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The Post Office Horizon IT Inquiry 17 October 2024
Thursday, 17 October 2024
(10.00 am)
MR BLAKE: Good morning, sir.
SIR WYN WILLIAMS: Good morning, Mr Blake.
MR BLAKE: This morning we're going to hear from
Mr Bartlett.
SIR WYN WILLIAMS: = Thank you.
JOHN JAMES BARTLETT (affirmed)
Questioned by MR BLAKE
MR BLAKE: Thank you very much. Can you give your full
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name, please?
John James Bartlett.
Thank you, Mr Bartlett. You have provided three witness
statements in this Inquiry. The first was produced for
Phases 5 and 6 and related to whistleblowing. Can I ask
you, please, to turn to that first.
Yes.
Is that statement dated 25 April 2024?
Itis.
Can I ask you, please, to turn to the final substantive
page. That is page 19.
Yes.
Can you confirm that is your signature?
Itis.
Can you confirm that that statement is true to the best
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page.
Yes.
I think that is page 99.
Yes.
Is that your signature?
Itis.
Is that statement true to the best of your knowledge and
belief?
Another amendment, if that's okay.
Absolutely.
Page 57 of that statement. The last sentence in the
second to last paragraph of 76(a), it should say that
A&CI perform an independent sample check of cases. So
that's changing "my" to "A&CI".
Thank you, and is that the only change to that
statement?
‘SIR WYN WILLIAMS: I haven't located that yet. Can you tell
me the reference again?
MR BLAKE: I think it's page 57, just the final sentence
before the final paragraph.
SIR WYN WILLIAMS: Yes.
MR BLAKE: “The policy provides that"; is that correct?
A.
It does.
SIR WYN WILLIAMS: Yes, and what was the substantive
amendment?
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of your knowledge and belief?
A. There's a couple of amendments, if that's okay.
Absolutely.
A. So on page 62, paragraph 88, the final sentence, which
says, "5 October 2005", could we change that please to
"5 October 2004".
Q. Absolutely.
A. Page 67, footnotes 132 and 133, amend to 26 July 2019 --
from 26 July 2019 to 29 July 2019.
Q. Thank you.
A. Page 77, paragraph 92. The first and then into the
second line, amend "March 2015" to "May 2015".
Then the last one on that statement, page 130, so
index entry 125: amend "26 July 2019" to "29 July 2019".
Q. Thank you very much. Subject to those changes, is that
statement true to the best of your knowledge and belief?
A. Itis.
Q. Thank you. That has a Unique Reference Number
WITN11190100 and will be uploaded on to the Inquiry's
website.
2
The second statement was produced for this phase.
Can I ask you, please, to turn to that. Is that dated
22 August of this year?
A. Itis.
Q. Can I please ask you to turn to the final substantive
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A. Sir, that was to remove the word "my" and replace it
with "A&CI".
MR BLAKE: I think, actually, that change has been made in
the version I have.
A. Ah, thank you.
SIR WYN WILLIAMS: = So "The policy provides that A&C!
perform", yes?
A. Yes, sir.
SIR WYN WILLIAMS: Fine. My version has that as well, so
that's fine.
MR BLAKE: Is that the only change, or not change, to that
particular --
A. That's it, thank you.
Q. Is that statement true to the best of your knowledge and
belief, subject to that change?
Itis.
That has a URN of WITN11190200 and will also be uploaded
onto the Inquiry's website.
Third and final statement is dated 9 September this
year; is that correct?
Yes, it is.
That addresses the Project May, that's race identity
codes issue?
A. Yes.
Could I please ask you to turn to page 9?
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The Post Office Horizon IT Inquiry
Yes.
Is that your signature?
Itis.
Is that statement true to the best of your knowledge and
belief?
Itis.
No changes to that one?
No changes.
Thank you very much.
Mr Bartlett, you are currently the Director of the
Assurance & Complex Investigations Team: is that
correct?
Itis.
That was formerly known as the Central Investigations
Unit?
That's correct.
You were appointed to that role on 21 February 2022?
To the Head of role, yes.
When did you first join the Post Office?
On that date.
Thank you. The Central Investigations Unit became what
we know as A&Cl in August 2023, is that correct?
That's correct.
Now, taking them separately, what is "assurance", in
Assurance & Complex Investigations Team?
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investigations that come out of Speak Up reports.
Thank you very much. Your background is as a former
police officer; is that correct?
17 years ago, yes.
Can you assist us with what rank you achieved in the
police?
Detective Constable.
Following that, I think you've worked at various private
sector organisations and also The Pensions Regulator; is
that correct?
So I have worked in two financial regulators and two
corporates before coming to Post Office.
Largely, those roles involved investigations?
Yes.
Thank you. I think you also have some legal training;
is that correct?
I have a legal qualification, rather than training.
I have the graduate diploma in law.
Thank you. How were you recruited to the Post Office?
I was approached by an agency.
Thank you. Where were you at that point in time?
I was Head of Investigations -- Enforcement
Investigations at The Pensions Regulator.
Thank you. I'd like to begin today by just asking you
about your induction at the Post Office. Did you
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So the assurance is investigative assurance, so part of
my team's role is to work with, particularly, the Retail
Teams and they look -- they review on a regular basis --
every two months they dip sample cases that are worked
on in the retail space and they look at it from
an investigative practice basis, dip sample, and then
make any recommendations for improvements.
You've mentioned the Retail Team. Lots of teams are
known by different names; what do you mean by Retail
Team?
Predominantly the teams that work under Mel Park.
Thank you. And Cl, "complex investigations"; what does
that involve?
Okay, so that involves cases that we're asked to
investigate in respect to principally sort of
allegations made against senior members of staff,
particularly those at SEG, so the Strategic Executive
Group, or at the Board. It involves looking into what
we call fact finds of where there may be enterprise-wide
or otherwise significant failings -- process failings in
the organisation. So we look at root cause.
It also covers the Project Phoenix, or past
investigations work, that falls under that too and,
within that -- sorry, separate to Project Phoenix but
within the complex or sensitive side, are any
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receive any briefings when you first joined on matters
relating to the Inquiry, such as wrongful prosecutions,
Horizon issues, Group Litigation?
Yes, I did.
Who provided you with that induction?
My boss. So the Group Legal Director.
Who was that at the time?
Sarah Gray.
Thank you. That's still Sarah Gray?
Itis. I also - sorry, just to complete that, I also
did a one-day induction, which every new joiner goes
through, and they covered those issues as well, there.
Since then, have you been following the developments in
the Inquiry?
Yes.
Have you read, for example, the expert reports produced
by Duncan Atkinson KC, or listened to his evidence?
I have listened to some of his evidence.
In light of what you have heard from the Inquiry
subsequently, what are your reflections on the training
that you were provided or the induction that you were
provided at the beginning?
I think it has been reinforced by the compulsory
training that everybody in Post Office has to do, in
relation to understanding the timeline and the effects
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of the scandal and the role that Post Office played in
that. That has certainly assisted that -- I think it
was about a year ago.
Thank you. Are you in any way involved in that?
No.
Right. I would like to talk to you about various other
teams at the Post Office that touch upon matters
relating to investigations. The first is what was
called the Security Team, and that's a team that we've
heard quite a lot about in this Inquiry?
Mm-hm.
At paragraph 11 of your second witness statement, you
say that that team stop being responsible for
investigations in 2019; is that correct?
Yes, although I think, in effect, they'd stopped before
then, but they had it removed from them as part of their
role, as I understand it, then.
You've said that they've been renamed the Network Crime
and Risk Support Team; is that correct?
Itis.
You say in your statement that they support postmasters
to prevent retail crime in their new role. Can you
assist us with what you mean by that?
So I have drawn that from material produced by that
team’s director, and my understanding from that material
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from 1983, was involved in the cases of Peter Holmes,
Allison Henderson, Alison Hall, as examples.
We have on the right-hand side Mr Talbot, who was
a Phase 4 witness in the Inquiry. He had been at the
Post Office since 1987.
We have a little further down there Robert Daily, by
way of example, again longstanding at the Post Office
since 1979. He was involved in a number of cases the
cases of Quarm, the Peter Holmes case, amongst others.
We have Steve Bradshaw, another name that's well
known to the Inquiry. He had been at the Post Office
since 1978 and was involved in a large number of
investigations that had been looked at by this Inquiry:
Janet Skinner, Hughie Thomas, the case of Ishaq, Lisa
Brennan, Lynette Hutchings, Joan Bailey, the Sefton and
Nield case, McKnight case, amongst others.
Are these individuals, or some of them, still
involved in that Network Crime and Risk Support Team?
Yes.
Does that team involve interacting with subpostmasters?
I believe so.
Can you see a problem with that?
Yes.
If we could turn to your second statement, please.
That's WITN11190200. Can you expand: you said you can
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and from conversations with them is that it's a crime
prevention or incident response function. But more than
that I couldn't really say because we don't really
interact with them over those issues.
Could we please turn to POL00447931. This is a document
that you have exhibited, it's says "Service & Support,
Overview of Teams and Responsibilities":
"Our vision is to champion our postmasters through
easy, reliable and trusted service to give postmasters
confidence that we will deliver the best possible
outcome."
Do you know when this was produced or the
approximate time? The metadata, if it assists, suggests
May 2021. Is this a document that you are, first of
all, familiar with and, second of all, was it around
when you joined the business?
I don't know. The name change, I think -- I'm not sure
if the name change is connected to this document but the
name change that I'm aware of is much more current than
that date.
Thank you. Because, if we turn to page 12 of this
document, it sets out a who's who in the Security Team.
We see there a number of names that are well familiar to
the Inquiry. We have, for example, Security Analyst,
Chris Knight. We know that he was at the Post Office
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see a problem with that; what is the problem, as far as
you are concerned?
I think the work of the Inquiry and from what I know
from Project Phoenix would strongly suggest that it's
not appropriate for those individuals to be interacting
with postmasters, given the behaviour of the past.
Could we turn, please, to page 6 of your statement,
that's paragraph 13. You say there:
"I have been asked to provide detail about where the
former Security Team Investigators sit within the new
structure. The Inquiry has linked that request with
recent media reports which suggest those former
Investigators all continue to be employed by Post Office
to conduct investigations. It is right that some
individuals who previously worked in the Security Team
within Post Office remain in the business whilst others
have left. However, none of those remaining are members
of the A&CI team, which now has conduct of all criminal
investigations within Post Office."
So that's true, as far as it goes, that they're not
involved in your particular team and are not involved
directly in those criminal investigations that are
carried out by the Post Office, but do we have to add to
that that a number of them are still involved in the
business, in subpostmaster-facing roles?
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Yes, but not investigatory roles, as I understand it.
What do you think supporting postmasters to prevent
retail crime involves?
From what I've been told, that's around placement of
CCTV, cameras, panic alarms. I think they also do
a review of things like safe codes and things like that.
So it's physical security.
Do you know of any plans or considerations that might be
taking place to either remove those individuals from the
business or to put them in roles where they don't
interact with subpostmasters?
I believe that's being discussed, yes.
What is your view as to what should happen?
The least should be that they are not in
postmaster-facing roles.
Can you tell us why you think it is that it's taken so
many years to reach a decision on that?
I don't know, I'm afraid. I joined two years ago,
I don't know why this wasn't considered before that.
I know it's been discovered -- sorry, discussed during
my time here but I've not been party to those
discussions or any rationale as to why they are there.
Thank you. That can come down, please.
Moving on to another team, Criminal Law Team. Now
you've said in your statement that that was effectively
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Office, is the closest we come to that something within
your team that's called the Law Enforcement Engagement
Team?
I wouldn't describe it as a Legal Team, no.
Sorry, a criminal team. So a team that has a direct
link to, for example, law enforcement agencies?
Yes, there are three and a half people whose role it
is -- is to engage with law enforcement on behalf of
Post Office.
‘Am I right to say that all criminal investigations will
go through that team?
Yes.
Who heads that particular subteam?
One of the Senior Investigation Managers in my team.
What's their name?
Andrew Morley.
Thank you. In terms of other teams, you've explained in
your witness statement that there's also a Financial
Crime team that deals with things like anti-money
laundering, counter terrorism and anti-bribery and
corruption. Am I right to say that they wouldn't be
involved in matters such as investigating individual
shortfalls in post offices?
So they sit in the compliance team, they're not within
my department, and their role is one of really
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Jarnail Singh between 2012 and 2015; is that correct?
As I understand it, yes.
There is now a criminal lawyer at the Post Office called
Stuart Lill; is that right?
Yes, in the Remediation Unit.
So he sits in the Remediation Unit --
(The witness nodded)
-- addressing matters such as compensation and redress?
I think it's around appeals, actually.
Appeals, thank you very much. Does he provide any
advice to your team in respect of criminal
investigations?
Yes, he does.
Does he provide any training to your team in respect of
criminal investigations?
He provides feedback on a case-by-case basis, and we --
he has attended some of our team -- at least one that
I can remember -- team training sessions where we
discussed disclosure and things like that.
Thank you. Do you know his background at all?
I believe he was a prosecutor for -- either for CPS or
for HMRC.
Thank you. Do your know when he joined the Post Office?
It was before me but I don't know the precise date.
Thank you. In terms of a Criminal Law Team at the Post
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a financial intelligence team. So they manage the
receipt and submission of suspicious activity reports,
money laundering related issues. I'm not aware of them
having been involved in shortfall issues.
In respect of, say, submitting a case to a law
enforcement agency, where the Post Office or a sub post
office has been the victim of a crime, would that not go
through that team; would that go through your team?
If Post Office is requesting assistance or reporting
a crime, then that would be through my team, not through
the Financial Crime Team. But they do liaise with law
enforcement, as I understand it, in terms of
longstanding national money laundering projects, best
practice around anti-money laundering, things like that.
So they do deal with law enforcement but on a more
strategical, thematic basis.
Thank you. Then we come to the Retail Team, which is
something we have briefly addressed already. In terms
of investigations into apparent shortfalls at individual
branches, am I right to understand that that is now
principally dealt with by that Retail Team?
Yes.
Who would you say is responsible for those
investigations, ultimately?
The Retail Team.
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The Post Office Horizon IT Inquiry
Who in particular?
So they all sit under Mel Park and so she's ultimately
accountable for those.
Thank you. You say at paragraph 11 of your witness
statement that the Retail Team has supported postmasters
to investigate discrepancies. The suggestion seems to
be in that statement that their involvement only takes
place if instigated by the subpostmaster. Now, is that
right or do they carry out their own investigations?
I think it's a combination of the two. I think the vast
majority comes through postmasters identifying, through
the review and dispute process, or through the call
centre. But I am aware of the Market Monitoring Team,
I think they're called, who look at patterns, and that
might commission some work to be done within the retail
space.
Does that team also fall within Mel Park's
responsibility?
It does, yes.
Do you know which team will be responsible for pursuing
subpostmasters in the civil courts, should that happen?
I'm not aware that that's going to happen. If it would,
I imagine it would start in the retail space but I don't
know because I don't think it's been approved or
planned.
17
still in various roles relating to postmasters. Does
anyone involved in the historic investigation of
subpostmasters relating to shortfalls still work for
your team?
No, not at all.
Does anybody who was historically involved in
investigating apparent shortfalls work in Retail Team,
as far as you're aware?
Not that I'm aware.
How about the Financial Crime team?
I don't believe so.
Thank you. In terms of outside firms you've mentioned
in your witness statement, you say at paragraph 31 that
A&CI non-criminal work is supported by nominal,
full-time equivalent staff in external firms assisting
Post Office; can you assist us with what that means?
Yes. So due to capacity issues within the team,
ie availability of staff within the team, we regularly
engage law firms to conduct investigations, either as
an extension of our team or, more frequently, where we
feel the investigation would benefit from being
conducted entirely by an external party, and that's when
we engage law firms or professional services firms that
have capability like that.
So law firms, accountancy firms, possibly?
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There's no plan for your team to be directly involved in
that, other than, for example, ensuring the consistency
of the Retail Team?
I'm pretty sure we would be asked to do that, were such
activity to take place.
Your team, as you've described in your statement, is
principally for high-risk investigations. What about
more mundane, everyday investigations: low level, civil
debts, or what appear to be debts, to the Post Office
caused by, for example, apparent discrepancies?
No, we're not involved in those.
So when you say it would likely be your team that
pursues subpostmasters in the civil courts --
No, that's -- sorry, that's not --
Sorry, that was my understanding of your evidence.
No, we would probably be requested to assure the work,
whichever team, if it happens, would be conducting that
activity. So we'd be the second line of defence in that
regard.
So your involvement would be one of assurance, not of
direct involvement?
I believe it would be, yes.
Now, we've looked at various teams, the A&CI team,
Security Team, Retail Team, and we've looked at
particular individuals in the Security Team and they are
18
Yes.
Any other type of firm that you can think of?
Sometimes barristers in an individual capacity but they
are often engaged via a law firm.
Is there any mechanism in place to ensure the quality of
the service that they provide?
So those investigations have the same level of oversight
as if we were conducting them. So they will report in
to probably a SEG member, so a Strategic Executive Group
member, there would be a Terms of Reference that would
have to be agreed by that SEG member. That SEG member
will be advised by probably the General Counsel or the
Group Legal Director, and there may well be other senior
members of staff as part of that oversight group.
We're trialling on two investigations something
called an Investigation Oversight Group as a concept,
for our was high-risk cases, and that's how that
operates.
We've heard in previous phases of actions on behalf of
the Post Office being farmed out to external firms like
Cartwright King --
Yes.
-- et cetera. Is there any large-scale farming out,
under your team?
Not large scale in terms of volumes of numbers because
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The Post Office Horizon IT Inquiry
we don't deal with volumes of -- we're a relatively
small caseload, certainly compared to how it was in the
past that's relevant to this Inquiry. We're not on the
same scale at all. So I would say no, it's not -- they
are frequent and, percentage wise, yes, we do engage
a lot because we're a small team. But it's not at
scale.
What proportion of your cases end up at an external
firm?
Not for -- for non-criminal cases, I'm not entirely
sure. It would be less than half.
For criminal cases?
None.
SIR WYN WILLIAMS: Sorry, was that "None"?
A
Yes, sir. None.
‘SIR WYN WILLIAMS: Sorry, yeah.
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Just so I can understand this process, I think I've
got it, but let's use an example. The Inquiry knows
that Mr Read was subject to an investigation, which
ultimately -- I say "ultimately" -- the last step in the
investigation was by a barrister, Ms Tutin. So is this
what would have happened in practice: that it would have
come first to your team, because that would have been
a high-profile investigation, but, in that instance, you
or someone on your behalf decided that an external law
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concerned?
Correct.
Who do you consider to be responsible and accountable
for your team at Board level?
That's in two ways. So we have a Speak Up champion, who
is a Non-Executive Director, Amanda Burton. We also
have an investigations Non-Executive Director champion,
who is Andrew Darfoor, now. So we have -- I report in
to them, they are monitoring what we do.
Do they speak on your behalf at Board meetings?
I believe they have, yes.
Thank you. If we zoom out, please, we can see that
there are, including you, 18 members of staff here in
your team. Is that the current position; has that
changed?
No, I think we're one fewer.
So 17 including yourself?
Including the Project Phoenix team, yes. If you take
them out, I think it's nine.
Thank you very much. If we could take that down,
please.
I want to move on to the KPMG report, focusing in
particular on the issue of training, but we'll look at
their findings. We've already looked at them in the
Inquiry, so I'm not going to take a great deal of time
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firm should be involved, a firm of solicitors, who in
turn instructed Ms Tutin, and then she made her report
back; is that it in summary form?
A. That's a proper description of the process, sir, yes.
SIR WYN WILLIAMS: Fine. Thanks. Yeah, okay.
MR BLAKE: I'd like to look at the oversight of your team's
work. Can we please turn to POL00447971. This is
a team organogram. It might be difficult to see but, if
we could just look at the top, thank you. If we could
focus on the top half. Is it possible to zoom in
a little more? We can see your name is on the left-hand
side -- thank you very much -- the third row down. Can
you see your name there?
I can.
It appears that you report to Sarah Gray, who is now the
Interim General Counsel.
oP
Correct.
I don't believe she reports to Ben Foat currently?
Not currently.
No. Am I right to say there is no direct line from
yourself to the Group Executive?
A. Sarah sits on the SEG so I would say that's the link
there.
Q. Thank you. So, essentially, Sarah Gray is responsible
for your team insofar as the Executive level is
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prop,
going through every individual one. You've set out
their key findings at paragraph 17 of your statement.
Can we please turn to POL00423697.
This is the Project Birch report. That was
commissioned and also produced prior to you joining the
Post Office; is that correct?
A. That is correct.
Q. We see there at the bottom, 13 August 2021. Was this
a document that was brought to your attention pretty
soon into taking up the role?
A. Day one.
Q. Thank you. If we could scroll down, please, to page 4.
We see there the context. ll very briefly take you
through that:
"Whilst Post Office no longer bring private
prosecutions it continues to perform a variety of
investigations as required, across its business.
"The Post Office's vision is that these
investigations be conducted to the appropriate standard
by appropriately qualified individuals and adhere to the
market practice with the necessary records created,
maintained and retained so [that the Post Office] can
discharge all its obligations, now and in the future,
including those required by statute."
It sets out there that:
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"Post Office engaged KPMG to undertake a review of
its current investigations process as set out in our
terms of engagement dated 30 June 2021."
What was your view on receiving this?
I think it was the basis of the establishment of the
team that I was asked to build and their recommended
approach seemed to make a lot of sense, a centralised
function. It's something I've seen in other corporate
entities, and it seemed logical.
Thank you. Could we please turn to page 10, and it sets
out there the "Executive summary". As I've said, we've
been through these before, so we'll speed through them.
The first significant bullet point there on the
right-hand side:
"Investigations are not conducted consistently
across [the Post Office]."
Is that the very purpose for the establishment of
your team?
Yes, particularly the assurance piece of my team.
Thank you. If we scroll down, please, we see more
bullet points. Over the page:
"Lack of overarching governance and oversight over
high-risk investigations."
Again, that's essentially the purpose of your team,
isn't it?
25
Area Managers and line managers are not used.
Training, we're beginning to address. There's more
to do there, and we've just got a new case management
tool.
If we scroll up to the bullet points above, how about in
respect of those?
Okay, so quality assurance is absolutely under way.
I think there will probably be more teams that we are
asked to assure but, at the moment, we have -- we're at
capacity in terms of teams. But there is a consistent
approach to that that's been validated by the Group
Assurance function.
Lessons learned, we have a process now where lessons
learned from investigations are collated by Group
Assurance, and followed through by them. Monitoring and
reporting, we've centralised investigations to a greater
extent and we operate a triage function within my team.
If we scroll up, I think we've addressed the first -- is
there anything additional you'd like to say about the
first bullet point on implementation?
So all the assurance work in non-A&ClI teams of -- sorry,
of non-A&Cl teams, one of the drivers for that assurance
work is to drive consistency and so, yes, that is being
dealt with.
Thank you. You've highlighted in your witness statement
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It's one of them, yes.
"There is no clear, consistent triage process in place
across [the Post Office] ...
"Lack of consistent monitoring and reporting of all
investigations ...
"There is no consistent approach to quality
assurance across the business teams ...
"There is limited evidence of ‘lessons learnt’, and
continuous improvement arising from investigations
across [the Post Office] ..."
Over the page, please:
“Business teams often use Area Managers and Line
Managers to conduct investigations ...
"There is a lack of training in respect of
investigations across [the Post Office] ...
"There is no consistent use of an investigations
case management tool across [the Post Office] ..."
That's the final substantive recommendation or
observation.
In your view, have all of those been addressed?
The first bullet point about use of Area Managers and
line managers, in a grievance context, so within the ER
area, that still takes place, but that's outside of the
remit that my team has. So for fact-finding, for
accountability investigations and for any criminal ones,
26
in particular the training issue. Is it your view that
of all of those bullet points, the training is the one
you're the most far behind in implementing?
Refresher training, yes.
You explain that there have been delays in getting it up
and running; is that correct?
Yes, we've engaged with -- so I think the focus of the
questions that I was asked to answer in my witness
statement was primarily focused on criminal
investigations. So, in terms of refresher training or
primary training for investigative work around the
criminal conduct, it is behind but we've been engaging
with the College of Policing and two of my staff are
doing fraud investigation apprenticeships.
Is the plan for you to adopt College of Policing
training, a package?
Yes, absolutely.
I think it was two and a half years after this KPMG
report that that approach was made or the first meeting
took place with the College of Policing; is that
correct?
So it was a year after my team started.
Can you assist with why that took so long?
There was a lot of other things going on and we were
trying to work out what requirements the Post Office had
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around criminal investigations because that would
determine the nature of the training that would -- or
refresher training as well, and ongoing training that
would be required.
Is the current position that there is not yet a training
programme in place?
We've had a needs analysis completed by the College of
Policing. They've proposed a training package, which we
would like to do, and we're just waiting for a formal
offer, if you like, of what that training would be, both
upfront, refresher and ongoing. But, as soon as we can
get that in writing, we'd like to agree it.
When do you expect that to take place?
I don't know. That sits with the College of Policing at
the moment.
So you're waiting on them to put forward the proposal?
They have given us a provisional proposal, which we've
given positive feedback on and we're just waiting for it
formally now.
Are we talking months, years?
Well, certainly not years. I'm hoping one or two
months.
Thank you. That's the College of Policing. So,
presumably, they can assist with the legal issues
relating to the preservation of evidence and matters
29
Tier 3, within Retail. We follow that practice and that
experience but, ultimately, if it's something that we're
not sure about, then we can approach Simon Oldnall's
team, the Horizon IT Team, in the first instance, and
seek their advice. We have done that on other technical
datasets before and it's worked very well.
In terms of the training that's provided by, for
example, the College of Policing, how are you going to
link that up with the wider teams that are involved in
investigations, such as the Retail Team that you've
spoken about?
So we're going to -- we will build in any developments
or new processes or procedures that we get from that
training, we'll consider it for inclusion in our
assurance work, and it will be through the assurance
work framework -- so the assurance framework that that
will percolate into the Retail Teams.
So are we to understand that, for example, your team go
to a training session with the College of Policing,
they'll have that training and then they will then train
the teams below them, or other teams in the business?
Yes, so depending on the significance of any changes or
new approaches, we can either -- the plan will be to
either give an actual training session, probably
starting with the team leaders in retail. But, in any
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such as that. What about covering, for example, the
interpretation of Horizon data, how to analyse Horizon
data; how is your team going to be trained in that?
So one of the aspects that we asked them to look at is
whether or not the transaction analysts -- I have two in
my team -- whether their methodology could be accredited
or approved by the College of Policing. They're still
looking into that aspect as to how that could happen but
that is something that we would like the College of
Policing to do.
Who provides them with training as to what it means,
what the printout from the Horizon system means, what
the ARQ data, for example, from Fujitsu means; who
assists them in understanding that?
So one of the two came from the Tier 3 Retail Team so he
had all of their training and experience and he's
brought that in and he's effectively mentoring the other
transaction analyst, who is an experienced intelligence
data analyst from HMRC.
What about investigations of underlying problems with
the Horizon system itself: how is your team going to be
trained to be able to interrogate the Horizon system or
to properly understand issues such as bugs, errors,
defects in the Horizon system?
So there is a process and guidance for doing that within
30
event, it will be considered as to whether it should be
folded into the multiple sets of criteria that we have
agreed with each of the different teams that we assure.
I appreciate you haven't been at the Post Office for all
that long but is it disappointing that these kind of
changes to training haven't already been implemented?
Yes.
Where would you say responsibility for that lies?
I'm not sure I can place that at any particular personal
group's door but I think what I can say is I'm not sure
Post Office, in 2019, thought they needed to understand
what had gone wrong in the investigation process.
I think that is evident. And the reason I feel I can
say that is Project Phoenix was not commissioned then
when perhaps it should have been.
So that's a broader concern but are there any particular
individuals who you would say that responsibility lies
with?
I wouldn't know. I wasn't in the Post Office then, I'm
afraid.
Was it something that you understood when you came in to
the business that there was that lack of introspection?
I think the fact that a CIU was required and authorised
was indicative of a change of approach, that there was
a recognition that professional investigations
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capability was required and that it needed to be
conducted not by people entirely brought through Post
Office.
Who, in your view, was responsible for that change in
approach?
Sarah Gray and Ben Foat.
Thank you. I'd like to move on to various policies and
procedures. You've addressed the investigations
policies, the two current key investigations policies,
at paragraph 48 to 49 of your witness statement. They
are the Group Investigations Policy, the GIP, and the
Cooperation with Law Enforcement Agencies and Addressing
Suspected Criminal Misconduct Policy -- is that
correct -- that's the CLEP?
Known as the CLEP, yes.
Thank you. Those policies date back to 2021; is that
right?
That's correct.
They pre-date your joining --
They do.
-- and there is now a new policy that is being
developed, that's known as the Group Investigation and
Cooperation with Law Enforcement Policy, the GICLEP?
We refer to it as the Proposed Combined Policy but, yes,
it is that.
33
It's called a "Draft", on the front page it says, "Draft
for comment"; what stage do you say this is currently
at?
It's a discussion document.
Discussing with who?
Board and SEG.
Has it gone to both of those groups?
They've discussed some of the concept in them. I have
provided it to both groups and, in two weeks' time, it's
going to be discussed by the Board and next week it's
being discussed by SEG.
Do you expect that it will be adopted in its current
form?
I think SEG will support it; I'm not sure about Board.
Why are you not sure about the Board?
Some of the feedback or commentary on one or two parts
of this that I've had would suggest that one or two of
the members of the Board want to discuss it further.
So, therefore, I don't think that they will, without
those discussions, want to say yes, go through the
governance process to have it approved.
Can you assist us with what in particular their concerns
are?
I think, in particular, is the element around changing
the current requirement that the CLEP has for Board to
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So, in effect, combining those two previous policies,
the GIP and CLEP to create a single unified policy?
Yes, correct.
Can we please turn to POL00448353; is this the current
draft of that policy?
Yes.
So we see there version 2.2 but it's still a draft for
comment. What stage of development do you say this
policy is up to now?
So, just to clarify, this is the current CLEP?
Yes.
So that is in force. I don't know why it has "Draft" on
it.
Thank you. This is the CLEP?
Yes.
Not the GICLEP?
I would need to see the next page, but looking at that
Even though it's called Group Investigations &
Cooperation with Law Enforcement Policy, if we scroll
over?
Apologies, yes, you're right. That is the proposed new
document. My mistake, sorry.
So this the combined policy?
This is the combined document.
34
approve the provision of certain types of evidence to
law enforcement.
This policy would make it easier for your team to pass
information to law enforcement without Board approval;
is that right?
It would remove the requirement to go to Board. It
would put in place a different governance structure
around that material being passed but, yes, it would --
we would notify Board of what's happened. That's clear
in the feedback that I've had from the Chairman, for
example, that that's what he would like. He -- the
feedback I've had is that the Chairman would approve
that change in responsibility but they would like to
know volumes, trends, characteristics.
Can you assist us with who, at Board level, is not happy
for that change to take place?
Elliot Jacobs, one of the Postmaster NEDs.
Just him?
That's -- he's the only person I've been aware of with
feedback.
Thank you.
Can we bring up onto screen your second witness
statement. It's WITN11190200. I'd like to look at
page 6 and into page 7. In your statement you have
identified some criticisms that have been made from the
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Group Litigation and from the Hamilton appeals, and
you've identified and set those out in your statement.
I'd just like to take you through those and, really, my
question is how this new policy addresses those
criticisms.
Okay.
Thank you. So it's paragraph 14, and you say there:
"The GLO Judgments and the decisions of the Court of
Appeal in Hamilton & Others ... were critical of the
Post Office's approach to investigations, specifically
in relation to apparent shortfalls and discrepancies
shown by Horizon. In particular and in summary, those
criticisms included:
"(a) That the Post Office operated with the
presumption of culpability ..."
Is that addressed in your new policy and, if so,
how?
Yes, it's pretty explicit in there that you have
an investigative mindset, which is open, you make no
presumptions of anything and you follow the evidence and
lines of inquiry, including towards or away from any
investigative hypothesis that you might have.
"(b) That Post Office provided insufficient information
to postmasters who had shortfalls during the
investigation and before and during proceedings ..."
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Yes.
Part of that might include an interview, for example?
No.
That's not the case?
No. We don't do interviews with postmasters.
Is that not part of the proposal in the new policy?
No.
Okay. Well, we'll get to that and we'll have a look at
the section on investigations?
So it’s worth noting that this policy isn't just
about -- doesn't just cover investigations into
postmasters; it's any investigation. So the piece about
interviewing, or -- it is interviewing -- interviewing
people largely relates to Post Office Limited's staff.
We do not -- so as the proposed policy is explicit,
which the previous policy wasn't -- is, we will not do
interviews under caution.
Thank you. If we scroll down, (c):
"That there was poor communication with postmasters
throughout an investigation with the outcome that
postmasters were unable to examine the issue themselves
Is that something that is addressed in the policy
and, if so, how?
Yes, so if you take the investigations conducted in
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Again, is that addressed and, if so, how?
I think that's principally addressed in the processes
within the Retail Teams that look at shortfalls.
So the responsibility for addressing that, you see, as
lying with the Retail Team?
Yes, but what I would say is if we had cause to
investigate anything like that, we would make that
information available, if it's a criminal matter, to the
police, for example.
How about making it available to the subpostmasters,
say, if a subpostmaster is being investigated?
We wouldn't investigate a subpostmaster for anything
other than something that might be criminal, and we
don't investigate people anyway. That is a principle
within the policies: that we investigate circumstances
or events; we don't investigate people.
Do you have guidance as to how much information should
be given to a postmaster if they are going to be
investigated --
So that --
-- for criminal conduct?
For criminal conduct, the police carry those
investigations, not us.
But you carry out a level of investigation to identify
whether it is sufficient to provide to the police?
38
retail space or, to some degree, within the Contracts
Team, they should be sharing information with the
postmaster as they go along or at the conclusion of
their reporting. To the extent that the Dispute
Resolution Team, when they produce a report following
their investigations, they consider that they are
writing those reports for the postmaster.
Thank you:
"(d) That there were failures to follow all
reasonable lines of inquiry, including potential
alternative explanations provided by postmasters."
Yes.
Is that addressed and, if so, how?
So itis. It's covered in more detail in the
Investigator's Manual, which is the aid for people
conducting investigations. It's not a policy; it's
a guidance document. But, yes, lines of inquiry is
essential.
How is that addressed?
I think it's in there as a policy statement, which is
"You will follow lines of inquiry towards or away from
the investigative hypothesis".
"(e) Suspicions of knowingly making false assertions
relating to the reliability of Horizon data ..."
Yes, so in the -- I think in the policy we talk about
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the purpose of an investigation is to establish the
truth, not to achieve a particular outcome, and I think
that fits in there.
"(f) That Post Office failed to discharge properly the
duties of a prosecutor, especially in respect of
disclosure."
Now, you're no longer the prosecutor but how else is
that addressed?
Well, we state we're no longer a prosecutor and we
say -- and we will assist any prosecutor or
Investigations Team in the discharge of their disclosure
obligations.
What do you see as your disclosure obligations?
Well, I think, on a strictly legal basis, if we're not
the investigating authority or the prosecuting
authority, we don't legally have one under CPIA, but we
adopt that as a concept. You know, it's something that
we support and we would provide whatever law enforcement
want. To the extent that, if they move towards the
disclosure phase of their investigation prior to it
going to a prosecutor or a prosecutor moving to
disclosure to another party, then we will give them
everything we have.
When you say "everything", what do you mean by that?
So the contents of the case file, and we will not apply
41
statements, whatever is necessary. So I guess it's the
concept of transparency in investigations, and that
transparency has to be based on the retention of
material to begin with.
You've mentioned in terms of this policy that, when it
gets to Board level, there will be some further
discussion at least in respect of one aspect. But why,
in your view, has it taken so long to get to this stage,
and it's still not completed?
So part of it is volume of work within the team.
Principally, at the senior -- my level and my direct
reports, we've had a volume of operational work,
investigative work, setting up the assurance function
that has meant that we had to deprioritise something; we
couldn't do it all. So we that to deprioritise the
formalisation of that policy.
We've heard evidence from some witnesses about a fear of
decision making and a fear of accountability within
certain levels of the Post Office.
Mm-hm.
To what extent has that contributed to these new
policies not yet being implemented?
I think that's -- I think that applies to this as well.
Where do you say the responsibility lies for that?
SEG.
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any form of relevancy test.
A case file might include internal logs, internal
comment; is it envisaged that those kinds of things will
be passed to the police?
Yes, well, we -- I think we'd have to apply some common
sense but that would be in discussion with law
enforcement. So we would open our file, I guess, in
effect, to them, and then talk through what material we
have, what material they want to consider, as part of
their relevancy test, and then we will give it to them.
Thank you. Are there any other significant changes made
in that draft policy that you can point to that you
believe will make a significant difference?
So in there we talk about the retention of material.
I think that's important, the material that is received
‘or generated in the course of an investigation, and it
doesn't have -- it shouldn't be restricted to criminal
investigations; it should be any investigation. That
material should be retained, and we should be prepared
to reveal it.
So for example, if there's an investigation that
leads -- not in my area but in the contract space, for
example, they should be prepared to show material
evidence to postmasters or any other party that's there.
So show them CCTV, show them analysis reports, witness
42
The Senior Executive Group?
Yes.
Thank you. You've mentioned the Investigator's Manual
perhaps we can turn to that, that's POL00448014.
This is a document that is in force, it has been
approved, I think, in June 2023; is that correct?
Yes, that's perhaps giving it a higher status or
authority than perhaps it should have.
Because it's not a policy; it's a guide?
Correct.
This particular version is 19 September 2023, version
1.1. Is that the most up-to-date version, as far as
you're aware?
I'm not sure. There is constantly -- it's meant to be
a living document, so it's not -- there will be
different versions. I know another one is being worked
‘on at the moment, to some degree. It has been paused
pending the discussions in the next couple of weeks
around the new policy because, obviously, that will have
implications for the guidance that's required.
Where does this sit with those other guides -- other
policies, sorry -- that you've mentioned?
So it's not a policy. This is a manual, it's not
even -- it's not a procedural document. It's guidance.
I think it's been described as a handrail for
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investigators.
But it presumably needs to be consistent with the
policies --
Yes.
-- and will therefore be adapted as the policy adapts?
Yes, and, of course, policies are not "how to" guides:
policies should be a statement of a particular position
on an issue.
Thank you. If we scroll over the page we can see how
it's described in the foreword. It's page 4.
"The Post Office is committed to doing things
correctly. Our Values and Behaviours represent the
conduct we expect. This expansive and detailed manual,
its guides and templates support those of our colleagues
charged to help us ensure the highest standards of
integrity, proper behaviour, crime prevention, detection
and case management are maintained."
Did you draft this or presumably this is one of the
first documents that you were involved in, having joined
the Post Office?
It was a team effort, so the team put this together, and
then sections of it that relate to the operations in
other teams, so for instance the Retail Teams, they had
an input too and provided their elements of this manual.
Thank you, If we could scroll down the page and into
45
investigation or provide clarification on matters or
systems relating to the investigation."
So that's somebody, presumably, who isn't suspected
‘of something, they might be a witness?
They can help the investigation, yes.
Thank you:
"A conduct interview is conducted with a person
suspected of breaching Group policy or regulation and
there is no suggestion that a criminal offence may have
‘occurred. Authority to conduct this type of interview
must be obtained from the investigator's line manager
... designated deputy.”
What does that mean: investigator's line manager
designated deputy?
The interviewer's line manager or someone that might be
acting in their stead. So, for example, if the line
manager is on annual leave or sick, then someone should
be acting in that capacity.
Should that be line manager or designated deputy?
Yes, there should be a space between the "R" and the
"Oo".
‘Ah, manager or -- yes, thank you very much:
“A criminal conduct interview is conducted with
a person who is suspected of committing a criminal
offence and may be conducted by a police officer or by
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the "Introduction", we see there:
"This manual is intended to provide clear guidance
‘on the considerations that must be made when conducting
investigations. It is not intended to be a training
manual for Investigators. The manual prescribes the
professional standards which the Group expects of all
those that undertake investigations on its behalf."
Is this used not just by your team, then, but by the
other teams within the business who carry out the lower
level investigations?
Correct.
Could we please turn to page 16. This is actually the
section I mentioned before. I'd just like to spend
a bit of time looking at "Interviews". It says there:
"This guidance applies to all types of investigative
interviewing, not only to interviews conducted as part
of a criminal investigation. The principles are based
‘on ensuring fairness to interviewee but also to
facilitate an appropriately effective investigation."
Then it sets out three different types of interviews
that might be conducted: witness interviews; conduct
subject interviews; and something called criminal
conduct subject interviews. It says:
"A witness interview is conducted with persons who
are able to provide testimony to the event under
46
appropriately trained, professionally qualified and
experienced investigators within A&CI. Authority to
conduct such interviews can only be authorised by the
Head of A&CI [that's you] or their designated deputy.
