INQ00001197 - Transcript (16/10/2024): Post Office Horizon IT Inquiry - Tracy Marshall [WITN1161] and Melanie Park [WITN1160]

Evidence on official site

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The Post Office Horizon IT Inquiry

Wednesday, 16 October 2024

(10.03 am)

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

SIR WYN WILLIAMS: Yes, thank you very much.

MR STEVENS: Sir, we'll be hearing from Tracy Marshall this
morning.

SIR WYN WILLIAMS: Yes. Can Ms Marshall be sworn, and then

I'll raise a very short matter with you.

MR STEVENS: Of course.

TRACY LOUISE MARSHALL (affirmed)

SIR WYN WILLIAMS: Mr Stevens, the issue which I wish to
raise with you relates to some questions which Mr Beer
asked of Mr Read last week in respect of one or more
emails going back to 2010 or 2011, which apparently were
emails of which this witness will have knowledge. Let
me try and put it as neutrally as possible.

My understanding, Mr Stevens, is that Mr Read (sic)
did that in order to probe whether Ms Marshall was
an appropriate witness to give evidence on behalf of the
Post Office in respect of what I'll call current
policies and practices, and that was why he was raising
issues from many years ago.

You have made me aware, quite properly, that you
intend to ask some questions about events in the

period -- and I'm deliberately choosing a wide period so
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A. Tracy Louise Marshall.

Q. Thank you for attending today to give evidence and thank
you for providing a written statement, to which I want
to turn now. You should have a copy in front of you.

A. Yes, I do.

Q. Is that dated 22 August 2024?

A. itis.

Q. Now, before I turn to your signature, I understand there

are a few minor changes to make, which I will take you
through now, given they're minor in nature. If we could
have the statement on the screen, please, and page 4.

In paragraph 10(a), you are discussing terms that you
used throughout the statement and you will see in the
third line from the bottom you say, "save for 114
Directly Managed Branches". I understand that should
read "111"?

A. Correct. Thank you.

Q. Page 12, please. If we go down to paragraph 30, please.
Here you're talking about amendments to terms of
contract between the Post Office and subpostmasters, and
you say, “Following the ClJ", which is Common Issues
Judgment], Post Office made the decision to amend the
template NT Terms", referring to Network Transformation
terms ~

A. Yes.

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16 October 2024

that nobody thinks it's confined -- between, say, 2010
and 2013 of this witness and, therefore, I have had to
consider whether or not it is appropriate that this
witness be given a direction about self-incrimination,
that direction having been given to a number of
witnesses who gave evidence about that period in time.
My current view is that, notwithstanding that there
will be some questions about that period, it is not
necessary for me to give that direction to Ms Marshall
but I wanted you to have the opportunity of making any
observations about that current view before you start
questioning, so to speak.
So is there anything you'd like to say about that?
MR STEVENS: I agree, sir, and nothing further.
SIR WYN WILLIAMS: Fine. Then we'll proceed but I should
make it clear, as I hope is obvious to everyone, that,
in respect of something like a direction against
self-incrimination, I keep that under review throughout
the whole of the witness's evidence, and so it's open to
me to change my mind, so to speak, if I think it
appropriate.
MR STEVENS: Thank you, sir.
SIR WYN WILLIAMS: Over to you, Mr Stevens.
Questioned by MR STEVENS

MR STEVENS: Please can you give your full name?
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Q. -- and I understand and after that should read "and
SPSO"?

A. Yes, that is correct.

Q. That is an abbreviation, SPSO, for the Standard
Subpostmaster Contract?

A. That's correct.

Q. If we can please turn to page 47. In paragraph 108, you
describe responsibility for various matters. You say:

"... however any changes to the scope of the
Postmaster Contract would go through SEG and the Post
Office Board for approval."

I understand after "Postmaster contract" it should
read “or associated policies"?

A. Correct. Thank you.

Q. Finally, page 60, please. If we could go right to the
bottom of the page there's a footnote, which we may need
to zoom in to. Given the nature of the correction, I'll
just deal with it as a footnote, rather than the
context. It says, "Reinstatement refers to the period
following suspension, or post-termination decision on
appeal”, and then I understand where that word "appeal"
is, the words thereafter should be struck through and,
in the place of those words, it should say "where the
postmaster is reinstated in their role"?

A. Correct. Thank you.

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The Post Office Horizon IT Inquiry

Thank you. The statement can come down from the screen.
Thank you.

Can I ask you, please, to turn to page 78 of the
statement.
Yes.
Below paragraph 199, you should see a signature.
Yes.
Is that your signature?
Itis, yes.
Can you confirm that the contents of the statement are
true to the best of your knowledge and belief?
They are, yes.
Thank you, Ms Marshall. That now stands as your
evidence in the Inquiry. It will be published on the
website shortly, the Inquiry's website, and for the
record, the URN, the unique reference number, is
WITN11610100.

Now, Ms Marshall your witness statement was provided
in response to two Rule 9 Requests to Post Office as
a company itself, rather than addressed directly to you.
That's correct, yes.
For reasons I don't need to go into now, you have been
put forward as a witness to speak on behalf of Post
Office on various matters in your statement?
Ihave, yes.

roles, predominantly for the next four or five years,

I'd say, working to franchising of our directly managed
branches, so converting them from Crown status to being
operated by postmasters, working with a number of
independent postmasters and larger corporate entities.
too.

What period of time are we discussing when you were
doing that role?

That would be up to 2007.

Whilst you were working with franchising and
postmasters, were you working with matters such as
appeals or suspensions, anything like that, during that
period?

No, nothing like that at all. This was simply working
with potential applicants to take on new branches and
making sure that the transition from the Crown branch
being operated by a new postmaster went smoothly, so
nothing at all to do with suspensions or investigations.
Then, from 2007, what role did you have?

So from 2007, I moved to be the Programme Office Manager

for a programme called Network Change. Network Change
involved the closure of around 2,500 branches, from
memory, and the implementation of what we now call
Outreach Services, things like mobile vans across the

network. That was a Government-funded programme and
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16 October 2024

You are currently the Retail Engagement Director with
Post Office Limited?

Yes, I am.

When did you first join the Post Office?

I joined in 1998, so I've been here for just over

25 years/26 years.

What was your role upon joining?

I joined as a graduate trainee, initially, for 18 months

and then I've progressed through the organisation

through a variety of roles.

If we pause there, as a graduate trainee, very brief
summary, what sort of work did you do?

There were three six-month secondments, one of them was
working in a directly managed branch, they used to be
called Crown branches; one of them was shadowing an Area
Manager, I think they were called Retail Line Managers;
and the third role was in Head Office, a very

administrative role within the finance function, just

getting knowledge of Head Office operations.

What role did you go into after being a graduate

trainee?

So I then went into being a Branch Manager in one of our
Crown branches for just over two years.

What was your next role?

After that, I did a variety of project and programme

I effectively, for the next three years, ran a programme
office effectively making sure that we were on track
with budgets, that we had reporting in place to our
shareholder and that all the necessary documentation
went out to the right postmasters.

So that's 2007 to 2010, roughly. Can I just check, you
may have been involved with Post Office closures as part
of the programme; at that stage, were you involved in
any respect in the termination of subpostmasters'
contracts because of alleged breaches, such as through
discrepancies and the like?

No, I was not.

From 2010, what was your role, please?

For the next two years, I was Agents Development
Manager. I had responsibility in that role working to
Kevin Gilliland for postmaster remuneration, and our
postmaster contracts, which at that time were being
updated in preparation for the next change programme
which was Network Transformation.

Were you involved in, as part of that, termination or
suspension of postmasters as a result of alleged
discrepancies?

I was not, no.

Then from 2012, what was your next role?

From 2012 through to 2017 or '18, I was involved in the
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Network Transformation Programme. So this was the
programme to ultimately convert post offices to new
models, the main model and the local model.

So, again, do I take it from that, not involved in
termination/suspension, those sorts of matters?

I was not involved no.

From 2017, please?

2017 to now, more senior leadership roles, responsible
for initially some of our network strategy, and then,
more recently, stepping into more of my current
accountabilities around postmaster onboarding and
postmaster training and some postmaster engagement.
Your roles and responsibilities now, when did you start
undertaking those roles?

So for onboarding and training, which you've seen me
talk about in my statement, I'd been doing that for
about four years, I would say; my responsibility for the
Contract Management and Deployment team, only for the
last year.

Thank you. I want to look at a particular period,

I think it's when you're Agents Development Manager --
Yes.

-- 2010 to 2012. Did you say you reported to Kevin
Gilliland?

\ did.

accountability for the team of Contract Advisers in the
network. From time to time, John or Lin Norbury, who
may have been his boss at the time, would often copy me
in on emails for information purposes but I don't know
why I would have been copied in here, specifically.

So, outside of this specific email, what was your
working relationship with John Breeden -- not in terms
of how did you get on: what substantively did you work
on together?

So because I had accountability for, at this point,
postmaster remuneration and the postmaster contracts
themselves, sometimes John Breeden would reach out to
myself or my team to ask for advice on the content of
the contracts, for example, or advice on the structure
of remuneration with postmasters.

Those issues you just referred to don't appear to be
raised in this email.

Agreed.

To what extent, at this time, were you involved with
Post Office's response to allegations that had been
raised by Justice for Subpostmasters Alliance?

I don't think I was involved with any of those
allegations.

If we go to page 2 of the email, please. This is

an email that's extremely well known to the Inquiry. It
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16 October 2024

In what team or department did you sit in that role?
Kevin was, I want to say, Director of Network and Sales,
so this was -- Kevin had wider accountabilities for the
network. He may have had responsibility for some of the
field teams. He certainly had a team responsible for
the relationship with the National Federation of
SubPostmasters, and he had a team focused on sales
capability in our branches, so a fairly wide remit.
Can we please bring up POL00088956. We see an email on
5 December 2010 from John Breeden, it's to Angela van
den Bogerd. If we just scroll down slightly, please, to
see the email that has been forwarded, we see an email
from Lynn Hobbs to John Breeden is being forwarded on.
If we can go back to the top, please, we see that
Mr Breeden addresses it to Angela van den Bogerd but
copies you in. We see you're the second person on the
CC line. The subject says, "Follow up" to a meeting
with the department with the JFSA, and it attaches some
documents regarding that.
I know you've seen this email and I'll come to the
contents of it shortly, but, firstly, why at this stage
would John Breeden copy you in to an email like this?
Having read the email train, I'm not completely sure why
I would have been copied in. I don't recall the email.

John Breeden, I remember, had the Contracts team, he had
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says, "My reply to Mike and Rod". It says:

"I have found out this week that Fujitsu can
actually put an entry into a branch account remotely."

It goes on to say how that was found. Final
sentence:

"One solution, quickly discounted because of the
implications around integrity, was for Fujitsu to
remotely enter a value into a branch account to
reintroduce the missing loss/gain. So [Post Office]
can't do this but Fujitsu can.”

Do you recall whether you read that email at the
time?

No, I don't recall reading the email at the time. I was
surprised to see it when it was disclosed to me as part
of the Inquiry. It's not something I would have been
involved with, to my recollection, as part of the role
that I was in at the time.

Let's move forward a month, if we can, please.
POL00294728. This is an email from you to Kevin
Gilliland, who you said earlier was your line manager?
He was, yes.

We see Angela van den Bogerd is also an addressee of
this email and Helen Rose is copied in. The subject is
"Horizon system issues". It refers to conversations

you'd had with Andy McLean and Dave Hulbert yesterday,
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you believe you made progress with the outstanding
questions raised.

Does this not show that you were involved with Post
Office's response to allegations about the Horizon IT
System and its integrity?

No, I don't think it does and, if it would help the

Inquiry for me just to provide little bit of context, if

that's okay?

Yes, please.

Okay. So, as I've said, during this time I worked Kevin
Gilliland and my accountabilities were very specifically
‘on postmaster remuneration and postmaster contracts.
Very often, Kevin would ask members of his lead team, of
which I was one of them, to go off and find information
about other matters that were not relevant to the roll

you were doing to assist him in whatever he was doing in
his role. From what I've read of this email, this is

clearly to me and, whilst I don't recollect it at the

time, it is clear to me that he was asking me to go off
and find information out to perhaps prepare him for

a meeting that he was going to with Angela shortly
afterwards.

I don't think I would have known -- certainly
wouldn't have known, the ins and outs of the Horizon

system, I wouldn't have had any involvement in remote
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In the last email I took you to, which referred to
remote access, it referred to it not being used due to
integrity concerns, but broadly speaking. Did you know
why you didn't refer to the integrity concerns that were
raised in that email when you reported to Angela and
Kevin in this email?
I don't and, you know, on reflection, I should have
joined the dots and, when typing this email to
Mr Gilliland, have noted the previous email, assuming of
course I read it, and I'm very sorry that I didn't do
that, in hindsight. But I would, you know, say again
this was an area very much outside of my expertise and
comfort zone and it's very clear to me that I wouldn't
have written this without very clear direction from
experts on what to say.

So do I take it that your evidence is, effectively, what

you have written down here is what you would have been
told by Andy McLean and Dave Hulbert?

Absolutely.

That document can come down.

I want to go to a slightly different issue, please.
POL00119947. This is an undated letter but we see from
the first page that it refers to an appeal hearing on
7 December 2010, and then correspondence on 28 February

2011, which gives us an indication. If we can just turn
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access. So my view of this email is that I have gone
off, found information from the Subject Matter Experts,

in this case Andy McLean and Dave Hulbert within the IT
Team, and have relayed that information to Kevin

Gilliland.

If we just scroll down slightly, please. You give some
commentary on remote access. You say:

[Post Office] cannot remotely access systems and
make changes to specific stock units etc. Fujitsu can
remotely access systems and they do this on numerous
‘occasions to a network wide basis in order to remedy
glitches in the system created as a result of new
software upgrades.

"Technically, Fujitsu could access an individual
branch remotely and move money around however this has
never happened yet."

You go on to refer to authority processes that are
in place and say:

"If a change were made remotely and to an individual
branch, it would be flagged on the business data ledgers
and would appear as a ‘mismatch’ in P&BA in
Chesterfield.

"So although changes can be made remotely, they
would be spotted and the person making the change would

be identified."
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the page, please, and go towards the bottom, we'll see

it was sent by Craig Tuthill. At the time, so early

2011, where did Craig Tuthill sit in the organisation to
you?

Craig -- I think at this time, whereas I was in a Head
Office function, Craig was in a field role managing the
Contract Advisers or certainly working very closely with
them. He may have worked to Lynn Hobbs at this period
of time.

Was there any reporting line to you on that basis?

No, not at all.

Can we turn back to the first page, please, and go down,
please. Thank you. It says:

"Throughout the appeal hearing and the written
submissions you have raised doubts about the integrity
of the Horizon accounting system and have offered no
other reason for the losses incurred. You are adamant
that neither you nor any of your staff acted
dishonestly."

It goes on to say a few lines down:

"I have also sought and received confirmation from
Tracy Marshall, Post Office Limited Agents Development
Manager, that [Post Office Limited] is fully satisfied
that the Horizon system and accounting processes around

it are robust and fit for purpose. She confirms the
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system is endorsed by the National Federation of
SubPostmasters and has been subjected to independently
assured testing processes, information security is
accredited to industry standards and the system also
meets all payment industry standards."

I mean, do you recall Mr Tuthill coming to you about
this appeal?
Not specifically. Again, I saw this in my bundle.
I don't remember this specific example. It would have
been quite usual for Craig and his team to come to
people in the centre, in the Head Office, if you like,
to ask for a view on the business's position and, from
time to time, I would, in my role here, have gone off to
our Communications Team to find lines to send back out
to the field teams.
So I'll take you to a different document. It's
POL00119963, please. We see it's an unusual format but
it appears to be an email from you to Craig Tuthill on
Monday, 28 February 2011. You say:

"Craig/Andy,

"This is the formal words used in external
communications. I would be happy to circulate this to
the contracts community if you think this is fit for
purpose?"

I think your evidence earlier was that you would
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a corporate witness. You know that Fujitsu's ability to
access branch accounts remotely and Post Office's
knowledge of that ability is being considered by this
Inquiry?

Ido.

From the emails we looked at, would you accept that you
were involved, to a certain extent, in the distribution

of knowledge on remote access within Post Office?

I would accept here that there are emails where I've
relayed information to people that concern remote
access, the very core issue to the purpose of this
Inquiry. But I wouldn't say that I was involved or

implicit in anything involving remote access.

To whatever extent you were involved, do you think that
you're an appropriate person to give evidence on behalf
of the Post Office because of that even limited extent

of involvement?

I think I am, and my role, particularly over the last

three or four years, has focused on delivering
improvements and changes for postmasters on a number of
core areas, including training and onboarding,

et cetera. So I do think I am best placed in the
organisation to be able to talk to those improvements
and about what the current position is.

Can I ask, the matters we've just discussed now, why
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check with the Communications Team about what the
business position was; is that effectively what this is
showing?
I believe so, yes. I believe this is an example of when
I've been asked a question, I've conferred with our
Communications Team in the Head Office and this form of
words here would have been standard -- the standard
position lines used in external communications that I've
been provided with, via the Comms Team.
Did you have any role in or did you take any steps to
satisfy yourself that what was said there was accurate?
I don't think I would have done, no. I think I was
relying on the information being provided to me by more
senior leaders within the organisation.
Thank you. That document can come down.

Aside from that type of matter there, where
an Appeals Manager is coming to you for a business
position on Horizon and you're giving an external
communication, during that period of time in 2010 to
2012, were you involved in inputting or assisting
Appeals Managers with making decisions on termination
or, indeed, Contract Managers on making decisions on
termination of subpostmasters?
No, I was not.

As we said earlier, you have been put forward as
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were they not referred to in your witness statement?

My witness statement was in response to specific Rule 9
Requests, two of them, and that is the basis,

ultimately, of my witness statement that I've prepared.
One further point before we move on to matters in your
statement, please could we have POL00448411. It's

a letter that's been seen by the Inquiry before, to
various people, including, sir, to you and to Mr Beer.

It's 28 May 2024, and it says:

"We are writing to you as a group of highly
disenfranchised [Post Office] employees ..."

Have you read this letter before?

Only when it was provided to me as part of my bundle.
If we can go to the bottom of this page, please, it says
at the bottom paragraph:

"lam sure you have been made aware that we have at
least 120 employees who have been in long-term roles who
have conflicts of interest, ie they were operating in
roles which to a greater or lesser degree were involved
in the wrongful prosecution of SPMs. Read has known yet
refuses to address the latter situation proactively,
despite being asked to. He reacts only to the specific
individuals after their names are called out in public.

For instance Angela van den Bogerd mentioned in her

statement the role of Tracy Marshall; the latter played
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a prominent role in 2010/15 in the unlawful convictions
of subpostmasters.”

Pausing there, what do you have to say to that
point?
I think -- I'm disappointed to see that there are
disenfranchised employees in Post Office, firstly, who
clearly have concerns about me, in my role. I think
there are some confusing facts in here that aren't quite
right. I've never played a role, any role, in the
unlawful convictions of subpostmasters. Whilst I can't
state factually, I suspect that this here is in direct
response, clearly, to the emails that we've just gone
through being shown in Mrs van den Bogerd's evidence in
Phase 5 or 6. But I'm disappointed that they feel that
way about me.

It says:

"Despite this, just 3 years ago, Marshall was
appointed as the Postmaster Engagement Director, much to
our dismay (and no wonder the trust results plummeted).
However, only within the last week, Read has remove
Marshall from her role and appointed her into another
obscure role."

When did you change roles as Postmaster Engagement
Director?

So I've never been Postmaster Engagement Director,
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There was clearly a shift in Post Office's view of what
the contract meant following the Common Issues Judgment.
Can we have, please, page 5, paragraph 15 of your
statement on the screen. You refer to the Standard
Subpostmaster Contract, which I think we see in your
statement elsewhere as SPSO; is that right?

Yes, that's correct.

You say it's the oldest contract, first introduced
between 1991 and 1994.

Yes, I believe so.

Since that was introduced, is it fair to say the

majority of postmasters who originally signed on to that
contract have been transferred onto a different Network
Transformation contract?

That's correct.

How many subpostmasters -- or postmasters, sorry --
remain on the Standard Subpostmaster Contract?

I don't have the specific figures to hand, I'm afraid,

so I can't really comment on that. I think it might be
around a thousand but I couldn't be sure.

Does Post Office issue the Standard Subpostmaster
Contract to any new applicants or new subpostmasters
that it onboards?

Yes, it does, from time to time. There are still some

branches who are on an SPSO contract, who continue to
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I think they're referring to Retail Engagement Director,
which is my current role. Following the email appearing
in Mrs van den Bogerd's evidence, I was asked to step
back from some of my role, so in late May/early June
this year, I stood down from the postmaster engagement
element of my role, effectively, which is a very small
team of two individuals, plus the Postmaster Experience
Director, Mark Eldridge.

So my role hasn't changed; I've just had some of my
responsibilities removed from it, and my role includes
now -- continues to include onboarding, training and the
Contract Management Team.

Do you consider yourself to be in an appropriate
position to carry out those roles, given your past
involvement which we've discussed?

I think so, yes. I mean, for the last four years
particularly, my role has been completely focused on
trying to do the right thing by postmasters and making
changes to our policies, procedures, processes, and
listening to postmasters as much as I can, and trying to
make changes. So I do still feel as though I am in

a very good position to do my role.

Let's look at some of those policies and procedures now.
I want to start with the types of contracts, the basis

on which Post Office contracts with subpostmasters.
22

have the ability, if they wanted to, to sell their

branch and premises to a new postmaster on those terms.
It doesn't happen that often. I recall a couple of

hundred cases that I'm aware of over the last few years,
but, yes, it does happen.

SIR WYN WILLIAMS: = Can I understand that: do you mean that

A

a postmaster on the Standard Subpostmaster Contract will
sell the branch to a new subpostmaster and then they

will still be on the old -- when I say "the old" -- on

the Standard Subpostmaster Contract?

That's correct, sir, yes.

SIR WYN WILLIAMS: Yes, fine. I understand, yes.
MR STEVENS: I want to look at what steps Post Office have

taken to clarify the written terms to subpostmasters of
the contracts following Common Issues. Can we turn to
page 12, please, paragraph 30. You say:

"Following the [Common Issues Judgment], Post Office
made the decision to amend the template NT Terms", and
it should say "and SPSO terms" --

It should, yes.

-- "being issued to new postmasters to reflect the
court's determination (as set out in the Contract
Restatement Guide) and to focus on making operational
improvements and positive changes to the way it works

with postmasters, before making widespread changes to
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its standard contractual terms."

I understand from your evidence what the Post Office
did was to send out a contract restatement document to
explain the effect of Common Issues?
Yes, it did.
Can we look at that, please. It's POL00037518. Is this
the document to which we were referring, the contract
restatement?
Itis, yes.
How was this sent to postmasters in the network?
So from what I can understand, it was sent out to
postmasters electronically, via a channel known as the
One Communications Channel, this was a tool used by our
Communications Team quite regularly to send out messages
to postmasters so this was sent electronically.
Why wasn't it sent in hard copy as well?
I honestly do not know. I wasn't involved at the time
but I believe it should have been sent out in hard copy.
All I can say is that, when we make any changes now to
‘our contract terms, we always make sure that hard copies
are sent out to postmasters, first and foremost so that
we have a record that it's been delivered and received
by the postmaster via Special Delivery. I can't comment
on why that wasn't the case here, I'm afraid.

In your statement you say that Post Office did not have
25

contract, suggested changes.

If I can pause you there, that's changes to a contract.
Yes.

I'm interested in what Post Office is doing to explain

the contractual terms as they are at the moment. You
said in your evidence that wasn't a plan to issue this

in hard copy: why?

It's a very good question, something I think we need to
think again about as a business. All postmasters should
have access to this.

Earlier in your evidence, you said previously it should
have been sent out in hard copy?

Yeah.

Is there any good reason why it’s not sent in hard copy
now?

No, absolutely none.

Are you in a position to say the Post Office will at

least consider it?

We will absolutely consider, and I think we should make
sure that all postmasters have hard copies of this
document.

If we look at what the document says, please. If we go
to page 2, it refers to the judgment, the Common Issues
trial, and then says:

"The judgment changes the meaning of the contracts
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a system for ensuring that subpostmasters had read the
Contractual Restatement Guide.
Yes.
Why not?
I don't know. I don't know and the business should have
done. When this -- what should have happened, in my
view, here is that this document was sent out in hard
copy to every postmaster by Special Delivery, so that we
had a record of it being received, first and foremost,
and it should have been followed up, in my opinion, with
check-ins from our field members to make sure the
postmasters had understood the terms and had received
them. I can't comment on why that didn't happen, I'm
afraid.
Is there any plan in Post Office at the moment to
correct this issue by taking the steps you've just
suggested now?
So there are two things that we're doing. First of all,
it's making sure that this document here is available
for all postmasters to view again. That won't be hard
copy, for reasons I'll come on to, but it will be made
available and is on our Branch Hub tool.

The second thing that we are doing is looking at
what we call the Contract Reform Project. So we are

underway, with making some other changes to our
26

Do you know who came up with that wording "changes
the meaning of the contracts"?
I don't, I'm afraid.
Do you agree with that?
I think, from what I know of the implied terms that have
been added into the contracts, I do think it changes the
meaning of the contracts, in that it's moved them --
it's certainly added more obligations on Post Office and
I think it is a fairer contract, particularly in the
areas of losses and shortfalls, for example. I'm not
sure if it specifically changes the meaning of the
contracts, however.
Well, as you've noted there, it says:
"It implies (adds) some new terms to the contracts.”
Has Post Office ever communicated to subpostmasters
that the terms that were found to be implied into the
contract in Common Issues Judgment applied before the
judgment was issued and not after it as well; so Post
Office was bound by them before the judgment?
I've not seen anything to suggest that, no.
That can come down, thank you.
It has been suggested by some postmasters that it is
confusing to have a contract and then a separate guide

explaining it, such as this; what do you say to that?
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I would agree. I think it's very important that every
postmaster out there has a contract with those new terms
added in to that contract. Again, I can't comment why,

at the time, steps weren't taken to amend the contracts
and send new contracts out and why it was simply done
via a contract restatement guide.

That wasn't within your purview?

No, it wasn't, no.

Do you know who made those decisions?

I can't recall who would have been responsible for
contract change at that time. Obviously, our Legal Team
would have been very involved with it. It would have,

I think, sat within the remit of Julie Thomas, who was
one of the Operations Directors within the business but

I can't be sure.

Just another point on this and how it was communicated.
Can we please look at page 45 of your statement,
paragraph 107. For context, in the main body of the
paragraph, you refer to postmaster contracts and the key
policies and guidance relating to contractual liability

for postmasters. You then refer to the Contract
Restatement Guide; is that the document we were just
referring to on the screen?

Itis, yes.

You say:
29

Inquiry in due course?
Quite possibly, yes.
Was there any other document which a postmaster could
turn to that explained the effect of common issues,
other than that contract restatement document?
No other document specifically on -- that would explain
the Common Issues Judgment impact. There are obviously
a number of other contractual documents, such as the
Operations Manual, which was updated around that time
but that didn't specifically address ClJ impact.
Do you know why, as part of an archiving exercise, such
an important document was taken down from Branch Hub?
I don't, I'm afraid, no.
Can we look, please, at POL00448241. This is a Standard
Subpostmaster Contract. If we turn to page 5, please
and to the bottom, to paragraph 20, please, it says:

"Each party shall:

“at all times in the performance of its obligations
and exercise of its rights under this contract act in
good faith ..."

So it looks like this is an amended contract
following, or making changes as a result of, Common
Issues; is --
l agree. I think it is, and it's dated August 2020 in

the footer of there.
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"This document was published on the One
Communication channel on 29 July 2020", which you just
said in your evidence.

(The witness nodded)

“As part of this exercise and responding to the Rule 9
Requests, the Retail Team have been advised that, due to
an archiving exercise, the document is no longer held on
Branch Hub and the Retail Team have arranged to
reinstate it so that it can be readily accessed by
postmasters ..."

Is that document now back on the One Communication
channel.

It's back on Branch Hub, yes.

Branch Hub, sorry, yes. The Rule 9 Request to which
this statement was provided -- well, there were two,

sorry: one was 12 June 2024 and one was 2 July 2024. Do
you know when it was realised that the document wasn't
‘on Branch Hub?

Not specifically but it would have been around the time

of those Rule 9 Requests coming in and me preparing my
witness statement.

When you say it was taken down as part of an archiving
exercise, when did that archiving exercise take place?

I don't know, I'm afraid.

Is that something that the Post Office can tell the
30

Yes, you say that. In your exhibit list to your
statement at number 4, we don't need to bring it up, the
document description is "SPSO Individual Contract v3
December 2023".
Okay.
Are you able to assist with when the changes were made
to the subpostmaster contract to reflect what was said
in Common Issues?
So changes were made to the SPSO contract and the two
Network Transformation contracts after the Common Issues
Judgment was handed down, to the best of my knowledge in
2020. There might have been some small iterations/
changes to it since then but, fundamentally, the new
implied terms were added in in 2020.
Just so we're clear, that applies, does it, to new
subpostmasters joining the network. These are the
contractual terms they're given upon joining?
New postmasters joining the contract would get this,
yes.
Thank you. That document can come down, thank you.
Could we look, please, at your statement, page 12,
paragraph 31 and 32. That's great, thank you. If you
just go down a bit further to have 31 at the top.
You give an example of changes made to various

policies in the summer of 2020 and it sets out the range
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of support available to postmasters and their staff.
Then, if we go further down, thank you:

"The Postmaster Support Guide is updated annually to
take account of any changes ... The Postmaster Support
Guide contains the following key areas ..."

We see: general support; training; managing cash:
branch balancing; accounting dispute resolution. So
quite serious material issues for a subpostmaster, yes?
Yes, issues that they would absolutely need advice and
support on in running their branch.

Aside from this being written down as policies, what
steps have been taken to ensure that there is
appropriate resourcing to implement these policies
properly?

Okay, so just to clarify, the Postmaster Support Guide
isn't a policy, as such. That's an overarching document
providing advice and support to postmasters. In the
back of the Postmaster Support Guide there is

an overview of the 12 postmaster policies that we have
put in place across all areas of the postmaster

lifecycle, to assist internal colleagues and make sure
that processes are followed correctly. Part of my role
as being accountable for those postmaster policies is to
make sure that the various teams can deliver them in

their respective teams and, to do that, clearly they do
33

the very clear steer that I had.

If it helps the Inquiry, though, we are in the
process actually, right now, of putting each one of our
12 policies onto a new template. That template is being
developed by colleagues in Data Protection, the Legal
teams and the Assurance teams, and those policies will
be made available shortly to postmasters, following
agreement, obviously, by our Audit and Risk Committee,
and GE.
The last point on these policies: with the change in the
policies, as they've changed and developed since Common
Issues, has that placed more or greater obligations on
Post Office than it did before the changes? So is there
more to do, effectively, more work to do, to fulfil
those policies than before?
I think that's very true, yes, they have.
Has there been any increase in resources to meet those
policies?
There's been some increase in resources, in my own team,
for example, who manage the policies. We do now have
more people to make sure we are getting them annually
reviewed by the right people, that we have group
assurance as well in place now, checking our policies,
checking our Control Framework and that we have actions

in place to mitigate any of the key risks. So yes,
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need resource to be able to do that effectively.
Resourcing is a challenge, in some areas, if I'm
honest. I'm very aware of the broader business issues
that we have: we're funded by Government; there are cost
challenges. I'm confident we do have resources in place
to deliver against the policies. We could always do
with a little bit more resource though, in some areas.
Firstly, the 12 policies you refer to, I think you use
the word "internal" -- you do in your statement,
I think -- subpostmasters don't have access to those 12
policies, do they?
Not at the moment, no. They don't have access to the
full policies but what this is a guide to the postmaster
policies, which is a shortened version of each one,
effectively, that postmasters can view, which is on
Branch Hub.
Why are they not given full access to the full policy?
It's a question that I've debated quite a lot over
recent years with various colleagues and our data
protection legal teams, et cetera. The policies
themselves, which are internally facing, have quite
detailed information in them around our Control
Framework, our risk appetite as a business and risks,
and it wasn't felt appropriate to disclose that

information externally, rightly or wrongly, and that was
34

resource has been put in place.
Can we look, please, at your statement page 17,
paragraph 36. Thank you. This is coming back to
something I cut you off on earlier. You're referring
here:

"In July 2024 the Retail Engagement Team presented
a proposal for the Contract Reform Project to the
Strategic Executive Group ..."

Why has this Contract Reform Project been started;
what's its purpose?
As a business, we've been talking about doing a more
widescale update of our contracts and getting new copies
out to everybody for some time.
Okay, pausing there, when you say "some time", from
roughly --
I'd say a few years and, for whatever reason, the
business decision has been taken not to do that activity
at that particular point in time. To give an example,
at one point, obviously, we were anticipating the
rollout of our New Branch IT System into branches, and
so it was considered that we should perhaps delay some
of this work until that system was in and there may be
changes that are needed as part of the introduction of
that system. For a few years we've been talking about
it.

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The Retail Team have been pushing quite strongly, as

have our Legal team, to make sure that we do this

activity. I feel this is very important for the reasons

I said earlier. I think it's important to get contracts

out to every postmaster, new contracts that do have the

implied terms in them, from the Common Issues Judgment.
We are now doing that. So we are -- we've already

made some proposed -- and I stress the word

"proposed" -- changes to the contracts with external

Legal, and our next stage, which will we'll be doing

later in October or November, is to go to our Strategic

Executive Group and take them through them, and the next

step will be then to engage with the postmasters; the

NFSP, obviously will need to be consulted with as part

of that process; look at what we're proposing to do; and

then, hopefully, we can get in a position where we send

contracts out.

It might be said that a reason for not bringing these

contract proposals sooner and enacting them more

quickly, is to avoid the proposals being scrutinised by

this Inquiry; what would you say to that?

I don't think that's the case.

Paragraph 36(b). You refer to "removing specific

rights". What right, at the moment, in the proposals,

are being envisaged to be removed?
37

but, by the time I thought I would revisit that with

you, my connection had been broken. So one way or
another we got ourselves an extra five minutes. That's
what it boils down to.

MR STEVENS: Thank you, sir.

prop

Right, I want to move on to training, please, and,
as Retail Engagement Director, you are accountable to
the Post Office Board for the design and implementation
of postmaster training?

That's correct.

You are supported in that role by the Head of Training?
lam.

I want to look at the job description, please, for Head
of Training. It's POL00448046.

So, job title, Head of Training. The Head of
Training obviously involves training for postmasters.
Are there any other types of worker -- I don't use that
in the technical sense -- for whom the Head of Training
is responsible for their training?

No, it's the development and delivery of training for
postmasters and those operating our branches. So it
would also be those working in our DMBs, for example.
If we look, please, at page 3, and we've got the
"Knowledge, Experience and Skills": the leadership

first; second, experience or background of training;
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I can't think of any specific rights, if I'm honest.
I can give some examples of other outdated terms and
references that might be removed, if that would be
helpful?

Are there any rights, obligations or terms that could be
perceived to be beneficial to a subpostmaster that are
being proposed to be removed?

I don't believe so, no. In fact, I think the changes

are much more favourable to postmasters and more
obligations on Post Office.

MR STEVENS: Thank you. That can come down.

Sir, that's probably a good time to take our morning
break.

SIR WYN WILLIAMS: All right. So --

MR STEVENS: If we could say 11.15? Thank you.
(11.05 am)

(A short break)
(11.25 am)

MR STEVENS: Sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR STEVENS: Firstly, I'll apologise to the transcriber for

initial only undercooking our 15-minute break and then,
sir, I apologise to you for overcompensating by giving
a 20-minute one.

SIR WYN WILLIAMS: Mr Stevens, I did wonder about your 11.15

2

38

third, knowledge of training related models; various
other matters including a good understanding of business
strategy, policies and operations.

There doesn't appear to be any need for knowledge or
experience of IT or Horizon; is that fair?
That is fair, yes.
Why is that?
So I think, as the Head of the Training Team, the
individual's job is to provide leadership and make sure
that a good quality of training is being delivered.
Those working into the Head of Training and who are
delivering classroom training, for example, do
absolutely have to have a good knowledge about the
Horizon system, but I don't believe it's essential for
this particular role, providing leadership to that team.
So who is responsible for the content of the training on
Horizon itself?
So ultimately, that would be me being accountable and
the Head of Training being responsible for the
production of all the content.
To whom can you turn for advice on whether the aspects
of training relating to Horizon are appropriate or
sufficient for subpostmasters?
When we're developing our training content, be it

classroom courses or e-learning modules or Work Aids, we
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are reliant on discussions with the various Subject
Matter Experts within the business. So, for example, if
there's something around cash and stock management, for
argument's sake, we would go to our Cash and Stock
Management Team. If there's something there around
discrepancies, we would confer with Mel Parks team.
Many of the policy documents on training say that Post
Office is committed to providing comprehensive training
to postmasters.

Yes.

What, if any, funding is there for postmasters to engage
in training?

So there's no particular funding provided to postmasters
or anybody operating our branches, to go to training.

So we don't, for example, pay for postmasters or their
assistants to go to a training course. Over the last

few years, many of our training has moved to being more
digital in format and that's as a result of postmaster
feedback and, of course, that collateral, which is on
Branch Hub or our Learning Management System, is freely
available to anybody working in a branch to access, free
of charge.

It still requires them to commit hours to it?

It does.

The hours they're committing to the training is hours
41

barrier preventing them from engaging with it?
It could be. I've got no evidence to suggest that it is
a barrier to them attending but it could be.
Do you have any data to understand how many people want
to attend that course against, in fact, how many people
in fact attended?
No, I don't, we only have statistics on how many people
do attend the course.
\s it fair to say that one of the purposes of training
‘on matters like investigating discrepancies is to reduce
discrepancies overall or at least reduce the need for
Post Office to investigate them?
I agree that there is -- the requirement for training on
investigating discrepancies is ultimately to get to the
root cause of the issue and prevent discrepancies from
taking place in the first place. So the concept of
investigating discrepancies is something that's very
important. This classroom course here, the half-day
classroom course, is just one aspect of that but, in
addition, there's a variety of other material that has
been developed and is available digitally, which will
assist postmasters or members of their team, in helping
them to investigate those discrepancies.

The digital format of training is something that we

as a business, and I, want to explore more of. From
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they're not committing to their profitable business?
That's true. It does require commitment, yes.
Presumably, for assistants, the hours that they have to
commit to training, the postmaster has to pay them while
they're doing that training?

They would have to, yes.

Can we look, please, at your statement, page 22,
paragraph 47. You say these some of the training
courses that have been introduced since the Common
Issues Judgment, and at (d) you refer to "Investigating
discrepancies", and that's a half-day classroom course
and Work Aid. That sounds like quite a significant or
important piece of training that is available to
postmasters; do you agree?

It's proved to be very useful for postmasters, yes. And
many of them who have attended it have said that it's
been, you know, very positive, well received, with good
levels of confidence, shall we say, after attending,

yes.

Because it's a half-day classroom, that requires

a postmaster or assistant to be out of the post office
for at least half a day, yes?

It does, yes.

Do you think the fact that postmasters aren't paid or

remunerated for doing that course is a significant
42

what I hear from postmasters, you know, they're busy
people running retail businesses as well, alongside
their post office, and for many the preference is not to
have to travel to a classroom, irrespective of costs.

It is to be able to do training in the comfort of their

own premises, their own home, perhaps in the evening as
well. So that's something that we want to explore more
of.

Is there any plan within the Post Office to consider or
assess the impact of any proposals to fund
subpostmasters or their assistants to do training?
There's no proposals at the moment but, obviously,
that's something that I can absolutely take back and
consider in the wider business.

I want to look to at some of the training guides and --
we don't need to bring it up -- in your statement you
refer to, at paragraph 77, the Operational Training
Guide being a fundamental tool for both new and existing
postmasters?

Yes.

Who is responsible for keeping that material up to date?
That's the Training Team.

Could we look, please, at POL00448131. This is about
monthly accounting for trading period balance; is this

taken from the Operational Training Guide?
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Yes, it is.
It covers, as I say, monthly accounting and balancing.
Please could we go to page 3.

You've got "Settling discrepancies", and these are
options that are given to postmasters when there's
a discrepancy prior to rolling into the next trading
period. One is “Review Dispute CALL [Business Support
Centre]"; another is "Make good cash".

I'll be exploring that in more detail with
a different witness but I want to look at the content of
this document with you. Under "Make good cash", it
says:

"This is optional if you would like to settle the
discrepancy without disputing it. You can select this
option, then physically add or remove cash to balance
without a discrepancy.”

Do you think that is a satisfactory description of
when subpostmasters -- or the guidance for
subpostmasters in using the "Make good cash"?
I do not think it's satisfactory.

Why isn't it satisfactory?

I don't think that that is clear enough that, if any
postmaster or officer in charge chooses to put cash in
from their own pocket, effectively, they should do so

only if they are absolutely sure that it's due to
45

our operational training materials.

When will this be corrected?

I think if it's not out there already now, it's imminent
by the end of October.

Further down, it says, "How to dispute a discrepancy”
we don't need to worry about Strategic Partner
branches -- it says:

“All other branches: Whichever option you use to
settle a discrepancy at the end of the trading period,
you can still dispute the discrepancy with Post Office.
To do this contract the Branch Support Centre.

"If you can demonstrate the reason for the
discrepancy or if you firmly believe the discrepancy
will be resolved through a Transaction Correction,
please call the Branch Support Centre with all the
details you have."

Is that not putting the burden on the postmaster to
show that the discrepancy is not the postmaster's fault,
rather than the investigative obligation being on the
Post Office?

Reading it back now, it could give that impression, yes.
And, again, that's something we should look at.
Pausing there, you say "we should look at”; is this,
currently not proposed to be amended as part of the

changes you were describing before?
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something that has happened in branch that is an error
of some sort, not with the system, but where you might
have, for example, given the customer £20 more,

et cetera.

We are in the process, actually, of updating this
section of the Operational Training Guide and any other
documentation that refers to something similar, to make
that message very clear.

Just pausing there: you say "in the process", the date
on this document is July 2023 --

Yes.

-- why has it taken so long to make what appears to be
a clear position of Post Office evident in the training
guide?

And that's a very good point. I think whilst people
within Post Office, myself, our teams, are very aware
ourselves of what should happen, ie you should only put
cash in if you're absolutely certain that it's something
that's been done in the branch, not related to an issue
with Horizon or something that needs to be investigated
further, it's one thing for us to think that. I don't

think we've quite got that message across to
postmasters. There's no excuse. It should have been
done quicker but I'm comforted by the fact that we're

now doing it and taking the opportunity to review all of
46

Not currently, to the best of my knowledge. However,

I will absolutely make this away to be amended and
looked at. But you're right: the onus is on Post Office

to investigate any discrepancies, should the postmaster
wish us to.

Over the page, please, page 4. There's more guidance,
it says at the top, "Guidance on disputing a discrepancy
or Transaction Correction". So "What happens at the end
of the investigation?", and the second paragraph:

"If a discrepancy amount has been investigated by
Post Office, or agreed by the Postmaster, and is found
to be a genuine loss to Post Office, the discrepancy
will be passed to the Postmaster Account Support Team to
support you through the options regarding settling the
amount."

Should that also say, "and is found to be a genuine
also to the Post Office and caused by your negligence,
carelessness or error"?

Perhaps, yes, as that would be more aligned to the
wording in our contracts.

Do you know if this wording is being considered to be
changed as part of the review?

I don't think so but, again, very happy to take that
away and make sure it's implemented quickly.

It might be said that this guidance isn't clear in the
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training because Post Office are seeking to downplay
their investigative obligations or when the "Make good
with cash" button should be used; what would you say to
that?

I don't think that's true at all. I accept the fact

that the wording could be better but Post Office, to the
best of my knowledge and from my work with other teams,
are absolutely not trying to downplay two fundamental
issues here: the first of which is that it is upon Post
Office to work with the postmasters, support them, in
thoroughly investigating any discrepancies; and the
second point, as you've mentioned, is we're very clear
that postmasters should only put their hand in their
purse and put money in the till if they are absolutely
sure that it is a genuine mistake that's been made in
branch, that they can recall. So I'm very clear on

that.

What we saw there in the Operational Training Guide,
does that reflect what's taught in classrooms and on the
various online resources?

The wording in that guide that you've just showed me,
I'm sure would be consistent with the other materials
used, you know, very ~- the team do take steps to make
sure that wording across all of our learning materials

is consistent for good reason. So when I'm going back
49

Office, not just the Training Team -- and you may have
heard our People Director talk about that -- Chief
People Officer -- Karen McEwan, last week -- we do have
structured training in place now for all new starters,
which involves, you know, understanding the Horizon
issues of the past, the findings from the Common Issues
Judgment, the Horizon Issues Judgment and, actually, you
know, watching excerpts from this Inquiry to understand
the previous issues that we had and the need to change,
both culturally and operationally.

So specifically to the Trainers, they would have
any -- any new people joining the team would have that
level of training.
Just pausing there, I'm not interested, really, in the
new people --
Okay.
~ it's the people who used to train before Common
Issues?
So for existing Trainers, who might have been in post
prior to Common Issues Judgment, they will have also
gone through various modules to get an understanding of
what happened in the past, what needs to change. They
will also, of course, have been able to view our
training policy, they have to look at our training

policy, and we have records annually that they've looked
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and making some changes to those documents, I will need
to look at the wider training collateral there, which

will include classroom content too.

Please can we look at page 36 of your statement,
paragraph 83. You give a description there of how
members of the Training Team are trained. You say
they're trained internally. I don't need to read the

rest of that out, it can be read.

How many of the trainers working now in the Training
Team were in post as Trainers before the Common Issues.
Judgment?
I don't know that number off the top of my head, I'm
afraid. There is quite a high churn rate in our
Training Team, so a good proportion are, you know, over
the last five or six years definitely but I can't say
for sure.

We've heard evidence of Post Office's previous view of
the obligations on subpostmasters, in respect of
settling discrepancies. What steps is Post Office
taking to ensure that those who were giving training on
the pre-Common Issues training course, they're not
carrying over that institutional understanding of how
the contract used to work into today's training
programme?

Sure. Well, I think, for anybody working in Post
50

at that and understood that and been trained out on it.

And, of course, our Trainers, as well, are all
quality assured, they're observed on a regular basis by
the leaders in the team to make sure that they are
delivering in the very best possible way and to the
standards that we expect.

So I'm confident that, if there were any -- anything
being trained out that wasn't -- you know, was pre-ClJ
and shouldn't be, in terms of approach to shortfalls,
for example, that if that did happen, it would have been
stamped out very quickly. I'm not aware of any examples
of that, though.

I should also clarify, sorry, I should have said my
question wasn't aimed at new trainees, not that I'm not
interested in it.

Thank you.

Clearly, we are looking at that as well.

Apologies.

My question wasn't aimed at that.

We don't need to bring it up but at page 42 of your
statement, paragraph 100, you refer to a Feedback
Committee being established in June 2024, to collate
feedback received on training, analyse it for patterns
and trends, and take any steps you deem necessary.

Yes.
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What was done with feedback prior to June 2024?

So I think, prior to June 2024, we received feedback

from postmasters or people going on training at the

various stages of the learning cycle. So we'd have
feedback provided after e-learning had been completed
online; feedback after attendance at classroom; feedback
after an onsite Trainer had been out to support
postmasters; and then feedback from new postmasters
after the first few months of them being in operation;

as well as getting feedback from those who use our

materials on our Learning Management System, et cetera.
But I think it's fair to say that, within the

respective teams, that data was being analysed and

looked at, perhaps in a slightly siloed way, so what

this has tried to do is bring all of those component

parts together. So everybody responsible for all of

those elements are meeting now regularly, looking at the

data holistically and understanding what needs to be
done in response to that feedback. It's very early

days, the first one was only in June, but I think it’s

working well.

Q. Could we please bring up EXPG0000007. This is the
YouGov survey that was produced for the Inquiry. Have
you had a chance to read this?

A. Yes, I have.

po

53

parts of training we've consistently seen levels of plus
90 per cent. So that's why I was very disappointed to
see these results because there is quite a stark
difference there.

Q. Is there any proposal to investigate the cause of the
difference between the feedback you receive and the
feedback that's been found in this YouGov survey?

A. I think with all of the statistics and feedback in this
YouGov report overall, absolutely. You know, the
business are, and I am, for my areas, looking at these
results and understanding what more we need to do, given
this feedback. I think it's very hard, obviously, when
you don't know, quite rightly, who these postmasters are
who have experienced this, but we take this very
seriously and, if people feel like this, we need to do
more.

Q. Thank you. That can come down.

I want to move on to a very brief point on branch
assurance/audit.

SIR WYN WILLIAMS: While it's on my mind, there are two
things that I'd like a bit more information about.

First of all, on surveying people's satisfaction, so
to speak, with training, in effect, you were saying that
your feedback to the Post Office directly reports much

higher numbers of people who are satisfied with the
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Q. Can ask to turn, please, to page 16, and if we could
go to the table at the bottom, please. We have
satisfaction responses in relation to the Horizon
training by length of time working as a postmaster,
which obviously will be relevant to the types of
training it's engaged at. Looking at the "2 years or
less" and the "3-5 years", the levels of satisfaction
and dissatisfaction, is that consistent with the
feedback Post Office had been receiving through its own
feedback forms?

A. It's not and it was very disappointing to see these
statistics, if I'm honest.

Q. I take it from you saying it was disappointing, your
feedback you received directly from subpostmasters is
better than what is shown here?

A. Itis, itis much better than is shown here. A short
while ago I just illustrated some of the feedback we get
at the various stages of the postmaster lifecycle, after
e-learning, after classroom, after onsite training and
then post a branch going live, and of course that's for
new postmasters coming in and their onboarding journey.

And at every one of those stages we ask the
postmasters to rate how confident they are with
progressing as one metric, and it's a score out of 10,

ascale of 1 to 10, and across all of those component
54

training they received.

In respect of your surveys, do a high proportion of
the people undergoing the training actually provide
feedback as well?

A. It varies depend on the stage, sir. It's a very good
question. I believe that after classroom, for example,
the feedback forms are provided to the delegates after
the classroom. So, in person, if you like. So there's
obviously a very good response rate there. For onsite
Trainers and post-Go Live, I'd have to check the details
but I think it's more on a voluntary basis, if you like,
from the postmaster, so response rates might be fairly
low there.

SIR WYN WILLIAMS: Yes, that's what's I'm struggling with
and I'm making that admission openly, about the survey
information I'm getting because, obviously, the
percentage of people completing the YouGov survey is
comparatively low, compared with the whole number of
postmasters. So I wanted to know whether the same
applied to your surveys or something different, if you
see what I mean.

A. I see exactly what you mean, sir. It's a very good
question and, you know, completion of surveys and
response rates is something that plays on not just my

mind but I'm sure many of my colleagues’ minds. We
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would love to get more people responding to surveys
generally, across the organisation. Response rates
are -- aside from our annual postmaster survey that we
do which, you know, earlier on this year had over 1,900
responses, the surveys that we do within the respective
business units, on operational issues, they're quite low
and we'd love to encourage more feedback but, sadly,
that's not materialised yet.

SIR WYN WILLIAMS: =Anyway, I think you've answered my
question in the sense that, if I summarise it in this
way: apart from those instances where people are
completing a survey following a classroom exercise, the
Post Office struggles to get a substantial number of its
cohort answering the surveys in a similar way to the
struggle that YouGov had to get people to respond; is
that fair?

A. That's fair, sir. Yes.

SIR WYN WILLIAMS: = Okay. That was that.

Then I had just a point of detail. Could we go
back, please, to paragraph 47 of your statement. It's
WITN11610100. That's where you describe the training
that continues to be available, if I can put it in that
way, for subpostmasters.

A. Yes.

SIR WYN WILLIAMS: I wanted to focus on the subparagraph
57

for anybody who wants to go along to have more training
to help them in their branch.

SIR WYN WILLIAMS: Right. That leads me to my second point
of detail. In respect of that specific half-day
classroom course on investigating discrepancies, do you
find that you've got more people who want to attend it
than you can supply, or what, or is there not very much
of a take-up from subpostmasters or postmasters; can you
give me some feel for that?

A. Sure. I don't think there's as much take-up as I would
like, sir, if I'm honest. I think over the last six
months or so, I think we've had around 200 delegates on
that particular course, although I'm not entirely sure
of my facts there. I think what I find, sir, is
a general lack of awareness, still, from postmasters and
their teams about what training is available to us and
that's one thing, again, that we're exploring at the
moment: how we can better advocate the range of training
materials that are out there, and get more postmasters
to take us up on them.

SIR WYN WILLIAMS: All right. Thank you very much.

Sorry, Mr Stevens, over to you again now.
MR STEVENS: Thank you, sir.
A brief point on branch assurance/audit. The

Inquiry has heard evidence about Post Office Auditors
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(d), "Investigating discrepancies", all right? Two
points I wanted clarification of: is investigating
discrepancies part of the mandatory training that people
who are newly joining as postmasters undergo, post-ClJ?

A. So, in part, yes, itis, sir. In the initial classroom
training, e-learning and onsite support, new postmasters
and their assistants, as well, in branch, will be taken
through ways in which they can help themselves in branch
with operational procedures to minimise discrepancies
and what steps to be taken, if there is a discrepancy,
to try to get to the bottom of it. So it is in there
across the various approaches.

SIR WYN WILLIAMS: Right. So I think you describe in detail
the -- what I'll call onboarding training from, I think,
paragraph 50 onwards of your statement. But, anyway,
there's a whole section on the training received right
at the start and I must have missed it because
I couldn't find in that specific reference to part of
the training being investigating discrepancies. But you
tell me that it is part of the training, yes?

A. Itis part at various stages, there is a lot of material
and it is covered as part of our classroom and onsite
too. The investigating discrepancies half-day classroom
course is, you know, just by the length of time, more

detailed and is available not on a mandatory basis but
58

logging onto branch terminals and making adjustments to
stamps without postmasters' knowledge. I just want to
explore one element of that with you. Please can we

bring up NFSP00001468. There's an email at the bottom
from Calum Greenhow to you on 10 May 2023, and it says:

"Tracy,

"It has come to my attention that [Post Office]
personnel are visiting postmasters, including audits
(Putney PO), where Area Managers/Auditors are entering
stock values onto Horizon without either consultation or
agreement with the postmaster."

It says:

“If these facts are correct, then the NFSP would
like to know who has authorised this policy within [Post
Office] and why it has not been discussed with the NFSP.
in advance?"

