
173/22
projects [1] 190/17
promoted [3] 2/19
12/3 12/13
prompted [2] 46/10
47/14
promptly [1] 116/8
proof [4] 48/13 51/4
114/20 115/15
proper [5] 44/21
66/20 111/4 169/2
169/2
properly [4] 67/21
107/8 116/16 126/11
property [2] 11/9
44/1
proportionate [1]
9/12
proposal [1] 40/21
propose [3] 73/12
74/10 149/6
proposed [6] 47/14
128/10 136/11 136/12!
181/1 185/8
prosecute [2] 8/11
91/17
prosecuted [2] 21/25
105/1
prosecuting [3] 6/18
9/4 90/2
prosecution [18] 8/1
9/10 50/20 51/6 51/14I
52/7 56/16 57/5 57/5
89/2 91/1 99/13 115/5
115/7 117/18 118/25
119/7 175/2
prosecutions [29]
5/16 6/2 6/16 6/20 7/7I
TIT 19/10 49/25 51/25]
52/1 52/16 52/18
52/23 53/5 53/18
54/10 88/3 88/7 89/10}
90/1 90/6 90/23 94/8
134/8 134/10 135/3
135/9 135/18 184/3
prove [3] 50/4 51/4
63/25
proved [3] 34/16
65/13 82/3
provide [9] 44/17
122/4 154/19 165/21
166/6 166/9 166/12
166/15 174/18
provided [9] 25/12
29/19 53/17 140/1
150/3 150/5 160/7
161/15 170/22
provider [3] 2/11
2/12 177/10
provides [2] 47/15
164/22
providing [2] 32/13
53/12
provision [2] 163/4
186/9
provisioned [1]
154/21
public [5] 8/11
101/12 102/3 168/16
168/19
publicly [1] 148/21
publish [1] 161/1
pull [3] 55/1 59/14
61/23
pulled [2] 62/6 92/18
pulling [2] 73/6 93/11
purely [2] 104/24
133/17
(73) post... - purely
Pp
179/24 182/13 186/3
186/11
purposes [4] 58/8
118/11 164/1 174/21
pursue [3] 41/14
111/4 129/23
pursuing [4] 40/20
115/3 135/8 172/14
purview [1] 83/2
push [3] 86/10
125/18 148/9
pushed [1] 45/9
pushing [3] 134/16
135/21 148/4
put [11] 50/15 66/17
78/24 100/16 111/2
128/15 131/2 144/1
155/12 160/1 182/14
puts [4] 144/2
putting [3] 35/24
131/15 191/17
Qu
qualifications [1] 3/7
qualified [3] 38/11
41/10 145/10
quality [4] 38/20
45/25 161/21 175/17
quashed [2] 131/23
136/4
query [2] 120/16
145/16
querying [1] 67/9
question [35] 9/15
23/24 25/18 26/13
26/21 26/25 30/7 63/3
78/23 79/7 88/21
91/19 94/8 99/19
105/7 105/9 106/6
107/14 111/23 113/6
124/5 134/9 146/12
166/1 175/11 181/14
182/15 182/16 182/20)
183/2 183/6 189/6
189/13 189/14 191/6
Questioned [12] 1/10
99/3 109/22 131/19
149/25 188/25 195/4
195/6 195/8 195/10
195/14 195/16
questioning [3]
108/20 146/11 148/18
questions [33] 1/25
6/22 36/9 46/6 47/14
55/16 77/14 98/5 98/6
98/13 98/20 100/11
108/1 108/15 108/16
108/24 109/5 113/11
113/11 113/15 123/11
132/11 148/16 150/10}
purpose [8] 34/5
100/23 165/10 165/18)
150/13 180/25 181/8
189/1 193/21 193/23
quick [4] 58/16 82/9
109/2 158/5
quickly [7] 12/7 26/8
63/10 69/14 84/19
86/9 158/8
quite [28] 11/2 11/19
11/19 24/10 25/23
41/24 42/17 43/10
56/6 60/18 73/21
84/18 93/4 114/21
120/4 122/22 125/23
157/4 163/24 182/12
182/22 186/4 186/6
194/3 194/5
R
raise [3] 53/22 53/24
184/13
raised [22] 46/6
51/15 62/22 63/6
63/10 76/25 78/9
78/21 86/19 96/21
102/1 124/1 136/23
146/24 155/9 161/19
175/6 179/9 183/1
186/20 186/25 187/9
raises [1] 9/17
raising [3] 23/16
47/14 178/3
ramifications [2]
33/6 82/17
ran [3] 22/17 65/19
74/2
rang [2] 93/22 95/4
range [2] 161/2
169/15
rapidly [3] 14/15
158/8 160/21
rare [3] 9/24 9/25
35/21
rather [9] 38/24 42/5
54/19 80/9 96/25
100/17 115/9 146/24
162/6
rationale [1] 140/9
re [4] 74/10 121/3
138/8 144/19
reach [2] 63/2 147/21
reached [1] 172/2
reaction [2] 54/5
173/12
read [21] 10/7 33/12
50/22 59/11 59/16
67/13 69/6 71/1
107/22 118/17 118/19)
128/7 130/12 132/21
133/1 135/11 142/14
143/4 143/13 145/23
182/10 182/13 188/23)
187/22 190/16 190/20)
quotes [1] 113/18
radar [1] 69/14
145/25
readily [1] 163/22
reading [17] 41/24
66/22 76/11 119/2
134/11 134/13
readings [1] 20/4
reads [9] 8/1 8/25
33/25 59/21 70/23
74/14 75/12 114/13
171/11
real [3] 129/24
129/24 129/25
realise [3] 35/16 51/5
101/11
realised [2] 58/10
146/18
realising [2] 34/25
35/4
reality [2] 37/13
107/2
really [19] 12/8 26/8
26/8 44/2 54/18 55/21
72/2 79/15 84/9 97/23
99/14 110/8 129/9
132/3 133/21 147/24
155/20 174/7 183/6
rearview [1] 18/22
reason [14] 38/17
54/25 68/19 87/7
104/22 142/16 142/17
153/7 164/11 183/1
191/9 192/20 192/25
193/10
reasonably [2] 87/9
109/7
reasoning [1] 115/2
reasons [8] 44/22
115/1 115/16 125/17
129/12 155/15 155/17
185/22
reassure [1] 171/17
Rebekah [1] 127/9
recall [35] 3/15 19/14
19/21 22/23 27/8
29/11 29/15 30/7
41/16 48/18 49/4 54/2
59/1 59/3 59/8 62/21
63/4 65/17 69/16 70/1
72/17 75/16 113/10
131/9 131/10 140/4
140/7 140/8 145/24
166/12 169/25 170/4
170/7 170/14 181/2
receipt [1] 76/20
receipts [5] 18/18
58/1 58/19 63/14 64/6
receive [1] 39/4
received [13] 8/4
27/3 41/23 58/12
59/12 90/3 91/19
91/21 136/1 139/21
51/9 52/12 52/24 54/6}
58/20 59/5 59/8 66/20
132/16 132/18 132/24
168/20 176/4 189/17
recent [2] 38/9
114/22
recently [3] 34/2
39/13 152/6
recipients [1] 8/24
recognise [10] 43/4
59/15 59/16 116/1
157/3
recollecting [1]
88/17
recollection [3]
88/13 119/16 119/18
recommenced [1]
39/25
recommendation [2]
169/9 169/16
recommendations
[4] 164/23 165/8
167/18 167/22
reconciliation [1]
64/7
record [1] 136/8
recording [1] 143/3
recover [4] 164/10
164/25 169/10 172/8
recovery [5] 164/6
164/8 164/18 169/23
170/3
recruit [1] 47/1
recruited [1] 47/5
rectify [1] 39/24
red [1] 38/9
redress [3] 182/1
182/18 190/24
reduce [1] 86/18
refer [5] 4/25 19/6
58/12 136/16 161/18
reference [17] 36/23
75/11 103/11 103/13
151/9 151/21 152/6
166/4 170/25 173/21
referenced [1]
176/11
references [1]
120/10
referral [1] 171/24
referred [4] 19/8
58/22 66/6 74/22
referring [2] 46/14
74/16
refers [5] 47/20
47/25 61/24 116/4
184/23
reflect [3] 41/22 90/4
97/23
reflected [2] 64/11
86/14
reflecting [1] 94/1
135/12 135/13 135/14)
135/14 135/18 135/20}
recognised [2] 34/14
41/18 46/19 60/2 73/6
103/16 112/13 150/22}
reflection [1] 119/9
reflective [1] 12/22
refreshed [1] 48/24
refreshing [1] 49/1
regard [1] 103/18
regarded [1] 14/1
regarding [8] 88/7
99/20 100/7 100/15
101/12 102/2 119/4
136/11
regards [7] 9/3 36/6
55/22 107/8 110/15
118/8 135/15
regions [1] 3/3
regression [3] 160/3
160/10 175/16
regrettable [1]
163/25
regular [1] 166/12
regularly [3] 26/2
165/15 193/8
regulatory [1] 122/1
reimbursement [1]
179/13
reinforce [1] 34/21
rejects [1] 40/21
relapsed [1] 185/24
relate [2] 23/18
161/19
related [19] 13/12
17/8 20/21 24/17
30/21 31/2 35/18
35/25 50/19 61/13
71/3 104/20 107/24
136/22 140/14 153/10}
163/3 181/15 184/3
relates [4] 7/24 80/8
126/18 164/4
relating [5] 38/9
46/17 88/1 179/6
184/14
relation [17] 6/23
59/21 78/12 80/19
84/1 140/12 156/6
161/21 164/6 164/8
167/20 175/19 176/2
179/13 182/20 182/23)
189/22
relationship [17] 4/5
6/14 23/25 24/15
24/19 25/10 25/21
34/15 39/17 41/22
43/2 46/22 168/14
172/3 175/4 179/5
190/8
relationships [1]
39/19
relative [1] 139/23
relatively [5] 12/6
33/1 33/7 89/21 125/6
relayed [1] 104/5
released [1] 160/12
relevance [1] 147/1
relevant [3] 72/25
(74) purpose - relevant
R
183/9
reliability [3] 101/13
113/23 174/12
reliable [4] 54/12
138/8 143/11 154/15
reliance [2] 34/10
175/7
relied [3] 11/22
169/22 170/2
rely [3] 174/20
190/15 190/21
relying [1] 90/21
remain [1] 13/23
remainder [1] 40/16
remains [4] 11/13
34/23 123/14 154/14
remediation [11]
153/25 154/1 154/6
157/15 157/18 158/2
179/17 180/5
remedy [1] 163/13
reminded [1] 110/16