"When conducting interviews, IOs ..."
What's an "lO"?
That's shorthand for the person that's conducting the
investigation.
An investigation officer?
Yes.
"When conducting interviews, [investigating officers]
must comply with the seven College of Policing
investigative interview principles. These principles
apply to all interviews, whether part of a criminal
investigation or any other form of investigation.”
So there is something called a criminal conduct
interview but, as you have previously said, that is not
something that you envisage taking place under caution;
is that correct?
So, when -- if it would help, I could explain the
background to this section.
Yes, please.
So when we first were tasked to start the team in early
2022, there was consideration that our team might do
interviews under caution in relation to suspected
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offences against Post Office. That affected the
drafting of this. That intent changed and so the new
version of the manual, when we know where we stand, in
terms of what's expected of us, this section will
entirely come out.
So, in future, will you just have two different types of
interviews or something else?
No, I think it would be a general witness who can assist
us within the Post Office or, indeed, outside the Post
Office, and then there will be the -- we call them
accountability investigations, so anyone who, during the
course of that investigation, might potentially be held
accountable for an event that we were asked to
investigate but that would not include anything
suspected -- a suspected criminal offence.
So, I mean, I'm not asking you to redraft this right now
but, if you could summarise what it might say in future,
‘once the proposal is passed, what do you envisage this
will say, in broad terms?
Okay. So I'm expecting us to adopt the general
guidelines around how to conduct an effective,
sensitive, witness interview. So --
So those College of Policing investigative interview
principles will stay, will they?
No, because they relate to the conduct of a criminal
49
"because we would like to talk to you about X, Y and Z
which we think you could help us with".
Then there are various bits about "You can have
a friend", and stuff that goes with that.
In terms of conduct, sometimes people might start as
a witness, and then as the evidence evolves, that may
change, in that they may then be accountable for
something they've done and that would be made clear to
them during the course of that interview, or any
subsequent interview.
Is that not problematic because somebody may say things
in an interview that they shouldn't be saying, because
they think you're interviewing them as a witness when in
fact your officer may suspect that they're more than
just a witness?
Not outside of a criminal context, no, because I think
you may go into an interview not really knowing what
this person can tell you, or having one set of views
based on what has been said by other witnesses, and then
that might change during the course of the
investigation. Bearing in mind we don't do -- the
resulting output of any of those accountability type
investigations, the worst-case scenario is that we would
make a recommendation that ER would conduct a code of
conduct type investigation, based on information we have
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investigation. So we would look at things like we can
look at the ACAS guidelines, we can look at College of
Policing do give guidance on dealing with -- on
interviewing witnesses -- vulnerable people and
witnesses generally. So we can look at drawing on that
sort of material, but also the ACAS side because we can
balance that -- those two approaches.
Will a person who is being interviewed know whether they
are being interviewed as a witness, as somebody whose
conduct is suspected of wrongdoing in some way and
whether -- here we have a third category -- something
even more serious than that.
Yes.
Will they be told the actual level of seriousness of
that interview?
They are, effectively, already. So because of our
history, we tell people who might be witnesses of any
type that they are not going to be interviewed under
caution because we want to be really clear about that
upfront, so they don't worry about that and they know
this isn't going to result in a criminal issue. We say
to them -- we write to people internally, Post Office
Limited staff, and say, "We would like you to meet with
the investigator", that could be one of my team, it
could be an external lawyer, for example, doing it,
50
gathered. So they would then have another opportunity
to speak with ER, and do it that way.
But --
"ER" being Employee Relations?
Yes.
I mean, is it not possible that you might pass on the
information to the police?
We haven't seen any of those so far and we -- I guess
theoretically, yes, but, on issues that are potentially
criminal, we try not to deal with too many people that
would muddy the evidential environment for the police.
How is that going to work, in practice, though, because
let's say you have a subpostmaster, you're not sure if
I they have been committing a crime, there's a --
We don't interview postmasters.
You won't interview any subpostmasters?
Well, it's not our role.
Who is going to be interviewing subpostmasters?
So, potentially, the Contracts team.
Even for a very significant loss?
If there's no suggestion of criminality, it won't come
to A&Cl.
If there is a suspicion of criminality, what happens?
You don't interview them or you do interview them?
We don't interview them.
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So they'll be interviewed by a tier below you that
doesn't have the training that your team is provided
with, because your team are the experts in
investigations, they'll be interviewed by somebody who
is not that top tier?
No. So as soon as a lower tier forms a suspicion, which
will not be based on -- well, it might be based on
something that's voluntarily offered during a -- and
saved to a call, to the call centre. So that's them
initiating contact. But my understanding is that
Tier 3, for example, do not speak to postmasters
particularly, so they won't be interviewing them.
So you won't have a postmaster's account, necessarily
No.
-- and you will have to determine whether something is
going to be passed to the police, based on what?
So we'll have to -- so that's -- so all the alternative
explanations are considered in Tier 2 and 3.
But a postmaster wouldn't have provided their
explanation?
Well, they may have volunteered information or
an account already but my understanding is that Tier 2
and 3 don't formally conduct an interview.
Can you assist us with the tiers: what is Tier 1,
Tier 2, Tier 3?
53
But those are discussions, not interviews?
Yes.
What determines the extent of an internal investigation
prior to reporting something to a law enforcement
agency?
I'm not aware that we've reported anything to law
enforcement relating to an internal investigation.
How about the actions of a subpostmaster, an apparent
discrepancy, or something along those lines?
Okay, so we have had -- so none of our, I think it's 16,
cases that A&Cl are currently working on that we've
reported to the police, none of those relate to a cash
shortfall.
In those particular cases, how do you determine whether
to pass something to the police or not?
So there is often information provided by another
person -- another party. So, for example, we've
reported a matter to the police where the postmaster has
reported that a family member has run off with a bag of
cash -- a pouch, cash pouch. We've had issues where we
have taken a witness statement from a postmaster who was
subject to coercive behaviour from a partner that has
resulted in activity in the branch that has come to our
attention.
So we will seek to get that additional evidence and,
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I think Mel Park addressed that yesterday.
Can you briefly address that?
So the vast majority of issues are, as I understand it
are dealt with at the call centre, and then the funnel
sort of narrows, the pyramid narrows. So those issues
that can't be resolved at that level are then escalated
to Tier 2. Most issues are dealt with there, and then
a much smaller subset are then passed to Tier 3, who are
very technically capable, and then they are the ones
that make referrals to us.
Although the guidance that we're seeing here refers to
these various types of interviews, actually, we should
read into here somewhere that this only applies to
people directly employed by the Post Office or it
certainly doesn't apply to subpostmasters?
In the main, yes. So there are -- so there are a few
occasions where the Contracts Team do speak with
postmasters over potential contract breach issues, and
what the purpose of this is, for them, is we would like
them to apply the same concepts of fairness,
transparency, sensitivity and openness in those --
document keeping, recordkeeping, and that sort of thing,
that you would have in another situation, so that they
are treating the postmasters fairly in those
discussions.
54
when reporting the matter that affects Post Office, we
would pass that information on as well, and that would
form part of our decision-making process to do it.
Thank you. I'd just like to talk about two other
policies very briefly before we take our mid-morning
break. The first is the Financial Crime Policy of July
2023. Could that be brought up on screen, that's
POL00447947. This isn't your team's policy, is it,
I don't think?
No, it's not.
In your statement, though, you have identified at
page 14 there was an error. If we could turn to
page 14, please. It's the bottom of that page in
respect of "Internal Financial Crime/Fraud". At the
bottom there, it says:
"Detective Controls:
“All reports received of or instances identified of
internal fraud will be fully investigated and where
appropriate, Post Office will prosecute individuals."
You've identified that as an error in that policy.
Are you aware of that having been amended since it has
been identified?
I know people were instructed to amend it. I don't know
whether they have.
The final document that we'll go to before the break is
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the Subpostmaster Contract. That's POL00000254. So
this is the Standard Postmasters' Contract. If we could
turn please to page 71, this is an issue that's been
identified and addressed with other witnesses, including
Mr Read. We can see there that it refers, at the top of
the page, to the "Investigation Division" and, if we
scroll over the page, we can see, for example, it refers
to "Enquiries by Officers of the Post Office
Investigation Division". At point 12, it says:
".., the Investigation Division does NOT enquire
into matters where crime is not suspected."
Is this it of date?
Absolutely. So, if I may, it might assist.
Yes.
In early August, I was asked by the lawyers who were
reviewing Postmaster Contracts to come up with a new,
better contract, fairer contract. I was asked to review
sections of this and I've asked for all of this to be
taken out.
Is it surprising, given the level of scrutiny that has
been taking place for years now on Postmaster Contracts
and on the policies and procedures of the Post Office,
that that has remained in there for so long?
I think I was very surprised it was there.
Who, in your view, is responsible for that?
57
postmasters?
It says in the new draft manual that we won't conduct
interviews under caution. I'm not sure it goes down
another level. I was thinking in the break perhaps we
need to separate out in the investigation policy, so
that we can be explicit as to what applies to
a postmaster linked investigation conducted in Retail,
for example, as opposed to inhouse -- Post Office
Limited type people.
Has there been an explicit decision that Post Office
will not interview postmasters?
There has been a decision that my team will not
interview postmasters, yes.
I think where we got to before the break was that the
other teams wouldn't interview postmasters: they would
have a discussion with them?
Yes.
Are you aware of any overarching decision that no
interviews will take place with postmasters?
So my understanding of practice and policy within the
retail space is that they do not do interviews.
‘SIR WYN WILLIAMS: = There may be a degree of difficulty, in
practice, in deciding whether what is, in fact,
happening amounts to an interview or a discussion,
right? Forget interviews under caution, that's clear.
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I don't know who actually owns Postmaster Contracts, I'm
afraid.
Would it have been your predecessor who would have
inputted into that?
I don't consider myself to have a predecessor but I take
your point: do you mean the Head of Security?
Perhaps.
Okay. I imagine they -- yes, partly. But I think
Postmaster Contracts are likely to be owned in their
totality in a different department.
MR BLAKE: Okay. Thank you.
Sir, that might be an appropriate moment to take our
mid-morning break.
SIR WYN WILLIAMS: Fine.
MR BLAKE: Can we come back at 11.40, please?
SIR WYN WILLIAMS: Okey doke.
MR BLAKE: Thank you very much.
(11.23 am)
(A short break)
(11.39 am)
MR BLAKE: Thank you, sir.
A.
Mr Bartlett, just to revisit that issue we were just
addressing before the break, does it say in the
investigators manual or in any of those policies that
we've looked at, that the Post Office won't interview
58
There has to be a caution. I understand your evidence
‘on that. But how is anyone to determine when
a discussion becomes an interview, Mr Bartlett?
You've got experience, I know, of both police and
other regulators in respect of this. I mean, I'm
familiar, obviously, with the situation in which
an employee -- let's forget subpostmasters, to take the
heat out of it -- has a discussion with an employer or
is formally interviewed by an employer about various
things. It's not an interview under caution, the
employer isn't doing anything like that, but they are
trying to get to the bottom of something, if I can put
it in that way.
Yes.
SIR WYN WILLIAMS: In practice, how is the difference to be
A
delineated?
I think it's very difficult to draw a distinction,
myself. It depends what definition of an interview that
one would want to settle on. You know, is it
a structured conversation with the objective of
establishing facts or experience of a particular matter
in hand? That could be one definition, in which case my
view is that that will occur in the retail space but it
depends on what they mean and what is meant.
25 SIRWYNWILLIAMS: Yeah, I mean, let's take the example that
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I raised with you to understand the process in respect
of involving outside investigators. When Ms Tutin was
speaking with Mr Read, I would expect that most people
would call that an interview, not a discussion.
A. lagree, sir.
SIR WYN WILLIAMS: Right. So, I'm only asking completely
open-mindedly: is it possible, in a document like
a manual or a policy, to actually lay down when
a discussion becomes an interview or vice versa, for
that matter?
A. Itis very difficult, and I think there are a range of
views as to when an interview is -- what an interview is
and when it is occurring.
SIR WYN WILLIAMS: Yes, I think -- well, I have some
sympathy with that, having seen various manifestations
of all this over 50 years. Anyway.
I think the more important question for me is: can
you foresee -- this is not about interviews under
caution, all right, I understand what's going on about
that -- but do you foresee any problem about there being
the facility for investigators, whether part of your
team or any other team, when appropriate, to interview
someone?
A. I think, in any other organisation, no, sir, I wouldn't.
In post office, because of the sensitivity of the past,
61
Q. -- and then that filters down throughout the rest of the
business and, by your assurance purpose, you ensure that
the rest of the business essentially keeps to the kinds
of standards that your department sets?
A. Yes.
Q. Sos it not your responsibility and your department's
responsibility to formulate the policy with respect to
interviewing, or however you may call it,
subpostmasters?
A. I think we would play a central part in that,
absolutely, but it needs to be a collegiate approach
because a lot of the staff that would need to do that
would not be within my team and I know that they would
be uncomfortable in some situations in doing that. So
I think it's something I can take away and discuss.
Q. The Investigator's Manual is a manual that your team is
responsible for; is that right?
A. Yes.
Q. The Group Investigations and Cooperation with Law
Enforcement Policy, the new policy, again, that is
something that your team are responsible for?
A. For drafting, yes.
Q. So wouldn't your team be responsible, ultimately,
however much consultation you carry out amongst other
teams, for a policy that addresses what to do in
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which I completely understand --
SIR WYN WILLIAMS: So what we're really grappling with is
the fact that, because of the history, people are very
sensitive about what might be regard as oppressive
interviews. That's the reality of it, is it not? So
they're trying to do everything they can to avoid it?
A. Yes, and I think it's something that the people who
would be spoken with would like to avoid and are
cautious about --
SIR WYN WILLIAMS: Sure.
A. participating in but, absolutely within Post Office,
there is huge nervousness about those sort of
conversations happening.
SIR WYN WILLIAMS: Fine. Thank you.
Sorry, Mr Blake.
MR BLAKE: No, it's been helpful, sir.
Can I just follow on, just to establish who is
responsible at the Post Office for formulating
an overarching policy that addresses that issue?
A. I think it would need to be a combination of different
teams.
Q. The way I understood your witness statement and your
evidence was that your department, A&Cl, essentially
sets the overarching POC for investigations --
A. Mm-hm.
62
circumstances where a postmaster, or their assistant, is
being interviewed?
A. Yes, once that policy is formulated and approved, then
yes, we would.
Q. Can you assist us with why such a policy is not yet in
place?
A. Because of the sensitivities -- sorry, that particular
element of the policy or the policy generally?
Q. Why there isn't a policy that sets out, for example,
what to do if, during an interview or a discussion, you
suspect somebody of criminality? Where does someone
turn to in the business, in the Retail Team, in the
Contracts team, where do they turn to to answer that
question?
A. They would contact our team.
Q. Your team currently doesn't have a policy. Why doesn't
it have a policy?
‘A. Because the landscape is constantly changing.
What does that mean?
A. In terms of the expectation or appetite within the Post
Office for investigations, it's not been yet nailed down
to my satisfaction. There's also --
Q. Isn't this is an absolute perfect example of that fear
to take things forward in the business because things
are going to be sensitive forever, if you let them?
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No, I would agree with that.
Can you assist the Chair with when such a policy might
be implemented?
Not with a specific date, no, because I'd need to go --
we'd need to go back and consult with other departments,
get their input, run it through the approvals process,
there. It will absolutely --
There's consultation, consultation, approvals processes
in all of these policies. We're years down the line
now.
Yes.
Can you say to the Chair when you anticipate that those
various consultations will have developed a policy that
relates to the interviewing of postmasters?
I can't say for certainty because I can't control that
but my ambition would be that we would have it done,
perhaps by the end of the calendar year or the financial
year.
Which calendar year?
This calendar year.
I'd like to move on then to liaison with law
enforcement. The Post Office formally ceased private
prosecutions on 22 September 2020; is that right?
Formally, yes.
I think you've said that they, essentially, didn't have
65
shows?
I think it shows that issues are being resolved in the
Retail Teams now on a more equal, collegiate and open
basis, through the process Mel Park oversees, that
perhaps in the past went straight to a criminal
investigation.
Do you think that those matters are being resolved
through Mel Park's team?
Yes.
Do you know how many prosecutions have actually taken
place, not just reported to the police, but actually
taken place, either in respect of that particular time
period or in respect of any time period that you're able
to assist us with?
From matters that we've reported?
Yes.
None.
None. So there have been 25 reported to the police --
(The witness nodded)
-- none have actually reached the prosecution stage?
Not yet.
Do you anticipate that a high proportion or a low
proportion of those 25 will reach that stage?
I don't think it -- that I'm able to comment on that
because I don't know what evidence the police have.
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a criminal trial for fraud, theft or false accounting
after the Second Sight Report, so after 8 July 2013,
subject to, I think you've said, there's a caveat in
your witness statement, that addresses an instance in
2015?
That's correct.
You've provided some data in your statement,
paragraph 89 onwards. There are lots of caveats in the
figures that you have provided but, broadly speaking,
you have set out that there have been in the region of
328 investigations into alleged fraud, theft or false
accounting since 8 July 2013; is that correct?
Yes, so I believe it was 301 were done in the old
Security Team, whilst they thought that they were
waiting for the business to continue, as they saw it.
So a much smaller figure that has been carried out under
your team?
Correct.
You say that there have been in the region of 25 that
have been reported to the police in that period; is that
correct?
That was correct to the time of writing the statement,
yes. I'm sure that may have changed since writing the
statement.
What do you consider the difference in those figures
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But I mean, those 25 go back to 2013, some of them,
presumably --
Not the ones we've reported.
Sorry, can you assist us, how many have you reported
since your team has been in place?
I think that's the 25 figure but I would need to check.
Okay.
‘SIR WYN WILLIAMS: Well, I'm sorry to interrupt again but am
A
I right in thinking that these 25 cases are the ones
that are summarised in your appendix -- I'm calling at
that -- from page 105 onwards?
It's included in the appendix, sir, yes, I think with
summary of others.
SIR WYN WILLIAMS: So we've actually got, at the end of
A
that, the last column of that analysis tells us if
there's been a closure date, in other words the case is
‘over one way or another, or whether it's ongoing? As
far as you're aware, is that still essentially the
picture or has it changed from the time you produced
your witness statement?
I think it's broadly the same, sir.
‘SIR WYN WILLIAMS: Yeah, okay.
MR BLAKE: Thank you.
I'd like to look at a number of Group Executive
Report decisions and Board decisions that relate to the
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issue of placing with law enforcement. Can we please
turn to POL00447975. We start on 20 April 2022 and
that's a Group Executive Report, you're listed there as
‘one of the authors of this report, and it sets out the
background to the establishment of what was then the
Central Investigations Unit, the CIU. If we scroll
down, we can see it says:
"Following detailed assessment, KPMG concluded in
their report of August 2021 that Post Office should
create a Central Investigations Unit. The introduction
of the CIU was to ensure [Post Office-wide]
investigations would be properly planned, resourced,
documented, and executed; with lessons learnt fed back
into the business. KPMG also recommended a target
operating model.
"Post Office decided to form a CIU and the Head of
CIU was appointed on 21 February 2022."
That's you?
Correct.
"We are seeking approval to recruit the rest of CIU in
line with KPMG's recommendations", and it sets out there
what was required at that point in time.
Paragraph 4 says:
"All observations made by KPMG are considered as
being met or [adopted] in this proposal which is as
69
So when I say "in part", I mean, it hasn't landed as
a branch, if you like, but the assurance and consistency
of approach methodologies has.
Thank you. So I don't know, what does the word
"virtual" even mean?
Well, certainly not in the same management chain. So as
‘opposed to a single chain of command with different
teams reporting in to us, into the same hierarchy and
up, what the virtual side is, for example, in Mel Park's
team, she has several team leaders that report into her
and she reports into someone different, to who I report
to. So that's why it would be virtual.
Thank you. If we scroll down:
"Business-based, decentralised teams conduct the
highest volume and lowest risk casework with the CIU
conducting the higher risk or more complex
investigations.”
That's accurate, is it?
Itis.
If we scroll down, it says there, the penultimate bullet
point:
"An alternative to private prosecutions is proposed
to permit criminality evidenced by Post Office
Investigators to be progressed in all four nations of
the UK in order to act as a deterrent and to seek
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follows:
"A virtual Post Office Investigations Branch
develops a one-team approach to Post Office
investigations, ensuring the application of best
practice across the organisation."
Is that in place?
Partially.
I mean, we spoke earlier of something overarching that
ensures the consistency of all of the investigations;
was that the aim of that?
Yes, it was.
When you say "partially", why partially?
1-
If we scroll up, sorry.
That's okay. The intent at the time was perhaps to have
a more -- so to help to embed practice approaches, it's
always good for different teams to have the same purpose
and to relate well to each other and to understand the
positions and that was the idea of a virtual scheme.
The business prefers a linear approach, which is
stuff -- reports come into the call centre, they go
through the process of Tier 1, Tier 2, Tier 3, and come
to us, and I think there was not the appetite within the
organisation to have something called an Investigations
Branch because of the history of the organisation.
70
financial recoveries."
Can you assist us with what that means?
Where we have suspicion that a criminal offence may have
occurred and harm may have been caused to the Post
Office because of that suspected criminal conduct, we
should report it to the police.
Thank you. "Seeking financial recoveries", this is
a term or similar words are used in a number of other
documents. To what extent is it necessary, in your
view, to use the criminal justice system to seek
financial recoveries, as opposed to, for example,
a civil claim?
I'm not sure I understand the question, sorry.
We'll see in a number of places that there's reference
to criminal prosecutions, passing matters to the police,
in order, amongst other things, to recovery money. Is
it your view that the criminal justice system is the
appropriate place to recovery money, and is it seen as
more helpful than, for example, civil proceedings?
Oh, okay. So to be very clear, the purpose of engaging
with the criminal justice system is not to recover
funds. That's not the overriding purpose but it is
an output of the criminal justice system for any
individual or organisation. So it wouldn't be to engage
law enforcement in order to recover funds. In fact,
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I believe I've said that in a SEG meeting and asked for
it to be minuted.
I think we'll come to that.
Okay. But it is a potential output. The reality of
that producing much is low.
Can you assist us, the authors are listed as yourself
and Sarah Gray. Did you draft different parts or are
you ultimately responsible for
No, I did the initial draft and then Sarah reviewed it
and made amendments that we agreed.
Thank you. If we stay then on this page and if we
scroll down, I'd just like to ask you about the bullet
point on this page. In this it's bullet point 5, we'll
see it appears elsewhere as well. It says:
"The Post Office Investigations Branch was the first
recognised investigation unit in the world dating back
to near the foundation of the Post Office itself. It
has an unblemished reputation.”
It gives its motto:
"... Gentle in Manner, Resolute in Deed, which is
very much in keeping with the intended approach of the
new investigation function."
Did you draft that?
\ did.
Can you assist us with why it's thought that the
73
sought from the Group Executive here is to approve, for
onward distribution to the Board, the following three
things: first that the Post Office, Post Office staff,
postmasters and postmasters' staff, all being within the
remit of the Post Office Investigation Branch. But, as
you say, that didn't happen, or there was no
investigations branch?
No.
“CIU to conduct criminal investigations", so that's your
team?
Yes.
"Mobilising a new partnership model with the relevant
bodies across the UK to facilitate the investigation and
referral of suspected criminal misconduct."
If we scroll down, the "Executive Summary" is that:
"CIU will be staffed from September 2022 and full
‘operational by January 2023."
There's the proposal, halfway down, that the
Investigation Branch remit includes Post Office and Post
Office staff, postmasters, and postmasters' staff for
a range of matters, based on employment, ownership of
property and practical factors.
Although the Investigations Branch doesn't exist, do
you see your own team's remit as including all of those?
Yes, but also the Retail Team.
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Investigations Branch has an unblemished reputation?
Because that applied in principally -- no, I'll rephrase
that. The security and investigation -- or the Security
Investigations Team that are responsible for the scandal
was not what I was referring to. Here, I was referring
to earlier, much earlier, iterations of an investigative
capability within the Post Office.
Because, plainly, the Investigations Team that was part
of the Security Team was involved in matters that the
Inquiry has been investigating?
Absolutely.
It's not, presumably, your view that they have
an unblemished reputation?
The opposite.
We're going to move on slightly in time. Can we please
look at POL00448354. This is a Group Executive report
of 6 July 2022. Am I right to say they have quite
similar wording all of these reports but they did go
separately to the Group Executive?
The one we just looked at was April 2022. We're now
in July 2022.
Mm-hm.
The proposals are changing slightly; is that right?
Yes.
If we scroll down, we can see that the input that is
74
As in both of you have responsibility or the remit of
both your team and the Retail Team includes those
individuals?
Correct.
Thank you:
"Post Office has no appetite to pursue private
prosecutions. However, it is proposed that Post Office
Investigators conduct investigations into suspected
criminality and to report what has been evidenced to law
enforcement and prosecutors in all four nations of the
UK. The rationale being to act as a deterrent and to
seek financial restitution through the independent and
external criminal justice system.”
Again there, slightly different wording, but there's
the reference there to "acting as a deterrent and
seeking financial restitution".
Do you have a view as to whether too much emphasis
is being placed on financial restitution through the
criminal justice system?
Too much emphasis in regards to in the document?
Yes.
Um --
In this document and similar documents?
No, because I think court enabled confiscation and
compensation is part of -- is an established part,
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an accepted part, of the criminal justice system, and so
maybe an output from one of the CPS or whoever are
prosecuting --
Yes.
-- and a court finding of guilt.
As a former police officer, do you think that you might
put too much emphasis on the criminal justice system as
being used as a root for, for example, financial
restitution, as opposed to non-criminal courts?
No, because I have been out of the police longer than
I was in the police. So my last law enforcement
experience was 17 years ago. So I have had a variety of
non-law enforcement roles since then.
Have your other roles involved the criminal justice
system?
Sometimes but not always.
Do you think that your focus might be too much on the
criminal justice system as a mechanism to obtain
financial restitution.
My commentary and connection to law enforcement is not,
again, restitution.
Can we scroll down, please, to page 2. At 1.2, it seems
there that the Group Executive agreed on 20 April 2022
to the forming of that virtual Post Office
Investigations branch.
77
Office] funds have been misappropriated ... and where we
seek only a commercial outcome to these events. For
example, where evidence obtained via an investigation
supports a suspicion of someone having defrauded [the
Post Office], they should be reported to the police
irrespective as to whether or not the loss has been made
good so that a credible deterrence may be established.
Existing policies facilitates the reporting to police
but not the preceding internal investigation. This
paper seeks the [Group Executive's] approval for CIU
staff to conduct criminal investigations within the IB's
remit and report these matters to police when
appropriate and in accordance with the CLEP."
It then sets out the operating model. It says:
"As a government organisation, Post Office is viewed
by law enforcement differently from a privately owned
company. It is unfortunately fact that LEAs.
deprioritise most reports of crime made by
government-linked organisations if made in the
traditional way."
Can you assist us with that?
Yes, my experience outside of the Post Office, as well
as within, is that police forces will prioritise the
allocation of resources, investigative resource, to
general members of the public first, which I think is
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(The witness nodded)
So what happened that meant that that didn't, actually,
ultimately take place?
As the various phases of the Inquiry progressed, members
of the GE became increasingly sensitive -- and I don't
mean that pejoratively, I just mean that they were
generally more sensitive -- to the use of language, and
so support for labelling, naming and acting, as
a collective function -- across functions lost its
appeal.
You mentioned earlier parity with the Retail Team in
certain respects, in terms of investigation functions.
Is a risk that, now that that doesn't exist, that that
overarching oversight has been lost in some way?
No, I think the insurance work that we conduct is the
practical measure of that.
Could we please turn over to page 5. Page 5 has
a heading "Operating Model -- Criminal Investigations".
I'd just like to take you through a few passages from
that. If we scroll down to 3.4:
"As a wholly government-owned corporation in receipt
of government funds, it may be viewed that we have
a duty to investigate as well as report suspected
criminal events to the relevant authority. We may be
criticised for not doing so, particularly where [Post
78
correct. Then there's a sort of hierarchy,
unofficially, of who is assisted, and government-owned
institutions come forwards the bottom of that list. And
so sometimes there is a struggle for law enforcement to
adopt honestly-held and submitted reports of crime.
Has that been your recent experience with the police?
Yes.
It says:
"There is an expectation that a degree of
self-sufficiency exists. Without recourse to private
prosecutions an alternative is required if the interests
of Post Office, postmasters, our staff, our shareholder,
and the public are to be protected."
Then it makes the proposal. It says:
"Suspected offences with an element of criminal
dishonesty would form the vast majority, if not all, of
‘our criminal investigations and potential referrals.
This would include theft, fraud of all types, and money
laundering. These types of offences are those which
most LEAs do not have sufficient, nor sufficiently
skilled, resource allocated, and which are lengthy to
investigate, often resulting in them not being
prioritised. If we do not investigate these matters
prior to referral then the likelihood of preventing the
loss of public money significantly diminishes, as does
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any deterrence factor.
"Jurisdiction is also relevant. Typically,
authorities in Scotland are less inclined to adopt
evidence collected by non-LEA investigators. England
and Wales LEAs expect an almost complete case in an
admissible format and Northern Ireland is likely to be
somewhere between the two."
Just pausing there, if the policy is to not
interview postmasters or their assistants, how can there
be sufficient information to meet that almost complete
case?
It can't, which is -- this is an example of how the
environment has changed since I started in the Post
Office and the appetite of the Post Office.
So is it your view -- and I don't want to put words in
your mouth, please do answer exactly in your own
words -- that the not interviewing of postmasters is
going to significantly limit the ability to take matters
forward in the criminal courts?
I think it makes it more difficult for the police to
adopt an investigation. I don't think it -- and then it
would sit with them. So for them to use the
investigative tools that they have, that we don't and
shouldn't have, as a corporate, they need a basis in
which to open an investigation, and it would be easier
81
get to that point, [Post Office] will need to collect
admissible evidence to assist over-stretched LEAs and
that requires competent, evidence-led, ethical
investigators."
Can you assist us with the current position insofar
as that's concerned: has there been, for example,
a letter sent to the City of London Police Economic
Crime Team?
A letter was sent to the Chief Constable -- sorry, the
Commissioner of the City of London Police, and there is
no dedicated team within the City of London Police, but
they have agreed -- because they also are lead force for
fraud and they oversee the fraud reporting position for
the country -- well, for England and Wales -- they have
undertaken to look at cases had come through Action
Fraud that we report. That's the extent of that.
Well, one proposal is contribution from the Post Office
to the cost of police investigations.
No, those discussions haven't taken place.
Scotland, Northern Ireland have --
So Northern Ireland, we're hopefully about to sign
an MOU with them, in terms of a single reporting point
for Post Office. That's not an undertaking by PSNI that
they will investigate everything we tell them or report
to them at all but it establishes a pipeline for Post
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for them to do that if an interview, for example, or
other techniques have been used to gather evidence that
they can consider.
"England and Wales", it says the proposal is for:
"A CEO letter to [what's now the Department for
Business], and then on with a Minister's endorsement
requests assistance from the Commissioner of the City of
London Police's Economic Crime Directorate ... to work
in partnership with the CIU to investigate and then
refer to the Crown Prosecution Service all strong cases
of dishonesty-based offences above a certain level of
complexity or monetary loss;
"A dedicated team to be formed within [the City of
London Police Economic Crime Department] ...
"Post Office or [the Department for Business] may be
asked to contribute to the cost of this team."
Then there are also similar proposals for Scotland
and Northern Ireland.
Paragraph 4.7 says:
"By seeking partnership working in this way, [Post
Office] demonstrates that we do not operate as victim,
investigator and prosecutor. Conceptually, the police
and the prosecutors will decide on the strength of
evidence [that] they will (or will not) progress through
the criminal justice system, not [the Post Office]. To
82
Office to go to a single point of contact.
In Scotland, we have a good, informal working
relationship with the Economic Crime Unit there but,
again, that's just so we have a single referral point
into someone that understand the issues that we're
dealing with. It doesn't affect their independence as
an investigator, and it doesn't guarantee that those
matters would be adopted as an investigation.
Thank you. Can we please turn to POL00448321. This is
a meeting of the Group Executive, "[Group Executive]
Tactical Meeting", 3 August 2022. We can see matters
being discussed over the page, please. It says,
"Investigations, Sarah Gray and John Bartlett"; did you
attend this meeting?
Yes, it looks that way. I don't remember it
particularly but it says I attended.
Let's have a look from the third bullet point down, if
we could scroll down, slightly:
"SG [Sarah Gray] outlined the 3 approvals requested
from the [Group Executive]. The remit in terms of the
applicability of the CIU branch was not controversial.
The part that was more controversial was the proposal in
relation to the CIU conducting criminal investigations.
To be clear, we were not looking for the CIU to
undertake criminal prosecutions; we were proposing that
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the CIU undertook criminal investigations before
referring. In terms of why we wanted to do this -- we
were a cash business and £2.5 million had been
identified as potentially being recoverable ..."
Do you know how that figure was arrived at?
I don't think that's correct. So it is -- I believe at
the time it was true that the apparent value of loss to
Post Office of the potential criminal matters that were
afoot totalled 2.5 million but it absolutely would not
be recoverable.
Do you have an idea of what that current figure might
look like?
So -- well, if you take it as not what could be
recovered but the total value of potential loss, is
about 3.6 million.
Thank you. If we scroll down:
"NR [Mr Read] queried whether the culture was that
people were back footed due to the situation over the
last 3 years. [Ms Gray] replied that whilst the vast
majority of [postmasters] were decent honest reliable
people, in any big group there would be people who
looked to take advantage of loopholes and there was
knowledge that there would be no deterrent. This was
incredibly disheartening for police who undertook the
investigations then saw the work go nowhere.”
85
that it may be suggested that you were perhaps too
focused on the criminal aspect rather than the civil
aspect, but that's something that you don't agree with
there?
So that was a discussion about the Proceeds of Crime Act
and recovery through the courts.
Yes.
So that's what the discussion was about.
But Mr Mladenov suggested, for example, that civil
recovery could be the root to recover losses.
He did, yes.
The focus from you seems to be on the Proceeds of Crime
Act; what's your view on that?
Because the discussion was around court cases and the
recovery -- sorry, criminal court matters, and so that
was the focus of the conversation.
Do you think there's been sufficient thought given
within the business to actually using the civil courts
to recovery money that's owed to the Post Office?
I believe papers have been taken to SEG in relation to
civil recovery.
Yes, and what role do you see you having in that?
I think, as mentioned earlier, we might assure the
evidence collection and testing of that evidence.
What is your view as to whether civil recovery, or using
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Is that something that you had been experiencing?
No, I think that relates to the Retail Team.
Thank you:
[Ms Gray] referenced the legal duty the Company has
as an organisation in receipt of public funds to
investigate and then refer suspected criminal conduct;
we were not currently completely fulfilling this duty
Then it goes on to you. It says that:
[You] noted [Post Office's] ownership structure and
shared [your] view that we needed to be doing more when
it came to criminal investigations; we could provide
evidence to law enforcers and prosecutors to assist them
Then this is Mr Mladenov:
"... noted that we could still recover losses via
civil recovery. [You] agreed that civil recovery
remained open to us, or we could pursue under the
Proceeds of Crime Act, so we could ask law enforcement
to ask the court for the criminal proceeds to be repaid
tous. We would also assert that we were asserting the
rights of [postmasters] when [postmasters]] staff stole
from them, so Proceeds of Crime Act was likely the best
way to recovery monies
This touches again on the same point I made before:
86
the criminal courts and the Proceeds of Crime Act would
be more appropriate as a general policy?
That's a difficult one, it depends on what perspective
you come from, I think. So, for example, if I was
a postmaster or postmaster's assistant, and I was told
that Post Office wanted to take me through a civil
recovery process I would be worried, the reason -
because history. And the reason being, I feel that, is
that there would be no independent assessor of evidence
between the Post Office and that material being
introduced into a civil court.
So, in essence, a civil process is adversarial --
(The witness nodded)
-- whereas a criminal process you have the level of the
police involvement as well?
And a prosecutor so it's two additional levels.
Thank you. We see there at the bottom, if we could
scroll down, please:
"SG [Ms Gray] noted that after encouraging a culture
of speak up, we had seen allegations increase of fraud,
theft or nebulous financial crime. NR asked for more
detail and also asked who was making the complaints.
[You] advised that [postmaster] staff were reporting
more than [postmasters]."
So have you seen an increase in the postmaster staff
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reporting crime?
We did at that time. It was the predominant category of
reporting through the Speak Up service at that time. It
isn't now. That's changed. But, at that time, that was
the case.
What is it now?
Behaviours at senior level.
What do you mean by that, sorry?
So people at -- the predominant or a high number of
reports through the Speak Up line, at the moment, are
commenting or reporting poor behaviours at Head of
Department level or SEG level.
Without going into any specific detail of specific
complaints can you give us a flavour of what those focus
on?
They are often around bullying, harassment -- sorry, not
harassment. Bullying, poor conduct, matters that would
normally be -- that would be dealt with in an ER
context.
Thank you. The final bullet point there:
“In AC's [I think that's Mr Cameron] absence,
[Ms Gray] raised his concern regarding the reliability
of evidence whilst we remained on Horizon. [You]
replied that you could choose which data we relied on
and we would use the most reliable data. [You]
89
where we proceeded and handed over to law enforcement
and prosecutors, it would be on the basis of having
conducted sound and thorough investigations ..."
If we scroll over the page, please. Thank you:
[You] advised that you had spoken with public
prosecutors service, and they were willing to work with
us. What we wanted to achieve was a strategic
relationship as it would be the same officers who dealt
with the cases."
Is that what we saw earlier?
That is -- what is missing from there is the Northern
Ireland Public Prosecutions Office.
Ah, so that was specific to Northern Ireland, was it?
Yes.
"[Mr Foat] noted that it was important to emphasise that
the case assessment, decision and conclusion would be
performed by the external prosecutor. Post Office had
a legal and a moral obligation to provide the
information of suspected criminal misconduct to law
enforcement and there was a public narrative that
supported that approach.
"[The Group Executive] RESOLVED to APPROVE for
‘onward forwarding to the Board for noting:
"[Post Office], [Post Office] staff, postmasters and
postmasters' staff all being within the remit of the
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furthered advised that in speaking to MR, MR's team ..."
That's Mr Roberts, is it, Martin Roberts?
Probably.
Sorry:
"... MR's team were not seeing any inherently
unreliable data."
Just pausing there, in this phase we've heard some
criticism of Mr Roberts: Karen McEwan was critical of
his abilities; the Subpostmaster Non-Executive Directors
also raised concerns about Mr Roberts. Did you have
concerns or do you have concerns about Mr Roberts’
abilities.
I didn't interact very often with Martin Roberts so
I haven't seen a range. I certainly wouldn't know
anything about his performance.
Do you know how he could have formed the view that they
were not seeing any inherently unreliable data; what was
your understanding at that time?
So that's through the application of the process in the
Retail Teams, where they look for what bugs, errors,
defects, calls to the helpline, existed around those
particular transactions that they were looking at.
So they look at helpline data?
I believe so.
"NR noted that whilst he took [Mr Cameron's] point,
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Post Office Investigation Branch;
"CIU to conduct criminal investigations; and
"The Mobilising of a new partnership model with the
relevant bodies across the UK to facilitate the
investigation and referral of suspected criminal
misconduct."
Are you able to assist us with why the Group
Executive approved that to the Board for noting, rather
than for active discussion at Board level?
No, I can't.
Can we please turn to POL00448320. So that was August
2022. By 27 September 2022, we have a Board report. Is
that the report that followed those discussions at Group
Executive level?
Presumably.
We have you there as the author, alongside Sarah Gray.
It says, "The Board is asked to note", and that's
exactly as we saw it in the previous document.
If we scroll down, we can see the recommendations in
terms of the operating model at page 6 and 7 remain the
same and you've explained the ultimate decision that was.
taken in respect of progressing that matter?
Yes.
Can we please turn to POL00448327. We're back at Group
Executive level now, we're now in 2023, 28 June 2023, so
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this is nine months later, and you are reporting to the
Group Executive in respect of prioritisation and
resourcing of your department; is that correct?
Yes.
It says there:
"The [Group Executive] is asked to agree the
priorities for CIU for the next two financial years ..."
So that takes us into now.
Yes.
"... and approve the additional funding recommended
below necessary to service the current and projected
investigations within these priorities."
So by this stage you'd been given approval to carry
out investigations into criminal matters; is that
correct?
Correct.