It goes on to set out some various other matters.

Firstly, were you involved in investigating this
issue following this email?

A. I wasn't specifically involved in investigating the
issue. The reason I got the email is because, at the
time, I was accountable for the relationship with the
NFSP but the issue was investigated, yes.

Q. Do you know what happened as a result of that

investigation?
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I do. So, as a result of the investigation, I believe
Post Office held its hands up and said, “Absolutely,
this shouldn't be happening" and, as a result of that,
that practice has absolutely stopped now in branches.
There was a follow-up call with Mr Greenhow and,
I think, Keith Richards from the NFSP as well, a short
time after this, to update them on the outcome of our
investigation and assure them that that wasn't now
happening.
Are you aware of how this practice began or whether
there was a policy in place?
I'm not, I'm afraid. I mean, I've never had any
accountability for the Branch Assurance Team and it's
certainly not something that's in our postmaster policy.
That can come down. Thank you.

I want to turn to suspension, reinstatement and
termination. You've given figures in your witness
statement, which I'll turn to in a moment, about the
number of branches -- I think it's number of branches
rather than subpostmasters -- where there has been
a termination, suspension or reinstatement since
financial year 2017.
Yes, that's correct.
You say that Post Office doesn't hold a central record

of that data, so it's likely that the record or the
61

Yes, the way it is written in here, yes. It should be
before, prior -- prior to that year.

So we can be confident, can we, that if we turn the page
to page 61, the figures given here are --

The figures of the numbers of them are accurate to the
best of my knowledge, absolutely.

But in the brackets, where there are asterisks?

Yes.

Sorry, I should say brackets relate to where Horizon
data was used or thought to be used?

Exactly.

Where there are asterisks, that's been done on, as

I understand it, a look-back review of available data
and that's the best estimation of a case that's based on
Horizon data?

Correct.

Could you expand on what you mean by where the
suspension, reinstatement or termination was based on
Horizon data?

Yes. So if suspensions or terminations were based on --
as a result of discrepancies or shortfalls occurring in
branch, ultimately, that would be what I'm referring to
here as "based on Horizon data".

So we see financial year 2019/2020, Common Issues

Judgment would have just been handed down at the start.
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information you provided is incomplete.

For prior to '17/'18 financial year I think, yes.

But post-'17, is that --

I'd just have to get up the relevant part of my witness
statement, if I can.

Page 60, paragraph 143, please. You say:

"For financial years 2017/18 and 2018/19, Post
Office did not keep records that identified whether the
SRT was based on Horizon data."

So that's in relation to --

Correct.
2017 and '18. If we go to paragraph 140, please, you
say:

"Post Office does not hold a complete record of
historical data in relation to postmaster suspensions,
reinstatements or terminations. Prior to financial year
2017/18, the Contracts Team was managed as two separate
teams ... with each team holding their own data. It may
be possible that some additional data from pre-2017
exists that could be derived from a manual review of
individual branch files."

So that first sentence, "Post Office does not hold
a complete record of historical data in relation to
postmaster suspensions", et cetera, is that aimed at

years before the financial year 2017/18?
62

Yes.

December 2019, you have Horizon Issues Judgment, and we
see there there's a drop in cases of both suspensions
and terminations. Are you able to say if the drop is
because of the judgments in the Group Litigation or
something else?

I think that the drop in those cases, and over
subsequent years, is as a result of the findings from

the Common Issues Judgment/Horizon Issues Judgment, but
as well as Post Office introducing its policies, which
we've talked about previously, which I think provide
greater clarity on the circumstances in which suspension
or ultimately termination should be enacted.

We see that, in the subsequent years, and noting that
the 2024/25 year is only to 24 June, there are still
contract suspensions and terminations based on Horizon
data?

Correct.

What is Post Office's basis for terminating contracts
using data generated by the Horizon IT system?

So we will -- our Contracts team will take a decision to
suspended or terminate someone's contract. If
discrepancies are involved, which is the use of Horizon
data, then we would obviously only be suspending or

ultimately terminating contracts once a very thorough
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investigation has happened into that discrepancy. The
teams in our central operations function, which are
managed by Mel Park, undertake those investigations into
discrepancies, and I am assured that -- and we've heard
a lot about Horizon data and the integrity of Horizon
data.

As part of their investigations, they will obviously
be looking to make sure and check whether Horizon could
be at play, looking at any known errors, for example,
but only when that determination has happened and we're
sure that the discrepancy is as a result of the
negligence, carelessness or error of a postmaster, would
we possibly enact a suspension or termination.
One thing we'll come to with a different witness is Post
Office's position is it's not pursuing civil claims for
discrepancies based on Horizon data --
That's my understanding, yes.
-- and Post Office's position is it only seeks repayment
without going to civil enforcement where the postmaster
agrees to pay?
Correct.
In these cases, where we see terminations or
suspensions, can you assist with, on the bracketed
numbers, whether, within those groups, the postmaster

disputed the discrepancy or suggested that Horizon was
65

situations where a postmaster resigns?
That's correct.
That can come down. Thank you.

The decision on suspension and termination is taken
by Contract Advisers; do they report to you?
No. The Contract Advisers report to their Head of
Contract Performance and Deployment, and they report in
tome.
You say in paragraph -- we don't need to turn it up --
150 of your statement that the Contract Advisers used to
sit under the Branch Assurance Team?
The Contract Advisers used to sit within the same
function as the Branch Assurance Team, yes.
That's been changed recently, has it?
It was changed in August last year.
Why was that?
Following a review of our procedures and processes by
Group Assurance, who are looking at, you know, how we
have delivered improvements following the Common Issues
Judgment, they identified a potential conflict with the
Branch Assurance Team sitting in the same time as the
Contracts team and, hence, the decision was taken to
move the Contracts team under me.
Please can we look at page 64 of your statement,

paragraph 154. You refer to the four current Contract
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at fault?

I'm not entirely sure whether, in each of these cases,

the link to discrepancies, the postmaster would have
disputed it or would have claimed that Horizon was at
fault. What I can say, of course, is that each of them
would have been investigated very thoroughly. Where we
suspend a postmaster or terminate their contract, what
we're not doing is suspending or terminating on the
basis of them having discrepancies. We are suspending
or terminating based on the fact that there have been
contract performance issues.

So, to give you an example, in the majority of our
cases, there are discrepancies that will have been
caused by operational procedures in branch not perhaps
being followed. Too much excess cash is a key one.
Failure to rem in cash and stock, for example, or not
undertaking daily cash declarations or your monthly
balancing, which have all led up to the accumulation of
discrepancies.

But I'm confident that the discrepancies are
investigated thoroughly.

Just on these numbers finally, I read this as the
contract is terminated, in that the Post Office itself
is making the decision to terminate the contract. Am

I right in reading this that it doesn't include
66

Advisers.

One joined Post Office in 2005. Area Manager for
nine years, now acting as a Contract Adviser.

2012, another joined then, (b), worked in various
roles in the business, now a Contract Adviser.

If you go down, please, (c), another joined 1981,
started in the role of Contract Adviser in 2006.

(d), the fourth, is more recent.

If you then go down please, 155. We see the Head of
Contract Management and Deployment, employed by the Post
Office since 2003, took a role of Contract Adviser in
2011.

The Inquiry has heard evidence about during the
period -- we're looking at 2000 to 2012 and
thereafter -- where the process for termination has been
criticised, in particular that there was an expectation
to respond to discrepancies robustly in the appeal
process and the decision process. What steps has Post
Office taken to ensure that the Contract Advisers who
were involved in those decisions have learnt from those
criticisms that have been made?

So I think I touched on some of this when we were
talking about our Training Team, as well, and people who
were in post prior to the Common Issues Judgment.

The -- all of the Contract Advisers, whether they were
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in the business or since they've come in since, have all
had training, quite structured training, delivered on

the implications of the Horizon IT Inquiry, the findings
from the Common Issues Judgment.

They've also had clearly training on the new terms
that have been added to the contracts as well, the
implied terms, which clearly do give a focus on our
approach to suspensions and terminations and it gives
a focus as well on the management of discrepancies and
how we will support postmasters more.

So they have all had training on the implications
and, again, they will have reviewed the policies
associated with their role on an annual basis to make
sure that they're doing their job in line with those
policies and procedures.
I want to look shortly at some of the review mechanisms
that are in place as well but can I look at suspensions
in a bit more detail briefly. It's POL00448254. So
this is the Postmaster Support Policy on contract
suspension.

Yes.
If we can turn, please, to page 17, down to the bottom
of the page, it says:

"Suspension will only be applied where absolutely

necessary to review the cause of a potential contractual
69

who then makes the final decision. That decision is
then reviewed at the next Postmaster Suspension Decision
Governance Committee meeting."
You set out the membership of that meeting there.
Why are there no either former postmasters or NFSP
representatives on that panel?
It's a very good question and something that we're
looking to address because the other panel, the
Termination Committee and the Decision Review Committee,
do now have postmasters or postmaster representatives on
those panels. I'd be very keen to have a postmaster
representative on this panel; and it's something that we
are looking at.
So that's something you're currently --
Currently looking at, yes.
\s it in consultation with the NFSP over that matter?
It will absolutely need to be in consultation with the
NFSP, and the NFSP do input to and approve all of our
policies, actually, before they go to our Audit and Risk
Committee.
At paragraph 177, just below, you say:
"To date, no decision has been overturned by the
Postmaster Suspension Decision Governance Committee."
Do you think that's a good or a bad thing?

I think it's a good thing because I think it genuinely
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breach identified by the Contract Adviser and where all
alternative options have been considered."

Is that the test that is to be applied, then, by
Contract Advisers when considering whether or not to
suspend a postmaster?

Yes, and they are absolutely trained and given
instruction that suspension should be the last resort

and only when, you know, issues aren't capable of being
remedied.

We've heard a lot of evidence about some policies being
under review. Is that test being considered for review

or change or is that a settled test?

I think we're always up to getting feedback and changing
things if we need to. These are reviewed on a very
regular basis and are reviewed by RCC and ARC, our two.
governance forums. So at the moment that is the
position, that suspension is absolutely the last resort.

I appreciate that these things are reviewed but is there
any indication that that test will be lowered or

weakened in future?

No. Not in my view.

Could we please look at your statement, page 72,
paragraph 176. You say that:

"The Contract Adviser can make a recommendation to

the Head of Contract ... and Deployment on suspension,
70

shows that we have followed the processes and procedures
and been fair and transparent to postmasters when making
suspension decisions.

It might be said that it shows that the Governance
Committee is not properly overseeing it and challenging
the decisions that were made; what would you say to

that?

It could show that. I don't think that's the case.

I think the members of the Suspension Decision
Governance Committee have all had training, they've all
had training on the contracts, they've all had training

‘on the ClJ judgment handed down, and I'm confident in
the decisions that they are making, and we've got some
good representatives there from across the business.

Has there ever been consideration for any independent
review or input to ensure that the Decision Governance
Committee is doing its job properly?

So the Decision Governance Committee, as with our other
committees, have been looked at by our group assurance
function, who are reviewing much of what we do across
the Retail function. I believe that they think it's fit

for purpose at the moment, as there have been other
conversations more generally, not just about Suspension
Decision Governance Committees, around the possible use

of independent external organisations to further assure
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‘our work. So that, again, is something that's ongoing.
‘SIR WYN WILLIAMS: What sort of numbers are we talking about
to get to the Governance Committee, of the people who
are suspended? Roughly at least, can you tell me how

many take the decision to the Committee?

A. So this Committee here, sir, is our internal Suspension
Decision Committee and every suspension decision, every
one of them, is ratified by this committee.

SIR WYN WILLIAMS: Right. I'm sorry, I misunderstood that.
Fine.

A. Thank you, sir.

MR STEVENS: Can we please look at POL00448206. This is the

equivalent support policy but for contract termination.
Could we please look at page 18, if we go down to
“Repudiatory breach", please. So we have examples here
of a repudiatory breach and we see in the middle:

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

Firstly, what is significant value in this context?

A. I don't think we actually have a definition of what
a significant value is. We're certainly talking here
about values over -- you know, certainly over £10,000/
£20,000, I would have thought, but we don't have

73
A. I do not.
Q. Actually, sorry, can we move to page 20, please, 4.11.
It says:

"Post Office will need to consider whether different
has complied with its own contractual duties in relation
to matters relevant to the reason for termination."

It goes on to say:

“If Post Office has materially failed to comply with
its own contractual duties in relation to the matters
relevant to the reason for termination, it is not
entitled to terminate on notice."

Are Contract Advisers giving any legal assistance to
determine whether Post Office has materially failed to
comply with its own contractual duties?

A. Yes, they are. So the important point here is that the
Contract Advisers are not lawyers, they're not legal
experts, so any proposed decision to terminate
a postmaster's contract, we would have external legal
assurance on that decision. Only when that assurance
has been given to us and that we've acted in line with
the terms of the Clu, we've acted, you know, under our
duty of good faith, not arbitrarily, irrationally,
capriciously, et cetera, would we then take that
decision to the Termination Decision Governance

Committee, for final ratification.
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a definition of a significant value.

But is it still the case, then, that it appears that, if

there are discrepancies of a significant value, that the
Post Office considers was caused by negligence,
carelessness or error of the postmaster, that is in and
of itself a ground for terminating the contract?

That, in itself, is grounds for terminating the

contract. But I would add that, of course, before we
get to that point, those discrepancies, whatever their
value, would have been thoroughly investigated, using
the process I've described earlier, before we settled on
the fact that they were caused by negligence,
carelessness or error.

In paragraph 163 of your statement -- we don't need to
turn it up -- you say:

"Contract Advisers do not investigate branch
discrepancies or deal with the recovery of outstanding
branch accounts."

Is it the case that they rely on another team in
Post Office to do that for them?

That's correct.

Which team is that?

So that would be the Central Operations Team and the
Postmaster Account Support Team.

You don't oversee that?
74

That can come down. Thank you.

If a decision to terminate has been made, there's
then the Postmaster Contract Termination Decisions
Committee. Can you explain what the role of that
Committee is?

Yes. So we've got the -- if a termination decision has
been proposed by the Head of Contract Management and
Deployment, we've got the external legal assurance
advice, we then go to that committee, who, very much
like the Suspension Committee that we talked about
earlier, is senior leaders within the organisation,
ultimately, with some legal input too, to review the
rationale document, review the legal advice, and
ultimately ensure that the teams have been working in
line with its contract, it's policies and its

procedures.

If we look at POL00448205, page 14, please.

Apologies, can I ask for some clarity here?

Yes.

We've just talked about the Termination Decision
Governance Committee, which is the internal committee,
and this document is now a separate review panel.

Is this the panel?

This is the panel if a postmaster chooses to appeal

a suspension or termination.
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So is that called the Postmaster Contract Termination
Decisions Panel?

This is the Postmaster Decision Review Panel.

Review Panel?

Yes, apologies.

So this is a separate body that's dealt with for

appeals?

Yes.

This the body that comprised of -- we see two Senior
Leadership Group members, one former postmaster and one
non-voting panel chair --

Correct.

Why is the panel chair non-voting, so there's a majority
in favour of the Senior Leadership Group?

That's a very good question, I think that the initial
thoughts around the panel chair not being -- voting is
so that they can more effectively provide independence
and effectively chair the meeting. That's the case for

a lot of our decision committees, that the Chair would
be a non-voting member.

Looking at this again now, that does clearly skew,
slightly, the postmasters versus senior leaders piece,
so I think, again, that's something that we should
absolutely look at.

In looking at something like that, would you liaise with
77

the Bates programme but never a discussion to cancel.
However, Tracy Marshall confirmed that there had been
discussion about cancelling the survey and that she and
others from within the team had pushed to ensure it went
ahead -- which ultimately it did.”

Can you provide some background to: (1) the
discussions on cancelling the survey; and why it was
continued?

So this is in relation to -- normally, we do an annual
postmaster survey which tends to happen January/February
time of each year, and we've done that since 2021.
Following the Mr Bates vs The Post Office programme in
January of this year, clearly there was lots of external

media attention, lots of, quite rightly, focus on the

Post Office and the awful impact that the Horizon

scandal has had on many postmasters.

There were, therefore, some discussions around the
timing of the postmaster survey, which could have
resulted in perhaps more negative feelings being given
in that survey.

This is a survey, sir, where we're talking about
general postmaster sentiment.

So there were some discussions. I don't think this
is quite a true reflection of my conversation and my

interview here. I don't recall there being a discussion
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the NFSP?
A. Absolutely. Again, this is something integral to our
policy.

Q. Thank you. That can come down.

You mentioned earlier a review about I think
considering whether independent input into these
decisions or reviewing them is being considered. When
will that review be complete or when will there be
proposals available?

A. I don't think I have any concrete dates on that but it
is an outstanding action that we have following feedback
from group assurance, so we will need to work on that
quickly. I would very much hope to have an updated view
within this financial year.

MR STEVENS: Sir, unless you have any questions on
termination, I'm going to move to a different topic.

SIR WYN WILLIAMS: That's fine, then, Mr Stevens.

MR STEVENS: The last topic I have, it's very brief. Can we
look at POL00460000, please. This is an investigation
report on Project Pineapple. I don't need to go through
all of it but can you turn to page 10, please.

In the middle, it says:

"Martin denied that there was consideration of
cancelling the [postmaster] survey. He said there had

been nervousness in the Executive discussions because of
78

about cancelling, full stop, the survey, but there was
certainly a discussion around potentially just
postponing it by a month or so, before it went ahead.
The survey did take place this year and I think it was
March time it went ahead.
MR STEVENS: Thank you.
Sir, those are all the questions I have. Unless you
have any questions now, I'll check if there are
questions from the Core Participants.
SIR WYN WILLIAMS: Check with the Core Participants, please.
MR STEVENS: Yes, there's two sets of questions, sir.
I don't know who wants to go first. I think Ms Page
first.
SIR WYN WILLIAMS: Fine.
Questioned by MS PAGE
MS PAGE: Ms Marshall, hello.
A. Hi.
Q. Have you downplayed your involvement in disputes with
postmasters over the years?
A. I really don't think I have, and I still maintain my
position that, whilst on the face of it, it looks as
though I've -- and I have sent emails which do talk
about remote access, for example, I was very much
passing on information from Subject Matter Experts to my

bosses at the time. I've never had any involvement with
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IT, with prosecutions, with investigations, over my
career history. But I do want to say I'm very sorry

that it gives that opinion of me and want to assure
everybody that that is absolutely not the case.

Let's have another look at a different section of your
email to Ms van den Bogerd and Mr Gilliland. It's
POL00294728 and, as it comes up, you'll appreciate now,
if not, you say, at the time, that this related to

a dispute with the Ferndown branch. The postmaster and
her husband were saying that there were integrity
problems with Horizon; you appreciate that now, do you?
I appreciate that now, yes.

If we could scroll down to the bit that wasn't read out,

it's got the heading "Independent review of Horizon
system integrity":

"Post Office Limited has allowed an independent
review of our Horizon system in the past, on one
occasion."

Then it refers to that occasion. It was to do with
the trial of Mrs Misra. It says this about the trial:

"The case made it to court on 11 November and after
reviewing all the evidence the judge exonerated Post
Office Limited in full, finding the Horizon system to be
robust."

That appears to be in bold; do you see that?
81

the issues around Horizon system remote access would
have come from Dave Hulbert and Andy McLean.

I don't think they would have been in a position, as
IT people, to talked length about the particular case of
Mrs Misra, here.
So where did you get that information from?
Well, I can't remember who I would have gone to, but
that wouldn't have been something that I would have
known about or been involved in, so I would have been
relying on, I'm guessing, some of my legal colleagues at
the time, to provide me with that information. It was
not something I was ever involved in.
Given that the trusted subpostmaster at Ferndown had
raised the issue of Horizon integrity, why do you think
it was that you and apparently Ms van den Bogerd and
Mr Gilliland, were prepared to take these assertions
from you, relayed via others, from various unknown
people, rather than considering what the subpostmaster
and her husband were saying?
I honestly can't comment on why Angela and Kevin, who
I think attended the Ferndown meeting, they didn't talk
about any of the information that I relayed, I don't
think. Hindsight's a wonderful thing, isn't it? They
should have been a little bit more upfront, I think, at

that meeting and asked for the perspective of the
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Ido.

"During the course of the independent review, the
defence legal team were provided with representatives
from Fujitsu and the knowledge and experience of using
the Horizon system. Fujitsu experts helped the defence
team complete their investigation.”

"The jury in the case of Misra v Post Office Limited
voted unanimously that she was guilty and as such, she
is now serving time in prison. This has been a high
profile case due to the fact that Mrs Misra is pregnant.

Mr Misra has made allegations that the defence team were
not allowed access to all the information they required
regarding the Horizon system but the judge made no such
accusation."

If we could just go a little further down, as well.

The final paragraph on the page:

“In addition to the independent review above, the
robustness of the Horizon system is audited on an annual
basis by Ernst & Young. Never before has the quality
and accuracy of the system been doubted here.”

Now, it appears that all of that information came
from conversations that you'd had with Dave Hulbert and
Andy McLean the day before; is that right?
I think the conversations with -- in this email, because

I don't remember it but having read it -- that certainly
82

postmaster.

I think at the time, here, in 2010/11, the business
position was incorrectly and wrongly that Horizon was
very much a robust system.
Was it part of the culture that, when there was a one
word versus another word, a subpostmaster versus someone
else, the someone else was always believed and the
subpostmaster was not; part of the culture of believing
that postmasters were incompetent or dishonest, not
worthy of belief?
I don't recognise that in the roles that I was doing, in
so far as feeling as though postmasters were incompetent
and shouldn't be relied on and that Post Office were
always right. I don't recognise that in the jobs that
I was doing and, in fact, of course, at the time here,
my job involved a lot of involvement with the NFSP and
hearing firsthand about the issues affecting
postmasters. Whether others had that view, I can't say,
but it was not something that I experienced.
Were others like Mr Gilliland and Mr Tuthill coming to
you for this sort of activity, which you say wasn't part
of your role, because you were willing?
No, I don't think so. I wasn't willing. I don't think
I was complicit in any of this at all. I think they
were coming to me, particularly Mr Gilliland, being my

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boss -- as I've said, he did so on numerous occasions --
asking me to go outside the remit of my role to find out
information for him to, you know, assist him in visiting
branches or whatever that might have been.

Evidently, as a result of what you were told by unknown
persons, you must have believed that Mrs Misra was
guilty of theft at the time?

I would have taken on face value, from what my
colleagues had told me. I assume so, yes. Clearly
now --

Do you accept that you were wrong about that?
Absolutely.

When did come to accept that you were wrong?

I think there was a widely held position in Post Office,
until the handing down of the various judgments, that
Post Office were not at fault and that was a message
that was given consistently in our communications.
Can you pinpoint a time when you recognised that
postmasters had been wrongly convicted?

On the handing down of the Common Issues and Horizon
Issues Judgments, yes absolutely.

Would you say that was about convictions? Can I just
press you on that because, of course, there was

a subsequent judgment about convictions. Did you

connect it with convictions when the Common Issues
85

experts in the business had provided me with. I don't
think I've ever been spreading lies or myths in the
business.
Do you have anything to say about your failure to raise
your knowledge based on these email chains over the many
years where Post Office was claiming not to have any
remote access into branch accounts?
So whilst I still absolutely maintain that I wasn't
involved in the particular issues here and I'm, you
know, getting the information from other people, I am
incredibly sorry that I sent any emails with any
relevance whatsoever to remote access or convictions and
I am hugely sorry for any -- for the horrific things
that postmasters and their families and children and
communities have gone through over the last few years.
Can I bring up, please, POL00416991, and this dates from
2011. If we just note that this is an email from Nigel
Allen to Andrew Winn with you on copy. If we go to the
first three paragraphs -- before we do that, the subject
"Ferndown ... Loss settled by [cheque] -- SPMR dispute":

"Thanks for this.

"I have discussed this with Tracy Marshall and she
has asked whether you can draft a letter to Mrs Rachel
Athwal, SPMR, explaining in as simple terms as possible

what happened and why it is now necessary for her to
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Judgment and the Horizon Issues Judgment came out?
I don't think I would have done, no.

So when do you think you did recognise that convictions
were wrongful?

I can't pinpoint it specifically. I mean, clearly since

the Inquiry has been going on now for some years, and

I have, you know, read and heard a lot of the horrific
stories experienced by postmasters, I have now become
very clear that those convictions were wrong but I'm
sorry, I can't pinpoint specifically when I would have
been aware of that.

Is it possibly not until Bates vs The Post Office?

It was absolutely before then.

Just returning back in time, if I may briefly. The

email that you sent to Mr Gilliland and Ms van den
Bogerd was part of the myth making in Post Office, we've
seen a lot of it, using sort of wisps of truth and

spinning them to support what was of the falsehood that
Horizon was robust. Whether you were relying on others.
or not, you were part of that, part of that myth making,
that chain of lies and fabrications. When did you
personally stop spreading those sorts of myths?

I can't think of other occasions when I have spread

those myths or lies. In this particular instance,

I was, as you said, very heavily relying on what other
86

send us another cheque. Mrs Athwal is arguing that she
did what the helpline told her to do and as she has
already settled the shortage by cheque which has cleared
from her bank account, doesn't see now why she should
send another one despite the surplus in the branch.”

Then this:

"Mrs Athwal and her husband have already challenged
the integrity of the Horizon system so it needs to be.
explained that she has not been disadvantaged by any
software problems and that POL took the necessary steps
to rectify this as soon as possible.

"In view of the sensitive situation at this branch,
could you please send the letter to Tracy first and cc
to me."

So you weren't just investigating to help
Mr Gilliland with his interview. You were involved in
how to resolve the dispute, weren't you?

It would appear that from this letter, yes, but that was

not part of my role at all at the time. Although, yes,

that's what it looks like from this email.

What this email tells us is that you were well aware

that the dispute involved the integrity of Horizon and

that it was seen as important to assert that the branch

had not been disadvantaged by a "software problem". You

understood, presumably, what this was about. This was
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about the need to keep the edifice up so that SPMs and
clients didn't lose confidence in the Horizon system.
You must have understood that, mustn't you?

A. As I've said, I should have understood that. I don't
know whether I did understand that at the time. It
wasn't something that was in my remit. But, yes, I'm --
what I'm certainly doing is maintaining the business
position here, that the issue with Horizon integrity
should not be challenged, which, as I've said, was
a position that was maintained for a long time,
incorrectly, in Post Office.

Q. You were sufficiently worried about the sensitivities
that you wanted to review the letter before it went out?

A. Well, that's very unlike me in that role to have to do
that, I have to say.

SIR WYN WILLIAMS: Just a minute. Do we know that, Ms Page?
This is a letter from Mr Allen, who is suggesting that
it be sent to Ms Marshall. We don't, actually -- or
I don't at the moment at least -- know whether it did go
to her, what she did about it, et cetera.

MS PAGE: This is the only email that I have about that,
sir.

‘SIR WYN WILLIAMS: Well, I think we ought to be careful
about making five from one and one, if you see what

I mean.
89

"There is no evidence that the Horizon system does
not work as it should. This is the finding of
independent investigators. It has been shown to be
robust and effective in dealing with six million
transactions", et cetera.

So those were key messages sent to you amongst many
other people in 2015 and this was, essentially, a script
for fending off concerns about Horizon, would you accept
that?

A. I think it was a script for us to cascade to the wider
teams, from what I can make of the email, to use, if
approached by the media, if approached and asked
questions by postmasters, yes, it has to be that.

Q. How many times do you think you would have adhered to
that sort of a script when dealing with concerns about
Horizon?

A. Probably -- it's hard to say. I don't remember how many
times I had those conversations. I certainly never
spoke to the media about it. At the time of this --
sorry, is it 2015, did you say?

Q. Yes.

A. At 2015, or from 2012 through -- well, all the way
through to my current position, I've been working on
programmes -- I was on the Network Transformation

Programme at this point, so I wouldn't have been
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16 October 2024

MS PAGE: Certainly.

If we can move forward in time to 2015 and, if we
could bring up, please, POL00117439. This first page
makes it quite plain that there are a very large number
of people on copy and, hopefully, you'll take it from me
that you're one of them. Indeed, you may be on page 2,
which I'll ask to scroll to now. Yes, there you are
actually towards the end of the long list.

This comes from Mark Davies, and he says:

"Thanks for taking part in the conference call on
Horizon this week."

He then forwards a note and we can perhaps just have
a look at a little bit of the content of that note. If
we go down to page 3, we can see reference there to the
BBC Panorama programme, which is maybe going to go out.
We can also see that there's reference to
a Parliamentary debate about the issue, ie the Horizon
issue, and the talk about the fact that this may lead to
further media coverage.

If we could go down to page 4, please. We can see
that he's set out various key points and messaging and,
if we could go to a little further down -- sorry, just
a little further up from there -- there's the paragraph,
second bullet point down, which has the sort of classic

line, if you like:
90

interfacing actually directly with postmasters or the
media. So I don't know how often I would have used it
but it wouldn't have been frequently.
Q. I won't take you to it, to save time but we can also see
that in 2019, reference POL00268061, you were again part
of a group Mark Davies copied in following the Common
Issues Judgment and how to handle the media fallout from
that. There was a summary of the Common Issues Judgment
attached and some tips on how to handle the media.
Do you remember receiving the Common Issues
Judgment, the summary of it?
A. Do you mean the media summary, the tips, as you call it?
Q. Yes. Let me put it in a different way. When did you
first appreciate what was said in the Common Issues
Judgment?
A. I only when it was -- probably after it was handed down.
I think when it was handed down, there was certainly
shock across the Post Office that that was the outcome.
Q. Can you tell us about your own personal reaction,
please?
‘SIR WYN WILLIAMS: Well, Ms Page, I'm sorry to sound
difficult but I'm not sure that this is actually going
to help me in terms of what I have to really decide on
my terms of reference. I mean, it's clear, is it not,

from everything that I've heard already, that everybody
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in the Post Office expected to win but they lost, so
then they had to come to terms with it.

MS PAGE: What I'm trying to get at, sir, and I hope that it
won't take very long and that it, I would suggest, is
relevant to this phase, is when did it really dawn on
Ms Marshall that Post Office had got it wrong for all
those years and there was a need to really change, and
it's the change I'm really driving at.

‘SIR WYN WILLIAMS: I think you can all safely conclude that
everybody in senior positions realised they needed to
change once they read and digested that judgment.

MS PAGE: Well, sir, that's what I'm exploring.

SIR WYN WILLIAMS: Yes, well, I don't think you need to.
I think I've got that point, whatever Ms Marshall says.

All I'm saying is it's self-evident, is it not,
Ms Page?

MS PAGE: Well, I'm not sure that it is. That's exactly my
point, sir. I think that there's reason to think that
it may have taken some time before people realised the
need for change.

SIR WYN WILLIAMS: Well, that might be right as well but
I have to look at it objectively, don't 1?

Anyway, sorry. Go on.
A. I'm happy to answer if you want me to?

MS PAGE: When did you think there was going to be a need
93

A. I've had conversations with many people across Post
Office, and my wider teams, ever since 2019, about the
impact of Common Issues Judgment; I've had many
conversations with postmasters about it; I've had many
conversations with the NFSP about it.

Q. Have you spoken to them about the sort of activity we
can see you were involved with, albeit you say
tangentially, of spinning myths, of perpetrating myths.
Have you talked to them about that and their own conduct
of that sort of behaviour and how they feel about it and
whether they see they need to change?

A. The first I saw -- I remembered of any of the details
you've shown me today was when they were disclosed to
the Inquiry. So before to that no, I hadn't because
I couldn't recollect being involved. Since they've been
disclosed, yes, I have had conversations with my own
team and other colleagues across the business, about
those emails, about my perceived role in those, and
I think that certainly the emails that you've shown me
point to, culturally, a Post Office that was very flawed
in the past.

What I can say is that, you know, in the roles that
I've been doing, and from my perception of the wider
business now, we've got more work to do, of course, but

we have significantly changed, culturally. That's what
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for serious change?

A. I think I was in quite a fortunate position at the time,
personally, that, by the time the Common Issues Judgment
was handed down, I was already very much in a role
focused on postmasters and making improvements. So,
whilst there was some shock at the fact that the Post
Office had lost both of the trials, the Common Issues
and the Horizon Issues Judgment, and there was a shock
at the extent of our failings as an organisation, I was
personally, I think, very quick -- very quick -- because
I was already focusing on the things that weren't
working for postmasters and that's kind of the role I've
had ever since.

Q. You've told us about the people that you work with in
Contract Management who are mostly -- the Contract
Managers and their boss are mostly people like you, who
have grown up in Post Office, if I can put it in that
way: people with very long careers in Post Office?

A. Some of them are, yes.

Q. You've told us that the structured training on the
Common Issues Judgment and the Inquiry, and so forth, is
something that they've all had to go through?

A. Yes.

Q. Did you have conversations with people afterwards about

what that meant?
94

I see. Prior to 2019, I don't think we've really put
postmasters at the heart of very much. Nowadays, we
absolutely do, and that's right. That's got to be right
and we've got to continue to do that.

Q. Only today, through questioning, have you identified,
for example, the need to review the guidance which puts
the burden of proof on postmasters to demonstrate why
they're disputing a discrepancy. Do you think that your
past and the culture that you grew up in has played
a part in that failure to fully change the mindset?

‘A. I don't. I don't. My focus is very much on making
improvements for postmasters.

Q._ Has it got anything to do with why you hadn't
identified, for example, that problem before?

A. No, it hasn't.

MS PAGE: Thank you, sir.

SIR WYN WILLIAMS: = Thank you, Ms Page.

MR STEVENS: Sir, sorry --

‘SIR WYN WILLIAMS: I'm sorry, I can't hear you.

MR STEVENS: Ah, can you hear me now, sir?

SIR WYN WILLIAMS: Yes.

MR STEVENS: I think that's the first time that question has
had any actual effect!

I may be being over cautious here. I was reviewing

the [draft] transcript and at LiveNote 86/18,
96

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The Post Office Horizon IT Inquiry

Ms Marshall was asked about "So when do you think you
did recognise that convictions were wrongful?", and
there was a long answer but it was "couldn't pinpoint it
specifically". Then, as it's on the page, Ms Page's
next question was:

"Is it possibly not until ‘Bates vs The Post
Office?"

“Answer: It was absolutely before then."

I just think for clarity, can I ask, when you refer
to Bates vs The Post Office, were you referring to the
Group Litigation or to the ITV drama, Mr Bates vs the
Post Office?
That may be a question for - I was thinking it was the
drama, the ITV drama; is that correct?

MS PAGE: So was I.
MR STEVENS: Yes. It's just howit reads is slightly ~

A.

months down the line.
Understood.

MR STEVENS: We're just checking that that was what you were

answering. Thank you.
Apologies, sir.
I think Mr Jacobs has some questions.

‘SIR WYN WILLIAMS: Right, fine.
MR JACOBS: I do, sir, I'm conscious of the time. I'll try

to and be quick.
97

Post Office does not recover shortfalls -- recover
shortfalls -- unless the subpostmaster agrees but
applies a different approach in relation to suspending
and terminating on the basis of shortfalls?

Do you see that there's a disconnect there,

Ms Marshall?

I do, and I can't comment on why we don't recover
shortfalls apart from where the postmaster agrees.
That's not my area. I think, in the cases of

suspensions or terminations, where there are
discrepancies and where the postmaster might not agree
with the reason for those discrepancies, I'd refer to my
earlier point that, where we're taking decisions to
suspend or terminate contracts, the team aren't basing
those decisions on discrepancies as such.

They're making the decisions based on that being the
‘outcome, as in it's due to operational performance
issues in branch, such as having lots of excess cash or
not doing monthly/weekly trading, et cetera.

But I appreciate there is a slight disconnect there
in the language.
I think our point, which I ought to, in fairness, put to
you, is: don't you think that the policy should reflect
that, should reflect that suspensions and terminations

will not be pursued in relation to Horizon generated
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16 October 2024

Questioned by MR JACOBS

MR JACOBS: Ms Marshall, Simon Oldnall gave evidence

yesterday and he said that Post Office doesn't recover
losses from subpostmasters, except where a postmaster
agrees the reason for the shortfall.

I that's my understanding at the moment, yes.

You've confirmed that's your understanding in your
evidence today. Now, Mr Stevens took you in your
evidence to the Contracts Termination Policy?

Yes.

Do you remember -- we don't need to turn it up because
it's fresh in our minds, I hope -- paragraph 4.6,
"Repudiatory breaches"?

Yes.

Do you remember that it said that, where there are
discrepancies of significant value that have been caused
by negligence, carelessness or error of the postmaster,
that resulted in a loss to the Post Office, and have

been fully investigated by the Post Office, that is
grounds for suspension and grounds for termination?
Yes.

Do you accept that there is therefore scope within this
policy for suspension based on a Horizon shortfall?

There is, yes.

Yes. This is my question for you: why is it that the
98

shortfalls?

I think we need to tighten up our wording. Of course,
having a discrepancy in a branch and having shortfalls
is, by definition, a reason for an investigation to

happen by the Central Operations Team, but we can
tighten up our wording, absolutely.

It's more about wording, isn't it? Our clients tell us

that they are concerned that the wording of the policies
does not reflect the express intentions given by you and
other witnesses from Post Office who are giving evidence
in this phase; do you see that?

I do, and I think it's very clear to me that the

position that we take in our policies should be the
position that myself, others, our teams, are all

adhering to. I also hope that, with the publication of
these external-facing policies that I've talked about

and on a new template, that will hopefully provide
clarity to postmasters too. A key thing for me is that

we do want to include postmasters much more in
day-to-day operational matters such as that. So I would
welcome any feedback that they have on the wording of
such policies, et cetera.

So are these policies likely to be reworded or reviewed?
All of the policies, as I've said, are always reviewed

on an ongoing basis. We're putting them on
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MR JACOBS:

The Post Office Horizon IT Inquiry

externally-facing templates, which are going to be
looked at by the NFSP. We're very happy to bring other
postmasters into the fold there too before they're
published.

You've anticipated my next question: will subpostmasters
be allowed to be or be permitted to see these policies

in draft before they're published and be consulted?

We certainly want to include other postmasters in the
consultation of those policies, and our Postmaster NED
looks as those policies as well, Elliot Jacobs, and as

well as Mark Eldridge, our Postmaster Experience
Director.

Ihave one final quick series of questions for you and

this is in relation to the Fujitsu letter, are you aware

of that, from Mr Patterson to Mr Read?

I'm aware from previous evidence, yes.

I'll quote from it, it's 17 May 2024:

"To be clear SFL will not support the Post Office to
act against subpostmasters. We will not provide support
for any enforcement actions taken by Post Office against
subpostmasters, whether civil, criminal, for alleged
shortfalls, fraud or false accounting.”

When did you first see this letter; when were you
first made aware of it?

Only in the Inquiry.
101

I don't need to ask you any more questions.

THE WITNESS: = Thank you.
MR JACOBS: That's all from me, thank you.

‘SIR WYN WILLIAMS:

Questioned by SIR WYN WILLIAMS

In the light of those questions, can we
just revisit paragraphs 143 of your witness statement,
Ms Marshall -- I'm sure that it's WITN11610100 —
because I want to be sure I'm fully understanding the

table, all right --

A. Yes. Yes, sir.

SIR WYN WILLIAMS: = -- once it's up. Just a little further
on, please. It's actually on page 61, that's what I'm
looking for. That's it. That table.

Now, as I've understood it -- and I'm concerned only

with the most recent period, all right. So let's start
in 2021/22. So in that year, there were 25 branches
where suspensions occurred, yes?

A. That's correct, sir.

SIR WYN WILLIAMS: = That may or may not mean 25 postmasters,

A

some postmasters may have had more than one branch, so
we should focus on branches, yes?
Correct.

SIR WYN WILLIAMS: The figure in brackets, 13, as I've

understood what follows under figure 1, means that they

were cases which relied on Horizon data?
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Q. Okay. The Contracts Termination Policy that we've
talked about requires a full investigation, doesn't it?

A. Into discrepancies, yes.

Q. How can Post Office fully investigate discrepancies
without assistance from Fujitsu; that's a real problem,
isn't it?

A. I think it is and I think I'm very confused, personally,
by the letter.

Q. Fujitsu doesn't consider that the Horizon system should
be used to evidence shortfalls. Do you accept that the
Horizon system should not be used to support suspensions
of terminations based on shortfalls?

A. As''ll go back to my previous comment, I'm quite
confused with the letter from Paul Patterson and why
Fujitsu won't stand behind their data. I'm not a data
expert or an IT expert but it's fascinating that they
can't stand behind the data when the data is fundamental
to everything that we do in our operations, quite
frankly, across our network.

Q. Well, you say it’s fascinating, but it's because of what
happened in the scandal, isn't it?

A. Sure.

Q. The effect of that letter makes many of Post Office's
policies unworkable, doesn't it?

A. I understand.
102

A. That's correct, sir.

SIR WYN WILLIAMS: Fine. So what I want to knowis, was the
reason for the suspension that Horizon demonstrated
a shortfall or was the reason something different?

A. Without knowing the specifics of each case, sir, I would
say that the majority of them -- in brackets, the 13
there that's highlighted -- would have been following
the result of an investigation into discrepancies or
shortfalls, which would have been down to Horizon data
and the suspension would have been enacted as a result
of that, yes.

SIR WYN WILLIAMS: But you also seem to be saying, in parts
of your evidence, that there wouldn't be a suspension
simply because Horizon showed a shortfall: there would
only be a suspension if there was an established reason,
after an investigation, which justified a suspension.

So do I take it that what you're telling me is that the
starting point is that Horizon shows a shortfall, there
is then an investigation into how that shortfall came to
be caused, and it is only if that investigation
demonstrates, in effect, some fault on the part of the
postmaster that a suspension would follow?

A. That's correct.

SIR WYN WILLIAMS: So that's the process that I should

understand, is it, when I interpret this table: in that
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The Post Office Horizon IT Inquiry

year there were 25 suspensions, 13 of which, in effect,
commenced by reason of Horizon showing a shortfall but
they only occurred because, following an investigation,

a suspension was thought to be justified because of the
activities or actions of the postmaster?

A. That's correct. The figures in brackets there, the 13,
would have been based on Horizon data, discrepancies or
shortfalls identified, but there would have been a full
and proper and thorough investigation into the cause of
those shortfalls, which would have then led to the
determination to suspend the contract, sir. Yes.

‘SIR WYN WILLIAMS: In the years that we are talking about,
2021/22 onwards, whether or not the suspension actually
occurs goes through the process that you described in
evidence when Mr Stevens was asking you questions?

A. Yes, sir.

SIR WYN WILLIAMS: Fine, all right. Then that deals with
that.

Then the final point I want to ask you about is the
years 2021/22 and 2023/24, and the footnotes to the
cases in progress, all right?

A. Mm-hm, yes.

SIR WYN WILLIAMS: = There are still, from 2021/22, two cases
in progress; that's right, is it not?

A. Yes. Could we go to the footnote, please, sir?
105

we are referring here -- the ones in brackets are the
suspensions that have been prolonged due to issues in
arranging postmaster meetings. One is now at the final
stage and with external professional advisers.

SIR WYN WILLIAMS: So that deals with the long suspension
but my question was, and perhaps you don't know, whether
the two cases in brackets in the table are also the two
cases where the postmasters have been arrested and
charged?

A. No, they're not, sir.

SIR WYN WILLIAMS: Right. So in none of the cases -- this
is the point -- in the table which we've been looking
at, are they what I'll call Horizon cases?

A. Correct.

SIR WYN WILLIAMS: Fine. Thank you very much. I just
wanted to be absolutely clear as to where we were on
that.

THE WITNESS: § Thank you, sir.

‘SIR WYN WILLIAMS: Right, good.

Well, thank you very much, Ms Marshall, for coming
to give oral evidence today and for making your witness
statement on behalf of the Post Office. I'm very
grateful to you for doing that.

So what time shall we resume, Mr Stevens?

MR STEVENS: Sir, I'm in your hands. We can either do 2.00
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‘SIR WYN WILLIAMS: Neither of which depend upon a Horizon
shortfall, as I understand it.

A. The footnote 18, which we've just looked at, relates to
postmasters having been arrested and charged with
offences, yes.

SIR WYN WILLIAMS: Yes. I'll get to 18. There's a"O" in
brackets after the "2", you see? If we go back to the
table, sorry, you see there's two cases in progress.

A. Yes.

SIR WYN WILLIAMS: But in brackets "0", which to me says
that neither of these were dependent, even as a starting
point, on Horizon showing a shortfall.

A. That's correct, sir, because these were both cases where
the police had intervened and the postmaster had been
charged with offences.

SIR WYN WILLIAMS: Fine. So I needn't bother with those,
now that I've got that, fine.

It's the next one, 2023/24, where there are still
four cases in progress, but two cases start life, if you
like, with Horizon demonstrating a shortfall.

A. Yes.

SIR WYN WILLIAMS: Now, are those two cases the two cases
which are referred to in footnote 19?

A. Can we scroll down to footnote 19, please? That's

correct, sir. So the two -- if we look at footnote 19,
106

or 2.10. I don't think we should have problems with
time to start at 2.10, if you prefer.

SIR WYN WILLIAMS: Well, then, I do prefer.

MR STEVENS: Thank you, sir.

SIR WYN WILLIAMS: Yes.

(1.12 pm)

(The Short Adjournment)

(2.10 pm)

MR STEVENS: Good afternoon, sir. Can you see and hear us?

SIR WYN WILLIAMS: Yes, thank you.

MR STEVENS: We are hearing from Ms Park.

SIR WYN WILLIAMS: Yes.

MELANIE JANE PARK (affirmed)
Questioned by MR STEVENS

MR STEVENS: Please can you state your full name?

A. Melanie Jane Park.

Q. Ms Park, as you know, my name is Sam Stevens and I ask
questions on behalf of the Inquiry. First, can I thank
you for producing a written statement today and,
secondly, for attending the Inquiry to give oral
evidence. I want to turn first to that statement which
should be in front of you in a bundle of documents. Can
1 ask you to turn that up, please --

A. Mm-hm.

Q.  -- and just confirm that's your statement of 22 August
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2024.

Yes, it is.

Now, before we go any further, there's one correction

l understand you wish to make. That's at paragraph 162,
please, which is page 71 of the statement. That will
come up on the screen, as well. ll just wait for it.

What I'll do is provide a summary of what I think the
correction is and you can tell me if you think I'm right

or wrong.

Five lines down, there's a sentence that reads:

"The cost of a given ARQ request corresponds with
the length of period being requested, for example ARQ
data for a 6-month period will cost more than a request
for a 3-month period."

My understanding is that, when you signed that, you
understood that to be correct on the basis of
information from Subject Matter Experts. You now
understand that that isn't correct, you wish to strike
it out of the statement and it is dealt with by the
evidence of another Post Office witness?

That's correct, yes.

MR STEVENS: So, sir, the highlighted text should be struck

out of the witness statement, effectively.

SIR WYN WILLIAMS: Yes, thanks very much.
MR STEVENS: The statement can come down from the screen but

109

No, I haven't.

Very briefly, could I just ask you to give an overview
of your career before joining the Post Office?

Mm-hm. I qualified as a chartered accountant in 1997
with KPMG, following which I moved to Boots the Chemist
in December 1997, where I stayed for 24 years. So

I started out doing various financial roles, both pure
financial accounting and more business partnering
latterly, and then moved into a more operational role
and then was Head of Retail Operations before I left.
In terms of your reporting line, I understand you report
to Neil Brocklehurst, the Interim Chief Operating
Officer?

Ido, yes.

In broad terms, could you summarise your roles and
responsibilities at the Post Office?

Yes, I have a number of quite different
responsibilities: the first of which is I have
responsibility for the Branch Support Centre, so the
team up in Chesterfield that are responsible for
supporting postmasters with a number of different
matters, we have a team of about 50 people up there.
That's the Branch Support Centre. I also have
responsibility for the network reconciliation and

support team, and they're responsible for understanding
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16 October 2024

could we please turn to page 101 of the statement; do
you see a signature?

Ido, yes.

Is it your signature?

Itis.

Are the contents of that statement true to the best of

your knowledge and belief?

They are, yes.

Thank you, Ms Park. That statement now stands as your
evidence in this Inquiry. It will be published on the

Inquiry website shortly. For the record, the unique
reference number is WITN11600100. II'm going to ask you
some questions about it but not every aspect of what is

a very detailed statement.

I'll start with similar questions to what I did this
morning. You have been chosen by Post Office to act as
a witness to give evidence on its behalf in response to
parts of two Rule 9 Requests sent to it; is that right?
That's correct.

You are the Central Operations Director to the Post
Office?

lam.

When did you join the Post Office?

17 October 2022, so two years tomorrow.

Have you had any other role at the Post Office?
110

any discrepancies, as a result of proactive comparison
of third-party data and issuing transaction corrections,
should they need to, once they've been investigated.

They also have the Network Monitoring Team as well
and their role is to again proactively look for branches
that might not be following operational processes as we
would like, and that which may suggest they are
struggling with those processes and try and intervene
before those processes lead to potential discrepancies,
as we've heard this morning.

I'm also responsible for the Network Support and
Resolution Team, and they are the team that help
postmasters with the review of discrepancies. So should
a postmaster use "Review or Dispute", and it can't be
call into the Branch Support Centre, they will be the
team that review the discrepancy and ultimately agree
the resolution with the postmaster.

Presumably you received a formal induction when you
joined the Post Office?

Yes, I did. I had a very -- I had six weeks where

I wasn't part of my role, I was travelling around the
various functions within Post Office, so the commercial
functions, the rest of the retail functions, to really

try and understand the rest of the role that I was being

brought in to do.
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Was there any discussion as part of your induction on
the findings by Mr Justice Fraser, as he then was, in
the Group Litigation?
Not formally. I think when I knew I'd taken a role at
Post Office, I made it by business to start doing some
research and looking into it and then I did get a number
of documents, when I first came, to read through and
then I've attended the Inquiry on a number of occasions
to try and understand in a bit more detail the impact
that -- on postmasters, such that it would help me do my
role more effectively.
I want to look at branch assurance and audits. Could we
look, please, at your statement, page 14, paragraph 38.
You say:
"The Inquiry has used the term 'audits' in relation
to [a set of questions]. Post Office does not carry out
audits on branches. The Branch Assurance Team attend
a branch to count physical cash and stock and establish
whether that agrees with what is record in Horizon."
That process before was known as an audit in Post
Office, wasn't it?
Itwas, yes.
Is it not effectively describing what an audit is, in
any event?

I don't believe so. So, in my experience as both
113

as ‘very good’, and one was ranked as 'good'."

That was July 2024. From your experience, how does
that stack up to other months: is that about average for
the results or better or worse?
I think given that this feedback form was only
introduced in June this year, I believe, I think it's
actually probably a better response than we would
generally see when we --

Sorry, can I just check -- it's my fault for asking the
question. When you say "better response", do you mean
the number of responses you get back to the question or
whether this is satisfactory --

In terms of the number of responses that we've had
since, and we've had some updated figures, and they
actually show a much improved response rate. So we are
getting a significantly increased response rate, if we

look -- versus what we see in other areas. And I think

it is important, because this could be quite an emotive
area, if -- and it's important that we seek feedback and
get feedback, and act on that feedback.

So you've noticed more responses. Is there any
difference to the ranking? So here it's 12 ranked as
“excellent”, one as "very good", one as "good"; is it
about the same proportions or are they different?

I think they've slightly improved. From my
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an external auditor and an internal auditor,

particularly external audit, you're looking at accounts
trying to understand the validity of the data in those
accounts. This is different -- this is simply

a stocktake, in effect. So what we're doing is ensuring
the physical value of the cash and stock and cash
equivalents in that branch and comparing it to what the
system thinks, as any other retailer would do on their
annual stock takes.

So your view, this is just correcting, essentially,
incorrect terminology?

Yes, it's ensuring the physical value, as it stands at
that point in time.

Page 20, please, of your statement, paragraph 53. It's
a point on feedback about branch audits. You say that:
"During a visit, the Lead Assurance Advisor will
give the postmaster a Branch Assurance Visit findings

letter ..."

You go on to say:

"The form also gives postmasters an opportunity to
give feedback on the Branch Assurance Visit and their
experience with the team. In July 2024, 34 Branch
Assurance Visits were completed, and 14 responses were
received to that feedback request. Of these 14

responses, 12 were ranked as ‘excellent’, one was ranked
114

recollection, I think we've received more "excellent"

and then probably one or two "good" and "very good", but
there are definitely more “excellents" than this data.
Could we look, please, at EXPG0000007. This is the
YouGov survey that was commissioned by the Inquiry.
Have you had the chance to review this?

Ihave, yes.

Can we turn please to page 32. We see it says, "Branch
audits", its referring to the same thing: the Branch
Assurance. Since January 2020, just over 3 in 4
postmasters surveyed said that their branch has not
received an audit; 12 per cent reported that they have
received an audit:

"Those who have received an audit [this is the third
paragraph] since January 2020 were more likely to be
satisfied than dissatisfied with how it was conducted.
Over half ... were satisfied compared with around one in
five ... who were dissatisfied."

So there appears to be a difference here in that
there are some people expressing through the YouGov
survey dissatisfaction with branch assurance; would you
agree?

Yes.
Are there in place any plans within Post Office to

investigate why there might be a difference between the
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results of the YouGov survey and results you're
obtaining through the feedback forms?

I think we have to look at the current process. I think

Ms Marshall referred earlier, without understanding the
detail of the people who completed this survey, it's

really difficult to go and ask questions about

historical assurance visits. I think what we have to do

is take the feedback for the -- again, for the assurance
visits that we're doing now and, where we see
dissatisfaction, we seek to understand why those
postmasters might have been dissatisfied with that visit
and take appropriate actions, either across the
assurance visit piece, or with the individuals that have
conducted that assurance visit.

Do I take it from your evidence earlier that Post Office

is seeking to increase the rate of return on those
feedback forms, so the number of people returning either
positive or negative feedback results?

Yes, I think the latest data, I think about 35 per cent

of visits conducted since June have received a feedback
form, so it is higher than we would normally see across
Post Office but we would always look to try to encourage
postmasters to feed back following a visit.

Could we look, please, I want to look at the Branch

Assurance Team, please. Could we look at POL00448256.
117

Apologies, training guide?

So it doesn't sit in the policy that is the Postmaster
Support Policies. In answer to your question: I'm not
sure. I joined in 2022 and this team don't line report

into me, so I'm not sure when this actual training guide
will have been enacted and taught through the teams that
exist.

Would the people in the Branch Assurance Team who were
in post before Common Issues, have been given training
on their role or how the policies have been updated

since Common Issues?