remit [6] 4/17 5/2
11/19 14/20 122/10
184/24
remote [10] 80/9
80/16 81/10 83/1
83/14 83/23 121/7
156/11 176/7 176/8
remotely [3] 81/6
81/7 120/19
remuneration [1]
169/11
repaid [1] 8/8
repay [5] 74/4 75/6
76/5 165/4 172/9
repeat [2] 48/19 79/7
repeated [3] 93/17
95/5 137/11
repeating [1] 188/15
replace [1] 186/18
replacement [4]
17/13 184/23 185/1
185/18
replied [1] 94/24
replies [4] 141/4
141/6 141/6 144/7
reply [7] 41/3 44/10
94/14 107/18 123/16
141/18 144/5
report [66] 11/12
11/23 46/14 46/19
47/15 50/25 51/10
51/22 52/13 52/24
53/12 53/15 54/6 54/8
54/9 54/11 54/13
relevant... [2] 181/21
159/10 162/21 179/14}
remember [11] 20/18
46/7 53/14 61/11 93/5)
100/21 111/24 119/20
137/17 192/19 193/12)
54/15 54/22 54/25
59/8 60/18 60/23
68/11 69/25 70/5
72/13 73/18 79/19
90/8 90/14 90/16
111/13 112/8 112/13
114/10 114/11 115/3
115/8 115/11 119/3
124/3 125/8 131/25
132/16 132/19 133/2
133/5 135/6 156/4
158/17
reported [17] 11/10
62/14 71/9 72/24
76/23 79/24 160/18
160/20 160/25 161/8
176/18 180/15 188/3
reporting [11] 3/25
111/22 132/12 161/5
reportings [1] 72/14
reports [10] 4/10
123/22
represent [2] 99/4
136/4
representatives [1]
122/7
reputational [1]
168/12
reputationally [1]
145/2
request [18] 34/12
35/24 38/6 38/18 46/1
46/12 46/18 47/13
61/8 96/22 135/1
166/6 166/13 173/13
179/9 181/2 181/15
182/25
requested [1] 42/2
requesting [4] 7/25
9/4 86/4 182/17
requests [8] 178/3
178/4 179/14 179/17
179/23 180/3 180/3
181/7
require [1] 178/24
required [10] 16/16
25/7 28/4 48/21 50/21
51/4 76/18 81/22
157/9 162/25
requires [2] 15/23
176/13
requiring [1] 16/5
reset [1] 81/22
resides [1] 81/8
resolution [3] 30/22
55/3 55/24 55/25 57/2
84/3 84/22 85/18 86/8)
87/10 87/14 90/4 90/6)
112/21 113/21 113/23)
15/18 46/24 47/9 62/4
46/7 46/10 46/22 77/3
161/24 176/16 176/22)
6/21 9/18 63/17 68/15
74/8 75/2 75/3 109/25)
30/24 62/8
resolve [2] 90/12
165/11
resolved [6] 25/7
40/11 77/23 86/9
90/11 158/25
resource [3] 35/22
38/13 159/18
resources [4] 35/14
35/17 38/1 157/12
respect [2] 26/24
157/4
respond [2] 125/20
147/12
responded [2]
113/11 113/14
responding [2] 122/5
155/9
responds [3] 127/13
172/22 173/17
response [27] 39/4
39/9 40/23 41/1 42/8
42/17 42/19 42/24
43/18 56/12 66/1
110/21 120/16 121/4
122/5 126/11 127/21
145/16 146/15 146/16)
146/23 150/10 154/5
156/22 173/16 173/16
190/2
responsibilities [11]
4/3 4/21 5/11 7/6
10/14 10/21 10/23
13/8 14/24 87/18
153/18
responsibility [23]
5/19 6/1 6/16 11/6
24/20 24/23 24/25
71/19 77/4 77/16
77/19 79/6 79/12
88/12 103/25 104/7
110/2 110/7 122/10
156/16 178/9 184/16
184/20
responsible [10]
2/16 3/1 4/11 5/7 5/13
5/23 103/20 114/9
179/4 180/23
rest [2] 48/13 78/15
restored [1] 40/12
restructure [1] 14/18
rests [1] 166/25
result [7] 10/20 40/15
75/18 114/11 119/6
145/14 160/19
resultant [1] 63/13
results [3] 138/14
143/18 145/17
resume [4] 57/14
57/15 149/8 194/8
retain [1] 47/21
retention [1] 136/22
retired [2] 46/25 47/4
retrieval [1] 50/12
retrieve [2] 174/16
183/24
retrieved [1] 184/10
retrieving [1] 183/16
return [1] 60/20
revealed [1] 78/3
revenues [2] 37/16
79/23
reverting [1] 28/23
review [45] 34/4 34/5
34/7 34/8 34/14 38/12
38/19 39/17 40/20
40/22 41/23 42/2
42/10 44/3 44/22 46/1
54/20 72/10 72/21
86/21 87/3 87/8 96/22,
103/8 113/2 125/16
132/6 133/12 133/17
133/18 134/4 134/6
134/17 135/15 140/19)
141/20 141/22 141/25)
147/17 148/5 148/10
165/11 165/14 176/25}
185/20
reviewed [4] 9/11
88/14 100/9 141/19
reviewing [4] 96/5
166/24 177/16 185/18}
revisit [1] 124/11
rewind [1] 15/3
right [108] 2/8 2/17
3/3 3/21 4/1 4/12 4/13)
4/24 5/2 9/2 10/2
10/21 10/25 11/15
14/25 16/3 16/13
18/14 19/16 28/4
28/23 31/5 38/1 44/2
44/2 45/14 48/12
51/10 52/12 54/16
58/6 58/14 65/7 67/12,
67/24 67/24 72/15
80/17 81/11 81/18
84/12 88/17 92/1 93/3)
93/13 94/25 95/7 96/3)
98/19 99/15 99/24
100/4 100/22 101/9
102/5 102/9 103/5
105/6 105/10 107/13
108/3 108/21 109/1
109/6 110/3 112/15
112/16 114/16 114/16)
118/15 124/21 125/4
126/6 126/10 128/24
135/17 138/12 140/7
147/3 148/20 149/5
149/10 150/11 152/15)
153/3 153/23 155/5
156/1 157/19 178/4
179/7 179/11 179/18
182/7 184/16 184/18
185/5 185/20 189/19
190/4 190/21 191/6
191/10 191/15 192/1
192/23 193/25 194/8
right-hand [3] 112/15]
112/16 114/16
rightly [2] 32/24 95/1
rights [14] 44/4
45/10 45/14 46/2 84/2)
84/5 85/11 85/11
85/12 86/3 86/5 86/18}
86/24 87/4
rigour [1] 184/5
ring [1] 25/6
rings [1] 92/25
rise [3] 2/7 167/25
169/14
rising [1] 2/7
risk [11] 4/19 36/18
154/18 156/24 166/5
167/25 168/12 168/13}
168/14 168/22 178/7
risks [4] 154/9
167/23 169/6 169/15
RMG [2] 6/10 119/6
RMG/POL [1] 119/6
road [5] 13/4 24/18
49/10 112/5 135/17
Rob [4] 7/13 7/18
7/21 9/13
robin [1] 55/13
robust [11] 80/24
82/15 121/15 121/18
123/7 123/14 123/24
124/9 124/10 138/8
143/11
robust/reliable [1]
138/8
robustness [1] 25/16
Rock [1] 47/7
Rod [16] 56/5 61/24
75/15 75/18 75/21
77/4 77/15 78/18
112/23 112/25 113/12)
118/5 119/5 123/10
427/11 127/17
Rod's [2] 63/23 77/15
role [25] 2/22 3/1 3/5
AIT 419 11/2 11/2 11/3
12/23 12/25 34/17
52/18 61/10 61/13
79/3 135/7 154/3
154/12 154/24 165/17
171/5 172/1 176/10
176/15 187/7
roles [7] 5/10 7/5
10/20 10/23 13/8
14/23 16/12
roll [3] 29/4 69/7
187/20
rollback [2] 28/25
30/17
rolled [4] 32/2 66/16
188/8 188/12
rolling [9] 28/22 29/3
29/10 33/1 35/7 40/2
59/24 60/6 187/25
rollout [27] 27/25
(75) relevant... - rollout
R
rollout... [26] 28/4
30/16 32/5 32/15
32/16 34/24 36/7
36/17 40/17 47/10
55/20 65/23 67/2
67/15 68/5 68/12
68/16 69/10 69/18
69/22 71/3 71/25
100/18 101/2 124/22
185/13
room [3] 34/19 95/8
109/3
root [6] 28/18 30/2
30/6 30/8 166/25
167/15
round [5] 44/11
55/12 55/13 89/12
96/8
route [1] 21/20
routinely [1] 79/5
Royal [33] 6/2 6/10
6/15 6/17 6/25 7/8
9/21 12/25 13/13 22/8
33/5 36/4 36/10 36/12
36/13 37/9 37/11
37/13 37/17 37/18
37/24 39/1 42/12 43/6
52/9 70/16 72/11 92/5
92/14 92/16 111/10
135/7 138/21
rudimentary [1]
84/12
Rule [1] 109/4
rumour [2] 116/25
117/3
run [14] 23/25 24/3
25/4 25/9 38/13 43/14
44/25 66/11 76/19
100/24 108/9 121/1
130/23 134/22
run-up [1] 66/11
running [13] 3/19
15/6 19/2 24/20 32/23)
34/24 40/1 66/5 66/22
72/4 100/23 151/12
160/15
runs [3] 1/16 150/25
190/15
Russell [11] 60/20
60/24 61/8 61/21
62/12 68/6 72/23
73/16 74/16 76/15
102/13
Russell's [1] 66/2
Ss
sacked [1] 116/10
safe [1] 33/9
safety [1] 52/22
said [54] 7/20 10/15
12/18 18/25 21/1 21/8
23/20 26/7 28/6 38/16)
46/3 47/22 62/24 68/6
69/1 72/9 78/21 87/21
89/18 89/23 91/7
91/11 93/24 94/21
94/25 95/1 95/6 95/7
99/15 101/17 107/12
108/19 110/8 110/10
112/12 112/13 116/23)
121/21 122/11 124/21
128/16 128/19 130/10;
132/4 135/5 140/24
147/19 153/13 162/8
166/1 170/14 174/3
183/11 184/19
Sam [1] 99/4
same [29] 14/6 57/2
60/24 61/19 72/8 76/4
76/12 79/20 84/13
94/15 97/25 101/21
101/24 105/24 106/8
115/24 123/7 124/9
128/18 130/12 130/18)
130/21 133/19 139/4
142/13 157/1 157/2
184/8 191/5
sanctions [1] 169/1
sanity [1] 122/2
sat [8] 11/18 44/11
45/1 72/13 80/1 106/4
121/21 135/2
saving [1] 35/6
savings [2] 34/25
35/4
saw [11] 4/7 55/24
74/8 87/13 113/13
114/24 116/2 118/15
124/21 139/5 147/10
say [121] 2/10 3/18
5/4 5/13 5/19 10/24
12/9 13/22 13/25