If we scroll down, please. We can see a section over
the page on "Prioritisation". It says:
"[The Post Office] requires a business as usual
central investigation function which is resourced to
deliver quality investigations in priority areas at
an appropriate scale and to assure the investigative
capabilities of the Dispute Resolution, Network
Monitoring & Reconciliation, and Contracts teams.
Financial Crime, Data Protection & Information Rights,
93,
If we scroll down, I'd just like to read to you from
paragraph 6:
"The intention to conduct a full network count of
stock and cash prior to rolling branches on to NBIT will
reasonably generate significant numbers of criminal
investigations. CIU will be required to play its part
in managing this investigative demand. CIU is not
staffed to meet current requirements and certainly not
a short to medium-term increase caused by the move to
NBIT. The rollout of NBIT will almost certainly
generate significant case work for CIU during the
all-branch audit phase."
This is something we have heard some evidence on, so
the idea is that, once NBIT is up and running, all
branches are audited?
Yes, I think the idea is so it's a fresh start on a new
system.
“Whilst this is difficult to precisely anticipate, if
only 1% of branches are found to have issues that need
potential criminal investigations to resolve shortfalls
or stock issues then a potential [circa] 115 new cases
will result.”
So is it still your anticipation that when the move
is undertaken to the new system, NBIT, that there will
be a significant number of new criminal cases?
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and ER investigation teams could also be assured in this
way in the future.
"[The Post Office] also needs the central function
to be able to flex in a way that allows it to deliver
[investigations required] outside of, and in addition
to, business as usual.
"[The department] is not currently resourced to
deliver these demands."
Can you assist us with that; what was meant by "not
currently resourced"?
We were being asked more than we had capacity to do.
Is that capacity in respect of funding, in respect of
manpower or something else?
Predominantly staffing.
We'll get to, in due course, how things developed but
was this approved?
Not entirely.
In terms of additional resourcing, was sufficient
resourcing provided?
No.
Why not, in your view?
Because the Post Office has limited budget, it has to
make difficult funding decisions and, on this occasion,
it was decided that this -- that there were other
priorities.
94
I think it depends what NBIT -- what the new system
entails and what it looks like. So is it going to be
a direct replacement or is it going to be a different
thing? I don't know at the moment. But if the -- the
presumption here at that stage was that it would be
an entirely new thing rolled out and, therefore, the
audits would be required, and that would remain the same
if that becomes the case.
When you say you don't know at the moment whether it
will become a new thing or not, NBIT's relatively far
down the line now, certainly in terms of the time it's
being taken to be built, are you sufficiently aware of
those developments of NBIT to be able to forward plan?
Not at this stage, no.
Why not?
Because I'm not sure -- I think the strategic review and
the NBIT project are yet to settle on something firm to
that level of detail, I think. I have provided a this
what we would need from an investigative perspective, in
terms of data access and understanding and things like
that, so I have been engaged at that level.
We saw from the reporting lines, you report to the
Interim General Counsel. Do you think that you are
sufficiently involved in the business, both structurally
and in practice, to be able to input sufficiently into
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the NBIT system?
I mean, it's a technical project, and we are being
consulted and we are providing an input in terms of,
from a practical point of view, once it's in place, what
we would need in terms of data to be able to perform our
role.
How about the concern that's being raised here: do you
think the business sufficiently understands the
resourcing impact that the all-branch audit, for
example, or simply the new system, might place on you?
I believe so it was evident in this paper, and it
wouldn't be CIU that would need to be involved: there
were many operational teams that would need to be
involved in that rollout.
Can we turn over the page, please, and there's a section
there on NBIT rollout and assisting the reset. It says:
“All suspected theft/frauds to be passed to CIU who
will then triage them and report as necessary to the
police. Where a report is for amounts in excess of
£100,000 then CIU will provide active investigative
support to the police. Where the summed is below
£100,000, CIU will form a link between the Retail
Central Operations investigation teams and the police to
facilitate the obtaining of evidence and witness
statements by the police."
97
moment, we apply the same level within our teams at the
moment but we flex it depending on available resource
and what matters are requiring investigation.
If we look down to "Business Integrity Operations (1) --
protection of public funds". It says:
"Investigate all suspected theft and fraud offences
against the [Post Office] and manage the interaction
with police for cases over the value of £100,000. For
matters below £100,000, CIU will manage a reporting
process to the police, but the police will need to deal
directly with other [Police] teams ..."
Sorry, that's
"POL teams".
The second bullet point there:
"Provide support to case having and testing of
evidence for civil recoveries [over] £50,000. Matters
below £50,000 would need to be supported by external
counsel (for which there is currently no funding) or not
proceeded with."
Can you assist us with that?
At the time that this was written, there was work
underway to look at whether civil cases was an option,
and as we -- as I mentioned earlier, the anticipated
involvement of A&Cl, or CIU as it was then, would be to
effectively provide quality assurance over the evidence
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Is that still the intention?
I think it would be the start point. There is no plan
that's cast in stone at this stage.
I don't want to pin you down on dates again but when do
you anticipate have to a plan might be in place?
I think it would depend on what the target rollout date
is, and I don't know what that is.
Is there a risk by placing this value threshold -- say
£100,000 goes to your team, below that goes to another
team -- of some two-tier system developing within the
Post Office with respect to investigations?
So this is in terms of -- so what it says here is that
we would provide active investigative support to the
police for over 100,000, but we would introduce the
police investigators for other matters below that
100,000 direct into the business.
Yes.
So you're still having police look at all of those
matters, so that's the same; the difference is the level
of involvement from my team. But it is a two-tier
system.
Do you think the 100,000 mark draws a line
appropriately?
I think that flexes, depending on -- well, it would --
it's a start point. It's slightly arbitrary and, at the
98
that had been collected.
At that point in time there was currently no funding; is
there funding for that and what's currently envisaged
for that?
I don't believe there is funding. I think it's still
a concept under discussion.
Thank you. Can we please turn to POL00447948. There is
then discussion of this paper at the Group Executive
level on 28 June 2023. Sarah Gray is present at this
meeting. Were you an attendee?
Er--
Pardon?
Sorry, I was just thinking. I don't know. I'm not
listed as having attended.
If we turn to page 6, it has your name but it may be
that your name is on the paper rather than attending it.
(The witness nodded)
Actually, no, it does mention "JB", so let's have
alook. If we scroll down, please, to the bottom of
page 6, it appears that you were at the meeting.
Okay.
It's over the page, sorry. It's internal page 6, our
page 6. "Central Investigation Unit Resourcing", if we
scroll down.
Yes, I'm noted there as attending but not at the top.
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Yes. It says:
"JB [you] spoke to the paper outlining the request
for additional resource to service the backlog of
investigations (which was increasing) and also to pin
additional support ahead of the rollout of NBIT where
there could be a number of referrals to CIU."
It sets out there "Even if the 1%", that's exactly
the same as in the paper itself:
"NR [Mr Read] queried how would [you] prioritise
[business as usual] work in [your] team. [You] replied
referencing the prioritisation as set out in the paper
"KS [I think that's Kathryn Sherratt] clarified that
the ask was an increase in budget. [Sarah Gray] replied
that it was, however outlined the potential financial
pay back with future years. [You] noted this and shared
[your] view financial savings should not be the basis
for the decision ..."
I think that's the point you were making in your.
evidence earlier.
Yes.
"... it was only one element. KS advised that whilst
the Group Executive did not appear to disagree with the
ask, that there needed to be understanding as to where
this money would come from in the budget..."
101
unfair.
"ACTION KS noted similar requests for additional funding
that had been and were coming to the Group Executive and
advised that the Group Executive needed to devise
a process to deal with these requests as the year went
on. [She] advised she was happy to take an action to
think about the best way to process these requests.”
You have there:
"The [Group Executive] RESOLVED:
"that the priorities for CIU [for those financial
years] are ... APPROVED; and
“in order to prepare for and manage anticipated
pre-NBIT rollout branch audit matters additional funding
in the amount of £360,000 to provide the resource as set
out in the paper is hereby APPROVED."
But it then says:
"The [Group Executive] declined to approve the other
additional funding requests in the paper at this time."
Where did that leave matters and have matters
changed since then?
So the 360 for the NBIT was to come from the NBIT
budget, so it was to use an existing budget to pay, if
required, whenever we got around the NBIT rollout, that
we could provide that support to that programme, which
in effect meant no extra money was being assigned out of
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Over the page, please.
"TM [Mr Mclnnes] queried whether a scaled up CIU
team was part of path clearing and NBIT preparation.
[Mr Mladenov] replied that the additional resource in
the CIU team required for NBIT should be charged to
NBIT. [You] contributed that it was not simply an issue
of scaling up the team, it was a matter of matching
resource to task."
What do you mean by that?
So there are two approaches to team staffing and remit
making. One is, you decide what you want to achieve and
you resource it properly, or you decide what your
resource is, and you task reasonably what that team can
deal with. We had neither of those.
"[You] raised a concern around fairness to postmasters
with relation to the capacity of CIU, for example,
suspended postmasters would remain suspended until CIU
had capacity to address the case ...”
Can you expand on that, please?
Yes, that's talking hypothetically that, if a matter was
referred to CIU for us to investigate, because it --
there was some suspicion of dishonesty and if, as
a consequence of that referral, the Contracts team had
suspended a postmaster, a case sitting on our books
because we don't have enough people to deal with it is
102
the normal Post Office budget because it was the NBIT
budget. So where that left us was I didn't get any
additional resource and, to a point you've made
previously, which is that this is an example of no
decision making.
Is it still the position?
I've had some additional, I think two, fixed-term
contract provision since. But I don't have a team --
going back to those two options, we don't have enough
people in the team to deal with -- comfortably deal
with, in a way that won't break my people, what's being
asked of us, and we're spending a lot of money on
external lawyers to do that work that we can't do.
When you say "external lawyers", we spoke much earlier
about using external firms.
Yes.
In respect of what work and how, actually, is that
a saving to the business?
Itisn't a saving to the business.
Why is it, in your view, that funding can't be extended
to your team in the way that you're asking?
So we get it -- we get funding on a -- so -- an outcome,
actually, from what Kathryn Sherratt is talking about in
this paper is that an Operational Expenditure Committee,
I think it's called, was established, which is a central
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point for all teams within the organisation to go to
when they've got unexpected funding requests. So that
was a positive outcome. It was centralised, it was more
coordinated.
And when we have an investigation where we feel
there's a need to go outside to have law firms or
whoever, accountancy firms, conduct that investigation,
we go there and we ask for the money, and that has, so
far, always been authorised. But what hasn't been
authorised is a permanent increase in the headcount
within my team. So, initially, those two extra
Investigation Managers that I mentioned earlier, they
were to be permanent, they were authorised to be
permanent, and then it was downscaled to being temporary
on a fixed-term contract for a year.
So I think -- I can understand a commercial decision
being let's have a -- let's not increase an ongoing
expense, it might be simpler to -- or more expedient to
have a temporary increase in cost.
Thank you. There's one final document that we'll go to
before the lunch break and that is at POL00458015. The
document we've just been looking at is June 2023, this
now October 2023 and it's a Post Office Board meeting.
If we could please turn to page 117. Sorry, it might
take a moment to come up.
105
provision of evidence to the police where [the Post
Office] suspects that they have been a victim of a crime
and allow more efficient sharing of evidence with
police."
Can you assist us with the purpose and the
background to this?
So it’s two-fold. The first request was in a compliant
way -- policy compliant way that the Board approved the
passing of evidence to Police Scotland on a case that
they were investigating. So that was the first one.
And then it was to elicit, or -- yes, to elicit
views from the Board as to what their views would be
about a change of process in terms of authorising future
passing of evidence to law enforcement.
Can you assist us with how this developed at Board
level, whether it was approved or not approved?
So they approved the passing of that in compliance with
the policy, of that particular piece of evidence to the
police, and then there was a discussion in the Board
that did not approve but wanted further discussion,
about the change in authorisation levels.
Do you understand why it was not approved?
It was very difficult to tell, during the course of that
Board meeting. It wasn't the best run Board meeting.
People were talking over each other. It was struggle to
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If we go over the page, perhaps. This is
a document, a Board report, dated 31 October 2023. It's
written by you. I'm just going to read to you from the
“Input Sought" and the "Executive Summary", and this is
something that we spoke about earlier today:
"The Board is asked to 1) approve in line with
policy to pass evidence to Police Scotland; and 2) for
Board to discuss the pros and cons of a policy change
which would allow a more confident handling of Horizon
data and its provision to law enforcement."
The "Executive Summary" says:
"[Post Office's] current Investigation Policy,
Cooperation with Law Enforcement Policy, and Legal Play
Book requires Board sign-off to permit the passing of
HNG-A Horizon evidence to the police to support their
investigations where [the Post Office] may be the victim
of a crime;
"In line with this Policy, Board sign-off is sought
for the passing of evidence to Police Scotland relating
to", and that's a particular case?
A. Yes.
Q. "Following the implementation of robust processes and
the hiring of highly experienced staff, a change to the
current Policy and Play Book is recommended. This would
remove the necessity for Board approval prior to the
106
understand the different views that were being said at
the time but I think the underlying objection for
those -- so some of the Board supported the change:
others didn't; others, I think, were unsure. And so
they agreed that they wanted more discussion about it.
But I think those that were in the "No, we shouldn't
change" group, I think they felt that what would be
passed would be data that could be considered to be
unreliable, that they still viewed or felt that it could
be viewed that the data was flawed.
Q. We'll get to --
SIR WYN WILLIAMS: The date of the meeting is what, sorry?
MR BLAKE: 31 October 2023.
SIR WYN WILLIAMS: 2023. Sorry, if you were going to ask
this question, Mr Blake, but this actual issue is still
under debate in October 2024, is it not?
A. Yes, sir.
‘SIR WYN WILLIAMS: Right.
MR BLAKE: You've said "not very well run". Can you assist
us with that: who was running it at that stage?
Henry Staunton was the Chairman.
What did you identify as the issue with regards to how
it was run?
o>
>
There was no structure or control over the conversation.
Were there particular tensions between particular
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groups?
A. Yes, I think the group that felt it was appropriate for
a change were disagreeing with the group that felt that
there shouldn't be a change and they weren't really
listening to each other.
Q. If we go over the page, please, we see there it says:
"The current Group Investigation Policy was written
during the long hiatus from 2015 to 2023 where [the Post
Office] did not conduct investigations nor proactively
pass evidence to the police. This Policy identifies at
1.3 Core Principles, including proactively reporting
matters to law enforcement and the manner of the
provision of information and for what purpose it may be
shared.
"Policy minimum control standards requires that the
Group Legal Director makes the decision to report
a potential crime against [the Post Office] to law
enforcement. Tool 2 of the Legal Play Book is
a flowchart which lays out how data intended to be
shared is categorised by risk and how it may be provided
to law enforcement.
"Where the evidence is not Legacy Horizon or HNG-X
and where there is no reason to believe the data to be
provided is unreliable or inaccurate, corroborative
evidence should be sought. Where none can be discovered
109
the current status of those discussions? Your evidence
has been that that change hasn't been made; why do you
think it hasn't been made, and who do you think is
responsible?
A. So think that the decision hasn't been made because of
the obvious sensitivities connected to saying,
“Actually, we think the version of Horizon that we run
at the moment is fit for the business to use". I find
that slightly odd because, if there were concerns, why
are we using it?
MR BLAKE: Thank you.
Sir, that might be an appropriate moment to take our
lunch.
SIR WYN WILLIAMS: Yes, by all means, yes.
MR BLAKE: Can we come back at 2.00, please?
SIR WYN WILLIAMS: Yes, of course.
MR BLAKE: Thank you very much.
(12.57 pm)
(The Short Adjournment)
(2.00 pm)
MR BLAKE: Good afternoon, sir.
SIR WYN WILLIAMS: Good afternoon.
MR BLAKE: Mr Bartlett, I'm going to pick up where we left
off, and that is the issue of reliance on Horizon data.
I want to go back in time slightly and, if we could
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in [the Post Office's] control, the evidence is to be
considered Medium Risk."
Can you assist us with that paragraph in particular
and how it is that corroborative evidence can be sought?
So that part of the policy is basically saying: if it's
the current version of Horizon, it can be passed, but it
would be -- sorry, it would be considered medium risk if
there wasn't anything else to corroborate that evidence.
Does that reflect in some way a concern that there may
be unreliable data within even the new system?
I didn't write that and I wasn't party to it, but my
reading and my understanding from those that were around
at the time is that it's a sensitivity issue, not
necessarily a distrust of the data. It's a "We're
seeking to rely on Horizon data; that didn't go well
before".
1.4 says:
"Point 3 of Tool 2 describes how the provision of
Medium Risk data to law enforcement must be managed:
‘The data must not be provided unless [the Post Office]
is legally compelled to provide it or the Board approves
its voluntary disclosure’."
It's that point that you were seeking to change?
Correct.
Thank you. In line with the Chair's question: what is
110
begin with BEISO000789. These are notes from a meeting
you weren't present at but I think it does set a scene.
This is the Post Office quarterly shareholder
meeting on 10 January 2023. If we scroll down, we can
see who was present. Please can we turn to page 4.
There's discussion there of what to do in respect of
losses. I'd like to take you to the third bullet point.
It says:
"AC [I think that's Mr Cameron] mentioned they are
seeing a rapid increase in losses including shortfalls
of cash in branches. [The Post Office] need to conduct
a proper investigation and demonstrate whether the
postmasters are accountable. However, it is difficult
to conduct a proper investigation based on the Horizon
data, and also [the Post Office] are not in a position
to ask for the relevant money back in the current
climate. It was noted as not a good time to prosecute
postmasters due to the current historical cases, but
this is seeing a rapid rise in losses for [the Post
Office]. MR's team are working on putting a new system
in place."
Was that a feeling that you shared as at January
2023?
I was not aware of that.
No? How about at the present time: is dare there, for
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example, a rapid rise in losses for the Post Office?
I don't know.
If we look down it says:
"AC raised that there are other solutions rather
than going to the police. If postmasters are
responsible and don't pay the money back, there is
an option to take it off their remuneration. Any
solutions as to how any shortfalls that postmasters are
accountable for can be recouped from postmasters, aside
from remuneration, were noted as preferable.
"[Post Office] -- In cases where there is fraud,
these could be tested in a civil jurisdiction. A paper
on this was noted as being worked on currently and would
be raised to [the Government] in due course."
Are you aware of that paper having been developed at
all?
I think that might have been the paper or the work that
I referred to earlier today but -- I'm not sure about
the timing but I think it might be.
Has that work been completed?
Yes, and I think that's led to there's no decision at
the moment, and I think, as Mel Park said yesterday,
it's still being considered.
Thank you. If we scroll down, it says there:
[Post Office] noted that where full investigations
113
Judgment --
"... Data."
Then he sets out various things that need to take
place. But, as you said, your understanding at this
time, you didn't have understanding of these issues at
this time?
No.
Can we please turn to POL00448362. This is a loss
recovery update. We have metadata that suggests it's
from February 2024. It does refer to your team in its
current form. Are you able to assist us with when this
might have been produced?
No, I think the first time I saw this was when it was
raised with other witnesses in the last week or two.
If we turn to page 3, it's the "Background" section, and
this you may have seen raised with other witnesses:
"Following the recommendations made in the Group
Litigation Order and Common Issues Judgment, [the Post
Office] ceased action to recover Established Losses from
[postmasters]. This activity has been on hold since
this time, except where a [postmaster] both agrees to
repay the established loss and proceeds to repay.
"To support implementation of associated [Common
Issues] recommendations, a new team ... and target
operating model was set up ...
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are done quite often [the Post Office] does get the
repayment. The issue is that the investigation has to
be good enough and that it is independent. However, the
problem is that the data is not sufficient to do
an investigation in many cases.
"[Mr Read] noted that ultimately those who steal
from [the Post Office] will be prosecuted.”
The concerns about the data not being sufficient for
an investigation: as at January 2023, are you aware that
that was a concern within the organisation?
So at I think about that time there were concerns not
over Horizon data but over stamp stock dispatch data,
and I know Al Cameron was close to those issues. But
this does seem to say it relates to cash shortfalls and,
no, I wasn't aware of that.
If we turn, please, to POL00423698. Around this time,
24 January, we have an email from Mr Cameron to Nick
Read. It's not an email you were copied into at the
time but he says:
"My view on losses, which I think you would know
but:
“From a cultural view we cannot start trying to take
money off postmasters until we have demonstrated HIJ
I think that's Horizon Issues Judgment.
114
"The process to review a discrepancy and identify
the cause is formally documented and regularly assured
by the Assurance and Complex Investigation Team."
So that's your team?
Yes.
That's an accurate statement?
So the -- yes, itis.
"This includes looking at Horizon transaction data to
ensure Horizon acted as expected and is therefore
unlikely to be the cause of the discrepancy."
Just pausing there, I think we addressed this
previously but the looking at Horizon transaction data,
can you assist us with what that involves?
So the safeguard side of this are the actions taken
within the Retail Teams, which is what bugs, errors,
defects had been reported that could be referring to
that branch, at the relevant time, and the relevant
transaction type. They look at training issues, they
look at calls into what is effectively Tier 1, the call
centre and then they look all the way through. So
I think that's what that means.
"There are a number of possible outcomes ..
“Write off as below de minimis value ...
"Write off as the cause has not been established,
"Correct with a transaction correction if the cause
116
(29) Pages 113 - 116
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was due to a processing error,
“Establish that the loss has arisen on the balance
of probabilities, due to the negligence, carelessness or
error of the [postmaster] and/or their assistants.
"In the last case above, the [postmaster] is asked
to contact the Postmaster Account Support Team to
arrange repayment ...
"If the [postmaster] disagrees with the findings,
they are able to refer through an internal dispute
process ...
"Currently repayment for discrepancies is only
sought from a [postmaster] voluntarily ..."
Then it is 7, really, that I'd like to look at:
"Whilst the current discrepancy review process does
involve checks in Horizon, the target operating model
and ultimately any recovery activity is predicated on
Horizon data being robust and for [the Post Office] to
be able to rely on this data. [The Post Office] is
currently awaiting confirmation from both Fujitsu and
[Post Office] IT that this is the case."
Now, if that metadata is right, if this was February
2024, are you aware since then of confirmation being
provided by Fujitsu and the Post Office IT Team that
that is the case?
So, the letters that have been brought up at the Inquiry
117
I believe he's the relationship manager at Fujitsu.
Thank you. We've seen this email before but I will read
from it because it's quite an important document in the
context of this dispute:
"One of my team has gone back to City of London
Police to see how the contact you referenced below was
progressing as we have an open and objective engagement
with [City of London Police City] on this matter.
"[City of London Police City] has informed us that
they have not had any additional information nor contact
with Fujitsu after the single, exploratory and
inconclusive conversation. They left that conversation
with the feeling that they were indirectly being told
that the Horizon system was unreliable and so the case
could not progress. We really need to explore this as
this is not the nuanced impression Simon Oldnall has
given me.
“As the potential victim in this case, [Post Office]
would be grateful if you could provide me with contact
details for either the equivalent person in Fujitsu ...
to my role ... or an appropriate person in your UK legal
team. I will then pass those details on to [City of
London Police] who are looking to have a trilateral
conversation with Fujitsu, [Post Office] and [City of
London Police]."
119
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over the last few weeks from Fujitsu, between Fujitsu
and POL, I think the final sort of letters on there show
that, although Fujitsu do not want POL to use Horizon
data for this sort of activity, they did not say it was
unreliable. In fact, they said that the data could be
used for appeals and it could be used for the
calculation of compensation for postmasters.
So I think that has been taken as a confirmation
that the data is correct because Fujitsu would not, I am
sure, want that data to be used in a Court of Appeal
case if it's not accurate.
So your reading of all of the correspondence, and we'll
get to some of it, between Post Office and Fujitsu, is
in effect confirmation from Fujitsu that the Horizon
data is reliable?
Yes, and also, if I may say, is -- there must be a duty
on Fujitsu to declare if they think it is unreliable,
and they haven't, as far as I'm aware.
Can we please turn to FUJ00243203. This is, I think,
the beginning of a dispute between you and Fujitsu. It
may have a longer history than that but I'm just going
to take you to this particular document, which relates
to supporting a City of London Police investigation.
That is 19 April, and it's an email from you to Daniel
Walton; who is Daniel Walton?
118
Just pausing there, do you think it is appropriate
for the Post Office, who could in some senses be
described as the victim -- and we will get to whether
"victim" is the right word or not -- do you think it is
right for the Post Office to be contacting Fujitsu in
respect of the City of London Police investigation?
Yes.
Why do you say that?
Because the feedback that we were provided from City of
London Police showed that there was some confusion as to
what was wanted and what was needed, and I felt that, if
I could speak to another investigator within the Fujitsu
organisation, that they would understand the evidential
needs of City of London Police and, therefore, be able
to better help the City of London Police.
Why, in your view, was it appropriate for Post Office to
do that conversation rather than, for example, the City
of London Police directly?
Because it was agreed with City of London Police that we
would do that.
The next paragraph says:
"It is impossible to overstate how important this
is: I need to advise both the police and [Post Office]
as to the evidentially-established reliability (or not)
of data that is being used every day in establishing
120
(30) Pages 117 - 120
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‘outcomes with postmasters and, potentially, to be
presented to the criminal justice system by the police
and the three public prosecuting agencies. The
non-provision of relevant witness statements from [Post
Office] and Fujitsu will rightly be interpreted by the
police and prosecutors as [Post Office] and Fujitsu not
having faith in the reliability of the data with the
obvious outcome resulting.”
What do you mean by “with the obvious outcome
resulting"?
So two different things: one is the immediacy for that
investigation, which would be closed, which, just to be
clear, we would agree with. We're not trying to push
through that case to conclusion. We want the evidence
to be tested by the police.
And then the broader outcome is if Fujitsu provided
awitness statement to the City of London Police that
looked at the individual transactions and whether, at
that time, date and that branch, with those particular
transactions that that evidence was -- that those
transactions were not necessarily reliable, that would
mean something would need to be done in terms of looking
into whether it's a systemic issue or just relating to
that branch.
But by failing to provide any witness statement,
121
Sorry, Mr Blake, just before we go on to this, can
Ihelp a bit further? I think we will probably have
material from that period in time, that was
contemporaneously made, that will show that we were
thinking about the wider impacts of this. It may not be
reflected with clarity in my email that you've just
shown, but I believe we have material that might be able
to demonstrate we were thinking about the wider impact.
Sorry, what do you mean by that; do you mean the focus
‘on the final few words --
The outcomes, yes.
So I think your evidence is that you could have
articulated it better, is that --
Yes.
Thank you. Looking at this letter, this is a letter
from yourself to the Lancashire Constabulary. Could we
perhaps bring up on to screen your second witness
statement, which is WITN11190200.
As the Chair has highlighted, there is an annexe to
your witness statement that includes a list of different
cases. It's at the back of your statement, and I'll
just take you, please, to page 105, so this where it
begins. Can we please turn to 118. There's a reference
there to Lancashire Police, case of 14 September 2022,
money laundering and theft. Is that the same case as we
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which was what -- the impression we were being given at
that stage, means that doubts should be brought into the
reliability of the whole system. So the outcome would
be that we would be recommending that, urgently, the
organisation -- Post Office looks at whether we should
continue to be using Horizon and to calculate payments
to postmasters, to whether our annual report and
accounts should be signed off. It's a significant
issue.
The obvious outcome resulting, though, one reading of
that sentence is what you're saying there is that,
without it, the police are obviously going to drop the
case?
That was -- that is one outcome, yes.
That's the obvious outcome, isn't it?
Itis one of the obvious outcomes, yes.
Did you mean for that to imply several obvious outcomes?
Yes.
Did this come as a surprise to you?
Yes, it did.
We saw that discussion from a year earlier, concerns
within the business. Why do you think it is that those
concerns hadn't reached you and your department?
I'm not sure.
Could we please turn to FUJ00243192?
122
see this letter relating to?
Yes.
Thank you. I'll just read for background that section
that says:
"The branch which was run by an Officer In Charge,
not the postmaster, was initially flagged by the Cash
Centre due to an increase in cash remittance return
amounts to the Cash Centre. It was also highlighted by
the MoneyGram compliance team that they wanted to
complete a compliance call with the branch to a large
number of high value transactions being completed to the
same destination. At this point the Financial Crime
team was involved and highlighted circa ..."
Is that £3.3 million?
Yes.
"... worth of MoneyGram Mobile send transactions
processed at the branch. The Financial Crime team
contacted the branch on requesting more information
regarding these transactions. On the same day, the
Financial Crime team was contacted by the Area Manager
who advised that the postmaster was in touch with them
and advised of a possible shortfall of £400,000 which
was related to the MoneyGram transactions. The CIU was
advised of the situation and tasked with completing
an investigation into this matter. Police have
124
(31) Pages 121 - 124
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interviewed the OIC ..."
That's the person in charge of the Post Office?
Yes. Sorry. Yes.
"... and restrained [circa] £500,000. Enquiries
indicated by Horizon was a shortage of £398,000 which if
proved would be a loss to [the Post Office]."
So it's a case involving nearly £400,000 of
potential loss to the Post Office.
Correct.
"Police worked on the basis that the OIC ‘creamed off
this amount from the cash transferred through MoneyGram.
Customer is considered money laundering suspect and OIC
suspected for potential conspiracy [regarding] money
laundering and theft of [circa] £398,000 from [the Post
Office]."
If we return, please, to page 118. We see on the
second from right column:
"Police requested statement regarding robustness of
Horizon -- [Post Office] producing a statement and also
referred police to Fujitsu.”
Has the Post Office produced a statement relating to
the robustness of Horizon?
That is in train and it is to be delivered by the end of
next month to Lancashire Police.
If we go back to the letter, please, it's FUJ00243192.
125
progressing to a charging decision. It is not for [the
Post Office] to influence the independence of the
investigation or the assessment of evidence in any case,
however, the reasoning around the credibility of the
Horizon system seems to be a significant factor, if not
the central factor, in the reasoning for not progressing
this investigation further and that reasoning appears to
be based on a misinterpretation of the findings of
courts.
"[The Post Office] have been asked to address three
questions in respect of the decision to No Further
Action this matter ..."
So had a decision to no further action the matter
taken place by this stage or was that something that was
just in contemplation.
I'm not sure, at this stage.
[Post Office] hopes that the information provided below
in respect of these questions is sufficient to assist
with a review of that decision. The questions posed
are:
"(a) the new Horizon system is much more reliable
than the old system
"(b) evidence that a court has ruled so
(c) that the new system was installed and in place
[in that particular post office]."
127
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It looks as though, as at 25 April of this year, the
police had taken no further action in respect of this
case; is that correct?
No, they'd submitted an advice file to the Crown
Prosecution Service and the Crown Prosecution Service
came back to them in relation to the money laundering
and the theft case matters that they wanted some --
effectively, a corroborative witness statement from
Horizon to support other evidence that the police had.
When you say from Horizon, from who: from the Post
Office or from Fujitsu?
CPS, I don't think, specified, but I'm not sure but, in
effect, the best evidence is held by Fujitsu, as opposed
to Post Office, which is why we referred Lancashire
Police to Fujitsu.
I'm just going to read to you from this letter. If we
scroll down slightly, it says:
"Post Office Legal have reviewed ..."
Just pausing there, did you draft this letter?
I stitched it together. The majority of the stuff, of
the text in there in relation to Justice Fraser's
comments are from the criminal lawyer within house.
That's Mr Lill?
Lill, yeah.
"Post Office Legal have reviewed the reasoning for not
126
If we scroll down, (c) is answered first, and you
say:
"We can confirm that [that] branch was operating the
HNG-A version of Horizon."
Then you address questions (a) and (b), and you say:
"The Horizon Issues Judgment ... is the judgment of
Mr Justice Fraser where, in short, he found there to be
numerous bugs, errors and defects affecting the Horizon
system that were capable of generating unexplained
shortfalls in branch accounts ... In the [Horizon Issues
Judgment], Fraser J made clear that it was important to
distinguish between the versions of the system in use
from 2000 to 2018, and the HNG-A system being used
thereafter ..."
You set out various sections of the judgment, and
there, the first section, Mr Justice Fraser says, for
example:
"It is agreed by the experts that the Horizon system
in its HNG-A form is now relatively robust."
Over the page, another section on robustness, where
he says that:
he experts are agreed that it is far more
robust than Horizon in earlier times."
A further section, where Mr Justice Fraser says:
".., there are only isolated instances of it
128
(32) Pages 125 - 128
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happening in respect of HNG-A, which the experts agree
is a better system than either of the other two
iterations of Horizon ..."
If we scroll down, please, again:
"I have found that the system as it is in 2019 is
far more robust than it was prior to 2017."
So that's a comparison between the 2017 and 2019
versions. You say:
"Lancashire police may have noted that the proposed
legislation by the government to exonerate all
postmasters prosecute by [Post Office] acknowledges in
the Explanatory Notes ..."
You quote from the government's explanatory notes.
It says there:
"The Department is not aware of any cases prosecuted
by CPS or Post Office Limited involving the HNG-A system
and therefore has concluded that there is no reasonable
case to extend the period [and this is in terms of
exoneration] beyond the conclusion of the use of the
previous versions of Horizon."
Further down the page, you then address the Hamilton
case, and you say:
"In Hamilton, the [Court of Appeal Criminal
Division] defined a case as a 'Horizon case’ where the
reliability of Horizon data was essential to the
129
clear the safety of those convictions, even though the
evidence relied upon was taken from versions of Horizon
that were the subject of the [Horizon Issues Judgment],
are not unsafe where there is other evidence of the
offence being committed or where the Horizon data was
used to corroborate other evidence."
Over the page, please. It's a passage on the next
page that I'd like to focus on. If we scroll down,
thank you, it's that passage there:
"If the defence were to challenge the reliability of
Horizon data, which the Post Office accepts is highly
likely, the prosecution would be entitled to rely upon
the findings of [Mr Justice Fraser] and the [Court of
Appeal Criminal Division] as set out above.”
Is that accurate?
That information, that section, was provided by the
inhouse lawyer.
Looking at it as somebody who, for example, has
a graduate diploma in law, do you consider that passage,
which was in a letter which you signed, to be accurate?
So it would certainly be useful to a prosecutor to be
able to draw on that judgment in discussions with
defence, which I think is the point that the lawyer is
trying to make. I don't think he's suggesting it's
evidence; I think he's suggesting that it's useful, in
134
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prosecution, in that there was no independent or
corroborative evidence of an actual loss from the branch
account as opposed to a shortfall where Horizon evidence
formed part of the evidence of the shortfall or
corroborated other evidence."
Over the page, please. You say:
“It is important to note that the Horizon scandal
relates specifically to [the Post Office] prosecutions
of postmasters for shortfalls in their branch accounts
where the only evidence to prove the loss was a reliance
‘on data from the Horizon system.”
Is that accurate, do you think?
That was the information provided to me by the inhouse
lawyer.
The next paragraph says:
"The decision to NFA the investigation appears to be
based on the public perception of the scandal and the
versions of Horizon in use at the time of the scandal.
It is not clear whether the CPS EIA have considered the
written judgments of the Horizon scandal when assessing
that the undermining issues in the case outweigh the
realistic prospect of conviction."
It says:
"Further, the [Court of Appeal Criminal Division]
have reviewed many appeals of convictions and have made
130
order that it's not just dismissed out of hand. That
was the purpose of this letter.
Don't the police and the CPS have to reach a certain
evidential threshold?
Yes, they do. This doesn't question that. It's just
saying "Please apply an evidential threshold, don't
dismiss it out of hand before".
Is a fair reading of that paragraph not that you can
rely on those findings, those judgments, to satisfy the
evidential criteria?
No, it's saying, "Please don't dismiss this out of
hand", and you could use that judgment in conversation
with any defence, should it progress that far. I think
that's what he meant by this.
Do you think that is both fair and accurate?
I think it's fair that this particular case is not
dismissed before an evidential test can take place.
If we could please turn back to your statement and the
annexe. That's WITN11190200. Page 105 is where the
table begins.
We've already looked at page 118. If we could zoom
‘out, please. Bottom of page 118 was where the
Lancashire Police case can be found.
The wording there, in the second-from-right column
132
(33) Pages 129 - 132
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"Police requested statement regarding robustness of
Horizon -- [Post Office] producing a statement and also
referred police to Fujitsu."
If we scroll down, please, to page 121. There is
a City of London Police case, again, same form of words
in that second-from-right column:
"Police requested statement regarding robustness of
Horizon -- [Post Office] producing a statement and also
referred police to Fujitsu."
Page 125, there's a section there addressing
Gloucestershire police and, again, the same form of
words in that column, “Police requested", et cetera.
If we scroll down, please, page 126. West Yorkshire
case, again, same form of words.
Page 127, West Midlands case. Again, same form of
words.
Putting the Lancashire case to one side, has there
been any case where the Post Office has produced such
a statement for the police in respect of the robustness
of Horizon?
No.
Is it the intention for the Post Office to produce
a statement addressing the robustness of Horizon?
Yes, so it will be -- it's been produced -- we have
a draft. It's been produced by Simon Oldnall but, in
133
looked at it in great deal already in this Inquiry but
I'll just look at some of that correspondence. Here we
have the letter to Nick Read from Mr Patterson of 17 May
this year. He says:
"lam writing to you directly in order to raise
serious concerns that have come to my attention which
indicate that the Post Office continues to pursue
enforcement action against postmasters and it expects
[Fujitsu] to support such actions.
"To be clear, [Fujitsu] will not support the Post
Office to act against postmasters. We will not provide
support for any enforcement actions, taken by the Post
Office against postmasters, whether civil or criminal,
for alleged shortfalls, fraud or false accounting.
In particular:
"Criminal investigations:
"We have become aware of a recent investigation by
the City of London Police ..."
I think that's the correspondence we've been looking
at.
Yes.
"The approach of [Fujitsu] is to cooperate with the
police and any other third party exercising independent
investigative, prosecutorial, regulatory or judicial
powers.
135
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conversations with Simon Oldnall, he was very conscious
that he was preparing a very similar witness statement
for the Inquiry and wanted to do this first.
There is a draft version of that statement. Is that
something that can be shared with the Inquiry?
Absolutely.
Can we please turn to FUJ00243199. Is it your view that
that statement will get over the hurdle in respect of
the police's ability to rely on Horizon data?
Not entirely, no. I think it will demonstrate the
control environment which surrounds the Horizon data
within Post Office, which falls under Simon Oldnall's
remit. The best -- so that's sort of a broad statement
saying what that environment is. The reason we're
referring forces to Fujitsu is that that is the best
golden source of evidence for them on the
transaction-by-transaction basis because no transfer of
data has occurred. That is the golden copy. So, for
them -- so if we can describe what controls we have in
place, to ensure that we know if transactions are not
accurate, and if Fujitsu can provide
a transaction-by-transaction analysis then we deal with
those two demands that they have asked for -- or not, if
the evidence doesn't support it.
Let's look at some of the Fujitsu correspondence. We've
134
"However, we are concerned by the behaviour of the
Post Office Investigation Team on this matter. That
team maintains an approach of Post Office as ‘victim’
and requires [Fujitsu] to provide a witness statement as
to the reliability of Horizon data stating that without
such statement the case will not progress. For the
Investigations Team to act in this matter seems to
disregard the serious criticisms raised in multiple
judicial findings and indeed exhibits a lack of respect
to the ongoing Inquiry."
What's your view of what is said in this letter?
So it is not Post Office seeking to pursue a criminal
prosecution, it's the police. It's not Post Office. We
are not -- we were not looking to pursue any civil
outcome, or anything like that. In relation to their
concern over the use of the word "victim", if criminal
conduct causes harm to the Post Office, that would make
us, in common use of the word and in the use within law
enforcement, as status of victim or complainant. And
that's what, in this case, we could be.
I think we've seen later correspondence from Mr Read to
suggest that won't be used between correspondence
between you and Fujitsu?
Yes, I think it might have been Owen Woodley but, yes,
in summary, yes.
136
(34) Pages 133 - 136
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The Post Office Horizon IT Inquiry
Were you party to this correspondence; was it discussed
with you at the time?
No.
When was the first time you saw this correspondence?
I'm not sure.
Is it in your preparation for the Inquiry?
No, I did see it before the Inquiry.
We're now in October. This is during the summer,
June/July. Can you assist us approximately with when
you first saw this correspondence?
I think I probably saw the first letter after the
response went out.
But you weren't consulted as part of the response?
No.
Would you have been expected to have been consulted as
part of the response?
Yes, potentially.
I'm going to stick to the timeline so I'll come away
from that Fujitsu correspondence. We're still going in
date order. Can we please turn to POL00448345, and this
is June this year, 26 June, a paper -- a report for the
Senior Executive Group, written by you:
"SEG approval is sought regarding the proposed
change in process in governing the passing of
information to law enforcement to assist them in
137
In conjunction with a lawyer, yes.