I couldn't say for certain. My understanding is they

would all have been given training on the policy that
stands and I think we've heard that the postmaster
policies -- that we have annual training on the

postmaster policies with the relevant teams. I couldn't
say on that particular piece of training material. I do
know that, shortly after I joined, the Branch Assurance
Advisors were all taken through additional training, and

of the Head of Operational Support, who they now line
into, has done a lot of work with them to show that,
actually, the role of the stock check, it's just as.

important how you do it and how you conduct yourself and
how you make the postmaster feel when doing that stock

check, and that's just as important as making sure you
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This is a "Branch Assurance Advisor -- Induction &
Training”, I think policy or report. At paragraph 60 of
your statement you say:

"There have been no new joiners since this was last
updated."

Is that correct?
That's my understanding, yes.
How many currently within the Branch Assurance Team were
in post before the Common Issues Judgment?
I've been advised by the head of that team that I think
it's 12 of the 18. I couldn't be quite sure but I did
ask that myself and my understanding is it's 12, or
around that number. A lot of -- most of them have been
in role for a significant length of time.
Could we look, please, at page 5. It's not
a particularly thrilling question about version control
but it will help us understand the document. If we
could go down, please, we see here the version controls.
for this training document and, on 1 September 2021,
this version 0.1 is a draft version, and we've got
decimal point figures to 4, then 3.1 and 4.0. At what
point in this version control did this become a policy
that was implemented and not just a draft policy?
So this isn't a policy; I believe this is a training

guide.
118

do an accurate count. And I know that training has
been -- that all of the advisors have been through that
training since I joined.
Some current and former postmasters have suggested that
Branch Assurance Visits should be conducted by a body
independent of the Post Office. What would you say to
that suggestion?
I understand why they would suggest that, and I know
a lot of retailers would use third parties to do those
stocktakes. I think having a knowledge of the Horizon
system and how you update that system, once you've done
your stock count, is really important. And having the
knowledge -- we run quite a complicated business, if you
look at the number of the stamps we sell, the currency,
the foreign currency, having that background knowledge,
will, I believe, make that stock count much more
accurate than employing an outside body to come in and
do that count on our behalf. But that's my opinion
rather than fact.
Can we bring up your statement, please, page 17,
paragraph 47. This is looking to the future of branch
assurance. You say:

"Post Office is currently reviewing the
circumstances where an announced visit may not be the

most appropriate cause [sic] of action."
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Should that be "course of action"?
"Course", yes, sorry.
“The intention is for there to be a three-tier process:
(i) announced visits (as is current practice); (ii)
notified visits whereby postmasters are informed that
a visit will be taking place on a specified date ...”
Just pausing there, is the difference between
an announced visit and a notified visit that the
subpostmaster agrees the date of the visit on the former
but not the latter?
That's right, yes.
Then there's:

... unannounced visits, with a clear governance
protocol as to how and when these may be required."

If we look at paragraph 46, you say:

“In the past year there have been two unannounced
visits which took place in exceptional circumstances
with sign off from the Chief Executive Officer, Nick
Read."

At present, if there's an unannounced visit, does
that have to sanctioned by the Chief Executive?

That is under review at the moment. I can't remember if
I wrote in my witness statement that the circumstances
between these three tiers of announced, notified and

unannounced has been reviewed, and I believe there's
121

The Postmaster Account Support Team.

Sorry, Account; and do they all report to you?

They do, through their head of, the BSC reports through
a different head of; the Network Support and Resolution
reports through a different head of.

Are there systems in place to ensure that relevant
knowledge of dispute resolution issues is communicated
between those teams?

Yes, absolutely. The case management system that we use
allows a case to be created and then, as it's handled
through each of those processes, details of that, how
the -- the details of the case will be logged and, if it
can't be resolved at each initial stage, all of those
details will be passed through to the next stage, so

they will be aware of all the checks and balances that
have already happened, before they start with their bit
of the process.

I think, as I understand it, that's on one particular

case: someone is dealing here within one team, it gets
passed over to another. I more meant are there any
systems in place that the people in different teams
could spot if there were themes or trends in dispute
resolution issues?

Yes, so the branch support centre, part of their role is

to understand if there are systemic issues and
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a paper, a recommendation paper, going to the SEG at the
end of next month, if not next month. But we would
definitely seek approval if we wanted to do

an unannounced visit.

On the current proposal, from whom will you be seeking
approval to do an unannounced visit?

I think, as it stands at the moment, it would be the

Interim CEO.

In what circumstances is it envisaged that

an unannounced visit would be used?

I think where we believe there have been serious
breaches of contract and we've failed to engage the
postmaster through all of the support mechanisms that we
try and intervene with those postmasters prior to this,

and they've failed to engage in any of that and we are
concerned as to the assurance of those assets in that
branch, and that the notified would impact the outcome
of that.

I want to look now at, I think, the most substantial

topic I'll deal with, which is investigating and

resolving discrepancies. As I understand it, the

dispute resolution system, as it were, has three primary
teams involved: the Branch Support Centre; the Network
Support and Resolution Team; and the Postmaster Agent

Support Team; is that correct?
122

particularly short-term issues that have arisen. We
sometimes have IT issues with some of our third parties,
and they would immediately understand that there's

a problem and raise that with the relevant functions if,
indeed, those functions hadn't already spotted it and
informed the Branch Support Centre.

In terms of the transaction correction team, so I'll
take, if I -- there are other investigations that we do
through the Network Reconciliation Team, and we do look
at themes. So, for example, we know that 80 per cent of
our transaction corrections are issued due to cash pouch
errors. So, again, we look at the thematics and try and
understand how we stop it at source, rather than deal
with it once it's happened. A good example of that is
the issuing of note counters and the operational
excellence incentive.

If Icome back to the network support and resolution
side of things, through the monthly meetings, they also
look at the root cause of the investigations that they
have reviewed into discrepancies and understand the
cause of those, and they are reported through.
I want to look at ways into that resolution system.

Before I do, it's probably helpful just to set out what
itis. There's a Tier 1 investigation, or support,

which is handled by the Branch Support Centre; is that
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right?
That's right yes.

If Tier 1 can't deal with it or resolve the matter, it

goes to Tier 2, which is handled by Tier 2 analysts in
the Network Support and Resolution Team?

That's right. There's an intermediate step, which is

a triage. So there is a triage case and the triage will
understand if there are any initial resolutions before

it goes into the full Tier 2 investigation. So there's

an intermediate stage.

Then, on top of that, there's a Tier 3, handled by

Tier 3 analysts in the same team?

That's correct, yes.

The ways into the system: one is to dispute

a discrepancy at the end of a trading period --

That's right yes.

-- and one is to dispute a transaction correction?

That's right yes.

You say in your statement that a postmaster can call the
Branch Support Centre for assistance with a discrepancy
at any stage.

That's correct, yes.

If a postmaster rings the Branch Support Centre not at
the end of a trading period, so midway through,

regarding a discrepancy, will the Branch Support Centre
125

again because it may have been a couple of days, they
might have spotted that a transfer hasn't happened
correctly between counters.

I think what this I referring to is the formal --
the formalisation of a discrepancy only happens at
trading period end and that's when the postmasters get
the opportunity to use the Review or Dispute function.
However, if the daily or weeklies don't balance in
between that, they can ring the Branch Support Centre
and, if it's significant -- and I think just for
context -- if it's significant and the Branch Support
Centre can't identify the cause, they do have the
opportunity to push it into the Tier 2 process prior to
the trading period end.
Thank you. Can we look, please, at the screens that
a postmaster sees, and it's POL00448048. I hope you can
help us with some of these screenshots that you've
provided. So we have on the first page, it says,
"Screenshots of trading period end process", it says:

"Confirm Loss/Gain, One or more declaration totals
do not match the system derived figure.

"Press Continue to see a list of discrepancies for
confirmation."

So is this the screen that pops up after a balance

has been attempted and Horizon is saying there's
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follow the Tier 1 procedure?

They absolutely will. So I think you referred to them
earlier today. We have a number of checks and balances
that we ask postmasters to do on a daily, weekly and
monthly basis and, at any point in the processes, if

a postmaster experience -- or any of their assistants
experience a discrepancy in that balancing, they should
ring the Branch Support Centre if they're not able to
identify the cause themselves.

Can we look, please, at your statement page 52,
paragraph 113. I just want to clarify one point. You
say:

"A postmaster wishing to dispute a branch
discrepancy must await trading period end to use the
[that's ‘Review or Dispute'] function but can seek BSC
support earlier than that.”

Now, just for clarity, if a postmaster raises
a discrepancy with the BSC mid-month, so not at the end
of the trading period, they can't resolve it at Tier 1,
does that go to Tier 2 at that point or do they have to
wait for the end of the trading period?

No, if they can't resolve it, generally the Branch
Support Centre will say, "If you can wait, if you can do
a balancing period, so do a full balance, and if it

still exists, call us back", and they will do the checks
126

a discrepancy, but it doesn't say what it is yet?

Yes. So for context, my understanding -- and I haven't
worked in a branch but I have seen this process in
operation in our model office -- if you have more than
one counter, you have to do a declaration of each
counter and, if any of those counters has a discrepancy,
it moves into an account and you then move to the next
counter. Again, if that has a discrepancy, it goes

into -- I think we refer to it as the local suspense
account because it may be, if you've not done the
transfer correctly, you might have a surplus in one
counter and then a shortfall in the other, and they
match off.

If, when you come to roll your last counter and
there is still a balance in your local suspense, that is
in effect the start of that discrepancy process, where
you will then get given a choice of how you deal with
that discrepancy.

Okay, so we get this screen. On the next page, we have,
"Confirm Rollover Type":

"Do you wish to rollover into the next [trading
period] or into the next [balancing period] in this
[trading period]?"

I don't think that's relevant because it's just

whether or not you're rolling over or into a trading
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period or balancing period?
That is correct.

But that's correct. Thank you.

Yeah.

If we turn over then please, this says, "Outstanding
Discrepancies":

"You have outstanding discrepancies of £9.99.

"Press Continue to transfer this to local suspense.
and continue to rollover.

"Press Cancel to cancel the rollover."

So at this point, is what it's saying that you can
continue and go to rollover and deal with the
discrepancies or you can come out altogether and
effectively do the count again or anything like that?
That's correct, yes. This is the individual stock unit
rollover.

So that's the stock unit. We then turn the page again.
So is this the rollover, so once you've done all the
stock units, you're then asking to roll over, and it
says:

"Branch Local Suspense amount is [minus] £9.99 which
must be resolved prior to rollover of stock unit, AA.

"Press Settle Local Suspense to resolve this and
continue to rollover.

"Press Cancel to cancel the rollover."
129

button if certain that the discrepancy has been caused
by the postmaster's negligence, carelessness or error;
is that correct?

It's correct but, if I can add to that: and they're
comfortable putting their own cash in. There could be
a situation where they may know the cause but it may be
of a value that they can't put that value in all at

‘once --

Right.

-- in which case they have a choice to then settle it to
Review or Dispute and discuss the next steps for that.
Yes, I'm not going to get involved with that but look
just at the circumstances in which -- because we
wouldn't even get to that if the first bit wasn't

fulfilled --

No.

-- so there has to be that.

Yes.

Are we any further on with whether or not there will be
a warning on Horizon?

Yes, we are, in two ways. So my preference would be
that there is a pop-up box if a postmaster chooses to
select "Make good -- cash" and, at that point, they get
a reminder. There isn't currently a pop-up box at that

point in the trading period end process and that
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That's correct, yes.
So, again, at this point, the discrepancy's been
highlighted, the postmaster can go forward to the next
screen or can come out and perhaps recheck the cash or
do anything like that?
That's correct, yes.
We then get the next one, which is two buttons "Make
good -- cash" and "Review Dispute CALL BSC".

I want to start with the "Make good -- cash",
please, and if we look at your statement at page 55,
paragraph 121 --
Is that going to be replaced on screen? Yeah.
Yeah, sorry. You say:

"During preparations for Phase 7 of the Inquiry,
Post Office identified that before a postmaster elects
to settle to cash or cheque there is currently no
reminder in Horizon that the postmaster should only use
this function if certain that the issue has been caused
by the Postmaster's (or the Postmaster's assistant's)
negligence, carelessness or error. Post Office is
investigating if such a reminder could be implemented in
the Horizon system before completing settle to [cash]
process."

So, firstly, I take it from this that Post Office's

position is that a postmaster should only press the cash
130

involves Accenture and Fujitsu. So the timescales for
that are much longer. So what I've asked to happen is
in the pop-up that you saw there, that says, "You have
a balance in your local suspense, do you want to settle
‘or cancel”, we're going to expand that pop-up box to
have that message in to say, "Only do this if you're
really clear that that discrepancy was as a result of

a mistake in branch and that you are comfortable putting
cash in to balance this", and we can do that ourselves
within our IT function, so it's a lot quicker.

Just for clarity, can we go back to POL00448048. Just
if we go to page 4, please, are you saying it will be at
this stage the message is displayed?

That's correct, yes.

Will that have the other benefit of -- because
presumably at this stage, a postmaster could see the
discrepancy, decide to cancel, recount the cash and then
decide to put the money in at that point, without

going -- without actually pressing the "Make good --
cash" button?

Absolutely, that would have that impact.

So the warning will be sufficiently clear to postmasters
that they should only correct the cash if they are
certain of the circumstances, as you said?

That's correct, yes.
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That can come down. Thank you.

When people do weekly balances and those sorts of
matters, will there be equivalent warnings if
a discrepancy is ever noticed when rolling into
a balancing period or not?
No, I don't believe so because the processes that we
follow, or we ask postmasters to follow as part of their
daily cash declarations or weekly balance wouldn't
formalise a discrepancy. So we wouldn't ask them to
action it, other than to call the Branch Support Centre
if they need support to try and resolve it before
trading period end.
I want to look now, please, at the other button, which
was the "Review Dispute". Can we go to page 49 of your
statement, please, paragraph 102.

It says here that, initially, what was previously
termed "Settle Centrally”, it was, you say, 13 May 2021
changed to "Review Dispute”, and then in February 2023,
the onscreen display was changed from "Review dispute"
to "Review dispute CALL BSC". Why was the "CALL BSC"
added?
The process that we ask postmasters to follow, following
use of Review or Dispute is to call the Branch Support
Centre because the sooner we are engaged, the sooner we

can start to understand the circumstances that that
133

Support Advisor. If we turn the page, we see the job
title at the bottom "Support Advisor". Then if we turn
the page again, there's "Principal accountabilities",
which are quite generic, and it says:

"You will also have role specific bolt-on
accountabilities. These are ..."

At then over the page, the "Tier 2 Resolution
Support Advisor", bolt-on. It says:

"You will be an expert in Post Office branch
operations, particularly branch accounting processes,
and be able to use would be data sources to support
postmasters and branches to find the causes of branch
discrepancies."

If we look at the Tier 3 Analyst one, as well,
please. That's POL00448081. The Tier 3 Analyst and the
second paragraph, the "purpose of the role", we see:

"This is a specialist role that requires a high
level of understanding of Post Office Operations to
include extensive knowledge of Horizon and branch office
accounting transactions ..."

Then over the page, "Knowledge, experience and
skills". If we go down, there's:

“Excellent knowledge of Horizon, interpretation of
branch logs ...”

Why does the Tier 2 analyst's job description not
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discrepancy might have occurred.
What we were seeing was number of postmasters using
the Review or Dispute functionality and not calling the
Branch Support Centre and asking for assistance to
understand and resolve that discrepancy.
Has this had an effect; did you notice more calls
following the change?
We did, but what we've done since then -- and I don't
know whether you'll come to it later in my witness
statement -- we, following use of Review or Dispute, we
relied on the postmaster to call us, so to create the
case. And we had an outbound calling process through
‘our Postmaster Account Support Team to try and contact
that postmaster to discuss the discrepancy. What we
have now is an automatic case create. So we have a link
between the use of Review or Dispute directly into
Dynamics. So we are able to see straight away where
a postmaster's used Review or Dispute, understand if
they've already called the Branch Support Centre, and
then immediately start that outbound calling, if they
haven't. So it allows us to intervene much quicker.
Thank you. I want to look at the Network Support.
Resolution Team so dealing with Tier 2 And Tier 3
investigations. Can I look, please, at POL00039629.

I think this is a generic job description for
134

require expressly knowledge of or detailed knowledge of
Horizon?

I think the level of review that our Tier 2

investigators, the checklists that they follow, they

know where to get the data that they need to get to for
that particular bit of the checklist. So knowing in

detail the kind of inner workings of Horizon isn't as
important than the Tier 3 team, who are reviewing much
more complex cases but, also, overseeing the quality of
those -- all of those Tier 2 cases.

That said, many of our Tier 2 Support Advisors will
come from Branch Support Centre or from internal roles,
where they are taken through that Horizon training as
part of that induction.

If we look at the Tier 2 role, please, if we look at
POL00448229.

This is a Postmaster Support Policy for accounting
dispute resolution, and can we look, please, at page 15.
If we can go down to show Tier 2, please. It says:

"These investigations are fully detailed
investigations after being assigned by Triage."

The second bullet point is:

"Undertaking a check of the Horizon system
information to ascertain whether Horizon was

a contributory factor to the Discrepancy ..."
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Bearing in mind the level of expertise with Horizon
you just discussed for Tier 2 analysts, what does that
check actually involve?

It involves a number of things. So I think we talked

about the branch impacting problem process that IT own,
we have knowledge articles for all of the known branch
impacting problems and screenshots of how those branch
impacting problems might impact a branch. So one of the
first things we do is check that the discrepancy hasn't,

or the branch hasn't exhibited any of those branch
impacting problems. We look at calls into the IT

support desk as well as the Branch Support Centre to
understand if the branch has logged any issues with

their either hardware or software from a Horizon
perspective, and then we recalculate a cash flow.

So we take the opening balance from a set period and
that's the period under review for the discrepancy. We,
through HORice and Credence, the databases that hold the
Horizon transaction data, we look at all the input --
deposits and withdrawals and all of the cash flows
through that branch, and recreate almost a closing
balance, and we check that that is actually the closing
balance that Horizon is showing us.

So we try and recreate that balance to understand

whether we've got missing transactions that don't flow
137

You say "absolutely would be"; does that mean it hasn't
happened today?

It's unusual.

Are Fujitsu involved at all in the Tier 2 process?

No, they're not, other than requesting ARC data where
required.

Forgive me, sorry. I had a reference. If you could go
to page 60, please. So you're here talking about after
this Tier 2 process and you say:

"If there are no suspected issues, the investigation
will continue and that might lead to a conclusion that
Horizon was not a contributory factor in the
discrepancy. However, if the data suggests that there
could be an issue, the IT Team would do further
analysis."

Is it fair to say, then, that the team, when.
resolving this, are -- once the investigation has been
done, if they haven't found a problem or haven't
identified a problem, they are still content to rely on
the data produced by Horizon to satisfy themselves that
there has been a loss to Post Office?
I think the data that sits from Horizon in HORice and
Credence is the start of that investigation but the
investigation looks at a whole raft of other things. So

it looks at the operational strength of that branch;
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through to the bottom line from Horizon by taking that
data out and recalculating it.

You just mentioned the branch impacting problems.

I think that's -- you say it's maintained by the IT Team
within Post Office.

That's right, yes.

So is it that the IT Team draft the copy that goes into

the branch impacting problem database for your team to
read when doing investigations?

Yes, so they create knowledge articles, and they're the
Subject Matter Experts, so they will create the

knowledge articles but a member of my team will review
them to make sure they can be easily understood and they
reflect the actual issue before they're published on the
Knowledge Base that can be used by a number of different
teams.

Is there -- so there is some sort of assurance checking

on that, but is there any checks to be done at Tier 3,

so if Tier 2 can't resolve a matter, it goes to Tier 3,

and they say, "Well, actually, this is a known problem

in the branch impacting problem". Is there feedback to
the IT Team to change the way the branch impacting
problem database is worded, so that the Tier 2 team can
understand it?

Yes, there absolutely would be.
138

have they been doing daily cash checks; have they been
doing weekly balances; it looks at outstanding

transaction corrections; it may look to see if all of

the transaction acknowledgements have been processed.

So it's part of a wider review that is then used to
come to a fair outcome and discuss that with the
postmaster.

That can come down. Thank you.

Could we look, please, at POL00448072. The document
is entitled "Escalation process" on the left. On the
right, the "Process Summary" says:

"If a discrepancy has been investigated, this
process shows how it can be escalated if the
[postmaster] does not agree with the decision, or if the
loss cannot established."

Then if we go to page 2, please. It says:

"The Weekly Case Review will assess the case and
based on the success rate value will make the decision
to escalate the case to Tier 3 or clear the account."

What is the "success rate value"?
I think what that's referring to is the fact that there
is a cost, both in resource and time, to escalating and,
if we believe that, actually, as a result of that
escalation, it won't change the outcome of a case, then

we might choose to write that off, rather than take
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a postmaster through a further process that we might not
get a different outcome. So we do have the opportunity,
subject to value limits, and also the history of that
branch and, potentially, previous write-offs, just to

take that and, on that occasion, not to progress with

the discrepancy but simply write it off.

Just so I am clear, if the postmaster's disputing it and
wants to go to Tier 3, is it the case that it could be
refused to be escalated but not written off?

I don't believe -- no, I don't think that's the case.

I think if a postmaster is escalating it, we will always
review the case. We always review all cases, from

a Tier 3 perspective, to make sure that that case has
been carried out consistently and transparently. Once
we've reviewed that, we then make a decision on the next
steps for that case.

So this escalation policy is, in essence, if the
subpostmaster disputes it, it's going to be escalated?
Absolutely.

But this is: should it be written off, rather than be
escalated?

Yes, it will go for a review.

Please could we look at page 63, paragraph 140 of your
statement. You say:

"If a Postmaster disagrees with the outcome of the
141

whether that's -- the review as to whether that's going
to happen, will that be complete before a decision is
made on whether or not Post Office pursues civil
litigation in future against postmasters?
It has to be part of that process, I believe.
Part of the same process?
Yes.
Thank you. The NFSP have suggested a three-stage test
for dispute resolution. The first is to ask if the
discrepancy is caused by Horizon; I may be paraphrasing
slightly but the second is, is it a mistake by the
postmaster or assistant; and only then, finally, ask
have Post Office's assets been used in an unintended
manner?

What's your view on that as a framework for dispute
resolution?
I don't think that's dissimilar to the framework that we
‘operate in now. Part of the review process is to
understand if Horizon has contributed, then we talk to
the postmaster to understand the circumstances, and only
then, with the cooperation of the postmaster, will we
look to resolution of that discrepancy. So I don't
think we're disagreeing there at all.
I just want to briefly look at another point on types of

escalation, please. It's POL00447943. This document is
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Tier 3 review, then the postmaster can challenge the
decision by email or phone call to their ... Analyst who
will present the case to the Dispute Resolution
Committee for review ..."

At 141, you say:

"If a postmaster disagrees with the outcome of the
Dispute Resolution Committee, there is currently no
further or independent review forum (Post Office is
currently considering the use of an independent panel as
part of reviewing its model for recovering shortfalls
outlined in paragraphs 35 and 36 above)."

Has there been any progress with that review in
terms of whether there will be an independent review of
the dispute resolution process at any point?
I think the review is currently underway, so a Working
Group that has been established, and we are looking at
all of the things that need to be true, as part of that
potential recovery process. And an independent review,
or a body that has independent people, maybe postmasters
or former postmasters, whether that should be created to
review these, yes.

We're going to come to, in a moment, civil recoveries.
At the minute, your evidence is that Post Office isn't
pursuing civil proceedings to recover discrepancies from

postmasters. The inclusion of an independent review, or
142

titled "Identifying postmaster support needs", on the
left, but the "Process Summary" says:

"During an investigation the advisor may behave
[I think that should be ‘the advisor may have']
a suspicion that financial crime may have occurred.
This is the process for referring any such suspicions to
the Central Investigations Unit."

So there's a bit of a mismatch between the process
and aim and what the process describes.

What instructions are there in place to
an investigator, in circumstances where they suspect
that there is financial crime; what instructions are
there in place for what the investigator says to the
postmaster before referring it to the Central
Investigations Unit?
So I don't think -- I think the initial triage and the
data collection and analysis would provide evidence that
may be in misappropriation or financial crime. At that
point, the triage form would be completed and it would
be referred to the A&CI team. I don't think at that
point we would have had a conversation with the
postmaster, unless the postmaster has spoken to us, and
suggested that one of their colleagues may have been
involved in the discrepancy.

I see. So this is done purely to triage and then it's
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off to another department --

Absolutely.

-- who will deal with it from there. That document can
come down. Thank you.

Please could we look at page 61 of your statement,
paragraph 133. I'm just looking at the time taken for
investigations. You say that:

"The NSRT aims to complete Tier 2 investigation
within 20 working days", and go on to say that some take
longer.

If we look, please, at POL00448229, page 16. Sorry,
it's the accounting disputing resolution document again.
Page 16, please. If we go to the bottom, please. Here,
it says that the Tier 2 investigation is to aim to
investigate within ten working days.

Has this been overtaken now and it's a 20 working
day limit based on your evidence?
I think, if you look at the total time, so all of Tier 2
investigations will be quality assessed by either a team
manager or a Tier 3 analyst and I think that's part of
the process. So I think 20 days is the end-to-end
ambition for discrepancy reviews.

Can we look, please, at POL00448231. This is a paper
that you authored on 31 January 2024 for the Group

Executive report. If we look at page 3, paragraph 9,
145

process and being able to resolve where we could. These
were a mixture of discrepancies that it was right to
take more than 20 days. Because what we shouldn't do is
rush discrepancies, and come to an incorrect conclusion.
So it's right that some do take longer than 20 days but
some were also very historic.

My ambition was to -- and I asked for additional
resource -- to clear those, and we are getting through
and resolving those, as we speak.
Were you given the resource?
Yes, I was.
So now, if someone has a case come in to Tier 2, is it
likely that it will be resolved within 20 working days?
We're not at the 70 per cent, which is our ambition but
we are not far off. But I guess, back to my first
point: it's really important that we don't try and chase
a service level agreement at the detriment of that
investigation, and the outcome for the postmaster.

MR STEVENS: Sir, that's probably a good time to take our

break. We're making good progress, I don't envisage any
difficulty finishing.

SIR WYN WILLIAMS: Fine. Resumption time this afternoon,

Mr Stevens?

MR STEVENS: 'll probably get it wrong again. Shall we say

3.35. I just listened to what I heard -- or misheard,
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please, "Network Support and Resolution Case Backlog":
"The additional Network Support resource has made

good progress in reducing the number of outstanding

discrepancy cases, with period 9 ending at 588, the

lowest for 12 months. The number of cases awaiting

triage has also reduced to just over 1,200, the target

being to have no case older than the 12 week process."
Is there still an issue with the backlog of cases?

I think -- so the backlog is building again, so it's

higher than it was then. I think that's caused by

a couple of things. So the "auto case create" that

I described earlier is really important in identifying

those cases a lot quicker. So the cases are getting

through the system into that Tier 2 world a lot quicker,

and I'd like to think that postmasters are also becoming

more aware of their option to review or dispute, and

therefore using that button more, and asking for help.

I guess what comes with that is, from a resource

perspective, there's a lag and we need to understand how

we address that.

In terms of there's a backlog, what impact is that

having on the time it takes to complete investigations?

The backlog was historic discrepancies when I first

joined. So it wasn't necessarily impacting the new

discrepancies that we were pushing through the new
146

I should say, to my right. 3.35, please.

SIR WYN WILLIAMS: Fine.
MR STEVENS: Thank you.
(3.18 pm)

(A short break)

(3.35 pm)

MR STEVENS: Sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you.

MR STEVENS: 'll continue.

We'll have a look now at the postmaster accounts
support team. Could we have page 48 of your statement,
please, subparagraph (e). You say:

"The PAST [which is the Postmaster Account Support
Team], which is responsible for initiating contact with
postmasters who have escalated disputes using the
[Review or Dispute] function but have not contacted the
BSC and, following investigation by the BSC and/or NSRT,
for arranging repayment plans and write-offs where
appropriate with Postmasters.”

Just a point of clarification. Should the "and"
after "BSC" be "or"? So the team is responsible for (a)
contacting postmasters who haven't escalated disputes to
the BSC but use the Review or Dispute function, and
separately, they are also tasked with initiating contact

with people who, following an investigation, it's been
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found there's a discrepancy?
No, it's "and/or" because if, following a conversation

with the BSC, we've been able to resolve a discrepancy

at the Tier 1 stage and the postmaster then says, "Oh

yes, I understand, how do I settle?", they may then

close the case and point them in the direction of the

PAST team. Because they've resolved the discrepancy and
the postmaster then wants to understand how to resolve
that.

Okay, so "and/or" --

"And/or" is the right one, yes.

That can come down. Thank you.

Why is it that the Postmaster Account Support Team
calls the subpostmaster, if they haven't -- if the
subpostmaster themselves haven't called the BSC, rather
than the BSC or Network Support Resolution Team?

So the BSC doesn't operate an outbound call facility and
that is something that we are going to look at because

it may be that they are better placed, given that the
knowledge they have of that Tier 1 checklist to do that.
So it’s part of an ongoing review. I think where we

don't -- where a branch doesn't call following use of
Review and Dispute, it's really important that we do get
the details from the postmaster or their colleagues

about that discrepancy and, therefore, that ~ currently
149

Comment" written by myself, the "Executive Summary"
would have been the summary created from the internal
Audit Team.

Right, so this isn't your words?

That's their observations following the internal audit,
yes, and then my response is underneath in the
"Management Comment".

So you're not speaking to these? Do you not agree with
that terminology?

No, I think "hindered" is probably a harsh word.

I think the inability to contact postmasters to discuss

the circumstances that the discrepancy might have arisen
in does hinder the investigation process, and that's why
we've looked at the auto case create and starting to

talk to postmasters a lot sooner.

Can we please look at POL00448295. I don't propose to
bring up the statement on the screen but, sir, for you

it's paragraph 123(a), so page 57.

You say that:

"The PAST [the support team we were discussing] will
make an outbound call to the postmaster and send them
a letter and statement of their account."

This is in circumstances where a postmaster has
pressed the Review and Dispute button but not called the

BSC. You say, "the call script", and you exhibit them,
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the Postmaster Account Support Team, that take that role
in trying to contact the postmasters.

Could we look, please, at POL00448322. This is
described in your witness statement as a January 2023
audit report. Could we look, please, at page 3. If we

go to the bottom, this is an "Executive Summary" partway
through. We see this is authored by you. Back to the
top, please. It says:

"The increase in the use of the Review and Dispute
button by postmasters (an increase of 60% [year on
year]) is affecting the work load of the teams and is
having an impact on their ability to respond and resolve
within the desired 10-day time frame ([year to date] at
[period 8] 76% of cases are completed within 10 days)."

You then say later on:

"Whilst the Service and Support teams are adhering
to the redesigned process and control framework and
closing 93% of cases (not all of which are resolved),
achievement of their desired 10-day investigation
completion time frame and ability to recover established
losses is being hindered by PM behaviour and a lack of
business appetite to recover losses."

What do you mean by “hindered by postmaster
behaviour"?

Can I, sorry, correct something. The "Management
150

the call script being here.

When we look at this document, it says:

"This script is for outbound calls for
subpostmasters who have settled a negative discrepancy
(or several discrepancies that result in a negative
amount) at Branch Trading."

So is this call script used for subpostmasters who
haven't contacted the BSC as well? So the postmaster
presses the Review and Dispute button, they don't call
the BSC, the Postmaster Account Support Team calls them
and your statement suggests this is the script that's
used; is that correct?

That's right, yes.

Right. If we look, please, at page 2, and if we go
down, please, to "Main conversation", it says "Main
Conversation":

"We need to find out if the postmaster/person in
charge is aware of the reasons for the discrepancies.

"Do you understand the reasons for this/these
discrepancy/ies [then the person's name]?"

"1. If they need more information:

"Talk through their account entries with them,
giving as much information and detail as you can.

"2. If they understand the reason for the

discrepancy:
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"I'm glad you understand what happened here [Mr So
And So]. We just want to make sure that you were aware,
comfortable with the reason for the discrepancy and
offer our support if not.

“What will happen next is that we will send you
a letter with a statement next week so you can see it
all for yourself. Give us a call back if you have any
questions when you receive it.”

Now, do you think this is sufficient in the script
in directing people for the circumstances in which
a postmaster should be asked by Post Office to settle
a discrepancy?
I think, on review, no, and I think this needs to be
included in the work we're doing to give postmasters
greater clarity on what their options are, and how we
will support them with any discrepancy that they may
experience as part of their trading period end or
outside of that. So I think we definitely have work to
do on being clearer.
So at the minute this document isn't being reviewed for
the issues we discussed before, about making it clear
the circumstances in which Post Office thinks
a subpostmaster should accept a discrepancy, but your
evidence is that you will review this?

Absolutely, yes.
153

Office expects of postmasters?
So I can't talk about historically. I think the work
that myself and my team have done to date have probably
focused on the bigger initiatives that will improve
support to postmasters in order to try and stop
discrepancies happening. I think, as part of my
preparation for this Inquiry, looking at these letters,
the knowledge articles, the pop-up box that we talked
about earlier, it became clear to me that we don't do
a good job in talking to postmasters about the
circumstances of a discrepancy and what support we have
available and how we help them and, as part of that,
we're looking at all of these documents and what's
available via the training -- I think Ms Marshall talked
earlier -- to give better clarity. It's part of our
ongoing review and continuous improvement that we should
never stop doing.
I wanted to look at another part of this letter, which
you yourself, in your witness statement, raise.

Sir, for you -- we don't need to go there -- it's
page 81, paragraph 198, if you wish to review it. Could
we look at page 3 of the document on screen. So this
appears to be a statement of account. It says it's not
a demand for payment at the top, and it gives four

different types of discrepancy, which I think you
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And similar scripts with similar teams?
Absolutely.
In the part of your statement I went to, you also
referred to a letter, please, a letter that's sent out.
Can I look at that. It's POL00448197. So I think this
is an example of an initial letter that's sent out by
the team. Over the page, please. We have "Accepting
the discrepancy":

"If, however, you understand and accept the
discrepancy, please contact my team on ..."

It goes on from there.

Again, is this something that is being reviewed by
Post Office at the moment?
Absolutely. So discrepancy letter 1 and then second
follow-up, I have had a complete overall, they've been
signed off and I believe are currently with Accenture
because these are auto created as part of our IT
systems. So we have to go through Accenture to get them
updated and changed but, yes, I appreciate that these
aren't as clear or as helpful as they should be and the
new ones are much more helpful, give more information
around the reasons and the different categories and also
where to go for support for each of those.
I asked this question this morning: why is it that these

letters and scripts aren't explicitly clear on what Post
154

acknowledge in your witness statement, the
classification and type of discrepancy isn't explained
to a postmaster receiving this letter.

That's right, yes.

In broad terms, an outstanding discrepancy is

a discrepancy that the postmaster has previously
received a letter about?

That's right.

A new discrepancy is a brand new one that's arisen,
first letter. A previously agreed discrepancy is where
the subpostmaster has agreed that that is a discrepancy
for which they are responsible?

That's right, yes.

And a disputed discrepancy is where there's an ongoing
investigation?

Or the investigation has been completed and the
postmaster has disputed it.

We see at the bottom there's a statement total, which
says £88.13. So the total doesn't distinguish between
different types of discrepancies but am I right in
saying that, in Post Office's view, the only one that it
would seek for subpostmasters to pay back is the
previously agreed discrepancy?

That's right, yes.

Now, in your statement, you referred that this was under
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review and you, just in your evidence earlier, said this
is now with Accenture. Can you help us with how this
has been corrected in new form of the letter?

A. Absolutely. So the descriptions that you've just talked
about for each of those four categories will be written
at the side of those. So that will help explain what we
mean by each of those. The statement total will be
removed, because you're right, it shouldn't be on there.
It bears no reference to the individual discrepancy
categories and, actually, if we scroll up, so we can see
the top, we've had feedback previously from, I believe,
the NFSP, but a number of postmaster forums that, whilst
we say this is not a demand for payment, when you open
a letter and see "demand for payment" that is quite
alarming, so what we're also doing is removing that
statement from this account.

Q. So it will no longer say at all, "This is not a demand
for payment"?

A. And we'll talk what it is in the front covering letters,
which we've just talked about.

Q. So the front covering letter, will that explain that it
isn't a demand for payment?

A. It will absolutely explain that.

Q. That can come down. Thank you.

I want to move to civil recovery, please. Could we
157

data."

You go on to say that:

"The data that has been identified indicates that
Post Office was successful in obtaining civil remedies
.. against postmasters in fewer than 100 instances
since the Rule 9 start date."

What degree of confidence can you put in that figure
of fewer than 100?

A. That information was given to me -- provided to me by
the Remediation Team, so I have no accountability for
any of those existing civil remedies. So I have to take
it on the authority through which it was provided to me.

Q. Presumably, then, you're not able to speak to why the
data is in such a way that it can only be said that
fewer than 100 instances have been pursued; is that
correct?

A. That's correct.

SIR WYN WILLIAMS: I'm sorry, can you remind me what the
Rule 9 start date was, so I've got some idea of the
period?

MR STEVENS: Yes. Just so I don't get it wrong, I'll just
double check the Rule 9. It was defined as, "Since Post
Office ceased carrying out prosecutions due to concerns
with the Horizon system".

SIR WYN WILLIAMS: So approximately earliest 2013, maybe
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look at page 9 of your witness statement, paragraph 21.
You say that:

"... Post Office does not currently have a team (or
any individuals) taking civil enforcement action against
postmasters to recover shortfalls shown by Horizon and,
for the avoidance of doubt, at present no civil
enforcement action relating to any shortfalls is being
carried out against [subpostmasters].”

When was that decision taken?

A. My understanding is it was sometime around 2018/19 but
I've had to rely on that fact from other people.

Q. Could we look, please, at page 24 of your statement --
sorry I have an incorrect reference there it might be
paragraph 24, My apologies.

Paragraph 24, it's page 10. You're answering
a question about the number of civil claims pursued by
Post Office, and you say you've, I think, completed this
with assistance from people from the Post Office
Remediation Unit. You say:

"_. lunderstand owing to the incompleteness of
records, changes over the years to relevant team(s)
involved in civil enforcement activity and the fact that
many of those individuals no longer work at Post Office,
those informing me have been unable to establish and

assure the source(s), completeness and accuracy of this
158

a little bit later?

MR STEVENS: Yes.

‘SIR WYN WILLIAMS: Fine.

MR STEVENS: That can come down, thank you, for the time
being.

Who would be best placed to provide that information
then, if we wanted to --

A. My understanding is there has been a witness statement
to confirm that.

Q. Can we look, please, at the future status of civil
proceedings. POL00448362. This is described as loss
recovery update. It's exhibited to your statement. Can
you assist for what purpose this document was created?

A. This document was created by our interim CEO to talk to
SEG about our current position on loss recovery.

Q. So if we turn, please, to page 4, "Options and
Recommendation", we see there's several options listed.
At the top, "Maintain current [position]". If we go
down to 4, please:

"Seek recovery of established losses via a civil
means/deduction from remuneration, following an agreed,
defined process with an external review board that will
take final recovery decision."

The recommendation there is "Yes".

Is that still a current recommendation?
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I think the recommendation was more around proceeding to
understand what options we would have to seek recovery.
What circumstances we would use those options and, as
a result of that, we've set up a working group to review
just that. This isn't necessarily a carte blanche to go
ahead and say, "Right, seek recovery". This is signal

of an intent that we need to do more work on.

Can we look, please, at POL00460458. This is

a Strategic Executive Group report. I think earlier in

your evidence you mentioned SEG; is that --

Yes.

We see you are the author, 20 May 2024. The title is,
“Postmaster Losses Overview/Branch Discrepancies". Was
this the proposal that's led to the Working Group or was

it a paper that led to a proposal to lead to the Working
Group?

This was an earlier paper. So the discussion about the
extent of losses on our profit and loss account and how
we addressed those losses has been ongoing since

I joined, and this was a paper that I wrote to move that
understanding and that discussion on. It wasn't
necessarily what drove the conversation that that paper
was written for at a later SEG.

Can we go down, please, to page 2, and down to

paragraph 11, please. It says:
161

it zoomed out, please, if we can. It says:

"Do not start recovery until clarified Horizon data
used in discrepancy/review process is robust."

Could you just expand on what you meant by that?
I can't remember the timing of it and whether it was
before or after the letter but, obviously, as we've seen
the Inquiry progress, there was -- and based on
conversations that were ongoing with certain criminal
proceedings that I think we've talked about. As one of
the options being civil recovery, I think we'd need to
assure ourselves and anybody else that was involved in
that as to the reliability of the data in Horizon. So
it wasn't just an internal assurance; it was to be able
to go to external bodies and go, "No, we can rely on
that data, and should”.

When it says, "Clarified Horizon data used in
discrepancy/review process if robust", what sort of
assurance would Post Office need on that before it
commences civil recovery in future or, indeed, any
non-voluntary recovery?

In my opinion, and I know this has been looked at, we
need to make sure we've got external expert assurance as
to that data. Given where we've been, and all of the
conversations we've had as part of the Inquiry, I think

it would be important to get some external expert
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"The table below summarises the key drivers of loss,
what additional activity is required to improve
prevention of the loss and also recommendations on
whether [Post Office] should start recovery activity on
any of these losses."

We see "Loss Driver", at they top, "Current
[postmaster] discrepancies post-April '21". It says,
"Recommendations for prevention", and then we have
"Recommendations for recovery".

Is that referring to civil recovery as in issuing
civil proceedings?

Not necessarily, no. It was that we have, I guess,

a number of options to seek recovery from postmasters.
So, again, that was looking at those options by which we
would recover other than voluntarily.

So that would include attachment of earnings, would it?
Yes, an auto deduction from rem, if that was one of the
options that we choose to --

So it's recovery but not necessarily civil proceedings
but some form of non-voluntary recovery from the
postmaster?

Absolutely, and having options to do that.

If we can zoom in on that recommendation for recovery
part. It says, the first bullet point, "Do not start

recovery" -- that doesn't assist, I don't think. Leave
162

assurance for everyone.

Could we look, please, at POL00448520. This describes
a SEG tactical meeting on 17 July 2024. Does that have
any special meaning, that it's a tactical meaning?

I think it's just the different types of Strategic

Executive Group meeting. I think they had strategic
‘ones and tactical ones, but ...

So the paper we just saw before, that was dated May
2024. Was that too old to be considered at this meeting
in 17 July 2024?

I can't recall but this would have been an update on

that position with a view to -- I think that was the --

the May paper was quite a rounded paper, talking about
discrepancies, how they arise, trying to get all of SEG

to a level of understanding, so that they are making
more informed decisions when we come with proposals and
recommendations, and I think, from recollection,
although I can't recall the paper that went with this,

that would have been a more detailed next steps versus
a Teach-In session.

We see you're not in the "present" line at the very top
but, if we just scroll down slightly, when it comes to
branch grapes, you join the meeting and, if we go
please -- we don't need to read all of it but, if we go

to page 2, there's a discussion about recovering
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discrepancies and, towards the bottom of the page, it
says:

"SEG discussed a number of other alternatives,
including:

"Some form of ‘losses' pool, to which all
postmasters contributed and from which repayments would
be made."

Could you just describe what that proposal was?
So that was something suggested by one of our Legal
Team, and --
Do you know who in the Legal team?
Neil Wallace(?). So he -- I think his opinion -- and
again, this is something that we need to look at all
options -- was to, if we had a budget for losses and
that budget wasn't achieved during any one year, then
however much we were short or the benefit we created
from not spending all that money on losses would go back
to postmasters to try to encourage postmasters to,
I guess, run operationally kind of robust branches and
seek support for discrepancies when they first saw them.
And, as a result of that, our cost in our profit and
loss account would be less, which means, ultimately, we
would be able to give more remuneration to all our
postmasters.

This reads like the proposal is to say postmasters
165

it's Post Office's position that it does not recover

losses, except where a postmaster agrees the reasons for

the shortfall, and now witnesses have said that's Post

Office's position; do you accept that?

Absolutely, yes.

At paragraph 15 of your statement you set out

12 postmaster policies, I think you call them a suite of

policies, which you say set out the guidelines of how

postmasters are supported, and their assistance across

number of key areas by Post Office --

That's right.

-- and it sets out minimum operating standards for Post

Office. Are you familiar with these policies, Ms Park?

I'm familiar with all of the policies in general but

more familiar with the ones that sit in my area.

Okay, could we then go very quickly to a section of the

policy that Mr Stein took Mr Read to last week, and it's

POL00448000. This is the Postmaster Account Support

Policy and it's page 8 of 25, section 2.5 "The risk".

It's just coming up on the page now. Page 8, please.

We can see the second paragraph there, and it says:
"Post Office can recover losses from a postmaster

when such losses are caused through negligence,

carelessness or error and Post Office has carried out

a reasonable and fair investigation, as set out in the
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contribute to a general pool to make up for losses or
discrepancies in Horizon.

A. That's not my understanding but, again, this will form
part of the Working Group conversations and look at what
options and alternatives we have.

Q. Sois this losses pool a matter that is actually being
still -- sorry, start again. Is the losses pool
suggestion under active consideration still?

A. I couldn't say for certain because I've not been
involved in those working groups over the last month or
so, so I don't know.

Q._ In summary terms, can you assist at all where the
Working Group has got to with next steps, in terms of
civil recoveries?

A. Ican't, no, sorry. I've not been involved. I will
pick up my involvement again over the next couple of
weeks.

MR STEVENS: Sir, that's all the questions I have. I will
look around the room.

There's questions from Howe+Co and NFSP.
‘SIR WYN WILLIAMS: Right.
Questioned by MR JACOBS
MR JACOBS: Hello, Ms Park, I have some questions for you.
Simon Oldnall gave evidence yesterday and Tracy

Marshall this afternoon gave evidence and confirmed that
166

Postmaster Accounting Dispute Resolution Policy ..."

Just pausing there, Mr Stevens took you to that.
policy earlier on this afternoon, just before 3.00 and
this is the Tier 2 investigation and the Tier 3
investigation?

A. That's the fair -- reasonable and fair investigation
that that piece refers to.

Q._ In Tier 2, one of nine actions that can be taken within
an investigation is to undertake a check on the Horizon
system information to ascertain whether Horizon was
a contributory factor in the discrepancy; is that right?

A. That's right, yes.

Q. Tier 3 sets out five contractual thresholds, and one of
those, one of those five, is that the Horizon system
information has been checked to ascertain whether the
Horizon system was a contributory factor to the
discrepancy. So part of the investigation but there is
an investigation into a shortfall?

A. That's correct, yes.

Q. So going back to the text of the policy, so Post Office
can recover the losses, carry out a reasonable
investigation, as set out in the other policy, the
resolution policy, as to the cause and reason for the
loss, and going over the page:

"... whether it was properly attributed to the
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postmaster. Postmasters are also responsible for losses
caused by their assistants.”
So we can take that off the screen now. Thank you.
Do you accept, in principle, there is scope within
the policy, this policy, for recovery based on Horizon
shortfall?
I think that, if we're talking about a shortfall, it
will be linked -- the way a shortfall is identified is
by doing a full count of cash and cash equivalents in
a branch and comparing that to Horizon data. So if we
are -- what Horizon expects the value to be in that
branch. So I think if we're talking about shortfalls,
they will all be linked back to Horizon because that's
the operating system that we check back to.
Okay. So you do accept, I think, is your answer, that
there can be recovery based on a Horizon shortfall under
the policy?
Yes.
The concern that our clients have -- and we represent
some current subpostmasters, as well as many, many
subpostmasters who were affected by the scandal and
their concern is -- and we put this to Ms Marshall
earlier -- that the Post Office's policies do not
reflect Post Office's expressed intent and the evidence

that the witnesses have given in this Inquiry. If it's
169

the door open and goes out for the day, perhaps that's
different.

But the position that the Post Office has accepted
in this Inquiry is that post offices do not recover
shortfalls unless the postmaster agrees with the reasons
for the shortfalls. That's not what is said in the
policy. Do you accept that the policy should reflect
Post Office's position, the position I've just
articulated -- and you can say something about other
extraneous factors, like leaving safe doors open and
going out for the day, but you're not being clear in the
policy, are you?
I think we could be more overt with our current position
in the policy and in some of the communications that we
have with postmasters during the investigation process.
You're right.
Our position is that the policy should be reviewed; do
you accept that it should be reviewed --
Absolutely ~
-- and changed?
-- and we will take that, definitely.
Will subpostmasters be entitled to comment on the
Postmaster Account Support Policy and Accounting Dispute
Resolution Policies before they're finalised?

I think we referred to that -- Ms Marshall referred to
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the position that Post Office does not recover Horizon
shortfall losses, except for when a subpostmaster agrees
to repay those losses and starts to repay, why doesn't
the policy say that? The policy seems to say something
completely different and opposite.
I think my understanding is that the policies, as well
as the contract, should include the opportunity, such
that, if the circumstances are shown that the shortfall
is a result of negligence, carelessness or error and we
do have situations where, actually, Horizon data isn't
involved, where we've spoken to the postmaster and, for
example, a safe has been left open, or they haven't been
doing regular cash decs and couldn't identify -- and
haven't been running their branches in an operationally,
I guess, sound way, where cash has fallen into the bin.
So we should have that opportunity in our policies
and contracts such that, when we're confident that all
of the support is in place and we're doing all of the
things we should be doing -- we're doing the right
training the right interventions -- we should have that
opportunity and, therefore, I do believe it's right to
have it in there, but I understand why, at the moment,
we're not necessarily fulfilling that opportunity to its
full extent.

Of course. Yes, if someone leaves a safe open or leaves
170

that earlier. So absolutely.

Super. I've now got one other line of questioning for
you. We asked Ms Marshall this morning about

Mr Patterson's letter to Mr Read, dated 17 May 2024.
Are you familiar with that letter?

lam, yes.

It's well known to the Inquiry now. It's worth saying
that it says in the second paragraph:

"To be clear, Fujitsu will not support the Post
Office to act against subpostmasters. We will not
provide support for any enforcement actions taken by
Post Office against subpostmasters, whether civil,
criminal, for alleged shortfalls, fraud or false
accounting.”

Now, I should say at this stage, before I ask you
a question, that I have looked at the fifth corporate
statement of Mr Patterson, and the reference -- we don't
need to call it up for the Inquiry -- is WITNO6650500.

At paragraph 66 and 67 of that statement, Mr Patterson
states that Fujitsu does continue, when contractually
bound to do so, to provide ARQ data but Fujitsu has
sought to put in place processes to ensure that any ARQ
data it provides is not used in enforcement action
against postmasters, and one of the things that Fujitsu

is seeking to do is require Post Office to confirm, when
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requesting ARQ data, whether it is to be used for
redress of subpostmasters or investigation into or
actions against a postmaster or member of a branch
staff.

So with that caveat, it's right, isn't it, that
Fujitsu are not going to cooperate by assisting or do
not intend to cooperate to assist Post Office in taking
any sort of enforcement action against postmasters; do
you accept that?

A. I accept that that's the letter, but --

‘SIR WYN WILLIAMS: Well --

MR JACOBS: Sir, I see that you're --

SIR WYN WILLIAMS: The letter speaks for itself. I think
this witness is incapable of giving an answer other
than, "The letter speaks for itself."

MR JACOBS: Indeed. I'll move on. I just wanted to clarify
that point with her.

My question to you is: how can Post Office fully
investigate without this assistance, without this data?

A. So, I -- the data, as it exists at the moment sits in
HORice and Credence, and that's the data we used to
investigate. I find it quite alarming that the provider
of an EPOS operating system is not assured of the
reliability of the data that is in that system. But we

don't need Fujitsu's cooperation because the data exists
173

conversation.
MR JACOBS: Thank you. I'm just going to ask if I have any
more questions for you. No, I haven't.

That's all I have, sir.

THE WITNESS: Thank you.

SIR WYN WILLIAMS: Yes. Ms Watt.
Questioned by MS WATT

MS WATT: Thank you, sir.

Good afternoon, Ms Park, we have this perennial
issue of just being able to see each other. Thank you,
it's just the location of the desks.

I just want to ask you a couple of questions to
check in with some of the matters you raise in your
witness statement.

I'm asking questions on behalf of the NFSP. Sorry,
I should have said that at the beginning.

I'm not going to call up these documents; I'm just
going to make some general summaries and ask some
questions. At paragraph 17 of your witness statement
you say, in relation to the 12 postmaster policies:

"Prior to submission to ARC [that's the Audit and

Risk Committee] each policy is reviewed and agreed with

the National Federation of SubPostmasters, NFSP, with
feedback also obtained from the Postmaster Experience

Director, who is a serving postmaster working within the
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in our systems and that we -- we use that data as part

of the investigation.

My final question for you then is that Fujitsu doesn't
consider that the Horizon system should be used to
evidence shortfalls. Do you accept that that is right:

the Horizon system should not be used to support
recovery action against subpostmasters?

I don't accept that but I understand we should seek to

do some external assurance on that and I find it quite
confusing that that data could be used for remediation
but not to support a review of how a discrepancy might
have arisen.

Well, I put this to Ms Marshall. The confusion

shouldn't really be confusing, it's because of the great
scandal that's taken place, isn't it? It's because of
what's happened in the past and how Post Office have
used Horizon data to oppress subpostmasters; that's why
things have changed.

And things have changed, so my opinion is that how we
support and review discrepancies with postmasters now is
not the same as what we -- how we did in the past, which
was awtul. So I don't see the data being called into
question, because of the processes that we follow, to
assure ourselves but I do understand. I think we get --

that external assurance would help everyone in this
174

Post Office. One of Post Office's Postmaster
Non-Executive Directors will also approve new policies
as a core member of ARC."

In his witness statement -- and I'm not calling it
up but for the Inquiry's record, WITN003700100 -- Calum
Greenhow of the NFSP says, at paragraph 326 that the
NFSP raised concerns about the audit reporting script,
suggested an alternative script. He also says that the
NFSP suggested a checklist for the postmaster and the
officer in charge to follow, given the potential
stressful situation that may be being dealt with at the
time but he says these suggestions were rejected by the
Post Office.

So the first question I wanted to ask you was: would
you agree that the policies you've been referring to
are, therefore, reviewed by the NFSP but are not always
agreed in full by them and that changes proposed by the
NFSP are not always taken on board?
I couldn't comment on that because that's not part of
the process that I'm then accountable for.
Okay. It might be that the following question you can't
answer either, and that's fine. Just say if you can't.