14/11 15/13 18/13
19/4 19/9 19/11 19/22
22/21 26/7 27/24
28/12 28/21 28/24
29/16 30/1 31/11
31/19 34/11 34/13
34/22 38/6 38/7 38/9
40/5 40/14 40/24 41/6
41/21 48/2 49/15
52/17 52/25 54/5 54/7,
56/19 58/1 59/4 61/4
61/21 63/8 63/18 64/5)
65/17 65/21 67/25
71/10 71/13 72/20
75/9 77/2 78/24 80/13
80/14 80/19 86/16
86/17 88/5 88/22 89/6
90/1 90/5 91/3 91/14
91/18 92/4 94/18
96/20 97/7 97/21
100/9 101/5 103/7
109/10 111/7 111/11
114/3 115/21 117/8
117/14 121/11 127/13}
136/10 142/10 143/2
152/17 153/22 156/13
156/17 157/3 158/1
158/4 158/9 158/24
161/5 161/14 162/4
163/3 163/12 165/6
166/24 167/6 175/10
178/3 178/6 178/15
182/9 182/20 185/3
185/7 187/3 188/10
191/21
saying [28] 20/2 20/8
20/11 20/18 33/13
33/16 45/20 53/11
55/18 57/2 60/24
68/19 70/18 80/4 94/7
103/23 124/16 128/11
130/20 135/16 135/19}
140/12 142/23 145/16
148/21 172/24 174/10}
190/15
says [39] 9/9 39/11
39/20 39/21 40/9
56/13 63/24 66/14
71/4 71/7 71/7 71125
73/23 74/1 76/15
84/13 93/5 93/25
102/13 107/15 112/7
113/17 113/19 114/14
120/15 121/2 121/25
127/19 136/6 139/12
139/14 143/10 143/18}
144/10 146/7 164/22
173/19 190/21 190/23}
scale [3] 138/13
143/15 186/15
scale/for [1] 138/13
scaled [1] 157/6
scandal [2] 99/6
110/2
Scheme [1] 182/2
schemes [1] 182/2
school [1] 2/3
scope [6] 141/25
144/16 144/17 153/9
154/2 155/3
Scott [12] 5/10 6/3
7/5 7/12 7/22 8/19
8/23 9/16 10/4 52/9
65/21 118/19
screen [6] 19/8 20/22
69/15 102/6 107/15
189/2
screens [1] 17/8
scroll [36] 7/15 7/16
7/19 8/22 39/6 47/18
58/17 59/20 61/15
61/19 73/15 74/13
102/9 115/25 117/24
120/11 120/25 123/8
123/16 126/23 127/5
127/22 129/16 133/10
133/22 141/3 141/4
144/4 146/16 164/17
167/21 169/18 171/1
171/3 172/21 173/17
scrutinised [1]
176/18
SD [3] 62/4 62/6 74/1
se [1] 28/8
second [36] 8/22
15/1 20/12 39/7 64/24
66/6 67/13 67/16 69/6
82/2 90/3 90/8 90/14
91/7 91/25 92/7 95/17,
110/23 119/16 125/8
125/13 129/6 129/7
135/22 136/13 137/6
137/11 137/22 139/10}
149/22 150/9 151/8
167/24 179/25 182/16)
183/2
secondly [6] 34/7
83/18 99/18 149/2
168/11 181/23
section [4] 99/13
132/3 134/13 134/13
sector [2] 33/21
152/18
secure [4] 81/14
117/10 128/16 154/15)
secured [1] 120/5
security [30] 2/16
2/19 3/8 3/11 3/13
3/17 4/14 4/17 4/20
4/24 4/25 5/7 5/25 6/4
6/14 6/15 7/13 7/21
9/3 10/3 53/25 62/9
62/15 65/15 71/19
85/17 85/21 154/9
156/23 176/19
Security's [1] 5/10
see [103] 1/3 1/19
7/18 7/23 8/4 8/19
8/23 9/7 9/12 15/16
22/7 26/19 33/23
35/22 36/23 38/6 39/6
39/7 40/19 40/23
43/19 44/2 44/10
47/16 51/19 51/23
53/5 55/3 55/19 57/21
58/23 59/14 60/19
61/15 66/5 72/17
72/23 77/15 78/9
78/22 93/15 96/5 96/9)
102/11 102/24 106/18}
109/17 113/16 117/23
118/2 118/12 118/14
118/20 121/4 121/12
123/8 124/2 124/6
124/11 126/23 127/5
127/12 127/17 127/23}
133/11 133/13 133/14}
133/25 137/23 137/25
138/1 138/2 138/4
138/17 138/19 139/2
139/4 139/6 139/8
139/12 141/4 141/5
141/6 141/7 144/5
144/6 144/8 146/15
146/17 147/5 149/15
151/3 151/15 151/24
169/8 169/20 171/2
171/4 173/17 173/21
181/13 191/11 193/8
seeing [7] 56/11
56/11 106/4 107/23
107/24 119/2 129/5
seek [3] 37/16 87/25
147/22
seeking [5] 8/18 16/7
52/8 180/7 181/22
Seema [7] 114/24
1415/2 115/6 115/17
119/1 119/4 121/14
seems [5] 7/20 26/14
68/6 182/22 190/16
seen [31] 6/18 14/20
18/1 25/20 29/7 32/10)
63/17 69/25 72/21
77/23 77/24 78/5
78/11 78/12 79/19
82/6 82/22 90/15
90/16 114/21 117/7
130/18 133/24 138/25]
139/25 141/14 146/15)
146/23 185/25 187/2
191/4
segment [1] 45/21
self [8] 35/9 119/13
119/15 119/15 119/19)
131/8 178/21 184/25
self-service [2]
178/21 184/25
self-serving [5]
119/13 119/15 119/15}
119/19 131/8
self-supporting [1]
35/9
send [3] 61/5 102/21
127/16
sending [1] 36/22
sends [2] 121/2
127/23
senior [6] 39/17 64/4
69/3 70/11 78/3 114/5
sense [14] 6/25
22/12 30/5 30/14
40/15 44/5 51/21 52/6)
65/6 87/7 92/10 100/4
167/14 174/22
sensitive [3] 52/4
52/4 89/21
sensitivities [1] 78/8
sensitivity [1] 52/1
sent [14] 7/20 54/15
117/22 130/24 140/4
145/15 145/21 145/24I
146/18 147/9 170/5
sentence [1] 64/24
separate [2] 107/20
161/25
(76) rollout... - separate
Ss
separated [1] 157/14
separation [13]
13/12 13/22 14/7
14/19 14/21 92/5
92/13 92/13 95/11
119/24 137/8 142/20
147/14
September [9] 61/25
70/21 71/8 71/10
75/25 151/21 153/2
177/20 177/21
September 2022 [1]
153/2
sequence [2] 63/11
63/12
Sergeant [1] 2/8
series [2] 47/14
167/18
seriously [3] 29/9
130/6 144/23
servant [1] 152/22
served [2] 2/4 2/6
service [34] 2/12
24/7 24/11 25/1 26/14,
28/3 31/16 37/14
42/21 42/21 45/23
50/13 50/13 51/8 55/5)
62/5 72/24 72/24
75/20 75/22 92/22
106/13 110/17 120/3
120/3 126/11 161/8
161/14 161/21 161/23}
162/2 162/3 178/21
184/25
services [10] 3/21
10/17 13/7 34/18 47/2)
47/3 166/7 171/21
175/4 181/1
serving [5] 119/13
119/15 119/15 119/19
131/8
session [1] 150/5
set [16] 44/20 44/21
47/3 50/15 51/16
63/11 85/13 86/6
113/1 113/4 115/12
123/15 128/13 128/16
154/5 165/10
setting [1] 156/19
settle [1] 116/10
settled [4] 24/23
192/11 192/12 192/16}
seven [3] 2/7 110/24
152/7
several [11] 27/11
27/23 34/18 41/13
43/10 44/6 60/25
62/12 84/6 102/15
107/16
Sewell [14] 44/7
46/24 47/6 52/2 58/4
62/22 73/17 109/24
139/8 141/4 141/6
142/7 142/24 146/24
shall [4] 57/13 57/15
103/19 109/10
share [1] 43/25
shared [4] 95/22
186/1 187/1 187/3
shareholder [2] 9/22
125/19
shareholders [1]
168/15
sharper [2] 26/17
26/18
she [44] 47/6 82/9
86/12 95/6 95/9 95/14
1114/1 111/22 112/2
112/4 125/24 128/4
138/6 140/1 141/6
141/10 141/11 141/12)
141/13 141/18 142/18)
142/25 143/2 143/9
143/10 143/10 143/11
143/14 143/16 143/18)
143/20 143/20 143/21
143/21 143/24 144/2
144/10 146/1 146/3
146/5 146/7 146/7
146/8 146/21
She'll [1] 79/19
she's [7] 79/18 139/8
142/20 142/25 144/1
145/21 146/22
sheer [1] 192/23
shift [4] 87/11
shoes [2] 18/25 25/3
Shoosmiths [10]
93/10 129/13 129/18
130/19 130/20 131/41
131/6 135/23 136/12
136/17
short [15] 17/19 26/7
27/2 37/23 39/10
57/18 59/5 100/13
109/15 125/6 130/23
149/6 149/13 183/11
194/6
shortcomings [1]
25/23
shortfall [10] 164/11
164/12 182/2 191/8
191/12 191/23 192/1
192/5 192/5 192/24
shortfalls [3] 164/7
164/9 179/20
shortly [7] 27/1 29/25)
63/21 139/5 156/2
173/19 191/17
should [37] 1/13
11/24 18/16 25/18
31/6 35/25 38/5 43/16
56/21 58/10 60/10
60/11 63/16 83/1 83/5)
84/7 84/8 86/25 90/2
90/6 91/13 95/22 96/1
96/17 102/6 106/25
113/25 117/10 117/11
158/7 166/22 181/7
189/10 189/20 189/20}
189/23 191/23
shoulders [1] 78/16
shouldn't [1] 99/14
show [9] 15/22 35/21
37/25 42/17 48/13
62/11 63/25 64/2
120/23
shown [2] 74/11
164/9
shows [1] 74/6
shrift [1] 26/7
shut [1] 86/17
shuts [1] 135/14
sic [1] 153/2
side [7] 45/15 50/15
52/7 88/23 112/16
114/17 115/12
sides [2] 78/7 105/21
sight [8] 55/6 82/2
90/8 90/14 91/7 95/18
125/8 129/6
Sight's [1] 90/3
ign [1] 40/3
signature [5] 1/19
151/3 151/15 151/25
152/7
signed [3] 42/21
63/19 126/19
significant [16] 11/16
13/9 18/8 19/1 23/21
34/9 35/6 36/2 37/8
92/4 92/8 146/6
163/12 168/12 169/14
176/6
significantly [3]
108/9 126/7 176/23
signs [1] 37/11
similar [8] 39/14
39/14 98/17 99/18
113/22 115/16 184/5
184/6
similarities [1] 76/11
Simon [6] 149/19
149/24 150/2 172/25
174/8 195/12