Yes. If we scroll over the page, we can see the
discussion of the caveat that was to be applied. It
says:
"There are currently 22 police forces requesting or
awaiting Horizon-based evidence across 33 police
investigations. To provide this information [your team]
will need to draw on Horizon data and often provide
transaction analysis. The current approach is that the
Board will need to be approached in the majority of
these matters as and when the data is able to be shared.
"A draft policy is attached ..."
It says:
"In particular, the draft proposes a change in the
governance of passing material to law enforcement which
we believe is risk balanced."
Then it says:
"The below is extracted from the draft ..."
There is a section there that says:
"It is policy that:
"Any information originating from Horizon after
1 January 2022 may be passed as either intelligence or
evidence to [law enforcement agencies] only after [you
‘or your nominated deputy] and an inhouse criminal lawyer
both give approval. A record of [their] rationale and
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criminal investigations and any subsequent prosecutions
prior to this matter being discussed at Board in July
2024.
"Executive Summary
"The current Group Investigations Policy ... (‘the
CLEP’) and [the old policies] are considered too
unwieldy and unnecessarily complex ..."
This is addressing the change we saw at the
beginning of today to the new policy.
If we could scroll down, please. It says:
"The old policies have been consolidated into
a draft single Investigation and Cooperation with Law
Enforcement Policy. The [new policy], amongst other
investigative operational policy changes, proposes
a streamlining of the governance of providing law
enforcement with information: the Director of A&CI and
the inhouse criminal counsel would have to agree to
providing the information and, depending on the age of
the information, a caveat would also be provided."
This is the change that I think we discussed before
the break and we saw the Board's discussion.
Yes.
So this is where you wanted to streamline the process,
and effectively for it to be delegate down to yourself
to make the decision and --
138
decision must be recorded
"Where information is requested by [law enforcement
agencies] that is Horizon data originating from
pre-1 January 2022, the same process must be followed.
In addition", there is additional wording that should be
applied and we'll have a look at what that additional
wording is.
If we scroll down, it says:
“Best evidence originating from Horizon sits with
Fujitsu and so [law enforcement agencies] should be
encouraged to request this material direct from
Fujitsu.”
If we scroll down, it then has the accompanying
lines that would apply to the version of Horizon, HNG-A.
No, pre-2022.
Why do you to that line?
So from that date onwards there are factors that I think
give us more comfort in the absence of anyone raising
substantial concerns with Horizon, HNG-A, which is the
work that Simon Oldnall described in terms of external
bodies reviewing bugs, errors, removing them, and that
sort of thing. There's also the process that goes --
that the Retail Team goes through that I've described
earlier in terms of checking the reliability at that
branch for those transactions, at the relevant time.
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And then, also from that -- almost from that time,
my team was in place and we can bring that objectivity
but also that assurance to what happens in the Retail
Team. So based on those three control factors we think
that we should, absent something saying that the whole
system is unreliable, that we should be able to handle
that evidence without Board having to give us
permission.
The caveat that is attached to the earlier material
being provided would be as follows:
"From 31 December 2019, all post offices have worked
on a version of Horizon that the High Court case of
Bates & Others has been considered by the High Court to
be ‘relatively robust’. In 2020, Horizon was tested for
the known errors and bugs identified in the Horizon
Issues Judgment and found not to be prevalent. During
2021, a process was developed to work collegiately with
postmasters to understand the causes any shortfalls.
Any Horizon data that pre-dates January 2022 cannot be
shown to have benefited from all three of those checks
and balances."
Yes.
Are these caveats and these form of words to be included
in a letter, in a statement or something else?
I think we'd probably put it in an emai, in the first
144
HORice, I believe -- but anyway, data that was used in
the retail space, and we wanted to ensure that those
mining tools were not going to change data in the course
of their extraction.
So we worked with Simon Oldnall's team to test the
validity of those tools and where we came to, in
particular, was that the Retail Team used those as
identifiers of something to them to look at, tripwires,
in effect. But any conversation with postmasters or any
data that they rely upon in resolving an issue with
postmasters comes from an original source, not through
those tools.
Thank you. Could we please turn to the discussion of
this issue at the Group Executive. That's POL00448310.
It's a meeting of 26 June. Could we please turn to
page 7. It's about three-quarters of the way down
page 7:
"Disclosure to support police investigations.
"Sarah Gray/John Bartlett
Did you attend this meeting?
Yes.
"TABLED and NOTED was the paper on disclosure to support
police investigations/passing of material to law
enforcement.
"SEG DECLINED to APPROVE the submission of the paper
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instance, or a letter. In reality, we will not -- we
are unlikely to pass any material that pre-dates 2022 to
the police as evidence anyway.
Paragraph 7 says:
"There are significant differences between the
environment that existed at the time the old policies
were formed and the current and future environment. The
current approach to dispute resolution and the
underlying technology could be seen as supporting a more
[business as usual] approach to passing information to
law enforcement. However, the most significant
difference between 2019 when the old policies were first
drafted and now is that A&CI exists and brings
significant criminal investigation experience to bear,
but more importantly, also considerably more objective
rigour to assessing evidence. Project Panther within
A&Cl is solely focused on testing the reliability of
data that the Post Office investigators and law
enforcement will rely upon."
Can you briefly tell us what Project Panther is?
This is our catch-all project name for us testing the
rigour or reliability of evidence that we rely upon in
our investigations or would provide to law enforcement
and genesis of that was that we came to realise that
extraction tools were being used to data mine from
142
on disclosure support for police investigations to the
Board, noting further work and assurance was required in
relation to Horizon data assurance."
Can you assist us with that, please?
Yes, I think, succinctly, they were awaiting Simon
Oldnall's witness statement.
Is there a difference between you and the Executive as
to quite how reliable the Horizon data currently is?
No, I don't think so, and the reason I say that is, if
they genuinely thought that the material produced —-
that the Horizon data was flawed, to the extent that we
shouldn't share it with law enforcement, they should do
something about it.
Can we please turn to FUJ00243204.
We're continuing chronologically but we're now back
to the Fujitsu correspondence. We're looking at
correspondence of 8 July from Fujitsu. You'll have seen
this, we've read it a number of times, that the fourth
paragraph is effectively a criticism of the letter/the
email that you sent. It then says:
"As the Post Office is well aware, there have been
and there continue to be bugs, errors and defects in the
Horizon system. Further, [Fujitsu] currently has, and
previously had, access to branch transaction records.
Your letter ... also acknowledges the existence of other
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matters (beyond the Horizon system) which could have
‘operated to create innocent discrepancies in branch
accounts including 'miskeys, or omissions [et cetera]’.
"In addition to [Fujitsu], the Horizon system is
reliant on the delivery of services by Post Office and
third parties retained by Post Office.”
What's your view of what is said here?
The same: that sometimes there are bugs, errors and
defects in the system.
Yes. You're obtaining the statement from Mr Oldnall.
Looking at this, do you think that what you're asking of
Fujitsu is achievable?
Achievable in the sense that could they produce
a witness statement, yes, because what that witness
statement would need to cover is a little bit like ours
in terms of what the control environment is to protect
and assure that data but, specifically, what the police
need is, at that branch, at the relevant period, the
relevant transactions, was there anything that would
make that data unreliable? That's the witness statement
that the police need.
But the kinds of concerns that are being raised here,
continued bugs, errors and defects, access to branch
transaction records --
Yes.
145
expert witness, who can provide evidence on the
reliability of Horizon data?
That was City of London Police's intent, that they told
us.
You say "was": when was that communicated and how likely
is that to happen?
That is prior to these letters. I haven't spoken to
City of London since, so I don't know what their current
intent is.
Can we please turn to FUJ00243303.
This is a letter from Fujitsu to the City of London
Police on 23 August this year. This letter is in your
witness pack. Is it a letter that before this Inquiry
you were aware of at all?
I don't think I saw this until last night.
Yes. Is it something that has been discussed with you
by Fujitsu at all?
No, which isn't surprising because I think in this
letter they say, "Please don't share with any other
party",
Thank you. It's to the Investigator, Fraud Operations,
Economic Crime Directorate; is that an individual who
you've been dealing with?
I think I've spoken with her once.
If we scroll down, Fujitsu say as follows:
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access to external providers, won't all of those
issues also have to be raised in a witness statement?
Yes.
In light of that, is it likely, possible, that there
will be a successful conviction based on that, in your
view?
It would depend on what the reliability of the data is
on that particular matter because, obviously, if it
comes back as, oh, there was a bug error or defect or
power outage, or something like that, that affected the
reliability of the specific transactions that the police
are interested in, then no, that shouldn't go forward.
Who's going to be able to work that out; who is going to
do the investigation as to whether there was a bug,
error or defect that did, in fact, impact on
a particular branch at a particular day?
So the police are asking Fujitsu to provide that
information. On this particular case as well, I'm aware
that once City of London Police have or had received
this information, in to the transaction level basis but
also the control environment, they were discussing with
us having an NCA-approved expert witness then look at
the system, but they wanted to look at the transactional
data first and the same with Lancashire Police.
So is there a plan to have an external NCA witness,
146
"As I understand it, the investigation is using data
from the Horizon system. During our discussions, the
City of London Police asked whether [Fujitsu] could
provide a statement regarding the reliability of the
current version of Horizon. As I hope was made clear in
our discussions, a witness statement from [Fujitsu]
attesting to the reliability or robustness of the
Horizon system and of data from it would amount to
expert opinion evidence. [Fujitsu] is unable to provide
expert opinion evidence in any legal proceedings in
relation to the Horizon system and the reliability of
its operation as it is neither independent nor does it
have sufficient information to provide such an opinion
at this time. Such a request has to be considered in
the light of the Inquiry."
Scrolling down, there's a section there on the
existence of bugs, errors and defects and remote access
powers. Fujitsu say:
"As discussed, the Horizon system has had and
continues to have bugs, errors and defects, some of
which may not have been detected at this time."
So there's the possibility of unknown errors:
"Accordingly, careful investigation is required to
ascertain whether bugs, errors and defects bugs, errors
and defects could that have operated to cause the
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accountancy discrepancies or transactions under
investigation. Further, [Fujitsu] notes that evidence
in the Inquiry has identified number of additional Post
Office and third party systems and business processes
(beyond the [Fujitsu] software) which also could or did
introduce shortfalls in branch accounts."
That's similar to the letter that we just looked at,
isn't it?
Yes.
Over the page, please. It says:
“In general terms, remote access is the ability to
access the Horizon system from a location other than
a counter at the branch.”
It sets out there remote access powers:
"Remote access powers enabling [Fujitsu] to access
and amend data affecting branch accounts have existed
and continue to exist within the Horizon system. The
use of such powers would need to be examined to
ascertain if they could potentially have caused or
affected the accounting discrepancies or transactions
under investigation.
"b) Systems and processes to be investigated ...
"It should be noted that the delivery of the current
Horizon system is reliant on the provision of services
by Post Office as well as third parties ..."
149
anticipated", et cetera.
The letter does actually enclose, as an appendix,
a large amount of information -- and we'll scroll
through that shortly -- that is being provided to the
police in respect of their overall systems and
repositories, et cetera.
If we scroll down, please, to (f), the letter says:
“Production Order
"To the extent that the records described in this
letter and its appendices may assist the City of London
Police's investigations[, Fujitsu] respectfully suggests
that the City of London Police provides ... a production
order ... To ensure that the City of London Police
receives the data required within an achievable time
frame, [Fujitsu] would appreciate the opportunity to
review and comment upon [it]."
But they also say:
“In the meantime, in the interests of the
transparency and to assist the City of London Police's
understanding of the content of this letter and its
appendices, [Fujitsu] is prepared to provide the
documents footnoted in [that] letter ... on a voluntary
basis and unredacted form."
Perhaps we could just quickly scroll through the
appendix. That can be found at FUJ00243304. Thank you.
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Then it sets out there further complications in
respect of third parties:
"c) [Fujitsu's] provision of records for police
investigations
"Based on the evidence which has been seen and heard
in the Inquiry to date, [Fujitsu] considers that all of
the matters mentioned above would need to be carefully
investigated on a case-by-case basis with the assistance
of an independent IT expert, and possibly also forensic
accounting expert, to determine as best they can the
cause of branch account discrepancies or transactions
under investigation. [Fujitsu] considers that only
after such investigation has been undertaken could
a meaningful statement be made by an appropriate
independent IT expert regarding the reliability of the
Horizon system and the data it has produced at the
relevant branch in the relevant time frame.
"[Fujitsu] is of course prepared to cooperate with
the police and the criminal courts in the ways that it
can. We have discussed that Fujitsu retains various
Horizon system records which may facilitate your ongoing
investigations. I said that I would work with the team
within [Fujitsu] currently supporting the Horizon system
in order to produce a list of those records. This
exercise has proven more complex than I had
150
We can quickly scroll through: various potentially
relevant records generated by the Horizon System are
being identified for the police.
What is your view of this letter and its contents?
So the issue around expert witness was raised in one of
their previous letters that I had seen before. I don't
agree -- Post Office doesn't agree, that it's an expert
witness, they're actually a witness of fact because what
they are being asked to provide is evidence of
particular transactions at particular times, and that's
it, together with a description of their Control
Framework -- is what I understand that the police would
like.
So the legal advice we've been provided, which
I agree with, is that that is not an expert witness.
statement.
In terms of the material that they've pointed out,
great. That might assist City of London Police. Fully
understand why they would like a production order.
Again, don't have an issue with that.
As a former police officer, what would you have made of
this, in respect of an ordinary theft case? So let's
say a £100,000-discrepancy has been identified --
Mm-hm.
-- and you're presented with the keys to the warehouse,
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effectively, but no statement. What would you have made
of that?
The production order provides you the material, so you
can look through the material and then engage with the
witness, because that's what they are, and agree what
would go in a witness statement to produce the evidence
that the production order prompted. So that would be
the next stage.
Do you feel that the police will be sufficiently
resourced, sufficiently interested, to actually pursue
those kinds of what may be called just an ordinary
criminal case?
This particular case?
Any case that the Post Office considers sufficiently
serious to pass to the police?
So City of London Police consider themselves to be
a strategic police force, when it comes to fraud in
particular. They are also the lead force for fraud in
England and Wales and, when I spoke to who was their
Assistant Commissioner, he's now, I believe, the interim
Chief Constable -- Chief Commissioner, sorry -- he saw
the strategic nature of us being able to pass cases to
them. So although I think this is about
£300,000-something, actually, I think (1) that value is
significant but I think they would realise that this is
153
system, if we could just bring up on to screen our
expert report, EXPG0000007. We've seen there it's
page 19 of that report, by way of example, identifies
current issues experienced by postmasters. Are these
results something that was surprising to you or not?
I didn't really have a frame of reference to compare
them to, if I'm honest.
But if, for example, we say that 70 per cent have
experienced screen freezes; 68 per cent, loss of
connection; 57 per cent have experienced unexplained
discrepancies in the last 12 months; does that cause you
any concern at all?
Of the respondents?
Yes.
Not 70 per cent of postmasters? Okay.
Sorry, was that an answer or was that a question?
Sorry, that was -- probably should have kept that in my
head. I don't know because I don't have a frame of
reference.
What do you mean by that?
Well, because I don't know the frequency because this --
the visibility of these events would, if they are
reported to Post Office, be within the Retail Team and
I wouldn't see that.
But isn't that something you should be on top of if
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potentially a test case.
But going forward, in terms of relatively routine police
prosecutions of cases where they are discrepancies and
in the Post Office view, that has been dishonestly
obtained, do you think, realistically, looking at, for
example, the letter that points to various bugs, errors
and defects, it also points out that there are third
party suppliers to Horizon, it points out issues of
remote access. Do you think, realistically, that's
going to lead to successful prosecutions?
So I think one of the outcomes of the scandal is that,
for all cases, irrespective of whether they're Post
Office derived, linked or otherwise, I think law
enforcement are going to have to do those verification
exercises, assurance exercises, on digital data, because
I think the scandal has shown that the assumption made,
that systems could be relied, upon has changed.
I remember when I first joined the police, there was no
natural assumption that a computer system was
functioning and workable, and we had to do what were
called system statements. And I think an outcome of the
scandal is that that's where law enforcement will end up
going back to. So I don't think it will be particular
tous.
Looking at further issues relating to the Horizon
154
you're investigating?
So on a case-by-case basis they would be looked at.
I don't understand what "case-by-case basis" means. If
we scroll down --
Well, I can explain --
Well, let's just have a look at what it says here then
perhaps you can explain in that context. It says:
“Among those that have experienced an issue in the
last 12 months, about two in three ... say that they
have experienced these issues on a monthly basis."
So we have there 65 per cent experiencing issues on
a monthly basis. If we scroll down, it says:
"This equates to about three in five (59%) of
[subpostmasters] surveyed."
Should you, in your position, not have a view on the
everyday experience of postmasters, irrespective of the
specific case?
Yes.
Does that cause you any concern, in respect of matters
going forward in the prosecution of subpostmasters?
So I think that this underlines the requirement to take
each case that we take into my team, that we do
absolutely nail down that we're satisfied or not that --
whether or not the accuracy of the data is an issue that
should rule out or rule in that investigation.
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How are you going to determine the accuracy of the data?
So that's the process that we've previously described.
Will that involve close liaison with Fujitsu?
Well, yes, if we're reporting a case to law enforcement,
if they're willing to talk to us, or it will be close
liaison with the police to help them understand the
environment.
Could we please turn to FUJ00243299. I'm going to take
you back to a document from December 2023. These are
issues that were raised with the Post Office about the
extension of the Horizon system. If we scroll down, we
can see that Fujitsu raise a few issues. They say:
"There are various challenges to the feasibility of
the continued delivery of the Horizon system and
associated services."
Number 1, it says:
"Due to the age and consequent end of service life
status of the underpinning Horizon infrastructure there
is an increasing risk of failure of the infrastructure
that could result in adverse impact in the delivery of
services to the public.
"2. The technical complexity and risk associated
with (i) updating infrastructure at varying states of
obsolescence and compatibility, and (ii) delivering new
system requirements, including because of lessons
157
beyond 2030".
A number of years, you'll still have the Horizon system.
We have those concerns that are raised by Fujitsu
about the reliability of the current system.
(The witness nodded)
We have further concerns raised about the ageing system.
(The witness nodded)
We have the Inquiry's own survey of current
subpostmasters.
(The witness nodded)
Do you think it's realistic to expect any successful
prosecutions based on Horizon data during that period?
It would depend on the evidence related to each of those
cases, and --
But what is your view --
-- do remember that the -- I'm absolutely convinced that
No police force will take forward to a prosecutor a case
that solely relies on Horizon data, that there must be
corroborative evidence because no one, rightly, should
seek to rely entirely on Horizon.
I think your evidence earlier, in terms of the
statistics, though, was that none of those cases had yet
proceeded to a prosecution?
Correct.
Looking forward, do you think there will be imminently,
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learned and commitments to end users. These activities
are increasingly risky and technically challenging ..."
Over the page, please.
"In consequence, we strongly recommend that Post
Office should continue to prioritise its objective of
replacing Horizon and its associated services, as early
as it can. Fujitsu will continue to support and
facilitate orderly transition to an alternative solution
Have you given thought to the impact of the aging
system on the reliability of the data and in respect of
the evidence that you're going to have to give to the
criminal courts?
So we look at the individual branch, the individual
transactions, and we have to assure ourselves that
there's nothing there that suggests that that data can't
be relied upon. Whether it was a brand new computer
system or not, that same test needs to be applied.
Stepping back, though, and looking at all that
correspondence that we've just been looking at, you're
going to have Horizon for a number of years still to
come, possibly 2030, possibly onwards -- is your view
onwards, you look like --
I think our Chairman is committed to 2028 but maybe
2030 --I think my eyebrows when you said "perhaps
158
in the next year, the next two years --
I think if Lancashire, in particular -- because that's
the one I'm probably a bit closer to -- I think if they
can satisfy themselves that the transactions that relate
to their investigation are reliable, then I think that
stands a good chance of going forward back to the CPS.
and that they may make a decision to proceed.
Obviously, if the validation process that Lancashire
carry out does not confirm that that data can be relied
upon, then that's a different matter.
I'd like to move on to a different topic. I'll just
address one short topic before we take our mid-afternoon
break and that is the investigation into Mr Jacobs, the
Subpostmaster Non-Executive Director. I'll look at
number to different complaints about your team. Can we
start by looking at WITN11180101. It's page 5, please.
At the bottom of page 5, we have an email from
Mr Morley, the Senior Investigations Manager within your
team, to Mr Jacobs. He says:
"lam employed by [Post Office] as Senior
Investigations Manager ... and I have reason to conduct
an investigation into alleged discrepancies at post
offices within the Universal Office Equipment Group.
I would now like to arrange to interview you in
connection with the alleged discrepancies and to this
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end please can you provide your availability ..."
A reference there to an interview: Mr Jacobs is
a subpostmaster, the investigation is into the Universal
Office Equipment Group; is that or is that not
a proposal to interview a subpostmaster?
No, it's to interview a NED who happens to be
a postmaster.
Is that such an easy distinction to make?
Well, the purpose of that investigation revolves
centrally around Elliot's status as a NED, that's the
purpose of the investigation.
But the suggestion in that email is that it's
an investigation into alleged discrepancies at post
offices within his Post Office?
Yes, because the existence or not of any discrepancies
is central to the other elements, the principal
elements, of that investigation.
Was Mr Jacobs suspected of having committed a crime?
No.
Did you have any view as to whether, for example, the
build up of discrepancies was dishonest or not?
No.
Can we scroll up, please. Mr Jacobs says:
"As I explained to [Mr Foat] I would be happy to.
assist ... your enquiry.”
161
the postmaster.
How can you not answer whether they would interview them
‘or not when you are providing the assurance for that
very team?
So we -- I accept your point from earlier today that we
need to look at that.
This is your letter, it says:
"My name is John Bartlett. I am the Head of the
Central Investigation Unit ..."
You say:
“Andrew has been investigating shortfalls at post
office branches within the Universal Office Equipment
Group and has invited you to a voluntary investigative
meeting.”
What is a "voluntary investigative meeting"?
It's effectively an interview.
Again, are there issues within the department as to how
to describe an interview --
No, there's issues within Post Office as to how much
clarity we can use in our language; "victim" was another
‘one -- is another example of that, of fearfulness of
using clear language that people would understand
because it might attract an adverse comment.
The shortfall that is alleged, as I've said,
approximately £200,000 originally alleged.
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If we scroll up, we have Mr Morley. He says:
"The interview will be conducted by myself and
[Mr Bartlett] who is the Head of the Post Office
Investigation Branch. Please find attached a letter
from John explaining in some detail the format of the
interview and the areas you wish to cover.”
Can we please look at that letter. That's
WITN11180102. So is it your evidence that this
investigation would never now take place in respect of
an ordinary subpostmaster?
If they weren't a NED then it wouldn't be with us.
When you say “with us", do you mean --
Well, a shortfall discussion or shortfall remedy or
investigation, however you want to characterise it, they
take place all the time in the Retail Team. So that's
why I didn't want to say it would never happen.
I think we're again getting back to the discussion or
the interview point. If a subpostmaster, like the
evidence that is presented in this letter -- a £200,000
approximate shortfall, and the suggestion is that there
was a lack of, or stop in engagement with the relevant
team, would the Retail Team interview that person or not
interview that person?
I don't know. I think the PAST team, the Postmaster
Support Team would be the ones that would interact with
162
The allegation was that he had stopped engaging, and
you say below that:
"We would like to circumstances with you this
mounting shortfall, understand what you think caused
them, and identify any reasons for not continuing to
engage with the PAST team."
\s it really your view that there was no suspicion
of criminal activity at that stage?
None had been raised with us.
Let's say you had that discussion, you're having what's
described as an investigative meeting. Halfway through,
you form a view as to whether he is honest or dishonest;
what do you do?
Well, if we feel he's honest, we carry on. If we feel
that there is -- that we have formed a suspicion that
an offence may have happened, we would stop.
Have you done that in cases?
We haven't needed to.
Is there guidance about when to stop, how to stop —-
Yes.
-- what to say? Yes.
If we scroll down, when you say "yes", is that Post
Office guidance?
Should be in the manual.
Conflicts of interest. If we scroll down, there are
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other allegations about conflicts of interest and
directors declarations.
Mm-hm.
If we scroll down, under "Conduct of the meeting", we
have seen there that it's not an under-caution
interview, and then there's discussion about audio
recording and we'll come to discussion about that.
If we go over the page, please, and scroll to the
bottom, it says there:
"Any decisions made based on this report, or any
resulting non-investigative actions, falls outside the
remit of the Investigation Team."
Can you assist us with what is meant there?
Yes, that means our job as investigators to collect
information and evidence, and we pass it to decision
makers.
Thank you. Could we please turn back to that email
chain so that's WITN11180101, and if we could start at
the bottom of page 3.
We have seen in this correspondence a discussion
between Mr Jacobs and Mr Morley about the provision of
information.
Mm-hm.
He says:
To begin, can you supply the 44-page PDF statement
165
his view of events early, so we had a sample of the
140-something emails that had been sent to Elliot by the
PAST team.
What was being suggested here was that they were all
provided to Elliot and the simplest, best format and
rooting would have been from them.
If you are investigating somebody and have a body of
evidence and are making an allegation, would it not be
more straightforward for you to be the team that
provides that information?
I think technologically wise, it was more effective for
it to come from the PAST team.
If we scroll up, please, the discussion continues about
the provision of information.
Then, please, could we turn to WITN11180103, page 2.
This is where things reach by 20 March 2023. Mr Jacobs.
says:
“I await your proper and fully disclosures and will
then take the matter under advisement.
"In addition, you have provided a highlighted
section of Board minutes -- can you please specify the
accusation being made for the avoidance of doubt and the
evidence on which you are relying in this regard?"
If we scroll over, please. This is the response
that we've already been through, and you'll be familiar
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in Excel format, broken down by branch", because it was
quite difficult to understand.
Scrolling down:
"Please provide line detail, including the reason
for each TC or BD ... so that it can be properly
reviewed ...
“Additionally the attached file cannot be accessed
"Please also provide the [relevant] email address
If we scroll up, there is the response from
Mr Morley. He says:
"Can I respectfully suggest that you address the
rest of your requests below to the postmaster support
team as per their letters/emails sent to you at the time
of the occurrence by PAST in which they offered to work
with you to understand the discrepancy."
So he has provided the relevant email address but,
in terms of the remaining request, it seems he has
directed Mr Jacobs to the PAST team; do you think that
that is appropriate?
So I think the reason that happened is that this was
very -- we chose to engage with Elliot and ask his --
get him involved in the discussion or, sorry, the --
through an interview, engaged with Elliot to understand
166
with, but I'll just read it out. Mr Morley says:
"I do not intend to enter in pre-interview protected
correspondence regarding advance disclosure which I am
under no legal obligation to provide and is provided on
this occasion out of courtesy in order that you can have
a high level understanding of the topics we wish to
cover, which are set out in the letter from Mr Bartlett.
Further detail regarding [the Post Office's] concerns
will be provided during the interview."
Do you think that that is appropriate?
Absolutely not.
"I am seeking in advance of the interview your agreement
to the recording of the interview ..."
Then he suggests, in effect, that if he doesn't
agree to the recording of the interview it will be wise
to allow six hours for that interview; do you think that
is appropriate?
I think it's factual, that it would be -- we were
asking -- in order that people don't have to make highly
detailed written notes, it would be -- if he willing,
then we could have an audio recording made.
Would it really take six hours to interview or is that
more of a threat?
No, I don't think it was a threat.
Do you think, realistically, that interview would have
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taken six hours if it hadn't been recorded.
A. I think the interview, as it stood, was over three hours
anyway.
Q. So it would have doubled in length?
A. So it would have taken a lot more to make -- I think
that is perhaps overegging it slightly, a cautious
approximation.
Q. Whyis it your view that the first paragraph is not
correct or not --
A. That is not the tone that I want our team to use.
I have raised it with him and he knows that that's not
what we do.
2
He is your Senior Investigations Manager, he is one of
your more senior staff.
Yes.
We saw that earlier on. What was his response?
He accepted that.
Are you aware that, after the interview, the Post Office
auditors attended Mr Jacobs' premises?
I believe it was a week later, yes.
What's your view of that, the approach that was taken?
A. I think for the resolution of the shortfall issue, it --
p>po>
o>
a count of stock and cash needed to be done.
Q. Do you think that you gave in your letter sufficient
information to Mr Jacobs, as to whether he was in any
169
Where do you say responsibility lies, who with?
I would say the former Chairman and Nick Read.
That's Mr Staunton --
Yes.
pProPro
-- and Nick Read. Do you have any targets, completion
targets --
No.
-- in your team? Do you think it might be appropriate
to have some sort of target as to when people are
notified of the closure of investigation?
A. So! think it's reasonable to have a completion of
investigation target but, where the output of that
investigation goes, is out of our control, then that
would be a false target that we wouldn't be able to keep
to because we have no control over it.
MR BLAKE: Thank you.
Sir, that might be an appropriate moment to take our
mid-afternoon break.
SIR WYN WILLIAMS: Yes, certainly. But can I just ask one
or two process questions about the Horizon reliability
issue, which you've examined at significant and proper
length, if I may say so.
But I just want to understand one or two things
while they're fresh in my mind, all right, Mr Bartlett.
The first thing is this, this is me just dotting the
174
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way suspected of something criminal, or what kind of
an interview it was?
A. Yes.
Q. Can we turn, please, to WITN11180104. That
correspondence we were just looking at is in March 2023.
We now get to February 2024, so almost a year later,
where we have a letter from you to Mr Jacobs, saying,
"As you're aware, the Assurance & Complex Investigation
Team conducted a fact-finding investigation ... with
your assistance", and essentially, the matter was
closed.
Do you think that is a reasonable time in which to
give Mr Jacobs a final closure on his investigation?
A. No, I don't, but I can explain why I don't.
Please do.
2
A. So itisn't right it took that long but, if you look at
the date -- and I'm afraid I can't recall it -- that we
submitted the two investigation reports, the final
investigation report and, by the time Mel Park submitted
her report, they then sat with the Chairman and the CEO
for a very, very long time. We had no explanation
provided to us as to what they were doing with the
investigation reports, despite us chasing, and we
couldn't issue a closure letter until we knew what the
outcome was.
170
Is: I take it that the City of London Police
investigation which is the subject of correspondence
between Fujitsu and the Post Office is the City of
London case mentioned in your schedule?
A. Yes, sir.
SIR WYN WILLIAMS: So that case was referred to the police
in October 2022, according to your schedule, yes?
A. If that is on the schedule, sir, yes.
‘SIR WYN WILLIAMS: I think I've got it right, yes. The
Lancashire one was 14 September 2022, and I believe the
City of London Police came shortly after afterwards.
But, in any event, that case has been ongoing in the
sense of being alive now for approximately two years, if
I'm right in my reading of your schedule?
A. That appears to be the case, sir.
SIR WYN WILLIAMS: I It got to the point in 2024, earlier this
year, where, if not expressly, the indication was that
the City of London Police weren't going to take it any
further without a lot more information; is that a fair
summary?
A. Without a lot more information and evidence, yes, sir.
SIR WYN WILLIAMS: Sure. So you have resolved, ie Post
Office -- and I'm choosing my words reasonably
carefully, so I'll start again.
Is it correct that Post Office Limited has resolved
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to provide a witness statement to the City of London
Police about this case, or is it a case that events have
been put in hand for Mr Oldnall to make a statement but
a decision as to whether to submit it to the police has
yet to be made?
A. Soa draft witness statement from Mr Oldnall has been
produced, it needs to be finalised, which he wanted to
do after giving evidence here.
SIR WYN WILLIAMS: Yes.
A. And then SEG -- so the Strategic Executive Group -- and
no doubt Board would like to consider that witness
statement because of its significance.
‘SIR WYN WILLIAMS: = That's what I wanted to flush out.
I appreciate this is just a summary, where you say in
your appendix, that police have requested a statement
regarding robustness of Horizon, POL are producing
a statement, what you actually mean -- and I'm not
saying this in a critical sense -- is that certain
employees of the Post Office have put in hand the making
of a statement, but it is yet to be decided whether or
not that will be submitted to the police.
A. That's correct, sir.
SIR WYN WILLIAMS: Fine. Can you give me some kind of
timescale for that?
A. So Post Office is committed to provide, if authorised
173
A. Yes, sir.
SIR WYN WILLIAMS: Right. Thank you very much. So we'll
resume a bit later than you anticipated, Mr Blake, yes?
MR BLAKE: It makes it more of a round number sir, actually.
3.45, please.
SIR WYN WILLIAMS: Allright, fine.
(3.33 pm)
(A short break)
(3.45 pm)
MR BLAKE: Moving on to Project Pineapple and Saf Ismail.
Could we please bring up onto screen POL00448302. This
is the well-known Project Pineapple email on page 4 of
that document. If we could turn to page 4. If we
scroll down slightly, the note of the discussion with
Mr Ismail and Mr Jacobs, it says:
"Equally Saf and Elliot are FED UP WITH THE AMOUNT
OF POWER WIELDED, BY FOAT. He and other members to
senior team act as if PMs ARE GUILTY UNTIL PROVED
INNOCENT ... 'No one believes us’ is a constant refrain
from PMs. WHILST FOAT IS AT THE HELM NOTHING WILL
CHANGE. We must also part company with all those
investigators who behaved so terribly with PMs. What on
earth is happening if Steve Bradshaw is still with us
his performance at the Inquiry was a disgrace and
reflected terribly on Post Office. Foat uses his
175
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to, that witness statement to Lancashire Police by the
end of next month.
SIR WYN WILLIAMS: So Lancashire first and there is a time
commitment with them?
A. Yes.
SIR WYN WILLIAMS: Right. The last question and then we'll
have our break.
My impression from your evidence about seeking to
establish the reliability of Horizon in each particular
case is that, although Post Office can go so far in
providing evidence to establish reliability, it is also
necessary that additional evidence is given, either by
Fujitsu, and/or by an independent expert; is that your
understanding?
A. I'd say both are required, sir.
SIR WYN WILLIAMS: Both. So in order for there to be any
prosecution, in truth, because the five cases that we
have outstanding saying that you are going to produce
a statement, according to the schedule, in order to
bring an investigation to a sufficient point that it can
be submitted to the prosecuting authorities, ie the CPS,
if it's England and Wales, there would have to be
witness statements and supporting exhibits from Post
Office Limited, Fujitsu Services Limited, and then
an appraisal by an independent expert?
174
leadership of the Inquiry Team as an instrument of his
power -- it all has to stop. The PM ‘is not the enemy’,
‘Only PMs can solve this’ and tell us how to change."
Here is a reference to you:
"JB is an ex-policeman. His behaviour has been
unacceptable and he needs to move on to prove we have
changed.”
Were you aware of this at the time?
A. No.
When did you first become aware of this allegation?
A. It was raised to me by Ben Foat. Once he received
whatever he received, he mentioned that to me.
Q. What is your view of what is said there?
I don't know what they're alluding to.
Q. Can I just ask, in terms of Mr Foat, it has been
suggested by at least one witness that Mr Foat wasn't
responsible for your team; is that right or wrong,
because we saw the organogram and it looked as though
Mr Foat was, at that particular, time responsible?
A. So Sarah Gray reported into him and I reported into
Sarah Gray.
Q. So, insofar as it addresses his responsibility, that is
correct?
A. Absolutely.
Q. Thank you. We've spoken about the various policies and
176
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the changes in the group policy. Has that had input
from subpostmasters?
The combined one has had input from the Postmaster
Experience Director.
Has it had, for example, input from the NFSP or the
Voice of the Postmaster; have they been invited to make
any comment?
So we have talked to the NFSP, primarily around Speak Up
but, obviously, connected to Speak Up are investigations
from that and, in terms of how we conduct
investigations, the Speak Up manager meets with the NFSP
every week where they talk about investigations. I've
attended those meetings on occasion and we've talked
about our approach to investigations, and the feedback
we've received is that it's supportive of our approach,
to the extent -- sorry, to follow that up, to the extent
that we have had cases referred to us by the NFSP, for
us to deal with.
But in terms of the policy that is not yet finalised, is
there any plan for any more involvement of
subpostmasters, whether it be via the NFSP, via the
Non-Executive Directors or some other --
Yes, so the NFSP we would like to have look at it and
provide an input.
Could we please turn to POL00446706. This is feedback
177
So if there are colleagues that feel this way, I'd like
to understand why and see what we can do to change if we
need to.
Prior to being shown that by the Inquiry, had those
concerns been drawn to your attention at all?
No.
Project May, you've provided a separate witness
statement on. That's the project relating to the race
identity codes?
Yes.
That was first commissioned on 30 May 2023, the final
report was 8 February 2024. You've addressed it in your
statement, and the background. Am I right to summarise
that those codes are likely to have originated from
Royal Mail Group before the split?
Yes.
Has the Post Office established the actual origins of
how the racist terminology came to be used?
As in an individual?
How it first came to be formulated within the Royal Mail
Group?
Well, what we know is that someone within the
investigations section within Royal Mail Group created
that document but we don't know who.
An external company called ETICA has been involved.
179
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from an anonymous survey at the Post Office. It's not
an Inquiry-led survey; it's from the Post Office. I'm
going to just take you to two lines from it and ask your
view. The first is 1461. It says:
"Teams could work better with each other such as
A&Cl as they do not take on feedback and assume their
way of working is correct without having the knowledge
to back it up so come across as non-transparent and
belittling.”
Then 1494, it says:
"Overall there is great teamwork and cooperation
between departments, however the A&Cl team can at times
come across the aggressive, refuse to accept feedback,
and can work in isolation not understanding our ways of
working/policies."
Are those complaints that you recognise, not as per
the individual who made them, but simply are they
concerns that you are aware of?
No.
What is your view of them?
It's a bit worrying, if that's how -- was this from
a colleague survey --
Yes.
-- as opposed to a postmaster survey?
Yes, I believe so.
178
Very briefly, what is their involvement?
They're a non-government organisation that are -- they
support organisations like the International Criminal
Court and human rights activities in terms of ethical
investigation.
The report was produced on 1 March 2024. One of their
recommendations was annual training on unconscious
bias --
(The witness nodded)
-- and also regular training to remain up-to-date with
best practice.
Mm-hm.
Again, is this is an area of training that is not yet
finalised?
So we're hoping this will form part of the provision
from the College of Policing.
Thank you. So, again, as we discussed earlier today --
It's imminent.
Imminent. There was originally going to be Part 2 of
Project May. Very briefly, what was the plan for
Project 2 and what has happened to it?
So originally we hoped that an organisation like ETICA
would look at a large sample of historic investigations,
so those that are pertinent to this Inquiry, with a view
of using various scientific and academic methods to
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review a large number of cases to see if they could
determine whether there was any conscious or unconscious
bias in decision making, particularly around the raising
of cases, the decision to prosecute, or acceptance of
payment via the contract enforcement.
Why is that not taking place?
I don't know.
Who is responsible for deciding whether it takes place
or not?
Nick Read made the decision to change Phase 2.
What did he change it to?
So it's now -- it looks like it's going to be the
establishment of a focus or consultative group within
Post Office as to the use of language and approaches
that take into account difference from an EDI
perspective in relation to investigations.
So is it now forward looking, rather than backward
looking?
Absolutely.
At paragraph 20 of your statement, you've said that your
team has purposely removed fields which would capture
demographic data on --
Yes.
-- the case management system. Might that cause issues
with not actually being now able to monitor, for
181
2024. I'm only taking you to that because it provides
a helpful summary of where things were at by this stage
and it's page 2. The bottom of the second paragraph
sets out various categories of investigations. Current
roles is not part of your remit, is it?
No.
Right. In terms of Project Phoenix, it says:
"The third category included and expanded upon the
scope of Project Phoenix and would focus on addressing
any misconduct allegations arising against current
employees as a result of evidence given at the Inquiry
in later Phases, in addition to the evidence provided at
the Human Impact Hearings."
Are you aware of when Project Phoenix was first
established; was that related to the Human Impact
Hearings?
Directly.
Why is it that the Post Office, in your view hadn't
started looking into the historic conduct of its
employees before the Human Impact Hearings?
I don't know for sure but my impression, which I think
I maybe mentioned this morning, is that that sort of
understanding was expected to come out of the Inquiry
itself but I think it demonstrated a lack of curiosity
on behalf of the organisation to learn by itself.
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example, disproportionate impact or disproportionate
numbers of investigations into certain ethnic groups?
Potentially. But the more prominent issue is that it's
not felt that we are required to collate that data, but
I take your point. I think it's a trade-off between
people not being comfortable with their ethnicity being
recorded, but the value to an organisation in capturing
that data.
Are you aware, for example, that the Inquiry sought
subpostmaster demographic information in advance of its
survey but, in fact, the Post Office doesn't hold that
kind of data in respect of the subpostmaster population?
No, I wasn't aware.