But in that paragraph 17 of your witness statement,
where you are setting all of this out, you list three

potential sources of postmaster feedback on Post Office
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policies: that that's the Postmaster Experience
Director; the Postmaster Non-Executive Director; and the
NFSP. So if I think about an example, you've got three
different sources of feedback and approval. Let's say,
for example, the Postmaster Experience Director agrees
with the policy that's being brought forward but the
NFSP and the Postmaster Non-Executive Directors don't
agree in full with it. Is it the case that the
agreement of the Postmaster Experience Director allows
the Post Office to say they've received postmaster
feedback and approved the policy?

A. Again, because I'm not accountable for that review
process, I'm sorry, I can't comment.

Q. Okay. I think, just picking up on that, this may also
not be -- you can tell me if it's not -- but would you
agree that what I've just described actually suggests
that the Post Office effectively has a number of bites
at the cherry to get the answer it needs on approval?

A. Again, I can't comment.

Q. Okay. At paragraph 80 and 81 of your witness statement
you discuss the Operational Excellence Project; is that
something you are familiar with?

A. That's something I'm familiar with, yes.

Q. Okay. You say the objective of the policy is to review

and improve the operational support provided to
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Q. -- so perhaps you might be able to comment on my
follow-up questions.
Would you agree that it is not sufficient,
ie 5 per cent of this remuneration is not sufficient,
when postmasters across the UK report in the NFSP
surveys and the postmaster surveys, or the Post Office
surveys and the YouGov survey for this Inquiry, that low
remuneration is the biggest issue they face, and that
5 per cent of not very much is, in fact, not very much?
A. I understand the feedback about low remuneration,
absolutely. With relation to the Operational Excellence
Incentive, my understanding was that that 5 per cent
wasn't intended to cover the full costs of all of those
back office processes, my understanding is there's
an element of the admin process fed into each of the
individual rem payments for the products, and this was
simply a way to encourage postmasters to complete the
back office processes that we asked them to do as part
of the contract in running their branches. But
I understand the feedback about the rem in general, yes.
MS WATT: Thank you. Those are my questions.
‘SIR WYN WILLIAMS: Thank you, Ms Watt.
Is that it, Mr Stevens?
MR STEVENS: Yes, sir. That is it.

SIR WYN WILLIAMS: Well, then, thank you very much, Ms Park,

179

ONOaARWN

©

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12
13
14
15
16
17
18
19
20
21
22
23
24
25

©NOORON

©

"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

16 October 2024

postmasters during each stage of their journey with the
Post Office.

A. Absolutely.

Q. You have a number of subparagraphs in that, but
subparagraph 81(d) is about operational excellence
incentive to encourage improvements in back office
processes in sub post offices and you talk about
a financial incentive for the subpostmaster meeting
targets on, for example, daily cash declarations and
completing monthly trading within a certain period.
That financial incentive is a payment of 5 per cent of
the postmaster's total variable remuneration for the
month.

Now, I wanted to ask if you were aware that the NFSP
did not agree that 5 per cent of a postmaster's total
variable remuneration was sufficient?

A. So whilst I have responsibility for the overall
Operational Excellence Programme, postmaster
remuneration isn't part of my accountabilities and that
sits with another member of the retail leadership team?

Q. So you're not aware specifically of the NFSP --

(The witness shook her head)

Q. However, I think you said earlier you were
an accountant, if that's correct --

A. Yes.

>

178

for making a witness statement on behalf of the Post
Office which is very detailed, and thank you very much
for expanding upon it in your oral evidence this
afternoon. I'm grateful to you.

THE WITNESS: Thank you, sir.

SIR WYN WILLIAMS: Right. We'll resume again at 10.00
tomorrow morning.

MR STEVENS: Yes, sir. Thank you.

(4.28 pm)

(The hearing adjourned until 10.00 am the following day)

180

(45) Pages 177 - 180
The Post Office Horizon IT Inquiry 16 October 2024

INDEX
TRACY LOUISE MARSHALL (affirmed) ....

Questioned by MR STEVENS .. 2
Questioned by MS PAGE ... 80
Questioned by MR JACOBS 98
Questioned by SIR WYN WILLIAMS ..... 103
MELANIE JANE PARK (affirmed) .... 108
Questioned by MR STEVENS . 108
Questioned by MR JACOBS ..... 166
Questioned by MS WATT .. 175

181

(46) Pages 181 - 181
MR JACOBS: [8]
97/24 98/2 103/1
103/3 166/23 173/12
173/16 175/2

MR STEVENS: [41]
113 115 119 2/14 2/22
2/25 24/13 38/11
38/15 38/19 38/21
39/5 59/23 73/12
78/15 78/18 80/6
80/11 96/18 96/20
96/22 97/16 97/19
107/25 108/4 108/9
108/11 108/15 109/22
109/25 147/19 147/24
148/3 148/7 148/9
159/21 160/2 160/4
166/18 179/24 180/8
MS PAGE: [9] 80/16
89/21 90/1 93/3 93/12
93/17 93/25 96/16
97/15

MS WATT: [2] 175/8
179/21

SIR WYN WILLIAMS:
[70] 1/4 1/7 1/11
2/15 2/23 24/6 24/12
38/14 38/20 38/25
55/20 56/14 57/9
57/18 57/25 58/13
59/3 59/21 73/2 73/9
78/17 80/10 80/14
89/16 89/23 92/21
93/9 93/13 93/21
96/17 96/19 96/21
97/23 103/5 103/11
103/19 103/23 104/2
104/12 104/24 105/12
105/17 105/23 106/1
106/6 106/10 106/16
106/22 107/5 107/11
107/15 107/19 108/3
108/5 108/10 108/12
109/24 147/22 148/2
148/8 159/18 159/25
160/3 166/21 173/11
173/13 175/6 179/22
179/25 180/6

THE WITNESS: [4]
103/2 107/18 175/5
180/5

47 [2] 62/2 62/3
"47/'18 [1] 62/2

"48 [3] 8/25 62/2
62/12

"24 [1] 162/7
‘audits' [1] 113/15
‘Bates [1] 97/6

"Do [1] 152/19
‘excellent’ [1] 114/25

"good' [1] 115/1
I'm [4] 153/1
‘losses’ [1] 165/5
‘mismatch’ [1] 14/21
"Review [1] 126/15
‘the [1] 144/4

‘very [1] 115/1
"What [1] 153/5

Oo.
0.1 [4] 118/20

1
1 September [1]
118/19

1,200 [1] 146/6
1,900 [1] 57/4

1.12 [1] 108/6

10 [6] 3/12 54/24
54/25 78/21 150/14
158/15

10 May [1] 60/5
10,000 [1] 73/24
10-day [2] 150/13
150/19

10.00 [2] 180/6
180/10

10.03 [1] 1/2

100 [4] 52/21 159/5
159/8 159/15

104 [1] 110/4

102 [4] 133/15

107 [1] 29/18

108 [1] 4/7

44 [2] 84/2 161/25
11 November [1]
81/21

11.05 [1] 38/16
11.15 [2] 38/15 38/25
11.25 [4] 38/18

111 [1] 3/16

413 [4] 126/11

114 [1] 3/14

12 [14] 3/18 24/16
32/21 33/19 34/8
34/10 35/4 114/25
115/22 116/12 118/11
118/12 146/7 175/20
12 June [1] 30/16
12 months [1] 146/5
12 postmaster [1]
167/7

120 [1] 20/17

124 [1] 130/11

123 [4] 151/18

13 [4] 103/23 104/6
105/1 105/6

13 May [4] 133/17
133 [1] 145/6

14 [4] 76/17 113/13
114/23 114/24

140 [2] 62/12 141/23
144 [1] 142/5

143 [2] 62/6 103/6

15 [4] 21/1 23/3
136/18 167/6
15-minute [1] 38/22
150 [4] 67/10

154 [1] 67/25

155 [1] 68/9

16 [3] 54/1 145/11
145/13

146 October 2024 [1]
1/1

162 [1] 109/4

163 [1] 74/14

17 [6] 36/2 69/22
110/24 120/20 175/19!
176/23

17 July [2] 164/3
164/10

47 May [2] 101/17
172/4

176 [1] 70/23

477 [4] 71/21

18 [8] 62/7 62/17
62/25 73/14 96/25
106/3 106/6 118/11
18 months [1] 6/8
419 [5] 62/7 106/23
106/24 106/25 158/10}
198 [1] 155/21

1981 [1] 68/6

199 [4] 5/6

1994 [1] 23/9

1994 [1] 23/9

1997 [2] 111/4 111/6
1998 [4] 6/5

2 July [1] 30/16

2 years [1] 54/6
2,500 [1] 7/22

2.00 [1] 107/25

2.40 [3] 108/1 108/2
108/8

2.5 [4] 167/19

20 [10] 31/16 46/3
75/2 114/14 145/9
145/16 145/21 147/3
147/5 147/13

20 May [1] 161/12
20,000 [1] 73/25
200 [1] 59/12

2000 [1] 68/14
2003 [1] 68/11

2005 [1] 68/2

2006 [1] 68/7

2007 [4] 7/9 7/19
7/20 8/6

2010 [8] 1/14 2/1 8/6
8/13 9/23 10/10 15/24
18/19

2010/11 [1] 84/2
2010/15 [1] 21/1
2011 [6] 1/14 15/25
16/3 17/19 68/12
87/17

2012 [7] 8/24 8/25
9/23 18/20 68/4 68/14)
91/22

2013 [2] 2/2 159/25
2015 [4] 90/2 91/7
91/20 91/22

2017 [6] 8/25 9/7 9/8
61/22 62/12 62/19
2017/18 [3] 62/7
62/17 62/25

2018/19 [2] 62/7
158/10

2019 [4] 64/2 92/5
95/2 96/1

2019/2020 [1] 63/24
2020 [8] 30/2 31/24
32/12 32/14 32/25
63/24 116/10 116/15
2021 [3] 79/11
118/19 133/17
2021/22 [4] 103/16
105/13 105/20 105/23}
2022 [2] 110/24
119/4

2023 [5] 32/4 46/10
60/5 133/18 150/4
2023/24 [2] 105/20
106/18

2024 [19] 1/1 3/6
20/9 30/16 30/16 36/6
52/22 53/1 53/2
101/17 109/1 114/22
115/2 145/24 161/12
164/3 164/9 164/10
172/4

2024/25 [1] 64/15

21 [4] 158/1

22 [5] 42/7 103/16
105/13 105/20 105/23}
22 August [2] 3/6
108/25

24 [6] 105/20 106/18
111/6 158/12 158/14
158/15

24 June [1] 64/15
25 [5] 64/15 103/16
103/19 105/1 167/19
25 years/26 years [1]
6/6

28 February [2]
15/24 17/19

28 May [1] 20/9

29 July [1] 30/2

3
3-5 years [1] 54/7
3.00 [1] 168/3

3.1 [1] 118/21

3.18 [1] 148/4

3.35 [3] 147/25 148/1
148/6

30 [2] 3/18 24/16

34 [2] 32/22 32/23
31 January [1]

145/24

32 [2] 32/22 116/8
326 [1] 176/6

34 [1] 114/22

35 [4] 142/11

35 per cent [1]
117/19

36 [4] 36/3 37/23
50/4 142/11

38 [4] 113/13

4

4.0 [4] 118/21
4.11 [1] 75/2
4.28 [1] 180/9
4.6 [1] 98/12
42 [4] 52/20
45 [1] 29/17
46 [1] 121/15
47 [4] 4/7 42/8 57/20
120/21

48 [1] 148/11
49 [4] 133/14

5

5 December [1]
10/10

5 per cent [4] 178/11
178/15 179/9 179/12
50 [2] 58/15 111/22
52 [1] 126/10

53 [1] 114/14

55 [1] 130/10

57 [1] 151/18

588 [1] 146/4

6

60 [5] 4/15 62/6
118/2 139/8 150/10
61 [3] 63/4 103/12
145/5

63 [1] 141/23

64 [1] 67/24

66 [1] 172/19

67 [1] 172/19

7 December [1]
15/24

70 per cent [1]
147/14

74 [4] 109/5
72 [1] 70/22
76 [1] 150/14
77 [1] 44/17
78 [1] 5/3

8

80 [1] 177/20

80 per cent [1]
124/10

81 [3] 155/21 177/20
178/5

83 [4] 50/5

(47) MR JACOBS: - 83
8

86/18 [1] 96/25
88.13 [1] 156/19

9

9.99 [2] 129/7 129/21
90 [1] 55/2
93 [1] 150/18

A

AA [1] 129/22
abbreviation [1] 4/4
ability [5] 19/1 19/3
24/1 150/12 150/20
able [16] 19/23 32/6
34/1 44/5 51/23 64/4
126/8 134/17 135/11
147/1 149/3 159/13
163/13 165/23 175/10)
179/1
about [116] 1/24 2/4
2/6 2/8 2/11 2/13 3/19)
9/16 9/17 13/4 13/15
16/15 17/6 18/1 19/24}
21/7 21/15 27/9 36/11
36/24 38/25 40/13
44/23 47/6 51/2 55/21
56/15 59/16 59/25
61/18 64/11 65/5
68/13 68/23 70/10
72/23 73/2 73/24
76/10 76/20 78/5 79/3
79/21 80/1 80/23
81/20 83/4 83/9 83/22
84/17 85/11 85/22
85/24 87/4 88/25 89/1
89/12 89/20 89/21
89/24 90/17 90/18
91/8 91/15 91/19
92/19 94/14 94/24
95/2 95/4 95/5 95/6
95/9 95/10 95/17
95/18 97/1 100/7
100/16 102/2 105/12
105/19 110/13 111/22)
114/15 115/3 115/24
117/6 117/19 118/16
137/5 139/8 149/25
153/21 155/2 155/9
155/10 156/7 157/5
157/20 158/16 160/15}
161/17 163/9 164/13
164/25 169/7 169/12
171/9 172/3 176/7
177/3 178/5 178/7
179/10 179/20
above [2] 82/17
142/11
absolutely [48] 15/19)
27/16 27/19 33/9
40/13 44/13 45/25
46/18 48/2 49/8 49/14
55/9 61/2 61/4 63/6

69/24 70/6 70/17
TANT 77/24 78/2 81/4
85/12 85/21 86/13
87/8 96/3 97/8 100/6
107/16 123/9 126/2
132/21 138/25 139/1
141/19 145/2 153/25
154/2 154/14 157/4
157/23 162/22 167/5
171/19 172/1 178/3
179/11
Accenture [4] 132/1
154/16 154/18 157/2
accept [19] 19/6 19/9
49/5 85/11 85/13 91/8
98/22 102/10 153/23
154/9 167/4 169/4
169/15 171/7 171/18
173/9 173/10 174/5
174/8
accepted [1] 171/3
Accepting [1] 154/7
access [20] 14/1
14/7 14/8 14/10 14/14
15/2 19/2 19/8 19/11
19/13 27/10 34/10
34/12 34/17 41/21
80/23 82/12 83/1 87/7,
87/12
accessed [1] 30/9
account [24] 12/3
12/8 33/4 48/13 74/24
88/4 123/1 123/2
128/7 128/10 134/13
140/19 148/13 149/13)
150/1 151/22 152/10
152/22 155/23 157/16)
161/18 165/22 167/18)
171/23
accountabilities [6]
9/11 10/3 13/11 135/3
135/6 178/19
accountability [4]
11/1 11/10 61/13
159/10
accountable [6]
33/23 39/7 40/18
60/22 176/20 177/12
accountant [2] 111/4
178/24
accounting [14]
16/16 16/24 33/7
44/24 45/2 101/22
111/8 135/10 135/20
136/17 145/12 168/1
171/23 172/14
accounts [6] 19/2
74/18 87/7 114/2
114/4 148/10
accredited [1] 17/4
accumulation [1]
66/18
accuracy [2] 82/20
158/25

accurate [4] 18/11
63/5 120/1 120/17
accusation [1] 82/14
achieved [1] 165/15
achievement [1]
150/19
acknowledge [1]
156/1
acknowledgements
[1] 140/4
across [17] 7/24
33/20 46/22 49/24
54/25 57/2 58/12
72/14 72/20 92/18
95/1 95/17 102/19
117/12 117/21 167/9
179/5
act [5] 31/19 101/19
110/16 115/20 172/10
acted [3] 16/18 75/20
75/21
acting [1] 68/3
action [9] 78/11
120/25 121/1 133/10
158/4 158/7 172/23
173/8 174/7
actions [7] 35/24
101/20 105/5 117/12
168/8 172/11 173/3
active [1] 166/8
activities [1] 105/5
activity [7] 36/17
37/3 84/21 95/6
158/22 162/2 162/4
actual [3] 96/23
119/5 138/14
actually [26] 12/3
35/3 46/5 51/7 56/3
71/19 73/22 75/2
89/18 90/8 92/1 92/22
103/12 105/13 115/7
115/15 119/22 132/19}
137/3 137/22 138/20
140/23 157/10 166/6
170/10 177/16
adamant [1] 16/17
add [3] 45/15 74/8
131/4
added [6] 28/7 28/9
29/3 32/14 69/6
133/21
addition [2] 43/20
82/17
additional [5] 62/19
119/19 146/2 147/7
162/2
address [4] 20/21
31/10 71/8 146/20
addressed [2] 5/20
161/19
addressee [1] 12/22
addresses [1] 10/15
adds [1] 28/15
adhered [1] 91/14

adhering [2] 100/15
150/16
adjourned [1] 180/10
Adjournment [1]
108/7
adjustments [1] 60/1
admin [1] 179/15
administrative [1]
6/18
admission [1] 56/15
advance [1] 60/16
advice [7] 11/13
11/14 33/9 33/17
40/21 76/9 76/13
advised [2] 30/6
118/10
Adviser [6] 68/3 68/5
68/7 68/11 70/1 70/24,
advisers [14] 11/1
16/7 67/5 67/6 67/10
67/12 68/1 68/19
68/25 70/4 74/16
75/12 75/16 107/4
advisor [7] 114/16
118/1 135/1 135/2
135/8 144/3 144/4
advisors [3] 119/19
120/2 136/11
advocate [1] 59/18
affected [1] 169/21
affecting [2] 84/17
150/11
affirmed [4] 1/10
108/13 181/2 181/12
afraid [8] 23/18 25/24)
26/14 28/4 30/24
31/13 50/13 61/12
after [28] 4/1 4/12
6/20 6/25 20/23 28/19)
32/10 42/18 53/5 53/6)
53/7 53/9 54/18 54/19
54/19 56/6 56/7 61/7
81/21 92/16 104/16
106/7 119/18 127/24
136/21 139/8 148/21
163/6
afternoon [6] 108/9
147/22 166/25 168/3
175/9 180/4
afterwards [2] 13/22
94/24
again [37] 9/4 15/11
17/8 26/20 27/9 29/3
47/22 48/23 59/17
59/22 69/12 73/1
77/21 77/23 78/2 92/5)
112/5 117/8 124/12
127/1 128/8 129/14
129/17 130/2 135/3
145/12 146/9 147/24
154/12 162/14 165/13}
166/3 166/7 166/16
177/12 177/19 180/6
against [15] 2/17

34/6 43/5 101/19
101/20 143/4 158/4
158/8 159/5 172/10
172/12 172/24 173/3
173/8 174/7
Agent [1] 122/24
Agents [3] 8/14 9/21
16/22
ago [3] 1/22 21/17
54/17
agree [16] 2/14 28/5
29/1 31/24 42/14
43/13 99/11 112/16
116/22 140/14 151/8
176/15 177/8 177/16
178/15 179/3
agreed [8] 11/18
48/11 156/10 156/11
156/23 160/21 175/22)
176/17
agreement [4] 35/8
60/11 147/17 177/9
agrees [10] 65/20
98/5 99/2 99/8 113/19I
121/9 167/2 170/2
1711/5 177/5
Ah [1] 96/20
ahead [4] 79/5 80/3
80/5 161/6
Aid [1] 42/12
Aids [1] 40/25
aim [2] 144/9 145/14
aimed [3] 52/14
52/19 62/24
aims [1] 145/8
alarming [2] 157/15
173/22
albeit [1] 95/7
aligned [1] 48/19
all [95] 7/14 7/18 8/4
16/11 17/5 25/19
26/18 26/20 27/9
27/20 31/18 33/20
38/14 40/20 46/25
47/8 47/15 49/5 49/24
51/4 52/2 53/15 53/16
54/25 55/8 55/22 58/1
59/21 66/18 68/25
69/1 69/11 70/1 71/18
72/10 72/10 72/11
78/21 80/7 81/22
82/12 82/21 84/24
88/19 91/22 93/6 93/9
93/15 94/22 100/14
100/24 103/3 103/9
103/15 105/17 105/21
119/13 119/19 120/2
122/13 123/2 123/13
123/15 129/18 131/7
136/10 137/6 137/19
137/20 139/4 140/3
141/12 142/17 143/23)
145/18 150/18 153/7
155/13 157/17 163/23}

(48) 86/18 - all
A

all... [15] 164/14
164/24 165/5 165/13
165/17 165/23 166/12
166/18 167/14 169/13
170/17 170/18 175/4
176/24 179/13
allegations [4] 11/20
11/23 13/4 82/11
alleged [4] 8/10 8/21
101/21 172/13
Allen [2] 87/18 89/17
Alliance [1] 11/21
allowed [3] 81/16
82/12 101/6
allows [3] 123/10
134/21 177/9
almost [1] 137/21
along [1] 59/1
alongside [1] 44/2
already [10] 37/7
47/3 88/3 88/7 92/25
94/4 94/11 123/16
124/5 134/19
also [36] 12/22 16/21
17/4 39/22 48/16
48/17 51/20 51/23
52/13 69/5 90/16 92/4
100/15 104/12 107/7
111/23 112/4 112/11
114/20 124/18 135/5
136/9 141/3 146/6
146/15 147/6 148/24
154/3 154/22 157/15
162/3 169/1 175/24
176/2 176/8 177/14
alternative [2] 70/2
176/8
alternatives [2]
165/3 166/5
although [4] 14/23
59/13 88/19 164/18
altogether [1] 129/13
always [11] 25/20
34/6 70/13 84/7 84/14
100/24 117/22 141/11
141/12 176/16 176/18)
am [19] 1/2 6/3 19/18
19/22 20/16 22/21
38/16 38/18 39/12
55/10 65/4 66/24
87/10 87/13 110/22
141/7 156/20 172/6
180/10
ambition [3] 145/22
147/7 147/14
amend [3] 3/22 24/18
29/4
amended [3] 31/21
47/24 48/2
amendments [1]
3/19
amongst [1] 91/6

amount [4] 48/10
48/15 129/21 152/6
analyse [1] 52/23
analysed [1] 53/13
analysis [2] 139/15
144/17
analyst [4] 135/14
135/15 142/2 145/20
analyst's [1] 135/25
analysts [3] 125/4
125/12 137/2
Andrew [1] 87/18
Andy [6] 12/25 14/3
15/18 17/20 82/23
83/2
Angela [7] 10/10
10/15 12/22 13/21
15/5 20/24 83/20
announced [4]
120/24 121/4 121/8
121/24
annual [6] 57/3 69/13
79/9 82/18 114/9
119/15
annually [3] 33/3
35/21 51/25
another [17] 21/21
29/16 39/3 45/8 68/4
68/6 74/19 81/5 84/6
88/1 88/5 109/20
123/20 143/24 145/1
155/18 178/20
answer [7] 93/24
97/3 119/3 169/15
173/14 176/22 177/18
answered [1] 57/9
answering [3] 57/14
97/20 158/15
anticipated [1] 101/5
anticipating [1]
36/19
any [94] 2/10 4/9 8/9
11/22 13/25 16/10
16/18 18/10 18/10
21/9 23/22 25/19
26/15 27/14 31/3 33/4
35/17 35/25 38/1 38/5)
39/17 40/4 41/11 43/4
44/9 44/10 45/22 46/6
48/4 49/11 51/12
51/12 52/7 52/11
52/24 55/5 61/12 65/9
70/19 72/15 75/12
75/17 78/10 78/15
80/8 80/25 83/22
84/24 87/6 87/11
87/11 87/13 88/9
95/12 96/23 100/21
101/20 103/1 109/3
110/25 112/14 113/1
113/24 114/8 115/21
116/24 122/15 123/20)
125/8 125/21 126/5
126/6 128/6 131/19

137/10 137/13 138/18}
142/12 142/14 144/6
147/20 153/7 153/16
158/4 158/7 159/11
162/5 163/19 164/4
165/15 172/11 172/22
173/8 175/2
anybody [5] 41/14
41/21 50/25 59/1
163/11
anything [9] 2/13
7/12 19/13 28/21 52/7
87/4 96/13 129/14
130/5
anyway [3] 57/9
58/15 93/23
apart [2] 57/11 99/8
apologies [6] 52/18
76/18 77/5 97/21
119/1 158/14
apologise [2] 38/21
38/23
apparently [2] 1/14
83/15
appeal [7] 4/21 4/21
15/23 16/14 17/7
68/17 76/24
appeals [4] 7/12
18/17 18/21 77/7
appear [4] 11/16
14/21 40/4 88/18
appearing [1] 22/2
appears [7] 17/18
46/12 74/2 81/25
82/21 116/19 155/23
appetite [2] 34/23
150/22
applicants [2] 7/15
23/22
applied [4] 28/18
56/20 69/24 70/3
applies [2] 32/15
99/3
appointed [2] 21/18
21/21
appreciate [7] 70/18
81/7 81/11 81/12
92/14 99/20 154/19
approach [3] 52/9
69/8 99/3
approached [2]
91/12 91/12
approaches [1]
58/12
appropriate [11] 1/19}
2/3 2/21 19/15 22/13
33/13 34/24 40/22
117/12 120/25 148/19}
approval [5] 4/11
122/3 122/6 177/4
177/18
approve [2] 71/18
176/2
approved [1] 177/11

approximately [1]
159/25
April [1] 162/7
arbitrarily [1] 75/22
ARC [4] 70/15 139/5
175/21 176/3
archiving [4] 30/7
30/22 30/23 31/11
are [197]
area [7] 6/15 15/12
60/9 68/2 99/9 115/19)
167/15
areas [9] 19/21 28/11
33/5 33/20 34/2 34/7
55/10 115/17 167/10
aren't [6] 21/8 42/24
70/8 99/14 154/20
154/25
arguing [1] 88/1
argument's [1] 41/4
arise [1] 164/14
arisen [4] 124/1
151/12 156/9 174/12
around [24] 7/22
9/11 12/7 14/15 16/24)
23/20 30/19 31/9
34/22 41/3 41/5 59/12
72/24 77/16 79/17
80/2 83/1 112/21
116/17 118/13 154/22)
158/10 161/1 166/19
ARQ [5] 109/11
109/12 172/21 172/22)
173/1
arranged [1] 30/8
arranging [2] 107/3
148/18
arrested [2] 106/4
107/8
articles [4] 137/6
138/10 138/12 155/8
articulated [1] 171/9
as [218]
ascertain [3] 136/24
168/10 168/15
aside [3] 18/16 33/11
57/3
ask [31] 1/24 5/3
11/13 13/13 17/12
19/25 54/1 54/22
76/18 90/7 97/9 103/1
105/19 108/17 108/23}
110/12 111/2 117/6
118/12 126/4 133/7
133/9 133/22 143/9
143/12 172/15 175/2
175/12 175/18 176/14
178/14
asked [14] 1/13 18/5
20/22 22/3 83/25
87/23 91/12 97/1
132/2 147/7 153/11
154/24 172/3 179/18
asking [8] 13/19 85/2

105/15 115/9 129/19
134/4 146/17 175/15
aspect [2] 43/19
110/13

aspects [1] 40/21
assert [1] 88/23
assertions [1] 83/16
assess [2] 44/10
140/17

assessed [1] 145/19
assets [2] 122/16
143/13

assigned [1] 136/21
assist [10] 13/16
32/6 33/21 43/22
65/23 85/3 160/13
162/25 166/12 173/7
assistance [7] 75/12
102/5 125/20 134/4
158/18 167/9 173/19
assistant [2] 42/21
143/12

assistant's [1]
130/19

assistants [6] 41/16
42/3 44/11 58/7 126/6
169/2

assisting [2] 18/20
173/6

associated [2] 4/13
69/13

assume [1] 85/9
assuming [1] 15/9
assurance [41] 35/6
35/23 55/19 59/24
61/13 67/11 67/13
67/18 67/21 72/19
75/19 75/19 76/8
78/12 113/12 113/17
114/16 114/17 114/21
114/23 116/10 116/21
4117/7 117/8 117/13
117/14 117/25 118/1
118/8 119/8 119/18
120/5 120/22 122/16
138/17 163/13 163/18}
163/22 164/1 174/9
174/25
assurance/audit [2]
55/19 59/24

assure [6] 61/8 72/25)
81/3 158/25 163/11
174/24

assured [4] 17/3 52/3}
65/4 173/23
asterisks [2] 63/7
63/12

at [283]

at page 15 [1] 136/18

Athwal [3] 87/24 88/1
88/7

attached [1] 92/9

attaches [1] 10/18

attachment [1]

(49) all... - attachment
A

B

attachment... [1]
162/16
attempted [1] 127/25
attend [4] 43/5 43/8
59/6 113/17
attendance [1] 53/6
attended [4] 42/16
43/6 83/21 113/8
attending [4] 3/2
42/18 43/3 108/20
attention [2] 60/7
79/14
attributed [1] 168/25
audit [15] 35/8 55/19
59/24 71/19 113/20
113/23 114/2 116/12
116/13 116/14 150/5
151/3 151/5 175/21
176/7
audited [1] 82/18
auditor [2] 114/1
114/41
Auditors [2] 59/25
60/9
audits [5] 60/8
113/12 113/17 114/15
116/9
August [4] 3/6 31/24
67/15 108/25
author [1] 161/12
authored [2] 145/24
150/7
authorised [1] 60/14
authority [2] 14/17
159/12
auto [4] 146/11
151/14 154/17 162/17
automatic [1] 134/15
available [14] 26/19
26/22 33/1 35/7 41/21
42/13 43/21 57/22
58/25 59/16 63/13
78/9 155/12 155/14
average [1] 115/3
avoid [1] 37/20
avoidance [1] 158/6
await [1] 126/14
awaiting [1] 146/5
aware [18] 1/23
20/16 24/4 34/3 46/16)
52/11 61/10 86/11
88/21 101/14 101/16
101/24 123/15 146/16)
152/18 153/2 178/14
178/21
awareness [1] 59/15
away [3] 48/2 48/24
134/17
awful [2] 79/15
174/22

BA [1] 14/21
back [33] 1/14 10/14
16/12 17/14 22/4
30/11 30/13 33/18
36/3 44/13 47/21
49/25 57/20 63/13
86/14 102/13 106/7
115/11 117/23 124/17)
126/25 132/11 147/15)
150/7 153/7 156/22
165/17 168/20 169/13}
169/14 178/6 179/14
179/18
background [3]
39/25 79/6 120/15
backlog [5] 146/1
146/8 146/9 146/21
146/23
bad [1] 71/24
balance [13] 44/24
45/15 126/24 127/8
127/24 128/15 132/4
132/9 133/8 137/16
137/22 137/23 137/24)
balances [4] 123/15
126/3 133/2 140/2
balancing [8] 33/7
45/2 66/18 126/7
126/24 128/22 129/1
133/5,
bank [1] 88/4
barrier [2] 43/1 43/3
Base [1] 138/15
based [18] 62/9
63/14 63/18 63/20
63/23 64/16 65/16
66/10 87/5 98/23
99/16 102/12 105/7
140/18 145/17 163/7
169/5 169/16
basing [1] 99/14
basis [16] 14/11
16/10 20/3 22/24 52/3
56/11 58/25 64/19
66/9 69/13 70/15
82/19 99/4 100/25
109/16 126/5
Bates [5] 79/1 79/12
86/12 97/10 97/11
BBC [1] 90/15
be [231]
Bearing [1] 137/1
bears [1] 157/9
became [1] 155/9
because [48] 8/10
11/10 12/6 19/16
42/20 49/1 55/3 56/16
58/17 60/21 64/5 71/8
71/25 78/25 82/24
84/22 85/23 94/10
95/14 98/11 102/20
103/8 104/14 105/3

105/4 106/13 115/18
127/1 128/10 128/24
131/13 132/15 133/6
133/24 147/3 149/2
149/7 149/18 154/17
157/8 166/9 169/13

173/25 174/14 174/15)
174/23 176/19 177/12

become [2] 86/8
118/22

becoming [1] 146/15
been [172] 2/5 5/22
6/5 8/7 9/16 10/12

10/24 11/3 11/5 11/20

12/15 15/17 17/2
17/10 18/5 18/7 18/9
18/25 20/7 20/16
20/17 21/25 22/17
23/13 25/18 25/22
26/10 27/12 28/7
28/23 29/10 29/12
30/6 30/19 32/12
33/12 35/17 35/19
36/1 36/9 36/11 36/17
36/24 37/1 39/2 42/9
42/17 43/21 46/19
46/23 48/10 49/15
51/19 51/23 52/1
52/10 53/5 53/7 54/9
55/7 60/15 61/20
63/12 63/25 66/6
66/10 66/13 67/14
68/15 68/21 69/6 70/2
71/22 72/2 72/15
72/19 72/22 73/18
73/20 74/10 75/20
76/2 76/7 76/14 78/25
79/2 82/9 82/20 83/3
83/8 83/9 83/9 83/24
85/4 85/19 86/6 86/11
87/2 88/9 88/24 91/3
91/23 91/25 92/3
95/15 95/23 98/16
98/19 104/7 104/9
104/10 105/7 105/8
106/4 106/14 107/2
107/8 107/12 110/16
112/3 117/11 118/4
118/10 118/13 119/6
119/9 119/10 119/13
120/2 120/2 121/16
121/25 122/11 127/1
127/25 130/2 130/18
131/1 139/17 139/21
140/1 140/1 140/4
140/12 141/14 142/12
142/16 143/13 144/23
145/16 148/25 149/3
151/2 154/15 156/16
157/3 158/24 159/3
159/15 160/8 161/19
163/21 163/23 164/11
164/19 166/9 166/15
168/15 170/12 170/12

170/14 176/15
Beer [2] 1/12 20/8
before [53] 2/11 3/8

28/18 28/20 35/13
35/15 47/25 50/10
51/17 62/25 63/2

82/19 82/23 86/13
87/19 89/13 93/19
95/14 96/14 97/8
101/3 101/7 109/3
111/3 111/10 112/9
113/20 118/9 119/9
123/16 124/23 125/8
130/15 130/22 133/11
138/14 143/2 144/14
153/21 163/6 163/18
164/8 168/3 171/24
172/15
began [1] 61/10
beginning [1] 175/16
behalf [9] 1/19 5/23
19/15 107/22 108/18
110/17 120/18 175/15)
180/1
behave [1] 144/3
behaviour [3] 95/10
150/21 150/24
behind [2] 102/15
102/17
being [62] 6/20 6/22
7/3 7I17 8/17 10/13
15/2 18/13 19/3 20/22,
21/13 24/21 26/9
33/11 33/23 35/4
37/20 37/25 38/7
40/10 40/18 40/19
A117 44/18 47/19
48/21 52/8 52/22 53/9)
53/13 58/19 66/15
70/8 70/10 70/11
77/16 78/7 79/19
79/25 84/25 95/15
96/24 99/16 109/12
112/24 136/21 146/7
147/1 150/21 152/1
153/19 153/20 154/12
158/7 160/5 163/10
166/6 171/11 174/22
175/10 176/11 177/6
belief [3] 5/11 84/10
110/7
believe [24] 13/1
18/4 18/4 23/10 25/18}
38/8 40/14 47/13 56/6
61/1 72/21 113/25
115/6 118/24 120/16
121/25 122/11 133/6
140/23 141/10 143/5
154/16 157/11 170/21
believed [2] 84/7
85/6
believing [1] 84/8

20/5 20/7 20/12 24/25)

71/19 74/8 74/11 80/3)

below [3] 5/6 71/21
162/1

benefit [2] 132/15
165/16
best [10] 5/11 19/22
32/11 48/1 49/7 52/5
63/6 63/14 110/6
160/6
better [9] 49/6 54/15
54/16 59/18 115/4
115/7 115/10 149/19
155/15
between [13] 2/1
3/20 23/9 55/6 116/25
121/7 121/24 123/8
127/3 127/9 134/16
144/8 156/19
bigger [1] 155/4
biggest [1] 179/8
bin [1] 170/15
bit [14] 13/7 32/23
34/7 55/21 69/18
81/13 83/24 90/13
113/9 123/16 131/14
136/6 144/8 160/1
bites [1] 177/17
blanche [1] 161/5
board [4] 4/11 39/8
160/22 176/18
bodies [1] 163/14
body [6] 29/18 77/6
77/9 120/5 120/17
142/19
Bogerd [7] 10/11
10/15 12/22 20/24
81/6 83/15 86/16
Bogerd's [2] 21/13
22/3
boils [1] 39/4
bold [1] 81/25
bolt [2] 135/5 135/8
bolt-on [2] 135/5
135/8
Boots [1] 111/5
boss [3] 11/3 85/1
94/16
bosses [1] 80/25
both [8] 44/18 51/10
64/3 94/7 106/13
111/7 113/25 140/22
bother [1] 106/16
bottom [16] 3/14
4/16 16/1 20/14 20/15
31/16 54/2 58/11 60/4I
69/22 135/2 138/1
145/13 150/6 156/18
165/1
bound [2] 28/20
172/21
box [4] 131/22
131/24 132/5 155/8
bracketed [1] 65/23
brackets [9] 63/7

(50) attachment... - brackets.
B

brackets... [8] 63/9
103/23 104/6 105/6
106/7 106/10 107/1
107/7
branch [121] 6/14
6/22 7/16 12/3 12/8
14/15 14/20 19/2 24/2)
24/8 26/22 30/8 30/13,
30/14 30/18 31/12
33/7 33/10 34/16
36/20 41/20 41/21
46/1 46/19 47/11
47/15 49/16 54/20
55/18 58/7 58/8 59/2
59/24 60/1 61/13
62/21 63/22 66/14
67/11 67/13 67/21
74/16 74/18 81/9 87/7
88/5 88/12 88/23
99/18 100/3 103/20
111/19 111/23 112/15)
113/12 113/17 113/18}
114/7 114/15 114/17
114/21 114/22 116/8
116/9 116/11 116/21
117/24 118/1 118/8
119/8 119/18 120/5
120/21 122/17 122/23)
123/24 124/6 124/25
125/20 125/23 125/25}
126/8 126/13 126/22
127/9 127/11 128/3
129/21 132/8 133/10
133/23 134/4 134/19
135/9 135/10 135/12
135/19 135/24 136/12)
137/5 137/6 137/7
137/8 137/10 137/10
137/12 137/13 137/21
138/3 138/8 138/21
138/22 139/25 141/4
149/22 152/6 161/13
164/23 169/10 169/12)
173/3
branches [25] 3/15
6/15 6/23 7/3 7/15
7/22 10/8 23/25 36/20
39/21 41/14 47/7 47/8
61/4 61/19 61/19 85/4
103/16 103/21 112/5
113/17 135/12 165/19}
170/14 179/19
brand [1] 156/9
breach [3] 70/1 73/15)
73/16
breaches [3] 8/10
98/13 122/12
break [5] 38/13 38/17!
38/22 147/20 148/5
Breeden [7] 10/10
10/13 10/15 10/22
10/25 11/7 11/12

brief [4] 6/11 55/18
59/24 78/18
briefly [4] 69/18
86/14 111/2 143/24
bring [12] 10/9 32/2
44/16 52/20 53/15
53/22 60/4 87/16 90/3
101/2 120/20 151/17
bringing [1] 37/18
broad [2] 111/15
156/5
broader [1] 34/3
broadly [1] 15/3
Brocklehurst [1]
111/12
broken [1] 39/2
brought [2] 112/25
177/16
BSC [17] 123/3
126/15 126/18 130/8
133/20 133/20 148/17)
148/17 148/21 148/23)
149/3 149/15 149/16
149/17 151/25 152/8
152/10
budget [2] 165/14
165/15
budgets [1] 8/3
building [1] 146/9
bullet [3] 90/24
136/22 162/24
bundle [3] 17/8 20/13
108/22
burden [2] 47/17
96/7
business [31] 14/20
18/2 18/17 26/5 27/9
29/14 34/3 34/23
36/11 36/17 40/2 41/2
42/1 43/25 44/14 45/7
55/10 57/6 68/5 69/1
72/14 84/2 87/1 87/3
89/7 95/17 95/24
111/8 113/5 120/13
150/22
business's [1] 17/12
businesses [1] 44/2
busy [1] 44/1
but [150] 2/10 2/15
10/15 10/21 11/4
12/10 15/3 15/11
15/22 17/17 19/12
21/14 23/20 24/5
25/18 26/21 29/14
30/19 31/10 32/13
34/13 39/1 40/14 43/3
43/19 44/12 45/10
46/2 46/24 48/3 48/23
49/6 50/15 52/20
53/12 53/20 55/14
56/11 56/25 57/7
58/15 58/19 58/25
60/23 62/3 63/7 64/9
65/10 66/20 69/17

70/18 73/13 73/25
74/2 74/8 78/10 78/21
79/1 80/1 81/2 82/13
82/25 83/7 84/19 86/9
88/18 89/6 92/3 92/4
92/22 93/1 93/21
95/24 97/3 99/2 99/20
100/5 102/16 102/20
104/12 105/2 105/8
106/10 106/19 107/6
109/25 110/13 116/2
117/22 118/11 118/17]
120/18 121/10 122/2
126/15 128/1 128/3
129/3 131/4 131/6
131/12 134/8 136/9
138/12 138/18 139/23
141/6 141/9 141/20
143/11 144/2 147/5
147/14 147/15 148/16}
148/23 151/17 151/24
153/23 154/19 156/20
157/12 158/10 162/19}
162/20 163/6 164/7
164/11 164/22 164/24
166/3 167/14 168/17
170/22 171/3 171/11
172/21 173/10 173/24
174/8 174/11 174/24
176/5 176/12 176/16
176/23 177/6 177/15
178/4 179/19

button [8] 49/3 131/1
132/20 133/13 146/17]
150/10 151/24 152/9
buttons [1] 130/7

Cc

call [31] 1/20 7/23
26/24 45/7 47/15
58/14 61/5 90/10
92/12 107/13 112/15
125/19 126/25 130/8
133/10 133/20 133/20
133/23 134/11 142/2
149/17 149/22 151/21
151/25 152/1 152/7
152/9 153/7 167/7
172/18 175/17

called [9] 6/15 6/16
7/21 20/23 77/1
134/19 149/15 151/24)
174/22

calling [4] 134/3
134/12 134/20 176/4
calls [5] 134/6
137/11 149/14 152/3
152/10

Calum [2] 60/5 176/5
came [5] 28/2 82/21
86/1 104/19 113/7
can [173] 1/3 1/7
2/25 4/7 5/1 5/3 5/10
8/6 10/9 10/14 12/2

12/10 12/18 14/9
14/23 15/20 15/25
16/12 18/15 19/25
20/14 22/20 23/3 24/6)
24/15 25/6 25/11
25/19 27/2 28/22
29/17 30/9 30/25
31/14 32/20 33/24
34/15 36/2 37/16 38/2
38/11 38/19 40/21
42/7 44/13 45/14
47/10 47/12 49/16
50/4 50/8 54/1 55/17
57/22 58/8 59/7 59/8
59/18 60/3 61/15 62/5)
63/3 63/3 65/23 66/5
67/3 67/24 69/17
69/22 70/24 73/4
73/12 75/2 76/1 76/4
76/18 77/17 78/4
78/18 78/21 79/6
85/18 85/22 87/16
87/23 90/2 90/12
90/14 90/16 90/20
91/11 92/4 92/19 93/9)
94/17 95/7 95/22
96/20 97/9 100/5
102/4 103/5 106/24
107/25 108/9 108/15
108/18 108/22 109/8
109/25 115/9 116/8
120/20 125/19 126/10}
126/15 126/23 126/23}
127/9 127/15 127/16
129/11 129/13 130/3
130/4 131/4 132/9
132/11 133/1 133/14
133/25 134/24 136/18}
136/19 138/13 138/15}
138/23 140/8 140/13
142/1 145/3 145/23
148/7 149/12 150/25
151/16 152/23 153/6
154/5 157/2 157/10
157/24 159/7 159/14
159/18 160/4 160/10
160/12 161/8 161/24
162/23 163/1 163/14
166/12 167/21 167/22}
168/8 168/21 169/3
169/16 171/9 173/18
177/15
can't [37] 12/10
21/10 23/19 25/23
26/13 29/3 29/10
29/15 38/1 50/15 83/7,
83/20 84/18 86/5
86/10 86/23 96/19
99/7 102/17 112/14
121/22 123/13 125/3
126/19 126/22 127/12}
131/7 138/19 155/2
163/5 164/11 164/18
166/15 176/21 176/22}

177/113 177/19
cancel [7] 79/1
129/10 129/10 129/25)
129/25 132/5 132/17
cancelling [4] 78/24
79/3 79/7 80/1
cannot [2] 14/8
140/15
capability [1] 10/8
capable [1] 70/8
capriciously [1]
75/23
career [2] 81/2 111/3
careers [1] 94/18
careful [1] 89/23
carelessness [10]
48/18 65/12 73/18
74/5 74/13 98/17
130/20 131/2 167/24
170/9
carried [3] 141/14
158/8 167/24
carry [3] 22/14
113/16 168/21
carrying [2] 50/22
159/23
carte [1] 161/5
cascade [1] 91/10
case [39] 14/3 25/24
37/22 63/14 72/8 74/2I
74/19 77/18 81/4
81/21 82/7 82/10 83/4I
104/5 123/9 123/10
123/12 123/19 125/7
131/10 134/12 134/15}
140/17 140/17 140/19)
140/24 141/8 141/10
141/12 141/13 141/16
142/3 146/1 146/7
146/11 147/12 149/6
151/14 177/8
cases [30] 24/4 64/3
64/7 65/22 66/2 66/13}
99/9 103/25 105/21
105/23 106/8 106/13
106/19 106/19 106/22!
106/22 107/7 107/8
107/11 107/13 136/9
136/10 141/12 146/4
146/5 146/8 146/13
146/13 150/14 150/18)
cash [39] 33/6 41/3
41/4 45/8 45/11 45/15)
45/19 45/23 46/18
49/3 66/15 66/16
66/17 99/18 113/18
114/6 114/6 124/11
130/4 130/8 130/9
130/16 130/22 130/25)
131/5 131/23 132/9
132/17 132/20 132/23)
133/8 137/15 137/20
140/1 169/9 169/9
170/13 170/15 178/9

(51) brackets... - cash
Cc
categories [3]
154/22 157/5 157/10
cause [11] 43/15
55/5 69/25 105/9
120/25 124/19 124/21
126/9 127/12 131/6
168/23
caused [13] 48/17
66/14 73/18 74/4
74/12 98/16 104/20
130/18 131/1 143/10
146/10 167/23 169/2
causes [1] 135/12
cautious [1] 96/24
caveat [1] 173/5
cc [2] 10/17 88/13
ceased [1] 159/23
cent [10] 55/2 116/12
117/19 124/10 147/14}
178/11 178/15 179/4
179/9 179/12
central [7] 61/24 65/2!
74/23 100/5 110/20
144/7 144/14
Centrally [1] 133/17
centre [24] 17/11
45/8 47/11 47/15
111/19 111/23 112/15}
122/23 123/24 124/6
124/25 125/20 125/23}
125/25 126/8 126/23
127/9 127/12 133/10
133/24 134/4 134/19
136/12 137/12
CEO [2] 122/8 160/14
certain [9] 19/7 46/18)
119/12 130/18 131/1
132/24 163/8 166/9
178/10
certainly [15] 10/5
13/23 16/7 28/9 61/14}
73/23 73/24 80/2
82/25 89/7 90/1 91/18
92/17 95/19 101/8
cetera [10] 19/22
34/20 46/4 53/11
62/24 75/23 89/20
91/5 99/19 100/22
chain [1] 86/21
chains [1] 87/5
chair [5] 77/11 77/13
77/16 77/18 77/19
challenge [2] 34/2
142/1
challenged [2] 88/7
89/9
challenges [1] 34/5
challenging [1] 72/5
chance [2] 53/24
116/6
change [22] 2/20
7/21 7/21 8/18 14/19

14/24 21/23 29/11
35/10 51/9 51/22
70/12 93/7 93/8 93/11
93/20 94/1 95/11
96/10 134/7 138/22
140/24
changed [12] 22/9
35/11 48/22 67/14
67/15 95/25 133/18
133/19 154/19 171/20)
174/18 174/19
changes [31] 3/9 4/9
14/9 14/23 19/20
22/19 22/21 24/24
24/25 25/19 26/25
27/1 27/2 27/25 28/2
28/7 28/12 31/22 32/6
32/9 32/13 32/24 33/4
35/13 36/23 37/9 38/8
47/25 50/1 158/21
176/17
changing [1] 70/13
channel [4] 25/12
25/13 30/2 30/12
charge [4] 41/22
45/23 152/18 176/10
charged [3] 106/4
106/15 107/9
chartered [1] 111/4
chase [1] 147/16
check [18] 8/6 18/1
26/11 56/10 65/8 80/8
80/10 115/9 119/22
119/25 136/23 137/3
137/9 137/22 159/22
168/9 169/14 175/13
check-ins [1] 26/11
checked [1] 168/15
checking [4] 35/23
35/24 97/19 138/17
checklist [3] 136/6
149/20 176/9
checklists [1] 136/4
checks [5] 123/15
126/3 126/25 138/18
140/1
Chemist [1] 111/5
cheque [4] 87/20
88/1 88/3 130/16
cherry [1] 177/18
Chesterfield [2]
14/22 111/20
Chief [4] 51/2 111/12
121/18 121/21
children [1] 87/14
choice [2] 128/17
131/10
choose [2] 140/25
162/18
chooses [3] 45/23
76/24 131/22
choosing [1] 1/25
chosen [1] 110/16
churn [1] 50/13

CI [1] 144/20
ClJ [6] 3/21 31/10
52/8 58/4 72/12 75/21
circulate [1] 17/22
circumstances [17]
64/12 120/24 121/17
121/23 122/9 131/13
132/24 133/25 143/20
144/11 151/12 151/23}
153/10 153/22 155/11
161/3 170/8
civil [22] 65/15 65/19
101/21 142/22 142/24
143/3 157/25 158/4
158/6 158/16 158/22
159/4 159/11 160/10
160/20 162/10 162/11
162/19 163/10 163/19]
166/14 172/12
claimed [1] 66/4
claiming [1] 87/6
claims [2] 65/15
158/16
clarification [2] 58/2
148/20
clarified [2] 163/2
163/16
clarify [5] 24/14
33/15 52/13 126/11
173/16
clarity [8] 64/12
76/18 97/9 100/18
126/17 132/11 153/15}
155/15
classic [1] 90/24
classification [1]
156/2
classroom [17]
40/12 40/25 42/11
42/20 43/18 43/19
44/4 50/3 53/6 54/19
56/6 56/8 57/12 58/5
58/22 58/23 59/5
classrooms [1]
49/19
clear [29] 2/16 13/19
15/13 15/14 32/15
35/1 45/22 46/8 46/13
48/25 49/12 49/16
86/9 92/24 100/12
101/18 107/16 121/13
132/7 132/22 140/19
1414/7 147/8 153/21
154/20 154/25 155/9
171/11 172/9
cleared [1] 88/3
clearer [1] 153/19
clearly [12] 13/18
21/7 21/12 23/1 33/25)
52/17 69/5 69/7 77/21
79/13 85/9 86/5
clients [3] 89/2 100/7
169/19
close [1] 149/6

closely [1] 16/7
closing [3] 137/21
137/22 150/18
closure [1] 7/22
closures [1] 8/7
Co [1] 166/20
cohort [1] 57/14
collate [1] 52/22
collateral [2] 41/19
50/2
colleagues [8] 33/21
34/19 35/5 83/10 85/9
95/17 144/23 149/24
colleagues’ [1] 56/25
collection [1] 144/17
come [40] 5/1 10/20
15/20 17/10 18/15
26/21 28/22 32/20
38/11 55/17 60/7
61/15 65/14 67/3 69/1
76/1 78/4 83/2 85/13
93/2 109/6 109/25
120/17 124/17 128/14}
129/13 130/4 133/1
134/9 136/12 140/6
140/8 142/22 145/4
147/4 147/12 149/12
157/24 160/4 164/16
comes [4] 81/7 90/9
146/18 164/22
comfort [2] 15/13
44/5
comfortable [3]
131/5 132/8 153/3
comforted [1] 46/24
coming [9] 17/6
18/17 30/20 36/3
54/21 84/20 84/25
107/20 167/20
commenced [1]
105/2
commences [1]
163/19
comment [14] 23/19
25/23 26/13 29/3
83/20 99/7 102/13
151/1 151/7 171/22
176/19 177/13 177/19}
179/1
commentary [1] 14/7
commercial [1]
112/22
commissioned [1]
116/5
commit [2] 41/23
42/4
commitment [1] 42/2
committed [1] 41/8
committee [26] 35/8
52/22 71/3 71/9 71/9
71/20 71/23 72/5
72/10 72/17 72/18
73/3 73/5 73/6 73/7
73/8 75/25 76/4 76/5

76/9 76/10 76/21
76/21 142/4 142/7
175/22
committees [3]
72/19 72/24 77/19
committing [2] 41/25
42/1
common [38] 3/21
23/2 24/15 24/17 25/4
27/23 28/18 31/4 31/7I
31/22 32/8 32/10
35/11 37/6 42/9 50/10
50/21 51/6 51/17
51/20 63/24 64/9
67/19 68/24 69/4
85/20 85/25 92/6 92/8
92/10 92/14 94/3 94/7I
94/21 95/3 118/9
119/9 119/11
Comms [1] 18/9
communicated [3]
28/16 29/16 123/7
communication [3]
18/19 30/2 30/11
communications [9]
17/14 17/22 18/1 18/6)
18/8 25/13 25/14
85/17 171/14
communities [1]
87/15
community [1] 17/23
company [1] 5/20
comparatively [1]
56/18
compared [2] 56/18
116/17
comparing [2] 114/7
169/10
comparison [1]
112/1
complete [9] 62/14
62/23 78/8 82/6 143/2
145/8 146/22 154/15
179/17
completed [7] 53/5
114/23 117/5 144/19
150/14 156/16 158/17)
completely [3] 10/23
22/17 170/5
completeness [1]
158/25
completing [4] 56/17
57/12 130/22 178/10
completion [2] 56/23
150/20
complex [1] 136/9
complicated [1]
120/13
complicit [1] 84/24
complied [1] 75/5
comply [2] 75/8
75/14
component [2] 53/15
54/25