simple [3] 100/13
101/3 172/13
simply [3] 50/22
70/10 173/13
Simpson [2] 127/7
130/12
since [11] 18/1 19/2
39/22 49/22 64/15
124/10 130/21 131/23
150/14 157/6 165/2
Singh [1] 119/5
single [2] 120/24
174/1
sir [31] 1/3 57/10
57/20 57/21 66/21
73/8 98/6 98/15 98/17
98/18 106/23 107/4
108/7 108/22 108/23
109/13 109/17 121/17]
122/22 126/25 131/20
146/12 148/18 149/6
149/15 149/18 153/15)
189/8 193/23 194/7
194/10
Sir Alan [1] 121/17
sit [14] 36/11 45/3
51/23 52/11 55/17
60/25 102/15 105/21
107/16 109/7 121/21
178/9 178/15 178/16
sitdown [1] 101/1
sites [1] 27/17
sits [3] 96/8 106/12
158/21
sitting [3] 13/21
36/25 37/17
situ [2] 11/5 12/8
situation [3] 28/22
34/6 72/6
size [1] 18/6
sizeable [1] 24/5
sized [1] 72/9
skill [1] 38/13
skills [1] 41/12
SLAs [2] 23/15
124/25
slight [1] 25/19
slightly [9] 20/14
30/5 73/4 98/11
115/24 124/13 173/15]
177/19 191/6
small [7] 11/3 11/3
11/20 29/22 57/5
114/9 162/11
Smith [35] 12/10
12/18 12/24 16/24
16/24 18/21 19/4
19/14 19/15 20/2
21/15 22/1 23/8 23/12,
27/4 46/10 46/11
46/24 47/4 47/13 58/5)
88/8 89/23 111/10
111/20 112/3 112/7
112/12 113/17 115/10
118/3 118/3 118/13
118/17 132/11
Smith's [1] 118/20
Smiths [1] 19/16
smooth [1] 32/23
so [272]
software [8] 18/17
30/3 30/25 31/18 32/9
32/14 184/24 185/2
solicitor [4] 116/8
116/10 116/18 116/23
solidified [1] 54/13
solution [8] 24/6
163/18 178/19 178/20
178/24 184/4 184/5
186/11
Solutions [1] 2/24
some [143] 2/1 4/21
6/25 7/1 10/13 11/16
12/16 14/18 15/10
16/16 18/9 19/13 20/9)
20/15 20/18 21/1
21/13 21/23 22/10
22/15 23/19 24/8
24/25 25/20 26/5
26/19 26/21 28/16
29/25 30/21 32/6
32/20 33/6 33/19 34/3I
36/9 37/9 38/2 38/4
41/5 42/20 43/19
44/23 46/17 47/3
47/15 47/16 49/23
49/24 50/24 51/1
51/11 51/15 51/20
51/24 51/25 52/25
53/14 53/17 54/9 55/6I
56/3 56/7 56/16 56/17I
57/7 60/19 64/24 65/6
65/10 65/14 65/18
68/11 78/4 79/25 80/5I
80/15 81/22 81/22
82/6 82/21 84/6 84/12
85/14 85/21 87/12
87/13 87/25 88/24
89/13 89/13 90/12
90/12 91/6 95/12 97/9
97/16 98/2 98/6 100/6I
108/15 110/6 110/17
111/23 111/24 111/24}
111/25 112/2 120/8
120/9 124/1 124/8
124/22 125/7 125/9
125/20 125/23 129/5
132/20 135/2 139/16
143/19 158/16 162/20)
162/24 168/24 169/6
169/6 169/17 171/13
172/8 172/14 175/16
176/1 180/3 180/25
182/12 186/12 186/13)
187/2 187/8 187/16
191/24
somebody [1] 192/11
somehow [2] 96/11
173/9
someone [12] 15/21
31/2 37/11 53/2 53/21
82/16 82/25 85/9
104/1 122/1 127/9
168/4
something [36] 10/9
14/12 15/19 16/18
20/13 20/14 33/15
41/19 49/18 55/11
56/18 59/16 64/9
64/11 67/23 69/7
69/13 71/17 75/7
76/21 78/10 82/11
89/18 105/4 105/18
(77) separated - something
Ss
something... [11]
107/24 117/18 126/9
129/20 130/7 137/16
147/23 160/24 166/17
173/12 187/6
sometimes [1] 20/25
somewhat [2] 41/2
190/25
somewhere [2] 92/2
170/10
soon [3] 95/4 132/24
145/18
sooner [1] 123/17
sophisticated [1]
85/14
sorry [16] 23/2 48/20
50/7 50/9 50/10 63/3
64/13 71/6 112/16
123/17 132/17 149/16}
164/16 184/11 187/3
187/5
sort [10] 14/18 26/21
32/6 88/1 106/1 113/1
117/3 123/7 179/25
190/11
sorting [1] 26/8
sorts [2] 147/18
190/17
sought [5] 17/22
172/8 175/24 176/25
190/24
sounding [1] 146/22
sounds [1] 67/16
source [2] 39/23
99/23
sources [2] 180/10
180/13
speak [3] 142/18
147/21 186/21
Speak-Up [1] 186/21
speaking [2] 19/14
19/21
speaks [1] 146/21
specific [4] 30/11
31/7 63/5 182/23
specifically [7] 45/12
80/19 122/25 176/12
184/23 187/10 188/10
specifics [1] 55/4
speculate [1] 174/25
speculating [2]
168/18 168/23
spell [1] 24/2
spend [1] 139/1
spending [2] 3/19
168/19
spent [6] 11/20 15/14
81/2 81/3 81/5 187/22
sphere [1] 101/12
SPMR's [1] 116/9
spoke [1] 59/2
spoken [3] 41/13
127/15 147/19
sponsor [1] 184/19
sponsoring [1]
184/20
spot [1] 147/4
spreadsheet [1]
74/12
spring [2] 27/9 49/1
Springford [2] 139/2
141/10
Square [3] 18/2
18/12 21/21
staffing [1] 41/12
stage [10] 13/25
42/11 61/9 63/6 91/15
144/4 155/14 155/21
178/14 185/17
stakeholders [5]
62/7 62/14 72/25
161/3 169/20
stance [4] 24/13
121/15 123/14 123/24)
stand [4] 40/1 48/17
82/1 183/6
standard [1] 188/21
standing [4] 9/25
34/4 34/15 46/2
standpoint [1]
104/24
stands [4] 16/14
41/20 60/4 60/8
start [17] 22/12 23/9
33/2 44/13 49/21
51/19 51/23 52/6
93/10 100/6 103/20
109/12 126/22 131/25)
135/7 141/3 185/14
started [5] 91/9
129/9 155/12 155/21
190/11
starting [3] 51/21
124/8 136/9
starts [3] 42/25 51/20)
126/24
state [2] 60/17 176/1
statement [72] 1/14
1/16 1/21 2/2 5/13
11/21 15/10 16/21
24/1 27/22 28/7 28/16
30/1 31/12 38/16
52/25 53/1 54/7 56/3
58/2 59/4 64/5 77/2
80/11 84/9 84/13 85/4
88/3 88/22 89/17 90/1
91/18 97/5 100/4
100/16 101/6 104/1
1141/9 112/5 113/13
113/18 118/23 121/21
121/25 122/2 128/16
130/23 136/6 149/2
149/21 150/4 150/21
150/25 151/5 151/8
151/12 151/17 151/20)
152/2 152/5 152/10
153/22 154/8 156/3
156/17 158/1 161/5
162/4 163/24 175/5
178/1 185/7
statements [5] 150/3
150/9 150/17 150/18
194/2
states [1] 38/4
statistics [1] 175/20
statutory [1] 150/6
stay [3] 14/6 14/11
123/9
stayed [1] 134/8
stealing [1] 21/4
Stein [8] 98/23 99/3
99/4 188/25 193/11
193/20 195/6 195/16
Stein's [1] 98/20
stenographer [1]
143/5
step [8] 16/19 39/2
87/20 105/3 105/6
105/8 105/9 188/19
Stephen [1] 27/10
steps [5] 39/24 42/9
160/17 175/14 184/1
Stevens [1] 113/18
still [20] 11/13 11/22
15/20 31/21 32/14
33/7 57/20 84/19
93/14 95/10 96/1
96/19 108/10 111/22
123/6 123/23 126/9
147/11 176/21 185/15}
stock [1] 60/1
stood [1] 92/20
stop [4] 102/9 133/23}
138/23 144/6
stopped [3] 32/16
90/2 90/7
storage [2] 183/13
184/7
store [1] 183/12
straight [1] 147/13
straightforward [1]
182/13
strategic [1] 25/8
strategies [1] 15/17
strategy [1] 36/5
stray [1] 88/10
stream [1] 117/14
stretch [1] 23/5
strictures [1] 99/2
strike [1] 172/9
strong [2] 7/9 43/22
strongly [2] 41/19
123/20
structure [1] 112/19
strung [1] 42/5
stuck [1] 123/18
studying [1] 3/10
stuff [1] 87/16
SU [4] 59/24 60/2
60/4 60/6
subject [7] 39/8
58/19 123/11 138/3
139/12 141/13 144/1
submitted [1] 181/6
subordinate [1]
190/5
subpostmaster [11]
74/4 75/7 81/21 82/1
82/17 83/10 91/3
116/11 191/11 191/20}
192/23
subpostmaster's [3]
64/18 91/15 116/8
subpostmasters [38]
19/14 20/7 20/15
20/18 48/3 48/9 48/13
48/21 51/1 52/19
70/24 76/7 77/12
80/22 82/24 86/21
87/6 90/3 93/7 94/10
97/4 97/4 97/5 99/5
117/2 117/17 124/15
125/22 126/5 129/21
130/4 130/16 131/1
131/22 136/2 137/4
158/10 163/5
subsequent [4]
36/17 68/12 119/17
171/24
subsequently [2]
83/13 153/5
subsidy [1] 168/20
substance [3] 116/9
139/22 188/5
substantially [1]
155/21
substantive [2] 2/1
155/14
subteam [1] 154/8
subteams [1] 153/23
success [1] 132/6
successful [3] 34/17
36/16 119/6
such [12] 52/1 52/1
54/22 80/16 80/23
83/15 83/23 140/24
141/20 182/2 185/2
193/3
Sue [6] 46/21 47/11
47/18 112/22 116/3
127/10
suffering [2] 18/4
131/7
sufficient [2] 157/12
186/9
sufficiently [2] 28/21
45/25
suggest [13] 23/16
67/14 69/11 69/16
76/24 79/17 87/10
114/22 117/12 142/5
142/6 142/21 165/22
suggested [10] 13/4
16/9 21/18 22/16 31/1
37/22 113/25 124/24
129/24 130/3
suggesting [9] 21/24
66/10 70/20 70/20
76/10 114/8 115/10
115/19 139/16
suggestion [2] 112/2
173/8
suggests [9] 25/14
58/25 66/2 69/6 95/14!