There's been some evidence in previous phases, for
example, relating to the Helpdesk, where negative
assumptions were made about certain ethnic groups. How
does that failure to collect that kind of data impact on
your ability to monitor those kinds of things?
We have a very small caseload, so we will know who's
connected to that caseload. So we could recreate that
if needed. But within Post Office in relation to
Project May, there was a very strong upsurge of opinion
that the collation of ethnic data was an issue.
Moving on to Project Phoenix, could we please turn to
POL00448649. These are the Board minutes of 29 April
182
In terms of that investigation, Phoenix, that's carried
out by a team that's within your division?
Yes.
Was any thought given to whether an internal group of
investigators was appropriate to be, for example,
liaising directly with subpostmasters?
So they're not internal in the sense that they were
existing members of the team. They weren't. They were
recruited specifically to do this, and they only do
matters relating to the Inquiry. So they don't do
business as usual work.
What's your view on the proposal that individuals should
be suspended whilst they're being investigated in
respect of Project Phoenix?
I think the appropriate policies have to be applied.
What do you mean by that?
So there are policies -- ER-owned policies that have to
be applied in terms of misconduct issues and they've got
to be applied.
There's been a thematic report that has been produced in
respect of Project Phoenix. That can be found at
POL00458007. That was completed on 28 August of this
year. We'll skip through this relatively quickly
because everybody has it and it can be considered in due
course. Over the page, please, to page 2. There are
184
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a number of failings that were identified in this
thematic report; is that right?
Correct.
Can you broadly summarise the findings there?
So I think bullet point three identifies five key
themes: so quality and application of investigations --
of investigative activity is one; recordkeeping; the
recruitment and training of investigators; separation of
function, so that's between those conducting criminal
investigations and those that were conducting contract
advising or contract resolution issues; and then there's
themes around poor conduct of Post Office staff.
If we could turn to the conduct of Post Office staff,
and that's on page 3, please. A number of issues were
raised in terms of the investigation, in terms of
compliance with legal obligations, et cetera, but I'm
just going to focus on this particular section. It
says:
"A range of issues were raised in the Human Impact
evidence and was the main driver for the initiation of
Project Phoenix. Some allegations have been disproved
with factual evidence obtained by the Phoenix team but
there have also been matters relating to current [Post
Office] employees that have been referred for code of
conduct investigations by the Employee Relations team
185
is available and then make observations, findings and
recommendations.
So they do that, they produce what is called
a merits assessment -- which we have shared all of them
that we have completed through the panel so far with the
Inquiry -- they then go to the panel, and there could
be, and there have been, recommendations in there of the
nature that are described there. And that's when
employment policies would kick in, at that point.
"Review" sounds perhaps quicker and more achievable than
an investigation. Why has it taken so long?
The appalling state of Post Office's databases -- data
systems. Going back that far, it is -- well, if you've
read any of the merits assessments you'll see that the
team that complete them put in there that there was
an expectation that when they started they would
literally be handed a case file and related papers for
them to review. That has absolutely not been the case.
So there's 5.4 million documents that are
potentially in play, and the way I try and explain it --
because everyone asks why has it taken so long. The way
I explain it is: you should be able to go to a filing
cabinet, find a file, take it out, whether that's
electronic or physical.
The way I tried to describe it is: imagine room with
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that are currently ongoing.
“Matters of a potential criminal nature have also
been identified and with Panel approval and submission
through the [Post Office] Cooperation with Law
Enforcement Policy, have been passed to the Metropolitan
Police Service for their consideration.
“Although the prosecution aspect of the reviewed
cases was not covered by the terms of reference for
Project Phoenix there have been matters identified by
the review team that have met with panel approval for
referral to the Solicitors Regulation Authority and
MPS."
Are we to understand that Phoenix conducts its
investigation, waits for that investigation to conclude
and then, in cases, for example, that are employment
matters, then passes it on to the Employee Relations
Team to conduct another investigation?
So I think some clarity over language is useful.
Yes.
So the Project Phoenix team conducts reviews, not
investigations. Again, I think that might be something
we could talk about for some time, but the reason for
saying "review' is that they don't reinvestigate the
original allegations made against the postmasters or
their staff. What they do is review the material that
186
5.4 million documents in but they've just been thrown in
there, there is no index, no description, you have to
search through each of those documents to try to find
it.
‘Are we now to expect that matters have been passed in
certain cases to the Employee Relations Team or the
police who are then, as you've only carried out
a review, then going to have to investigate and, if so,
what do you expect the timelines to be?
So I don't know about the police investigation because
obviously that's out our control and we don't know what
other evidence they have, but we actively cooperate with
them, and pass -- and make referrals proactively to them
where we have concerns, and then they take it from
there. We're in the process of agreeing how we can pass
them the material that's been collected, so they don't
have to repeat that process.
And with the employment relations type HR type
investigations, at the moment we're trying to work out
with the police how those two functions interact and we
will be guided by the police -- Post Office will be
guided by the police.
Thank you. I'd just like to provide updates on two
other investigations. The first is Project Willow. Can
you assist us briefly with where things stand with that?
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(47) Pages 185 - 188
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A. So there are three Project Willows, which one --
Q. Can you assist us with all of them, as quickly as you
can.
A. Okay, so Project Willow was an investigation to test
whether someone who believed that they were a PIDA
qualifying whistleblower had received detriment. So
that's that investigation. That's closed.
Willow2 is an investigation in relation to NBIT, and
there are two particular themes in there. One is that
senior decision makers, so CEO and SEG, were provided
with selective information in order to make decisions.
That is currently open and is being investigated
externally -- by an external organisation, one of the
law firms and accountancy firms.
The second part of that is that -- I think you
mentioned it to Chris Brocklesby, which is that the
information security elements, some relating to the NBIT
build, were deliberately deactivated in order to --
Q. What is the status of that?
A. So that is also being dealt with by the same
investigation team externally.
Project Willow3 is a newer allegation, and that
relates to whether a potential supplier that could
assist with various elements of delivery of NBIT process
was properly briefed to the Board or whether that was
189
many questioners are there?
MR BLAKE: There are three. Mr Stein proposes to be first
and the longest but he will be ten minutes.
The other two questioners are no more than five
minutes each.
SIR WYN WILLIAMS: Right, well, I'm going to make it easy
for everyone by saying that it is now 4.10, and
I propose to sit no later than 4.40, all right? So I'll
allow a little latitude because I don't want to rush
people but I'm not going to sit beyond 4.40. So between
the three of you, you'll have to work it out, as they
say.
MR BLAKE: Thank you, sir.
Mr Stein?
Questioned by MR STEIN
MR STEIN: Thank you, sir, I have my watch by me which is,
you know, always a very reliable judge of my timings.
The questions I have for you, Mr Bartlett, come from
the direction of obviously a very large group of people
that have been badly affected by the scandal but the
group of people I represent also includes current
subpostmasters; do you understand?
A. (No audible answer)
Q. Now, you have been asked number of questions by Mr Blake
about NBIT and what is happening --
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skewed, and that is underway.
Nearing completion or just underway?
That investigation had to be paused because, for speed
purposes, we chose to use the same team to conduct the
investigation around Saf Ismail that recently surfaced
and that you are aware of. So that team has completed
that investigation and now they are back on Willow3.
Finally, Project Acer, can you give us an update as to
first of all, in very overview terms, what that is and
where it's up to?
Sure. So Project Acer is an allegation that came up
through the Speak Up service function that an individual
within Post Office had instructed their team to destroy
or otherwise remove material that might be of value to
the Inquiry. We told the Inquiry about it, you informed
the Met Police about it; it is now a Met Police
investigation.
Just for clarity's sake, it doesn't involve a witness in
Phase 7?
No.
MR BLAKE: Thank you.
Sir, those are all of my questions. There are some
questions from Core Participants. We have discussed
orders and timings.
SIR WYN WILLIAMS: Well, I mean, let's be realistic. How
190
Yes.
-- and you've provided some more recent information.
You address that in your statement. I don't need to go
to it because I'm just referring to the fact that you're
talking about NBIT. So, for your purposes, it's within
your statement, Mr Bartlett, it is page 15,
paragraph 25. What you're saying there is that on
28 June 2023, the GE agreed that A&Cl priorities for the
financial years 23/24, 24/25, would be, and then you
give an order of priority.
Then the fourth order of priority, therefore, at (d)
was preparing for transition of the network to New
Branch IT System, NBIT. Okay?
Then slightly further down you start to talk about
the fact that work on NBIT is delayed because,
essentially, the landscape is not sufficiently developed
to require this work.
(The witness nodded)
All right. So we understand and just hopefully you'll
agree with me that your work that was proposed for NBIT
was put on hold pending more development, more
information?
Correct.
Okay. Now, your statement, which contains those
references, is dated 22 August of this year. Yes?
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Yes.
o>
Okay. Now, since that time, we have heard from
Mr Railton, the new Chair of Post Office, who I think
towards the end of his evidence was talking about
whether NBIT is really a very good idea or not, and was
wondering whether, in fact, it was a poor idea. That
was information that presumably you are aware of and
heard?
A. No.
Q. Okay. Well, in the magazine Computer Weekly, which has
been an integral part of the background to the
development of this scandal, they are a news
organisation that were one of the principal
organisations that actually broke the scandal in the
press. Now, they've been setting out the fact that they
have hold of information, internal Post Office document,
from the new Acting CEO, Neil Brocklehurst, revealing
that:
"While the strategic review is ongoing and informed
by other discussions with the Board and stakeholders, we
have taken the opportunity to review our current
approach to our delivery of new technology to make sure
it will deliver what postmasters need in the most
effective way possible."
Then goes on to say this:
193
Right. Nobody has been identified?
Er--
As to the skewer?
There have been allegations made and the external
investigators are seeking to corroborate or otherwise
that.
Q. The person that is doing the skewing, is that
an important person within the organisation?
A. Potentially but the -- there are also a number of people
who have left the organisation that that might also
relate to.
rPOoOPrPSD
Q. Are you able to provide the name of the person that is
the suspect for the skewing?
A. That would depend on what the Chair is --
Q. What is the name of the person that's doing the skewing?
MR BLAKE: Mr Stein --
SIR WYN WILLIAMS: I don't think he need answer that.
MR STEIN: Right, okay. I'll change subjects because it
sounds like that's a developing situation, Mr Bartlett.
We also have a new statement from Mr Patterson.
Mr Patterson is the European Director of Fujitsu. Okay?
Mr Patterson has given evidence in the Inquiry and has
provided a statement, again, demonstrating things are
among on, that is dated 23 September 2024. He says this
in relation to police requests:
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"This means from next week we will start reassessing
and reprioritising the NBIT programme.”
Now, is that a document that you're aware of,
an internal Post Office document, from the Acting CEO,
Neil Brocklehurst, saying, essentially, the Post Office
is going to start reassessing and reprioritising?
I'm aware that they're reassessing and reprioritising.
So the question of NBIT and what is going to happen with
it does seem to be under fairly close examination within
the Post Office; that seems to be where we're at?
Yes.
It doesn't seem at all certain that it's likely to go
ahead. Again, that seems to be where we're at; do you
agree?
I have heard those things but I'm not closely associated
to it because it's a technology process.
You have had discussed with the Mr Blake towards the end
of the questions, he asked you Willows -- I think it's
Willow2 3, and 4, I wasn't certain --
No.
Willow2 and 3?
Willow2 and 3 relate to NBIT.
You were talking about information that has been skewed.
Can you help us, who is doing the skewing?
That's the purpose of the investigation.
194
"Fujitsu has informed the relevant police forces and
POL that, whilst Fujitsu is willing to cooperate with
the investigations through the provision of documentary
records, Fujitsu is not in a position to provide the
witness statements requested. Fujitsu is of the view
that such witness statements will amount to expert
opinion evidence, which Fujitsu cannot provide on the
basis that Fujitsu is not independent (amongst other
reasons). Fujitsu has made clear to POL that
discussions regarding these investigations are
confidential as between Fujitsu and relevant police
forces."
Then it goes on to say:
"It became apparent to Fujitsu, through the police
requests, that the views of POL and Fujitsu, with
respect to the use of Horizon data in enforcement action
against postmasters and branch staff, are fundamentally
different."
Okay?
Okay.
So if we trace through the questions that Mr Blake was
asking you earlier, from December 2023, Fujitsu was
describing the system as being obsolescent, old, patched
up, constant needing for repairs?
(The witness nodded)
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You've then seen other correspondence talking about the
fact of current BEDs that they know about and others
that they don't know about. Yes?
Yes.
You've then heard from me, reading part of
Mr Patterson's statement recently provided to this
Inquiry, saying that Fujitsu, frankly, are not prepared
to provide any statements to support the system. They
are just not doing it, Mr Bartlett.
Well, they have responded to a production order, or are
intending to, and that will be followed up with
a witness statement in order to produce that evidence.
I would also challenge their assertion that they are
an expert witness. In my opinion and legal advice that
we have received is they are not an expert witness.
I'm going to come to that. Now, the position between
Fujitsu and the Post Office does seem to be rather at
odds. We've had now this whole series of
correspondence, starting with December 2023, right the
way through to only a few days ago, essentially, saying
that Fujitsu and the Post Office have very serious
disagreement between their stance on these matters.
Yes.
That's at the very least --
I think that's fair.
197
Mm-hm.
You've also said in your evidence that "because the POL
Senior Executive and Directors Board haven't said it's
unreliable, we will assume it's reliable". So you're
working on the basis of two negative assumptions, aren't
you, Mr Bartlett?
And then the next step is that the police, to
an evidential standard, test those transactions in the
system.
Right. We've now got evidence, in relation to your
statement, of ongoing investigations. You describe one
as being some sort of test case that you're thinking
about, yes?
I'm not sure --
Lancashire or the City?
I think that's likely to be the first case.
Right, okay.
Now, we can see, at the back of your statements, a
schedule that relates to those investigations --
Mm-hm.
-- and, indeed, the individuals being investigated can
identify their own cases, can't they, because they've
got the numbers, the figures for each case?
Yeah.
Right. Have those investigation teams, for each one of
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Yes, that's at the very least what we've got. Okay?
So it does seem as though Fujitsu may have slightly
different advice in relation to the provision of
statements than you've got. Who has your advice been
given by?
I don't know. It was external counsel but I don't know
the name of --
Have you seen written advice?
I've seen a summary of that written advice.
Right. So the position in relation to Fujitsu appears
to be that they're not prepared to provide any expert
evidence at all, from their point of view, in relation
to the operation of the system. It also seems to be
they're saying the system is old, it's out of date, it
needs a lot of work, it needs a lot of support and there
are bugs in the system. It doesn't seem as though
they're particularly keen on saying, "There's no
problems in the system, we'll provide a statement to say
that it's okay". It doesn't seem that way, does it,
Mr Bartlett?
That's what they are not being asked for. They're being
asked around specific transactions --
Well, hang on, Mr Bartlett. You said in your evidence
that "because Fujitsu haven't said that it's unreliable,
we are therefore prepared to assume it is reliable"?
198
the police forces involved, been given all of the
correspondence that you've had questions asked by
Mr Blake about? Have they been given all that
correspondence?
So we've discussed with Lancashire some of that
correspondence since those letters have come in, and
we've made them aware of it, and they're still engaging
with Fujitsu, as I understand. As the next cases come
up, then we will talk to them about that too. We will
make everything available to them and we will share it
as they would like.
That's Lancashire. City?
I haven't spoken to City for some time.
Given that on 17 May 2024, Mr Patterson was expressing
very strong reservations about the use of data from
Fujitsu in relation to investigations --
Mm-hm.
-- why wasn't that immediately provided to the police
forces that were conducting these ongoing
investigations?
My -- the interpretation of the letters is that he
wasn't saying the data was unreliable: he was saying he
didn't want it to be used in a prosecution.
In fact it says, the 17 May letter, that they don't
believe it should be used at all in relation to
200
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prosecutions, civil actions or shortfalls generally. It
is a pretty strong letter, Mr Bartlett.
It is a strong letter.
You would have thought it should go to a police
investigation to look at these issues. Why didn't it go
to those police investigations immediately?
Because it wasn't saying that there was an issue with
the data; it's saying their intent, their preference,
their desire, their position, is that it's not used in
those circumstances.
So it was considered for disclosure --
Yes.
-- was it, Mr Bartlett? So you actually looked at it
and said, "Should this go to police forces that are
conducting investigations?", and your decision or
someone else's was, "No, it shouldn't"?
Well, we subsequently had legal advice, as well, which
says it shouldn't.
It doesn't seem that the Post Office has changed very
much, Mr Bartlett --
Well, that's --
-- if we analyse everything that you say.
Well, that's a little bit unfair, actually, because
we've discussed those issues with those law enforcement
teams as they've cropped up. We're not concealing
201
There is a current investigation. There is no previous
investigation.
Right. Did you see their evidence to the Inquiry?
Some of it.
Okay. So I'm just going to ask you something about
that. Saf Ismail says in his witness statement -- I'm
not calling these up but, just for the record,
WITN11170100 -- at paragraph 221:
"Often postmasters will be suspended prior to
interview without understanding the reasons for that
suspension. Postmasters are still not shown evidence
relating to investigation into their branches prior to
investigation interviews being conducted by Post Office
Investigators."
You've been taken to Mr Jacobs' concerns -- Mr Blake
took you to a series of documents this afternoon --
about the lack of information provided to him when he
was notified of an investigation and invited to
an interview. At paragraph 24 of his witness statement,
WITN11180100, he talks about his experience:
"I considered the interview to be an interrogation
and adversarial. It was not a collaborative discussion.
The interview was similar in style to a formal police
interview, as the questions put to me were interrogatory
and the documents were put to me as exhibits."
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anything at all.
Q. Mr Bartlett, overall, what we seem to have from your
evidence is we seem to have a situation whereby you and
your team are prepared to back the Horizon system with
no evidence whatsoever that the thing should actually be
presented before any court in relation to any shortfall.
That's basically the situation, Mr Bartlett, isn't it?
A. No.
MR STEIN: Thank you.
MR BLAKE: Sir, we have Ms Watt and Ms Allan.
SIR WYN WILLIAMS: Yes.
Questioned by MS WATT
MS WATT: Good afternoon, Mr Bartlett. I ask questions on
behalf of the NFSP.
A. Hello.
Q. You've been answering questions about the development of
the post-Horizon scandal conduct of investigations
throughout today and also what seems to be the vexed
issue of when is it an interview, a meeting or
a discussion.
I just want to take a look at some of those issues
regarding the cases of Elliot Jacobs and the other
Postmaster Non-Executive Director who underwent
an investigation, Saf Ismail. You just mentioned that
one, I think.
202
Okay, so that's my summary. Just a couple of
questions now.
At paragraph 69(b)(ii) of your second witness
statement, you talk about the policy -- Mr Blake took
you to it this morning, I'm not sure how to pronounce
it, I'l say GICLEP.
A. The new Combined --
Q. The new Combined policy, yes, and that's POL00448353.
You described the commitment to ethically executed,
evidence-led, transparent investigations. Given the
evidence of Mr Ismail and Mr Jacobs, in what way would
you say the Post Office investigations met those
standards?
A. So we've never dealt with Mr Ismail in that --
Can you refer just to Mr Jacobs?
A. So Mr Jacobs. Well, I'm very pleased that the interview
with Elliot Jacobs was recorded because it can go on
record to show what the nature of that interview was.
2
It absolutely was not an interrogation. It was an early
engagement with him to understand his position and for
him to give explanations, and for us to be open-minded
as to what that may be. There was a subsequent -- off
the back of Project Pineapple, which people have heard
about, the ER team conducted a review of the conduct of
that, of Elliot Jacobs' investigation, and they found
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that his complaints were completely unfounded.
I've just got one final question after this one. Would
you agree that how postmasters, whether NEDs or not,
feel about the way they're dealt with is important?
Absolutely.
Would you not agree that the conduct of, for instance,
that investigation, certainly the reporting of it, would
simply reinforce to today's postmasters that not a great
deal has actually changed. Some of the wording in your
new Combined Policy has changed, some of the deck chairs
have been rearranged, but what's said about their recent
experience, if that's anything to go by, there's still
a long way to go to win back the trust of postmasters in
the conduct of investigations?
There is a long way to go but what I would say is, if
postmasters were to listen to the interview that we had
with Elliot, I'm absolutely confident that they would
think that things are different compared to how they
were done before, and also, it might be helpful to add
a couple of matters that were referred to us by the NFSP
were dealt with very sensitively and we received
feedback from the NFSP to that effect. So I think it is
different from the past.
Because the NFSP liaise with you on the way in which you
are in fact conducting matters; is that not correct?
205
conduct a full criminal investigation following a report
from the Post Office of suspected criminality.
Prior to May this year and during your tenure at the
Post Office, I assume that you're aware that the Post
Office was a Specialist Reporting Agency in Scotland,
meaning it was entitled to carry out its own full
criminal investigation into suspected criminal conduct
and to report the findings of that directly to the
Public Prosecutor in Scotland without the requirement to
have this first reported to the police?
Yes.
I assume that you're also aware that, in May of this
year, the Lord Advocate, Scotland's most senior law
officer, confirmed that the Post Office was no longer
fit to continue in its own as a Specialist Reporting
Agency in Scotland, due to its failure to comply with
its duties of disclosure and candour?
Yes, we were consulted around that and I contributed to
a response back saying that we did not want to have that
status any more.
If you can elaborate, what were the reasons that you
provided for not wanting to have that status?
Because we're not a prosecuting agency. Therefore, we
shouldn't have that right or ability to have that
status.
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Yes, and in those particular cases, they brought them to
us, and we discussed with them our approach and what the
‘outcome was, and they were happy with how that was
conducted.
But we're not talking about Mr Jacobs' case when you're
talking about that?
Yes, certainly not Mr Jacobs. It's two other matters.
MS WATT: Yes, thank you.
‘SIR WYN WILLIAMS: Sorry, just so I'm clear, Mr Bartlett,
A.
are you saying that following the interview with
Mr Jacobs, he made a complaint which was investigated
and found to be unjustified?
Yes, sir.
SIR WYN WILLIAMS: Right, fine. Next, please.
Questioned by MS ALLAN
MS ALLAN: Good afternoon, Mr Bartlett.
A
My name is Christie Allan, and I represent Core
Participant Susan Sinclair, who is a wrongfully
convicted subpostmaster and the first to successfully
appeal her conviction in Scotland.
In your second paragraph at paragraph 69, which
I don't propose to turn up, you describe the activity of
the A&CI staff as a POL criminal investigation, but
caveat this with the fact that it's not an end-to-end
investigation, and it is for law enforcement agencies to
206
You mentioned earlier that there seemed to be
an apparent reluctance by authorities in Scotland to
adopt evidence collected by non-law enforcement
agencies. Do you think that this, the stripping of Post
Office's role as a Specialist Reporting Agency, has had
a bearing on that?
I'm sure it has but it's not limited to the Post Office.
So, in my previous role at a financial regulator, the
Procurator Fiscal insisted that Police Scotland recreate
an investigation that had already been completed by the
Regulator, because they wanted Police Scotland to do it.
Okay, thank you. Has any official review work been
undertaken by your team or within wider Post Office, as
a result of the decision by the Lord Advocate?
No, we supported it being removed.
MS ALLAN: Okay, thank you. I think that ends my questions
there. Thank you.
THE WITNESS: Thank you.
‘SIR WYN WILLIAMS: = Thank you very much.
So is that it, Mr Blake?
MR BLAKE: That's it, sir, yes.
‘SIR WYN WILLIAMS: Right. Very good. Well, I think
everybody knows that tomorrow we are starting at
9.00 am. In part, at least, that is on my convenience,
because I have a personal appointment, which I have to
208
(52) Pages 205 - 208
The Post Office Horizon IT Inquiry
keep, which means that we won't be able to sit beyond
1.00, all right? So I want everybody to know that the
sitting hours tomorrow are conditioned by that.
Itis also the case that Mr Foat will be giving
evidence remotely. I acceded to a request to that
effect on the grounds of his health and so I am giving
everyone warning that his evidence, save in the most
exceptional circumstances, has to end tomorrow, so that
means by around 1.00, so that Mr Blake, and anyone who
wishes to ask him questions, should tailor their
questioning with all that in mind. All right?
With those remarks, I will bid you good evening and
see you in the morning.
MR BLAKE: Thank you very much, sir.
(4.31 pm)
(The hearing adjourned until 9.00 am the following day)
209
17 October 2024
INDEX
JOHN JAMES BARTLETT (affirmed) ....
Questioned by MR BLAKE ....
Questioned by MR STEIN ..... 191
Questioned by MS WATT .. 202
Questioned by MS ALLAN .... 206
210
(53) Pages 209 - 210
MR BLAKE: [31] 1/3
1/5 1/10 3/19 3/22 4/3
4/11 22/6 58/11 58/15
58/17 58/21 62/16
68/23 108/13 108/19
4114/11 114/15 111/17
111/21 111/23 171/16
175/4 175/10 190/21
191/2 191/13 195/16
202/10 208/21 209/14
MR STEIN: [3]
191/16 195/18 202/9
MS ALLAN: [2]
206/16 208/16
MS WATT: [2]
202/13 206/8
SIR WYN WILLIAMS:
[50] 1/4 1/7 3/17
3/21 3/24 4/6 4/9
21/14 21/16 22/5
58/14 58/16 59/22
60/15 60/25 61/6
61/14 62/2 62/10
62/14 68/8 68/14
68/22 108/12 108/14
108/18 111/14 111/16
111/22 171/19 172/6
172/9 172/16 172/22
173/9 173/13 173/23
174/3 174/6 174/16
175/2 175/6 190/25
191/6 195/17 202/11
206/9 206/14 208/19
208/22
THE WITNESS: [1]
208/18
‘creamed [1] 125/10
"Horizon [1] 129/24
‘is [1] 176/2
‘lessons [1] 26/8
"miskeys [1] 145/3
"No [1] 175/19
‘Only [1] 176/3
"relatively [1] 141/14
‘The [2] 110/20 138/5
‘victim’ [1] 136/3
/
[Data [1] 115/2
1
1 January [1] 139/22
4 March 2024 [1]
180/6
4.00 [2] 209/2 209/9
4.4 [1] 44/12
4.2 [1] 77/22
1.3 [1] 109/11
4.4 [1] 110/17
40 [1] 25/10
10 January [1] 112/4
10.00 [1] 1/2
100,000 [8] 97/20
97/22 98/9 98/14
98/16 98/22 99/8 99/9
100,000-discrepancy
[1] 152/23
105 [3] 68/11 123/22
132/19
11 [2] 9/12 17/4
11.23 [1] 58/18
11.39 [1] 58/20
11.40 [1] 58/15
115 [1] 95/21
417 [4] 105/24
118 [4] 123/23
125/16 132/21 132/22)
12 [2] 10/21 57/9
12 months [2]
155/11 156/9
12.57 [1] 111/18
121 [1] 133/4
125 [2] 2/14 133/10
126 [1] 133/13
127 [1] 133/15
13 [1] 12/8
13 August [1] 24/8
130 [1] 2/13
132 [1] 2/8
133 [1] 2/8
14 [3] 37/7 56/12
56/13
14 September [2]
123/24 172/10
140-something [1]
167/2
1461 [1] 178/4
1494 [1] 178/10
15 [1] 192/6
16 [2] 46/12 55/10
17 [2] 23/17 24/2
17 May [3] 135/3
200/14 200/24
17 October 2024 [1]
1
17 years [2] 7/4
772
18 [1] 23/13
19 [2] 1/21 155/3
19 April [1] 118/24
19 September [1]
44/11
1978 [4] 11/12
1979 [1] 11/8
1983 [1] 11/4
1987 [1] 11/5
2
2.00 [2] 111/15
111/20
2.2 [1] 34/7
2.5 million [2] 85/3
85/9
20 [2] 69/2 181/20
20 April [1] 77/23
20 March [1] 167/16
200,000 [2] 162/19
163/25
2000 [1] 128/13
2004 [1] 2/6
2005 [1] 2/5
2012 [1] 14/1
2013 [3] 66/2 66/12
68/1
2015 [5] 2/12 2/12
14/1 66/5 109/8
2017 [2] 129/6 129/7
2018 [1] 128/13
2019 [11] 2/8 2/9 2/9
2/14 2/14 9/14 32/11
129/5 129/7 141/11
142/12
2020 [2] 65/23
141/14
2021 [6] 10/14 24/8
25/3 33/16 69/9
141/17
2022 [20] 5/17 48/24
69/2 69/17 74/17
74/20 74/21 75/16
77/23 84/11 92/12
92/12 123/24 139/22
140/4 140/15 141/19
142/2 172/7 172/10
2023 [24] 5/22 44/6
44/11 56/7 75/17
92/25 92/25 100/9
105/22 105/23 106/2
108/13 108/14 109/8
112/4 112/23 114/9
157/9 167/16 170/5
179/11 192/8 196/22
197/19
2024 [13] 1/1 1/18
108/16 115/10 117/22
138/3 170/6 172/16
179/12 180/6 183/1
195/24 200/14
2028 [1] 158/24
2030 [3] 158/22
158/25 159/1
21 February [2] 5/17
69/17
22 [1] 139/5
22 August [2] 2/23
192/25
22 September [1]
65/23
221 [1] 203/8
23 August [1] 147/12
23 September [1]
195/24
23/24 [1] 192/9
24 [2] 192/9 203/19
24 January [1]
114/17
24/25 [1] 192/9
25 [8] 66/19 67/18
67/23 68/1 68/6 68/9
192/7 192/9
25 April [2] 1/18
126/1
26 July [3] 2/8 2/9
2/14
26 June [2] 137/21
143/15
27 September [1]
92/12
28 August [1] 184/22
28 June [3] 92/25
100/9 192/8
29 April [1] 182/25
29 July [2] 2/9 2/14
3
3 August [1] 84/11
3 years [1] 85/19
3.3 million [1] 124/14
3.33 [1] 175/7
3.4 [4] 78/20
3.45 [2] 175/5 175/9
3.6 million [1] 85/15
30 June [1] 25/3
30 May [1] 179/11
300,000-something
[1] 153/24
301 [1] 66/13
34 [1] 19/13
31 December [1]
141/11
31 October [2] 106/2
108/13
328 [1] 66/11
33 [1] 139/6
360 [1] 103/21
360,000 [1] 103/14
398,000 [2] 125/5
125/14
4
4.10 [4] 1941/7
4.31 pm [1] 209/15
4.40 [2] 191/8 191/10
4.7 [4] 82/19
400,000 [2] 124/22
125/7
44-page [1] 165/25
48 [1] 33/10
49 [1] 33/10
5 October [2] 2/5 2/6
5.4 million [2] 187/19
188/1
50 years [1] 61/16
50,000 [2] 99/16
99/17
500,000 [1] 125/4
57 [2] 3/11 3/19
57 per cent [1]
155/10
59 [1] 156/13
6
6 July [1] 74/17
62 [1] 2/4
65 per cent [1]
156/11
67 [1] 2/8
68 per cent [1] 155/9
69 [2] 204/3 206/21
70 per cent [2] 155/8
155/15
71 [4] 57/3
76 [1] 3/12
77 [A] 2/11
8
8 February [1]
179/12
8 July [3] 66/2 66/12
144/17
88 [1] 2/4
89 [4] 66/8
9
9 September [1] 4/19)
9.00 am [2] 208/24
209/16
92 [4] 2/11
99 [4] 3/3
A
abilities [2] 90/9
90/12
ability [5] 81/18
134/9 149/11 182/18
207/24
able [24] 30/22 46/25
67/13 67/24 92/7 94/4I
96/13 96/25 97/5
115/11 117/9 117/18
120/14 123/7 131/22
139/11 141/6 146/13
153/22 171/14 181/25I
187/22 195/12 209/1
about [105] 7/25 9/3
9/6 9/10 12/9 18/7
19/10 26/21 27/5
27/19 30/1 30/20 31/3I
31/11 35/14 35/15,
38/10 39/11 39/12
40/25 42/14 43/17
50/19 50/20 51/1 51/3I
55/8 56/4 60/9 61/18
61/19 61/20 62/4 62/9I
62/12 73/12 83/21
85/15 87/5 87/8 90/10
90/11 90/15 97/7
103/7 104/15 104/23
106/5 107/13 107/21
108/5 112/25 113/18
114/8 114/11 123/5
123/8 143/16 144/13
(64) MR BLAKE: - about
A
about... [46] 153/23
156/9 156/13 157/10
159/4 159/6 160/15
164/19 165/1 165/6
165/7 165/21 167/13
171/20 173/2 174/8
176/25 177/12 177/14
182/16 186/22 188/10}
190/15 190/16 191/25)
192/5 192/14 193/4
194/23 197/1 197/2
197/3 199/13 200/3
200/9 200/15 202/16
203/5 203/17 203/20
204/4 204/24 205/4
205/11 206/5 206/6
above [5] 27/5 82/11
117/5 131/14 150/7
absence [2] 89/21
140/18
absent [1] 141/5
absolute [1] 64/23
absolutely [21] 2/3
2/7 3/10 27/7 28/17
57/13 62/11 63/11
65/7 74/11 85/9 134/6
156/23 159/16 168/11
176/24 181/19 187/18)
204/19 205/5 205/17
AC [2] 112/9 113/4
AC's [1] 89/21
academic [1] 180/25
ACAS [2] 50/2 50/6
acceded [1] 209/5
accept [2] 163/5
178/13
acceptance [1] 181/4
accepted [2] 77/1
169/17
accepts [1] 131/11
access [11] 96/20
144/24 145/23 146/1
148/17 149/11 149/12)
149/14 149/15 149/15
154/9
accessed [1] 166/7
accompanying [1]
140/13
accordance [1]
79/13
according [2] 172/7
174/19
Accordingly [1]
148/23
account [6] 53/13
53/22 117/6 130/3
150/11 181/15
accountability [4]
26/25 43/18 49/11
51/22
accountable [6] 17/3
23/3 49/13 51/7
112/13 113/9
accountancy [4]
19/25 105/7 149/1
189/14
accounting [5] 66/1
66/12 135/14 149/20
150/10
accounts [6] 122/8
128/10 130/9 145/3
149/6 149/16
accredited [1] 30/6
accuracy [2] 156/24
157/1
accurate [8] 71/18
116/6 118/11 130/12
131/15 131/20 132/15)
134/21
accusation [1]
167/22
Acer [2] 190/8
190/11
achievable [4]
145/12 145/13 151/14)
187/10
achieve [3] 41/2 91/7
102/11
achieved [1] 7/5
acknowledges [2]
129/11 144/25
across [14] 24/17
25/16 26/3 26/7 26/10
26/15 26/17 70/5
75/13 78/9 92/4 139/6
178/8 178/13
act [10] 71/25 76/11
86/19 86/23 87/5
87/13 88/1 135/11
136/7 175/18
acted [1] 116/9
acting [6] 47/16
47/18 76/15 78/8
193/17 194/4
action [9] 83/15
103/2 103/6 115/19
126/2 127/12 127/13
135/8 196/16
actions [7] 20/19
55/8 116/14 135/9
135/12 165/11 201/41
active [3] 92/9 97/20
98/13
actively [1] 188/12
a ities [2] 158/1
18!
activity [10] 16/2
18/5 18/18 55/23
115/20 117/16 118/4
164/8 185/7 206/22
actual [5] 31/24
50/14 108/15 130/2
179/17
actually [28] 4/3 14/9
46/12 54/12 58/1 61/8
67/10 67/11 67/20
68/14 78/2 87/18
100/18 104/17 104/23
111/7 151/2 152/8
153/10 153/24 173/17]
175/4 181/25 193/14
201/13 201/23 202/5
205/9
adapted [1] 45/5
adapts [1] 45/5
add [2] 12/23 205/19
addition [5] 94/5
140/5 145/4 167/20
183/12
additional [18] 27/19
55/25 88/16 93/10
94/18 101/3 101/5
102/4 103/2 103/13
103/18 104/3 104/7
119/10 140/5 140/6
149/3 174/12
Additionally [1]
166/7
address [11] 27/2
54/2 102/18 127/10
128/5 129/21 160/12
166/9 166/13 166/18
192/3
addressed [15]
16/18 26/20 27/18
33/8 37/16 38/1 38/2
39/23 40/13 40/19
41/8 54/1 57/4 116/11
179/12
addresses [6] 4/22
37/4 62/19 63/25 66/4
176/22
addressing [8] 14/8
33/12 38/4 58/23
133/10 133/23 138/8
183/9
adhere [1] 24/20
adjourned [1] 209/16
Adjournment [1]
111/19
admissible [2] 81/6
83/2
adopt [7] 28/15 41/17I
49/20 80/5 81/3 81/21
208/3
adopted [3] 35/12
69/25 84/8
advance [3] 168/3
168/12 182/10
advantage [1] 85/22
adversarial [2] 88/12
203/22
adverse [2] 157/20
163/23
advice [10] 14/11
31/5 126/4 152/14
197/14 198/3 198/4
198/8 198/9 201/17
advise [1] 120/23
advised [10] 20/12
88/23 90/1 91/5
101/22 103/4 103/6
124/21 124/22 124/24}
advisement [1]
167/19
advising [1] 185/11
Advocate [2] 207/13
208/14
affect [1] 84/6
affected [4] 49/1
146/10 149/20 191/20}
affecting [2] 128/8
149/16
affects [1] 56/1
affirmed [2] 1/8
210/2
afoot [1] 85/9
afraid [4] 13/18 32/20)
58/2 170/17
after [14] 28/18 28/22!