(52) categories - component
Cc

comprehensive [1]
41/8
comprised [1] 77/9
concept [1] 43/16
concern [3] 19/10
169/19 169/22
concerned [3] 100/8
103/14 122/16
concerns [7] 15/3
15/4 21/7 91/8 91/15
159/23 176/7
conclude [1] 93/9
conclusion [2]
139/11 147/4
concrete [1] 78/10
conduct [2] 95/9
119/23
conducted [4]
116/16 117/14 117/20}
120/5
confer [1] 41/6
conference [1] 90/10
conferred [1] 18/5
confidence [3] 42/18
89/2 159/7
confident [7] 34/5
52/7 54/23 63/3 66/20
72/12 170/17
confined [1] 2/1
confirm [6] 5/10
108/25 127/20 128/20)
160/9 172/25
confirmation [2]
16/21 127/23
confirmed [3] 79/2
98/7 166/25
confirms [1] 16/25
conflict [1] 67/20
conflicts [1] 20/18
confused [2] 102/7
102/14
confusing [4] 21/8
28/24 174/10 174/14
confusion [1] 174/13
connect [1] 85/25
connection [1] 39/2
conscious [1] 97/24
consider [9] 2/3
22/13 27/18 27/19
44/19 44/14 75/4 102/9)
174/4
consideration [3]
72/15 78/23 166/8
considered [7] 19/3
36/21 48/21 70/2
70/11 78/7 164/9
considering [4] 70/4
78/6 83/18 142/9
considers [1] 74/4
consistent [3] 49/22
49/25 54/8
consistently [3] 55/1

85/17 141/14
consultation [4]
60/10 71/16 71/17
101/9
consulted [2] 37/14
101/7
contact [6] 134/13
148/14 148/24 150/2
151/11 154/10
contacted [2] 148/16
152/8
contacting [1]
148/22
contains [1] 33/5
content [8] 11/13
40/16 40/20 40/24
45/10 50/3 90/13
139/19
contents [3] 5/10
10/21 110/6
context [6] 4/19 13/7
29/18 73/21 127/11
128/2
continue [10] 23/25
96/4 127/22 129/8
129/9 129/12 129/24
139/11 148/9 172/20
continued [1] 79/8
continues [2] 22/11
57/22
continuous [1]
155/16
contract [88] 3/20
4/5 4/10 4/12 9/18
11/1 16/7 18/22 22/12
23/2 23/5 23/8 23/13
23/14 23/17 23/22
23/25 24/7 24/10
24/22 25/3 25/7 25/20
26/24 27/1 27/2 28/10
28/18 28/24 29/2 29/3
29/6 29/11 29/21 31/5)
31/15 31/19 31/21
32/3 32/7 32/9 32/18
36/7 36/9 37/19 47/11
50/23 64/16 64/22
66/7 66/11 66/23
66/24 67/5 67/6 67/7
67/10 67/12 67/25
68/3 68/5 68/7 68/10
68/11 68/19 68/25
69/19 70/1 70/4 70/24
70/25 73/13 74/6 74/8
74/16 75/12 75/16
75/18 76/3 76/7 76/15
77/1 94/15 94/15
105/11 122/12 170/7
179/19
contracts [38] 8/10
8/17 10/25 11/11
11/14 13/12 17/23
22/24 22/25 24/15
27/25 28/3 28/7 28/8
28/13 28/15 29/4 29/5)

29/19 32/10 36/12
37/4 37/5 37/9 37/17
48/20 62/17 64/19
64/21 64/25 67/22
67/23 69/6 72/11 98/9
99/14 102/1 170/17
contractual [11] 25/1
26/2 27/5 29/20 31/8
32/17 69/25 75/5 75/9
75/14 168/13
contractually [1]
172/20
contribute [1] 166/1
contributed [2]
143/19 165/6
contributory [4]
136/25 139/12 168/11
168/16
control [5] 34/22
35/24 118/16 118/22
150/17
controls [1] 118/18
conversation [7]
79/24 144/21 149/2
152/15 152/16 161/22
175/1
conversations [13]
12/24 72/23 82/22
82/24 91/18 94/24
95/1 95/4 95/5 95/16
163/8 163/24 166/4
convert [1] 9/2
converting [1] 7/3
convicted [1] 85/19
convictions [9] 21/1
21/10 85/22 85/24
85/25 86/3 86/9 87/12
97/2
cooperate [2] 173/6
173/7
cooperation [2]
143/21 173/25
copied [4] 10/24 11/5)
12/23 92/6
copies [4] 10/16
25/20 27/20 36/12
copy [13] 3/4 10/22
11/3 25/16 25/18 26/8}
26/21 27/7 27/12
27/14 87/18 90/5
138/7
core [5] 19/11 19/21
80/9 80/10 176/3
corporate [3] 7/5
19/1 172/16
correct [53] 3/17 4/3
416 4/14 4/25 5/21
23/7 23/15 24/11
26/16 39/10 60/13
61/23 62/11 63/16
64/18 65/21 67/2
74/21 77/12 97/14
103/18 103/22 104/1
104/23 105/6 106/13

106/25 107/14 109/16
109/18 109/21 110/19}
118/6 122/25 125/13
125/22 129/2 129/3
129/15 130/1 130/6
131/3 131/4 132/14
132/23 132/25 150/25}
152/12 159/16 159/17,
168/19 178/24
corrected [2] 47/2
157/3
correcting [1] 114/10
correction [7] 4/17
47/14 48/8 109/3
109/8 124/7 125/17
corrections [3] 112/2
124/11 140/3
correctly [3] 33/22
127/3 128/11
correspondence [1]
15/24
corresponds [1]
109/11
cost [5] 34/4 109/11
109/13 140/22 165/21
costs [2] 44/4 179/13
could [65] 3/10 4/15
14/14 20/6 31/3 32/21
34/6 38/5 38/15 43/2
43/3 44/23 45/3 47/21
49/6 53/22 54/1 57/19)
62/20 63/17 65/8
70/22 72/8 73/14
79/18 81/13 82/15
88/13 90/3 90/20
90/22 105/25 110/1
4111/2 111/15 113/12
115/18 116/4 117/24
117/25 118/15 118/18}
123/22 130/21 131/5
132/16 139/7 139/14
140/9 141/8 141/23
145/5 147/1 148/11
150/3 150/5 155/21
157/25 158/12 163/4
164/2 165/8 167/16
171/13 174/10
couldn't [10] 23/20
58/18 95/15 97/3
118/11 119/12 119/16}
166/9 170/13 176/19
count [7] 113/18
120/1 120/12 120/16
120/18 129/14 169/9
counter [5] 128/5
128/6 128/8 128/12
128/14
counters [3] 124/15
127/3 128/6
couple [5] 24/3 127/1
146/11 166/16 175/12}
course [28] 1/9 15/10}
31/1 41/16 41/19
42/11 42/25 43/5 43/8)

43/18 43/19 50/21
51/23 52/2 54/20
58/24 59/5 59/13 66/5I
74/8 82/2 84/15 85/23
95/24 100/2 121/1
121/2 170/25
courses [2] 40/25
42/9
court [1] 81/21
court's [1] 24/22
cover [1] 179/13
coverage [1] 90/19
covered [1] 58/22
covering [2] 157/19
157/21
covers [1] 45/2
Craig [7] 16/2 16/3
16/5 16/6 17/10 17/18)
17/20
Craig/Andy [1] 17/20
create [6] 134/11
134/15 138/10 138/11
146/11 151/14
created [8] 14/12
123/10 142/20 151/2
154/17 160/13 160/14)
165/16
Credence [3] 137/18
139/23 173/21
crime [3] 144/5
144/12 144/18
criminal [3] 101/21
163/8 172/13
criticised [1] 68/16
criticisms [1] 68/21
Crown [4] 6/15 6/23
7/3 7/16
culturally [3] 51/10
95/20 95/25
culture [3] 84/5 84/8
96/9
currency [2] 120/14
120/15
current [18] 1/20 2/7
2/11 9/10 19/24 22/2
67/25 91/23 117/3
120/4 121/4 122/5
160/15 160/18 160/25}
162/6 169/20 171/13
currently [15] 6/1
47/24 48/1 71/14
71/15 118/8 120/23
130/16 131/24 142/7
142/9 142/15 149/25
154/16 158/3
customer [1] 46/3
cut [1] 36/4
cycle [1] 53/4

D

daily [6] 66/17 126/4
127/8 133/8 140/1
178/9

data [66] 14/20 34/19)

(

'53) comprehensive - data
D

53/13 53/18 61/25
62/9 62/15 62/18

62/19 62/23 63/10
63/13 63/15 63/19
63/23 64/17 64/20

102/17 103/25 104/9
105/7 109/13 112/2
114/3 116/3 117/19
135/11 136/5 137/19
138/2 139/5 139/13

159/1 159/3 159/14
163/2 163/12 163/15

173/1 173/19 173/20

174/1 174/10 174/17
174/22

database [2] 138/8
138/23

databases [1] 137/18
date [9] 44/21 46/9
71/22 121/6 121/9
150/13 155/3 159/6
159/19

dated [4] 3/6 31/24
164/8 172/4

dates [2] 78/10 87/16
Dave [5] 12/25 14/3
15/18 82/22 83/2
Davies [2] 90/9 92/6
dawn [1] 93/5

day [15] 42/11 42/20
42/22 43/18 58/23
59/4 82/23 100/20
100/20 145/17 150/13
150/19 1741/1 171/11
180/10

days [9] 53/20 127/1
145/9 145/15 145/21
147/3 147/5 147/13
150/14

deal [8] 4/18 74/17
122/20 124/13 125/3
128/17 129/12 145/3
dealing [4] 91/4
91/15 123/19 134/23
deals [2] 105/17
107/5

dealt [3] 77/6 109/19
176/11

debate [1] 90/17
debated [1] 34/18
December [5] 10/10
15/24 32/4 64/2 111/6
December 2019 [1]
64/2

decide [3] 92/23

data... [64] 35/5 43/4

64/24 65/5 65/6 65/16
102/15 102/15 102/17;

139/20 139/22 144/17)

163/16 163/23 169/10)
170/10 172/21 172/23)

173/21 173/24 173/25)

132/17 132/18
decimal [1] 118/21
decision [38] 3/22
4/20 24/18 36/17
64/21 66/24 67/4
67/22 68/18 71/1 71/1
71/2 71/9 71/22 71/23
72/9 72/16 72/18
72/24 73/5 73/7 73/7
75/17 75/19 75/24
75/24 76/2 76/6 76/20
77/3 77/19 140/14
140/18 141/15 142/2
143/2 158/9 160/23
decisions [14] 18/21
18/22 29/9 68/20 72/3
72/6 72/13 76/3 77/2
78/7 99/13 99/15
99/16 164/16
declaration [2]
127/20 128/5
declarations [3]
66/17 133/8 178/9
decs [1] 170/13
deduction [2] 160/21
162/17
deem [1] 52/24
defence [3] 82/3 82/5
82/11
defined [2] 159/22
160/22
definitely [5] 50/15
116/3 122/3 153/18
171/21
definition [3] 73/22
74/1 100/4
degree [2] 20/19
159/7
delay [1] 36/21
delegates [2] 56/7
59/12
deliberately [1] 1/25
deliver [2] 33/24 34/6
delivered [4] 25/22
40/10 67/19 69/2
delivering [3] 19/19
40/12 52/5
delivery [3] 25/23
26/8 39/20
demand [5] 155/24
157/13 157/14 157/17)
157/22
demonstrate [2]
47/12 96/7
demonstrated [1]
104/3
demonstrates [1]
104/21
demonstrating [1]
106/20
den [9] 10/11 10/15
12/22 20/24 21/13
22/3 81/6 83/15 86/15)
denied [1] 78/23

department [3] 10/1
10/18 145/1

depend [2] 56/5
106/1

dependent [1]
106/11

Deployment [5] 9/18

deposits [1] 137/20
derived [2] 62/20
127/21
describe [4] 4/8
57/21 58/13 165/8
described [6] 74/11
105/14 146/12 150/4
160/11 177/16
describes [2] 144/9
164/2
describing [2] 47/25
113/23
description [6] 32/3
39/13 45/17 50/5
134/25 135/25
descriptions [1]
157/4
design [1] 39/8
desired [2] 150/13
150/19
desk [1] 137/12
desks [1] 175/11
despite [3] 20/22
21/17 88/5
detail [9] 45/9 57/19
58/13 59/4 69/18
113/9 117/5 136/7
152/23
detailed [7] 34/22
58/25 110/14 136/1
136/20 164/19 180/2
details [7] 47/16
56/10 95/12 123/11
123/12 123/14 149/24)
determination [3]
24/22 65/10 105/11
determine [1] 75/13
detriment [1] 147/17
developed [3] 35/5
35/11 43/21
developing [1] 40/24
development [4]
8/14 9/21 16/22 39/20
did [54] 1/18 6/4 6/12
6/20 6/25 7/19 9/13
9/23 9/25 10/1 11/8
11/8 15/3 16/3 18/10
18/10 21/23 25/3 25/5
25/25 30/23 35/13
38/25 52/10 62/8 79/5
80/4 83/6 85/1 85/13
85/24 86/3 86/21 88/2
89/5 89/19 89/20
91/20 92/13 93/5
93/25 94/24 97/2
101/23 110/15 110/23}

67/7 68/10 70/25 76/8

112/20 113/6 118/11
118/22 134/6 134/8
174/21 178/15
didn't [6] 15/4 15/10
26/13 31/10 83/21
89/2

difference [6] 55/4
55/6 115/22 116/19
116/25 121/7
different [28] 15/21
17/16 23/13 45/10
56/20 65/14 75/4

104/4 111/17 111/21
114/4 115/24 123/4
123/5 123/21 138/15
141/2 154/22 155/25
156/20 164/5 170/5
171/2 1771/4

difficult [2] 92/22
117/6

difficulty [1] 147/21
digested [1] 93/11
digital [2] 41/18
43/24

digitally [1] 43/21
direct [1] 21/11
directing [1] 153/10
direction [6] 2/4 2/5
2/9 2/17 15/14 149/6
directly [8] 3/15 5/20
6/14 7/2 54/14 55/24
92/1 134/16
Director [16] 6/1 10/2)
21/18 21/24 21/25
22/1 22/8 39/7 51/2
101/12 110/20 175/25}
177/12 17712 17715
177/19

Directors [3] 29/14
176/2 177/7
disadvantaged [2]
88/9 88/24
disagreeing [1]
143/23

disagrees [2] 141/25
142/6

disappointed [3]
21/5 21/14 55/2
disappointing [2]
54/11 54/13
disclose [1] 34/24
disclosed [3] 12/14
95/13 95/16
disconnect [2] 99/5
99/20

discounted [1] 12/6
discrepancies [69]
8/11 8/22 41/6 42/11
43/10 43/11 43/14
43/15 43/17 43/23
45/4 48/4 49/11 50/19)
58/1 58/3 58/9 58/19
58/23 59/5 63/21

78/16 81/5 92/13 99/3,

64/23 65/4 65/16 66/3
66/9 66/13 66/19
66/20 68/17 69/9
73/17 74/3 74/9 74/17I
98/16 99/11 99/12
99/15 102/3 102/4
104/8 105/7 112/1
112/9 112/13 122/21
124/20 127/22 129/6
129/7 129/13 135/13
142/24 146/23 146/25)
147/2 147/4 152/5
152/18 155/6 156/20
161/13 162/7 164/14
165/1 165/20 166/2
174/20
discrepancy [81]
45/6 45/14 45/16 47/5)
47/9 47/10 47/13
47/13 47/18 48/7
48/10 48/12 58/10
65/1 65/11 65/25 96/8}
100/3 112/16 125/15
125/20 125/25 126/7
126/14 126/18 127/5
128/1 128/6 128/8
128/16 128/18 131/1
132/7 132/17 133/4
133/9 134/1 134/5
134/14 136/25 137/9
137/17 139/13 140/12!
141/6 143/10 143/22
144/24 145/22 146/4
149/1 149/3 149/7
149/25 151/12 152/4
152/20 152/25 153/3
153/12 153/16 153/23
154/8 154/10 154/14
155/11 155/25 156/2
156/5 156/6 156/9
156/10 156/11 156/14I
156/23 157/9 163/3
163/17 168/11 168/17)
174/11
discrepancy's [1]
130/2
discrepancy/ies [1]
152/20
discrepancy/review
[2] 163/3 163/17
discuss [5] 131/11
134/14 140/6 151/11
177/21
discussed [7] 19/25
22/15 60/15 87/22
137/2 153/21 165/3
discussing [3] 3/12
7/7 151/20
discussion [8] 79/1
79/3 79/25 80/2 113/1
161/17 161/21 164/25)
discussions [5] 41/1
78/25 79/7 79/17
79/23

(54) data... - discussions
D

disenfranchised [2]
20/11 21/6
dishonest [1] 84/9
dishonestly [1] 16/19}
dismay [1] 21/19
display [1] 133/19
displayed [1] 132/13
dispute [42] 33/7
45/7 47/5 47/10 81/9
87/20 88/17 88/22
112/14 122/22 123/7
123/22 125/14 125/17)
126/13 127/7 130/8
131/11 133/14 133/18
133/19 133/20 133/23
134/3 134/10 134/16
134/18 136/18 142/3
142/7 142/14 143/9
143/15 146/16 148/16)
148/23 149/23 150/9
151/24 152/9 168/1
171/23

Dispute’ [1] 126/15
disputed [4] 65/25
66/4 156/14 156/17
disputes [4] 80/18
141/18 148/15 148/22)
disputing [5] 45/14
48/7 96/8 141/7
145/12
dissatisfaction [3]
54/8 116/21 117/10
dissatisfied [3]
116/16 116/18 117/11
dissimilar [1] 143/17
distinguish [1]
156/19

distribution [1] 19/7
DMBs [1] 39/22

do [183]

document [36] 15/20
17/16 18/15 25/3 25/7
26/7 26/19 27/21
27/22 29/22 30/1 30/7
30/11 30/17 31/3 31/5
31/6 31/12 32/3 32/20
33/16 45/11 46/10
76/13 76/22 118/17
118/19 140/9 143/25
145/3 145/12 152/2
153/20 155/22 160/13
160/14
documentation [2]
8/4 46/7

documents [8] 10/19
31/8 41/7 50/1 108/22
113/7 155/13 175/17
does [30] 13/3 13/6
23/21 23/24 24/5
32/15 41/24 42/2
42/23 49/19 62/14
62/22 77/21 91/1 99/1

100/9 113/16 115/2
121/20 126/20 135/25)
137/2 139/1 140/14
151/13 158/3 164/3
167/1 170/1 172/20
doesn't [17] 24/3
40/4 61/24 66/25 88/4
98/3 102/2 102/9
102/24 119/2 128/1
149/17 149/22 156/19)
162/25 170/3 174/3
doing [38] 7/8 9/16
13/16 13/16 26/18
26/23 27/4 36/11 37/7
37/10 42/5 42/25
46/25 66/8 69/14
72/17 84/11 84/15
89/7 95/23 99/19
107/23 111/7 113/5
114/5 117/9 119/24
138/9 140/1 140/2
153/14 155/17 157/15)
169/9 170/13 170/18
170/19 170/19
don't [104] 5/22
10/24 11/4 11/16
11/22 12/13 13/6
13/18 13/23 15/7 17/9)
18/12 23/18 26/5 26/5)
28/4 30/24 31/13 32/2
34/10 34/12 37/22
38/8 39/17 40/14
41/15 43/7 44/16
45/22 46/21 47/6
48/23 49/5 50/7 50/12
52/20 55/13 59/10
67/9 72/8 73/22 73/25
74/14 74/25 78/10
78/20 79/23 79/25
80/12 80/20 82/25
83/3 83/22 84/11
84/14 84/23 84/23
86/2 87/1 89/4 89/18
89/19 91/17 92/2
93/13 93/22 96/1
96/11 96/11 98/11
99/7 99/23 103/1
107/6 108/1 113/25
119/4 127/8 128/24
133/6 134/8 137/25
141/10 141/10 143/17)
143/22 144/16 144/20)
147/16 147/20 149/22)
151/16 152/9 155/9
155/20 159/21 162/25)
164/24 166/11 172/17)
173/25 174/8 174/22
(77/7
done [19] 18/12 26/6
29/5 46/19 46/24 53/1
53/19 63/12 79/11
86/2 119/21 120/11
128/10 129/18 134/8
138/18 139/18 144/25)

155/3
door [1] 171/1
doors [1] 171/10
dots [1] 15/8
double [1] 159/22
doubt [1] 158/6
doubted [1] 82/20
doubts [1] 16/15
down [62] 3/18 5/1
10/11 14/6 15/17
15/20 16/12 16/20
18/15 22/5 28/22
30/22 31/12 32/11
32/20 32/23 33/2
33/11 38/11 39/4 47/5
55/17 61/15 63/25
67/3 68/6 68/9 69/22
72/12 73/14 76/1 78/4
81/13 82/15 85/15
85/20 90/14 90/20
90/22 90/24 92/16
92/17 94/4 97/17
104/9 106/24 109/10
109/25 118/18 133/1
135/22 136/19 140/8
145/4 149/12 152/15
157/24 160/4 160/19
161/24 161/24 164/22
downplay [2] 49/1
49/8
downplayed [1]
80/18
draft [6] 87/23 96/25
101/7 118/20 118/23
138/7
drama [3] 97/11
97/14 97/14
Driver [1] 162/6
drivers [1] 162/1
driving [1] 93/8
drop [3] 64/3 64/4
64/7
drove [1] 161/22
due [9] 15/2 30/6
31/1 45/25 82/10
99/17 107/2 124/11
159/23
during [11] 7/12
13/10 18/19 68/13
82/2 114/16 130/14
144/3 165/15 171/15
178/1
duties [3] 75/5 75/9
75/14
duty [4] 75/22
Dynamics [1] 134/17

E

e-learning [4] 40/25
53/5 54/19 58/6

each [18] 31/17
34/14 35/3 62/18 66/2
66/5 79/11 104/5
123/11 123/13 128/5

154/23 157/5 157/7
175/10 175/22 178/1
179/15
earlier [25] 12/20
17/25 18/25 27/11
36/4 37/4 57/4 74/11
76/11 78/5 99/13
117/4 117/15 126/3
126/16 146/12 155/9
155/15 157/1 161/9
161/17 168/3 169/23
172/1 178/23
earliest [1] 159/25
early [3] 16/2 22/4
53/19
earnings [1] 162/16
easily [1] 138/13
edifice [1] 89/1
effect [10] 25/4 31/4
55/23 96/23 102/23
104/21 105/1 114/5
128/16 134/6
effective [1] 91/4
effectively [16] 8/1
8/2 15/16 18/2 22/6
34/1 34/15 35/14
45/24 77/17 77/18
109/23 113/11 113/23}
129/14 177/17
either [8] 60/10 71/5
107/25 117/12 117/17,
137/14 145/19 176/22}
Eldridge [2] 22/8
101/11
electronically [2]
25/12 25/15
elects [1] 130/15
element [3] 22/6 60/3
179/15
elements [1] 53/17
Elliot [1] 101/10
else [4] 64/6 84/7
84/7 163/11
elsewhere [1] 23/6
email [37] 10/9 10/12
10/12 10/20 10/22
10/23 10/24 11/6
11/17 11/24 11/25
12/11 12/13 12/19
12/23 13/17 14/1 15/1
15/5 15/6 15/8 15/9
17/18 22/2 60/4 60/19)
60/21 81/6 82/24
86/15 87/5 87/17
88/20 88/21 89/21
91/11 142/2
emails [10] 1/14 1/15
11/4 19/6 19/9 21/12
80/22 87/11 95/18
95/19
emotive [1] 115/18
employed [1] 68/10
employees [3] 20/11
20/17 21/6

employing [1] 120/17]
enact [1] 65/13
enacted [3] 64/13
104/10 119/6
enacting [1] 37/19
encourage [5] 57/7
117/22 165/18 178/6
179/17
end [18] 47/4 47/9
48/8 90/8 122/2
125/15 125/24 126/14)
126/18 126/21 127/6
127/14 127/19 131/25)
133/12 145/21 145/21
153/17
ending [1] 146/4
endorsed [1] 17/1
enforcement [8]
65/19 101/20 158/4
158/7 158/22 172/11
172/23 173/8
engage [4] 37/13
41/11 122/12 122/15
engaged [2] 54/6
133/24
engagement [9] 6/1
9/12 21/18 21/23
21/25 22/1 22/5 36/6
39/7
engaging [1] 43/1
enough [1] 45/22
ensure [8] 33/12
50/20 68/19 72/16
76/14 79/4 123/6
172/22
ensuring [3] 26/1
114/5 114/12
enter [1] 12/8
entering [1] 60/9
entirely [2] 59/13
66/2
entities [1] 7/5
entitled [3] 75/11
140/10 171/22
entries [1] 152/22
entry [1] 12/3
envisage [1] 147/20
envisaged [2] 37/25
122/9
EPOS [1] 173/23
equivalent [2] 73/13
133/3
equivalents [2] 114/7
169/9
Ernst [1] 82/19
error [11] 46/1 48/18
65/12 73/18 74/5
74/13 98/17 130/20
131/2 167/24 170/9
errors [2] 65/9
124/12
escalate [1] 140/19
escalated [6] 140/13
141/9 141/18 141/21

(55) disenfranchised - escalated
E

escalated... [2]
148/15 148/22
escalating [2] 140/22
141/11

escalation [4] 140/10
140/24 141/17 143/25}
essence [1] 141/17
essential [1] 40/14
essentially [2] 91/7
114/10

establish [2] 113/18
158/24

established [6] 52/22
104/15 140/15 142/16)
150/20 160/20
estimation [1] 63/14
et [10] 19/22 34/20
46/4 53/11 62/24
75/23 89/20 91/5
99/19 100/22

et cetera [10] 19/22
34/20 46/4 53/11
62/24 75/23 89/20
91/5 99/19 100/22
etc [1] 14/9

even [3] 19/16
106/11 131/14
evening [1] 44/6
event [1] 113/24
events [1] 1/24

ever [7] 28/16 72/15
83/12 87/2 94/13 95/2
133/4

every [7] 26/8 29/1
37/5 54/22 73/7 73/7
110/13

everybody [5] 36/13
53/16 81/4 92/25
93/10

everyone [3] 2/16
164/1 174/25
everything [2] 92/25
102/18

evidence [46] 1/19
2/6 2/19 3/2 5/14
15/16 17/25 19/15
21/13 22/3 25/2 27/6
27/11 30/3 43/2 50/17
59/25 68/13 70/10
81/22 91/1 98/2 98/8
98/9 100/10 101/16
102/10 104/13 105/15}
107/21 108/21 109/20)
110/10 110/17 117/15}
142/23 144/17 145/17
153/24 157/1 161/10
166/24 166/25 169/24}
174/5 180/3

evident [2] 46/13
93/15

Evidently [1] 85/5
exactly [3] 56/22

63/11 93/17

example [28] 11/14
17/9 18/4 28/11 32/24
35/20 36/18 39/22
40/12 41/2 41/15 46/3
52/10 56/6 65/9 66/12)
66/16 80/23 96/6
96/14 109/12 124/10
124/14 154/6 170/12
177/13 177/5 178/9
examples [3] 38/2
52/11 73/15
excellence [5]

124/16 177/21 178/5
178/18 179/11
excellent [3] 115/23
116/1 135/23
excellents [1] 116/3
except [3] 98/4 167/2
170/2

exceptional [1]
121/17

excerpts [1] 51/8
excess [2] 66/15
99/18

excuse [1] 46/23
Executive [13] 36/8
37/12 78/25 121/18
121/21 145/25 150/6
151/1 161/9 164/6
176/2 177/2 177/7
exercise [7] 30/5
30/7 30/23 30/23
31/11 31/19 57/12
exhibit [2] 32/1
151/25

exhibited [2] 137/10
160/12

exist [1] 119/7
existing [3] 44/18
51/19 159/11

exists [4] 62/20
126/25 173/20 173/25)
exonerated [1] 81/22
expand [3] 63/17
132/5 163/4
expanding [1] 180/3
expect [1] 52/6
expectation [1]

68/16

expected [1] 93/1
expects [2] 155/1
169/11

experience [17] 22/7
39/24 39/25 40/5 82/4
101/11 113/25 114/22)
115/2 126/6 126/7
135/21 153/17 175/24}
177/1 177/5 177/9
experienced [3]
55/14 84/19 86/8
expert [5] 102/16
102/16 135/9 163/22
163/25

expertise [2] 15/12
137/1

experts [9] 14/2
15/15 41/2 75/17
80/24 82/5 87/1
109/17 138/11
EXPG0000007 [2]
53/22 116/4

explain [7] 25/4 27/4
31/6 76/4 157/6
157/21 157/23
explained [3] 31/4
88/9 156/2
explaining [2] 28/25
87/24

explicitly [1] 154/25
explore [3] 43/25
44/7 60/3

exploring [3] 45/9
59/17 93/12
express [1] 100/9
expressed [1] 169/24
expressing [1]
116/20

expressly [1] 136/1
extensive [1] 135/19
extent [7] 11/19 19/7
19/14 19/16 94/9
161/18 170/24
external [18] 17/21
18/8 18/18 37/9 72/25}
75/18 76/8 79/13
100/16 107/4 114/1
114/2 160/22 163/14
163/22 163/25 174/9
174/25
external-facing [1]
100/16

externally [2] 34/25
101/1
externally-facing [1]
101/1

extra [1] 39/3
extraneous [1]
171/10

extremely [1] 11/25

F
fabrications [1]

86/21

face [3] 80/21 85/8
179/8

facility [1] 149/17
facing [3] 34/21
100/16 101/1

fact [17] 38/8 42/24
43/5 43/6 46/24 49/5
66/10 74/12 82/10
84/15 90/18 94/6
120/19 140/21 158/11
158/22 179/9

factor [4] 136/25
139/12 168/11 168/16)
factors [1] 171/10

facts [3] 21/8 59/14
60/13

factually [1] 21/11
failed [4] 75/8 75/13
122/12 122/15
failings [1] 94/9
failure [3] 66/16 87/4
96/10

fair [13] 23/11 40/5
40/6 43/9 53/12 57/16
57/17 72/2 139/16
140/6 167/25 168/6
168/6

fairer [1] 28/10
fairly [2] 10/8 56/12
fairness [1] 99/22
faith [2] 31/20 75/22
fallen [1] 170/15
fallout [1] 92/7

false [2] 101/22
172/13

falsehood [1] 86/18
familiar [6] 167/13
167/14 167/15 172/5
177/22 177/23
families [1] 87/14
far [2] 84/12 147/15
fascinating [2]
102/16 102/20

fault [6] 47/18 66/1
66/5 85/16 104/21
115/9

favour [1] 77/14
favourable [1] 38/9
February [4] 15/24
17/19 79/10 133/18
fed [1] 179/15
Federation [3] 10/6
17/1 175/23

feed [1] 117/23
feedback [46] 41/19
52/21 52/23 53/1 53/2
53/5 53/6 53/6 53/8
53/10 53/19 54/9
54/10 54/14 54/17
55/6 55/7 55/8 55/12
55/24 56/4 56/7 57/7
70/13 78/11 100/21
114/15 114/21 114/24)
115/5 115/19 115/20
115/20 117/2 117/8
117/17 117/18 117/20}
138/21 157/11 175/24,
176/25 177/4 177/11
179/10 179/20

feel [7] 21/14 22/21
37/3 55/15 59/9 95/10
119/24

feeling [1] 84/12
feelings [1] 79/19
felt [1] 34/24
fending [1] 91/8
Ferndown [4] 81/9
83/13 83/21 87/20

few [8] 3/9 16/20
24/4 36/16 36/24
41/17 53/9 87/15
fewer [3] 159/5 159/8)
159/15

field [4] 10/5 16/6
17/15 26/11

fifth [1] 172/16
figure [4] 103/23
103/24 127/21 159/7
figures [7] 23/18
61/17 63/4 63/5 105/6
115/14 118/21

files [1] 62/21

final [9] 12/4 71/1
75/25 82/16 101/13
105/19 107/3 160/23
174/3

finalised [1] 171/24
finally [3] 4/15 66/22
143/12

finance [1] 6/18
financial [14] 61/22
62/2 62/7 62/16 62/25
63/24 78/14 111/7
111/8 144/5 144/12
144/18 178/8 178/11
find [11] 13/14 13/20
17/14 58/18 59/6
59/14 85/2 135/12
152/17 173/22 174/9
finding [2] 81/23 91/2
findings [5] 51/6 64/8
69/3 113/2 114/17
fine [15] 2/15 24/12
73/10 78/17 80/14
97/23 104/2 105/17
106/16 106/17 107/15}
147/22 148/2 160/3
176/22

finishing [1] 147/21
firmly [1] 47/13

first [38] 6/4 15/23
16/12 23/8 25/21 26/9)
26/18 39/25 43/16
49/9 53/9 53/20 55/22)
62/22 80/12 80/13
87/19 88/13 90/3
92/14 95/12 96/22
101/23 101/24 108/18)
108/21 111/18 113/7
127/18 131/14 137/9
143/9 146/23 147/15
156/10 162/24 165/20)
176/14

firsthand [1] 84/17
firstly [7] 10/21 21/6
34/8 38/21 60/18
73/21 130/24

fit [3] 16/25 17/23
72/21

five [8] 7/1 39/3
50/15 89/24 109/10
116/18 168/13 168/14I

(56) escalated... - five
F

flagged [1] 14/20
flawed [1] 95/20
flow [2] 137/15
137/25

flows [1] 137/20

69/7 69/9 79/14 96/11
103/21
focused [5] 10/7
19/19 22/17 94/5
155/4
focusing [1] 94/11
fold [1] 1041/3
follow [12] 10/17
61/5 104/22 126/1
133/7 133/7 133/22
136/4 154/15 174/23
176/10 179/2
follow-up [2] 154/15
179/2
followed [4] 26/10
33/22 66/15 72/1
following [32] 3/21
4/20 22/2 23/2 24/15
24/17 31/22 33/5 35/7
57/12 60/19 67/17
67/19 78/11 79/12
92/6 104/7 105/3
111/5 112/6 117/23
133/22 134/7 134/10
148/17 148/25 149/2
149/22 151/5 160/21
176/21 180/10
follows [1] 103/24
footer [1] 31/25
footnote [7] 4/16
4/18 105/25 106/3
106/23 106/24 106/25}
footnote 19 [2]
106/23 106/24
footnotes [1] 105/20
foreign [1] 120/15
foremost [2] 25/21
26/9
Forgive [1] 139/7
form [9] 18/6 114/20
115/5 117/21 144/19
157/3 162/20 165/5
166/3
formal [3] 17/21
112/18 127/4
formalisation [1]
127/5
formalise [1] 133/9
formally [1] 113/4
format [3] 17/17
41/18 43/24
former [5] 71/5 77/10
120/4 121/9 142/20
forms [4] 54/10 56/7
4117/2 117/17
forth [1] 94/21

focus [7] 24/23 57/25)

fortunate [1] 94/2
forum [1] 142/8
forums [2] 70/16
157/12
forward [6] 5/23
12/18 18/25 90/2
130/3 177/6
forwarded [2] 10/12
10/13
forwards [1] 90/12
found [9] 12/2 12/4
14/2 28/17 48/11
48/16 55/7 139/18
149/1
four [8] 7/1 9/17
19/19 22/16 67/25
106/19 155/24 157/5
fourth [1] 68/8
frame [2] 150/13
150/20
framework [5] 34/23
35/24 143/15 143/17
150/17
franchising [2] 7/2
7/10
frankly [1] 102/19
Fraser [1] 113/2
fraud [2] 101/22
172/13
free [1] 41/21
freely [1] 41/20
frequently [1] 92/3
fresh [1] 98/12
front [4] 3/4 108/22
157/19 157/21
Fujitsu [19] 12/2 12/7
12/10 14/9 14/14 82/4
82/5 101/14 102/5
102/9 102/15 132/1
139/4 172/9 172/20
172/21 172/24 173/6
174/3
Fujitsu's [2] 19/1
173/25
fulfil [1] 35/14
fulfilled [4] 131/15
fulfilling [1] 170/23
full [16] 2/25 34/13
34/17 34/17 80/1
81/23 102/2 105/8
108/15 125/9 126/24
169/9 170/24 176/17
177/18 179/13
fully [8] 16/23 73/20
96/10 98/19 102/4
103/8 136/20 173/18
function [12] 6/18
16/6 65/2 67/13 72/20
72/21 126/15 127/7
130/18 132/10 148/16)
148/23
functionality [1]
134/3
functions [5] 112/22

112/23 112/23 124/4
124/5

fund [1] 44/10
fundamental [3]
44/18 49/8 102/17
fundamentally [1]
32/13

funded [2] 7/25 34/4
funding [2] 41/11
41/13

72/25 82/15 90/19
90/22 90/23 103/11
109/3 131/19 139/14
141/1 142/8

future [5] 70/20
120/21 143/4 160/10
163/19

G

gain [2] 12/9 127/20
gave [4] 2/6 98/2
166/24 166/25

GE [1] 35/9

general [7] 33/6
59/15 79/22 166/1
167/14 175/18 179/20
generally [4] 57/2
72/23 115/8 126/22
generated [2] 64/20
99/25

generic [2] 134/25
135/4

genuine [3] 48/12
48/16 49/15
genuinely [1] 71/25
get [39] 11/8 32/18
37/4 37/16 43/14
51/21 54/17 57/1
57/13 57/15 58/11
59/19 62/4 73/3 74/9
83/6 93/3 106/6 113/6
115/11 115/20 127/6
128/17 128/19 130/7
131/12 131/14 131/23
136/5 136/5 141/2
147/24 149/23 154/18}
159/21 163/25 164/14
174/24 177/18

gets [1] 123/19
getting [10] 6/19
35/21 36/12 53/10
56/16 70/13 87/10
115/16 146/13 147/8
Gilliland [12] 8/16
9/24 12/20 13/11 14/5
15/9 81/6 83/16 84/20}
84/25 86/15 88/16
give [25] 1/19 2/9
2/25 3/2 14/6 19/15
32/24 36/18 38/2
47/21 50/5 59/9 66/12
69/7 107/21 108/20

further [17] 2/14 20/5
32/23 33/2 46/21 47/5}

110/17 111/2 114/17
114/21 153/7 153/14

given [29] 2/4 2/5
34/17 45/5 46/3 55/11

79/19 83/13 85/17

100/9 109/11 115/5
119/9 119/13 128/17
147/10 149/19 159/9

gives [5] 15/25 69/8
81/3 114/20 155/24
giving [7] 18/18
38/23 50/20 75/12
100/10 152/23 173/14}
glad [1] 153/1
glitches [1] 14/12
go [80] 3/18 4/10
4/15 5/22 6/20 10/14
11/24 13/14 13/19
14/17 15/21 16/1
16/12 20/14 27/22
32/23 33/2 37/11 41/4)
41/14 41/16 45/3 54/2
56/10 57/19 59/1
62/12 68/6 68/9 71/19)
73/14 76/9 78/20
80/12 82/15 85/2
87/18 89/19 90/14
90/15 90/20 90/22
93/23 94/22 102/13
105/25 106/7 109/3
114/19 117/6 118/18
126/20 129/12 130/3
132/11 132/12 133/14}
135/22 136/19 139/7
140/16 141/8 141/22
145/9 145/13 150/6
152/14 154/18 154/23}
155/20 159/2 160/18
161/5 161/24 163/14
163/14 164/23 164/24}
165/17 167/16

goes [12] 12/4 16/20
60/17 75/7 105/14
125/4 125/9 128/8
138/7 138/19 154/11
1741/1

going [29] 1/14 13/21
49/25 53/3 54/20
65/19 78/16 86/6
90/15 92/22 93/25
101/1 110/12 122/1
130/12 131/12 132/5
132/19 141/18 142/22
143/1 149/18 168/20
168/24 171/11 173/6
175/2 175/17 175/18
gone [6] 14/1 17/13
21/12 51/21 83/7
87/15

good [42] 1/3 22/22

154/21 155/15 165/23}

3/10 4/17 22/14 32/17,

61/17 63/4 70/6 75/20)

163/23 169/25 176/10)

27/8 27/14 31/20
38/12 40/2 40/10
40/13 42/17 45/8
45/11 45/19 46/15
49/2 49/25 50/14 56/5)
56/9 56/22 71/7 71/24I
71/25 72/14 75/22
77/15 107/19 108/9
115/23 115/23 116/2
116/2 124/14 130/8
130/9 131/23 132/19
146/3 147/19 147/20
155/10 175/9
good’ [1] 115/1
got [25] 39/3 39/23
43/2 45/4 46/22 59/6
60/21 72/13 76/6 76/8I
81/14 93/6 93/14
95/24 96/3 96/4 96/13
106/17 118/20 137/25]
159/19 163/22 166/13}
172/2 177/3
governance [12]
70/16 71/3 71/23 72/4I
72/10 72/16 72/18
72/24 73/3 75/24
76/21 121/13
Government [2] 7/25
34/4
graduate [3] 6/8 6/11
6/20
grapes [1] 164/23
grateful [2] 107/23
180/4
great [2] 32/22
174/14
greater [4] 20/19
35/12 64/12 153/15
Greenhow [3] 60/5
61/5 176/6
grew [1] 96/9
ground [1] 74/6
grounds [3] 74/7
98/20 98/20
group [22] 20/10
35/22 36/8 37/12 64/5
67/18 72/19 77/10
77/14 78/12 92/6
97/11 113/3 142/16
145/24 161/4 161/9
161/14 161/16 164/6
166/4 166/13
groups [2] 65/24
166/10
grown [1] 94/17
guess [5] 146/18
147/15 162/12 165/19}
170/15
guessing [1] 83/10
guidance [6] 29/20
45/18 48/6 48/7 48/25
96/6
guide [19] 24/23 26/2
28/24 29/6 29/22 33/3

(67) flagged - guide
G

guide... [13] 33/5
33/15 33/18 34/13
44/18 44/25 46/6
46/14 49/18 49/21
118/25 119/1 119/5
guidelines [1] 167/8
guides [1] 44/15
guilty [2] 82/8 85/7

H

had [78] 2/2 8/3 8/15
10/3 10/4 10/5 10/7
10/25 10/25 11/10
11/20 12/25 13/25
22/9 26/1 26/9 26/12
26/12 35/1 39/2 51/9
53/5 53/7 53/24 54/9
57/4 57/15 57/19
59/12 61/12 69/2 69/5
69/11 72/10 72/11
72/11 78/24 79/2 79/4
79/16 80/25 82/22
83/13 84/18 85/9
85/19 87/1 88/24
91/18 93/2 93/6 94/7
94/13 94/22 95/1 95/3,
95/4 95/16 96/23
103/20 106/14 106/14
110/25 112/20 112/20}
115/13 115/14 116/6
134/6 134/12 139/7
144/21 154/15 157/11
158/11 163/24 164/6
165/14
hadn't [3] 95/14
96/13 124/5
half [7] 42/11 42/20
42/22 43/18 58/23
59/4 116/17
half-day [3] 43/18
58/23 59/4
hand [2] 23/18 49/13
handed [6] 32/11
63/25 72/12 92/16
92/17 94/4
handing [2] 85/15
85/20
handle [2] 92/7 92/9
handled [4] 123/10
124/25 125/4 125/11
hands [2] 61/2
107/25
happen [10] 24/3
24/5 26/13 46/17
52/10 79/10 100/5
132/2 143/2 153/5
happened [15] 14/16
26/6 46/1 51/22 60/24
65/1 65/10 87/25
102/21 123/16 124/14)
127/2 139/2 153/1
174/16

happening [3] 61/3
61/9 155/6
happens [2] 48/8
127/15
happy [4] 17/22
48/23 93/24 101/2
hard [11] 25/16 25/18}
25/20 26/7 26/20 27/7
27/12 27/14 27/20
55/12 91/17
hardware [1] 137/14
harsh [1] 151/10
has [105] 10/12
14/15 17/2 19/19
20/20 21/20 22/17
28/16 28/23 29/2
35/12 35/17 36/1 36/9)
36/17 41/17 42/4
43/20 46/1 46/12
48/10 53/15 59/25
60/7 60/14 60/15 61/4
61/20 65/1 65/10
67/14 68/13 68/15
68/18 71/22 72/15
75/5 75/8 75/13 75/20
76/2 76/6 79/16 81/16
82/9 82/11 82/19 86/6
87/23 88/2 88/3 88/9
90/24 91/3 91/13 96/9)
96/13 96/22 97/22
113/15 116/11 119/21
120/1 121/25 122/22
127/25 128/6 128/8
130/18 131/1 131/17
134/6 137/13 139/17
139/21 140/12 141/13)
142/12 142/16 142/19)
143/5 143/19 144/22
145/16 146/2 146/6
147/12 151/23 156/6
156/11 156/16 156/17)
157/3 159/3 160/8
161/19 163/21 166/13)
167/24 168/15 170/12)
170/15 171/3 172/21
177/17
hasn't [6] 22/9 96/15
127/2 137/9 137/10
139/1
have [326]
have’ [1] 144/4
haven't [12] 111/1
128/2 134/21 139/18
139/18 148/22 149/14)
149/15 152/8 170/12
170/14 175/3
having [14] 2/5 10/23
66/9 82/25 99/18
100/3 100/3 106/4
120/10 120/12 120/15)
146/22 150/12 162/22)
he [20] 1/21 10/4
10/5 10/7 10/25 12/21
13/16 13/19 13/21

16/8 20/22 78/24 85/1
90/9 90/12 98/3 113/2
165/12 176/8 176/12
he's [4] 90/21
head [25] 6/17 6/19
16/5 17/11 18/6 39/11
39/13 39/15 39/15
39/18 40/8 40/11
40/19 50/12 67/6 68/9
70/25 76/7 111/10
118/10 119/20 123/3
123/4 123/5 178/22
heading [1] 81/14
hear [7] 1/3 38/19
44/1 96/19 96/20
108/9 148/7
heard [11] 50/17 51/2I
59/25 65/4 68/13
70/10 86/7 92/25
112/10 119/14 147/25}
hearing [6] 1/5 15/23
16/14 84/17 108/11
180/10
heart [1] 96/2
heavily [1] 86/25
held [3] 30/7 61/2
85/14
Helen [1] 12/23
hello [2] 80/16
166/23
help [14] 13/6 58/8
59/2 88/15 92/23
112/12 113/10 118/17
127/17 146/17 155/12
157/2 157/6 174/25
helped [1] 82/5
helpful [4] 38/4
124/23 154/20 154/21
helping [1] 43/22
helpline [1] 88/2
helps [1] 35/2
hence [1] 67/22
her [12] 20/24 21/21
21/21 81/10 83/19
87/25 88/2 88/4 88/7
89/20 173/17 178/22
here [43] 3/19 6/5
11/5 15/17 17/13 18/7
19/9 21/8 21/11 25/24]
26/7 26/19 36/5 43/18
49/9 54/15 54/16 63/1
63/4 63/23 73/6 73/15
73/23 75/15 76/18
79/25 82/20 83/5 84/2
84/15 87/9 89/8 96/24,
107/1 115/22 116/19
118/18 123/19 133/16}
139/8 145/13 152/1
153/1
Hi [1] 80/17
high [4] 50/13 56/2
82/9 135/17
higher [3] 55/25
117/21 146/10

highlighted [3] 104/7
109/22 130/3

highly [4] 20/10

him [4] 13/16 13/20
85/3 85/3

hinder [1] 151/13
hindered [3] 150/21
150/23 151/10
hindsight [1] 15/11
Hindsight's [1] 83/23
his [7] 11/3 13/13
13/17 17/10 88/16
165/12 176/4
historic [2] 146/23
147/6

historical [3] 62/15
62/23 117/7
historically [1] 155/2
history [2] 81/2 141/3
hm [3] 105/22 108/24
111/4

Hobbs [2] 10/13 16/8
hold [4] 61/24 62/14
62/22 137/18
holding [1] 62/18
holistically [1] 53/18
home [1] 44/6
honest [4] 34/3 38/1
54/12 59/11

honestly [2] 25/17
83/20

hope [6] 2/16 78/13
93/3 98/12 100/15
127/16

hopefully [3] 37/16
90/5 100/17

HORice [3] 137/18
139/22 173/21
Horizon [114] 12/24
13/4 13/24 16/16
16/24 18/18 40/5
40/14 40/17 40/22
46/20 51/5 51/7 54/3
60/10 62/9 63/9 63/15)
63/19 63/23 64/2 64/9
64/16 64/20 64/23
65/5 65/5 65/8 65/16
65/25 66/4 69/3 79/15
81/11 81/14 81/17
81/23 82/5 82/13
82/18 83/1 83/14 84/3,
85/20 86/1 86/19 88/8
88/22 89/2 89/8 90/11
90/17 91/1 91/8 91/16)
94/8 98/23 99/25
102/9 102/11 103/25
104/3 104/9 104/14
104/18 105/2 105/7
106/1 106/12 106/20
107/13 113/19 120/10
127/25 130/17 130/22}
131/20 135/19 135/23}
136/2 136/7 136/13
136/23 136/24 137/1

137/14 137/19 137/23}
138/1 139/12 139/20
139/22 143/10 143/19)
158/5 159/24 163/2
163/12 163/16 166/2
168/9 168/10 168/14
168/16 169/5 169/10
169/11 169/13 169/16
1470/1 170/10 174/4
174/6 174/17
horrific [2] 86/7
87/13

hours [4] 41/23
41/25 41/25 42/3
how [56] 11/8 12/4
23/16 25/10 29/16
43/4 43/5 43/7 47/5
50/5 50/9 50/22 54/23}
59/18 61/10 67/18
69/10 73/4 88/17
91/14 91/17 92/2 92/7I
92/9 95/10 97/16
102/4 104/19 115/2
116/16 118/8 119/10
119/23 119/23 119/24I
120/11 121/14 123/11
124/13 128/17 137/7
140/13 146/19 149/5
149/8 153/15 155/12
157/2 161/18 164/14
167/8 173/18 174/11
174/16 174/19 174/21
Howe [1] 166/20
however [11] 4/9
14/15 21/20 28/13
48/1 79/2 127/8
139/13 154/9 165/16
178/23

Hub [8] 26/22 30/8
30/13 30/14 30/18
31/12 34/16 41/20
hugely [1] 87/13
Hulbert [5] 12/25
14/3 15/18 82/22 83/2)
hundred [1] 24/4
husband [3] 81/10
83/19 88/7

l accept [2] 49/5
173/10

l agree [3] 2/14 31/24)
43/13

also [2] 100/15
111/23

lam [13] 6/3 19/18
19/22 20/16 22/21
39/12 55/10 65/4
87/10 87/13 110/22
141/7 172/6

l apologise [1] 38/23
l appreciate [4]
70/18 81/12 99/20
154/19

(68) guide... -I appreciate
ask [8] 5/3 19/25
54/1 76/18 97/9
108/17 108/23 172/15)
lasked [2] 147/7
154/24
lassume [1] 85/9
I believe [14] 18/4
18/4 23/10 25/18 56/6)
61/1 72/21 115/6
118/24 120/16 121/25)
143/5 154/16 157/11
I bring [1] 87/16
I can [13] 22/20
25/11 25/19 27/2 38/2
44/13 57/22 62/5 66/5)
91/11 94/17 95/22
131/4
I can't [24] 21/10
23/19 25/23 26/13
29/3 29/10 29/15 38/1
50/15 83/7 84/18 86/5
86/10 86/23 96/19
99/7 121/22 155/2
163/5 164/11 164/18
166/15 177/13 177/19}
I certainly [1] 91/18
I come [1] 124/17
I couldn't [8] 23/20
58/18 95/15 118/11
119/12 119/16 166/9
176/19
I cut [1] 36/4
I described [1]
146/12
I did [8] 6/25 9/25
38/25 89/5 110/15
112/20 113/6 118/11
I didn't [1] 15/10
I do [20] 3/5 19/5
19/22 22/21 28/7
45/20 61/1 75/1 81/2
82/1 97/24 99/7
100/12 108/3 110/3
111/14 119/17 124/23
170/21 174/24
I don't [71] 5/22
10/24 11/4 11/22
12/13 13/6 13/18
13/23 15/7 17/9 18/12)
23/18 26/5 26/5 28/4
30/24 31/13 37/22
38/8 39/17 40/14 43/7
45/22 46/21 48/23
49/5 50/7 50/12 59/10)
72/8 73/22 78/10
78/20 79/23 79/25
80/12 82/25 83/3
83/22 84/11 84/14
84/23 84/23 86/2 87/1
89/4 89/19 91/17 92/2
93/13 96/11 96/11
103/1 108/1 113/25

128/24 133/6 134/8
141/10 141/10 143/17)
143/22 144/16 144/20)
147/20 151/16 159/21
162/25 166/11 174/8
174/22

l effectively [1] 8/1

I experienced [1]
84/19

I feel [1] 37/3

I find [3] 59/14
173/22 174/9

I first [2] 113/7
146/23

I got [1] 60/21

I guess [5] 146/18
147/15 162/12 165/19)
170/15

Thad [8] 8/15 11/10
35/1 57/19 91/18
112/20 112/20 139/7
I hadn't [1] 95/14

I have [33] 2/2 5/25
12/2 14/1 16/21 53/25)
78/10 78/18 80/7
80/20 80/22 86/7 86/8
86/23 87/22 89/15
89/21 92/23 93/22
95/16 101/13 111/18
116/7 128/3 154/15
158/13 159/10 159/11
166/18 166/23 172/16)
175/2 175/4

I haven't [3] 111/1
128/2 175/3

Ihear [1] 44/1
heard [1] 147/25

I honestly [2] 25/17
83/20

I hope [4] 2/16 93/3
98/12 127/16
linterpret [1] 104/25
I joined [6] 6/5 6/8
119/4 119/18 120/3
161/20

I just [12] 54/17 60/2
85/22 97/9 107/15
111/2 115/9 126/11
143/24 147/25 173/16)
175/12

keep [1] 2/18

I knew [1] 113/4

I know [5] 10/20 28/6
120/1 120/8 163/21
Ileft [14] 111/10

I look [2] 69/17
134/24

I made [1] 113/5

I may [3] 86/14 96/24
143/10

I mean [7] 17/6 22/16
56/21 61/12 86/5
89/25 92/24

I misunderstood [1]