142/10 146/4 164/19
165/20
sum [2] 50/15 171/15
summarise [2] 99/10
106/21
summarising [1]
113/6
summary [11] 14/23
61/6 61/23 73/7 82/11
93/6 99/14 101/16
102/22 107/3 116/21
summer [4] 132/5
132/9 135/22 170/12
summertime [1]
170/10
summons [1] 8/5
super [1] 84/24
super-users [1]
84/24
supervised [2] 84/25
85/2
supervision [2] 6/7
11/25
supplied [1] 4/23
supplier [2] 34/10
190/22
suppliers [2] 4/5
145/8
support [36] 11/25
23/12 25/13 39/16
52/14 53/13 81/4
81/20 82/25 94/22
97/17 139/23 154/13
154/18 156/22 158/24)
165/7 165/9 165/10
165/24 166/5 166/9
166/13 166/15 166/20)
170/2 170/22 171/10
172/11 178/7 180/1
180/5 180/22 181/24
183/25 193/9
supported [2] 4/23
24/13
supporting [3] 35/9
171/14 171/17
suppose [1] 96/21
sure [27] 4/19 9/24
23/6 40/11 44/20 49/3}
50/19 55/22 60/3
61/10 66/21 75/21
84/16 94/18 94/19
98/8 100/20 122/11
125/15 126/13 128/19)
1314/7 139/25 154/14
(78) something... - sure
Ss
sure... [3] 158/16
180/13 187/24
surprise [1] 41/2
surprised [2] 85/17
128/17
surprising [2] 54/21
68/6
surprisingly [1]
130/22
Susan [14] 7/22 8/24
52/9 77/7 77/9 77/10
77/16 78/22 79/16
80/1 88/9 89/13 127/8
127/15
suspect [3] 49/4
147/15 147/15
suspected [4] 71/20
170/24 181/20 182/23
suspended [2] 85/9
85/9
Suspense [2] 59/23
60/11
suspicion [2] 49/8
142/18
sustainable [1] 145/8)
swapping [1] 145/8
swiftly [1] 158/6
swing [1] 17/13
switch [1] 89/20
sworn [6] 1/8 1/9
149/23 149/24 195/2
195/12
symmetry [1] 101/18
system [127] 15/5
15/23 16/1 16/14
16/15 17/5 17/15
20/19 21/1 21/17
21/23 21/24 26/13
31/22 31/25 32/6
33/10 33/15 44/14
47/21 47/23 51/5
53/19 54/8 55/8 55/20)
56/2 56/11 56/12
56/14 56/23 57/9 62/6
64/1 66/9 66/10 66/11
68/8 69/8 79/17 80/16
80/18 80/20 81/6 81/8
83/15 84/1 90/19 94/4
94/18 95/21 96/3 96/4
96/8 96/9 96/11 96/12,
96/15 99/20 100/3
100/7 102/3 102/7
103/8 104/12 104/12
105/21 110/16 111/6
114/20 114/25 115/14
115/18 115/18 116/14}
116/14 116/15 119/23)
120/17 120/19 120/20}
120/23 124/17 124/22
126/1 126/9 126/10
127/1 128/16 129/25
130/5 131/12 132/20
134/17 134/23 139/24)
139/24 147/17 159/7
159/13 160/16 161/7
163/9 166/15 174/5
174/17 174/19 175/20}
177/14 185/13 185/15)
186/6 187/10 187/14
187/15 187/20 187/25)
188/8 189/24 190/15
190/16 190/21 191/12)
191/16 192/8 193/13
193/18
systematically [1]
56/23
systems [21] 16/12
20/8 21/12 31/4 32/2
79/2 79/9 80/2 82/13
85/6 85/10 85/12
96/10 104/4 134/7
160/14 161/20 162/2
162/15 184/6 192/3
T
table [3] 45/13 45/20
51/17
tabled [2] 48/6 49/16
tack [1] 133/2
tackle [1] 69/19
tackling [1] 135/3
Tait [14] 24/9 33/20
33/24 39/4 42/1 46/2
54/19 57/8 70/17
93/22 96/21 119/18
137/18 148/11
Tait's [1] 69/14
take [53] 7/11 16/19
31/6 31/8 36/16 37/1
42/9 43/16 43/21
43/23 45/21 56/9
57/10 58/16 70/25
73/12 77/13 78/16
93/3 93/11 95/8 98/7
98/10 98/10 98/11
98/14 103/15 104/7
105/3 105/6 105/9
108/12 108/13 110/2
115/13 119/11 121/11
121/15 121/15 121/16)
123/10 125/24 136/24}
140/16 141/23 143/24)
144/2 160/17 164/13
183/5 184/1 188/19
191/7
taken [32] 9/11 14/19
14/19 16/20 39/20
39/24 41/8 43/20
45/13 49/9 58/5 75/13
81/17 87/20 104/14
108/14 127/4 131/1
144/23 164/1 164/5
164/5 174/24 175/15
181/16 181/17 182/4
182/23 183/3 183/3
186/7 188/19
takes [2] 85/10
126/25
taking [12] 3/5 21/15
25/24 37/13 42/7 45/4
108/5 130/6 133/3
142/20 156/16 174/22
talk [14] 25/8 45/7
45/7 53/20 72/14
89/12 119/11 139/22
143/23 146/25 147/16
183/7 193/5 193/8
talked [13] 11/21
21/23 37/1 51/14 55/3
55/7 84/6 90/13
101/16 111/5 124/3
137/9 186/14
talking [16] 5/5 6/20
11/8 11/8 19/17 20/24
51/24 97/20 100/20
103/25 111/17 112/1
114/4 140/19 141/16
143/8
talks [10] 53/2 68/15
84/10 95/21 95/23
104/1 112/5 121/14
128/4 183/3
tamper [2] 114/20
115/14
tangent [1] 25/19
target [1] 165/9
Teach [1] 150/5
team [89] 4/17 4/24
5/7 5/17 5/25 6/15
6/15 7/4 7/10 7/14
10/4 12/1 12/8 24/5
24/5 34/2 42/12 42/20
52/3 53/23 54/1 55/3
56/23 62/6 63/20
65/19 68/17 69/3
69/12 72/13 79/18
81/5 89/12 92/16
92/16 92/18 98/15
99/13 103/17 105/23
113/14 114/5 115/12
118/7 123/4 140/6
142/8 147/22 153/19
153/22 154/1 154/4
154/5 154/12 154/17
154/18 154/19 156/20}
156/24 157/16 159/9
159/10 159/24 161/17
161/25 162/1 165/8
165/16 165/18 165/19}
165/20 165/24 166/5
166/6 166/10 166/18
167/1 167/2 171/24
173/20 178/7 178/10
180/1 180/4 180/6
180/7 180/19 180/22
190/10
teams [4] 23/13
40/15 65/20 97/18
teams' [1] 40/12
tech [5] 30/24 110/4
110/5 113/14 128/22
technical [6] 24/25
54/14 60/18 120/19
166/19 186/2
technology [25] 3/7
3/14 4/11 10/17 13/7
15/24 15/24 32/1
84/15 109/25 122/10
152/14 152/19 152/19
153/5 153/10 153/19
154/17 157/8 159/9
161/25 163/19 163/20
169/21 184/7
telecoms [2] 44/25
45/4
telephone [4] 26/19
30/13 95/12 147/18
telephony [2] 45/9
45/16
tell [4] 121/6 125/13
132/23 187/11
telling [4] 20/5 110/9
110/11 190/12
tells [1] 107/18
ten [5] 20/17 73/19
98/23 149/6 155/4
ten-minute [1] 149/6
tend [1] 76/24
tenure [5] 27/11
100/5 136/19 155/25
157/8
term [3] 16/2 97/8
117/15
terminology [1]
166/2
terms [24] 7/6 10/8
14/2 17/11 22/19 27/9}
29/17 36/7 36/18
37/14 41/15 41/18
43/4 46/22 49/12 68/7I
71/5 77/11 110/13
112/12 115/7 170/8
177/6 193/14
test [14] 32/11 88/13
92/20 113/22 114/24
115/16 115/19 141/20
144/14 144/18 159/24}
159/24 160/2 160/2
tested [3] 100/22
115/17 159/5
testing [19] 38/13
62/2 65/1 66/3 66/17
67/15 82/18 100/17
100/19 159/6 159/19
159/21 159/23 160/1
160/9 160/10 162/8
175/17 186/4
than [25] 14/7 20/20
28/6 28/14 29/3 38/24)
43/2 43/9 51/6 51/16
52/2 54/18 72/19
82/15 86/25 87/10
93/20 96/25 98/24
100/17 110/12 113/3
146/24 162/6 186/7
thank [75] 1/4 1/5
1/11 1/24 3/5 3/18
7/15 8/22 13/18 19/6
27/21 33/23 39/13
41/1 46/20 57/10
57/22 57/23 58/9
58/17 58/18 60/21
60/22 73/15 98/4
98/25 107/6 107/13
108/3 108/22 109/13
109/18 109/19 118/13I
122/22 131/14 131/17I
131/20 141/5 144/6
148/15 149/2 149/4
149/10 149/11 149/18I
149/23 150/20 151/11
151/20 152/2 152/5
152/13 153/1 153/12
153/17 167/21 169/7
4171/2 172/21 173/1
175/14 181/13 184/11
184/11 188/22 188/24I
189/7 193/20 193/21
193/22 194/1 194/6
194/7 194/10
thanks [3] 118/7
118/18 127/20
that [1424]
that's [157] 2/21 3/4
4/2 4/13 5/18 12/20
13/16 16/2 16/11
19/15 21/10 22/21
24/4 25/3 28/2 28/11
28/12 28/24 30/3 30/4I
31/12 33/22 47/2
47/24 50/1 50/6 51/4
53/2 53/21 54/6 54/18
60/18 60/21 64/8 66/7I
66/12 67/4 67/11
67/16 71/4 74/7 72/2
72/7 73/12 73/14 76/3
77/25 78/2 78/5 82/7
82/8 83/7 83/7 83/8
85/7 89/16 92/11
93/18 95/16 95/16
96/8 96/19 98/24 99/7I
99/14 99/21 99/24
101/5 1041/6 105/6
105/14 105/20 105/20I
105/24 106/3 106/19
107/4 107/23 108/21
109/6 111/15 114/8
114/13 115/21 117/18I
118/3 118/12 118/15
119/8 123/12 124/10
130/8 131/15 137/12
138/17 143/7 150/8
150/12 151/10 151/11
151/21 151/24 152/16I
152/21 152/25 153/4
153/6 153/21 153/24
154/11 154/13 154/19]
154/22 154/23 155/6
(79) sure... - that's
T
that's... [42] 156/9
157/2 157/2 157/11
157/20 158/21 160/13
161/24 162/7 162/23
163/2 163/6 163/16
165/5 165/19 168/6
170/18 170/19 172/20
175/23 177/14 178/5
179/8 179/15 179/19
179/21 183/18 183/19
184/15 184/17 184/17
185/3 185/6 185/6
185/11 187/1 187/3
189/6 191/7 192/20
193/14 193/23
theft [6] 5/8 8/6 21/25]
51/2 71/20 181/19
their [37] 3/20 4/20
23/16 24/13 25/3
27/16 27/17 37/6 44/6
45/4 53/3 74/8 81/4
85/11 85/11 86/22
89/12 90/16 91/8
96/12 97/23 108/19
116/18 118/13 125/20
126/19 129/23 130/3
131/23 139/23 163/8
163/9 164/3 165/12
166/18 166/19 189/21
them [32] 6/18 9/19
11/4 26/6 32/22 35/24}
37/21 38/12 48/22
55/7 61/2 61/7 62/25
65/9 67/8 76/7 76/20
94/7 95/13 99/6
102/17 102/23 120/1
130/24 135/1 148/24
150/20 159/3 161/19
172/9 182/4 193/8
theme [1] 25/25
themes [1] 25/8
themselves [4] 18/9
29/15 35/17 130/2
then [87] 3/23 10/13
11/17 12/25 13/5
13/18 13/20 14/3
14/17 15/3 16/23 17/4}
19/2 31/2 31/6 31/19
33/20 34/11 34/22
37/18 39/20 39/21
40/14 41/6 44/19
44/24 46/5 50/16