66/2 66/2 88/19
119/11 137/11 139/21
139/23 150/13 169/18
172/11 173/8 205/2
afternoon [7] 111/21
111/22 160/12 171/18}
202/13 203/16 206/16
afterwards [1]
172/11
again [25] 3/18 11/7
25/24 38/1 63/20 68/8
76/14 77/21 84/4
86/25 98/4 129/4
133/5 133/11 133/14
133/15 152/20 162/17,
163/17 172/24 180/13}
180/17 186/21 194/13
195/23
against [10] 6/16
49/1 99/7 109/17
135/8 135/11 135/13
183/10 186/24 196/17,
age [2] 138/18
157/17
ageing [1] 159/6
agencies [8] 15/6
33/12 121/3 139/23
140/3 140/10 206/25
208/4
agency [7] 7/20 16/6
55/5 207/5 207/16
207/23 208/5
aggressive [1]
178/13
aging [1] 158/10
ago [5] 7/4 9/3 13/18
77/12 197/20
agree [17] 29/12 61/5
65/1 87/3 93/6 121/13)
129/1 138/17 152/7
152/7 152/15 153/5
168/15 192/20 194/14}
205/3 205/6
agreed [11] 20/11
32/3 73/10 77/23
83/12 86/17 108/5
120/19 128/18 128/22)
192/8
agreeing [1] 188/15
agreement [1]
168/12
agrees [1] 115/21
Ah [3] 4/5 47/22
91/13
ahead [2] 101/5
194/13
aid [1] 40/15
aim [1] 70/10
AL [4] 114/13
alarms [1] 13/5
Alison [1] 11/2
alive [1] 172/13
all [83] 10/15 10/15
12/13 12/18 14/20
15/10 17/2 19/5 21/4
24/23 26/4 26/20
27/21 28/2 30/16 32/4I
40/9 43/15 46/6 46/15
48/14 53/17 56/17
57/18 61/16 61/19
65/9 69/24 70/9 71/24I
74/18 75/4 75/24
76/10 80/16 80/18
82/10 83/25 91/25
95/12 95/14 97/9
97/17 98/18 99/6
105/1 111/14 113/16
116/20 118/12 129/10)
141/11 141/20 142/21
146/1 147/14 147/17
150/6 154/12 155/12
158/19 162/15 167/4
171/24 175/6 175/21
176/2 179/5 187/4
189/2 190/9 190/22
191/8 192/19 194/12
198/12 200/1 200/3
200/25 202/1 209/2
209/11 209/11
all-branch [2] 95/12
97/9
Allan [4] 202/10
206/15 206/17 210/10)
allegation [5] 164/1
167/8 176/10 189/22
190/11
allegations [7] 6/16
88/20 165/1 183/10
185/21 186/24 195/4
alleged [7] 66/11
135/14 160/22 160/25)
161/13 163/24 163/25)
Allison [1] 11/2
allocated [1] 80/21
allocation [1] 79/24
allow [4] 106/9 107/3
168/16 191/9
allows [1] 94/4
(65) about... - allows
A
alluding [1] 176/14
almost [5] 81/5 81/10
95/10 141/1 170/6
along [2] 40/3 55/9
alongside [1] 92/16
already [9] 16/18
23/24 32/6 50/16
53/22 132/21 135/1
167/25 208/10
also [62] 4/17 6/22
7/9 7/15 8/10 8/10
13/5 15/18 17/17 23/6)
24/5 46/18 50/6 64/22
69/14 75/25 81/2
82/17 83/12 86/21
88/22 90/10 94/1 94/3,
101/4 112/15 118/16
124/8 125/19 133/2
133/8 138/19 140/22
141/1 141/3 142/15
144/25 146/2 146/21
149/5 150/9 151/17
153/18 154/7 166/9
174/11 175/21 180/10)
185/23 186/2 189/20
191/21 195/9 195/10
195/20 197/13 198/13}
199/2 202/18 205/19
207/12 209/4
alternative [5] 40/11
53/17 71/22 80/11
158/8
although [7] 9/15
54/11 75/23 118/3
153/23 174/10 186/7
always [4] 70/17
77/16 105/9 191/17
am [20] 1/2 15/10
15/21 16/20 17/13
22/20 58/18 58/20
68/8 74/17 118/9
135/5 160/20 163/8
168/3 168/12 179/13
208/24 209/6 209/16
Amanda [1] 23/6
ambition [1] 65/16
amend [5] 2/8 2/12
2/14 56/23 149/16
amended [1] 56/21
amendment [2] 3/9
3/25
amendments [2] 2/2
73/10
among [2] 156/8
195/24
amongst [6] 11/9
11/16 63/24 72/16
138/13 196/8
amount [6] 103/14
125/11 148/8 151/3
175/16 196/6
amounts [3] 59/24
97/19 124/8
analyse [2] 30/2
201/22
analysis [5] 29/7
42/25 68/15 134/22
139/9
analyst [3] 10/24
30/18 30/19
analysts [1] 30/5
Andrew [3] 15/16
23/8 163/11
annexe [2] 123/19
132/19
annual [3] 47/17
122/7 180/7
anonymous [1]
178/1
another [17] 3/9
11/10 13/24 41/22
44/16 52/1 54/23
55/16 55/17 59/4
68/17 98/9 120/12
128/20 163/20 163/21
186/17
answer [7] 28/8
64/13 81/16 155/16
163/2 191/23 195/17
answered [1] 128/1
answering [1] 202/16
anti [3] 15/19 15/20
16/14
anti-bribery [1] 15/20
anti-money [2] 15/19
16/14
anticipate [4] 65/12
67/22 95/18 98/5
anticipated [4] 99/23
103/12 151/14 175/3
anticipation [1]
95/23
any [91] 6/7 6/25 8/1
9/4 13/8 13/22 14/10
14/14 20/2 20/5 20/23
26/25 31/12 31/22
31/25 32/9 32/16
37/21 39/12 41/10
42/1 42/11 42/18
42/24 48/15 50/17
51/9 51/22 52/8 52/16
58/24 59/18 61/20
61/22 61/24 67/13
72/23 81/1 85/21
89/13 90/5 90/17
104/2 113/7 113/8
117/16 119/10 121/25)
127/3 129/15 132/13
133/18 135/12 135/23}
136/14 138/1 139/21
141/18 141/19 142/2
143/9 143/9 147/19
148/10 153/14 155/12)
156/19 159/11 161/15)
161/20 164/5 165/10
165/10 169/25 171/5
172/12 172/18 174/16}
177/7 177/20 177/20
181/2 183/10 184/4
187/14 197/8 198/11
202/6 202/6 207/20
208/12
anybody [1] 19/6
anyone [5] 19/2
49/11 60/2 140/18
209/9
anything [13] 27/19
37/20 38/7 38/12
49/14 55/6 60/11
90/15 110/8 136/15
145/19 202/1 205/12
anyway [5] 38/14
61/16 142/3 143/1
169/3
Apologies [1] 34/22
appalling [1] 187/12
apparent [8] 16/19
18/10 19/7 37/11 55/8
85/7 196/14 208/2
appeal [7] 37/9 78/10
118/10 129/23 130/24
131/14 206/20
appeals [5] 14/9
14/10 37/1 118/6
130/25
appear [2] 18/9
101/23
appears [7] 22/15
73/14 100/20 127/7
130/16 172/15 198/10
appendices [2]
151/10 151/21
appendix [5] 68/10
68/12 151/2 151/25
173/15
appetite [4] 64/20
70/23 76/6 81/14
applicability [1]
84/21
application [3] 70/4
90/19 185/6
applied [7] 74/2
139/3 140/6 158/18
184/15 184/18 184/19)
applies [4] 43/23
46/15 54/13 59/6
apply [8] 41/25 42/5
48/14 54/15 54/20
99/1 132/6 140/14
appointed [2] 5/17
69/17
appointment [1]
208/25
appraisal [1] 174/25
appreciate [3] 32/4
151/15 173/14
apprenticeships [1]
28/14
approach [24] 25/7
26/6 27/11 28/19 31/3
32/24 33/5 37/10
63/11 70/3 70/20 71/3,
73/21 91/21 135/22
136/3 139/9 142/8
142/10 169/21 177/14
177/15 193/22 206/2
approached [2] 7/20
139/10
approaches [5]
31/23 50/7 70/16
102/10 181/14
appropriate [22] 12/5]
24/19 56/19 58/12
61/22 72/18 79/13
88/2 93/22 109/2
111/12 119/21 120/1
120/16 150/14 166/21
168/10 168/17 171/8
171/17 184/5 184/15
appropriately [4]
24/20 46/19 48/1
98/23
approval [9] 36/4
69/20 79/10 93/13
106/25 137/23 139/25}
186/3 186/10
approvals [3] 65/6
65/8 84/19
approve [9] 36/1
36/12 75/1 91/22
93/10 103/17 106/6
107/20 143/25
approved [15] 17/24
30/7 35/21 44/6 64/3
92/8 94/16 103/11
103/15 107/8 107/16
107/16 107/17 107/22}
146/22
approves [1] 110/21
approximate [2]
10/13 162/20
approximately [3]
137/9 163/25 172/13
approximation [1]
169/7
April [7] 1/18 69/2
74/20 77/23 118/24
126/1 182/25
arbitrary [1] 98/25
are [223]
area [7] 26/12 26/21
26/23 27/1 42/22
124/20 180/13
areas [2] 93/21 162/6
aren't [1] 199/5
arisen [1] 117/2
arising [2] 26/9
183/10
around [27] 10/15
13/4 14/9 16/14 28/11
29/1 35/24 36/8 44/19)
49/21 87/14 89/16
90/21 102/15 103/23
110/12 114/16 127/4
152/5 161/10 177/8
181/3 185/12 190/5
198/22 207/18 209/9
ARQ [1] 30/13
arrange [2] 117/7
160/24
arrived [1] 85/5
articulated [1]
123/13
as [254]
ascertain [2] 148/24
149/19
aside [1] 113/9
ask [20] 1/15 1/20
2/22 2/25 4/25 73/12
86/19 86/20 101/14
101/24 105/8 108/14
112/16 166/23 171/19)
176/15 178/3 202/13
203/5 209/10
asked [30] 6/14 12/9
18/4 25/6 27/9 28/8
30/4 49/13 57/15
57/17 57/18 73/1
82/16 88/21 88/22
92/17 93/6 94/11
104/12 106/6 117/5
127/10 134/23 148/3
152/9 191/24 194/18
198/21 198/22 200/2
asking [8] 7/24 49/16
61/6 104/21 145/11
146/17 168/19 196/22)
asks [1] 187/21
aspect [5] 30/8 43/7
87/2 87/3 186/7
aspects [1] 30/4
assert [1] 86/21
asserting [1] 86/21
assertion [1] 197/13
assertions [1] 40/23
assessing [2] 130/20
142/16
assessment [4] 69/8
91/16 127/3 187/4
assessments [1]
187/14
assessor [1] 88/9
assigned [1] 103/25
assist [43] 7/5 9/23
19/16 28/23 29/24
35/22 36/15 41/10
49/8 53/24 57/13 64/5)
65/2 67/14 68/4 72/2
73/6 73/25 79/21 83/2I
83/5 86/13 92/7 94/9
99/20 107/5 107/15
108/19 110/3 115/11
116/13 127/18 137/9
137/25 144/4 151/10
151/19 152/18 161/25)
165/13 188/25 189/2
189/24
assistance [4] 16/9
(66) alluding - assistance
A
assistance... [3] 82/7
150/8 170/10
assistant [3] 64/1
88/5 153/20
assistants [2] 81/9
117/4
assisted [2] 9/2 80/2
assisting [2] 19/15
97/16
assists [2] 10/13
30/14
associated [5]
115/23 157/15 157/22)
158/6 194/15
assume [5] 178/6
198/25 199/4 207/4
207/12
assumption [2]
154/16 154/19
assumptions [2]
182/16 199/5
assurance [27] 5/11
5/24 5/25 6/1 6/1
18/20 25/19 26/7 27/7)
27/12 27/15 27/21
27/22 31/15 31/15
31/16 43/13 63/2 71/2
99/25 116/3 141/3
144/2 144/3 154/15
163/3 170/8
assure [7] 18/16 27/9)
32/3 87/23 93/22
145/17 158/15
assured [2] 94/1
116/2
at [246]
Atkinson [1] 8/17
attached [4] 139/12
141/9 162/4 166/7
attend [2] 84/14
143/20
attended [5] 14/17
84/16 100/14 169/19
177/13
attendee [1] 100/10
attending [2] 100/16
100/25
attention [4] 24/9
55/24 135/6 179/5
attesting [1] 148/7
attract [1] 163/23
audible [1] 191/23
audio [2] 165/6
168/21
audit [3] 95/12 97/9
103/13
audited [1] 95/15
auditors [1] 169/19
audits [1] 96/7
August [10] 2/23
5/22 24/8 57/15 69/9
84/11 92/11 147/12
184/22 192/25
author [1] 92/16
authorisation [1]
107/21
authorised [6] 32/23
48/3 105/9 105/10
105/13 173/25
authorising [1]
107/13
authorities [3] 81/3
174/21 208/2
authority [7] 41/15
41/16 44/8 47/10 48/2
78/24 186/11
authors [2] 69/4 73/6
availability [2] 19/18
161/1
available [5] 38/8
38/10 99/2 187/1
200/10
avoid [2] 62/6 62/8
avoidance [1] 167/22
await [1] 167/18
awaiting [3] 117/19
139/6 144/5
aware [39] 10/19
16/3 17/13 17/22 19/8)
19/9 36/19 44/13 55/6
56/21 59/18 68/18
96/12 112/24 113/15
114/9 114/15 117/22
118/18 129/15 135/17)
144/21 146/18 147/14)
169/18 170/8 176/8
176/10 178/18 182/9
182/13 183/14 190/6
193/7 194/3 194/7
200/7 207/4 207/12
away [4] 37/21 40/21
63/15 137/18
B
back [36] 22/3 33/16
58/15 65/5 68/1 69/13
73/16 85/18 92/24
101/16 104/9 111/15
111/25 112/16 113/6
119/5 123/21 125/25
126/6 132/18 144/15
146/9 154/23 157/9
158/19 160/6 162/17
165/17 178/8 187/13
190/7 199/18 202/4
204/23 205/13 207/19)
background [9] 7/2
14/20 48/21 69/5
107/6 115/15 124/3
179/13 193/11
backlog [1] 101/3
backward [1] 181/17
badly [1] 191/20
bag [1] 55/19
Bailey [1] 11/15
balance [2] 50/7
117/2
balanced [1] 139/16
balances [1] 141/21
barrister [1] 21/21
barristers [1] 20/3
Bartlett [30] 1/6 1/8
1/12 1/13 5/10 58/22
60/3 84/13 111/23
143/19 162/3 163/8
168/7 171/24 191/18
192/6 195/19 197/9
198/20 198/23 199/6
201/2 201/13 201/20
202/2 202/7 202/13
206/9 206/16 210/2
based [19] 43/3
46/17 51/19 51/25
53/7 53/7 53/16 71/14
75/21 82/11 112/14
127/8 130/17 139/6
141/4 146/5 150/5
159/12 165/10
basically [2] 110/5
202/7
basis [21] 6/3 6/6
14/16 16/16 25/5
41/14 67/4 81/24 91/2
101/17 125/10 134/17]
146/20 150/8 151/23
156/2 156/3 156/10
156/12 196/8 199/5
Bates [1] 141/13
BD [1] 166/5
be [365]
bear [1] 142/14
bearing [2] 51/21
208/6
became [3] 5/21 78/5
196/14
because [88] 10/3
10/21 17/24 20/25
21/6 21/23 29/1 44/9
44/19 49/25 50/6
50/16 50/19 51/1
51/11 51/12 51/16
52/12 53/3 61/25 62/3
63/12 64/7 64/18
64/24 65/4 65/15
67/25 70/25 72/5 74/2
74/8 76/24 77/10
83/12 87/14 88/8
94/22 96/16 102/21
102/25 104/1 111/5
111/9 118/9 119/3
120/9 120/19 134/17
145/14 146/8 147/18
152/8 153/5 154/15
155/18 155/21 155/21
157/25 159/19 160/2
161/15 163/23 166/1
171/15 173/12 174/17]
176/18 183/1 184/24
187/21 188/10 190/3
191/9 192/4 192/15
194/16 195/18 198/24,
199/2 199/22 201/7
201/23 204/17 205/24,
207/23 208/11 208/25
become [3] 96/10
135/17 176/10
becomes [3] 60/3
61/9 96/8
BEDs [1] 197/2
been [144] 4/3 8/13
8/23 9/18 11/4 11/11
11/13 12/9 13/4 13/20}
13/21 16/4 16/7 17/24}
21/23 25/12 26/20
27/11 28/5 28/12 32/4,
32/6 32/15 36/19
36/25 44/5 44/17
44/25 51/19 52/14
56/21 56/22 57/3
57/21 58/3 59/10
59/12 62/16 64/21
66/10 66/16 66/19
66/20 67/18 68/5
68/16 72/4 74/10 76/9
77/10 78/14 79/1 79/6)
80/6 82/2 83/6 85/3
86/1 87/17 87/20
93/13 96/21 100/1
103/3 105/9 105/9
105/22 107/2 111/2
1119/2 111/3 111/5
113/15 113/17 113/20}
115/12 115/20 116/16}
116/24 117/25 118/8
127/10 133/18 133/24)
133/25 135/19 136/24}
137/15 137/15 138/11
141/13 144/21 147/16
147/23 148/21 150/5
150/13 152/14 152/23}
154/4 158/20 163/11
164/9 167/2 167/6
167/25 169/1 172/12
173/3 173/6 176/5
176/15 177/6 179/5
179/25 182/14 184/20
184/20 185/21 185/23}
185/24 186/3 186/5
186/9 187/7 187/18
188/1 188/5 188/16
191/20 191/24 193/11
193/15 194/23 195/1
195/4 198/4 200/1
200/3 202/16 203/15
205/11 208/10 208/12,
before [30] 3/20 7/12
9/15 13/19 14/24
25/12 31/6 37/25
46/13 56/5 56/25
58/23 59/14 85/1
86/25 105/21 110/16
119/2 123/1 132/7
132/17 137/7 138/20
147/13 152/6 160/12
179/15 183/20 202/6
205/19
begin [4] 7/24 43/4
112/1 165/25
beginning [4] 8/22
27/2 118/20 138/9
begins [2] 123/23
132/20
behalf [7] 15/8 20/19
21/25 23/10 46/7
183/25 202/14
behaved [1] 175/22
behaviour [5] 12/6
45/16 55/22 136/1
176/5
behaviours [3] 45/12
89/7 89/11
behind [2] 28/3 28/12!
being [74] 9/13 13/12)
19/21 20/20 27/23
33/21 35/11 36/8
38/11 43/22 44/16
50/8 50/9 52/4 61/20
64/2 67/2 67/7 69/25
75/4 76/11 76/18 77/8I
80/22 84/12 85/4 88/8
88/10 91/25 94/11
96/12 97/2 97/7
103/25 104/11 105/14)
105/17 108/1 113/13
113/23 114/8 117/17
117/22 119/13 120/25)
122/1 124/11 128/13
131/5 138/2 141/10
142/25 145/22 151/4
152/3 152/9 153/22
167/4 167/22 172/13
179/4 181/25 182/6
182/6 184/13 189/12
189/20 196/23 198/21
198/21 199/12 199/21
203/13 208/15
BEIS0000789 [1]
112/1
belief [5] 2/1 2/16 3/8
4/15 5/5
believe [25] 11/21
13/12 14/21 18/22
19/11 22/18 23/11
42/13 66/13 73/1 85/6
87/20 90/24 97/11
100/5 109/23 119/1
123/7 139/16 143/1
153/20 169/20 172/10)
178/25 200/25
believed [1] 189/5
believes [1] 175/19
belittling [1] 178/9
below [14] 31/21
53/1 93/11 97/21 98/9
98/15 99/9 99/17
116/23 119/6 127/17
139/18 164/2 166/14
Ben [3] 22/18 33/6
(57) assistance... - Ben
B
Ben... [1] 176/11
benefit [1] 19/21
benefited [1] 141/20
best [18] 1/25 2/16
3/7 4/14 5/4 10/10
16/13 70/4 86/23
103/7 107/24 126/13
134/13 134/15 140/9
150/10 167/5 180/11
better [5] 57/17
120/15 123/13 129/2
178/5
between [25] 14/1
47/20 81/7 88/10
97/22 108/25 118/1
118/13 118/20 128/12)
129/7 136/22 136/23
142/5 142/12 144/7
165/21 172/3 178/12
182/5 185/9 191/10
196/11 197/16 197/22)
beyond [6] 129/19
145/1 149/5 159/1
191/10 209/1
bias [2] 180/8 181/3
bid [1] 209/12
big [1] 85/21
Birch [1] 24/4
bit [7] 46/14 123/2
145/15 160/3 175/3
178/21 201/23
bits [1] 51/3
Blake [15] 1/4 1/9
62/15 108/15 123/1
175/3 191/24 194/17
196/21 200/3 203/15
204/4 208/20 209/9
210/4
Board [46] 6/18 23/4
23/10 35/6 35/10
35/14 35/15 35/18
35/25 36/4 36/6 36/9
36/15 43/6 68/25 75/2
91/23 92/8 92/9 92/12
92/17 105/23 106/2
106/6 106/8 106/14
106/18 106/25 107/8
107/12 107/15 107/19
107/24 107/24 108/3
110/21 138/2 139/10
141/7 144/2 167/21
173/11 182/25 189/25}
193/20 199/3
Board's [1] 138/21
bodies [3] 75/13 92/4
140/21
body [1] 167/7
Book [3] 106/14
106/24 109/18
books [1] 102/24
boss [1] 8/6
both [14] 29/10 35/7
35/9 60/4 76/1 76/2
96/24 115/21 117/19
120/23 132/15 139/25)
174/15 174/16
bottom [12] 24/8
56/13 56/15 60/12
80/3 88/17 100/19
132/22 160/17 165/9
165/19 183/3
Bradshaw [2] 11/10
175/23
branch [43] 55/23
70/2 70/25 71/2 73/15)
74/1 75/5 75/7 75/19
75/23 77/25 84/21
92/1 95/12 97/9
103/13 116/17 121/19)
121/24 124/5 124/10
124/17 124/18 128/3
128/10 130/2 130/9
140/25 144/24 145/2
145/18 145/23 146/16)
149/6 149/13 149/16
150/11 150/17 158/14)
162/4 166/1 192/13
196/17
branches [7] 16/20
95/4 95/15 95/19
112/11 163/12 203/12)
brand [4] 158/17
breach [1] 54/18
breaching [1] 47/8
break [14] 56/6 56/25
58/13 58/19 58/23
59/4 59/14 104/11
105/21 138/21 160/13)
171/18 174/7 175/8
Brennan [1] 11/15
bribery [1] 15/20
briefed [1] 189/25
briefings [1] 8/1
briefly [8] 16/18
24/13 54/2 56/5
142/20 180/1 180/20
188/25
bring [7] 24/15 36/22
123/17 141/2 155/1
174/20 175/11
brings [1] 142/13
broad [2] 49/19
134/13
broader [2] 32/16
121/16
broadly [3] 66/9
68/21 185/4
Brocklehurst [2]
193/17 194/5
Brocklesby [1]
189/16
broke [1] 193/14
broken [1] 166/1
brought [7] 24/9
30/17 33/2 56/7
117/25 122/2 206/1
budget [7] 94/22
101/14 101/25 103/22
103/22 104/1 104/2
bug [2] 146/9 146/14
bugs [15] 30/23
90/20 116/15 128/8
140/21 141/15 144/22
145/8 145/23 148/17
148/20 148/24 148/24)
154/6 198/16
build [4] 25/6 31/12
161/21 189/18
built [1] 96/12
bullet [14] 25/13
25/21 26/21 27/5
27/20 28/2 71/20
73/12 73/13 84/17
89/20 99/14 112/7
185/5
bullying [2] 89/16
89/17
Burton [1] 23/6
business [36] 10/16
12/16 12/25 13/10
24/17 26/7 26/12
31/21 32/22 46/9 63/2
63/3 64/12 64/24
66/15 69/14 70/20
71/14 82/6 82/15 85/3,
87/18 93/19 94/6
96/24 97/8 98/16 99/4
101/10 104/18 104/19}
111/8 122/22 142/10
149/4 184/11
Business-based [1]
71/14
but [181] 6/24 9/16
10/2 10/18 12/23 13/1
13/21 14/24 16/11
16/15 17/13 17/23
20/3 21/6 21/18 21/24
22/8 23/23 26/23 27/9
27/10 28/12 29/11
30/8 31/2 31/25 32/5
32/10 32/16 33/24
34/7 34/17 36/8 36/13
38/6 38/24 40/17 41/7
41/16 42/6 42/22 43/7
45/2 46/8 46/18 48/17
49/14 49/17 50/6 52/3
52/9 53/10 53/19
53/22 55/1 58/5 58/8
60/2 60/11 60/23
61/20 62/11 63/11
65/16 66/9 67/11 68/1
68/6 68/8 71/2 72/22
73/4 74/18 75/5 75/25
76/14 77/16 79/9
83/11 83/25 84/3
84/16 85/9 85/14 87/3
87/9 89/4 94/15 96/4
98/4 98/14 98/20 99/2
99/10 100/15 100/25
103/16 104/8 105/9
107/20 108/2 108/6
108/15 110/6 110/11
112/2 112/18 113/18
113/19 114/12 114/13}
114/19 114/21 115/4
116/12 118/21 119/2
121/25 123/7 126/12
126/12 133/25 135/1
136/24 137/13 141/3
142/15 143/1 143/9
144/15 145/17 145/22)
146/20 146/23 151/17}
153/1 153/25 154/2
155/8 155/25 158/24
159/15 161/12 166/18}
168/1 170/14 170/16
171/12 171/19 171/23)
172/12 173/3 173/20
177/9 177/19 178/17
179/24 182/3 182/4
182/7 182/11 182/21
183/21 183/24 185/16}
185/22 186/22 188/1
188/12 191/3 191/10
191/20 194/15 195/9
198/6 203/7 205/11
205/15 206/5 206/23
208/7
Cc
cabinet [1] 187/23
calculate [1] 122/6
calculation [1] 118/7
calendar [3] 65/17
65/19 65/20
call [14] 6/19 17/12
49/10 53/9 53/9 54/4
61/4 63/8 70/21
116/19 124/10
called [15] 9/9 14/3
15/2 17/14 20/16
34/19 35/1 46/22
48/16 70/24 104/25
153/11 154/21 179/25}
187/3
calling [2] 68/10
203/7
calls [2] 90/21
116/19
came [10] 30/15
32/21 86/12 126/6
142/24 143/6 172/11
179/18 179/20 190/11
cameras [1] 13/5
Cameron [4] 89/21
112/9 114/13 114/17
Cameron's [1] 90/25
can [172] 1/10 1/15
1/20 1/23 1/25 2/22
2/25 3/17 7/5 9/22
11/22 11/25 11/25
13/16 13/23 14/18
19/16 20/2 21/17 22/7
22/11 22/12 22/14
23/12 24/3 24/22
28/23 29/11 29/24
31/3 31/23 32/9 32/10I
32/13 34/4 35/22
36/15 36/22 42/12
44/4 45/9 47/5 48/3
49/8 50/1 50/2 50/5
50/6 51/3 51/18 53/24
54/2 57/5 57/7 58/15
59/6 60/12 61/17 62/6I
62/17 63/15 64/5 65/2I
65/12 68/4 69/1 69/7
72/2 73/6 73/25 74/15
74/25 77/22 79/21
81/9 82/3 83/5 84/9
84/11 89/14 92/11
92/19 92/24 93/17
94/9 97/15 99/20
100/7 102/13 102/19
105/16 107/5 107/15
108/19 109/25 110/3
110/4 110/6 111/15
112/4 112/5 113/9
115/8 116/13 118/19
123/1 123/23 128/3
132/8 132/17 132/23
134/5 134/7 134/19
134/21 137/9 137/20
139/2 141/2 142/20
144/4 144/14 147/1
147/10 150/10 150/20)
151/25 152/1 153/4
156/5 156/7 157/12
158/7 160/4 160/9
160/15 161/1 161/23
162/7 163/2 163/20
165/13 165/25 166/5
166/13 167/21 168/5
170/4 170/14 171/19
173/23 174/10 174/20)
176/3 176/15 178/12
178/14 179/2 184/21
184/24 185/4 188/15
188/24 189/2 189/3
190/8 194/24 199/18
199/21 204/15 204/17
207/21
can't [10] 54/6 65/15
65/15 81/12 92/10
104/13 104/20 158/16)
170/17 199/22
candour [1] 207/17
cannot [4] 114/22
141/19 166/7 196/7
capabilities [1] 93/23
capability [3] 19/24
33/1 74/7
capable [2] 54/9
128/9
capacity [8] 19/17
20/3 27/10 47/18
94/11 94/12 102/16
102/18
capture [1] 181/21
(58) Ben... - capture
Cc
capturing [1] 182/7
careful [1] 148/23
carefully [2] 150/7
172/24
carelessness [1]
117/3
carried [4] 12/23
66/16 184/1 188/7
carry [9] 17/9 38/22
38/24 46/9 63/24
93/13 160/9 164/14
207/6
Cartwright [1] 20/21
case [86] 11/9 11/14
11/16 11/16 14/16
14/16 16/5 26/17 27/3)
39/4 41/25 42/2 45/17
51/23 60/22 68/16
81/5 81/11 89/5 91/16
95/11 96/8 99/15
102/18 102/24 106/20
107/9 117/5 117/20
117/24 118/11 119/14}
119/18 121/14 122/13)
123/24 123/25 125/7
126/3 126/7 127/3
129/18 129/22 129/24}
130/21 132/16 132/23
133/5 133/14 133/15
133/17 133/18 136/6
136/20 141/12 146/18)
150/8 150/8 152/22
153/12 153/13 153/14
154/1 156/2 156/2
156/3 156/3 156/17
156/22 157/4 159/17
172/4 172/6 172/12
172/15 173/2 173/2
174/10 181/24 187/17)
187/18 199/12 199/16
199/23 206/5 209/4
case’ [1] 129/24
caseload [3] 21/2
182/19 182/20
cases [43] 3/13 6/4
6/14 11/1 11/8 11/9
20/17 21/8 21/10
21/12 55/11 55/14
68/9 82/10 83/15
87/14 91/9 95/21
95/25 99/8 99/22
112/18 113/11 114/5
123/21 129/15 153/22)
154/3 154/12 159/14
159/22 164/17 174/17
177/17 1814/1 181/4
186/8 186/15 188/6
199/22 200/8 202/22
206/1
casework [1] 71/15
cash [12] 55/12
55/20 55/20 85/3 95/4
112/11 114/14 124/6
124/7 124/8 125/11
169/23
cast [1] 98/3
catch [1] 142/21
catch-all [1] 142/21
categories [1] 183/4
categorised [1]
109/20
category [3] 50/11
89/2 183/8
cause [11] 6/21 38/6
116/2 116/10 116/24
116/25 148/25 150/11
155/11 156/19 181/24)
caused [5] 18/10
72/4 95/9 149/19
164/4
causes [2] 136/17
141/18
caution [10] 39/17
48/18 48/25 50/19
59/3 59/25 60/1 60/10
61/19 165/5
cautious [2] 62/9
169/6
caveat [5] 66/3
138/19 139/3 141/9
206/24
caveats [2] 66/8
141/23
CCTV [2] 13/5 42/25
ceased [2] 65/22
115/19
cent [5] 155/8 155/9
155/10 155/15 156/11
central [13] 5/14 5/21
63/10 69/6 69/10
93/20 94/3 97/23
100/23 104/25 127/6
161/16 163/9
centralised [3] 25/7
27/16 105/3
centrally [1] 161/10
centre [7] 17/13 53/9
54/4 70/21 116/20
124/7 124/8
CEO [5] 82/5 170/20
189/10 193/17 194/4
certain [11] 36/1
43/19 78/12 82/11
132/3 173/18 182/2
182/16 188/6 194/12
194/19
certainly [13] 9/2
21/2 29/21 54/15 71/6
90/14 95/8 95/10
96/11 131/21 171/19
205/7 206/7
certainty [1] 65/15
cetera [6] 20/23
133/12 145/3 151/1
151/6 185/16
chain [3] 71/6 71/7
165/18
Chair [5] 65/2 65/12
123/19 193/3 195/14
Chair's [1] 110/25
Chairman [6] 36/10
36/12 108/21 158/24
170/20 171/2
chairs [1] 205/10
challenge [2] 131/10
197/13
challenges [1]
157/13
challenging [1] 158/2I
champion [3] 10/8
23/5 23/7
chance [1] 160/6
change [36] 2/5 3/15
4/3 4/11 4/11 4/15
10/17 10/18 10/19
32/24 33/4 36/13
36/16 51/7 51/20
106/8 106/23 107/13
107/21 108/3 108/7
109/3 109/4 110/23
111/2 137/24 138/8
138/20 139/14 143/3
175/21 176/3 179/2
181/10 181/11 195/18}
changed [12] 23/15
49/2 66/23 68/19
81/13 89/4 103/20
154/17 176/7 201/19
205/9 205/10
changes [8] 2/15 5/7
5/8 31/22 32/6 42/11
138/14 177/1
changing [4] 3/14
35/24 64/18 74/23
characterise [1]
162/14
characteristics [1]
36/14
charge [2] 124/5
125/2
charged [2] 45/15
102/5
charging [1] 127/1
chasing [1] 170/23
check [2] 3/13 68/6
checking [1] 140/24
checks [2] 117/15
141/20
Chief [3] 83/9 153/21
153/21
choose [1] 89/24
choosing [1] 172/23
chose [2] 166/23
190/4
Chris [2] 10/25
189/16
Christie [1] 206/17
chronologically [1]
144/15
Cl [24] 3/13 3/14 4/2
4/6 5/22 6/12 12/18
18/23 19/14 27/21
27/22 48/2 48/4 52/22,
55/11 62/23 99/24
138/16 142/13 142/17
178/6 178/12 192/8
206/23
circa [4] 95/21
124/13 125/4 125/14
circumstances [5]
38/15 64/1 164/3
201/10 209/8
City [41] 82/7 82/13
83/7 83/10 83/11
118/23 119/5 119/8
119/8 119/9 119/9
119/22 119/24 120/6
120/9 120/14 120/15
120/17 120/19 121/17]
133/5 135/18 146/19
147/3 147/8 147/11
148/3 151/10 151/12
151/13 151/19 152/18
153/16 172/1 172/3
172/11 172/18 173/1
199/15 200/12 200/13}
CIU [34] 32/23 69/6
69/11 69/16 69/17
69/20 71/15 75/9
75/16 79/10 82/9
84/21 84/23 84/24
85/1 92/2 93/7 95/6
95/7 95/11 97/12
97/17 97/20 97/22
99/9 99/24 101/6
102/2 102/5 102/16
102/17 102/21 103/10}
124/23
civil [21] 17/21 18/8
18/13 72/12 72/19
86/17 86/17 87/2 87/9
87/18 87/21 87/25
88/6 88/11 88/12
99/16 99/22 113/12
135/13 136/14 201/1
claim [1] 72/12
clarification [1] 47/1
clarified [1] 101/13
clarify [1] 34/10
clarity [3] 123/6
163/20 186/18
clarity's [1] 190/18
clear [17] 26/2 36/9
46/2 50/19 51/8 59/25
72/20 84/24 121/13
128/11 130/19 131/1
135/10 148/5 163/22
196/9 206/9
clearing [1] 102/3
CLEP [7] 33/14 33/15)
34/2 34/10 34/14
35/25 79/13
CLEP" [1] 138/6
climate [1] 112/17
close [4] 114/13
157/3 157/5 194/9
closed [3] 121/12
170/11 189/7
closely [1] 194/15
closer [1] 160/3
closest [1] 15/1
closure [4] 68/16
170/13 170/24 171/10}
code [2] 51/24
185/24
codes [4] 4/23 13/6
179/9 179/14
coercive [1] 55/22
collaborative [1]
203/22
collate [1] 182/4
collated [1] 27/14
collation [1] 182/23
colleague [1] 178/22
colleagues [2] 45/14
179/1
collect [3] 83/1
165/14 182/17
collected [4] 81/4
100/1 188/16 208/3
collection [1] 87/24
collective [1] 78/9
College [14] 28/13
28/15 28/20 29/7
29/14 29/23 30/7 30/9
31/8 31/19 48/12
49/23 50/2 180/16
collegiate [2] 63/11
67/3
collegiately [1]
141/17
column [5] 68/15
125/17 132/24 133/6
133/12
combination [2]
17/10 62/20
combined [7] 33/24
34/24 34/25 177/3
204/7 204/8 205/10
combining [1] 34/1
come [33] 7/1 13/23
15/1 16/17 21/23 49/5)
52/21 55/23 57/16
58/15 70/21 70/22
73/3 80/3 83/15 88/4
101/25 103/21 105/25}
111/15 122/19 135/6
137/18 158/22 165/7
167/12 178/8 178/13
183/23 191/18 197/16
200/6 200/8
comes [4] 17/11
143/11 146/9 153/17
comfort [1] 140/18
comfortable [1]
182/6
comfortably [1]
104/10
(69) capturing - comfortably
Cc
coming [2] 7/12
103/3
command [1] 71/7
comment [7] 34/8
35/2 42/3 67/24
151/16 163/23 177/7
commentary [2]
35/16 77/20
commenting [1]
89/11
comments [1]
126/22
commercial [2] 79/2
105/16
commission [1]
17/15
commissioned [3]
24/5 32/14 179/11
Commissioner [4]
82/7 83/10 153/20
153/21
commitment [2]
174/4 204/9
commitments [1]
158/1
committed [5] 45/11
131/5 158/24 161/18
173/25
Committee [1]
104/24
committing [2] 47/24
52/14
common [4] 42/5
115/18 115/23 136/18}
communicated [1]
147/5
communication [1]
39/19
company [4] 79/17
86/4 175/21 179/25
compare [1] 155/6
compared [2] 21/2
205/18
comparison [1]
129/7
compatibility [1]
157/24
compelled [1] 110/21
compensation [3]
14/8 76/25 118/7
competent [1] 83/3
complainant [1]
136/19
complaint [1] 206/11
complaints [5] 88/22
89/14 160/15 178/16
205/1
complete [5] 8/10
81/5 81/10 124/10
187/15
completed [8] 29/7
43/9 113/20 124/11
184/22 187/5 190/6
208/10
completely [4] 61/6
62/1 86/7 205/1
completing [1]
124/24
completion [3] 171/5
171/11 190/2
complex [9] 5/11
5/25 6/12 6/25 71/16
116/3 138/7 150/25
170/8
complexity [2] 82/12
157/22
compliance [5] 15/24!
107/17 124/9 124/10
185/16
compliant [2] 107/7
107/8
complications [1]
150/1
comply [2] 48/12
207/16
compulsory [1] 8/23
computer [3] 154/19
158/17 193/10
concealing [1]
201/25
concept [5] 20/16
35/8 41/17 43/2 100/6
concepts [1] 54/20
Conceptually [1]
82/22
concern [9] 32/16
89/22 97/7 102/15
110/9 114/10 136/16
155/12 156/19
concerned [4] 12/2
23/1 83/6 136/1
concerns [19] 35/22
90/10 90/11 90/11
111/9 114/8 114/11
122/21 122/23 135/6
140/19 145/22 159/3
159/6 168/8 178/18
179/5 188/14 203/15
conclude [1] 186/14
concluded [2] 69/8
129/17
conclusion [4] 40/3
91/16 121/14 129/19
conditioned [1]
209/3
conduct [53] 12/14
12/18 19/19 26/13
28/12 38/21 38/22
45/13 46/21 46/23
A7IT 47/10 47/23 48/3
48/16 49/21 49/25
50/10 51/5 51/24
51/25 53/23 59/2
71/14 72/5 75/9 76/8
78/15 79/11 86/6
89/17 92/2 95/3 105/7
109/9 112/11 112/14
136/17 160/21 165/4
177/10 183/19 185/12
185/13 185/25 186/17
190/4 202/17 204/24
205/6 205/14 207/1
207/7
conducted [18]
19/22 24/19 25/15
33/2 39/25 46/16
46/21 46/24 47/7
47/23 47/25 59/7 91/3
162/2 170/9 203/13
204/24 206/4
conducting [14]
18/17 20/8 40/16 46/3}
48/5 48/7 48/11 71/16
84/23 185/9 185/10
200/19 201/15 205/25
conducts [2] 186/13
186/20
confidence [1] 10/10
confident [2] 106/9
205/17
confidential [1]
196/11
confirm [4] 1/23 1/25
128/3 160/9
confirmation [4]
117/19 117/22 118/8
118/14
confirmed [1] 207/14
confiscation [1]
76/24
conflicts [2] 164/25
165/1
confusion [1] 120/10
conjunction [1]
139/1
connected [4] 10/18
111/6 177/9 182/20
connection [3] 77/20
155/10 160/25
cons [1] 106/8
conscious [2] 134/1
181/2
consequence [2]
102/23 158/4
consequent [1]
157/17
consider [10] 23/3
31/14 40/6 42/9 58/5
66/25 82/3 131/19
153/16 173/11
considerably [1]
142/15
consideration [2]
48/24 186/6
considerations [2]
13/8 46/3
considered [16]
13/19 32/1 53/18
69/24 108/8 110/2
110/7 113/23 125/12
130/19 138/6 141/13
148/14 184/24 201/11
203/21
considers [3] 150/6
150/12 153/14
consistency [4] 18/2
27/23 70/9 71/2
consistent [6] 26/2
26/4 26/6 26/16 27/10
45/2
consistently [1]
25/15
consolidated [1]
138/11
conspiracy [1]
125/13
Constable [3] 7/7
83/9 153/21
Constabulary [1]
123/16
constant [2] 175/19
196/24
constantly [2] 44/14
64/18
consult [1] 65/5
consultation [3]
63/24 65/8 65/8
consultations [1]
65/13
consultative [1]
181/13
consulted [4] 97/3
137/13 137/15 207/18}
contact [7] 53/10
64/15 84/1 117/6
119/6 119/10 119/19
contacted [2] 124/18
124/20
contacting [1] 120/5
contains [1] 192/24
contemplation [1]
127/15
contemporaneously
[1] 123/4
content [1] 151/20
contents [2] 41/25
152/4
context [6] 24/13
26/22 51/16 89/19
119/4 156/7
continue [8] 12/13
66/15 122/6 144/22
149/17 158/5 158/7
207/15
continued [2] 145/23
157/14
continues [4] 24/16
135/7 148/20 167/13
continuing [2]
144/15 164/5
continuous [1] 26/9
contract [11] 42/22
54/18 57/1 57/2 57/17,
57/17 104/8 105/15
181/5 185/10 185/11
Contracts [10] 40/1
52/19 54/17 57/16
57/21 58/1 58/9 64/13
93/24 102/23
contribute [1] 82/16
contributed [3] 43/21
102/6 207/18
contribution [1]
83/17
control [12] 65/15
108/24 109/15 110/1
134/11 141/4 145/16
146/21 152/11 171/13)
171/15 188/11
controls [2] 56/16
134/19
controversial [2]
84/21 84/22
convenience [1]
208/24
conversation [9]
60/20 87/16 108/24
119/12 119/12 119/24}
120/17 132/12 143/9
conversations [3]
10/1 62/13 134/1
convicted [1] 206/19
conviction [3] 130/22!