73/9
I more [1] 123/20
I moved [2] 7/20
111/5
I must [1] 58/17
I needn't [1] 106/16
l only [1] 92/16
I ought [1] 99/22
I put [1] 174/13
I qualified [1] 111/4
lread [2] 15/10 66/22
I really [1] 80/20
I recall [1] 24/3
referring [1] 127/4
I remember [1] 10/25
I remembered [1]
95/12
I right [2] 66/25
156/20
I said [1] 37/4
I saw [2] 17/8 95/12
I say [2] 24/9 45/2
I see [4] 56/22 96/1
144/25 173/12
I sent [1] 87/11
I settle [1] 149/5
I should [10] 2/15
15/7 52/13 52/13 63/9
89/4 104/24 148/1
172/15 175/16
I started [1] 111/7
I stayed [1] 111/6
I still [2] 80/20 87/8
I stood [1] 22/5
I stress [1] 37/8
I summarise [1]
57/10
I suspect [1] 21/11
I take [6] 9/4 15/16
54/13 104/17 117/15
130/24
I thank [1] 108/18
I that's [1] 98/6
Ithen [1] 6/22
I think [152] 2/20
6/16 9/21 16/5 17/25
18/12 19/18 21/5 21/7
22/1 22/16 23/5 23/19
27/8 27/19 28/6 28/10
29/1 29/13 31/24 34/8
34/10 35/16 37/4 38/8
40/8 46/15 47/3 50/25
53/2 53/12 53/20 55/8
55/12 56/11 57/9
58/13 58/14 59/11
59/12 59/14 61/6
61/19 62/2 64/7 64/11
68/22 70/13 71/25
71/25 72/9 77/15
77/23 78/5 80/4 80/12
82/24 83/21 83/24
84/2 84/24 85/14
89/23 91/10 92/17
93/9 93/14 93/18 94/2

94/10 95/19 96/22
97/22 99/9 99/22
100/2 100/12 102/7
102/7 109/7 113/4
115/5 115/6 115/17
115/25 116/1 117/3
117/3 117/7 117/19
117/19 118/2 118/10
119/14 120/10 122/7
122/11 122/19 123/18}
126/2 127/4 127/10
128/9 134/25 136/3
137/4 138/4 139/22
140/21 141/11 142/15)
144/4 144/16 145/18
145/20 145/21 146/9
146/10 149/21 151/10}
151/11 153/13 153/13}
153/18 154/5 155/2
155/6 155/14 155/25
158/17 161/1 161/9
163/9 163/10 163/24
164/5 164/6 164/12
164/17 165/12 167/7
169/7 169/12 169/15
170/6 171/13 171/25
173/13 174/24 177/3
177/14 178/23
I thought [1] 39/1
I took [4] 15/4
I touched [1] 68/22
Iturn [1] 3/8
l understand [21] 3/8
3/15 4/1 4/12 4/21
24/6 24/12 25/2 63/13
102/25 106/2 109/4
111/11 120/8 123/18
149/5 158/20 170/22
174/8 179/10 179/20
I want [24] 3/3 9/20
10/2 15/21 22/24
24/13 39/6 39/13
44/15 45/10 55/18
61/16 69/16 103/8
104/2 105/19 108/21
113/12 117/24 122/19
124/22 130/9 133/13
134/22
I wanted [7] 2/10
56/19 57/25 58/2
155/18 176/14 178/14}
Iwas [32] 8/12 8/14
8/23 8/25 9/6 11/22
12/13 12/17 13/14
16/5 18/12 18/24
19/12 22/3 55/2 60/22,
80/23 83/12 84/11
84/15 84/24 86/25
91/24 94/2 94/4 94/9
94/11 96/24 97/13
112/21 112/24 147/11
I wasn't [5] 25/17
60/20 84/23 87/8
112/21

I went [1] 154/3
I will [5] 3/9 48/2 50/1
166/15 166/18
Iwish [4] 1/11
I won't [1] 92/4
I worked [1] 13/10
I would [26] 9/17
10/24 11/5 12/15
13/23 15/11 17/13
17/22 18/12 19/9 29/1
39/1 59/10 73/25 74/8I
78/13 83/7 83/8 83/9
85/8 86/2 86/10 92/2
93/4 100/20 104/5
I wouldn't [4] 13/25
15/13 19/12 91/25
I wrote [2] 121/23
161/20
I'd [10] 7/2 9/16
36/16 55/21 56/10
62/4 71/11 99/12
113/4 146/15
ll [26] 1/8 1/20 4/17
10/20 17/16 26/21
38/21 45/9 58/14
61/18 80/8 90/7 97/24
101/17 102/13 106/6
107/13 109/6 109/7
110/15 122/20 124/7
147/24 148/9 159/21
173/16
I'm [87] 1/25 10/23
15/10 21/5 21/14
23/18 24/4 25/24
26/13 27/4 28/4 28/11
30/24 31/13 34/2 34/3}
34/5 38/1 46/24 49/16
49/22 49/25 50/12
51/14 52/7 52/11
52/14 54/12 56/14
56/15 56/16 56/25
59/11 59/13 61/12
61/12 63/22 66/2
66/20 72/12 73/9
78/16 81/2 83/10 86/9
87/9 89/6 89/7 92/21
92/22 93/3 93/8 93/12!
93/15 93/17 93/24
96/19 97/24 101/16
102/7 102/13 102/15
103/7 103/8 103/12
103/14 107/22 107/25)
109/8 110/12 112/11
119/3 119/5 131/12
145/6 159/18 167/14
175/2 175/15 175/17
175/17 176/4 176/20
177/12 177/13 177/23}
180/4
I've [46] 6/5 6/9 13/10)
13/17 18/5 18/5 18/8
19/9 20/4 21/9 21/25
22/9 28/21 34/18 43/2I
61/12 74/11 80/22

(59) l ask - I've
87/2 89/4 89/9 91/23
92/25 93/14 94/12
95/1 95/3 95/4 95/23

103/23 106/17 113/8
118/10 132/2 158/11
159/19 166/9 166/15
171/8 172/2 177/16
idea [1] 159/19
identified [41] 14/25
62/8 67/20 70/1 96/5
96/14 105/8 130/15
139/19 159/3 169/8
identify [3] 126/9
127/12 170/13
identifying [2] 144/1
146/12

ie [4] 20/18 46/17
90/17 179/4

ie 5 per cent [1]
179/4

ie the [1] 90/17

ie they [1] 20/18

ie you [1] 46/17

ies [1] 152/20

if [216]

[1] 121/4
illustrated [1] 54/17
immediately [2]
124/3 134/20
imminent [1] 47/3
impact [11] 31/7
31/10 44/10 79/15
95/3 113/9 122/17
132/21 137/8 146/21
150/12

impacting [9] 137/5
137/7 137/8 137/11
138/3 138/8 138/21
138/22 146/24
implement [1] 33/13
implementation [2]
7/23 39/8
implemented [3]
48/24 118/23 130/21
implications [3] 12/7
69/3 69/11

implicit [1] 19/13
implied [5] 28/6
28/17 32/14 37/6 69/7
implies [1] 28/15
important [18] 29/1
31/12 37/3 37/4 42/13,
43/18 75/15 88/23
115/18 115/19 119/23}
119/25 120/12 136/8
146/12 147/16 149/23}
163/25

impression [1] 47/21
improve [3] 155/4
162/2 177/25

I've... [28] 80/25 85/1

100/16 100/24 103/14}

improved [2] 115/15
115/25
improvement [1]
155/16
improvements [7]
19/20 19/23 24/24
67/19 94/5 96/12
178/6
inability [1] 151/11
incapable [1] 173/14
incentive [5] 124/16
178/6 178/8 178/11
179/12
include [8] 22/11
50/3 66/25 100/19
101/8 135/19 162/16
170/7
included [1] 153/14
includes [1] 22/10
including [5] 19/21
20/8 40/2 60/8 165/4
inclusion [1] 142/25
incompetent [2] 84/9
84/12
incomplete [1] 62/1
incompleteness [1]
158/20
incorrect [3] 114/11
147/4 158/13
incorrectly [2] 84/3
89/11
increase [5] 35/17
35/19 117/16 150/9
150/10
increased [1] 115/16
incredibly [1] 87/11
incrimination [2] 2/4
2/18
incurred [1] 16/17
indeed [5] 18/22 90/6
124/5 163/19 173/16
independence [1]
TMNT
independent [16] 7/5
72/15 72/25 78/6
81/14 81/16 82/2
82/17 91/3 120/6
142/8 142/9 142/13
142/18 142/19 142/25)
independently [1]
17/2
indicates [1] 159/3
indication [2] 15/25
70/19
individual [7] 14/14
14/19 32/3 62/21
129/15 157/9 179/16
individual's [1] 40/9
individuals [5] 20/23
22/7 117/13 158/4
158/23
induction [4] 112/18
113/1 118/1 136/14
industry [2] 17/4

17/5

17/3 18/13 19/10
34/22 34/25 55/21
56/16 62/1 80/24
82/12 82/21 83/6
83/11 83/22 85/3
87/10 109/17 136/24
152/21 152/23 154/21
159/9 160/6 168/10
168/15
informed [3] 121/5
124/6 164/16
informing [1] 158/24
initial [7] 38/22 58/5
77/15 123/13 125/8
144/16 154/6
initially [3] 6/8 9/9
133/16
initiating [2] 148/14
148/24
initiatives [1] 155/4
inner [1] 136/7
input [5] 71/18 72/16
76/12 78/6 137/19
inputting [1] 18/20
Inquiry [35] 5/14
11/25 12/15 13/7 19/4
19/12 20/7 31/1 35/2
37/21 51/8 53/23
59/25 68/13 69/3 86/6
94/21 95/14 101/25
108/18 108/20 110/10}
110/11 113/8 113/15
116/5 130/14 155/7
163/7 163/24 169/25
171/4 172/7 172/18
179/7
Inquiry's [2] 5/15
176/5
ins [2] 13/24 26/11
instance [2] 20/24
86/24
instances [3] 57/11
159/5 159/15
institutional [1]
50/22
instruction [1] 70/7
instructions [2]
144/10 144/12
integral [1] 78/2
integrity [12] 12/7
13/5 15/3 15/4 16/15
65/5 81/10 81/15
83/14 88/8 88/22 89/8
intend [2] 1/24 173/7
intended [1] 179/13
intent [2] 161/7
169/24
intention [1] 121/3
intentions [1] 100/9
interest [1] 20/18
interested [3] 27/4

information [30] 11/4I
13/14 13/20 14/2 14/4

51/14 52/15
interfacing [1] 92/1
interim [3] 111/12
122/8 160/14
intermediate [2]
125/6 125/10
internal [9] 33/21
34/9 73/6 76/21 114/1
136/12 151/2 151/5
163/13
internally [2] 34/21
50/7
interpret [1] 104/25
interpretation [1]
135/23
intervene [3] 112/8
122/14 134/21
intervened [1]
106/14
interventions [1]
170/20
interview [2] 79/25
88/16
into [47] 5/22 6/20
6/22 9/10 12/3 12/8
21/21 28/7 28/17
36/20 40/11 45/6
50/23 65/1 65/3 78/6
87/7 101/3 102/3
104/8 104/19 105/9
111/9 112/15 113/6
119/5 119/21 124/20
124/22 125/9 125/14
127/13 128/7 128/9
128/21 128/22 128/25
133/4 134/16 137/11
138/7 146/14 168/18
170/15 173/2 174/22
179/15
introduced [4] 23/8
23/11 42/9 115/6
introducing [1] 64/10
introduction [1]
36/23
investigate [10]
43/12 43/23 48/4 55/5)
74/16 102/4 116/25
145/15 173/19 173/22}
investigated [10]
46/20 48/10 60/23
66/6 66/21 73/20
74/10 98/19 112/3
140/12
investigating [15]
42/10 43/10 43/14
43/17 49/11 58/1 58/2
58/19 58/23 59/5
60/18 60/20 88/15
122/20 130/21
investigation [42]
48/9 60/25 61/1 61/8
65/1 78/19 82/6 100/4,
102/2 104/8 104/16
104/19 104/20 105/3

105/9 124/24 125/9
139/10 139/17 139/23)
139/24 144/3 145/8
145/14 147/18 148/17)
148/25 150/19 151/13}
156/15 156/16 167/25)
168/4 168/5 168/6
168/9 168/17 168/18
168/22 171/15 173/2
174/2
investigations [15]
7/18 65/3 65/7 81/1
124/8 124/19 134/24
136/20 136/21 138/9
144/7 144/15 145/7
145/19 146/22
investigative [2]
47/19 49/2
investigator [2]
144/11 144/13
investigators [2]
91/3 136/4
involve [1] 137/3
involved [39] 7/22
8/7 8/8 8/20 8/25 9/4
9/6 11/19 11/22 12/16I
13/3 18/20 19/7 19/12
19/14 20/19 25/17
29/12 60/18 60/20
64/23 68/20 83/9
83/12 84/16 87/9
88/16 88/22 95/7
95/15 122/23 131/12
139/4 144/24 158/22
163/11 166/10 166/15}
170/11
involvement [7]
13/25 19/17 22/15
80/18 80/25 84/16
166/16
involves [4] 39/16
51/5 132/1 137/4
involving [1] 19/13
irrationally [1] 75/22
irrespective [1] 44/4
is [512]
isn't [21] 33/16 45/21
48/25 83/23 100/7
102/6 102/21 109/18
118/24 131/24 136/7
142/23 151/4 153/20
156/2 157/22 161/5
170/10 173/5 174/15
178/19
issue [21] 1/11 15/21
19/11 23/21 26/16
27/6 43/15 46/19
60/19 60/21 60/23
83/14 89/8 90/17
90/18 130/18 138/14
139/14 146/8 175/10
179/8
issued [3] 24/21
28/19 124/11

(60) I've... - issued
issues [69] 1/22 3/21
11/16 12/24 23/2
24/15 24/17 25/4
27/23 28/18 31/4 31/7
31/23 32/8 32/10 33/8
33/9 34/3 35/12 37/6
42/10 49/9 50/10
50/21 51/6 51/6 51/7
51/9 51/18 51/20 57/6
63/24 64/2 64/9 64/9
66/11 67/19 68/24
69/4 70/8 83/1 84/17
85/20 85/21 85/25
86/1 87/9 92/7 92/8
92/10 92/14 94/3 94/7
94/8 94/21 95/3 99/18
107/2 118/9 119/9
119/11 123/7 123/23
123/25 124/1 124/2
137/13 139/10 153/21
issuing [3] 112/2
124/15 162/10

it [472]

it's [139] 2/1 2/19
9/21 10/10 12/15
15/13 17/16 17/17
20/6 20/9 23/8 25/6
25/22 26/19 27/8
27/14 28/8 28/9 29/1
30/13 31/24 34/18
37/4 39/14 39/20
40/14 42/15 42/16
42/20 45/20 45/25
46/18 46/21 47/3 47/3
48/24 51/17 53/12
53/19 53/20 54/6
54/11 54/24 55/12
55/20 56/5 56/11
56/22 57/20 61/13
61/19 61/25 65/15
69/18 71/7 71/12
71/25 72/21 76/15
78/18 81/6 81/14
91/17 92/24 93/8
93/15 97/4 97/16
98/12 99/17 100/7
100/12 101/17 102/16}
102/20 102/20 103/7
103/11 103/12 106/18}
114/12 114/14 115/6
115/9 115/19 115/22
4117/5 118/11 118/12
118/15 119/22 123/10)
124/14 124/23 127/10}
127/11 127/16 128/24
129/11 131/4 132/10
138/4 139/3 140/5
141/18 143/25 144/25)
145/12 145/16 146/9
147/5 147/16 148/25
149/2 149/21 149/23
151/18 154/5 155/15

155/20 155/23 158/15)
160/12 162/19 164/4
164/5 167/1 167/17
167/19 167/20 169/25)
170/21 172/7 172/7
173/5 174/14 174/15
175/11 177/15
it! [1] 153/8
iterations [1] 32/12
its [19] 13/5 25/1
31/18 31/19 36/10
54/9 57/13 61/2 64/10)
72/17 75/5 75/9 75/14)
76/15 76/15 110/17
116/9 142/10 170/23
itself [7] 5/20 40/17
66/23 74/6 74/7
173/13 173/15
ITV [2] 97/11 97/14

J

Jacobs [6] 97/22
98/1 101/10 166/22
181/8 181/16

JANE [3] 108/13
108/16 181/12

January [6] 79/10
79/13 116/10 116/15
145/24 150/4

January 2020 [2]
116/10 116/15

January/February [1]
79/10

JFSA [1] 10/18

job [10] 39/13 39/15
40/9 69/14 72/17
84/16 134/25 135/1
135/25 155/10

jobs [1] 84/14

John [7] 10/10 10/13
10/22 10/25 11/2 11/7)
11/12

join [3] 6/4 110/23
164/23

joined [12] 6/5 6/8
15/8 68/2 68/4 68/6
112/19 119/4 119/18
120/3 146/24 161/20

joiners [1] 118/4

joining [7] 6/7 32/16

32/17 32/18 51/12

58/4 111/3

journey [2] 54/21

178/1

judge [2] 81/22 82/13

judgment [37] 3/22

23/2 24/17 27/23

27/25 28/18 28/19

28/20 31/7 32/11 37/6

42/10 50/11 51/7 51/7

51/20 63/25 64/2 64/9)

64/9 67/20 68/24 69/4

72/12 85/24 86/1 86/1

92/7 92/8 92/11 92/15)

93/11 94/3 94/8 94/21
95/3 118/9
Judgment/Horizon
[1] 64/9
judgments [3] 64/5
85/15 85/21
Julie [1] 29/13
July [8] 30/2 30/16
36/6 46/10 114/22
115/2 164/3 164/10
June [9] 22/4 30/16
52/22 53/1 53/2 53/20
64/15 115/6 117/20
jury [4] 82/7
just [106] 4/18 6/5
6/18 6/23 8/6 10/11
11/16 13/7 14/6 15/25)
19/25 21/12 21/17
22/9 26/16 29/16
29/22 30/2 32/15
32/23 33/15 43/19
46/9 49/21 51/1 51/14
54/17 56/24 57/19
58/24 60/2 62/4 63/25)
66/22 71/21 72/23
76/20 80/2 82/15
85/22 86/14 87/17
88/15 89/16 90/12
90/22 97/9 97/16
97/19 103/6 103/11
106/3 107/15 108/25
109/6 111/2 114/10
115/9 116/10 118/23
119/22 119/25 121/7
124/23 126/11 126/17I
127/10 128/24 131/13
132/11 132/11 137/2
138/3 141/4 141/7
143/24 145/6 146/6
147/25 148/20 153/2
157/1 157/4 157/20
159/21 159/21 161/5
163/4 163/13 164/5
164/8 164/22 165/8
167/20 168/2 168/3
171/8 173/16 175/2
175/10 175/11 175/12
175/17 176/22 177/14
177/16
Justice [2] 11/21
113/2
justified [2] 104/16
105/4

K

Karen [1] 51/3

keen [1] 71/11

keep [3] 2/18 62/8
89/1

keeping [1] 44/21
Keith [1] 61/6

Kevin [10] 8/16 9/23
10/2 10/3 12/19 13/10}
13/13 14/4 15/6 83/20

key [9] 29/19 33/5
35/25 66/15 90/21
91/6 100/18 162/1
167/10
kind [3] 94/12 136/7
165/19
knew [1] 113/4
know [58] 10/20 11/4
15/3 15/7 15/11 19/1
25/17 26/5 26/5 28/2
28/6 29/9 30/17 30/24,
31/11 42/17 44/1
48/21 49/23 50/12
50/14 51/5 51/8 52/8
55/9 55/13 56/19
56/23 57/4 58/24
60/14 60/24 67/18
70/8 73/24 75/21
80/12 85/3 86/7 87/10
89/5 89/16 89/19 92/2
95/22 104/2 107/6
108/17 119/18 120/1
120/8 124/10 131/6
134/9 136/5 163/21
165/11 166/11
knowing [2] 104/5
136/6
knowledge [32] 1/15
5/11 6/19 19/3 19/8
32/11 39/24 40/1 40/4,
40/13 48/1 49/7 60/2
63/6 82/4 87/5 110/7
120/10 120/13 120/15)
123/7 135/19 135/21
135/23 136/1 136/1
137/6 138/10 138/12
138/15 149/20 155/8
known [11] 11/25
13/23 13/24 20/20
25/12 65/9 83/9
113/20 137/6 138/20
172/7
KPMG [1] 111/5

L

lack [2] 59/15 150/21
lag [1] 146/19
language [1] 99/21
large [1] 90/4

larger [1] 7/5

last [21] 1/13 9/19
15/1 19/18 21/20
22/16 24/4 35/10
41/16 50/15 51/3
59/11 67/15 70/7
70/17 78/18 87/15
118/4 128/14 166/10
167/17

late [1] 22/4

later [5] 37/11 134/9
150/15 160/1 161/23
latest [1] 117/19
latter [3] 20/21 20/25
121/10

latterly [1] 111/9
lawyers [1] 75/16
lead [6] 13/13 90/18
112/9 114/16 139/11
161/15
leaders [4] 18/14
52/4 76/11 77/22
leadership [7] 9/8
39/24 40/9 40/15
77/10 77/14 178/20
leads [1] 59/3
learning [8] 40/25
41/20 49/24 53/4 53/5
53/11 54/19 58/6
learnt [1] 68/20
least [6] 20/17 27/18
42/22 43/11 73/4
89/19
Leave [1] 162/25
leaves [2] 170/25
170/25
leaving [1] 171/10
led [4] 66/18 105/10
161/14 161/15
ledgers [1] 14/20
left [4] 111/10 140/10
144/2 170/12
legal [15] 29/11
34/20 35/5 37/2 37/10)
75/12 75/16 75/18
76/8 76/12 76/13 82/3
83/10 165/9 165/11
length [5] 54/4 58/24
83/4 109/12 118/14
less [2] 54/7 165/22
lesser [1] 20/19
Let [2] 1/15 92/13
let's [5] 12/18 22/23
81/5 103/15 177/4
letter [33] 15/22 20/7
20/12 87/23 88/13
88/18 89/13 89/17
101/14 101/23 102/8
102/14 102/23 114/18)
151/22 153/6 154/4
154/4 154/6 154/14
155/18 156/3 156/7
156/10 157/3 157/14
157/21 163/6 172/4
172/5 173/10 173/13
173/15
letter 4 [1] 154/14
letters [3] 154/25
155/7 157/19
level [6] 51/13
135/18 136/3 137/1
147/17 164/15
levels [3] 42/18 54/7
55/1
liability [1] 29/20
liaise [1] 77/25
lies [3] 86/21 86/24
87/2
life [1] 106/19

(61) issues - life
L
lifecycle [2] 33/21
54/18
light [1] 103/5
like [34] 2/13 2/17
7/12 7/14 7/24 8/11
10/22 17/11 31/21
42/12 43/10 45/13
55/15 55/21 56/8
56/11 59/11 60/14
76/10 77/25 84/20
88/20 90/25 94/16
106/20 112/7 129/14
130/5 146/15 165/25
171/10
likely [4] 61/25
100/23 116/15 147/13}
limit [1] 145/17
limited [7] 6/2 16/22
16/23 19/16 81/16
81/23 82/7
limits [1] 141/3
Lin [1] 11/2
line [16] 3/14 6/16
10/17 12/20 16/10
69/14 75/20 76/15
90/25 97/17 111/11
119/4 119/20 138/1
164/21 172/2
lines [4] 16/20 17/14
18/8 109/10
link [2] 66/3 134/15
linked [2] 169/8
169/13
list [4] 32/1 90/8
127/22 176/24
listed [1] 160/17
listened [1] 147/25
listening [1] 22/20
litigation [4] 64/5
97/11 113/3 143/4
little [9] 13/7 34/7
82/15 83/24 90/13
90/22 90/23 103/11
160/1
live [2] 54/20 56/10
LiveNote [1] 96/25
load [1] 150/11
local [7] 9/3 128/9
128/15 129/8 129/21
129/23 132/4
location [1] 175/11
logged [2] 123/12
137/13
logging [1] 60/1
logs [1] 135/24
long [8] 20/17 46/12
89/10 90/8 93/4 94/18
97/3 107/5
long-term [1] 20/17
longer [6] 30/7 132/2
145/10 147/5 157/17
158/23

look [94] 9/20 22/23
24/13 25/6 27/22
29/17 31/14 32/21
36/2 37/15 39/13
39/23 42/7 44/15
44/23 45/10 47/22
47/23 50/2 50/4 51/24
63/13 67/24 69/16
69/17 70/22 73/12
73/14 76/17 77/24
78/19 81/5 90/13
93/22 106/25 112/5
113/12 113/13 115/17)
116/4 117/3 117/22
117/24 117/24 117/25)
118/15 120/14 121/15)
122/19 124/9 124/12
124/19 124/22 126/10
127/15 130/10 131/12)
133/13 134/22 134/24)
135/14 136/15 136/15)
136/18 137/11 137/19)
140/3 140/9 141/23
143/22 143/24 145/5
145/11 145/18 145/23)
145/25 148/10 149/18)
150/3 150/5 151/16
152/2 152/14 154/5
155/18 155/22 158/1
158/12 160/10 161/8
164/2 165/13 166/4
166/19

looked [10] 19/6 48/3
51/25 53/14 72/19
101/2 106/3 151/14
163/21 172/16
looking [24] 26/23
52/17 53/17 54/6
55/10 65/8 65/9 67/18)
68/14 71/8 71/13
71/15 77/21 77/25
103/13 107/12 113/6
114/2 120/21 142/16
145/6 155/7 155/13
162/14

looks [7] 31/21 80/21
88/20 101/10 139/24
139/25 140/2

lose [1] 89/2

loss [16] 12/9 48/12
73/19 87/20 98/18
127/20 139/21 140/15)
160/11 160/15 161/18)
162/1 162/3 162/6
165/22 168/24
loss/gain [2] 12/9
127/20

losses [22] 16/17
28/11 98/4 150/21
150/22 160/20 161/13}
161/18 161/19 162/5
165/14 165/17 166/1
166/6 166/7 167/2
167/22 167/23 168/21

169/1 170/2 170/3
lost [2] 93/1 94/7
lot [15] 34/18 58/21
65/5 70/10 77/19
84/16 86/7 86/17
118/13 119/21 120/9
132/10 146/13 146/14
151/15

lots [3] 79/13 79/14
99/18

LOUISE [3] 1/10 3/1
181/2

love [2] 57/1 57/7
low [5] 56/13 56/18
57/6 179/7 179/10
lowered [1] 70/19
lowest [1] 146/5
Lynn [2] 10/13 16/8

made [26] 1/23 3/22
13/1 14/19 14/23
20/16 24/18 26/21
29/9 32/6 32/9 32/24
35/7 37/8 49/15 68/21
72/6 76/2 81/21 82/11
82/13 101/24 113/5
143/3 146/2 165/7
main [4] 9/3 29/18
152/15 152/15
maintain [3] 80/20
87/8 160/18
maintained [2] 89/10
138/4
maintaining [1] 89/7
majority [4] 23/12
66/12 77/13 104/6
make [43] 2/16 3/9
14/9 22/21 25/19
25/20 26/11 27/19
33/21 33/24 35/21
37/2 40/9 45/8 45/11
45/19 46/7 46/12 48/2
48/24 49/2 49/23 52/4
65/8 69/13 70/24
91/11 109/4 119/24
120/16 130/7 130/9
131/23 132/19 138/13}
140/18 141/13 141/15)
151/21 153/2 163/22
166/1 175/18
makes [3] 71/1 90/4
102/23
making [30] 2/10
7/16 8/2 14/24 18/21
18/22 22/18 24/23
24/25 26/19 26/25
31/22 50/1 56/15 60/1
66/24 72/2 72/13
86/16 86/20 89/24
94/5 96/11 99/16
107/21 119/25 147/20
153/21 164/15 180/1
manage [1] 35/20

managed [5] 3/15
6/14 7/2 62/17 65/3
management [13]
9/18 22/12 41/3 41/5
41/20 53/11 68/10

69/9 76/7 94/15 123/9)

150/25 151/7
manager [10] 6/16
6/22 7/20 8/15 9/21
12/20 16/23 18/17
68/2 145/20
Managers [5] 6/16
18/21 18/22 60/9
94/16
Managers/Auditors
[1] 60/9
managing [2] 16/6
33/6
mandatory [2] 58/3
58/25
manner [1] 143/14
manual [2] 31/9
62/20
many [26] 1/22 23/16
41/7 41/17 42/16 43/4)
43/5 43/7 44/3 50/9
56/25 73/5 79/16 87/5
91/6 91/14 91/17 95/1
95/3 95/4 102/23
118/8 136/11 158/23
169/20 169/20
March [1] 80/5
Mark [4] 22/8 90/9
92/6 101/11
Marshall [31] 1/5 1/7
1/10 1/18 2/9 3/1 5/13}
5/18 16/22 20/25
21/17 21/21 79/2
80/16 87/22 89/18
93/6 93/14 97/1 98/2
99/6 103/7 107/20
117/4 155/14 166/25
169/22 171/25 172/3
174/13 181/2
Martin [1] 78/23
match [2] 127/21
128/13
material [5] 33/8
43/20 44/21 58/21
119/17
materialised [1] 57/8
materially [2] 75/8
75/13
materials [5] 47/1
49/22 49/24 53/11
59/19
matter [11] 1/8 14/2
18/16 41/2 71/16
80/24 109/17 125/3
138/11 138/19 166/6
matters [16] 4/8 5/24
7/11 9/5 13/15 19/25
20/5 40/2 43/10 60/17
75/6 75/9 100/20

111/22 133/3 175/13
may [45] 4/16 8/7
10/4 11/3 16/8 20/9
22/4 36/22 51/1 60/5
62/18 86/14 90/6
90/18 93/19 96/24
97/13 101/17 103/19
103/19 103/20 112/7
120/24 121/14 127/1
128/10 131/6 131/6
133/17 140/3 143/10
144/3 144/4 144/5
144/18 144/23 149/5
149/19 153/16 161/12)
164/8 164/13 172/4
176/11 177/14
Maylearly [1] 22/4
maybe [3] 90/15
142/19 159/25
McEwan [1] 51/3
McLean [5] 12/25
14/3 15/18 82/23 83/2)
me [56] 1/16 1/23 2/9
2/20 9/15 11/3 12/14
13/7 13/18 13/19
13/19 15/13 18/13
20/13 21/7 21/15
30/20 40/18 49/21
58/20 59/3 59/9 67/8
67/23 73/4 81/3 83/11
84/25 85/2 85/9 87/1
88/14 89/14 90/5
92/13 92/23 93/24
95/13 95/19 96/20
100/12 100/18 103/3
104/17 106/10 109/8
113/10 119/5 139/7
155/9 158/24 159/9
159/9 159/12 159/18
177/15
mean [16] 17/6 22/16
24/6 56/21 56/22
61/12 63/17 86/5
89/25 92/12 92/24
103/19 115/10 139/1
150/23 157/7
meaning [6] 27/25
28/3 28/8 28/12 164/4I
164/4
means [3] 103/24
160/21 165/22
means/deduction [1]
160/21
meant [4] 23/2 94/25
123/20 163/4
mechanisms [2]
69/16 122/13
media [8] 79/14
90/19 91/12 91/19
92/2 92/7 92/9 92/12
meet [1] 35/17
meeting [13] 10/17
13/21 53/17 71/3 71/4)
77/18 83/21 83/25

(62) lifecycle - meeting
meeting... [5] 164/3
164/6 164/9 164/23
178/8

meetings [2] 107/3
124/18

meets [1] 17/5

Mel [2] 41/6 65/3

MELANIE [3] 108/13
108/16 181/12

member [5] 77/20
138/12 173/3 176/3
178/20

members [6] 13/13
26/11 43/22 50/6 72/9
77/10

membership [1] 71/4

memory [1] 7/23

mentioned [5] 20/24
49/12 78/5 138/3
161/10

message [5] 46/8
46/22 85/16 132/6
132/13

messages [2] 25/14
91/6

messaging [1] 90/21

metric [1] 54/24

mid [1] 126/18

mid-month [1]
126/18

middle [2] 73/16
78/22

midway [1] 125/24

might [27] 23/19
32/12 37/18 38/3 46/2
48/25 51/19 56/12
72/4 85/4 93/21 99/11
112/6 116/25 117/11
127/2 128/11 134/1
137/8 139/11 140/25
141/1 151/12 158/13
174/11 176/21 179/1

Mike [4] 12/4

million [1] 91/4

mind [4] 2/20 55/20
56/25 137/1

minds [2] 56/25
98/12

mindset [1] 96/10

minimise [1] 58/9

minimum [1] 167/12

minor [2] 3/9 3/10

minus [1] 129/21

minute [5] 38/22
38/24 89/16 142/23
153/20

minutes [1] 39/3

misappropriation [1]
144/18

misheard [1] 147/25

mismatch [1] 144/8

Misra [6] 81/20 82/7

82/10 82/11 83/5 85/6
missed [1] 58/17
missing [2] 12/9
137/25
mistake [3] 49/15
132/8 143/11
misunderstood [1]
73/9
mitigate [1] 35/25
mixture [1] 147/2
Mm [3] 105/22
108/24 111/4
Mm-hm [3] 105/22
108/24 111/4
mobile [1] 7/24
model [4] 9/3 9/3
128/4 142/10
models [2] 9/3 40/1
modules [2] 40/25
51/21
moment [17] 26/15
27/5 34/12 37/24
44/12 59/18 61/18
70/16 72/22 89/19
98/6 121/22 122/7
142/22 154/13 170/22)
173/20
Monday [1] 17/19
money [4] 14/15
49/14 132/18 165/17
Monitoring [1] 112/4
month [10] 6/13
12/18 80/3 109/13
109/14 122/2 122/2
126/18 166/10 178/13}
monthly [7] 44/24
45/2 66/17 99/19
124/18 126/5 178/10
monthly/weekly [1]
99/19
months [6] 6/8 53/9
59/12 97/17 115/3
146/5,
more [73] 1/13 9/8
9/10 9/10 18/13 28/9
34/7 35/12 35/14
35/14 35/21 36/11
37/19 38/9 38/9 41/17
43/25 44/7 45/9 46/3
48/6 48/19 55/11
55/16 55/21 56/11
57/1 57/7 58/24 59/1
59/6 59/19 68/8 69/10
69/18 72/23 77/17
79/19 83/24 95/24
100/7 100/19 103/1
103/20 109/13 111/8
111/9 113/9 113/11
115/21 116/1 116/3
116/15 120/16 123/20}
127/20 128/4 134/6
136/9 146/16 146/17
147/3 152/21 154/21
154/21 161/1 161/7

164/16 164/19 165/23}
167/15 171/13 175/3
morning [8] 1/3 1/6
38/12 110/16 112/10
154/24 172/3 180/7
most [4] 103/15
118/13 120/25 122/19]
mostly [2] 94/15
94/16

move [13] 12/18
14/15 20/5 39/6 55/18
67/23 75/2 78/16 90/2
128/7 157/25 161/20
173/16

moved [5] 7/20 28/8
41/17 111/5 111/9
moves [1] 128/7

Mr [50] 1/11 1/12
1/13 1/17 1/17 2/23
2/24 10/15 15/9 17/6
20/8 38/25 59/22 61/5)
78/17 79/12 81/6
82/11 83/16 84/20
84/20 84/25 86/15
88/16 89/17 97/11
97/22 98/1 98/8
101/15 101/15 105/15}
107/24 108/14 113/2
147/23 153/1 166/22
167/17 167/17 168/2
172/4 172/4 172/17
172/19 179/23 181/4
181/8 181/14 181/16
Mr Allen [1] 89/17
Mr Bates [1] 79/12
Mr Beer [2] 1/12 20/8
Mr Breeden [1] 10/15]
Mr Gilliland [7] 15/9
81/6 83/16 84/20
84/25 86/15 88/16
Mr Greenhow [1]
61/5
Mr Jacobs [3] 97/22
166/22 181/16
Mr Justice Fraser [1]
113/2
Mr Misra [1] 82/11
Mr Patterson [2]
172/17 172/19
Mr Patterson's [1]
172/4
Mr Read [4] 1/13
4/17 167/17 172/4
Mr So [1] 153/1
Mr Stein [1] 167/17
Mr Stevens [15] 1/11
1/17 2/23 2/24 59/22
78/17 98/8 105/15
107/24 108/14 147/23
168/2 179/23 181/4
181/14
Mr Tuthill [2] 17/6
84/20
Mrs [9] 21/13 22/3

81/20 82/10 83/5 85/6
87/23 88/1 88/7
Mrs Athwal [2] 88/1
88/7
Mrs Misra [4] 81/20
82/10 83/5 85/6
Mrs Rachel [1] 87/23
Mrs van [2] 21/13
22/3
Ms [42] 1/7 1/18 2/9
5/13 5/18 80/12 80/15)
80/16 81/6 83/15
86/15 89/16 89/18
92/21 93/6 93/14
93/16 96/17 97/1 97/4
98/2 99/6 103/7
107/20 108/11 108/17}
110/9 117/4 155/14
166/23 167/13 169/22
171/25 172/3 174/13
175/6 175/7 175/9
179/22 179/25 181/6
181/18
Ms Marshall [20] 1/7
1/18 2/9 5/13 5/18
80/16 89/18 93/6
93/14 97/1 98/2 99/6
103/7 107/20 117/4
155/14 169/22 171/25)
172/3 174/13
Ms Page [7] 80/12
80/15 89/16 92/21
93/16 96/17 181/6
Ms Page's [1] 97/4
Ms Park [7] 108/11
108/17 110/9 166/23
167/13 175/9 179/25
Ms van [3] 81/6
83/15 86/15
Ms Watt [2] 175/6
179/22
much [35] 1/4 15/12
21/18 22/20 38/9
54/16 55/24 59/7
59/10 59/21 66/15
72/20 76/9 78/13
80/23 84/4 94/4 96/2
96/11 100/19 107/15
107/20 109/24 115/15]
120/16 132/2 134/21
136/8 152/23 154/21
165/16 179/9 179/9
179/25 180/2
must [5] 58/17 85/6
89/3 126/14 129/22
mustn't [1] 89/3
my [118] 1/17 2/7
2/20 9/10 9/16 9/17
11/13 12/1 12/16
13/11 14/1 15/12 17/8
17/13 19/18 20/2 20/4}
20/13 21/7 22/2 22/4
22/6 22/9 22/9 22/10
22/17 22/22 26/6

26/10 30/20 32/11
33/22 35/19 39/2 48/1
49/7 49/7 50/12 52/13)
52/19 55/10 55/20
56/24 56/25 57/9 59/3
59/14 60/7 62/4 63/6
65/17 70/21 79/24
79/24 80/20 80/24
81/1 83/10 84/16
84/25 85/2 85/8 88/19I
89/6 91/23 92/24
93/17 95/2 95/16
95/18 95/23 96/11
98/6 98/25 99/9 99/12I
101/5 102/13 107/6
108/17 109/15 112/21
113/10 113/25 115/9
115/25 118/7 118/12
119/12 120/18 121/23)
128/2 131/21 134/9
138/12 147/7 147/15
148/1 151/6 154/10
155/3 155/6 158/10
158/14 160/8 163/21
166/3 166/16 167/15
170/6 173/18 174/3
174/19 178/19 179/1
179/12 179/14 179/21
myself [6] 11/13
46/16 100/14 118/12
151/1 155/3
myth [2] 86/16 86/20
myths [5] 86/22
86/24 87/2 95/8 95/8

N

name [4] 2/25 108/15)
108/17 152/20

names [1] 20/23
National [3] 10/6
17/1 175/23

nature [2] 3/10 4/17
necessarily [6]
146/24 161/5 161/22
162/12 162/19 170/23}
necessary [6] 2/9 8/4!
52/24 69/25 87/25
88/10

NED [1] 101/9

need [50] 4/16 5/22
27/8 32/2 33/9 34/1
37/14 40/4 43/11
44/16 47/6 50/1 50/7
51/9 52/20 55/11
55/15 67/9 70/14
TAI17 74/14 75/4
78/12 78/20 89/1 93/7I
93/13 93/20 93/25
95/11 96/6 98/11
100/2 103/1 112/3
133/11 136/5 142/17
146/19 152/17 152/21
155/20 161/7 163/10
163/18 163/22 164/24)

(63) meeting... - need
N

172/18 173/25
needed [2] 36/23
93/10
needn't [1] 106/16
needs [7] 46/20
51/22 53/18 88/8
144/1 153/13 177/18
negative [4] 79/19
117/18 152/4 152/5
negligence [10]
48/17 65/12 73/18
74/4 74/12 98/17
130/20 131/2 167/23
170/9
Neil [2] 111/12
165/12
neither [3] 16/18
106/1 106/11
nervousness [1]
78/25
network [29] 3/23
7/21 7/21 7/25 8/19
9/1 9/9 10/2 10/4 11/2
14/11 23/13 25/10
32/10 32/16 91/24
102/19 111/24 112/4
112/11 122/23 123/4
124/9 124/17 125/5
134/22 146/1 146/2
149/16
neutrally [1] 1/16
never [9] 14/16 21/9
21/25 61/12 79/1
80/25 82/19 91/18
155/17
new [37] 7/15 7/17
9/2 14/12 23/22 23/22
24/2 24/8 24/21 28/15)
29/2 29/5 32/13 32/15
32/18 35/4 36/12
36/20 37/5 44/18 51/4,
51/12 51/15 52/14
53/8 54/21 58/6 69/5
100/17 118/4 146/24
146/25 154/21 156/9
156/9 157/3 176/2
newly [1] 58/4
next [29] 6/24 7/1 8/1
8/14 8/18 8/24 37/10
37/12 45/6 71/2 97/5
101/5 106/18 122/2
122/2 123/14 128/7
128/19 128/21 128/22)
130/3 130/7 131/11
141/15 153/5 153/6
164/19 166/13 166/16)
NFSP [28] 37/14
60/13 60/15 60/23
61/6 71/5 71/16 71/18
71/18 78/1 84/16 95/5)
101/2 143/8 157/12

need... [3] 165/13

176/6 176/7 176/9
176/16 176/18 177/3
177/7 178/14 178/21
17915

NFSP00001468 [1]
60/4

Nick [1] 121/18

Nigel [1] 87/17

nine [2] 68/3 168/8

no [60] 7/14 8/12
8/23 9/6 12/13 13/6
16/11 16/16 18/12
18/24 21/19 27/16
28/21 29/8 29/8 30/7

44/12 46/23 67/6
70/21 71/5 71/22
82/13 84/23 86/2 91/1
95/14 96/15 107/10
111/1 118/4 126/22
130/16 131/16 133/6
139/5 139/10 141/10
142/7 146/7 149/2
151/10 153/13 157/9
157/17 158/6 158/23

166/15 175/3
nobody [1] 2/1
nodded [1] 30/4
non [8] 77/11 77/13
77/20 162/20 163/20
176/2 177/2 177/7
Non-Executive [3]
176/2 177/2 177/7
non-voluntary [2]
162/20 163/20
non-voting [2] 77/11
7713

none [2] 27/16
107/11

nor [1] 16/18
Norbury [1] 11/2
normally [2] 79/9
117/21

not [191]

note [4] 87/17 90/12
90/13 124/15

noted [2] 15/9 28/14
nothing [3] 2/14 7/14
718

notice [2] 75/11
134/6

noticed [2] 115/21
133/4

notified [4] 121/5
121/8 121/24 122/17
noting [1] 64/14
notwithstanding [1]
2/7

November [2] 37/11
81/21

now [77] 3/4 3/8 3/10

166/20 175/15 175/23)

31/6 31/13 34/12 38/8)
39/20 41/13 43/2 43/7,

159/10 162/12 163/14)

5/13 5/18 5/22 7/23
9/8 9/13 19/25 22/11
22/23 25/19 26/17
27/15 30/11 35/3
35/20 35/23 37/7
46/25 47/3 47/21 50/9
51/4 53/17 59/22 61/4
61/8 68/3 68/5 71/10
76/22 77/21 80/8 81/7
81/11 81/12 82/9
82/21 85/10 86/6 86/8
87/25 88/4 90/7 95/24
96/20 98/8 103/14
106/17 106/22 107/3
109/3 109/17 110/9
117/9 119/20 122/19
126/17 133/13 134/15}
143/18 145/16 147/12
148/10 153/9 156/25
157/2 167/3 167/20
169/3 172/2 172/7
172/15 174/20 178/14
Nowadays [1] 96/2
NSRT [2] 145/8
148/17
NT [2] 3/23 24/18
number [35] 2/5 5/16
7/4 19/20 31/8 32/2
50/12 56/18 57/13
61/19 61/19 90/4
110/12 111/17 111/21
113/6 113/8 115/11
115/13 117/17 118/13
120/14 126/3 134/2
137/4 138/15 146/3
146/5 157/12 158/16
162/13 165/3 167/10
177/17 178/4
number 4 [1] 32/2
numbers [5] 55/25
63/5 65/24 66/22 73/2
numerous [2] 14/10
85/1

[e)

objective [1] 177/24
objectively [1] 93/22
obligation [1] 47/19
obligations [7] 28/9
31/18 35/12 38/5
38/10 49/2 50/18
obscure [1] 21/22
observations [2]
2/11 1514/5

observed [1] 52/3
obtained [1] 175/24
obtaining [2] 117/2
159/4

obvious [1] 2/16
obviously [14] 29/11
31/7 35/8 36/19 37/14
39/16 44/12 54/5
55/12 56/9 56/16
64/24 65/7 163/6

occasion [3] 81/18
81/19 141/5
occasions [4] 14/11
85/1 86/23 113/8
occurred [4] 103/17
105/3 134/1 144/5
occurring [1] 63/21
occurs [1] 105/14
October [4] 1/1 37/11
47/4 110/24

off [17] 13/14 13/19
14/2 17/13 36/4 50/12
91/8 121/18 128/13
140/25 141/6 141/9
141/20 145/1 147/15
154/16 169/3
offences [2] 106/5
106/15

offer [1] 153/4
offered [1] 16/16
office [177] 1/20 3/20
3/22 4/11 5/19 5/24
6/2 6/4 6/17 6/19 7/20
8/2 8/7 12/9 14/8 16/6)
16/22 16/23 17/11
18/6 19/8 19/16 20/11
21/6 22/25 23/21
24/13 24/17 25/2
25/25 26/15 27/4
27/17 28/9 28/16
28/20 30/25 35/13
38/10 39/8 41/8 42/21
43/12 44/3 44/9 46/13)
46/16 47/10 47/20
48/3 48/11 48/12
48/17 49/1 49/6 49/10
50/19 51/1 54/9 55/24

57/13 59/25 60/7 166/24
60/15 61/2 61/24 62/8] on [307]
62/14 62/22 64/10 onboarding [6] 9/11

66/23 68/2 68/11
68/19 73/19 73/20
74/4 74/20 75/4 75/8
75/13 79/12 79/15
81/16 81/23 82/7
84/13 85/14 85/16
86/12 86/16 87/6
89/11 92/18 93/1 93/6)
94/7 94/17 94/18 95/2
95/20 97/7 97/10
97/12 98/3 98/18
98/19 99/1 100/10
101/18 101/20 102/4
107/22 109/20 110/16)
110/21 110/23 110/25}
111/3 111/16 112/19
112/22 113/5 113/16
113/21 116/24 117/15)
117/22 120/6 120/23
128/4 130/15 130/20
135/9 135/18 135/19
138/5 139/21 142/8
142/23 143/3 153/11
153/22 154/13 155/1

158/3 158/17 158/18
158/23 159/4 159/23
162/4 163/18 167/10
167/13 167/22 167/24)
168/20 170/1 171/3
172/10 172/12 172/25)
173/7 173/18 174/16
176/1 176/13 176/25
177/10 177/17 178/2
178/6 179/6 179/14
179/18 180/2
Office's [18] 11/20
13/4 19/2 23/1 50/17
64/19 65/15 65/18
102/23 130/24 143/13)
156/21 167/1 167/4
169/23 169/24 171/8
176/1
officer [5] 45/23 51/3
111/13 121/18 176/10}
offices [3] 9/2 171/4
178/7
offs [2] 141/4 148/18
often [4] 11/3 13/13
24/3 92/2
Oh [1] 149/4
okay [16] 13/8 13/10
32/5 33/15 36/14
51/16 57/18 102/1
128/19 149/10 167/16)
169/15 176/21 177/14I
177/20 177/24
old [3] 24/9 24/9
164/9
older [1] 146/7
oldest [1] 23/8
Oldnall [2] 98/2

9/15 19/21 22/11
54/21 58/14
onboards [1] 23/23
once [10] 64/25
93/11 103/11 112/3
120/11 124/14 129/18)
131/8 139/17 141/14
one [75] 1/13 6/13
6/15 6/22 12/6 13/14
20/5 25/13 29/14 30/1
30/11 30/16 30/16
34/14 35/3 36/19
38/24 39/2 43/9 43/19
45/7 46/21 53/20
54/22 54/24 59/17
60/3 65/14 66/15 68/2
73/8 77/10 77/10
81/17 84/5 88/5 89/24)
89/24 90/6 101/13
103/20 106/18 107/3
109/3 114/25 115/1
115/23 115/23 116/2
116/17 123/18 123/19)
125/14 125/17 126/11

(64) need... - one
[e)

one... [20] 127/20
128/5 128/11 130/7
135/14 137/8 144/23
149/11 156/9 156/21
162/17 163/9 165/9
165/15 168/8 168/13
168/14 172/2 172/24
176/1
ones [5] 107/1
154/21 164/7 164/7
167/15
ongoing [7] 73/1
100/25 149/21 155/16)
156/14 161/19 163/8
online [2] 49/20 53/6
only [35] 9/18 20/13
20/22 21/20 38/22
43/7 45/25 46/17
49/13 53/20 64/15
64/24 65/10 65/18
69/24 70/8 75/19
89/21 92/16 96/5
101/25 103/14 104/15}
104/20 105/3 115/5
127/5 130/17 130/25
132/6 132/23 143/12
143/20 156/21 159/14}
onscreen [1] 133/19
onsite [5] 53/7 54/19
56/9 58/6 58/22
onto [4] 23/13 35/4
60/1 60/10
onus [1] 48/3
onwards [2] 58/15
105/13
open [6] 2/19 157/13
170/12 170/25 171/1
171/10
opening [1] 137/16
openly [1] 56/15
operate [2] 143/18
149/17
operated [2] 7/4 7/17
operating [7] 20/18
39/21 41/14 111/12
167/12 169/14 173/23)
operation [2] 53/9
128/4
operational [21]
24/23 44/17 44/25
46/6 47/1 49/18 57/6
58/9 66/14 99/17
100/20 111/9 112/6
119/20 124/15 139/25
177/21 177/25 178/5
178/18 179/11
operationally [3]
51/10 165/19 170/14
operations [12] 6/19
29/14 31/9 40/3 65/2
74/23 100/5 102/18
110/20 111/10 135/10

135/18
opinion [6] 26/10
81/3 120/18 163/21
165/12 174/19
opportunity [10] 2/10
46/25 114/20 127/7
127/13 141/2 170/7
170/16 170/21 170/23)
opposite [1] 170/5
oppress [1] 174/17
option [3] 45/15 47/8
146/16
optional [1] 45/13
options [15] 45/5
48/14 70/2 153/15
160/16 160/17 161/2
161/3 162/13 162/14
162/18 162/22 163/10)
165/14 166/5
or [221]
oral [3] 107/21
108/20 180/3
order [3] 1/18 14/11
155/5,
organisation [7] 6/9
16/3 18/14 19/23 57/2
76/11 94/9
organisations [1]
72/25
originally [1] 23/12
other [46] 13/15
16/17 26/25 31/3 31/5)
31/6 31/8 38/2 39/17
40/2 43/20 46/6 47/8
49/7 49/22 60/17 71/8
72/18 72/22 86/23
86/25 87/10 91/7
95/17 100/10 101/2
101/8 110/25 114/8
115/3 115/17 124/8
128/12 132/15 133/10)
133/13 139/5 139/24
158/11 162/15 165/3
168/22 171/9 172/2
173/14 175/10
others [6] 79/4 83/17
84/18 84/20 86/19
100/14
ought [2] 89/23 99/22
our [107] 6/22 7/2 8/3
8/16 9/9 10/8 17/14
18/5 21/19 22/19
25/13 25/20 26/11
26/22 26/25 29/11
34/19 34/22 34/23
35/3 35/8 35/23 35/24
36/12 36/20 37/2
37/10 37/11 38/12
38/22 39/21 39/22
40/24 41/4 41/14
41/17 41/20 46/16
47/1 48/20 49/24
50/13 51/2 51/23
51/24 52/2 53/10

53/11 57/3 58/22 61/7
61/14 64/21 65/2
66/12 67/17 68/23
69/7 70/15 71/18
71/19 72/18 72/19
73/1 73/6 75/21 77/19
78/2 81/17 85/17 94/9
98/12 99/22 100/2
100/6 100/7 100/13
100/14 101/9 101/11
102/18 102/19 120/18
124/2 124/11 128/4
132/10 134/13 136/3
136/11 147/14 147/19]
153/4 154/17 155/15
160/14 160/15 161/18}
165/9 165/21 165/21
165/23 169/19 170/16
171/13 171/17 174/1
ourselves [5] 39/3
46/17 132/9 163/11
174/24
out [64] 8/5 11/12
12/2 13/20 17/14
20/23 22/14 24/22
25/3 25/11 25/14
25/18 25/21 26/7
27/12 29/2 29/5 32/25)
36/13 37/5 37/17
42/21 47/3 50/8 52/1
52/8 52/11 53/7 54/24
59/19 60/17 71/4
81/13 85/2 86/1 89/13)
90/15 90/21 109/19
109/23 111/7 113/16
124/23 129/13 130/4
138/2 141/14 152/17
154/4 154/6 158/8
159/23 163/1 167/6
167/8 167/12 167/24
167/25 168/13 168/21
168/22 1741/1 171/11
176/24
outbound [5] 134/12
134/20 149/17 151/21
152/3
outcome [10] 61/7
92/18 99/17 122/17
140/6 140/24 141/2
141/25 142/6 147/18
outdated [1] 38/2
outlined [1] 142/11
Outreach [1] 7/24
outs [1] 13/24
outside [5] 11/6
15/12 85/2 120/17
153/18
outstanding [8] 13/1
74/17 78/11 129/5
129/7 140/2 146/3
156/5
over [36] 2/23 6/5
6/23 19/18 24/4 34/18
41/16 48/6 50/14