50/17 51/22 55/24
56/20 57/4 58/4 60/10
61/18 63/2 63/24
66/18 69/8 76/5 78/16)
79/17 81/12 83/4 91/5
95/7 98/20 100/24
100/25 102/5 102/20
104/3 104/4 110/6
112/7 113/6 113/16
114/2 114/6 117/20
121/6 123/16 124/18
124/22 126/7 127/12
127/13 127/17 128/24)
132/10 137/1 143/10
147/8 149/8 158/18
160/25 161/4 167/15
169/7 175/18 183/6
188/13 191/23 192/6
192/15 192/24
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44/9 44/19 44/19
44/24 50/21 67/7
67/10 68/14 69/10
69/15 69/25 72/6
75/11 76/11 77/17
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120/12 126/5 128/11
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168/12 168/13 176/10}
176/21 177/1 184/13
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191/4 193/17
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91/13 99/23 100/7
121/16 128/7 142/20
167/4 168/7 193/17
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20/12 26/8 28/3 30/10
31/11 34/8 41/15 48/2
48/14 49/23 54/12
61/1 63/20 63/22
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107/20 121/18 129/21
141/16 167/25 169/19)
179/6 182/10
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16/1 17/7 18/8 21/4
21/24 22/10 24/24
25/9 26/18 28/9 32/21
35/13 35/13 37/5 37/7
43/22 55/8 60/10
60/11 63/16 63/16
63/25 65/12 65/13
66/19 70/14 70/15
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100/2 101/23 105/21
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122/17 125/1 125/20
128/7 128/9 129/13
130/6 136/14 138/13
141/19 141/21 141/21
141/22 142/12 143/11
144/14 144/15 144/15
145/9 145/10 145/11
148/23 156/5 157/5
157/25 158/7 159/4
159/6 161/18 161/18
165/22 168/4 168/4
168/5 172/9 173/25
174/4 174/5 174/18
176/24 180/2 180/22
181/6 193/4 193/5
193/7 193/9
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104/16 117/16 134/11
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18/16 20/3 21/5 23/4
23/5 23/7 23/24 24/1
25/12 25/19 25/25
26/24 28/12 29/12
29/23 33/12 36/25
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44/20 44/21 48/12
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59/11 62/24 64/21
66/12 66/25 67/12
68/14 69/1 69/5 73/9
76/8 77/14 80/7 80/14
81/23 82/13 83/6 84/6
84/9 84/20 86/12
86/16 88/17 90/13
91/9 92/11 93/20
94/23 94/24 95/13
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166/22 170/6 173/12
174/16 175/7 175/24
176/7 176/25 178/11
178/13 178/15 178/16
179/16 179/25 181/4
181/6 182/15 183/2
185/19 186/1 186/5
186/14 187/1 188/18
189/10 189/17 190/1
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40/20 42/2 132/6
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132/6
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26/9 26/17 27/12 29/9
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162/16 167/20 169/6
173/4 175/16 176/5
178/3 186/24 187/2
187/16 188/18
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125/4 148/10 158/5
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186/4 186/21 189/13
189/15 192/6
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84/21 101/5
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thus [1] 34/16
ticket [1] 134/25
tied [4] 85/7 105/11
105/12 123/20
tier [2] 24/16 110/4
tight [2] 84/9 176/12
tightened [1] 176/9
time [120] 2/13 2/14
4/7 10/11 10/22 11/11
11/20 12/5 12/11
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19/20 20/12 21/12
21/15 22/14 24/2 24/3I
26/5 27/2 28/17 29/20
29/24 30/24 31/8 32/1
38/23 39/10 44/7 45/1
47/8 48/17 48/20
48/23 49/3 49/19
(80) that's... - time
T
54/13 55/11 57/10
57/13 59/11 59/17
64/12 64/13 64/22
70/5 75/8 81/2 81/3
81/5 83/12 83/13
85/13 85/23 86/13
87/2 87/14 87/24
89/12 89/14 92/11
92/20 93/14 94/16
94/17 94/20 97/23
98/17 100/21 101/9
105/24 106/4 108/11
120/1 120/10 123/19
123/22 125/13 127/5
127/20 128/2 129/4
135/4 136/1 137/7
139/1 140/18 142/12
142/13 148/8 155/12
155/18 165/2 170/6
172/8 178/13 183/11
187/23 194/5
timeline [1] 29/8
times [10] 26/9 38/22
104/15 112/25 113/8
127/2 130/18 133/24
138/25 190/19
timescale [2] 125/6
170/9
timetable [1] 185/24
timing [2] 141/25
144/16
timings [1] 90/4
title [14] 10/13 10/16
10/24 12/13 12/19
13/22 14/2 14/3 14/4
14/22 153/3 153/8
165/20 171/10
today [19] 1/5 3/17
11/4 16/14 31/4 31/5
32/7 87/20 96/10
97/11 97/20 116/2
138/15 149/3 149/9
150/13 169/22 183/10
190/19
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together [15] 12/17
37/23 39/19 42/15
49/22 61/23 62/6
65/19 65/20 73/7
78/24 92/18 93/11
129/22 131/15
toing [1] 92/17
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17/18 17/19 18/16
18/24 22/23 29/5
41/14 42/6 52/7 52/8
54/3 62/12 66/7 69/9
time... [78] 51/22
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101/25 102/24 103/13)
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99/11 99/21 111/8
123/3 124/7 126/4
126/9 129/7 132/15
144/15 174/5
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193/4 194/9
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146/21
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34/25 65/25 96/10
97/12 98/3 106/3
162/17
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13/3 13/9 14/14 18/3
54/22 54/25 56/7
64/23 65/10 73/10
76/9 94/23 95/13
95/14 112/6 121/16
132/9 136/20 155/25
tool [1] 175/22
toothed [1] 22/17
top [10] 7/15 19/6
24/15 25/6 37/7 39/7
61/18 133/24 139/8
181/13
topic [7] 22/21 57/25
80/8 89/11 90/1
177/24 184/13
topics [1] 131/24
total [1] 8/9
towards [2] 100/5
126/3
TP [2] 60/7 60/8
trace [1] 148/22
traced [1] 148/23
track [2] 62/7 185/16
trading [4] 158/21
165/12 174/19 192/9
trail [5] 74/6 80/24
83/22 83/24 90/21
training [11] 3/6 4/22
15/25 16/22 17/17
24/23 57/4 96/8 96/14
111/6 139/23
transaction [8] 60/16
80/21 163/4 165/16
167/3 167/9 175/21
180/11
transactions [1]
183/13
transcript [1] 58/9
Transit [2] 5/1 11/13
transmitted [1]
178/23
transparency [1]
164/2
travels [1] 78/10
treating [1] 146/5
treatment [1] 168/7
trial [6] 58/24 115/17
30/12 30/23 31/7 31/9)
108/23 117/13 146/10)
22/16 30/7 30/22 31/6
31/9 41/3 43/23 50/25)
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trigger [4] 189/19
191/16 191/24 193/1
troubles [1] 39/24
true [11] 1/21 9/25
16/14 82/1 104/20
151/5 151/17 152/2
152/10 184/17 185/6
truly [2] 12/22 53/10
try [3] 98/25 99/1
103/5
29/3 32/3 35/12 45/6
45/19 49/25 75/20
88/20 90/24 97/18
124/4 124/5 135/12
142/10 187/23
Tuesday [1] 1/1
turn [8] 1/17 19/5
117/20 136/7 140/25
150/15 151/1 151/13
turned [2] 53/8
141/15
Turner [1] 74/9
twice [1] 128/15
two [47] 9/19 18/23
19/6 19/9 19/16 20/3
20/4 26/4 26/22 27/9
31/11 31/17 31/20
37/7 42/17 43/21
44/19 47/25 54/18
55/15 59/19 61/20
67/3 67/8 70/12 71/2
72/5 74/23 78/11
84/24 89/17 91/21
94/3 94/7 94/23 95/12
113/3 131/15 131/24
141/23 144/19 147/19}
149/21 159/17 181/8
192/6 194/3
two-thirds [1] 26/22
twofold [1] 34/5
type [29] 4/18 6/10
7/9 11/17 18/4 20/22
20/25 25/1 25/8 32/11
36/10 37/19 50/13
52/5 53/16 55/7 56/14
56/16 57/5 57/6 84/7
84/11 84/14 86/15
87/10 97/15 138/12
165/21 191/24
types [2] 34/8 89/20
Uo
UK [4] 11/16 37/6
37/7 182/3
UK Government [1]
182/3
ultimately [7] 14/25
43/23 46/18 156/18
163/18 163/23 186/5
117/20 117/23 118/10
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106/20 118/13 123/25)
unable [1] 28/17
unauditable [1]
90/19
unaware [2] 15/20
136/19
Unbalanced [1]
60/17
unclear [3] 122/21
166/8 168/11
uncorruptible [2]
83/24 129/2
under [14] 7/8 40/1
43/6 53/2 86/12 95/2
144/1 145/17 169/8
169/19 179/16 181/13
182/1 184/19
underlying [7] 28/18
30/2 30/6 30/8 166/11
167/15 168/9
understand [32] 4/16
5/6 6/13 10/2 20/11
22/18 29/21 51/3
52/12 61/1 68/2 70/4
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105/1 107/17 110/21
145/6 155/15 155/19
158/20 168/17 171/13
171/16 174/10 175/2
185/22 188/7 191/22
192/18
understanding [19]
7/2 8/8 15/4 41/7 51/9)
80/25 81/19 83/12
90/15 91/6 111/15