146/5 206/20
convictions [2]
130/25 131/1
convinced [1] 159/16
cooperate [4] 135/22
150/18 188/12 196/2
cooperation [8]
33/12 33/23 34/20
63/19 106/13 138/12
178/11 186/4
coordinated [1]
105/4
copied [1] 114/18
copy [1] 134/18
Core [3] 109/11
190/23 206/17
corporate [2] 25/8
81/24
corporates [1] 7/12
corporation [1] 78/21
correct [51] 3/22
4/20 5/12 5/16 5/22
5/23 7/3 7/10 7/16
9/14 9/19 14/1 22/17
23/2 24/6 24/7 28/6
28/21 33/14 33/18
34/3 44/6 44/10 46/11
48/19 66/6 66/12
66/18 66/21 66/22
69/19 76/4 80/1 85/6
93/3 93/15 93/16
110/24 116/25 118/9
125/9 126/3 159/24
169/9 172/25 173/22
176/23 178/7 185/3
(60) coming - correct
Cc
correct... [2] 192/23
205/25
correction [1] 116/25)
correctly [1] 45/12
correspondence [22]
118/12 134/25 135/2
135/19 136/21 136/22
137/1 137/4 137/10
137/19 144/16 144/17)
158/20 165/20 168/3
170/5 172/2 197/1
197/19 200/2 200/4
200/6
corroborate [3]
110/8 131/6 195/5
corroborated [1]
130/5
corroborative [5]
109/24 110/4 126/8
130/2 159/19
corruption [1] 15/21
cost [3] 82/16 83/18
105/19
could [87] 2/5 4/25
10/5 11/24 12/7 22/9
22/9 23/20 24/12
25/10 30/6 30/8 45/25)
46/12 48/20 49/17
50/24 50/25 51/2 56/7
56/12 57/2 60/22
78/17 84/18 85/13
86/12 86/16 86/18
86/19 87/10 88/17
89/24 90/16 94/1
101/6 103/24 105/24
108/8 108/9 111/25
113/12 116/16 118/5
118/6 119/15 119/19
120/2 120/12 122/25
123/12 123/16 132/12
132/18 132/21 136/20}
138/10 142/9 143/13
143/15 145/1 145/13
148/3 148/25 149/5
149/19 150/13 151/24}
154/17 155/1 157/8
157/20 165/17 165/18
167/15 168/21 175/11
175/13 177/25 178/5
181/1 182/20 182/24
185/13 186/22 187/6
189/23
couldn't [3] 10/3
43/15 170/24
counsel [6] 20/12
22/16 96/23 99/18
138/17 198/6
count [2] 95/3 169/23}
counter [2] 15/20
149/13
country [1] 83/14
couple [4] 2/2 44/18
204/1 205/20
course [12] 42/16
45/6 49/12 51/9 51/20
94/15 107/23 111/16
113/14 143/3 150/18
184/25
court [16] 37/8 76/24
77/5 86/20 87/14
87/15 88/11 118/10
127/23 129/23 130/24}
131/13 141/12 141/13)
180/4 202/6
courtesy [1] 168/5
courts [10] 17/21
18/13 77/9 81/19 87/6
87/18 88/1 127/9
150/19 158/13
cover [4] 39/11
145/15 162/6 168/7
covered [3] 8/12
40/14 186/8
covering [1] 30/1
covers [1] 6/22
CPIA [1] 41/16
CPS [8] 14/21 77/2
126/12 129/16 130/19)
132/3 160/6 174/21
create [3] 34/2 69/10
145/2
created [2] 24/21
179/23
credibility [1] 127/4
credible [1] 79/7
crime [37] 9/18 9/22
10/1 11/18 13/3 15/19)
16/7 16/10 16/11
19/10 45/16 52/14
56/6 56/14 57/11
79/18 80/5 82/8 82/14)
83/8 84/3 86/19 86/23
87/5 87/12 88/1 88/21
89/1 93/25 106/17
107/2 109/17 124/12
124/17 124/20 147/22)
161/18
Crime/Fraud [1]
56/14
criminal [102] 12/18
12/22 13/24 14/3
14/11 14/15 14/25
15/5 15/10 19/14
21/10 21/12 26/25
28/9 28/12 29/1 33/13
38/8 38/13 38/21
38/22 42/17 46/17
46/22 47/9 47/23
47/24 48/14 48/16
49/15 49/25 50/21
51/16 52/10 66/1 67/5)
72/3 72/5 72/10 72/15
72/17 72/21 72/23
75/9 75/14 76/13
76/19 77/1 77/7 77/9
77/14 77/18 78/18
78/24 79/11 80/15
80/17 81/19 82/25
84/23 84/25 85/1 85/8
86/6 86/12 86/20 87/2
87/15 88/1 88/14
91/19 92/2 92/5 93/14
95/5 95/20 95/25
121/2 126/22 129/23
130/24 131/14 135/13
135/16 136/12 136/16
138/1 138/17 139/24
142/14 150/19 153/12
158/13 164/8 170/1
180/3 185/9 186/2
206/23 207/1 207/7
207/7
criminality [6] 52/21
52/23 64/11 71/23
76/9 207/2
criteria [2] 32/2
132/10
critical [3] 37/9 90/8
173/18
ised [1] 78/25
ism [2] 90/8
9
criticisms [4] 36/25
37/5 37/13 136/8
cropped [1] 201/25
Crown [3] 82/10
126/4 126/5
culpability [1] 37/15
cultural [1] 114/22
culture [2] 85/17
88/19
curiosity [1] 183/24
current [39] 10/19
23/14 25/2 29/5 33/9
34/4 34/10 35/12
35/25 83/5 85/11
93/11 95/8 106/12
106/24 109/7 110/6
111/41 112/16 112/18
115/11 117/14 138/5
139/9 142/7 142/8
147/8 148/5 149/23
155/4 159/4 159/8
183/4 183/10 185/23
191/21 193/21 197/2
203/1
currently [21] 5/10
22/18 22/19 35/2
55/11 64/16 86/7 94/7
94/10 99/18 100/2
100/3 113/13 117/11
117/19 139/5 144/8
144/23 150/23 186/1
189/12
Customer [1] 125/12
D
Daily [4] 11/6
Daniel [2] 118/24
118/25
dare [1] 112/25
Darfoor [1] 23/8
data [91] 30/2 30/3
30/13 30/19 40/24
66/7 89/24 89/25 90/6
90/17 90/23 93/25
96/20 97/5 106/10
108/8 108/10 109/19
109/23 110/10 110/14,
110/15 110/19 110/20}
111/24 112/15 114/4
114/8 114/12 114/12
115/2 116/8 116/12
117/17 117/18 118/4
118/5 118/9 118/10
118/15 120/25 121/7
129/25 130/11 1341/5
131/11 134/9 134/11
134/18 136/5 139/8
139/11 140/3 141/19
142/18 142/25 143/1
143/3 143/10 144/3
144/8 144/11 145/17
145/20 146/7 146/24
147/2 148/1 148/8
149/16 150/16 151/14)
154/15 156/24 157/1
158/11 158/16 159/12}
159/18 160/9 181/22
182/4 182/8 182/12
182/17 182/23 187/12
196/16 200/15 200/22}
201/8
databases [1] 187/12
datasets [1] 31/6
date [18] 5/20 10/20
14/24 33/16 33/19
44/12 57/12 65/4
68/16 98/6 108/12
121/19 137/20 140/17)
150/6 170/17 180/10
198/14
dated [7] 1/18 2/22
4/19 25/3 106/2
192/25 195/24
dates [3] 98/4 141/19
142/2
dating [1] 73/16
day [6] 8/11 24/11
120/25 124/19 146/16}
209/16
days [1] 197/20
de [1] 116/23
de minimis [1]
116/23
deactivated [1]
189/18
deal [14] 16/15 21/1
23/25 52/10 99/10
102/14 102/25 103/5
104/10 104/10 134/22}
135/1 177/18 205/9
dealing [3] 50/3 84/6
147/23
deals [1] 15/19
dealt [10] 16/21
27124 54/4 54/7 89/18}
91/8 189/20 204/14
205/4 205/21
debate [1] 108/16
debts [2] 18/9 18/9
December [4] 141/11
157/9 196/22 197/19
decent [1] 85/20
decentralised [1]
71114
decide [3] 82/23
102/11 102/12
decided [4] 21/25
69/16 94/24 173/20
deciding [2] 59/23
181/8
decision [30] 13/17
43/18 56/3 59/10
59/12 59/18 91/16
92/21 101/18 104/5
105/16 109/16 111/5
113/21 127/1 127/11
127/13 127/19 130/16)
138/25 140/1 160/7
165/15 173/4 181/3
181/4 181/10 189/10
201/15 208/14
decision-making [1]
56/3
decisions [6] 37/8
68/25 68/25 94/23
165/10 189/11
deck [1] 205/10
declarations [1]
165/2
declare [1] 118/17
declined [2] 103/17
143/25
dedicated [2] 82/13
83/11
Deed [1] 73/20
defect [2] 146/9
146/15
defects [12] 30/24
90/21 116/16 128/8
144/22 145/9 145/23
148/17 148/20 148/24I
148/25 154/7
defence [4] 18/18
131/10 131/23 132/13)
defined [1] 129/24
definition [2] 60/18
60/22
defrauded [1] 79/4
degree [4] 40/1 44/17I
59/22 80/9
delayed [4] 192/15
delays [1] 28/5
delegate [1] 138/24
deliberately [1]
189/18
delineated [1] 60/16
(61) correct... - delineated
D
deliver [5] 10/10
93/21 94/4 94/8
193/23
delivered [1] 125/23
delivering [1] 157/24
delivery [6] 145/5
149/23 157/14 157/20
189/24 193/22
demand [1] 95/7
demands [2] 94/8
134/23
demographic [2]
181/22 182/10
demonstrate [3]
112/12 123/8 134/10
demonstrated [2]
114/23 183/24
demonstrates [1]
82/21
demonstrating [1]
195/23
department [13]
15/25 58/10 62/23
63/4 82/5 82/14 82/15)
89/12 93/3 94/7
122/23 129/15 163/17
department's [1]
63/6
departments [2] 65/5
178/12
depend [4] 98/6
146/7 159/13 195/14
depending [4] 31/22
98/24 99/2 138/18
depends [4] 60/18
60/24 88/3 96/1
deprioritise [3] 43/14
43/15 79/18
deputy [5] 47/12
47/14 47/19 48/4
139/24
derived [4] 154/13
describe [6] 15/4
134/19 163/18 187/25
199/11 206/22
described [11] 18/6
44/25 45/10 120/3
140/20 140/23 151/9
157/2 164/11 187/8
204/9
describes [1] 110/18
describing [1]
196/23
description [3] 22/4
152/11 188/2
designated [4] 47/12
47/14 47/19 48/4
desire [1] 201/9
despite [1] 170/23
destination [1]
124/12
destroy [1] 190/13
detail [8] 12/9 40/14
88/22 89/13 96/18
162/5 166/4 168/8
detailed [3] 45/13
69/8 168/20
details [2] 119/20
119/22
detected [1] 148/21
detection [1] 45/16
Detective [2] 7/7
56/16
determine [7] 29/2
53/15 55/14 60/2
150/10 157/1 181/2
determines [1] 55/3
deterrence [2] 79/7
81/1
deterrent [4] 71/25
76/11 76/15 85/23
detriment [1] 189/6
developed [7] 33/22
65/13 94/15 107/15
113/15 141/17 192/16)
developing [2] 98/10
195/19
development [4]
34/8 192/21 193/12
202/16
developments [3]
8/13 31/12 96/13
develops [1] 70/3
devise [1] 103/4
did [33] 5/19 7/25 8/4
8/11 45/18 73/7 73/9
73/23 73/24 74/18
84/13 87/11 89/2
90/10 101/23 103/19
107/20 108/22 109/9
118/4 122/17 122/19
122/20 126/19 137/7
143/20 146/15 149/5
161/20 176/10 181/11
203/3 207/19
didn't [13] 65/25 75/6
78/2 90/13 104/2
108/4 110/11 110/15
115/5 155/6 162/16
200/23 201/5
difference [7] 42/13
60/15 66/25 98/19
142/12 144/7 181/15
differences [1] 142/5
different [24] 6/9
32/3 36/7 44/16 46/20
49/6 58/10 62/20
70/17 71/7 71/11 73/7,
76/14 96/3 108/1
121/11 123/20 160/10)
160/11 160/15 196/18)
198/3 205/18 205/23
differently [1] 79/16
difficult [10] 22/8
60/17 61/11 81/20
88/3 94/23 95/18
107/23 112/13 166/2
iculty [1] 59/22
ital [1] 154/15
inishes [1] 80/25
[2] 6/4 6/6
diploma [2] 7/18
131/19
direct [7] 15/5 18/21
22/20 43/11 96/3
98/16 140/11
directed [1] 166/20
irection [1] 191/19
directly [9] 12/22
18/1 54/14 99/11
120/18 135/5 183/17
184/6 207/8
director [12] 5/10 8/6
9/25 20/13 23/6 23/7
109/16 138/16 160/14]
177/4 195/21 202/23
Directorate [2] 82/8
147/22
directors [4] 90/9
165/2 177/22 199/3
disagree [1] 101/23
disagreeing [1]
109/3
disagreement [1]
197/22
disagrees [1] 117/8
disappointing [1]
32/5
discharge [3] 24/23
41/4 41/11
disclosure [12]
14/19 41/6 41/11
41/13 41/20 41/22
143/18 143/22 144/1
168/3 201/11 207/17
disclosure’ [1]
110/22
disclosures [1]
167/18
discovered [2] 13/20
109/25
discrepancies [15]
17/6 18/10 37/11
117/11 145/2 149/1
149/20 150/11 154/3
155/11 160/22 160/25)
161/13 161/15 161/21
discrepancy [6] 55/9
116/1 116/10 117/14
152/23 166/17
discuss [3] 35/18
63/15 106/8
discussed [19] 13/12
13/20 14/19 35/8
35/10 35/11 84/12
137/1 138/2 138/20
147/16 148/19 150/20
180/17 190/23 194/17
200/5 201/24 206/2
discussing [2] 35/5
146/21
discussion [35] 35/4
42/6 43/7 59/16 59/24
60/3 60/8 61/4 61/9
64/10 87/5 87/8 87/14
92/9 100/6 100/8
107/19 107/20 108/5
112/6 122/21 138/21
139/3 143/13 162/13
162/17 164/10 165/6
165/7 165/20 166/24
167/13 175/14 202/20}
203/22
discussions [13]
13/22 35/20 44/18
54/25 55/1 83/19
92/13 111/1 131/22
148/2 148/6 193/20
196/10
disgrace [1] 175/24
disheartening [1]
85/24
dishonest [2] 161/21
164/12
dishonestly [1] 154/4I
dishonesty [3] 80/16
82/11 102/22
dishonesty-based [1]
82/11
dismiss [2] 132/7
132/11
dismissed [2] 132/1
132/17
dispatch [1] 114/12
disproportionate [2]
182/1 182/1
disproved [1] 185/21
dispute [7] 17/12
40/4 93/23 117/9
118/20 119/4 142/8
disregard [1] 136/8
distinction [2] 60/17
161/8
distinguish [1]
128/12
distribution [1] 75/2
distrust [1] 110/14
division [7] 57/6 57/9
57/10 129/24 130/24
131/14 184/2
do [145] 6/9 8/24
10/12 12/23 13/2 13/5}
13/8 14/20 14/23
16/11 16/15 17/9
17/20 18/4 21/5 23/3
23/9 23/10 27/3 29/9
29/13 30/10 33/20
34/8 35/2 35/12 38/17,
39/5 39/15 39/16
41/13 41/24 43/15
43/24 48/24 49/18
50/3 51/21 52/2 52/24)
53/11 54/17 55/14
56/3 58/6 59/21 59/21
61/20 62/6 63/12
63/25 64/10 64/13
66/25 67/7 67/10
67/22 75/23 76/17
77/6 77/17 80/20
80/23 81/16 82/1
82/21 85/2 85/5 85/11
87/17 87/22 89/8
90/11 90/16 94/11
96/23 97/7 98/4 98/22I
102/9 104/13 104/13
107/22 111/2 111/3
112/6 114/4 118/3
120/1 120/4 120/8
120/17 120/20 121/9
122/22 123/9 123/9
130/12 131/19 132/5
132/15 134/3 140/16
144/12 145/11 146/14)
153/9 154/5 154/9
154/14 154/20 155/20)
156/22 159/11 159/16)
159/25 162/12 164/13)
164/13 166/20 168/2
168/10 168/16 168/25)
169/12 169/24 170/12)
170/15 171/14 1714/5
171/8 173/8 178/6
179/2 184/9 184/9
184/10 184/16 186/25}
187/3 188/9 191/22
194/13 208/4 208/11
document [29] 10/5
10/14 10/18 10/22
24/9 34/23 34/25 35/4
40/17 44/5 44/15
44/24 54/22 56/25
61/7 76/20 76/23
92/18 105/20 105/22
106/2 118/22 119/3
157/9 175/13 179/24
193/16 194/3 194/4
documentary [1]
196/3
documented [2]
69/13 116/2
documents [9] 45/19
72/9 76/23 151/22
187/19 188/1 188/3
203/16 203/25
does [35] 3/23 6/12
11/20 14/10 14/13
14/14 17/17 17/19
19/1 19/6 44/21 47/13)
57/10 58/23 64/11
64/19 71/4 80/25
100/18 110/9 112/2
114/1 114/14 115/10
117/14 148/12 151/2
155/11 156/19 160/9
182/17 194/9 197/17
198/2 198/19
doesn't [20] 39/11
42/17 53/2 54/15
(62) deliver - doesn't
D
doesn't... [16] 64/16
64/16 75/23 78/13
84/6 84/7 132/5
134/24 152/7 168/14
182/11 190/18 194/12)
198/16 198/19 201/19}
doing [13] 28/14
30/25 45/11 50/25
60/11 63/14 78/25
86/11 170/22 194/24
195/7 195/15 197/9
doke [1] 58/16
don't [87] 10/3 10/17
13/10 13/18 13/19
14/24 17/23 17/24
19/11 21/1 22/18
29/14 34/12 35/19
38/14 38/16 39/5
41/16 50/20 51/21
52/15 52/24 52/25
53/23 56/9 56/23 58/1
58/5 67/24 67/25 71/4
78/5 81/15 81/21
81/23 84/15 85/6 87/3
96/4 96/9 98/4 98/7
100/5 100/13 102/25
104/8 104/9 113/2
113/6 126/12 131/24
132/3 132/6 132/11
144/9 147/8 147/15
147/19 152/6 152/20
154/23 155/18 155/18}
155/21 156/3 162/24
168/19 168/24 170/14}
170/14 176/14 179/24}
181/7 183/21 184/10
186/23 188/10 188/11
188/16 191/9 192/3
195/17 197/3 198/6
198/6 200/24 206/22
done [10] 17/15 31/5
51/8 65/16 66/13
114/1 121/22 164/17
169/23 205/19
door [1] 32/10
dotting [1] 171/25
doubled [1] 169/4
doubt [2] 167/22
173/11
doubts [1] 122/2
down [63] 11/6 13/23
22/12 23/20 24/12
25/20 39/18 45/25
59/3 61/8 63/1 64/21
65/9 69/7 71/13 71/20
73/12 74/25 75/15
75/18 77/22 78/20
84/17 84/18 85/16
88/18 92/19 93/17
95/1 96/11 98/4 99/4
100/19 100/24 112/4
113/3 113/24 126/17
128/1 129/4 129/21
131/8 133/4 133/13
138/10 138/24 140/8
140/13 143/16 147/25)
148/16 151/7 156/4
156/12 156/23 157/11
164/22 164/25 165/4
166/1 166/3 175/14
192/14
downscaled [1]
105/14
draft [19] 34/5 34/7
34/12 35/1 35/1 42/12
45/18 59/2 73/7 73/9
73/23 126/19 133/25
134/4 138/12 139/12
139/14 139/18 173/6
drafted [1] 142/13
drafting [2] 49/2
63/22
draw [3] 60/17
131/22 139/8
drawing [1] 50/5
drawn [2] 9/24 179/5
draws [1] 98/22
drive [1] 27/23
driver [1] 185/20
drivers [1] 27/22
drop [4] 122/12
due [11] 19/17 85/18
94/15 112/18 113/14
117/1 117/3 124/7
157/17 184/24 207/16)
Duncan [1] 8/17
during [17] 13/20
37/24 37/25 49/11
51/9 51/20 53/8 64/10
95/11 107/23 109/8
137/8 141/16 148/2
159/12 168/9 207/3
duties [2] 41/5
207/17
duty [4] 78/23 86/4
86/7 118/16
E
each [13] 32/3 70/18
107/25 109/5 156/22
159/13 166/5 174/9
178/5 188/3 191/5
199/23 199/25
earlier [23] 70/8 74/6
74/6 78/11 87/23
91/10 99/23 101/20
104/14 105/12 106/5
113/18 122/21 128/23}
140/24 141/9 159/21
163/5 169/16 172/16
180/17 196/22 208/1
early [5] 48/23 57/15
158/6 167/1 204/19
earth [1] 175/23
easier [2] 36/3 81/25
easy [3] 10/9 161/8
191/6
Economic [5] 82/8
82/14 83/7 84/3
147/22
EDI [1] 181/15
effect [10] 9/15 34/1
42/8 103/25 118/14
126/13 143/9 168/14
205/22 209/6
effective [4] 46/19
49/21 167/11 193/24
effectively [10] 13/25)
30/17 50/16 99/25
116/19 126/8 138/24
144/19 153/1 163/16
effects [1] 8/25
efficient [1] 107/3
effort [1] 45/21
EIA [1] 130/19
either [10] 13/9 14/21
19/19 31/23 31/24
67/12 119/20 129/2
139/22 174/12
elaborate [1] 207/21
electronic [1] 187/24
element [4] 35/24
64/8 80/15 101/22
elements [5] 45/24
161/16 161/17 189/17
189/24
elicit [2] 107/11
107/11
Elliot [10] 36/17
166/23 166/25 167/2
167/5 175/16 202/22
204/17 204/25 205/17
Elliot's [1] 161/10
else [5] 41/7 49/7
94/13 110/8 141/24
else's [1] 201/16
elsewhere [1] 73/14
email [13] 114/17
114/18 118/24 119/2
123/6 141/25 144/20
160/17 161/12 165/17)
166/9 166/18 175/12
emails [2] 166/15
167/2
embed [1] 70/16
emphasis [3] 76/17
76/20 77/7
emphasise [1] 91/15
employed [3] 12/13
54/14 160/20
employee [5] 52/4
60/7 185/25 186/16
188/6
employees [4]
173/19 183/11 183/20
185/24
employer [3] 60/8
60/9 60/11
employment [4]
75/21 186/15 187/9
188/18
enabled [1] 76/24
enabling [1] 149/15
enclose [1] 151/2
encouraged [1]
140/11
encouraging [1]
88/19
end [14] 21/8 65/17
68/14 125/23 154/22
157/17 158/1 161/1
174/2 193/4 194/17
206/24 206/24 209/8
endorsement [1]
82/6
ends [1] 208/16
enemy’ [1] 176/2
enforcement [60]
7/22 15/2 15/6 15/8
16/6 16/12 16/15
33/12 33/23 34/20
36/2 36/4 41/18 42/7
55/4 55/7 63/20 65/22
69/1 72/25 76/10
77/11 77/13 77/20
79/16 80/4 86/19 91/1
91/20 106/10 106/13
107/14 109/12 109/18}
109/21 110/19 135/8
135/12 136/19 137/25
138/13 138/16 139/15)
139/23 140/2 140/10
142/11 142/19 142/23)
143/24 144/12 154/14}
154/22 157/4 1841/5
186/5 196/16 201/24
206/25 208/3
enforcers [1] 86/13
engage [8] 15/8
19/19 19/23 21/5
72/24 153/4 164/6
166/23
engaged [5] 20/4
25/1 28/7 96/21
166/25
engagement [5] 15/2
25/3 119/7 162/21
204/20
engaging [4] 28/12
72/20 164/1 200/7
England [5] 81/4
82/4 83/14 153/19
174/22
enough [3] 102/25
104/9 114/3
enquire [1] 57/10
Enquiries [2] 57/8
125/4
enquiry [1] 161/25
ensure [8] 20/5 45/15)
63/2 69/11 116/9
134/20 143/2 151/13
ensures [1] 70/9
ensuring [3] 18/2
46/18 70/4
entails [1] 96/2
enter [1] 168/2
enterprise [1] 6/19
enterprise-wide [1]
6/19
entirely [8] 19/22
21/10 33/2 49/5 94/17
96/6 134/10 159/20
entities [1] 25/9
entitled [2] 131/12
207/6
entry [1] 2/14
environment [9]
52/11 81/13 134/11
134/14 142/6 142/7
145/16 146/21 157/7
envisage [2] 48/18
49/18
envisaged [2] 42/3
100/3
equal [1] 67/3
Equally [1] 175/16
equates [1] 156/13
Equipment [3]
160/23 161/4 163/12
equivalent [2] 19/15
119/20
ER [10] 26/22 51/24
52/2 52/4 89/18 94/1
100/11 184/17 195/2
204/24
ER-owned [1] 184/17
error [6] 56/12 56/20
1417/1 117/4 146/9
146/15
errors [15] 30/23
90/20 116/15 128/8
140/21 141/15 144/22)
145/8 145/23 148/17
148/20 148/22 148/24)
148/24 154/6
escalated [1] 54/6
especially [1] 41/5
essence [1] 88/12
essential [2] 40/18
129/25
essentially [10]
22/24 25/24 62/23
63/3 65/25 68/18
170/10 192/16 194/5
197/20
establish [5] 41/1
62/17 117/2 174/9
174/11
established [9] 76/25]
79/7 104/25 115/19
115/22 116/24 120/24}
179/17 183/15
establishes [1] 83/25
establishing [2]
60/21 120/25
establishment [4]
25/5 25/17 69/5
(63) doesn't... - establishment
E
establishment... [1]
181/13
et [6] 20/23 133/12
145/3 151/1 151/6
185/16
et cetera [6] 20/23
133/12 145/3 151/1
151/6 185/16
ethical [2] 83/3 180/4
ethically [1] 204/9
ethnic [3] 182/2
182/16 182/23
ethnicity [4] 182/6
ETICA [2] 179/25
180/22
European [1] 195/21
even [8] 34/19 44/24
50/12 52/20 71/5
101/7 110/10 131/1
evening [1] 209/12
event [4] 32/1 46/25
49/13 172/12
events [6] 38/16
78/24 79/2 155/22
167/1 173/2
every [5] 6/4 8/11
24/1 120/25 177/12
everybody [4] 8/24
184/24 208/23 209/2
everyday [2] 18/8
156/16
everyone [3] 187/21
191/7 209/7
everything [6] 41/23
41/24 62/6 83/24
200/10 201/22
evidence [114] 8/17
8/18 18/15 26/8 29/25
36/1 37/20 42/24
43/17 51/6 55/25 60/1
62/23 67/25 79/3 81/4
82/2 82/24 83/2 83/3
86/13 87/24 87/24
88/9 89/23 95/13
97/24 99/16 99/25
101/20 106/7 106/15
106/19 107/1 107/3
107/9 107/14 107/18
109/10 109/22 109/25}
110/1 110/4 110/8
111/1 121/14 121/20
123/12 126/9 126/13
127/3 127/23 130/2
130/3 130/4 130/5
130/10 131/2 131/4
131/6 131/25 134/16
134/24 139/6 139/23
140/9 141/7 142/3
142/16 142/22 147/1
148/9 148/10 149/2
150/5 152/9 153/6
158/12 159/13 159/19
159/21 162/8 162/19
165/15 167/8 167/23
172/21 173/8 174/8
174/11 174/12 182/14)
183/11 183/12 185/20)
185/22 188/12 193/4
195/22 196/7 197/12
198/12 198/23 199/2
199/10 202/3 202/5
203/3 203/11 204/10
204/11 208/3 209/5
209/7
evidence-led [2] 83/3
204/10
evidenced [2] 71/23
76/9
evident [2] 32/13
97/11
evidential [7] 52/11
120/13 132/4 132/6
132/10 132/17 199/8
evidentially [1]
120/24
evidentially-establish'
ed [1] 120/24
evolves [1] 51/6
ex [1] 176/5
ex-policeman [1]
176/5
exactly [3] 81/16
92/18 101/7
examination [1]
194/9
examine [1] 39/21
examined [2] 149/18
171/21
example [53] 8/16
10/24 11/7 15/6 18/2
18/10 21/18 30/1
30/13 31/8 31/18
36/11 38/9 39/2 42/21
42/23 47/16 50/25
53/11 55/17 57/7 59/8)
60/25 64/9 64/23 71/9)
72/11 72/19 77/8 79/3
81/12 82/1 83/6 87/9
88/4 97/10 102/16
104/4 113/1 120/17
128/17 131/18 154/6
155/3 155/8 161/20
163/21 177/5 182/1
182/9 182/15 184/5
186/15
examples [1] 11/2
Excel [1] 166/1
except [1] 115/21
exceptional [1] 209/8
excess [1] 97/19
executed [2] 69/13
204/9
Executive [42] 6/17
20/9 22/21 22/25 23/6
23/7 25/11 44/1 68/24
69/3 74/16 74/19 75/1
75/15 77/23 84/10
84/10 84/20 90/9
91/22 92/8 92/14
92/25 93/2 93/6 100/8
101/23 103/3 103/4
103/9 103/17 106/4
106/11 137/22 138/4
143/14 144/7 160/14
173/10 177/22 199/3
202/23
Executive's [1] 79/10
exercise [1] 150/25
exercises [2] 154/15
154/15
exercising [1] 135/23}
exhibited [4] 10/6
exhibits [3] 136/9
174/23 203/25
exist [3] 75/23 78/13
149/17
existed [3] 90/21
142/6 149/16
existence [3] 144/25
148/17 161/15
existing [3] 79/8
103/22 184/8
exists [2] 80/10
142/13
exonerate [1] 129/10
exoneration [1]
129/19
expand [2] 11/25
102/19
expanded [1] 183/8
expansive [1] 45/13
expect [8] 29/13
35/12 45/13 61/3 81/5
159/11 188/5 188/9
expectation [3]
64/20 80/9 187/16
expected [4] 49/4
116/9 137/15 183/23
expecting [1] 49/20
expects [2] 46/6
135/8
expedient [1] 105/18
Expenditure [1]
104/24
expense [1] 105/18
experience [12]
30/16 31/2 60/4 60/21
77/12 79/22 80/6
142/14 156/16 177/4
203/20 205/12
experienced [8]
30/18 48/2 106/23
155/4 155/9 155/10
156/8 156/10
experiencing [2]
86/1 156/11
expert [18] 8/16
146/22 147/1 148/9
148/10 150/9 150/10
150/15 152/5 152/7
152/15 155/2 174/13
174/25 196/6 197/14
197/15 198/11
experts [4] 53/3
128/18 128/22 129/1
EXPG0000007 [1]
155/2
explain [7] 28/5
48/20 156/5 156/7
170/14 187/20 187/22}
explained [3] 15/17
92/21 161/24
explaining [1] 162/5
explanation [2] 53/20}
170/21
explanations [3]
40/11 53/18 204/21
explanatory [2]
129/12 129/13
explicit [4] 37/18
39/15 59/6 59/10
exploratory [1]
119/11
explore [1] 119/15
expressing [1]
200/14
expressly [1] 172/17
extend [1] 129/18
extended [1] 104/20
extension [2] 19/20
157/11
extent [11] 27/17
40/4 41/19 43/21 55/3)
72/9 83/16 144/11
151/9 177/16 177/16
external [19] 19/15
19/22 20/20 21/8
21/25 50/25 76/13
91/17 99/17 104/13
104/14 104/15 140/20}
146/1 146/25 179/25
189/13 195/4 198/6
externally [2] 189/13
189/21
extra [2] 103/25
105/11
extracted [1] 139/18
extraction [2] 142/25
143/4
eyebrows [1] 158/25
F
facilitate [6] 46/19
75/13 92/4 97/24
150/21 158/8
facilitates [1] 79/8
facility [4] 61/21
facing [2] 12/25
13/15
fact [21] 6/19 26/24
32/23 51/14 59/23
62/3 72/25 79/17
118/5 146/15 152/8
170/9 182/11 192/4
192/15 193/6 193/15
197/2 200/24 205/25
206/24
fact-finding [1] 26/24I
factor [3] 81/1 127/5
127/16
factors [3] 75/22
140/17 141/4
facts [1] 60/21
factual [2] 168/18
185/22
failed [1] 41/4
failing [1] 121/25
failings [3] 6/20 6/20
185/1
failure [3] 157/19
182/17 207/16
failures [1] 40/9
fair [5] 132/8 132/15
132/16 172/19 197/25]
fairer [1] 57/17
fairly [2] 54/24 194/9
fairness [3] 46/18
54/20 102/15
faith [1] 121/7
fall [1] 17/17
falls [3] 6/23 134/12
165/11
false [5] 40/23 66/1
66/11 135/14 171/14
familiar [4] 10/15
10/23 60/6 167/25
family [1] 55/19
far [16] 12/1 12/20
19/8 28/3 44/12 52/8
68/18 96/10 105/9
118/18 128/22 129/6
132/13 174/10 187/5
187/13
farmed [1] 20/20
farming [1] 20/23
fear [3] 43/17 43/18
64/23
fearfulness [1]
163/21
feasibility [1] 157/13
February [6] 5/17
69/17 115/10 117/21
170/6 179/12
fed [2] 69/13 175/16
feedback [12] 14/16
29/18 35/16 36/10
36/12 36/20 120/9
177/14 177/25 178/6
178/13 205/22
feel [9] 19/21 32/13
88/8 105/5 153/9
164/14 164/14 179/1
205/4
feeling [2] 112/22
119/13
felt [6] 108/7 108/9
109/2 109/3 120/11
182/4
(64) establishment... - felt
F
few [6] 54/16 78/19
118/1 123/10 157/12
197/20
fewer [1] 23/16
fields [1] 181/21
figure [4] 66/16 68/6
85/5 85/11
figures [3] 66/9
66/25 199/23
file [7] 41/25 42/2
42/7 126/4 166/7
187/17 187/23
filing [1] 187/22
ers [1] 63/1
final [16] 1/20 2/4
2/25 3/19 3/20 4/19
26/18 56/25 89/20
105/20 118/2 123/10
170/13 170/18 179/11
205/2
finalised [3] 173/7
177/19 180/14
Finally [1] 190/8
financial [27] 7/11
15/18 16/1 16/11
19/10 56/6 56/14
65/17 72/1 72/7 72/11
76/12 76/16 76/18
77/8 77/19 88/21 93/7
93/25 101/15 101/17
103/10 124/12 124/17)
124/20 192/9 208/8
find [4] 111/8 162/4
187/23 188/3
finding [3] 26/24 77/5]
170/9
findings [10] 23/24
24/2 117/8 127/8
131/13 132/9 136/9
185/4 187/1 207/8
finds [1] 6/19
fine [8] 4/9 4/10 22/5
58/14 62/14 173/23
175/6 206/14
firm [6] 20/2 20/4
21/9 22/1 22/1 96/17
firms [13] 19/12
19/15 19/19 19/23
19/23 19/25 19/25
20/20 104/15 105/6
105/7 189/14 189/14
first [47] 1/14 1/16
2/11 5/19 8/1 9/8
10/14 21/23 25/13
26/21 27/18 27/20
28/19 31/4 45/19
48/23 56/6 73/15 75/3)
79/25 107/7 107/10
115/13 128/1 128/16
134/3 137/4 137/10
137/11 141/25 142/12)
146/24 154/18 169/8
171/25 174/3 176/10
178/4 179/11 179/20
183/14 188/24 190/9
191/2 199/16 206/19
207/10
Fiscal [1] 208/9
fit [2] 111/8 207/15
fits [1] 41/3
five [4] 156/13
174/17 185/5 191/4
fixed [2] 104/7
105/15
fixed-term [1] 104/7
flagged [1] 124/6
flavour [1] 89/14
flawed [2] 108/10
144/11
flex [2] 94/4 99/2
flexes [1] 98/24
flowchart [1] 109/19
flush [1] 173/13
Foat [12] 22/18 33/6
91/15 161/24 175/17
175/20 175/25 176/11
176/15 176/16 176/19)
209/4
focus [11] 22/10 28/7
T7IN7 87/12 87/16
89/14 123/9 131/8
181/13 183/9 185/17
focused [3] 28/9 87/2
142/17
focusing [1] 23/22
fold [1] 107/7
folded [1] 32/2
follow [6] 31/1 37/20
40/9 40/21 62/17
177/16
followed [4] 27/15
92/13 140/4 197/11
following [10] 7/8
8/13 40/5 69/8 75/2
106/22 115/17 206/10)
207/1 209/16
follows [3] 70/1
141/10 147/25
footed [1] 85/18
footnoted [1] 151/22
footnotes [1] 2/8
force [6] 34/12 44/5
83/12 153/17 153/18
159/17
forces [8] 79/23
134/15 139/5 196/1
196/12 200/1 200/19
201/14
forensic [1] 150/9
foresee [2] 61/18
61/20
forever [1] 64/25
foreword [1] 45/10
forget [2] 59/25 60/7
form [18] 22/3 35/13
42/1 48/15 56/3 69/16
80/16 97/22 115/11
128/19 133/5 133/11
133/14 133/15 141/23
151/23 164/12 180/15}
formal [2] 29/9
203/23
formalisation [1]
43/16
formally [6] 29/19
53/23 60/9 65/22
65/24 116/2
format [4] 81/6 162/5
166/1 167/5
formed [5] 82/13
90/16 130/4 142/7
164/15
former [6] 7/2 12/10
12/12 77/6 152/21
171/2
formerly [1] 5/14
forming [1] 77/24
forms [1] 53/6
formulate [1] 63/7
formulated [2] 64/3
179/20
formulating [1] 62/18}
forward [11] 29/16
64/24 81/19 96/13
146/12 154/2 156/20
159/17 159/25 160/6
181/17
forwarding [1] 91/23
forwards [1] 80/3
found [9] 95/19 128/7I
129/5 132/23 141/16
151/25 184/21 204/25}
206/12
foundation [1] 73/17
four [2] 71/24 76/10
fourth [2] 144/18
192/11
frame [4] 150/17
151/15 155/6 155/18
framework [3] 31/16
31/16 152/12
frankly [1] 197/7
Fraser [5] 128/7
128/11 128/16 128/24
131/13
Fraser's [1] 126/21
fraud [16] 28/14
56/14 56/18 66/1
66/11 80/18 83/13
83/13 83/16 88/20
99/6 113/11 135/14
147/21 153/17 153/18
frauds [1] 97/17
freezes [1] 155/9
frequency [1] 155/21
frequent [1] 21/5
frequently [1] 19/20
fresh [2] 95/16
171/24
friend [1] 51/4
front [1] 35/1
FUJ00243192 [2]
122/25 125/25
FUJ00243199 [1]
134/7
FUJ00243203 [1]
118/19
FUJ00243204 [1]
144/14
FUJ00243299 [1]
157/8
FUJ00243303 [1]
147/10
FUJ00243304 [1]
151/25
Fujitsu [88] 30/13
117/19 117/23 118/1
118/1 118/3 118/9
118/13 118/14 118/17]
118/20 119/1 119/11
119/20 119/24 120/5
120/12 121/5 121/6
121/16 125/20 126/11
126/13 126/15 133/3
133/9 134/15 134/21
134/25 135/9 135/10
135/22 136/4 136/23
137/19 140/10 140/12}
144/16 144/17 144/23}
145/4 145/12 146/17
147/11 147/17 147/25
148/3 148/6 148/9
148/18 149/2 149/5
149/15 150/6 150/12
150/18 150/20 150/23}
151/11 151/15 151/21
157/3 157/12 158/7
159/3 172/3 174/13
174/24 195/21 196/1
196/2 196/4 196/5
196/7 196/8 196/9
196/11 196/14 196/15)
196/22 197/7 197/17
197/21 198/2 198/10
198/24 200/8 200/16
Fujitsu's [1] 150/3
fulfilling [1] 86/7
full [7] 1/10 19/15
75/16 95/3 113/25
207/1 207/6
full-time [1] 19/15
fully [3] 56/18 152/18
167/18
function [11] 10/2
25/8 27/12 27/17
43/13 73/22 78/9
93/20 94/3 185/9
190/12
functioning [1]
154/20
functions [3] 78/9
78/12 188/20
fundamentally [1]
196/17
funding [13] 93/10
94/12 94/23 99/18
100/2 100/3 100/5
103/2 103/13 103/18
104/20 104/22 105/2
funds [6] 72/22 72/25]
78/22 79/1 86/5 99/5
funnel [1] 54/4
further [21] 11/6
35/18 43/6 107/20
123/2 126/2 127/7
127/11 127/13 128/24)
129/21 130/24 144/2
144/23 149/2 150/1
154/25 159/6 168/8
172/19 192/14
furthered [1] 90/1
future [7] 24/23 49/6
49/17 94/2 101/16
107/13 142/7
G
gather [1] 82/2
gathered [1] 52/1
gave [1] 169/24
GE [2] 78/5 192/8
general [8] 20/12
22/16 49/8 49/20
79/25 88/2 96/23
149/11
generally [4] 50/5
64/8 78/7 201/1
generate [2] 95/5
95/11
generated [2] 42/16
1652/2
generating [1] 128/9
genesis [1] 142/24
Gentle [1] 73/20
genuinely [1] 144/10
get [19] 29/12 31/13
39/8 43/8 55/25 60/12!