50/22 57/4 59/11
59/22 64/7 71/16
73/24 73/24 80/19
81/1 87/5 87/15 96/24
116/10 116/17 123/20
128/25 129/5 129/19
135/7 135/21 146/6
154/7 158/21 166/10
166/16 168/24
overall [4] 43/11 55/9
154/15 178/17
overarching [1]
33/16
overcompensating
[1] 38/23
oversee [1] 74/25
overseeing [2] 72/5
136/9
overt [1] 171/13
overtaken [1] 145/16
overturned [1] 71/22
overview [3] 33/19
111/2 161/13
Overview/Branch [1]
161/13
owing [1] 158/20
own [14] 35/19 44/6
44/6 45/24 54/9 62/18
75/5 75/9 75/14 92/19)
95/9 95/16 131/5
137/15

Pp

page [95] 3/11 3/18
4/7 4/15 4/16 5/3
11/24 15/23 16/1
16/12 20/14 23/3
24/16 27/23 29/17
31/15 32/21 36/2
39/23 42/7 45/3 48/6
48/6 50/4 52/20 54/1
62/6 63/3 63/4 67/24
69/22 69/23 70/22
73/14 75/2 76/17
78/21 80/12 80/15
82/16 89/16 90/3 90/6)
90/14 90/20 92/21
93/16 96/17 97/4
103/12 109/5 110/1
113/13 114/14 116/8
118/15 120/20 126/10}
127/18 128/19 129/17
130/10 132/12 133/14}
135/1 135/3 135/7
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140/16 141/23 145/5
145/11 145/13 145/25}
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page 10 [2] 78/21
158/15
page 101 [1] 110/1
page 12 [3] 3/18
24/16 32/21
page 14 [2] 76/17
113/13
page 16 [3] 54/1
145/11 145/13
page 17 [3] 36/2
69/22 120/20
page 18 [1] 73/14
page 2 [7] 11/24
27/23 90/6 140/16
152/14 161/24 164/25)
page 20 [2] 75/2
114/14
page 22 [1] 42/7
page 24 [1] 158/12
page 3 [6] 39/23 45/3
90/14 145/25 150/5
155/22
page 32 [1] 116/8
page 36 [1] 50/4
page 4 [5] 3/11 48/6
90/20 132/12 160/16
page 42 [1] 52/20
page 45 [1] 29/17
page 47 [1] 4/7
page 48 [1] 148/11
page 49 [1] 133/14
page 5 [3] 23/3 31/15
118/15
page 52 [1] 126/10
page 55 [1] 130/10
page 57 [1] 151/18
page 60 [3] 4/15 62/6
139/8
page 61 [3] 63/4
103/12 145/5
page 63 [1] 141/23
page 64 [1] 67/24
page 71 [1] 109/5
page 72 [1] 70/22
page 78 [1] 5/3
page 8 [2] 167/19
167/20
page 81 [1] 155/21
page 9 [1] 158/1
Page's [1] 97/4
paid [1] 42/24
panel [13] 71/6 71/8
71/12 76/22 76/23
76/24 77/2 77/3 77/4
77/11 77/13 77/16
142/9
panels [1] 71/11
Panorama [1] 90/15
paper [11] 122/1
122/1 145/23 161/15
161/17 161/20 161/22)
164/8 164/13 164/13
164/18
paragraph [58] 3/12

(65) one... - paragraph
Pp
paragraph... [57]
3/18 4/7 5/6 20/15
23/3 24/16 29/18
29/19 31/16 32/22
36/3 37/23 42/8 44/17
48/9 50/5 52/21 57/20
58/15 62/6 62/12 67/9
67/25 70/23 71/21
74/14 82/16 90/23
98/12 109/4 113/13
114/14 116/15 118/2
120/21 121/15 126/11

130/11 133/15 135/16}

141/23 145/6 145/25
151/18 155/21 158/1

158/14 158/15 161/25)

167/6 167/21 172/8
172/19 175/19 176/6
176/23 177/20
paragraph 10 [1]
3/12

paragraph 100 [1]
52/21

paragraph 102 [1]
133/15
paragraph 107 [1]
29/18

paragraph 108 [1]
4I7

paragraph 11 [1]
161/25
paragraph 113 [1]
126/11
paragraph 121 [1]
130/11

paragraph 123 [1]
151/18
paragraph 133 [1]
145/6

paragraph 140 [2]
62/12 141/23
paragraph 143 [1]
62/6

paragraph 15 [2]
23/3 167/6
paragraph 154 [1]
67/25

paragraph 162 [1]
109/4

paragraph 163 [1]
7414

paragraph 17 [1]
175/19
paragraph 176 [1]
70/23

paragraph 177 [1]
71/21

paragraph 198 [1]
155/21

paragraph 199 [1]
5/6

paragraph 20 [1]

31/16
paragraph 21 [1]
158/1
paragraph 24 [2]
158/14 158/15
paragraph 30 [2]
3/18 24/16
paragraph 31 [1]
32/22
paragraph 326 [1]
176/6
paragraph 36 [2]
36/3 37/23
paragraph 38 [1]
113/13
paragraph 4.6 [1]
98/12
paragraph 46 [1]
121/15
paragraph 47 [3]
42/8 57/20 120/21
paragraph 50 [1]
58/15
paragraph 53 [1]
114/14
paragraph 60 [1]
118/2
paragraph 66 [1]
172/19
paragraph 77 [1]
44117
paragraph 80 [1]
177/20
paragraph 83 [1]
50/5

paragraph 9 [1]
145/25
paragraphs [3] 87/19
103/6 142/11
paragraphs 143 [1]
103/6
paragraphs 35 [1]
142/11
paraphrasing [1]
143/10
Park [11] 65/3 108/11
108/13 108/16 108/17)
110/9 166/23 167/13
175/9 179/25 181/12
Parks [1] 41/6
Parliamentary [1]
90/17
part [60] 8/7 8/20
12/14 12/16 20/13
30/5 30/22 31/11
33/22 36/23 37/14
47/24 48/22 58/3 58/5)
58/18 58/20 58/21
58/22 62/4 65/7 84/5
84/8 84/21 86/16
86/20 86/20 88/19
90/10 92/5 96/10
104/21 112/21 113/1
123/24 133/7 136/14

140/5 142/10 142/17
143/5 143/6 143/18

145/20 149/21 153/17

154/3 154/17 155/6

155/12 155/15 155/18}

162/24 163/24 166/4
168/17 174/1 176/19
178/19 179/18
Participants [2] 80/9
80/10
particular [12] 9/20
36/18 40/15 41/13
59/13 68/16 83/4
86/24 87/9 119/17
123/18 136/6
particularly [8] 19/18
22/17 28/10 84/25
114/2 118/16 124/1
135/10
parties [2] 120/9
124/2
Partner [1] 47/6
partnering [1] 111/8
parts [4] 53/16 55/1
104/12 110/18
partway [1] 150/6
party [2] 31/17 112/2
passed [3] 48/13
123/14 123/20
passing [1] 80/24
past [12] 22/14 51/6
51/22 81/17 95/21
96/9 121/16 148/13
149/7 151/20 174/16
174/21
patterns [1] 52/23
Patterson [4] 101/15
102/14 172/17 172/19}
Patterson's [1] 172/4
Paul [4] 102/14
pause [2] 6/11 27/2
pausing [7] 21/3
36/14 46/9 47/23
51/14 121/7 168/2
pay [4] 41/15 42/4
65/20 156/22
payment [7] 17/5
155/24 157/13 157/14
157/18 157/22 178/11
payments [1] 179/16
people [50] 17/11
19/10 20/8 35/21
35/22 43/4 43/5 43/7
44/2 46/15 51/2 51/3
51/12 51/15 51/17
53/3 55/15 55/25 56/3
56/17 57/1 57/11
57/15 58/3 59/6 68/23)
73/3 83/4 83/18 87/10
90/5 91/7 93/19 94/14
94/16 94/18 94/24
95/1 111/22 116/20
117/5 117/17 119/8
123/21 133/2 142/19

148/25 153/10 158/11
158/18

people's [1] 55/22
per [10] 55/2 116/12

178/11 178/15 179/4
179/9 179/12
perceived [2] 38/6
95/18
percentage [1] 56/17
perception [1] 95/23
perennial [1] 175/9
performance [4]
31/18 66/11 67/7
99/17
perhaps [12] 13/20
36/21 44/6 48/19
53/14 66/14 79/19
90/12 107/6 130/4
1471/1 179/1
period [42] 1/25 1/25
2/6 2/8 4/19 7/7 7/13
9/20 16/8 18/19 44/24
45/7 47/9 68/14
103/15 109/12 109/13}
109/14 125/15 125/24}
126/14 126/19 126/21
126/24 127/6 127/14
127/19 128/22 128/22)
128/23 129/1 129/1
131/25 133/5 133/12
137/16 137/17 146/4
150/14 153/17 159/20}
178/10
permitted [1] 101/6
perpetrating [1] 95/8
person [5] 10/16
14/24 19/15 56/8
152/17
person's [1] 152/20
personal [1] 92/19
personally [4] 86/22
94/3 94/10 102/7
personnel [1] 60/8
persons [1] 85/6
perspective [4]
83/25 137/15 141/13
146/19
phase [4] 21/14 93/5
100/11 130/14
Phase 5 [1] 21/14
Phase 7 [1] 130/14
phone [1] 142/2
physical [3] 113/18
114/6 114/12
physically [1] 45/15
pick [1] 166/16
picking [1] 177/14
piece [5] 42/13 77/22
117/13 119/17 168/7
Pineapple [1] 78/20
pinpoint [4] 85/18
86/5 86/10 97/3
place [25] 4/23 8/3

117/19 124/10 147/14)

14/18 30/23 33/20
34/5 35/23 35/25 36/1
43/16 43/16 51/4
61/11 69/17 80/4
116/24 121/6 121/17
123/6 123/21 144/10
144/13 170/18 172/22)
174/15
placed [4] 19/22
35/12 149/19 160/6
plain [1] 90/4
plan [3] 26/15 27/6
44/9
plans [2] 116/24
148/18
play [1] 65/9
played [3] 20/25 21/9
96/9
plays [1] 56/24
please [129] 2/25
3/11 3/18 3/18 4/7
4/15 5/3 8/13 9/7 10/9)
10/11 10/14 11/24
12/18 13/9 14/6 15/21
16/1 16/12 16/13
17/17 20/6 20/14 23/3)
24/16 25/6 27/22
29/17 31/14 31/15
31/16 32/21 36/2 39/6I
39/13 39/23 42/7
44/23 45/3 47/15 48/6)
50/4 53/22 54/1 54/2
57/20 60/3 62/6 62/12)
67/24 68/6 68/9 69/22
70/22 73/12 73/14
73/15 75/2 76/17
78/19 78/21 80/10
87/16 88/13 90/3
90/20 92/20 103/12
105/25 106/24 108/15)
108/23 109/5 110/1
113/13 114/14 116/4
116/8 117/24 117/25
118/15 118/18 120/20)
126/10 127/15 129/5
130/10 132/12 133/13}
133/15 134/24 135/15)
136/15 136/18 136/19
139/8 140/9 140/16
141/23 143/25 145/5
145/11 145/13 145/13)
145/23 146/1 148/1
148/12 150/3 150/5
150/8 151/16 152/14
152/15 154/4 154/7
154/10 157/25 158/12)
160/10 160/16 160/19}
161/8 161/24 161/25
163/1 164/2 164/24
167/20
plummeted [1] 21/19
plus [2] 22/7 55/1
pm [6] 108/6 108/8
148/4 148/6 150/21

(66) paragraph... - pm
Pp

pm... [1] 180/9

PO [1] 60/9

pocket [1] 45/24
point [48] 11/10 20/5
21/4 29/16 35/10
36/18 36/19 46/15
49/12 55/18 57/19
59/3 59/24 74/9 75/15)
90/24 91/25 93/14
93/18 95/20 99/13
99/22 104/18 105/19
106/12 107/12 114/13}
114/15 118/21 118/22)
126/5 126/11 126/20
129/11 130/2 131/23
131/25 132/18 136/22)
142/14 143/24 144/19)
144/21 147/16 148/20
149/6 162/24 173/17
points [2] 58/2 90/21
POL [1] 88/10
POL00037518 [1]
25/6

POL00039629 [1]
134/24
POL00088956 [1]
10/9

POL00117439 [1]
90/3

POL00119947 [1]
15/22

POL00119963 [1]
ATT

POL00268061 [1]
92/5

POL00294728 [2]
12/19 81/7
POL00416991 [1]
87/16

POL00447943 [1]
143/25
POL00448000 [1]
167/18
POL00448046 [1]
39/14

POL00448048 [2]
127/16 132/11
POL00448072 [1]
140/9

POL00448081 [1]
135/15
POL00448131 [1]
44/23

POL00448197 [1]
154/5

POL00448205 [1]
76/17

POL00448206 [1]
73/12

POL00448229 [2]
136/16 145/11

POL00448231 [1]

145/23
POL00448241 [1]
31/14
POL00448254 [1]
69/18
POL00448256 [1]
117/25
POL00448295 [1]
151/16
POL00448322 [1]
150/3
POL00448362 [1]
160/11
POL00448411 [1]
20/6
POL00448520 [1]
164/2
POL00460000 [1]
78/19
POL00460458 [1]
161/8
police [1] 106/14
policies [57] 1/21
4/13 22/19 22/23
29/20 32/25 33/11
33/13 33/19 33/23
34/6 34/8 34/11 34/13
34/14 34/20 35/4 35/6)
35/10 35/11 35/15
35/18 35/20 35/23
40/3 64/10 69/12
69/15 70/10 71/19
76/15 100/8 100/13
100/16 100/22 100/23}
100/24 101/6 101/9
101/10 102/24 119/3
119/10 119/15 119/16)
167/7 167/8 167/13
167/14 169/23 170/6
170/16 171/24 175/20)
176/2 176/15 177/1
policy [45] 33/16
34/17 41/7 51/24
51/25 60/14 61/11
61/14 69/19 73/13
78/3 98/9 98/23 99/23
102/1 118/2 118/22
118/23 118/24 119/2
119/13 136/17 141/17,
167/17 167/19 168/1
168/3 168/20 168/22
168/23 169/5 169/5
169/17 170/4 170/4
1714/7 1714/7 171/12
171/14 171/17 171/23)
175/22 177/6 177/11
177124
pool [4] 165/5 166/1
166/6 166/7
pop [5] 131/22
131/24 132/3 132/5
155/8
pop-up [3] 132/3
132/5 155/8

pops [1] 127/24
position [35] 17/12
18/2 18/8 18/18 19/24
22/14 22/22 27/17
37/16 46/13 65/15
65/18 70/17 80/21
83/3 84/3 85/14 89/8
89/10 91/23 94/2
100/13 100/14 130/25}
160/15 160/18 164/12
167/1 167/4 170/1
171/3 171/8 171/8
171/13 171/17
positions [1] 93/10
positive [3] 24/24
42/17 117/18
possible [6] 1/16
52/5 62/19 72/24
87/24 88/11
possibly [4] 31/2
65/13 86/12 97/6
post [197]
post-'17 [1] 62/3
post-April '21 [1]
162/7
post-ClJ [1] 58/4
post-Go [1] 56/10
post-termination [1]
4/20
postmaster [173]
4/10 4/12 4/24 7/17
8/16 8/17 9/11 9/12
9/12 11/11 11/11
13/12 13/12 21/18
21/23 21/25 22/5 22/7
24/2 24/7 25/23 26/8
29/2 29/19 31/3 33/3
33/4 33/15 33/18
33/19 33/20 33/23
34/13 37/5 39/9 41/18
42/4 42/21 45/23
47I17 48/4 48/11
48/13 54/4 54/18
56/12 57/3 60/11
61/14 62/15 62/24
65/12 65/19 65/24
66/3 66/7 67/1 69/19
70/5 71/2 71/10 71/11
71/23 73/19 74/5
74/24 76/3 76/24 77/1
77/3 77/10 78/24
79/10 79/18 79/22
81/9 84/1 98/4 98/17
99/8 99/11 101/9
101/11 104/22 105/5
106/14 107/3 112/14
112/17 114/17 119/2
119/14 119/16 119/24
122/13 122/24 123/1
125/19 125/23 126/6
126/13 126/17 127/16
130/3 130/15 130/17
130/25 131/22 132/16
134/11 134/13 134/14]

136/17 140/7 140/14
141/1 141/11 141/25
142/1 142/6 143/12
143/20 143/21 144/1
144/14 144/22 144/22
147/18 148/10 148/13}
149/4 149/8 149/13
149/24 150/1 150/23
151/21 151/23 152/8
152/10 152/17 153/11
156/3 156/6 156/17
157/12 161/13 162/7
162/21 167/2 167/7
167/18 167/22 168/1
169/1 170/11 171/5
171/23 173/3 175/20
175/24 175/25 176/1
176/9 176/25 177/1
177/2 17715 177/7
177/9 177/10 178/18
179/6

postmaster's [9]
47/18 75/18 130/19
130/19 131/2 134/18
141/7 178/12 178/15
postmaster/person
[4] 152/17
postmasters [139]
7/4 7/5 7/11 8/5 8/21
11/15 19/20 22/18
22/20 23/12 23/16
24/21 24/25 25/10
25/12 25/15 25/21
26/12 26/20 27/9
27/20 28/23 29/21
30/10 32/18 33/1
33/17 34/15 35/7
37/13 38/9 39/16
39/21 41/9 41/11
41/13 41/15 42/14
42/15 42/24 43/22
44/1 44/19 45/5 46/23)
49/10 49/13 53/3 53/8
53/8 54/21 54/23
55/13 56/19 58/4 58/6
59/8 59/15 59/19 60/8
69/10 71/5 71/10 72/2
77/22 79/16 80/19
84/9 84/12 84/18
85/19 86/8 87/14
91/13 92/1 94/5 94/12,
95/4 96/2 96/7 96/12
100/18 100/19 101/3
101/8 103/19 103/20
106/4 107/8 111/21
112/13 113/10 114/20}
116/11 117/11 117/23
120/4 121/5 122/14
126/4 127/6 132/22
133/7 133/22 134/2
135/12 142/19 142/20}
142/25 143/4 146/15
148/15 148/19 148/22)
150/2 150/10 151/11

151/15 153/14 155/1
155/5 155/10 158/5
159/5 162/13 165/6
165/18 165/18 165/24I
165/25 167/9 169/1
171/15 172/24 173/8
174/20 178/1 179/5
179/17
postmasters' [1]
60/2
postponing [1] 80/3
potential [7] 7/15
67/20 69/25 112/9
142/18 176/10 176/25)
potentially [2] 80/2
141/4
pouch [1] 124/11
practice [3] 61/4
61/10 121/4
practices [1] 1/21
pre [3] 50/21 52/8
62/19
pre-2017 [1] 62/19
pre-ClJ [1] 52/8
pre-Common [1]
50/21
predominantly [1]
7/1
prefer [2] 108/2
108/3
preference [2] 44/3
131/21
pregnant [1] 82/10
premises [2] 24/2
44/6
preparation [2] 8/18
155/7
preparations [1]
130/14
prepare [1] 13/20
prepared [2] 20/4
83/16
preparing [1] 30/20
present [4] 121/20
142/3 158/6 164/21
presented [1] 36/6
press [7] 85/23
127/22 129/8 129/10
129/23 129/25 130/25}
pressed [1] 151/24
presses [1] 152/9
pressing [1] 132/19
presumably [5] 42/3
88/25 112/18 132/16
159/13
prevent [1] 43/15
preventing [1] 43/1
prevention [2] 162/3
162/8
previous [6] 15/9
50/17 51/9 101/16
102/13 141/4
previously [7] 27/11
64/11 133/16 156/6

(67) pm... - previously
P
previously... [3]
156/10 156/23 157/11
primary [1] 122/22
Principal [1] 135/3
principle [1] 169/4
prior [14] 45/6 51/20
53/1 53/2 62/2 62/16
63/2 63/2 68/24 96/1
122/14 127/13 129/22)
175/21
prison [1] 82/9
proactive [1] 112/1
proactively [2] 20/21
112/5
probably [10] 38/12
91/17 92/16 115/7
116/2 124/23 147/19
147/24 151/10 155/3
probe [1] 1/18
problem [11] 88/24
96/14 102/5 124/4
137/5 138/8 138/20
138/21 138/23 139/18}
139/19
problems [7] 81/11
88/10 108/1 137/7
137/8 137/11 138/3
procedure [1] 126/1
procedures [8] 22/19
22/23 58/9 66/14
67/17 69/15 72/1
76/16
proceed [1] 2/15
proceeding [1] 161/1
proceedings [5]
142/24 160/11 162/11
162/19 163/9
process [50] 35/3
37/15 46/5 46/9 68/15)
68/18 68/18 74/11
104/24 105/14 113/20}
117/3 121/3 123/17
127/13 127/19 128/3
128/16 130/23 131/25
133/22 134/12 137/5
139/4 139/9 140/10
140/11 140/13 141/1
142/14 142/18 143/5
143/6 143/18 144/2
144/6 144/8 144/9
145/21 146/7 147/1
150/17 151/13 160/22)
163/3 163/17 171/15
176/20 177/13 179/15}
processed [1] 140/4
processes [19] 14/17
16/24 17/3 22/19
33/22 67/17 72/1
112/6 112/8 112/9
123/11 126/5 133/6
135/10 172/22 174/23)
178/7 179/14 179/18

produced [2] 53/23
139/20
producing [1] 108/19
production [1] 40/20
products [1] 179/16
professional [1]
107/4
profile [1] 82/10
profit [2] 161/18
165/21
profitable [1] 42/1
programme [15] 6/25]
7/20 7/21 7/25 8/1 8/8)
8/18 9/1 9/2 50/24
79/1 79/12 90/15
91/25 178/18
programmes [1]
91/24
progress [10] 13/1
105/21 105/24 106/8
106/19 141/5 142/12
146/3 147/20 163/7
progressed [1] 6/9
progressing [1]
54/24
project [6] 6/25
26/24 36/7 36/9 78/20
177/21
prolonged [1] 107/2
prominent [1] 21/1
proof [1] 96/7
proper [1] 105/9
properly [5] 1/23
33/14 72/5 72/17
168/25
proportion [2] 50/14
56/2
proportions [1]
115/24
proposal [7] 36/7
55/5 122/5 161/14
161/15 165/8 165/25
proposals [7] 37/19
37/20 37/24 44/10
44/12 78/9 164/16
propose [1] 151/16
proposed [7] 37/8
37/9 38/7 47/24 75/17,
76/7 176/17
proposing [1] 37/15
prosecution [1]
20/20
prosecutions [2]
81/1 159/23
protection [2] 34/20
35/5
protocol [1] 121/14
proved [1] 42/15
provide [14] 13/7
40/9 56/3 64/11 77/17,
79/6 83/11 100/17
101/19 109/7 144/17
160/6 172/11 172/21
provided [15] 5/18

18/9 18/13 20/13
30/15 41/13 53/5 56/7
62/1 82/3 87/1 127/18
159/9 159/12 177/25
provider [1] 173/22
provides [1] 172/23
providing [4] 3/3
33/17 40/15 41/8
public [1] 20/23
publication [1]
100/15

published [6] 5/14
30/1 101/4 101/7
110/10 138/14

pure [1] 111/7
purely [1] 144/25
purpose [7] 16/25
17/24 19/11 36/10
72/22 135/16 160/13
purposes [2] 11/4
43/9

purse [1] 49/14
pursued [3] 99/25
158/16 159/15
pursues [1] 143/3
pursuing [2] 65/15
142/24

purview [1] 29/7
push [1] 127/13
pushed [1] 79/4
pushing [2] 37/1
146/25

put [21] 1/16 5/23
12/3 18/25 33/20 36/1
45/23 46/17 49/13
49/14 57/22 92/13
94/17 96/1 99/22
1314/7 132/18 159/7
169/22 172/22 174/13
Putney [1] 60/9
puts [1] 96/6
putting [5] 35/3
47/17 100/25 131/5
132/8

Qo
qualified [1] 1141/4
quality [5] 40/10 52/3
82/19 136/9 145/19
question [28] 18/5
27/8 34/18 52/14
52/19 56/6 56/23
57/10 71/7 77/15
96/22 97/5 97/13
98/25 101/5 107/6
115/10 115/11 118/16}
119/3 154/24 158/16
172/16 173/18 174/3
174/23 176/14 176/21
Questioned [14] 2/24
80/15 98/1 103/4
108/14 166/22 175/7
181/4 181/6 181/8
181/10 181/14 181/16

181/18

questioning [3] 2/12
96/5 172/2
questions [30] 1/12
1/24 2/8 13/2 78/15
80/7 80/8 80/9 80/11
91/13 97/22 101/13
103/1 103/5 105/15
108/18 110/13 110/15)
113/16 117/6 153/8
166/18 166/20 166/23}
175/3 175/12 175/15
175/19 179/2 179/21
quick [4] 94/10 94/10
97/25 101/13
quicker [5] 46/24
132/10 134/21 146/13}
146/14

quickly [6] 12/6
37/20 48/24 52/11
78/13 167/16

quite [31] 1/23 17/10
21/8 25/14 31/2 33/8
34/18 34/21 37/1
42/12 46/22 50/13
55/3 55/13 57/6 69/2
79/14 79/24 90/4 94/2
102/13 102/18 111/17}
115/18 118/11 120/13}
135/4 157/14 164/13
173/22 174/9

quote [1] 101/17

R

Rachel [1] 87/23

raft [1] 139/24

raise [6] 1/8 1/12
87/4 124/4 155/19
175/13

raised [7] 11/17
11/21 13/2 15/5 16/15)
83/14 176/7

raises [1] 126/17
raising [1] 1/21

ran [1] 8/1

range [2] 32/25 59/18
ranked [4] 114/25
114/25 115/1 115/22
ranking [1] 115/22
rate [8] 50/13 54/23
56/9 115/15 115/16
117/16 140/18 140/20
rates [3] 56/12 56/24
57/2

rather [10] 4/18 5/20
47/19 61/20 83/18
120/19 124/13 140/25}
141/20 149/15
ratification [1] 75/25
ratified [1] 73/8
rationale [1] 76/13
RCC [1] 70/15

reach [1] 11/12
reaction [1] 92/19

reacts [1] 20/22
read [28] 1/13 1/17
3/16 4/1 4/13 10/23
12/11 13/17 15/10
20/12 20/20 21/20
26/1 50/7 50/8 53/24
66/22 81/13 82/25
86/7 93/11 101/15
113/7 121/19 138/9
164/24 167/17 172/4
readily [1] 30/9
reading [3] 12/13
47/21 66/25
reads [3] 97/16
109/10 165/25
real [1] 102/5
realised [3] 30/17
93/10 93/19
really [16] 23/19
51/14 80/20 92/23
93/5 93/7 93/8 96/1
112/23 117/6 120/12
132/7 146/12 147/16
149/23 174/14
reason [20] 16/17
27/14 36/16 37/18
47/12 49/25 60/21
75/6 75/10 93/18 98/5I
99/12 100/4 104/3
104/4 104/15 105/2
152/24 153/3 168/23
reasonable [3]
167/25 168/6 168/21
reasons [8] 5/22
26/21 37/3 152/18
152/19 154/22 167/2
171/15
recalculate [1]
137/15
recalculating [1]
138/2
recall [10] 10/24
12/11 12/13 17/6 24/3)
29/10 49/16 79/25
164/11 164/18
receive [2] 55/6
153/8
received [19] 16/21
25/22 26/9 26/12
42/17 52/23 53/2
54/14 56/1 58/16
112/18 114/24 116/1
116/12 116/13 116/14I
117/20 156/7 177/10
receiving [3] 54/9
92/10 156/3
recent [3] 34/19 68/8
103/15
recently [2] 9/10
67/14
recheck [1] 130/4
recognise [4] 84/11
84/14 86/3 97/2
recognised [1] 85/18

(68) previously... - recognised
R

recollect [2] 13/18
95/15
recollection [3]
12/16 116/1 164/17
recommendation [7]
70/24 122/1 160/17
160/24 160/25 161/1
162/23
recommendations
[4] 162/3 162/8
162/9 164/17
reconciliation [2]
111/24 124/9
record [10] 5/16
25/22 26/9 61/24
61/25 62/14 62/23
110/11 113/19 176/5
records [3] 51/25
62/8 158/21
recount [1] 132/17
recover [14] 98/3
99/1 99/1 99/7 142/24
150/20 150/22 158/5
162/15 167/1 167/22
168/21 170/1 171/4
recoveries [2]
142/22 166/14
recovering [2]
142/10 164/25
recovery [24] 74/17
142/18 157/25 160/12)
160/15 160/20 160/23
161/2 161/6 162/4
162/9 162/10 162/13
162/19 162/20 162/23)
162/25 163/2 163/10
163/19 163/20 169/5
169/16 174/7
recreate [2] 137/21
137/24
rectify [1] 88/11
redesigned [1]
150/17
redress [1] 173/2
reduce [2] 43/10
43/11
reduced [1] 146/6
reducing [1] 146/3
refer [14] 14/17 15/4
23/4 29/19 29/21 34/8
37/23 42/10 44/17
52/21 67/25 97/9
99/12 128/9
reference [11] 5/16
58/18 90/14 90/16
92/5 92/24 110/12
139/7 157/9 158/13
172/17
references [1] 38/3
referred [12] 11/16
15/1 15/2 20/1 106/23)
117/4 126/2 144/20

154/4 156/25 171/25
171/25
referring [15] 3/23
22/1 25/7 29/23 36/4
63/22 97/10 107/1
116/9 127/4 140/21
144/6 144/14 162/10
176/15
refers [7] 4/19 12/24
15/23 27/23 46/7
81/19 168/7
reflect [9] 24/21 32/7
49/19 99/23 99/24
100/9 138/14 169/24
171/7
reflection [2] 15/7
79/24
Reform [3] 26/24
36/7 36/9
refused [1] 141/9
refuses [1] 20/21
regarding [4] 10/19
48/14 82/13 125/25
regular [3] 52/3
70/15 170/13
regularly [2] 25/14
53/17
reinstate [1] 30/9
reinstated [1] 4/24
reinstatement [4]
4/19 61/16 61/21
63/18
reinstatements [1]
62/16
reintroduce [1] 12/9
rejected [1] 176/12
relate [1] 63/9
related [3] 40/1 46/19]
81/8
relates [2] 1/12 106/3
relating [3] 29/20
40/22 158/7
relation [13] 54/3
62/10 62/15 62/23
75/5 75/9 79/9 99/3
99/25 101/14 113/15
175/20 179/11
relationship [3] 10/6
11/7 60/22
relayed [4] 14/4
19/10 83/17 83/22
relevance [1] 87/12
relevant [11] 13/15
54/5 62/4 75/6 75/10
93/5 119/16 123/6
124/4 128/24 158/21
reliability [2] 163/12
173/24
reliant [1] 41/1
relied [3] 84/13
103/25 134/11
rely [4] 74/19 139/19
158/11 163/14
relying [4] 18/13

83/10 86/19 86/25
rem [4] 66/16 162/17
179/16 179/20
remain [1] 23/17
remediation [3]
158/19 159/10 174/10
remedied [1] 70/9
remedies [2] 159/4
159/11
remedy [1] 14/11
remember [10] 10/25
17/9 82/25 83/7 91/17
92/10 98/11 98/15
121/22 163/5
remembered [1]
95/12
remind [1] 159/18
reminder [3] 130/17
130/21 131/24
remit [4] 10/8 29/13
85/2 89/6
remote [10] 13/25
14/7 15/2 19/8 19/10
19/13 80/23 83/1 87/7
87/12
remotely [8] 12/3
12/8 14/8 14/10 14/15}
14/19 14/23 19/2
remove [2] 21/20
45/15
removed [5] 22/10
37/25 38/3 38/7 157/8
removing [2] 37/23
157/15
remunerated [1]
42/25
remuneration [12]
8/16 11/11 11/15
13/12 160/21 165/23
178/12 178/16 178/19!
179/4 179/8 179/10
repay [2] 170/3 170/3
repayment [2] 65/18
148/18
repayments [1]
165/6
replaced [1] 130/12
reply [1] 12/1
report [13] 55/9 67/5
67/6 67/7 78/20
111/11 118/2 119/4
123/2 145/25 150/5
161/9 179/5
reported [4] 9/23
15/5 116/12 124/21
reporting [4] 8/3
16/10 111/11 176/7
reports [3] 55/24
123/3 123/5
represent [1] 169/19
representative [1]
71/12
representatives [4]
71/6 71/10 72/14 82/3

repudiatory [3] 73/15)
73/16 98/13
request [4] 30/14
109/11 109/13 114/24}
requested [1] 109/12
requesting [2] 139/5
173/1
Requests [5] 5/19
20/3 30/6 30/20
110/18
require [3] 42/2
136/1 172/25
required [4] 82/12
121/14 139/6 162/2
requirement [1]
43/13
requires [4] 41/23
42/20 102/2 135/17
research [1] 113/6
resigns [1] 67/1
resolution [26] 33/7
112/12 112/17 122/22)
122/24 123/4 123/7
123/23 124/17 124/22}
125/5 134/23 135/7
136/18 142/3 142/7
142/14 143/9 143/16
143/22 145/12 146/1
149/16 168/1 168/23
171/24
resolutions [1] 125/8
resolve [12] 88/17
125/3 126/19 126/22
129/23 133/11 134/5
138/19 147/1 149/3
149/8 150/12
resolved [6] 47/14
123/13 129/22 147/13
149/7 150/18
resolving [3] 122/21
139/17 147/9
resort [2] 70/7 70/17
resource [8] 34/1
34/7 36/1 140/22
146/2 146/18 147/8
147/10
resources [4] 34/5
35/17 35/19 49/20
resourcing [2] 33/13
34/2
respect [7] 1/13 1/20
2/17 8/9 50/18 56/2
59/4
respective [3] 33/25
53/13 57/5
respond [3] 57/15
68/17 150/12
responding [2] 30/5
57/1
response [16] 5/19
11/20 13/4 20/2 21/12}
53/19 56/9 56/12
56/24 57/2 110/17
1415/7 115/10 115/15

115/16 151/6
responses [7] 54/3
57/5 114/23 114/25
115/11 115/13 115/21
responsibilities [4]
9/13 22/10 111/16
111/18
responsibility [7] 4/8
8/15 9/17 10/4 111/19
111/24 178/17
responsible [15] 9/8
10/5 29/10 39/19
40/16 40/19 44/21
53/16 111/20 111/25
112/11 148/14 148/21
156/12 169/1

rest [3] 50/8 112/23
112/24

restatement [7]
24/23 25/3 25/8 26/2
29/6 29/22 31/5
result [20] 8/21 14/12
31/22 41/18 60/24
61/1 61/3 63/21 64/8
65/11 85/5 104/8
104/10 112/1 132/7
140/23 152/5 161/4
165/21 170/9
resulted [2] 79/19
98/18

resulting [1] 73/19
results [7] 21/19 55/3)
55/11 115/4 117/1
4117/1 117/18

resume [2] 107/24
180/6

Resumption [1]
147/22

retail [13] 6/1 6/16
22/1 30/6 30/8 36/6
37/1 39/7 44/2 72/21
111/10 112/23 178/20}
retailer [1] 114/8
retailers [1] 120/9
return [1] 117/16
returning [2] 86/14
117/17
review [83] 2/18 45/7
46/25 48/22 62/20
63/13 67/17 69/16
69/25 70/11 70/11
71/9 72/16 76/12
76/13 76/22 77/3 77/4
78/5 78/8 81/14 81/17
82/2 82/17 89/13 96/6I
112/13 112/14 112/16)
116/6 121/22 127/7
130/8 131/11 133/14
133/18 133/19 133/20)
133/23 134/3 134/10
134/16 134/18 136/3
137/17 138/12 140/5
140/17 141/12 141/12)
141/22 142/1 142/4

(69) recollect - review
R

review... [30] 142/8
142/12 142/13 142/15)
142/18 142/21 142/25)
143/1 143/18 146/16
148/16 148/23 149/21
149/23 150/9 151/24
152/9 153/13 153/24
155/16 155/21 157/1
160/22 161/4 163/3
163/17 174/11 174/20)
177/112 177/24
reviewed [17] 35/22
69/12 70/14 70/15
70/18 71/2 100/23
100/24 121/25 124/20
141/15 153/20 154/12)
171/17 171/18 175/22)
176/16
reviewing [7] 72/20
78/7 81/22 96/24
120/23 136/8 142/10
reviews [1] 145/22
revisit [2] 39/1 103/6
reworded [1] 100/23
Richards [1] 61/6
right [67] 4/15 8/5
21/9 22/18 23/6 35/3
35/22 37/24 38/14
39/6 48/3 58/1 58/13
58/16 59/3 59/21
66/25 73/9 82/23
84/14 93/21 96/3 96/3
97/23 103/9 103/15
105/17 105/21 105/24}
107/11 107/19 109/8
110/18 121/11 125/1
125/2 125/6 125/16
125/18 131/9 138/6
140/11 147/2 147/5
148/1 149/11 151/4
152/13 152/14 156/4
156/8 156/13 156/20
156/24 157/8 161/6
166/21 167/11 168/11
168/12 170/19 170/20}
170/21 171/16 173/5
174/5 180/6
rightly [3] 34/25
55/13 79/14
rights [4] 31/19
37/24 38/1 38/5
ring [2] 126/8 127/9
rings [1] 125/23
risk [5] 34/23 35/8
71/19 167/19 175/22
risks [2] 34/23 35/25
robust [8] 16/25
81/24 84/4 86/19 91/4
163/3 163/17 165/19
robustly [1] 68/17
robustness [1] 82/18
Rod [1] 12/1

role [62] 4/24 6/7
6/17 6/18 6/20 6/24
7/8 7/19 8/13 8/15
8/24 10/1 12/16 13/17)
16/6 17/13 18/10
19/18 20/25 21/1 21/7)
21/9 21/9 21/21 21/22
22/2 22/4 22/6 22/9
22/10 22/17 22/22
33/22 39/11 40/15
68/7 68/11 69/13 76/4
84/22 85/2 88/19
89/14 94/4 94/12
95/18 110/25 111/9
112/5 112/21 112/24
113/4 113/11 118/14
119/10 119/22 123/24}
135/5 135/16 135/17
136/15 150/1
roles [15] 6/10 7/1
9/8 9/13 9/14 20/17
20/19 21/23 22/14
68/5 84/11 95/22
111/7 111/15 136/12
roll [3] 13/15 128/14
129/19
rolling [3] 45/6
128/25 133/4
rollout [1] 36/20
rollover [10] 128/20
128/21 129/9 129/10
129/12 129/16 129/18)
129/22 129/24 129/25)
room [1] 166/19
root [2] 43/15 124/19
Rose [1] 12/23
roughly [3] 8/6 36/15
73/4
rounded [1] 164/13
Rule [9] 5/19 20/2
30/5 30/14 30/20
110/18 159/6 159/19
159/22
Rule 9 [8] 5/19 20/2
30/14 30/20 110/18
159/6 159/19 159/22
run [2] 120/13 165/19)
running [4] 33/10
44/2 170/14 179/19
rush [1] 147/4

Ss

sadly [1] 57/7

safe [3] 170/12
170/25 171/10

safely [1] 93/9

said [33] 12/20 13/10
18/11 18/25 27/6
27/11 30/3 32/7 37/4
37/18 42/16 48/25
52/13 61/2 72/4 78/24
85/1 86/25 89/4 89/9
92/14 98/3 98/15
100/24 116/11 132/24}

136/11 157/1 159/14
167/3 171/6 175/16
178/23
sake [1] 41/4
sales [2] 10/2 10/7
Sam [1] 108/17
same [8] 56/19 67/12
67/21 115/24 116/9
125/12 143/6 174/21
sanctioned [1]
121/21
sat [1] 29/13
satisfaction [3] 54/3
54/7 55/22
satisfactory [4]
45/17 45/20 45/21
115/12
satisfied [4] 16/23
55/25 116/16 116/17
satisfy [2] 18/11
139/20
save [2] 3/14 92/4
saw [6] 17/8 49/18
95/12 132/3 164/8
165/20
say [123] 2/1 2/13
3/14 3/21 4/8 4/23 7/2
9/17 9/23 10/2 12/4
14/7 14/18 15/11
15/15 16/20 17/19
19/12 21/3 23/8 23/11
24/9 24/16 24/19
25/19 25/25 27/17
28/25 29/25 30/22
32/1 36/14 36/16
37/21 38/15 41/7 42/8
42/18 43/9 45/2 46/9
47/23 48/16 49/3 50/6
50/15 53/12 61/24
62/6 62/13 63/9 64/4
66/5 67/9 70/23 71/21
72/6 74/15 75/7 81/2
81/8 84/18 84/21
85/22 87/4 89/15
91/17 91/20 95/7
95/22 102/20 104/6
113/14 114/15 114/19]
115/10 118/3 119/12
119/17 120/6 120/22
121/15 125/19 126/12
126/23 128/1 130/13
132/6 133/17 138/4
138/20 139/1 139/9
139/16 141/24 142/5
145/7 145/9 147/24
148/1 148/12 150/15
151/19 151/25 157/13}
157/17 158/2 158/17
158/19 159/2 161/6
165/25 166/9 167/8
170/4 170/4 171/9
172/15 175/20 176/22
177/4 177/10 177/24
saying [11] 54/13

55/23 81/10 83/19
93/15 104/12 127/25
129/11 132/12 156/21
172/7
says [57] 4/19 10/17
12/1 12/1 16/13 20/9
20/14 21/16 27/22
27/24 28/14 31/16
45/12 47/5 47/7 48/7
60/5 60/12 69/23 75/3)
78/22 81/20 90/9
93/14 106/10 116/8
127/18 127/19 129/5
129/20 132/3 133/16
135/4 135/8 136/19
140/11 140/16 144/2
144/13 145/14 149/4
150/8 152/2 152/15
155/23 156/19 161/25]
162/7 162/24 163/1
163/16 165/2 167/21
172/8 176/6 176/8
176/12
scale [1] 54/25
scandal [4] 79/16
102/21 169/21 174/15}
scope [3] 4/9 98/22
169/4
score [1] 54/24
screen [13] 3/11 5/1
23/4 29/23 109/6
109/25 127/24 128/19}
130/4 130/12 151/17
155/22 169/3
screens [1] 127/15
screenshots [3]
127/17 127/19 137/7
script [11] 91/7 91/10}
91/15 151/25 152/1
152/3 152/7 152/11
153/9 176/7 176/8
scripts [2] 154/1
154/25
scroll [7] 10/11 14/6
81/13 90/7 106/24
157/10 164/22
scrutinised [1] 37/20
second [13] 10/16
26/23 39/25 48/9
49/12 59/3 90/24
135/16 136/22 143/11
154/14 167/21 172/8
secondly [1] 108/20
secondments [1]
6/13
section [5] 46/6
58/16 81/5 167/16
167/19
section 2.5 [1]
167/19
security [1] 17/3
see [73] 1/3 3/13 5/6
10/9 10/12 10/12
10/14 10/16 12/14

12/22 15/22 16/1
177 21/5 23/5 33/6
38/19 54/11 55/3
56/21 56/22 63/24
64/3 64/14 65/22 68/9
73/16 77/9 81/25 88/4I
89/24 90/14 90/16
90/20 92/4 95/7 95/11
96/1 99/5 100/11
101/6 101/23 106/7
106/8 108/9 110/2
115/8 115/17 116/8
117/9 117/21 118/18
127/22 132/16 134/17)
135/1 135/16 140/3
144/25 148/7 150/7
153/6 156/18 157/10
157/14 160/17 161/12)
162/6 164/21 167/21
173/12 174/22 175/10}
seeing [1] 134/2
seek [11] 115/19
117/10 122/3 126/15
156/22 160/20 161/2
161/6 162/13 165/20
174/18
seeking [4] 49/1
117/16 122/5 172/25
seeks [1] 65/18
seem [1] 104/12
seems [1] 170/4
seen [9] 9/15 10/20
20/7 28/21 55/1 86/17
88/23 128/3 163/6
sees [1] 127/16
SEG [8] 4/10 122/1
160/15 161/10 161/23
164/3 164/14 165/3
select [2] 45/14
131/23
self [3] 2/4 2/18
93/15
self-evident [1] 93/15)
self-incrimination [2]
2/4 2/18
sell [3] 24/1 24/8
120/14
send [10] 17/14 25/3
25/14 29/5 37/16 88/1
88/5 88/13 151/21
153/5
senior [7] 9/8 18/14
76/11 77/9 77/14
77/22 93/10
sense [2] 39/18
57/10
sensitive [1] 88/12
sensitivities [1]
89/12
sent [18] 16/2 25/10
25/11 25/15 25/16
25/18 25/21 26/7
27/12 27/14 80/22
86/15 87/11 89/18

(70) review... - sent
Ss

sent... [4] 91/6
110/18 154/4 154/6
sentence [3] 12/5
62/22 109/10
sentiment [1] 79/22
separate [4] 28/24
62/17 76/22 77/6
separately [1] 148/24
September [1]
118/19
series [1] 101/13
serious [3] 33/8 94/1
122/11
seriously [1] 55/15
service [2] 147/17
150/16
Services [1] 7/24
serving [2] 82/9
175/25
session [1] 164/20
set [12] 24/22 60/17
71/4 90/21 113/16
124/23 137/16 161/4
167/6 167/8 167/25
168/22
sets [4] 32/25 80/11
167/12 168/13
setting [1] 176/24
settle [10] 45/13 47/9
129/23 130/16 130/22)
131/10 132/4 133/17
149/5 153/11
settled [5] 70/12
74/11 87/20 88/3
152/4
settling [3] 45/4
48/14 50/19
several [2] 152/5
160/17
SFL [1] 101/18
shadowing [1] 6/15
shall [4] 31/17 42/18
107/24 147/24
shareholder [1] 8/4
she [10] 16/25 79/3
82/8 82/8 87/22 88/1
88/2 88/4 88/9 89/20
shift [1] 23/1
shock [3] 92/18 94/6
94/8
shook [1] 178/22
short [8] 1/8 38/17
54/16 61/6 108/7
124/1 148/5 165/16
short-term [1] 124/1
shortage [1] 88/3
shortened [1] 34/14
shortfall [19] 98/5
98/23 104/4 104/14
104/18 104/19 105/2
106/2 106/12 106/20
128/12 167/3 168/18

169/6 169/7 169/8
169/16 170/2 170/8
shortfalls [23] 28/11
52/9 63/21 99/1 99/2
99/4 99/8 100/1 100/3
101/22 102/10 102/12)
104/9 105/8 105/10
142/10 158/5 158/7
169/12 171/5 171/6
172/13 174/5
shortly [7] 5/15 10/21
13/21 35/7 69/16
110/11 119/18
should [82] 2/15 3/4
3/15 4/1 4/12 4/22
4/23 5/6 15/7 24/19
24/20 25/18 26/5 26/6
26/10 27/9 27/11
27/19 36/21 45/24
46/17 46/17 46/23
47/22 47/23 48/4
48/16 49/3 49/13
52/13 52/13 63/1 63/9
64/13 70/7 77/23
83/24 88/4 89/4 89/9
91/2 99/23 99/24
100/13 102/9 102/11
103/21 104/24 108/1
108/22 109/22 112/3
112/13 120/5 121/1
126/7 130/17 130/25
132/23 141/20 142/20)
144/4 148/1 148/20
153/11 153/23 154/20)
155/16 162/4 163/15
170/7 170/16 170/19
170/20 171/7 171/17
171/18 172/15 174/4
174/6 174/8 175/16
shouldn't [6] 52/9
61/3 84/13 147/3
157/8 174/14
show [6] 13/3 47/18
72/8 115/15 119/21
136/19
showed [2] 49/21
104/14
showing [4] 18/3
105/2 106/12 137/23
shown [8] 21/13
54/15 54/16 91/3
95/13 95/19 158/5
170/8
shows [4] 72/1 72/4
104/18 140/13
sic [2] 1/17 120/25
side [2] 124/18 157/6
sign [1] 121/18
signal [1] 161/6
signature [5] 3/8 5/6
5/8 110/2 110/4
signed [3] 23/12
109/15 154/16
significant [11] 42/12

42/25 73/17 73/21
73/23 74/1 74/3 98/16
118/14 127/10 127/11
significantly [2]
95/25 115/16
siloed [1] 53/14
similar [5] 46/7 57/14
110/15 154/1 154/1
Simon [2] 98/2
166/24
simple [1] 87/24
simply [6] 7/14 29/5
104/14 114/4 141/6
179/17
since [24] 23/11
32/13 35/11 42/9
61/21 68/11 69/1 69/1
79/11 86/5 94/13 95/2
95/15 115/14 116/10
116/15 117/20 118/4
119/11 120/3 134/8
159/6 159/22 161/19
sir [60] 1/3 1/5 2/14
2/22 20/8 24/11 38/12
38/19 38/23 39/5 56/5)
56/22 57/17 58/5
59/11 59/14 59/23
73/6 73/11 78/15
79/21 80/7 80/11
89/22 93/3 93/12
93/18 96/16 96/18
96/20 97/21 97/24
103/4 103/10 103/18
104/1 104/5 105/11
105/16 105/25 106/13}
106/25 107/10 107/18
107/25 108/4 108/9
109/22 147/19 148/7
151/17 155/20 166/18}
173/12 175/4 175/8
179/24 180/5 180/8
181/10
sit [6] 10/1 16/3
67/11 67/12 119/2
167/15
sits [3] 139/22
173/20 178/20
g [1] 67/21
situation [4] 20/21
88/12 131/6 176/11
situations [2] 67/1
170/10
six [5] 6/13 50/15
59/11 91/4 112/20
six-month [1] 6/13
skew [1] 77/21
skills [2] 39/24
135/22
slight [1] 99/20
slightly [9] 10/11
14/6 15/21 53/14
77/22 97/16 115/25
143/11 164/22
small [2] 22/6 32/12

smoothly [1] 7/17
so [299]
software [4] 14/13
88/10 88/24 137/14
solution [1] 12/6
some [73] 1/12 1/24
2/8 9/9 9/12 10/4
10/18 14/6 21/8 22/4
22/9 22/23 23/24
26/25 28/15 28/23
32/12 34/2 34/7 35/19)
36/13 36/14 36/21
37/8 38/2 42/8 44/15
46/2 50/1 54/17 59/9
60/17 62/19 68/22
69/16 70/10 72/13
76/12 76/18 79/6
79/17 79/23 83/10
86/6 92/9 93/19 94/6
94/19 97/22 103/20
104/21 110/13 113/5
115/14 116/20 120/4
124/2 127/17 138/17
145/9 147/5 147/6
159/19 162/20 163/25}
165/5 166/23 169/20
171/14 174/9 175/13
175/18 175/18
someone [5] 84/6
84/7 123/19 147/12
170/25
someone's [1] 64/22
something [42] 2/17
12/15 27/8 30/25 36/4
41/3 41/5 43/17 43/24)
44/7 44/13 46/1 46/7
46/18 46/20 47/22
56/20 56/24 61/14
64/6 71/7 71/12 71/14,
73/1 77/23 77/25 78/2,
83/8 83/12 84/19 89/6
94/22 104/4 149/18
150/25 154/12 165/9
165/13 170/4 171/9
177/22 177/23
sometime [1] 158/10
sometimes [2] 11/12
124/2
soon [1] 88/11
sooner [4] 37/19
133/24 133/24 151/15)
sorry [33] 15/10
23/16 30/14 30/16
52/13 59/22 63/9 73/9)
75/2 81/2 86/10 87/11
87/13 90/22 91/20
92/21 93/23 96/18
96/19 106/8 115/9
121/2 123/2 130/13
139/7 145/11 150/25
158/13 159/18 166/7
166/15 175/15 177/13}
sort [12] 6/12 46/2
73/2 84/21 86/17

90/24 91/15 95/6
95/10 138/17 163/17
173/8

sorts [3] 9/5 86/22
133/2

sought [2] 16/21
172/22

sound [2] 92/21
170/15

sounds [1] 42/12
source [2] 124/13
158/25

sources [3] 135/11
176/25 177/4

speak [6] 2/12 2/20
5/23 55/23 147/9
159/13

speaking [2] 15/3
151/8

speaks [2] 173/13
173/15

special [3] 25/23
26/8 164/4
specialist [1] 135/17
specific [11] 11/6
14/9 17/9 20/2 20/22
23/18 37/23 38/1
58/18 59/4 135/5
specifically [13] 11/5
13/11 17/8 28/12
30/19 31/6 31/10
51/11 60/20 86/5
86/10 97/4 178/21
specifics [1] 104/5
specified [1] 121/6
spending [1] 165/17
spinning [2] 86/18
95/8