144/2 165/5 165/17
172/12 185/4 185/15
186/5 193/18
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20/2 21/11 27/1 27/12
41/25 52/13 52/21
53/11 53/14 60/2
68/21 70/5 83/8 83/14
111/17 161/3
undertake [1] 42/1
undertaken [1] 3/6
undertaking [2] 14/8
17/14
underway [2] 38/14
49/23
underwrite [1]
125/22
undoubtedly [1]
142/14
unduly [1] 182/21
unhappy [2] 25/24
37/25
unilaterally [1]
182/10
unit [3] 60/1 179/17
180/5
unless [2] 164/11
172/9
unlikely [1] 167/5
unnecessary [1]
148/25
unreliable [2] 174/6
174/18
unsatisfactorily [1]
54/20
unsatisfactory [1]
144/22
until [14] 17/21 39/4
50/24 111/13 120/4
129/3 136/12 137/6
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untold [1] 117/46
unusual [1] 63/14
unwillingness [1]
175/1
up [85] 2/22 3/5 7/19
8/22 11/17 12/25
15/12 18/1 31/14 38/1
39/2 42/21 44/23
45/24 49/13 51/17
59/14 61/15 61/19
66/11 69/14 70/23
71/2 74/25 75/2 76/16I
78/9 80/11 84/19 86/7I
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98/20 99/19 99/21
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123/20 126/12 127/5
127/12 127/17 127/22I
128/2 128/13 128/18
129/3 130/15 131/1
133/8 134/19 136/7
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148/6 154/5 156/19
157/6 165/10 168/4
171/2 171/3 172/21
173/17 176/9 181/11
186/5 186/21 191/21
update [5] 32/9 36/6
72/11 159/8 164/18
updates [2] 16/5
73/20
upon [15] 2/22 6/13
42/10 87/8 104/13
154/25 155/7 156/14
157/24 169/23 170/2
175/7 182/10 190/16
190/17
upside [1] 77/13
us [35] 1/3 26/15
34/20 36/16 36/25
37/25 38/3 41/9 57/21
94/1 98/7 107/18
109/17 110/18 111/8
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129/7 131/3 132/3
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158/17 160/18 160/20}
163/21 164/7 180/9
(81) time... - us
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us... [2] 187/11
192/21
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176/15 176/17 183/20
183/24 184/2 190/24
191/9
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54/12 81/16 81/17
83/18 87/4 93/16
94/17 99/16 104/17
156/10 174/14 181/24}
190/18 193/10 193/14
193/15
user [8] 60/10 84/10
120/17 120/18 124/2
160/23 161/12 179/25
users [2] 15/25 84/24
uses [2] 82/9 184/6
using [8] 118/10
141/20 144/15 147/16
191/10 192/13 192/25}
192/25
usual [1] 157/16
usually [8] 37/11
55/15 69/13 82/8
82/12 105/16 105/18
134/19
utilise [1] 162/17
Vv
validate [1] 90/20
validates [1] 91/4
validating [1] 82/18
validation [2] 138/13
143/14
value [1] 167/7
van [1] 127/18
various [12] 8/24
72/14 84/21 106/8
112/25 116/3 121/13
127/9 127/25 153/23
169/6 169/20
vast [1] 180/2
Vehicles [2] 5/1
1112
vendor [1] 69/19
Vennells [17] 12/13
13/20 88/9 110/10
111/13 111/20 114/7
118/4 127/7 127/13
138/2 141/18 142/7
142/23 142/24 146/17) ¥
146/25
Vennells' [2] 143/7
144/6
verbal [1] 21/8
verbally [1] 19/23
verification [2] 145/3 w
145/17
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verify [1] 159/6
Verizon [3] 2/24 3/5
3/18
versa [1] 147/9
version [6] 15/6
100/13 115/24 116/2
117/23 159/5
versus [3] 30/16 44/6
76/4
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11/15 11/15 11/22
14/4 17/19 18/5 22/13
22/13 25/5 26/21
37/25 52/4 52/4 55/1
58/18 61/2 69/14
76/22 78/21 81/14
81/14 81/23 81/23
86/11 97/6 97/16
98/25 102/7 102/17
103/1 103/11 103/14
109/2 119/17 121/14
121/18 123/20 127/4
130/7 130/16 130/23
133/10 133/22 137/22)
137/24 141/1 142/12
143/8 144/11 145/12
148/15 149/9 155/3
156/2 160/21 162/11
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178/22 178/22 180/25)
182/16 182/16 183/8
184/7 184/12 187/10
188/22 194/1 194/3
194/6
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56/22 74/4 75/7 85/19
85/20 86/10 91/2
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115/7 136/13 140/7
177/8 189/18 192/2
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24/12 32/25 42/20
53/4 54/13 66/9 67/1
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90/4 91/17 93/14 96/2
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viewpoint [3] 31/1
31/5 129/4
[2] 76/19 87/8
ing [2] 15/15
277
volume [3] 40/7
187/13 187/25
Ww
Wi
walk
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76/18
Walton [7] 171/4
171/6 172/22 173/18
173/19 189/16 190/12
waning [1] 109/9
want [52] 12/19 16/6
17/6 19/17 20/1 21/19
22/15 27/14 38/2 38/4
43/25 44/15 44/16
45/10 55/23 60/24
72/2 82/5 83/11 88/20
90/7 92/10 92/21
94/22 95/2 105/15
115/5 117/15 124/5
128/14 128/19 129/20
131/24 132/3 132/4
133/6 133/7 133/9
133/13 133/21 135/22
135/23 136/6 136/7
136/9 137/24 138/19
139/1 146/8 167/19
180/4 189/3
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14/20 24/19 25/1 25/4
27/5 38/25 38/25
47/18 108/24 113/1
121/15 125/24 126/9
130/4 134/24 153/17
171/16 193/19
wanting [1] 186/2
wants [7] 98/13
121/1 142/25 143/10
143/14 143/20 143/21
warned [1] 58/10
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wasn't [42] 12/22
13/2 14/10 18/11
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53/10 53/18 55/2 66/3
71/9 72/22 82/3 84/22
84/25 85/2 89/25
89/25 92/15 102/25
104/7 113/4 115/4
116/21 118/11 120/4
125/10 128/17 129/18}
130/3 134/15 135/19
172/13 187/6
watch [4] 146/21
waters [1] 33/9
wave [2] 100/25
100/25
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11/15 12/5 18/10
22/18 25/3 25/5 26/14
30/23 31/4 31/9 33/11
33/17 37/21 51/11
66/18 69/5 71/1 73/1
78/6 78/10 79/25
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127/22 134/15 135/17I
145/17 147/7 158/16
164/22 165/23 172/14}
183/9 187/17 192/3
193/17
ways [4] 33/12 94/3
161/13 192/7
we [385]
we'd [7] 11/4 33/8
45/20 94/19 144/20
161/11 176/22
we'll [13] 9/14 26/25
29/13 29/25 33/23
44/21 70/25 98/21
108/3 109/12 146/17
173/18 194/8
we're [29] 23/6 32/18
43/15 44/20 44/21
55/20 56/10 56/14
56/15 67/20 72/3 72/6
79/1 93/1 94/3 94/21
100/20 103/25 108/9
120/3 123/12 130/10
135/17 135/25 140/18}
178/20 178/23 185/17,
185/17
we've [24] 9/19 30/20
30/20 32/19 49/15
57/11 67/3 70/17 72/4
90/13 108/14 110/6
110/15 115/22 130/18}
134/11 143/4 153/1
175/16 176/16 177/6
180/11 187/22 193/15]
wealth [2] 87/16
94/10
weeds [1] 87/17
week [5] 13/14 15/1
74/3 92/12 110/23
weekend [1] 189/18
weekly [18] 41/7
91/22 93/2 93/25 95/5)
110/22 111/17 119/17}
125/14 126/3 129/8
136/13 136/16 137/6
137/12 142/11 147/13}
147/25
weeks [9] 7/4 22/6
30/11 30/12 31/6 32/8)
42/6 114/23 144/21
well [57] 4/14 10/6
14/4 20/3 20/22 27/13}
29/11 30/4 38/13
41/22 41/23 53/9 56/5)
56/5 59/7 62/24 66/9
66/12 66/21 69/5 74/7
78/21 79/14 86/6
98/17 98/19 99/1
99/21 99/25 102/4
105/4 108/6 109/6
111/7 114/16 115/9
117/6 118/6 120/8
121/20 122/19 123/5
124/7 128/3 128/24
135/12 142/5 142/12
146/9 148/20 180/4
181/6 182/16 183/2
191/23 193/13 194/1
went [18] 21/6 23/7
25/19 26/11 42/18
43/18 46/25 47/5
70/15 79/14 91/8
112/4 121/9 128/6
130/8 130/9 159/3
192/18
were [218]
weren't [7] 10/24
25/14 32/10 35/17
89/8 107/19 121/19
what [220]
what's [14] 52/6 80/9
102/23 106/1 106/18
127/25 142/25 145/19}
154/12 154/21 160/3
175/21 176/19 191/22)
whatever [3] 37/12
79/23 89/5
when [91] 3/9 4/16
4/22 5/4 6/5 12/5
13/16 14/14 15/3
18/11 19/22 21/1 21/4)
21/24 22/22 24/16
26/4 29/2 29/11 29/13}
29/14 29/15 30/6 32/4
33/23 36/4 43/3 47/21
48/24 48/25 49/10
50/16 50/16 50/22
55/3 55/7 59/4 59/24
59/24 60/6 60/6 63/3
65/17 65/19 67/25
82/19 85/5 85/15
85/19 92/25 95/17
95/18 99/10 99/18
102/1 105/18 107/22
109/23 112/11 113/15]
114/3 115/11 115/13
128/17 129/1 129/4
129/7 129/8 134/20
134/21 135/11 138/14I
143/18 144/17 144/18)
148/22 150/6 160/4
160/20 161/18 170/8
170/14 175/10 176/24}
177/18 179/9 180/18
187/3 189/3 189/13
189/14
when I [4] 50/22
whenever [1] 44/12
where [90] 12/7 13/3
21/5 21/5 23/9 26/2
26/9 27/15 28/13
30/14 34/9 34/19 36/5I
36/6 36/14 38/23
43/10 44/5 44/6 44/20
45/24 47/2 51/13
51/20 52/10 55/8
56/19 56/23 61/2
(82) us... - where
Ww