SPMR [2] 87/20
87/24

SPMs [2] 20/20 89/1

spoke [1] 91/19

spoken [3] 95/6
144/22 170/11

spot [1] 123/22

spotted [3] 14/24
124/5 127/2

spread [1] 86/23

spreading [2] 86/22
87/2

SPSO [7] 4/2 4/4 23/6
23/25 24/19 32/3 32/9

SRT [1] 62/9

stack [1] 115/3

staff [3] 16/18 33/1
173/4

stage [15] 8/8 10/21
37/10 56/5 107/4
123/13 123/14 125/10)
125/21 132/13 132/16
143/8 149/4 172/15
178/1

stages [4] 53/4 54/18
54/22 58/21

(71) sent... - stages
Ss

stamped [1] 52/11
stamps [2] 60/2
120/14
stand [2] 102/15
102/17
standard [10] 4/4
18/7 18/7 23/4 23/17
23/21 24/7 24/10 25/1
31/14
standards [4] 17/4
17/5 52/6 167/12
stands [5] 5/13 110/9
114/12 119/14 122/7
stark [1] 55/3
start [22] 2/11 9/13
22/24 58/17 63/25
103/15 106/19 108/2
110/15 113/5 123/16
128/16 130/9 133/25
134/20 139/23 159/6
159/19 162/4 162/24
163/2 166/7
started [3] 36/9 68/7
111/7
starters [1] 51/4
starting [3] 104/18
106/11 151/14
starts [1] 170/3
state [2] 21/11
108/15
statement [88] 3/3
3/11 3/13 5/1 5/4 5/10
5/18 5/24 9/16 20/1
20/2 20/4 20/6 20/25
23/4 23/6 25/25 29/17,
30/15 30/21 32/2
32/21 34/9 36/2 42/7
44/16 50/4 52/21
57/20 58/15 61/18
62/5 67/10 67/24
70/22 74/14 103/6
107/22 108/19 108/21
108/25 109/5 109/19
109/23 109/25 110/1
110/6 110/9 110/14
113/13 114/14 118/3
120/20 121/23 125/19}
126/10 130/10 133/15
134/10 141/24 145/5
148/11 150/4 151/17
151/22 152/11 153/6
154/3 155/19 155/23
156/1 156/18 156/25
157/7 157/16 158/1
158/12 160/8 160/12
167/6 172/17 172/19
175/14 175/19 176/4
176/23 177/20 180/1
states [1] 172/20
statistics [3] 43/7
54/12 55/8
status [2] 7/3 160/10

stayed [1] 111/6
steer [1] 35/1
Stein [1] 167/17
step [3] 22/3 37/13
125/6
stepping [1] 9/10
steps [15] 18/10
24/13 26/16 29/4
33/12 49/23 50/19
52/24 58/10 68/18
88/10 131/11 141/16
164/19 166/13
Stevens [17] 1/11
1/17 2/23 2/24 38/25
59/22 78/17 98/8
105/15 107/24 108/14)
108/17 147/23 168/2
179/23 181/4 181/14
still [19] 22/21 23/24
24/9 41/23 47/10
59/15 64/15 74/2
80/20 87/8 105/23
106/18 126/25 128/15)
139/19 146/8 160/25
166/7 166/8
stock [16] 14/9 41/3
41/4 60/10 66/16
113/18 114/6 114/9
119/22 119/24 120/12)
120/16 129/15 129/17)
129/19 129/22
stocktake [1] 114/5
stocktakes [1]
120/10
stood [1] 22/5
stop [5] 80/1 86/22
124/13 155/5 155/17
stopped [1] 61/4
stories [1] 86/8
straight [1] 134/17
strategic [6] 36/8
37/11 47/6 161/9
164/5 164/6
strategy [2] 9/9 40/3
strength [1] 139/25
stress [1] 37/8
stressful [1] 176/11
strike [1] 109/18
strongly [1] 37/1
struck [2] 4/22
109/22
structure [1] 11/14
structured [3] 51/4
69/2 94/20
struggle [1] 57/15
struggles [1] 57/13
struggling [2] 56/14
112/8
sub [1] 178/7
subject [9] 10/17
12/23 14/2 41/1 80/24
87/19 109/17 138/11
141/3
subjected [1] 17/2

submission [1]
175/21
submissions [1]
16/15
subparagraph [3]
57/25 148/12 178/5
subparagraph 81 [1]
178/5
subparagraphs [1]
178/4
subpostmaster [24]
4/5 23/5 23/17 23/21
24/7 24/8 24/10 31/15
32/7 33/8 38/6 83/13
83/18 84/6 84/8 99/2
121/9 141/18 149/14
149/15 153/23 156/11
170/2 178/8
subpostmasters [41]
3/20 10/7 11/21 17/2
18/23 21/2 21/10
22/25 23/16 23/22
24/14 26/1 28/16
32/16 34/10 40/23
44/11 45/18 45/19
50/18 54/14 57/23
59/8 61/20 98/4 101/5
101/19 101/21 152/4
152/7 156/22 158/8
169/20 169/21 171/22
172/10 172/12 173/2
174/7 174/17 175/23
subpostmasters' [1]
8/9
subsequent [3] 64/8
64/14 85/24
substantial [2] 57/13
122/19
substantively [1]
11/8
success [2] 140/18
140/20
successful [1] 159/4
such [19] 7/11 8/10
28/25 31/8 31/11
33/16 82/8 82/13
99/15 99/18 100/20
100/22 113/10 130/21
144/6 159/14 167/23
170/7 170/17
sufficient [5] 40/23
153/9 178/16 179/3
179/4
sufficiently [2] 89/12
132/22
suggest [5] 28/21
43/2 93/4 112/7 120/8
suggested [10]
26/17 27/1 28/23
65/25 120/4 143/8
144/23 165/9 176/8
176/9
suggesting [1] 89/17
suggestion [2] 120/7

166/8
suggestions [1]
176/12
suggests [3] 139/13
152/11 177/16
suite [1] 167/7
summaries [1]
175/18
summarise [2] 57/10
111/15
summarises [1]
162/1
summary [11] 6/12
92/8 92/11 92/12
109/7 140/11 144/2
150/6 151/1 151/2
166/12
summer [1] 32/25
Super [1] 172/2
supply [1] 59/7
support [93] 33/1
33/3 33/4 33/6 33/10
33/15 33/17 33/18
45/7 47/11 47/15
48/13 48/14 49/10
53/7 58/6 69/10 69/19
73/13 74/24 86/18
101/18 101/19 102/11
111/19 111/23 111/25)
112/11 112/15 119/3
119/20 122/13 122/23
122/24 122/25 123/1
123/4 123/24 124/6
124/17 124/24 124/25}
125/5 125/20 125/23
125/25 126/8 126/16
126/23 127/9 127/11
133/10 133/11 133/23
134/4 134/13 134/19
134/22 135/1 135/2
135/8 135/11 136/11
136/12 136/17 137/12
137/12 144/1 146/1
146/2 148/11 148/13
149/13 149/16 150/1
150/16 151/20 152/10
153/4 153/16 154/23
155/5 155/11 165/20
167/18 170/18 171/23
172/9 172/11 174/6
174/11 174/20 177/25)
supported [2] 39/11
167/9
supporting [1]
111/21
sure [44] 7/16 8/2
10/23 20/16 23/20
25/20 26/11 26/19
27/20 28/12 29/15
33/21 33/24 35/21
37/2 40/9 45/25 48/24,
49/15 49/22 49/24
50/16 50/25 52/4
56/25 59/10 59/13

65/8 65/11 66/2 69/14
92/22 93/17 102/22
103/7 103/8 118/11
119/4 119/5 119/25
138/13 141/13 153/2
163/22
surplus [2] 88/5
128/11
surprised [1] 12/14
survey [20] 53/23
55/7 56/15 56/17 57/3I
57/12 78/24 79/3 79/7I
79/10 79/18 79/20
79/21 80/1 80/4 116/5I
116/21 117/1 117/5
179/7
surveyed [1] 116/11
surveying [1] 55/22
surveys [9] 56/2
56/20 56/23 57/1 57/5
57/14 179/6 179/6
179/7
suspect [2] 21/11
144/11
suspected [1] 139/10)
suspend [4] 66/7
70/5 99/14 105/11
suspended [2] 64/22
73/4
suspending [4]
64/24 66/8 66/9 99/3
suspense [6] 128/9
128/15 129/8 129/21
129/23 132/4
suspension [34] 4/20)
8/21 9/5 61/16 61/21
63/18 64/12 65/13
67/4 69/20 69/24 70/7
70/17 70/25 71/2
71/23 72/3 72/9 72/23}
73/6 73/7 76/10 76/25
98/20 98/23 104/3
104/10 104/13 104/15)
104/16 104/22 105/4
105/13 107/5
suspensions [16]
7/12 7/18 62/15 62/24I
63/20 64/3 64/16
65/23 69/8 69/17
99/10 99/24 102/11
103/17 105/1 107/2
suspicion [1] 144/5
suspicions [1] 144/6
sworn [1] 1/7
system [51] 12/24
13/5 13/25 14/12
16/16 16/24 17/1 17/4I
26/1 36/20 36/22
36/24 40/14 41/20
46/2 53/11 64/20
81/15 81/17 81/23
82/5 82/13 82/18
82/20 83/1 84/4 88/8
89/2 91/1 102/9

(72) stamped - system
Ss

system... [21] 102/11
114/8 120/11 120/11
122/22 123/9 124/22
125/14 127/21 130/22
136/23 146/14 159/24}
168/10 168/14 168/16
169/14 173/23 173/24
174/4 174/6
systemic [1] 123/25
systems [6] 14/8
14/10 123/6 123/21
154/18 174/1

T

table [8] 54/2 103/9
103/13 104/25 106/8
107/7 107/12 162/1
tactical [3] 164/3
164/4 164/7
take [46] 3/9 7/15 9/4
15/16 17/16 18/10
30/23 33/4 37/12
38/12 44/13 48/23
49/23 52/24 54/13
55/14 59/8 59/10
59/20 64/21 73/5
75/23 80/4 83/16 90/5
92/4 93/4 100/13
104/17 117/8 117/12
117/15 124/8 130/24
137/16 140/25 141/5
145/9 147/3 147/5
147/19 150/1 159/11
160/23 169/3 171/21
take-up [1] 59/10
taken [25] 24/14 29/4
30/22 31/12 33/12
36/17 44/25 46/12
58/7 58/10 67/4 67/22
68/19 85/8 93/19
101/20 113/4 119/19
136/13 145/6 158/9
168/8 172/11 174/15
176/18
takes [2] 114/9
146/22
taking [10] 26/16
43/16 46/25 50/20
90/10 99/13 121/6
138/1 158/4 173/7
talk [13] 9/16 19/23
51/2 80/22 83/21
90/18 143/19 151/15
152/22 155/2 157/19
160/14 178/7
talked [13] 64/11
76/10 76/20 83/4 95/9
100/16 102/2 137/4
155/8 155/14 157/4
157/20 163/9
talking [13] 3/19
36/11 36/24 68/23

73/2 73/23 79/21
105/12 139/8 155/10
164/13 169/7 169/12
tangentially [1] 95/8
target [1] 146/6
targets [1] 178/9
tasked [1] 148/24
taught [2] 49/19
119/6
Teach [1] 164/20
team [113] 9/18 10/1
10/5 10/7 10/25 11/1
11/13 13/13 14/4
17/10 17/14 18/1 18/6
18/9 22/7 22/12 25/14
29/11 30/6 30/8 35/19
36/6 37/1 37/2 40/8
40/15 41/5 41/6 43/22
44/22 48/13 49/23
50/6 50/10 50/14 51/1
51/12 52/4 61/13
62/17 62/18 64/21
67/11 67/13 67/21
67/22 67/23 68/23
74/19 74/22 74/23
74/24 79/4 82/3 82/6
82/11 95/17 99/14
100/5 111/20 111/22
111/25 112/4 112/12
112/12 112/16 113/17)
114/22 117/25 118/8
118/10 119/4 119/8
122/24 122/25 123/1
123/19 124/7 124/9
125/5 125/12 134/13
134/23 136/8 138/4
138/7 138/8 138/12
138/22 138/23 139/14)
139/16 144/20 145/19)
148/11 148/14 148/21
149/7 149/13 149/16
150/1 151/3 151/20
152/10 154/7 154/10
155/3 158/3 158/21
159/10 165/10 165/11
178/20
teams [26] 10/5
17/15 33/24 33/25
34/20 35/6 35/6 46/16
49/7 53/13 59/16
62/18 65/2 76/14
91/11 95/2 100/14
119/6 119/16 122/23
123/8 123/21 138/16
150/11 150/16 154/1
technical [1] 39/18
Technically [1] 14/14
tell [7] 30/25 58/20
73/4 92/19 100/7
109/8 177/15
telling [1] 104/17
tells [1] 88/21
template [5] 3/23
24/18 35/4 35/4

100/17
templates [1] 101/1
ten [4] 145/15
tends [1] 79/10
term [3] 20/17 113/15}
124/1
termed [1] 133/17
terminals [1] 60/1
terminate [7] 64/22
66/7 66/24 75/11
75/17 76/2 99/14
terminated [1] 66/23
terminating [7] 64/19
64/25 66/8 66/10 74/6
TAIT 99/4
termination [27] 4/20
8/9 8/20 9/5 18/21
18/23 61/17 61/21
63/18 64/13 65/13
67/4 68/15 71/9 73/13
75/6 75/10 75/24 76/3
76/6 76/20 76/25 77/1
78/16 98/9 98/20
102/1
termination/suspensiI
on [1] 9/5
terminations [9]
62/16 63/20 64/4
64/16 65/22 69/8
99/10 99/24 102/12
terminology [2]
114/11 151/9
terms [39] 3/12 3/19
3/23 3/24 11/7 24/2
24/14 24/18 24/19
25/1 25/20 26/12 27/5)
28/6 28/15 28/17 29/2
32/14 32/17 37/6 38/2
38/5 52/9 69/5 69/7
75/21 87/24 92/23
92/24 93/2 111/11
111/15 115/13 124/7
142/13 146/21 156/5
166/12 166/13
test [5] 70/3 70/11
70/12 70/19 143/8
testing [1] 17/3
text [2] 109/22
168/20
than [37] 4/18 5/20
31/5 35/13 35/15
47/19 54/15 54/16
59/7 61/20 83/18
103/20 109/13 115/7
116/3 116/16 117/21
120/17 120/19 124/13
126/16 128/4 133/10
136/8 139/5 140/25
141/20 146/7 146/10
147/3 147/5 149/16
159/5 159/8 159/15
162/15 173/15
thank [68] 1/4 2/22
3/2 3/2 3/17 4/14 4/25

5/1 5/2 5/13 9/20
16/13 18/15 28/22
32/20 32/20 32/22
33/2 36/3 38/11 38/15
38/20 39/5 52/16
55/17 59/21 59/23
61/15 67/3 73/11 76/1
78/4 80/6 96/16 96/17
97/20 103/2 103/3
107/15 107/18 107/20}
108/4 108/10 108/18
110/9 127/15 129/3
133/1 134/22 140/8
143/8 145/4 148/3
148/8 149/12 157/24
160/4 169/3 175/2
175/5 175/8 175/10
179/21 179/22 179/25]
180/2 180/5 180/8
thanks [3] 87/21
90/10 109/24

that [1064]

that's [154] 4/6 5/21
8/6 11/25 13/8 20/7
23/7 23/15 24/11 27/2
32/22 33/16 35/16
37/22 38/12 39/3
39/10 41/18 42/2
42/11 43/17 44/7
44/13 44/22 46/15
46/19 47/22 49/5
49/15 54/20 55/2 55/7
56/14 57/8 57/17
57/21 59/17 61/14
61/23 62/10 63/12
63/14 63/14 65/17
67/2 67/14 71/14
71/24 72/8 73/1 74/21
77/6 77/15 77/18
77/23 78/17 88/20
89/14 93/12 93/17
94/12 95/25 96/3 96/3
96/22 98/6 98/7 99/9
102/5 103/3 103/12
103/13 103/18 104/1
104/7 104/23 104/24
105/6 105/24 106/13
106/24 108/25 109/4
109/21 110/19 111/23}
118/7 119/25 120/18
121/11 123/18 125/2
125/6 125/13 125/16
125/18 125/22 126/15}
127/6 128/24 129/3
129/15 129/17 130/1
130/6 132/14 132/25
135/15 137/17 138/4
138/6 140/21 141/10
143/1 143/1 143/17
145/20 146/10 147/19}
151/5 151/13 152/11
152/13 154/4 154/6
156/4 156/8 156/9
156/13 156/24 159/17]

161/14 166/3 166/18
167/3 167/11 168/6
168/12 168/19 169/13)
171/1 171/6 173/10
173/21 174/15 174/17
175/4 175/21 176/19
176/22 177/1 177/6
177/23 178/24
theft [1] 85/7
their [63] 4/24 20/23
24/1 33/1 33/10 33/25]
39/19 41/15 42/1
43/22 44/3 44/5 44/6
44/11 45/24 49/2
49/13 49/13 54/21
58/7 59/2 59/16 62/18
65/7 66/7 67/6 69/13
69/14 74/9 82/6 87/14)
94/16 95/9 102/15
1412/5 114/8 114/21
116/11 119/10 123/3
123/16 123/24 126/6
131/5 133/7 137/14
142/2 144/23 146/16
149/24 150/12 150/19)
151/5 151/22 152/22
153/15 153/17 167/9
169/2 169/22 170/14
178/1 179/19
them [59] 6/13 6/15
7/3 13/14 16/8 20/3
26/13 28/8 28/20
33/24 34/22 35/21
37/6 37/12 37/12
37/19 41/23 42/4
42/16 43/1 43/3 43/12
43/23 49/10 53/9 59/2)
59/20 61/7 61/8 63/5
66/5 66/9 73/8 74/20
78/7 86/18 90/6 94/19
95/6 95/9 100/25
104/6 118/13 119/21
126/2 133/9 138/13
149/6 151/21 151/25
152/10 152/22 153/16)
154/18 155/12 165/20)
167/7 176/17 179/18
thematics [1] 124/12
themes [2] 123/22
124/10
themselves [6] 11/12)
34/21 58/8 126/9
139/20 149/15
then [98] 1/7 2/15
4/21 6/9 6/22 7/19
8/24 9/9 15/24 24/8
27/24 28/24 29/21
32/13 33/2 37/13
37/16 38/22 45/15
53/8 54/20 57/19
60/13 64/24 68/4 68/9I
70/3 71/1 71/2 74/2
75/23 76/3 76/9 78/17
81/19 86/13 88/6

(73) system... - then
T

then... [61] 90/12
93/2 97/4 97/8 104/19)
105/10 105/17 105/19}
108/3 111/9 111/10
113/2 113/6 113/8
116/2 118/21 121/12
123/10 125/11 128/7
128/12 128/17 129/5
129/17 129/19 130/7
131/10 132/17 133/18}
134/8 134/20 135/2
135/7 135/21 137/15
139/16 140/5 140/16
140/24 141/15 142/1
143/12 143/19 143/21
144/25 146/10 149/4
149/5 149/8 150/15
151/6 152/20 154/14
159/13 160/7 162/8
165/15 167/16 174/3
176/20 179/25
there [182]
there's [47] 4/16
35/19 41/3 41/5 41/13,
43/20 44/12 45/5
46/23 48/6 56/8 58/16
59/10 60/4 64/3 76/2
77/13 80/11 90/16
90/23 93/18 99/5
106/6 106/8 109/3
109/10 121/12 121/20)
121/25 124/3 124/24
125/6 125/9 125/11
127/25 135/3 135/22
144/8 146/19 146/21
149/1 156/14 156/18
160/17 164/25 166/20}
179/14
thereafter [2] 4/22
68/15
therefore [7] 2/2
79/17 98/22 146/17
149/25 170/21 176/16)
these [43] 32/16
33/13 35/10 37/18
42/8 45/4 54/11 55/3
55/10 55/13 60/13
65/22 66/2 66/22
70/14 70/18 78/6
83/16 87/5 100/16
100/23 101/6 106/11
106/13 114/24 121/14]
121/24 127/17 135/6
136/20 142/21 147/1
151/8 152/19 154/17
154/19 154/24 155/7
155/13 162/5 167/13
175/17 176/12
they [136] 5/12 6/14
6/16 14/10 14/23 20/1
20/18 21/14 24/1 24/8
27/5 33/9 33/25 34/11

34/12 34/17 35/16
42/13 42/6 45/24 45/25
49/14 49/16 51/11
51/20 51/22 51/24
52/4 54/23 56/1 58/8
65/7 67/5 67/7 67/20
68/25 69/11 69/12
70/6 71/19 72/13
72/21 74/12 74/19
75/15 77/17 82/12
83/3 83/21 83/23
84/24 93/1 93/2 93/10
93/11 95/10 95/11
95/11 95/13 100/8
100/21 102/16 103/24)
105/3 107/13 110/8
112/3 112/4 112/7
112/12 112/15 115/14)
115/24 116/12 119/12)
119/20 120/8 123/2
123/3 123/15 123/16
124/3 124/18 124/19
124/21 126/2 126/7
126/19 126/20 126/22)
126/25 127/1 127/9
127/12 128/12 131/6
1314/7 131/10 131/23
132/23 132/23 133/11
134/20 136/4 136/4
136/5 136/13 138/10
138/11 138/13 138/13}
138/20 139/18 139/19)
140/1 140/1 144/11
148/24 149/5 149/14
149/19 149/20 152/9
152/21 152/24 153/16)
154/20 156/12 162/6
164/6 164/14 164/15
165/20 169/13 170/12)
179/8

they're [25] 3/10 22/1
32/17 41/25 42/1 42/5
44/1 50/7 50/21 52/3
57/6 69/14 75/16 96/8)
99/16 101/3 101/7
107/10 111/25 126/8
131/4 138/10 138/14
139/5 171/24

they've [15] 35/11
51/25 69/1 69/5 72/10)
72/11 94/22 95/15
112/3 115/25 122/15
134/19 149/7 154/15
177/10

thing [10] 22/18
26/23 46/21 59/17
65/14 71/24 71/25
83/23 100/18 116/9
things [17] 7/24
26/18 55/21 70/14
70/18 87/13 94/11
124/18 137/4 137/9
139/24 142/17 146/11
170/19 172/24 174/18)

174/19
think [208]
thinking [1] 97/13
thinks [3] 2/1 114/8
153/22
third [7] 3/14 6/17
40/1 112/2 116/14
120/9 124/2
third-party [1] 112/2
this [304]
this/these [1] 152/19
Thomas [1] 29/13
thorough [2] 64/25
105/9
thoroughly [4] 49/11
66/6 66/21 74/10
those [93] 4/23 9/5
9/14 11/16 11/22
19/23 22/14 22/23
24/2 29/2 29/9 30/20
33/23 34/10 35/6
35/15 35/17 39/21
39/22 40/11 43/23
50/1 50/20 53/10
53/15 53/17 54/22
54/25 57/11 64/7 65/3
65/24 68/20 68/20
69/14 71/11 74/9 80/7
86/9 86/22 86/24 91/6
91/18 93/7 95/18
95/18 99/12 99/15
101/9 101/10 103/5
105/10 106/16 106/22
112/8 112/9 114/3
116/14 117/10 117/16}
120/9 122/14 122/16
123/8 123/11 123/13
124/5 124/21 128/6
133/2 136/10 136/10
137/7 137/10 146/13
147/8 147/9 154/23
157/5 157/6 157/7
158/23 158/24 159/11
161/3 161/19 162/14
166/10 168/14 168/14]
170/3 179/13 179/21
though [6] 22/21
34/7 35/2 52/12 80/22}
84/12
thought [4] 39/1
63/10 73/25 105/4
thoughts [1] 77/16
thousand [1] 23/20
three [10] 6/13 8/1
19/19 87/19 121/3
121/24 122/22 143/8
176/24 177/3
thresholds [1]
168/13
thrilling [1] 118/16
through [51] 3/10
4/10 4/22 6/9 6/10
8/10 8/25 21/13 37/12I
47/14 48/14 51/21

54/9 58/8 78/20 87/15
91/22 91/23 94/22
96/5 105/14 113/7
116/20 117/2 119/6
119/19 120/2 122/13
123/3 123/3 123/5
123/11 123/14 124/9
124/18 124/21 125/24}
134/12 136/13 137/18
137/21 138/1 141/1
146/14 146/25 147/8
150/7 152/22 154/18
159/12 167/23
throughout [3] 2/18
3/13 16/14
tier [47] 121/3 124/24
125/3 125/4 125/4
125/9 125/11 125/12
126/1 126/19 126/20
127/13 134/23 134/23
135/7 135/14 135/15
135/25 136/3 136/8
136/10 136/11 136/15]
136/19 137/2 138/18
138/19 138/19 138/23}
139/4 139/9 140/19
141/8 141/13 142/1
145/8 145/14 145/18
145/20 146/14 147/12)
149/4 149/20 168/4
168/4 168/8 168/13
Tier 4 [5] 125/3 126/1
126/19 149/4 149/20
Tier 2 [25] 125/4
125/4 125/9 126/20
127/13 134/23 135/7
135/25 136/3 136/10
136/11 136/15 136/19)
137/2 138/19 138/23
139/4 139/9 145/8
145/14 145/18 146/14}
147/12 168/4 168/8
Tier 3 [12] 125/12
134/23 135/14 135/15)
136/8 138/18 138/19
140/19 141/8 142/1
168/4 168/13
tiers [1] 121/24
tighten [2] 100/2
100/6
till [1] 49/14
time [71] 2/6 7/7 8/17
11/2 11/2 11/3 11/19
12/12 12/13 12/17
13/10 13/19 16/2 16/5}
16/9 17/13 17/13
18/19 23/24 23/24
25/17 29/4 29/11
30/19 31/9 36/13
36/14 36/18 38/12
39/1 54/4 58/24 60/22,
61/7 67/21 79/11 80/5)
80/25 81/8 82/9 83/11
84/2 84/15 85/7 85/18

86/14 88/19 89/5
89/10 90/2 91/19 92/4I
93/19 94/2 94/3 96/22)
97/24 107/24 108/2
114/13 118/14 140/22!
145/6 145/18 146/22
147/19 147/22 150/13)
150/20 160/4 176/12
times [3] 31/18 91/14
91/18

timescales [1] 132/1
timing [2] 79/18
163/5

tips [2] 92/9 92/12
title [3] 39/15 135/2
161/12

titled [1] 144/1

today [8] 3/2 95/13
96/5 98/8 107/21
108/19 126/3 139/2
today's [1] 50/23
together [2] 11/9
53/16

told [6] 15/18 85/5
85/9 88/2 94/14 94/20I
tomorrow [2] 110/24
180/7

too [8] 7/6 50/3 58/23
66/15 76/12 100/18
101/3 164/9

took [7] 15/1 68/11
88/10 98/8 121/17
167/17 168/2

tool [3] 25/13 26/22
44/18

top [11] 10/14 32/23
48/7 50/12 125/11
150/8 155/24 157/11
160/18 162/6 164/21
topic [3] 78/16 78/18
122/20

total [6] 145/18
156/18 156/19 157/7
178/12 178/15

totals [1] 127/20

touched [1] 68/22

towards [3] 16/1 90/8
165/1

track [1] 8/2

Tracy [11] 1/5 1/10
3/1 16/22 20/25 60/6
79/2 87/22 88/13
166/24 181/2

trading [20] 44/24
45/6 47/9 99/19
125/15 125/24 126/14)
126/19 126/21 127/6
127/14 127/19 128/21
128/23 128/25 131/25)
133/12 152/6 153/17
178/10

train [2] 10/23 51/17

trained [5] 50/6 50/7
52/1 52/8 70/6

(74) then... - trained
T

6/21

trainees [1] 52/14
Trainer [1] 53/7
trainers [6] 50/9
50/10 51/11 51/19
52/2 56/10
training [105] 9/12

39/15 39/16 39/16
39/18 39/19 39/20

40/11 40/12 40/16
40/19 40/22 40/24

41/16 41/17 41/25
42/4 42/5 42/8 42/13

44/11 44/15 44/17
44/22 44/25 46/6

50/2 50/6 50/9 50/14
50/20 50/21 50/23

51/24 52/23 53/3 54/4
54/6 54/19 55/1 55/23,
56/1 56/3 57/21 58/3
58/6 58/14 58/16
58/19 58/20 59/1
59/16 59/18 68/23
69/2 69/2 69/5 69/11
72/10 72/11 72/11
94/20 118/2 118/19
118/24 119/1 119/5
119/9 119/13 119/15
119/17 119/19 120/1
120/3 136/13 155/14
170/20

transaction [9] 47/14
48/8 112/2 124/7
124/11 125/17 137/19)
140/3 140/4
transactions [3] 91/5
135/20 137/25
transcriber [1] 38/21
transcript [1] 96/25
transfer [3] 127/2
128/11 129/8
transferred [1] 23/13
Transformation [6]
3/23 8/19 9/1 23/14
32/10 91/24
transition [1] 7/16
transparent [1] 72/2
transparently [1]
141/14

travel [1] 44/4
travelling [1] 112/21
trends [2] 52/24
123/22

triage [8] 125/7 125/7I

trainee [3] 6/8 6/11

9/15 19/21 22/11 33/6
39/6 39/9 39/11 39/14,

39/25 40/1 40/8 40/10)
AMT 41/8 41/12 41/14
43/9 43/13 43/24 44/5
46/13 47/1 49/1 49/18

51/1 51/4 51/13 51/24

125/7 136/21 144/16
144/19 144/25 146/6
trial [3] 27/24 81/20
81/20

trials [1] 94/7

tried [1] 53/15

true [7] 5/11 35/16

142/17

trust [1] 21/19
trusted [1] 83/13
truth [1] 86/17

try [15] 1/16 58/11
97/24 112/8 112/24
113/9 117/22 122/14

137/24 147/16 155/5
165/18

49/8 93/3 114/3 150/2
164/14
turn [28] 3/4 3/8 4/7

31/4 31/15 40/21 54/1

69/22 74/15 78/21
98/11 108/21 108/23
110/1 116/8 129/5
129/17 135/1 135/2
160/16

Tuthill [5] 16/2 16/3
17/6 17/18 84/20
two [29] 5/19 6/23
8/14 20/3 22/7 26/18
30/15 32/9 49/8 55/20)
58/1 62/17 70/15 77/9)
80/11 105/23 106/8
106/19 106/22 106/22)
106/25 107/7 107/7
110/18 110/24 116/2
121/16 130/7 131/21
type [3] 18/16 128/20
156/2

types [7] 22/24 39/17
54/5 143/24 155/25
156/20 164/5

typing [1] 15/8

U

UK [1] 179/5
ultimately [12] 9/2
20/4 40/18 43/14
63/22 64/13 64/25
76/12 76/14 79/5
112/16 165/22
unable [1] 158/24
unanimously [1]
82/8
unannounced [7]
121/13 121/16 121/20)
121/25 122/4 122/6
122/10

undated [1] 15/22
under [13] 2/18

42/2 49/5 79/24 110/6

124/12 133/11 134/13)

trying [7] 22/18 22/20)

5/3 15/25 16/12 24/15)

61/16 61/18 63/3 67/9

31/19 45/11 67/11
67/23 70/11 75/21
103/24 121/22 137/17
156/25 166/8 169/16
undercooking [1]
38/22
undergo [1] 58/4
undergoing [1] 56/3
underneath [1] 151/6
understand [54] 3/8
3/15 4/1 4/12 4/21
24/6 24/12 25/2 25/11
43/4 51/8 63/13 89/5
102/25 104/25 106/2
109/4 109/18 111/11
112/24 113/9 114/3
117/10 118/17 120/8
122/21 123/18 123/25]
124/3 124/13 124/20
125/8 133/25 134/5
134/18 137/13 137/24
138/24 143/19 143/20
146/19 149/5 149/8
152/19 152/24 153/1
154/9 158/20 161/2
170/22 174/8 174/24
179/10 179/20
understanding [27]
1/17 40/2 50/22 51/5
51/21 53/18 55/11
65/17 98/6 98/7 103/8
109/15 111/25 117/4
118/7 118/12 119/12
128/2 135/18 158/10
160/8 161/21 164/15
166/3 170/6 179/12
179/14
understood [10]
26/12 52/1 88/25 89/3
89/4 97/18 103/14
103/24 109/16 138/13
undertake [2] 65/3
168/9
undertaking [3] 9/14
66/17 136/23
underway [2] 26/25
142/15
unintended [1]
143/13
unique [2] 5/16
110/11
unit [6] 129/15
129/17 129/22 144/7
144/15 158/19
units [3] 14/9 57/6
129/19
unknown [2] 83/17
85/5
unlawful [2] 21/1
21/10
unless [5] 78/15 80/7
99/2 144/22 171/5
unlike [1] 89/14
until [6] 36/22 85/15

86/12 97/6 163/2
180/10
unusual [2] 17/17
139/3
unworkable [1]
102/24
up [56] 7/9 10/9
10/17 26/10 28/2 32/2}
44/16 44/21 52/20
53/22 59/8 59/10
59/20 60/4 61/2 61/5
62/4 66/18 67/9 70/13
74/15 81/7 87/16 89/1
90/3 90/23 94/17 96/9)
98/11 100/2 100/6
103/11 108/23 109/6
111/20 111/22 115/3
120/20 127/24 131/22)
131/24 132/3 132/5
151/17 154/15 155/8
157/10 161/4 166/1
166/16 167/20 172/18}
175/17 176/5 177/14
179/2
update [5] 36/12 61/7
120/11 160/12 164/11
updated [8] 8/18 31/9)
33/3 78/13 115/14
118/5 119/10 154/19
updating [1] 46/5
upfront [1] 83/24
upgrades [1] 14/13
upon [5] 6/7 32/17
49/9 106/1 180/3
URN [1] 5/16
us [26] 1/3 15/25
38/19 46/21 48/5
59/16 59/20 75/20
88/1 88/21 91/10
92/19 94/14 94/20
100/7 108/9 118/17
126/25 127/17 134/11
134/21 137/23 144/22}
148/7 153/7 157/2
us a[1] 153/7
use [23] 34/8 39/17
47/8 53/10 64/23
72/24 91/11 112/14
120/9 123/9 126/14
127/7 130/17 133/23
134/10 134/16 135/11
142/9 148/23 149/22
150/9 161/3 174/1
used [34] 3/13 6/14
15/2 17/21 18/8 25/13}
49/3 49/23 50/23
51/17 63/10 63/10
67/10 67/12 92/2
102/10 102/11 113/15)
122/10 134/18 138/15}
140/5 143/13 152/7
152/12 163/3 163/16
172/23 173/1 173/21
174/4 174/6 174/10

174/17

useful [1] 42/15
using [8] 45/19 64/20)
74/10 82/4 86/17
134/2 146/17 148/15
usual [1] 17/10

Vv
v3 [1] 32/3
validity [1] 114/3
value [17] 12/8 73/17
73/21 73/23 74/1 74/3I
74/10 85/8 98/16
114/6 114/12 1314/7
1314/7 140/18 140/20
141/3 169/11
values [2] 60/10
73/24
van [9] 10/10 10/15
12/22 20/24 21/13
22/3 81/6 83/15 86/15]
vans [1] 7/24
variable [2] 178/12
178/16
varies [1] 56/5
variety [3] 6/10 6/25
43/20
various [21] 4/8 5/24
20/8 32/24 33/24
34/19 40/1 41/1 49/20
51/21 53/4 54/18
58/12 58/21 60/17
68/4 83/17 85/15
90/21 111/7 112/22
version [6] 34/14
118/16 118/18 118/20)
118/20 118/22
versus [5] 77/22 84/6
84/6 115/17 164/19
very [88] 1/4 1/8 6/11
6/17 13/11 13/13
15/10 15/12 15/13
15/14 16/7 19/11 22/6)
22/22 27/8 29/1 29/12)
34/3 35/1 35/16 37/3
42/15 42/17 43/17
46/8 46/15 46/16
48/23 49/12 49/16
49/23 52/5 52/11
53/19 54/11 55/2
55/12 55/14 55/18
56/5 56/9 56/22 59/7
59/21 64/25 66/6
70/14 71/7 71/11 76/9I
77/15 78/13 78/18
80/23 81/2 84/4 86/9
86/25 89/14 90/4 93/4I
94/4 94/10 94/10
94/18 95/20 96/2
96/11 100/12 101/2
102/7 107/15 107/20
107/22 109/24 110/14)
1411/2 112/20 115/23
116/2 147/6 164/21

(75) trainee - very
Vv

very... [6] 167/16
179/9 179/9 179/25
180/2 180/2

via [7] 18/9 25/12
25/23 29/6 83/17
155/14 160/20

view [18] 2/7 2/11
14/1 17/12 23/1 26/7
26/20 34/15 50/17
51/23 70/21 78/13
84/18 88/12 114/10
143/15 156/21 164/12)
visit [16] 114/16
114/17 114/21 117/11
117/13 117/14 117/23
120/24 121/6 121/8
121/8 121/9 121/20
122/4 122/6 122/10
visiting [2] 60/8 85/3
visits [9] 114/23
117/7 117/9 117/20
120/5 121/4 121/5
121/13 121/17
voluntarily [1]
162/15

voluntary [3] 56/11
162/20 163/20
voted [1] 82/8
voting [4] 77/11
77/13 77/16 77/20
vs [5] 79/12 86/12
97/6 97/10 97/11

Wo
wait [3] 109/6 126/21
126/23

Wallace [1] 165/12
want [40] 3/3 9/20
10/2 15/21 22/24
24/13 39/6 39/13 43/4
43/25 44/7 44/15
45/10 55/18 59/6 60/2)
61/16 69/16 81/2 81/3
93/24 100/19 101/8
103/8 104/2 105/19
108/21 113/12 117/24}
122/19 124/22 126/11
130/9 132/4 133/13
134/22 143/24 153/2
157/25 175/12
wanted [13] 2/10
24/1 56/19 57/25 58/2
89/13 107/16 122/3
155/18 160/7 173/16
176/14 178/14

wants [4] 59/1 80/12
141/8 149/8

warning [2] 131/20
132/22

warnings [1] 133/3
was [246]

wasn't [26] 25/16

25/17 25/24 27/6 29/7
29/8 30/17 34/24 52/8
52/14 52/19 60/20
61/8 81/13 84/21
84/23 87/8 89/6
112/21 113/21 131/14)
146/24 161/21 163/13)
165/15 179/13
watching [1] 51/8
Watt [4] 175/6 175/7
179/22 181/18

way [17] 21/15 24/24
39/2 52/5 53/14 57/11
57/14 57/23 63/1
91/22 92/13 94/18
138/22 159/14 169/8
170/15 179/17

ways [4] 58/8 124/22
125/14 131/21

we [432]

we'd [3] 53/4 57/7
163/10

we'll [8] 1/5 2/15 16/1
37/10 65/14 148/10
157/19 180/6

we're [35] 26/18
32/15 34/4 37/15
40/24 46/24 49/12
59/17 65/10 66/8
68/14 70/13 71/7
73/23 79/21 97/19
99/13 100/25 101/2
114/5 117/9 132/5
142/22 143/23 147/14)
147/20 153/14 155/13}
157/15 169/7 169/12
170/17 170/18 170/19)
170/23

we've [49] 19/25
21/12 22/15 36/11
36/24 37/7 39/23
46/22 50/17 55/1
59/12 64/11 65/4
70/10 72/13 75/20
75/21 76/6 76/8 76/20
79/11 86/16 95/24
96/1 96/4 102/1 106/3'
107/12 112/10 115/13)
115/14 116/1 118/20
119/14 122/12 134/8
137/25 141/15 149/3
151/14 157/11 157/20)
161/4 163/6 163/9
163/22 163/23 163/24}
170/11

weakened [1] 70/20

website [3] 5/15 5/15
110/11

Wednesday [1] 1/1

week [8] 1/13 12/2
21/20 51/3 90/11
146/7 153/6 167/17

weeklies [1] 127/8

weekly [6] 99/19

126/4 133/2 133/8
140/2 140/17
weeks [2] 112/20
166/17
welcome [1] 100/21
well [51] 11/25 25/16
28/14 28/19 30/15
35/23 42/17 44/2 44/7
50/25 52/2 52/17
53/10 53/21 56/4 58/7
61/6 64/10 68/23 69/6
69/9 69/17 82/15 83/7
88/21 89/14 89/23
91/22 92/21 93/12
93/13 93/17 93/21
93/21 101/10 101/11
102/20 107/20 108/3
109/6 112/4 135/14
137/12 138/20 152/8
169/20 170/6 172/7
173/11 174/13 179/25)
went [9] 6/22 7/17
8/5 79/4 80/3 80/5
89/13 154/3 164/18
were [107] 1/14 6/13
6/16 7/7 7/10 7/11 8/2
8/8 8/17 8/20 11/19
13/3 13/11 13/15
13/16 14/19 15/4
18/20 19/7 19/14 20/1
20/18 20/19 25/7
28/17 29/22 30/15
32/6 32/9 32/14 36/19
47/25 50/10 50/20
52/7 55/23 60/18
63/20 68/20 68/22
68/24 68/25 72/6
74/12 79/17 79/23
81/10 81/10 82/3
82/11 83/16 83/19
84/9 84/12 84/13
84/20 84/22 84/25
85/5 85/11 85/13
85/16 86/4 86/9 86/19)
86/20 88/16 88/21
89/12 91/6 92/5 95/7
95/13 97/2 97/10
97/19 101/23 103/16
103/25 105/1 106/11
106/13 107/16 114/23
114/23 114/25 116/15}
116/17 116/18 118/8
119/8 119/19 122/22
123/22 134/2 146/25
147/2 147/6 147/10
151/20 153/2 163/8
165/16 169/21 176/12)
178/14 178/23
weren't [4] 29/4
88/15 88/17 94/11
what [160] 1/20 6/7
6/12 6/20 6/24 7/7
7/19 7/23 8/13 8/24
10/1 11/6 11/8 11/19

13/17 15/15 15/16
15/17 18/1 18/2 18/11
19/24 21/3 23/1 24/13}
25/2 25/11 26/6 26/24,
27/4 27/22 28/6 28/25)
32/7 33/11 34/13
37/15 37/21 37/24
39/4 41/11 44/1 46/12,
46/17 48/8 49/3 49/18
50/19 51/22 51/22
53/1 53/14 53/18
54/15 55/11 56/21
56/22 58/10 58/14
59/7 59/14 59/16
60/24 63/17 63/22
64/19 66/5 66/7 68/18)
72/6 72/20 73/2 73/21
73/22 76/4 83/18 85/5)
85/8 86/18 86/25
87/25 88/2 88/20
88/21 88/25 89/7
89/20 89/24 91/11
92/14 92/23 93/3
93/12 94/25 95/22
95/25 97/19 102/20
103/12 103/24 104/2
104/17 107/13 107/24}
109/7 109/7 110/13
110/15 113/19 113/23}
114/5 114/7 115/17
117/7 118/21 120/6
122/9 124/23 127/4
128/1 129/11 132/2
133/16 134/2 134/8
134/14 137/2 140/20
140/21 144/9 144/10
144/12 144/13 146/18)
146/21 147/3 147/25
150/23 153/1 153/15
154/25 155/11 157/6
157/15 157/19 159/7
159/18 160/13 161/2
161/3 161/22 162/2
163/4 163/17 165/8
166/4 169/11 171/6
174/21 177/16
what's [6] 36/10
49/19 56/14 143/15
155/13 174/16
whatever [6] 13/16
19/14 36/16 74/9 85/4)
93/14
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when [86] 6/4 7/7
9/13 9/21 12/14 15/5
15/8 18/4 20/13 21/23}
24/9 25/19 26/6 30/17,
30/22 30/23 32/6
36/14 40/24 45/5
45/18 47/2 49/2 49/25
55/12 65/10 68/22
70/4 70/8 72/2 75/19
78/7 78/8 84/5 85/13
85/18 85/25 86/3

86/10 86/21 86/23
91/15 92/13 92/16
92/17 93/5 93/25
95/13 97/1 97/9
101/23 101/23 102/17I
104/25 105/15 109/15)
110/23 112/18 113/4
113/7 115/8 115/10
119/5 119/24 121/14
127/6 128/14 133/2
133/4 138/9 139/16
146/23 152/2 153/8
157/13 158/9 163/16
164/16 164/22 165/20)
167/23 170/2 170/17
172/20 172/25 179/5
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61/20 63/7 63/9 63/12
63/17 65/19 65/22
66/6 67/1 68/15 69/24I
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87/6 98/4 98/15 99/8
99/10 99/11 99/13
103/17 106/13 106/18}
107/8 107/16 111/6
112/20 117/9 120/24
122/11 128/16 131/6
134/17 136/5 136/13
139/5 144/11 147/1
148/18 149/21 149/22)
151/23 154/23 156/10)
156/14 163/23 166/12
167/2 170/10 170/11
170/15 176/24
whereas [1] 16/5
whereby [1] 121/5
whether [43] 1/18 2/3}
12/11 40/21 56/19
61/10 62/8 65/8 65/24
66/2 68/25 70/4 75/4
75/13 78/6 84/18
86/19 87/23 89/5
89/19 95/11 101/21
105/13 107/6 113/19
115/12 128/25 131/19)
134/9 136/24 137/25
142/13 142/20 143/1
143/1 143/3 162/4
163/5 168/10 168/15
168/25 172/12 173/1
which [106] 1/11
1/12 1/14 1/15 3/3 3/9)
3/21 4/16 8/17 8/19
9/15 13/14 15/1 15/25}
20/19 22/2 22/6 22/15
22/25 23/5 25/7 30/2
30/14 31/3 31/9 34/14)
34/15 34/21 37/10
41/19 43/21 49/9 50/2
51/5 54/5 57/4 58/8
61/18 64/10 64/11
64/12 64/23 65/2

(76) very... - which
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which... [63] 66/18
69/7 73/20 74/22
76/21 79/5 79/10
79/18 80/22 84/21
88/3 89/9 90/7 90/15
90/24 96/6 99/22
101/1 103/25 104/9
104/16 105/1 105/10
106/1 106/3 106/10
106/23 107/12 108/21
109/5 111/5 111/18
112/7 121/17 122/20
124/25 125/4 125/6
129/21 130/7 131/10
131/13 133/13 135/4
147/14 148/13 148/14)
150/18 153/10 153/22
155/18 155/25 156/12
156/18 157/20 159/12)
162/14 165/5 165/6
165/22 167/8 174/21
180/2

Whichever [1] 47/8
while [3] 42/4 54/17
55/20

whilst [10] 7/10
13/18 21/10 46/15
80/21 87/8 94/6
150/16 157/12 178/17
who [60] 2/6 11/2
12/20 20/17 20/17
21/6 23/12 23/25
23/25 28/2 29/9 29/10
29/13 35/20 40/11
40/16 42/16 44/21
50/20 51/17 51/19
53/10 55/13 55/14
55/25 58/4 59/1 59/6
60/14 67/18 68/19
68/23 71/1 72/20 73/3
76/9 80/12 83/7 83/20
89/17 94/15 94/16
100/10 116/14 116/18
117/5 119/8 119/20
136/8 142/2 145/3
148/15 148/22 148/25)
152/4 152/7 160/6
165/11 169/21 175/25
whole [4] 2/19 56/18
58/16 139/24

whom [3] 39/18
40/21 122/5

why [47] 1/21 10/21
10/23 11/5 15/4 19/25
25/16 25/24 26/4
26/13 27/7 27/14 29/3
29/5 31/11 34/17 36/9
40/7 45/21 46/12 55/2
60/15 67/16 71/5
77/13 79/7 83/14
83/20 87/25 88/4 96/7
96/13 98/25 99/7

102/14 116/25 117/10}
120/8 133/20 135/25
149/13 151/13 154/24)
159/13 170/3 170/22
174/17
wide [3] 1/25 10/8
14/11
widely [1] 85/14
wider [7] 10/3 44/14
50/2 91/10 95/2 95/23)
140/5
widescale [1] 36/12
widespread [1] 24/25)
will [107] 1/15 2/8 3/9)
3/13 5/14 24/7 24/9
26/21 27/17 27/19
35/6 37/10 37/13
37/14 43/21 47/2
47/14 48/2 48/13 50/1
50/3 51/20 51/23 54/5
58/7 64/21 64/21 65/7,
66/13 69/10 69/12
69/24 70/19 71/17
75/4 78/8 78/8 78/12
99/25 100/17 101/5
101/18 101/19 109/5
109/13 110/10 112/15)
114/16 118/17 119/6
120/16 121/6 122/5
123/12 123/14 123/15)
125/7 125/25 126/2
126/23 126/25 128/17)
131/19 132/12 132/15)
132/22 133/3 135/5
135/9 136/11 138/11
138/12 139/11 140/17)
140/18 141/11 141/22)
142/3 142/13 143/2
143/21 145/3 145/19
147/13 151/20 153/5
153/5 153/16 153/24
155/4 157/5 157/6
157/7 157/17 157/21
157/23 160/22 166/3
166/15 166/18 169/8
169/13 171/21 171/22)
172/9 172/10 176/2
WILLIAMS [2] 103/4
181/10
willing [2] 84/22
84/23
win [1] 93/1
Winn [4] 87/18
wish [6] 1/11 48/5
109/4 109/18 128/21
155/21
wishing [1] 126/13
wisps [1] 86/17
withdrawals [1]
137/20
within [35] 6/18 14/3
18/14 19/8 21/20 29/7
29/13 29/14 41/2 44/9
46/16 53/12 57/5

60/14 65/24 67/12
76/11 78/14 79/4
98/22 112/22 116/24
118/8 123/19 132/10
138/5 145/9 145/15
147/13 150/13 150/14
168/8 169/4 175/25
178/10
without [13] 15/14
45/14 45/16 60/2
60/10 65/19 102/5
104/5 117/4 132/18
132/19 173/19 173/19}
WITN003700100 [1]
176/5
WITN06650500 [1]
172/18
WITN11600100 [1]
110/12
WITN11610100 [3]
5/17 57/21 103/7
witness [36] 1/15
1/19 2/2 2/4 5/18 5/23}
19/1 20/1 20/2 20/4
30/4 30/21 45/10
61/17 62/4 65/14
103/6 107/21 109/20
109/23 110/17 121/23
134/9 150/4 155/19
156/1 158/1 160/8
173/14 175/14 175/19}
176/4 176/23 177/20
178/22 180/1
witness's [1] 2/19
witnesses [4] 2/6
100/10 167/3 169/25
won't [5] 26/20 92/4
93/4 102/15 140/24
wonder [2] 21/19
38/25
wonderful [1] 83/23
word [6] 4/21 34/9
37/8 84/6 84/6 151/10
worded [1] 138/23
wording [11] 28/2
48/20 48/21 49/6
49/21 49/24 100/2
100/6 100/7 100/8
100/21
words [5] 4/22 4/23
17/21 18/7 151/4
work [21] 6/12 11/8
35/14 36/22 40/25
42/12 49/7 49/10
50/23 73/1 78/12 91/2
94/14 95/24 119/21
150/11 153/14 153/18}
155/2 158/23 161/7
worked [4] 13/10
16/8 68/4 128/3
worker [1] 39/17
working [31] 6/14 7/2!
7/4 7/10 7/11 7/14
8/15 11/7 16/7 39/22

40/11 41/21 50/9
50/25 53/21 54/4
76/14 91/23 94/12
142/15 145/9 145/15
145/16 147/13 161/4
161/14 161/15 166/4
166/10 166/13 175/25)
workings [1] 136/7
works [1] 24/24
world [1] 146/14
worried [1] 89/12
worry [1] 47/6
worse [1] 115/4
worth [1] 172/7
worthy [1] 84/10
would [140] 4/10 7/9
9/17 10/22 10/24 11/3]
11/5 11/12 12/15 13/6}
13/13 13/23 14/20
14/21 14/24 14/24
15/11 15/17 17/9
17/13 17/22 17/25
18/7 18/12 19/6 19/9
29/1 29/10 29/12
29/12 30/19 31/6
32/18 33/9 37/21 38/3
39/1 39/22 40/18 41/4
41/6 42/6 45/13 48/19
49/3 49/22 51/11
51/12 52/10 57/1
59/10 60/13 63/22
63/25 64/24 65/12
66/3 66/4 66/6 72/6
73/25 74/8 74/10
74/23 75/18 75/23
77/19 77/25 78/13
83/1 83/3 83/7 83/8
83/9 85/8 85/22 86/2
86/10 88/18 91/8
91/14 92/2 93/4
100/20 104/5 104/7
104/9 104/10 104/14
104/22 105/7 105/8
105/10 112/7 113/10
114/8 115/7 116/21
117/21 117/22 119/8
119/13 120/6 120/8
120/9 122/2 122/7
122/10 122/17 124/3
131/21 132/21 135/11
138/25 139/1 139/14
144/17 144/19 144/19}
144/21 151/2 156/22
160/6 161/2 161/3
162/15 162/16 162/16)
163/18 163/25 164/11
164/19 165/6 165/17
165/22 165/23 174/25}
176/14 177/15 179/3
wouldn't [11] 13/24
13/25 15/13 19/12
83/8 91/25 92/3
104/13 131/14 133/8
133/9

write [4] 140/25
141/4 141/6 148/18
write-offs [2] 141/4
148/18

writing [1] 20/10
written [13] 3/3 15/14)
15/17 16/14 24/14
33/11 63/1 108/19
141/9 141/20 151/1
157/5 161/23

wrong [7] 85/11
85/13 86/9 93/6 109/9
147/24 159/21
wrongful [3] 20/20
86/4 97/2

wrongly [3] 34/25
84/3 85/19

wrote [2] 121/23
161/20

WYN [2] 103/4
181/10

Y

Yeah [4] 27/13 129/4
130/12 130/13
year [23] 9/19 22/5
57/4 61/22 62/2 62/16I
62/25 63/2 63/24
64/15 67/15 78/14
79/11 79/13 80/4
103/16 105/1 115/6
121/16 150/10 150/11
150/13 165/15
years [34] 1/22 6/6
6/6 6/23 7/1 8/1 8/14
9/17 19/19 21/17
22/16 24/4 34/19
36/16 36/24 41/17
50/15 54/6 54/7 62/7
62/25 64/8 64/14 68/3}
80/19 86/6 87/6 87/15]
93/7 105/12 105/20
110/24 111/6 158/21
yes [185]
yesterday [3] 12/25
98/3 166/24
yet [4] 14/16 20/20
57/8 128/1
you [576]
you'd [3] 2/13 12/25
82/22
you'll [3] 81/7 90/5
134/9
you're [26] 3/19 9/21
10/16 18/18 19/15
36/4 46/18 48/3 71/14I
90/6 104/17 114/2
117/1 128/25 129/19
132/6 139/8 151/8
157/8 158/15 159/13
164/21 171/11 171/16)
173/12 178/21
you've [25] 9/15
10/20 26/16 28/14

(77) which... - you've
Y

you've... [21] 45/4
49/12 49/21 57/9 59/6)
61/17 94/14 94/20
95/13 95/19 98/7
101/5 115/21 120/11
127/17 128/10 129/18}
157/4 158/17 176/15
177/13
YouGov [9] 53/23
55/7 55/9 56/17 57/15
116/5 116/20 117/1
179/7
Young [1] 82/19
your [118] 2/25 3/8
5/8 5/11 5/13 5/18
5/24 6/7 6/24 8/13
8/24 9/13 11/6 12/20
15/16 16/18 17/25
20/1 20/5 22/14 23/3
23/5 25/2 25/25 27/6
27/11 29/7 29/17 30/3
32/1 32/1 32/21 34/9
36/2 38/25 42/7 44/16
48/17 50/4 52/20
54/13 55/24 56/2
56/20 57/20 58/15
61/17 66/17 67/10
67/24 70/22 74/14
80/18 81/5 84/22 87/4
87/5 92/19 96/8 98/7
98/7 98/8 103/6
104/13 107/21 107/25)
108/15 108/25 110/4
110/7 110/9 111/3
111/11 111/15 113/1
113/13 114/10 114/14}
115/2 117/15 118/3
119/3 120/12 120/20
125/19 126/10 128/14)
128/15 130/10 132/4
133/14 138/8 141/23
142/23 143/15 145/5
145/17 148/11 150/4
151/4 152/11 153/23
154/3 155/19 156/1
156/25 157/1 158/1
158/12 160/12 161/10)
167/6 169/15 175/13
175/19 176/23 177/20}
180/3
yourself [5] 18/11
22/13 119/23 153/7
155/19

r4

zone [1] 15/13
zoom [2] 4/17 162/23
zoomed [1] 163/1

(78) you've... - zoomed