where... [61] 67/19
68/11 68/11 72/6
80/25 81/4 81/8 82/15
83/6 85/8 87/19 89/18
90/24 91/8 91/12
92/10 92/11 93/22
93/25 94/9 94/12
94/21 96/6 96/10
97/11 100/25 102/17
103/6 105/17 108/10
110/18 116/7 121/10
121/25 125/1 126/4
126/13 131/16 134/24}
136/13 137/15 138/19
144/23 147/3 154/13
155/20 159/21 161/7
165/2 169/12 174/16
176/12 176/13 178/15
178/20 180/4 185/17
188/7 188/10 189/20
193/4
whereby [5] 158/13
158/18 160/20 176/10}
178/24
wherever [1] 117/16
whether [27] 15/16
27/5 27/8 27/16 41/17,
49/3 50/6 50/19 59/1
63/5 67/9 98/11
115/13 115/14 115/15}
118/15 123/1 127/6
159/4 160/19 160/22
160/23 180/18 182/25
188/4 189/22 193/9
which [114] 2/4 4/10
4/11 5/1 5/17 13/11
14/4 14/18 15/6 17/8
18/13 18/17 18/18
19/7 20/6 20/6 21/12
22/2 24/18 26/25
27/17 28/4 30/9 35/20)
39/18 46/18 47/25
48/10 52/10 58/13
59/16 62/15 62/21
66/6 69/5 71/16 71/17,
73/1 73/12 74/16 76/8
77/6 78/8 84/7 86/12
86/19 89/9 90/9 90/13
91/25 92/4 93/16
94/25 95/13 96/21
100/8 100/9 105/13
110/12 113/24 115/25}
117/22 120/21 121/12)
121/22 125/21 125/25)
128/1 128/2 128/3
128/10 133/24 141/22)
143/9 145/3 147/14
148/12 150/4 150/5
150/14 150/22 152/5
153/25 155/8 156/5
158/5 158/7 162/5
162/21 163/19 163/23
164/14 166/17 168/8
172/18 175/2 175/14
176/23 177/24 179/11
179/22 181/1 181/8
181/20 182/13 184/15)
185/23 187/6 189/2
190/22 192/13 192/25)
194/2 194/3
while [2] 146/22
149/21
whilst [3] 3/10 79/3
157/15
white [4] 44/25
Whitehead [3]
120/14 120/15 121/7
whizzing [1] 135/25
who [31] 5/23 6/11
6/16 23/23 33/20
44/24 53/25 58/4
71/19 79/5 79/12
86/11 94/6 97/21
98/13 99/5 109/20
112/14 114/3 116/8
116/11 128/7 131/22
136/5 141/19 144/15
161/10 161/16 178/24)
180/1 190/14
who's [1] 143/10
whoever [2] 55/15
89/14
whole [13] 22/12
25/25 29/23 34/7
37/25 43/6 56/8 78/1
81/19 82/2 82/18
87/16 113/14
whom [2] 138/13
143/15
whose [1] 93/5
why [48] 9/16 10/25
24/4 31/24 38/17 61/8)
62/18 63/1 63/5 64/21
75/16 77/19 78/8
78/15 85/21 89/16
90/7 95/16 101/23
107/12 122/15 125/17)
129/10 129/11 130/8
131/4 142/16 142/17
144/14 144/16 147/14)
147/15 155/15 163/17,
174/22 174/24 178/9
180/7 182/11 182/17
182/24 191/9 192/13
192/14 192/15 192/17,
192/20 193/10
widow [1] 136/4
will [49] 8/4 8/14
14/18 32/8 40/11
40/18 40/19 41/16
41/23 60/20 60/24
61/8 61/23 65/22
65/24 69/12 73/16
73/21 78/7 80/8 98/25)
99/1 99/1 102/14
105/9 109/10 116/17
141/19 141/20 142/18}
143/23 150/13 161/8
170/16 178/12 178/16
178/18 178/21 178/25)
180/9 180/10 180/11
181/24 183/20 183/24
184/8 191/9 191/15
191/17
Will's [3] 61/10 63/8
73/20
willing [4] 42/1 98/11
123/10 131/2
Wilson [8] 7/13 7/18
7/21 8/18 9/13 136/3
136/3 136/4
winded [2] 96/2
146/10
window [4] 56/16
57/5 91/12 92/2
wish [1] 31/10
wished [2] 47/17
86/17
withdraw [1] 122/22
within [36] 5/14 5/20
TIT TIT 1714 22/24
23/13 23/14 23/23
32/8 34/9 38/8 42/22
50/11 53/23 79/11
99/1 112/1 117/4
117/4 117/6 124/25
153/11 154/1 156/7
156/20 159/24 161/1
166/17 174/20 178/9
183/13 184/24 186/20
189/11 191/16
without [8] 12/16
80/22 91/2 91/4 96/12
132/5 192/1 192/6
WITN03680100 [1]
150/22
WITN03680200 [1]
151/9
WITN03680300 [1]
151/21
WITN03680400 [1]
152/7
WITN11130100 [2]
15/12 136/8
witness [31] 1/5 1/8
1/13 4/8 73/13 108/6
108/11 108/12 108/13
109/3 109/8 111/9
113/18 118/23 131/9
149/2 149/19 149/23
156/12 156/21 158/3
160/11 170/13 171/9
172/23 176/3 177/3
181/5 186/23 194/2
194/5
witnesses [3] 48/24
133/6 186/19
won't [8] 41/2 69/9
69/10 94/6 94/19
106/21 116/17 128/1
wonder [8] 7/11
15/11 58/16 59/14
80/11 88/4 164/13
170/21
wonderful [1] 87/23
word [4] 43/21 73/23
73/24 190/18
worded [1] 183/8
wording [2] 121/12
123/21
words [11] 19/25
21/13 22/16 26/6
35/15 93/16 99/16
115/5 123/15 128/17
189/20
work [22] 10/14
14/16 22/11 26/13
26/14 29/6 32/19
96/14 97/21 103/5
110/5 110/18 123/25
138/13 152/23 155/20}
156/18 158/19 170/17}
177/8 185/20 194/4
worked [8] 2/10 6/22
6/25 22/19 81/20
93/15 97/8 152/17
worker [3] 181/18
181/25 183/7
working [14] 23/13
42/21 49/25 55/4 55/5)
80/17 92/12 92/24
97/24 116/16 117/10
126/10 145/12 170/4
workplace [1] 189/15}
works [3] 12/17
17/18 38/5
workstreams [1]
157/13
world [5] 30/12 30/23
30/24 32/1 49/12
worried [3] 35/13
125/3 129/19
worry [4] 19/25 32/20
82/24 145/16
worth [4] 16/21 17/17I
35/24 142/16
would [173] 3/16
11/1 12/21 13/21
13/22 14/19 14/20
16/15 18/8 18/24
18/25 19/3 24/15
24/16 25/3 25/6 25/17,
26/2 26/7 26/14 28/24
28/25 29/9 31/10 33/8)
33/17 34/20 36/11
37/1 37/3 38/10 39/15
43/4 43/18 44/12
48/13 49/5 49/9 52/23
53/4 55/12 55/13
55/13 55/14 56/18
56/24 59/11 60/2 61/5)
62/15 63/13 64/23
65/17 66/23 67/14
67/22 67/25 68/9
68/16 69/14 69/16
69/20 69/22 69/24
72/9 72/10 72/13
72/20 74/25 75/10
75/22 76/24 76/24
TTI17 78/8 78/19
78/19 78/20 78/24
79/24 80/15 82/14
82/24 83/19 83/22
84/14 84/25 86/16
87/17 88/7 89/12 97/7
98/8 101/22 102/4
102/7 102/21 106/10
106/24 110/19 112/23)
113/8 113/9 114/22
119/10 119/21 119/23}
120/21 121/9 125/11
132/21 132/23 132/25)
133/2 134/5 134/5
134/7 134/8 134/9
134/22 135/2 140/22
142/5 142/6 142/10
142/14 142/21 143/23)
145/2 145/22 145/24
146/20 154/6 154/24
155/19 158/4 158/18
159/15 161/1 163/21
165/20 165/22 166/13)
166/15 166/17 167/16)
168/16 168/18 168/18)
168/21 170/10 177/12!
180/7 180/15 180/15
180/19 180/21 180/22)
182/14 182/24 182/24)
183/17 185/8 185/9
186/17 187/17 188/1
188/17 190/2 192/8
192/15 192/16 192/21
wouldn't [8] 42/7
43/12 75/9 116/19
121/11 132/23 142/9
192/17
wrap [1] 45/24
wrapped [1] 15/24
write [7] 17/14 37/2
60/23 74/3 75/6
128/10 130/14
writedown [1] 70/25
writer [1] 73/6
writes [2] 138/6
141/18
writing [7] 76/16
92/14 95/11 112/21
142/24 167/7 167/8
written [8] 33/11
45/12 56/13 61/6
79/25 82/9 102/22
107/18
wrong [19] 15/19
19/24 21/9 31/22
31/25 33/15 43/12
43/13 66/15 70/20
70/20 76/10 81/15
105/11 118/15 124/17
(83) where... - wrong
Wo
wrong... [3] 128/11
148/22 192/19
wrongly [3] 32/24
95/1 114/23
wrote [2] 38/23 100/7
Y
yeah [15] 73/3 75/9
79/1 92/2 99/16
126/21 131/5 135/10
137/14 138/5 139/7
139/19 140/24 141/9
176/6
year [18] 3/19 13/10
50/17 51/7 86/13
120/4 124/11 130/21
140/20 148/5 153/6
153/7 164/6 170/25
177/19 177/20 181/4
189/9
year's [1] 177/17
years [17] 2/4 2/7 6/8
14/12 15/14 16/9
18/23 23/5 92/20 97/9}
97/14 97/24 100/5
110/24 152/18 152/23)
187/23
yes [226]
yet [9] 74/25 78/6
110/2 122/14 123/23
124/9 131/2 170/15
191/1
you [903]
you'd [14] 27/3 38/7
42/2 42/5 42/5 62/13
67/12 78/9 78/18
98/11 123/3 126/13
132/5 148/23
you'll [7] 7/23 37/9
44/15 94/6 116/1
192/13 193/3
you're [73] 7/23 16/7
16/18 19/17 29/2 29/4}
29/5 30/16 32/4 32/4
33/13 33/16 38/3
46/14 49/11 51/15
51/16 51/20 53/7 58/8
66/10 67/7 67/9 68/19)
70/20 76/11 77/14
79/15 80/4 81/9 81/9
81/10 85/5 86/23 87/1
88/17 89/6 90/21
92/13 93/21 94/24
100/23 101/10 102/20}
104/1 123/10 123/19
123/23 124/8 124/9
126/2 126/3 126/4
127/14 127/15 130/13}
130/14 135/12 135/13}
140/7 141/8 141/15
143/2 160/9 164/14
170/18 175/8 178/1
179/2 179/3 190/17
190/21 194/4
you've [62] 10/15
16/2 19/7 23/20 29/6
30/4 40/6 44/2 44/2
45/22 45/25 49/11
49/12 64/11 69/1
83/11 83/12 89/19
90/11 90/12 90/20
91/1 91/5 91/16 91/16)
91/20 100/11 100/15
100/22 101/6 111/8
119/13 124/7 124/15
124/19 129/11 131/25)
132/4 132/15 135/5
135/6 135/21 135/23
137/9 137/11 139/25
140/19 140/20 150/3
150/9 159/17 162/8
168/7 175/8 175/24
175/25 176/4 177/25
179/11 183/11 188/11
193/16
Young [60] 1/6 1/9
1/12 1/24 7/13 18/12
26/24 57/24 66/1
66/13 71/4 71/23
72/20 74/17 80/7 84/3)
84/22 85/17 85/20
86/8 86/19 87/13
87/25 96/18 96/20
98/4 98/8 99/4 103/3
104/8 104/21 105/5
106/14 107/7 107/21
108/10 108/14 109/23}
112/22 112/24 114/7
119/19 121/1 130/25
131/8 131/21 133/25
137/23 138/17 139/10)
141/8 143/2 144/8
145/21 146/16 148/16)
148/19 148/20 177/15)
195/2
Young's [2] 84/5
86/23
your [229]
yourself [1] 21/11
Zo
zeroised [1] 60/12
(84) wrong... - zeroised