65/6 83/1 94/15 104/2I
104/22 104/22 108/11
1414/1 118/13 120/3
134/8 166/24 170/6
gets [1] 43/6
getting [2] 28/5
162/17
GICLEP [3] 33/23
34/16 204/6
GIP [2] 33/11 34/2
give [16] 1/10 10/9
31/24 41/22 42/10
50/3 89/14 139/25
140/18 141/7 158/12
170/13 173/23 190/8
192/10 204/21
given [19] 12/6 29/17
29/18 38/18 57/20
87/17 93/13 119/17
122/1 158/10 174/12
183/11 184/4 195/22
198/5 200/1 200/3
(65) few - given
G
given... [2] 200/14
204/10
gives [1] 73/19
giving [4] 44/7 173/8
209/4 209/6
GLO [1] 37/8
Gloucestershire [1]
133/11
go [41] 15/11 16/7
16/8 31/18 35/20 36/6
40/3 51/17 56/25 65/4}
65/5 68/1 70/21 74/18
84/1 85/25 105/1
105/6 105/8 105/20
106/1 109/6 110/15
111/25 123/1 125/25
146/12 153/6 165/8
174/10 187/6 187/22
192/3 194/12 201/4
201/5 201/14 204/17
205/12 205/13 205/15
goes [12] 8/11 12/20
51/4 59/3 86/9 98/9
98/9 140/22 140/23
171/13 193/25 196/13
going [61] 1/5 17/22
23/25 24/1 28/24 30/3
30/21 31/8 31/12
35/10 38/18 41/21
50/18 50/21 52/12
52/18 53/16 61/19
64/25 74/15 81/18
89/13 96/2 96/3 104/9
106/3 108/14 111/23
113/5 118/21 122/12
126/16 137/18 137/19
143/3 146/13 146/13
154/2 154/10 154/14
154/23 156/20 157/1
157/8 158/12 158/21
160/6 172/18 174/18
178/3 180/19 181/12
185/17 187/13 188/8
191/6 191/10 194/6
194/8 197/16 203/5
golden [2] 134/16
134/18
gone [3] 32/12 35/7
119/5
good [15] 1/3 1/4
70/17 79/7 84/2
111/21 111/22 112/17)
114/3 160/6 193/5
202/13 206/16 208/22
209/12
got [15] 21/18 27/3
59/14 60/4 68/14
103/23 105/2 172/9
172/16 184/18 198/1
198/4 199/10 199/23
205/2
governance [5]
25/22 35/21 36/7
138/15 139/15
governing [1] 137/24
government [8]
78/21 78/22 79/15
79/19 80/2 113/14
129/10 180/2
government's [1]
129/13
government-linked
[1] 79/19
government-owned
[2] 78/21 80/2
graduate [2] 7/18
131/19
grappling [1] 62/2
grateful [1] 119/19
Gray [18] 8/8 8/9
22/15 22/24 33/6 73/7
84/13 84/19 85/19
86/4 88/19 89/22
92/16 100/9 101/14
143/19 176/20 176/21
Gray/John [1] 143/19
great [5] 23/25 135/1
152/18 178/11 205/8
greater [1] 27/16
grievance [1] 26/22
grounds [1] 209/6
group [62] 6/18 8/3
8/6 20/9 20/13 20/14
20/16 22/21 27/11
27/14 33/11 33/22
34/19 37/1 44/1 46/6
47/8 63/19 68/24 69/3
74/16 74/19 75/1
77/23 79/10 84/10
84/10 84/20 85/21
91/22 92/7 92/13
92/24 93/2 93/6 100/8)
101/23 103/3 103/4
103/9 103/17 108/7
109/2 109/3 109/7
109/16 115/17 137/22)
138/5 143/14 160/23
161/4 163/13 173/10
177/1 179/15 179/21
179/23 181/13 184/4
191/19 191/21
group's [1] 32/10
groups [5] 35/7 35/9
109/1 182/2 182/16
guarantee [1] 84/7
guess [3] 42/7 43/1
52/8
guidance [11] 30/25
38/17 40/17 44/20
44/24 46/2 46/15 50/3
54/11 164/19 164/23
guide [1] 44/9
guided [2] 188/21
188/22
guidelines [2] 49/21
50/2
guides [3] 44/21 45/6
45/14
guilt [1] 77/5
GUILTY [1] 175/18
H
had [65] 9/16 11/4
11/11 11/13 28/25
29/7 30/16 32/12
35/17 36/10 36/12
37/24 38/6 43/12
43/14 45/23 55/10
55/20 77/12 83/15
85/3 86/1 88/20 91/5
91/17 94/11 100/1
102/14 102/18 102/23
103/3 104/7 116/16
119/10 126/2 126/9
127/13 144/24 146/19}
148/19 150/25 152/6
154/20 159/22 164/1
164/9 164/10 167/1
167/2 170/21 177/1
177/3 177/5 177/17
179/4 189/6 190/3
190/13 194/17 197/18}
200/2 201/17 205/16
208/5 208/10
hadn't [3] 122/23
169/1 183/18
half [4] 15/7 21/11
22/10 28/18
halfway [2] 75/18
164/11
Hall [4] 11/2
Hamilton [4] 37/1
37/9 129/21 129/23
hand [9] 11/3 22/11
25/14 60/22 132/1
132/7 132/12 173/3
173/19
handed [2] 91/1
187/17
handle [1] 141/6
handling [1] 106/9
handrail [1] 44/25
hang [1] 198/23
happen [8] 13/13
17/21 17/22 30/8 75/6
147/6 162/16 194/8
happened [6] 21/22
36/9 78/2 164/16
166/22 180/21
happening [5] 59/24
62/13 129/1 175/23
191/25
happens [4] 18/17
52/23 141/3 161/6
happy [4] 36/15
103/6 161/24 206/3
harassment [2]
89/16 89/17
harm [2] 72/4 136/17
has [129] 2/18 4/3
4/9 4/17 8/23 8/24 9/2)
12/11 12/18 14/17
15/5 16/7 17/5 23/14
26/24 34/12 35/7
35/25 43/3 43/8 43/14
43/21 44/5 44/17
51/19 55/18 55/19
55/22 55/23 56/21
57/20 57/23 59/10
59/12 60/1 60/8 66/16)
68/5 68/19 71/3 71/10)
73/18 74/1 74/10 76/6)
76/9 78/14 78/17 79/6
80/6 81/13 83/6 86/4
94/22 94/22 100/15
105/8 111/2 113/20
114/2 115/20 116/24
117/2 118/8 119/5
119/9 119/16 123/19
125/21 127/23 129/17
131/18 133/17 133/18}
134/18 140/13 141/13}
144/23 147/16 148/14}
148/19 149/3 150/5
150/13 150/16 150/25}
152/23 154/4 154/16
154/17 163/11 163/13
166/18 166/19 172/12}
172/25 173/4 173/6
176/2 176/5 176/15
177/14 177/13 17715
179/17 179/25 180/21
181/21 184/20 184/24}
187/11 187/18 187/21
190/6 193/10 194/23
195/1 195/22 195/22
196/1 196/9 198/4
201/19 205/9 205/10
208/5 208/7 208/12
209/8
hasn't [5] 71/1 105/9
1119/2 111/3 111/5
have [311]
haven't [12] 3/17
32/4 32/6 52/8 83/19
90/14 118/18 147/7
164/18 198/24 199/3
200/13
having [18] 16/4
45/19 51/18 56/21
61/15 79/4 87/22 91/2
98/18 99/15 100/14
113/15 121/7 141/7
146/22 161/18 164/10}
178/7
he [60] 10/25 11/4
11/8 11/11 14/6 14/10)
14/13 14/14 14/16
14/17 14/21 14/23
30/15 36/11 36/11
87/11 90/16 90/25
114/19 115/3 128/7
128/21 132/14 134/1
134/2 135/4 153/21
160/19 162/1 164/1
164/12 165/24 166/12)
166/18 166/19 168/14)
168/14 168/20 169/11
169/13 169/13 169/17
169/25 173/7 175/17
176/6 176/11 176/12
176/12 181/11 191/3
194/18 195/17 195/24I
200/21 200/22 200/22!
203/17 203/20 206/11
he's [8] 30/16 30/17
36/19 119/1 131/24
131/25 153/20 164/14)
head [9] 5/18 7/22
48/4 58/6 69/16 89/11
155/18 162/3 163/8
headcount [1]
105/10
heading [1] 78/18
heads [1] 15/13
health [1] 209/6
hear [1] 1/5
heard [12] 8/19 9/10
20/19 43/17 90/7
95/13 150/5 193/2
193/8 194/15 197/5
204/23
hearing [1] 209/16
Hearings [3] 183/13
183/16 183/20
heat [1] 60/8
held [3] 49/12 80/5
126/13
Hello [1] 202/15
HELM [1] 175/20
help [9] 45/15 47/5
48/20 51/2 70/16
120/15 123/2 157/6
194/24
Helpdesk [1] 182/15
helpful [4] 62/16
72/19 183/2 205/19
helpline [2] 90/21
90/23
Henderson [1] 11/2
Henry [1] 108/21
her [5] 22/2 71/10
147/24 170/20 206/20}
here [17] 13/21 23/13]
50/11 54/11 54/13
TAI5 75/1 96/5 97/7
98/12 135/2 145/7
145/22 156/6 167/4
173/8 176/4
hereby [1] 103/15
hiatus [1] 109/8
hierarchy [2] 71/8
80/1
high [10] 18/7 20/17
21/24 25/23 67/22
89/9 124/11 141/12
141/13 168/6
high-risk [3] 18/7
(66) given... - high-risk
H
high-risk... [2] 20/17
25/23
higher [2] 44/7 71/16
highest [2] 45/15
71/15
highlighted [5] 27/25
123/19 124/8 124/13
167/20
highly [3] 106/23
131/11 168/19
HlJ [1] 114/23
him [8] 36/18 166/24
169/11 176/20 203/17)
204/20 204/21 209/10
hiring [1] 106/23
his [24] 8/17 8/18
14/20 89/22 90/9
90/15 161/14 166/23
167/1 169/16 170/13
175/24 175/25 176/1
176/5 176/22 193/4
203/6 203/19 203/20
204/20 205/1 209/6
209/7
historic [3] 19/2
180/23 183/19
historical [1] 112/18
historically [1] 19/6
history [5] 50/17 62/3
70/25 88/8 118/21
hm [11] 9/11 43/20
62/25 74/22 152/24
165/3 165/23 180/12
199/1 199/20 200/17
HMRC [2] 14/22
30/19
HNG [9] 106/15
109/22 128/4 128/13
128/19 129/1 129/16
140/14 140/19
HNG-A [8] 106/15
128/4 128/13 128/19
129/1 129/16 140/14
140/19
HNG-X [1] 109/22
hold [4] 115/20
182/11 192/21 193/16}
Holmes [2] 11/1 11/9
honest [4] 85/20
155/7 164/12 164/14
honestly [1] 80/5
honestly-held [1]
80/5
hope [1] 148/5
hoped [1] 180/22
hopefully [2] 83/21
192/19
hopes [1] 127/17
hoping [2] 29/21
180/15
HORice [1] 143/1
Horizon [109] 8/3
30/2 30/2 30/12 30/21
30/22 30/24 31/4
37/12 40/24 89/23
106/9 106/15 109/22
110/6 110/15 111/7
111/24 112/14 114/12)
114/25 116/8 116/9
116/12 117/15 117/17)
118/3 118/14 119/14
122/6 125/5 125/19
125/22 126/9 126/10
127/5 127/21 128/4
128/6 128/8 128/10
128/18 128/23 129/3
129/20 129/25 130/3
130/7 130/11 130/18
130/20 131/2 131/3
131/5 131/11 133/2
133/8 133/20 133/23
134/9 134/11 136/5
139/6 139/8 139/21
140/3 140/9 140/14
140/19 141/12 141/14)
141/15 141/19 144/3
144/8 144/11 144/23
145/1 145/4 147/2
148/2 148/5 148/8
148/11 148/19 149/12)
149/17 149/24 150/16)
150/21 150/23 152/2
154/8 154/25 157/11
157/14 157/18 158/6
158/21 159/2 159/12
159/18 159/20 171/20,
173/16 174/9 196/16
202/4 202/17
Horizon-based [1]
139/6
hours [5] 168/16
168/22 169/1 169/2
209/3
house [1] 126/22
how [67] 7/19 19/10
20/17 21/2 27/5 30/2
30/3 30/8 30/21 31/8
37/4 37/17 38/1 38/10
38/17 39/24 40/13
40/19 41/7 45/6 45/9
49/21 52/12 55/8
55/14 60/2 60/15
67/10 68/4 81/9 81/12
85/5 90/16 94/15 97/7
101/9 104/17 107/15
108/22 109/19 109/20)
110/4 110/18 112/25
113/8 119/6 120/22
144/8 147/5 157/1
163/2 163/17 163/19
164/19 176/3 177/10
178/21 179/18 179/20}
182/16 188/15 188/20)
190/25 204/5 205/3
205/18 206/3
however [12] 12/17
63/8 63/24 76/7
101/15 112/13 114/3
127/4 136/1 142/11
162/14 178/12
HR [1] 188/18
huge [1] 62/12
Hughie [1] 11/14
human [5] 180/4
183/13 183/15 183/20}
185/19
hurdle [1] 134/8
Hutchings [1] 11/15
hypothesis [2] 37/22
40/22
hypothetically [1]
102/20
l acceded [1] 209/5
laccept [1] 163/5
l agree [2] 61/5
152/15
also [2] 8/10 8/10
lam [8] 17/13 118/9
135/5 160/20 163/8
168/3 168/12 209/6
l appreciate [2] 32/4
173/14
lask [4] 1/15 1/20
2/22 202/13
l assume [2] 207/4
207/12
l attended [1] 84/16
l await [1] 167/18
I believe [17] 11/21
13/12 14/21 18/22
66/13 73/1 85/6 87/20
90/24 97/11 119/1
123/7 143/1 153/20
169/20 172/10 178/25)
lean [11] 14/18
21/17 22/14 32/9
32/10 32/13 60/12
63/15 105/16 156/5
170/14
I can't [4] 65/15
65/15 92/10 170/17
I certainly [1] 90/14
I completely [1] 62/1
I considered [1]
203/21
I contributed [1]
207/18
I could [2] 48/20
120/12
I couldn't [1] 10/3
I did [4] 8/4 73/9
73/24 137/7
I didn't [5] 90/13
104/2 110/11 155/6
162/16
Ido [1] 168/2
I don't [55] 10/17
13/18 13/19 14/24
17/23 17/24 19/11
22/18 29/14 34/12
35/19 56/9 56/23 58/1
58/5 67/24 67/25 71/4
78/5 81/15 81/21
84/15 85/6 96/4 98/4
98/7 100/5 100/13
104/8 113/2 126/12
131/24 144/9 147/8
147/15 152/6 154/23
155/18 155/18 155/21
156/3 162/24 168/24
170/14 170/14 176/14}
181/7 183/21 188/10
191/9 192/3 195/17
198/6 198/6 206/22
l explain [1] 187/22
l explained [1]
161/24
I feel [2] 32/13 88/8
I felt [1] 120/11
Ifind [4] 1141/8
I first [1] 154/18
I guess [3] 42/7 43/1
52/8
Thad [2] 150/25
152/6
Ihave [22] 4/4 7/11
TINT 7/18 8/18 9/24
12/9 30/5 35/8 61/14
77/10 77/12 96/18
96/21 129/5 160/21
169/11 191/16 191/18)
194/15 208/25 208/25
I haven't [4] 3/17
90/14 147/7 200/13
Ihelp [1] 123/2
I hope [1] 148/5
l imagine [2] 17/23
58/8
joined [1] 13/18
I just [6] 62/17 78/6
171/19 171/23 176/15}
202/21
I know [7] 12/3 13/20
44/16 56/23 60/4
63/13 114/13
I made [1] 86/25
I may [3] 57/13
118/16 171/22
I maybe [1] 183/22
I mean [9] 49/16 52/6
60/5 60/25 68/1 70/8
71/1 97/2 190/25
I mentioned [3]
46/13 99/23 105/12
Ineed [1] 120/23
I please [2] 2/25 4/25
I probably [1] 137/11
I propose [1] 191/8
I raised [1] 61/1
referred [1] 113/18
I remember [1]
154/18
I report [2] 23/8
71/11
l reported [1] 176/20
I represent [2]
191/21 206/17
l respectfully [1]
166/13
Iright [7] 15/10 15/21
16/20 22/20 68/9
7417 179/13
I said [1] 150/22
I saw [2] 115/13
147/15
I say [3] 21/20 71/1
144/9
I spoke [1] 153/19
I started [1] 81/13
I stitched [1] 126/20
I take [3] 58/5 172/1
182/5
I they [1] 52/14
I think [160] 3/3 3/19
4/3 7/8 7/15 8/23 9/2
9/15 10/17 12/3 13/5
14/9 17/10 17/10
17/14 21/17 23/16
23/19 25/5 27/8 27/18
28/7 28/18 32/10
32/13 32/23 35/14
35/24 38/2 40/20
40/25 41/2 41/14 42/5)
42/15 43/23 43/23
44/6 44/25 49/8 51/16)
54/1 55/10 57/24 58/8
59/14 60/17 61/11
61/17 61/24 62/7
62/20 63/10 63/15
65/25 66/3 67/2 68/6
68/12 68/21 70/23
73/3 76/24 78/15
79/25 81/20 86/2
87/23 88/4 89/21
95/16 96/1 96/16
96/18 98/2 98/6 98/24}
100/5 101/13 101/19
104/7 104/25 105/16
108/2 108/4 108/6
108/7 109/2 111/5
4112/2 112/9 113/17
113/19 113/21 113/22)
114/11 114/20 114/25)
115/13 116/11 116/21
1418/2 118/8 118/19
123/2 123/12 131/23
131/25 132/13 132/16)
134/10 135/19 136/21
136/24 137/11 138/20)
141/25 144/5 147/18
147/24 153/23 153/24I
153/25 154/11 154/13}
154/16 154/21 156/21
158/24 158/25 159/21
160/2 160/3 160/5
162/17 162/24 166/22!
(67) high-risk... - I think
I think... [23] 167/11
168/18 169/2 169/5
169/22 171/11 172/9
182/5 183/21 183/24
184/15 185/5 186/18
186/21 189/15 193/3
194/18 197/25 199/16
202/25 205/22 208/16
208/22
I tried [1] 187/25
Itry [1] 187/20
l understand [10]
9/17 13/1 14/2 16/12
54/3 60/1 61/19 72/13
152/12 200/8
I understood [1]
62/22
I want [4] 23/22
111/25 169/10 209/2
I wanted [1] 173/13
Iwas [15] 7/20 7/22
25/6 28/8 57/15 57/17
57/24 59/4 74/5 74/5
77/11 88/4 88/5
100/13 112/24
I wasn't [5] 32/19
110/11 114/15 182/13}
194/19
I will [3] 119/2 119/22)
209/12
I would [15] 9/6 21/4
22/22 34/17 38/6 61/3
65/1 68/6 88/7 150/22
160/24 161/24 171/2
197/13 205/15
I wouldn't [4] 15/4
32/19 61/24 155/24
I'd [20] 7/24 22/6
33/7 36/23 37/3 46/13,
56/4 65/4 65/21 68/24
73/12 78/19 95/1
112/7 117/13 131/8
160/11 174/15 179/1
188/23
lll [13] 24/13 74/2
123/21 124/3 135/2
137/18 160/11 160/14
168/1 172/24 191/8
195/18 204/6
I'm [67] 10/17 10/19
13/18 16/3 17/22 18/4}
19/9 21/10 23/25
29/21 32/9 32/10
32/19 35/14 44/14
49/16 49/20 55/6 58/1
59/3 60/5 61/6 66/23
67/24 68/8 68/10
72/13 96/16 100/13
100/25 106/3 111/23
113/18 118/18 118/21
122/24 126/12 126/16)
127/16 137/5 137/18
146/18 155/7 157/8
159/16 160/3 170/17
172/14 172/23 173/17)
178/2 183/1 185/16
191/6 191/10 192/4
194/7 194/15 197/16
199/14 203/5 203/6
204/5 204/16 205/17
206/9 208/7
I've [19] 13/4 13/21
21/17 25/8 25/11
35/17 36/10 36/12
36/19 57/18 73/1
104/7 140/23 147/24
163/24 172/9 177/12
198/9 205/2
IB's [1] 79/11
idea [6] 70/19 85/11
95/14 95/16 193/5
193/6
identified [16] 36/25
37/2 56/11 56/17
56/20 56/22 57/4 85/4
141/15 149/3 152/3
152/23 185/1 186/3
186/9 195/1
identifiers [1] 143/8
identifies [3] 109/10
155/3 185/5
identify [5] 38/24
108/22 116/1 164/5
199/22
identifying [1] 17/11
identity [2] 4/22
179/9
ie [3] 19/18 172/22
174/21
ie availability [1]
19/18
ie Post [1] 172/22
ie the [1] 174/21
if [193] 2/2 3/9 10/13
10/18 10/21 11/24
16/9 17/8 17/22 18/17
20/8 22/8 22/9 23/12
23/18 23/20 24/12
25/20 27/5 27/18
29/10 31/2 34/20
37/16 38/1 38/6 38/8
38/11 38/18 39/18
39/24 39/25 40/13
41/14 41/19 42/21
45/9 45/25 47/16
48/20 49/17 52/13
52/21 52/23 56/12
57/2 57/6 57/13 60/12
64/10 64/25 68/15
69/6 70/14 71/2 71/13
71/20 73/11 73/11
74/25 75/15 78/20
79/19 80/11 80/16
80/23 81/8 82/1 84/17
85/13 85/16 88/4
88/17 91/4 92/19
93/17 95/1 95/18 96/4
96/8 99/4 100/15
100/19 100/23 101/7
102/20 102/22 103/22
105/24 106/1 108/14
109/6 110/5 110/7
111/9 111/25 112/4
113/3 113/5 113/24
114/16 115/15 116/25
117/8 117/21 117/21
118/11 118/16 118/17
119/19 120/11 121/16
125/5 125/16 125/25
126/16 127/5 128/1
129/4 131/8 131/10
132/18 132/21 133/4
133/13 134/19 134/20
134/21 134/23 136/16
138/10 139/2 140/8
140/13 144/9 146/8
147/25 149/19 151/7
155/1 155/7 155/8
155/22 155/25 156/3
156/12 157/4 157/5
157/11 160/2 160/3
160/8 162/1 162/11
162/18 164/14 164/14)
164/22 164/25 165/4
165/8 165/18 166/11
167/7 167/13 167/24
168/14 168/20 169/1
170/16 171/22 172/8
172/13 172/17 173/25}
174/22 175/13 175/13
175/18 175/23 178/21
179/1 179/2 181/1
182/21 185/13 187/13
188/8 196/21 201/22
205/12 205/15 207/21
ii [2] 157/24 204/3
imagine [3] 17/23
58/8 187/25
immediacy [1]
121/11
immediately [2]
200/18 201/6
imminent [2] 180/18
180/19
imminently [1]
159/25
impact [11] 97/9
123/8 146/15 157/20
158/10 182/1 182/17
183/13 183/15 183/20
185/19
impacts [1] 123/5
implementation [3]
27/20 106/22 115/23
implemented [3]
32/6 43/22 65/3
implementing [1]
28/3
implications [1]
44/20
imply [1] 122/17
important [9] 42/15
61/17 91/15 119/3
120/22 128/11 130/7
195/8 205/4
importantly [1]
142/15
impossible [1]
120/22
impression [4]
119/16 122/1 174/8
183/21
improvement [1]
26/9
improvements [1]
6/7
inaccurate [1]
109/24
incident [1] 10/2
inclined [1] 81/3
include [4] 39/2 42/2
49/14 80/18
included [4] 37/13
68/12 141/23 183/8
includes [5] 75/19
76/2 116/8 123/20
191/21
including [13] 23/13
23/17 23/18 24/24
37/21 40/10 57/4
75/24 109/11 112/10
145/3 157/25 166/4
inclusion [1] 31/14
inconclusive [1]
119/12
increase [9] 88/20
88/25 95/9 101/14
105/10 105/17 105/19)
112/10 124/7
increasing [2] 101/4
157/19
increasingly [2] 78/5
158/2
incredibly [1] 85/24
indeed [3] 49/9 136/9
199/21
independence [2]
84/6 127/2
independent [12]
3/13 76/12 88/9 114/3I
130/1 135/23 148/12
150/9 150/15 174/13
174/25 196/8
index [2] 2/14 188/2
indicate [1] 135/7
indicated [1] 125/5
indication [1] 172/17
indicative [1] 32/24
indirectly [1] 119/13
individual [12] 15/22
16/19 20/3 24/1 72/24}
121/18 147/22 158/14}
158/14 178/17 179/19}
190/12
individuals [11]
11/17 12/5 12/15 13/9)
18/25 24/20 32/17
56/19 76/3 184/12
199/21
induction [4] 7/25
8/5 8/11 8/21
influence [1] 127/2
informal [1] 84/2
information [47] 36/4I
37/23 38/8 38/17 40/2I
51/25 52/7 53/21
55/16 56/2 81/10
91/19 93/25 109/13
119/10 124/18 127/17)
130/13 131/16 137/25]
138/16 138/18 138/19)
139/7 139/21 140/2
142/10 146/18 146/20)
148/13 151/3 165/15
165/22 167/10 167/14)
169/25 172/19 172/21
182/10 189/11 189/17)
192/2 192/22 193/7
193/16 194/23 203/17)
informed [4] 119/9
190/15 193/19 196/1
infrastructure [3]
157/18 157/19 157/23)
inherently [2] 90/5
90/17
inhouse [5] 59/8
130/13 131/17 138/17)
139/24
initial [1] 73/9
initially [2] 105/11
124/6
initiating [1] 53/10
initiation [1] 185/20
innocent [2] 145/2
175/19
input [10] 45/24 65/6
74/25 96/25 97/3
106/4 177/1 177/3
17715 177/24
inputted [1] 58/4
inquiry [46] 1/14 8/2
8/14 8/19 9/10 10/24
11/4 11/11 11/13 12/3}
12/11 21/3 21/18
23/25 37/21 40/10
40/17 40/21 74/10
78/4 117/25 134/3
134/5 135/1 136/10
137/6 137/7 147/13
148/15 149/3 150/6
175/24 176/1 178/2
179/4 180/24 182/9
183/11 183/23 184/10)
187/6 190/15 190/15
195/22 197/7 203/3
Inquiry's [3] 2/19
4/18 159/8
insisted [1] 208/9
(68) I think... - insisted
insofar [3] 22/25
83/5 176/22
installed [1] 127/24
instance [6] 21/24
31/4 45/23 66/4 142/1
205/6
instances [2] 56/17
128/25
instigated [1] 17/8
institutions [1] 80/3
instructed [3] 22/2
56/23 190/13
instrument [1] 176/1
insufficient [1] 37/23
insurance [1] 78/15
integral [1] 193/11
integrity [2] 45/16
99/4
intelligence [3] 16/1
30/18 139/22
intend [1] 168/2
intended [4] 46/2
46/4 73/21 109/19
intending [1] 197/11
intent [5] 49/2 70/15
147/3 147/9 201/8
intention [3] 95/3
98/1 133/22
interact [5] 10/4
13/11 90/13 162/25
188/20
interacting [2] 11/20
12/5
interaction [1] 99/7
interest [2] 164/25
165/1
interested [2] 146/12
153/10
interests [2] 80/11
151/18
interim [3] 22/16
96/23 153/20
internal [13] 42/2
42/2 55/3 55/7 56/14
56/18 79/9 100/22
117/9 184/4 184/7
193/16 194/4
internally [1] 50/22
International [1]
180/3
interpretation [2]
30/2 200/21
interpreted [1] 121/5
interrogate [1] 30/22
interrogation [2]
203/21 204/19
interrogatory [1]
203/24
interrupt [1] 68/8
interview [71] 39/2
46/24 47/7 47/10
47/23 48/13 48/17
49/22 49/23 50/15
51/9 51/10 51/12
51/17 52/15 52/16
52/24 52/24 52/25
53/23 58/25 59/11
59/13 59/15 59/24
60/3 60/10 60/18 61/4
61/9 61/12 61/12
61/22 64/10 81/9 82/1
160/24 161/2 161/5
161/6 162/2 162/6
162/18 162/22 162/23)
163/2 163/16 163/18
165/6 166/25 168/2
168/9 168/12 168/13
168/15 168/16 168/22)
168/25 169/2 169/18
170/2 202/19 203/10
203/19 203/21 203/23)
203/24 204/16 204/18)
205/16 206/10
interviewed [8] 50/8
50/9 50/18 53/1 53/4
60/9 64/2 125/1
interviewee [1] 46/18
interviewer's [1]
47/15
interviewing [11]
39/13 39/13 39/13
46/16 50/4 51/13
52/18 53/12 63/8
65/14 81/17
interviews [23] 39/5
39/17 46/14 46/16
46/20 46/21 46/22
46/23 48/3 48/5 48/11
48/14 48/25 49/7
54/12 55/1 59/3 59/19
59/21 59/25 61/18
62/5 203/13
into [46] 2/11 6/18
16/19 24/10 30/8
31/17 32/2 36/24
39/11 45/25 51/17
54/13 57/11 58/4
66/11 69/14 70/21
71/8 71/10 71/11 76/8)
84/5 88/11 89/13 93/8
93/14 96/25 98/16
114/18 116/19 121/23)
122/2 124/25 138/11
156/22 160/13 160/22,
161/3 161/13 176/20
176/20 181/15 182/2
183/19 203/12 207/7
introduce [2] 98/14
149/6
introduced [1] 88/11
introduction [2] 46/1
69/10
introspection [1]
32/22
investigate [17] 6/15
17/6 38/7 38/12 38/14
38/15 38/16 49/14
78/23 80/22 80/23
82/9 83/24 86/6 99/6
102/21 188/8
investigated [9]
38/11 38/19 56/18
149/22 150/8 184/13
189/12 199/21 206/11
investigating [9]
15/22 19/7 41/15
48/11 74/10 107/10
156/1 163/11 167/7
investigation [145]
15/14 19/2 19/21
20/16 21/19 21/21
21/24 28/14 32/12
33/22 37/25 38/24
39/12 39/20 41/1
41/20 42/16 42/18
42/21 46/17 46/19
47/1 47/2 47/5 48/8
48/9 48/15 48/15
49/12 50/1 51/21
51/25 55/3 55/7 57/6
57/9 57/10 59/5 59/7
67/6 73/16 73/22 74/3
75/5 75/13 75/19
78/12 79/3 79/9 81/21
81/25 84/8 92/1 92/5
93/20 94/1 97/23 99/3
100/23 105/5 105/7
105/12 106/12 109/7
112/12 112/14 114/2
114/5 114/9 116/3
118/23 120/6 121/12
124/25 127/3 127/7
130/16 135/17 136/2
138/12 142/14 146/14
148/1 148/23 149/2
149/21 150/12 150/13
156/25 160/5 160/13
160/22 161/3 161/9
161/11 161/13 161/17]
162/4 162/9 162/14
163/9 165/12 170/8
170/9 170/13 170/18
170/19 170/23 171/10
171/12 171/13 172/2
174/20 180/5 184/1
185/15 186/14 186/14
186/17 187/11 188/10
189/4 189/7 189/8
189/21 190/3 190/5
190/7 190/17 194/25
199/25 201/5 202/24
203/1 203/2 203/12
203/13 203/18 204/25]
205/7 206/23 206/25
207/1 207/7 208/10
investigations [151]
5/11 5/14 5/21 5/25
6/12 6/23 7/1 7/13
7/22 7/23 9/8 9/14
11/13 12/14 12/19
12/22 14/12 14/15
15/10 16/19 16/24
17/9 18/7 18/8 19/19
20/7 20/15 23/7 24/17,
24/19 25/2 25/15
25/23 26/5 26/9 26/13)
26/15 26/16 26/25
27/14 27/16 28/10
29/1 30/20 31/10
32/25 33/8 33/9 33/11
34/19 37/10 38/23
39/9 39/11 39/25 40/6)
40/16 41/11 42/18
43/2 46/4 46/7 46/10
49/11 51/23 53/4
62/24 63/19 64/21
66/11 69/6 69/10
69/12 70/2 70/4 70/9
70/24 71/17 73/15
74/1 74/4 74/8 75/7
75/9 75/23 76/8 77/25)
78/18 79/11 80/17
83/18 84/13 84/23
85/1 85/25 86/12 91/3)
92/2 93/12 93/14
93/21 94/5 95/6 95/20)
98/11 101/4 106/16
109/9 113/25 135/16
136/7 138/1 138/5
139/7 142/23 143/18
143/23 144/1 150/4
150/22 151/11 160/18}
160/21 169/13 177/9
177/11 177/12 177/14}
179/23 180/23 181/16}
182/2 183/4 185/6
185/10 185/25 186/21
188/19 188/24 196/3
196/10 199/11 199/19}
200/16 200/20 201/6
201/15 202/17 204/10)
204/12 205/14
investigations/passi
ng [1] 143/23
investigative [25] 6/1
6/6 28/11 37/19 37/22
40/22 43/13 46/15
48/13 49/23 74/6
79/24 81/23 93/22
95/7 96/19 97/20
98/13 135/24 138/14
163/13 163/15 164/11
165/11 185/7
investigator [5]
50/24 82/22 84/7
120/12 147/21
investigator's [5]
40/15 44/3 47/11
47/13 63/16
investigators [20]
12/10 12/13 45/1 46/5}
48/2 58/24 61/2 61/21
71/24 76/8 81/4 83/4
98/15 142/18 165/14
175/22 184/5 185/8
195/5 203/14
investigatory [1]
13/1
invited [3] 163/13
177/6 203/18
involve [5] 6/13
11/20 117/15 157/3
190/18
involved [27] 7/13
9/4 11/1 11/8 11/12
11/18 12/21 12/21
12/24 15/22 16/4 18/1
18/11 19/2 19/6 22/1
31/9 45/19 74/9 77/14
96/24 97/12 97/14
124/13 166/24 179/25)
200/1
involvement [8] 17/7
18/20 18/21 88/15
98/20 99/24 177/20
180/1
involves [4] 6/14
6/18 13/3 116/13
involving [3] 61/2
125/7 129/16
10 [1] 48/6
10s [1] 48/5
Ireland [6] 81/6 82/18)
83/20 83/21 91/12
91/13
irrespective [3] 79/6
154/12 156/16
is [707]
Ishaq [1] 11/14
Ismail [7] 175/10
175/15 190/5 202/24
203/6 204/11 204/14
isn't [16] 25/25 39/10
47/3 50/21 56/8 60/11
64/9 64/23 89/4
104/19 122/15 147/18}
149/8 155/25 170/16
202/7
isolated [1] 128/25
isolation [1] 178/14
issue [31] 4/23 23/23
28/1 39/21 45/8 50/21
57/3 58/22 62/19 69/1
102/6 108/15 108/22
110/13 111/24 114/2
121/23 122/9 143/10
143/14 152/5 152/20
156/8 156/24 169/22
170/24 171/21 182/3
182/23 201/7 202/19
issues [47] 8/3 8/12
10/4 16/3 16/4 19/17
29/24 30/23 52/9 54/3I
54/5 54/7 54/18 55/20
67/2 84/5 95/19 95/21
114/13 114/25 115/5
115/18 115/24 116/18)
128/6 128/10 130/21
(69) insofar - issues
issues... [20] 131/3
141/16 146/2 154/8
154/25 155/4 156/10
156/11 157/10 157/12
163/17 163/19 181/24}
184/18 185/11 185/14)
185/19 201/5 201/24
202/21
it [565]
it's [145] 3/19 10/1
10/6 12/4 13/7 13/16
13/20 14/9 17/10
17/24 21/4 21/6 23/19)
25/8 26/1 31/2 31/6
34/7 34/19 35/1 35/4
35/9 35/10 36/23 37/7
37/18 38/8 39/10
39/12 40/14 40/16
40/16 40/20 41/17
43/1 43/9 44/9 44/9
44/14 44/15 44/23
44/23 44/24 44/24
44/25 45/10 45/10
52/17 55/10 56/10
56/13 60/10 60/17
62/7 62/16 63/15
64/21 68/12 68/17
68/21 70/16 73/13
73/25 74/12 88/16
95/16 96/11 97/2 97/4
98/25 98/25 100/5
100/22 100/22 104/25)
105/23 106/2 107/7
110/5 110/13 110/14
110/23 113/23 114/18)
115/9 115/15 118/11
118/24 119/3 121/23
122/8 123/21 125/7
125/25 131/7 131/9
131/24 131/25 132/1
132/5 132/11 132/16
133/24 133/25 136/13)
136/13 143/15 143/16
147/21 152/7 155/2
159/11 160/16 161/6
161/12 163/16 165/5
168/18 171/11 174/22)
177/15 178/1 178/2
178/21 180/18 181/12)
181/12 182/3 182/5
183/3 190/10 192/5
194/12 194/16 194/18)
198/14 198/19 198/24)
199/3 199/4 201/8
201/9 206/7 206/24
208/7
iterations [2] 74/6
129/3
its [27] 24/17 24/23
25/2 35/12 45/14 46/7
73/19 78/9 95/6
106/10 110/22 115/10)
128/19 148/12 151/10)
151/20 152/4 158/5
158/6 173/12 182/10
183/19 186/13 207/6
207/15 207/16 207/17
itself [5] 30/21 73/17
101/8 183/24 183/25
J
Jacobs [20] 36/17
160/13 160/19 161/2
161/18 161/23 165/21
166/20 167/16 169/25)
170/7 170/13 175/15
202/22 204/11 204/15)
204/16 204/17 206/7
206/11
Jacobs' [4] 169/19
203/15 204/25 206/5
JAMES [3] 1/8 1/12
210/2
Janet [1] 11/14
January [8] 75/17
112/4 112/22 114/9
114/17 139/22 140/4
141/19
Jarnail [1] 14/1
JB [3] 100/18 101/2
176/5
Joan [1] 11/15
job [1] 165/14
JOHN [7] 1/8 1/12
84/13 143/19 162/5
163/8 210/2
join [1] 5/19
joined [6] 8/1 10/16
13/18 14/23 45/19
154/18
joiner [1] 8/11
joining [2] 24/5 33/19)
judge [1] 191/17
judgment [11]
114/25 115/1 115/18
128/6 128/6 128/11
128/15 131/3 131/22
132/12 141/16
judgments [3] 37/8
130/20 132/9
judicial [2] 135/24
136/9
July [13] 2/8 2/9 2/9
2/14 2/14 56/6 66/2
66/12 74/17 74/21
137/9 138/2 144/17
June [10] 25/3 44/6
92/25 100/9 105/22
137/9 137/21 137/21
143/15 192/8
June/July [1] 137/9
jurisdiction [2] 81/2
113/12
just [80] 3/19 7/24
8/10 21/17 22/9 27/3
29/9 29/18 34/10
36/18 37/3 39/10
39/11 46/8 46/13 49/6
51/15 56/4 58/22
58/22 62/17 62/17
67/11 73/12 74/20
78/6 78/19 81/8 84/4
90/7 95/1 100/13
105/22 106/3 116/11
118/21 120/1 121/12
121/23 123/1 123/6
123/22 124/3 126/16
126/19 127/15 132/1
132/5 135/2 149/7
151/24 153/11 155/1
156/6 158/20 160/11
168/1 170/5 171/19
171/23 171/25 173/14
176/15 178/3 185/17
188/1 188/23 190/2
190/18 192/4 192/19
197/9 202/21 202/24
203/5 203/7 204/1
204/15 205/2 206/9
justice [17] 72/10
72/17 72/21 72/23
76/13 76/19 77/1 77/7
77/14 77/18 82/25
121/2 126/21 128/7
128/16 128/24 131/13
K
Karen [1] 90/8
Kathryn [2] 101/13
104/23
KC [1] 8/17
keen [1] 198/17
keep [2] 171/14
209/1
keeping [2] 54/22
73/21
keeps [1] 63/3
kept [1] 155/17
key [3] 24/2 33/9
185/5
keys [1] 152/25
kick [1] 187/9
kind [5] 32/5 170/1
173/23 182/12 182/17
kinds [5] 42/3 63/3
145/22 153/11 182/18I
King [4] 20/21
knew [1] 170/24
Knight [1] 10/25
know [61] 5/22 10/12
10/17 10/25 12/3 13/8}
13/18 13/19 13/20
14/20 14/23 14/24
17/20 17/24 29/14
32/19 34/12 36/14
41/17 44/16 49/3 50/8
50/20 56/23 56/23
58/1 60/4 60/19 63/13
67/10 67/25 71/4 85/5
90/14 90/16 96/4 96/9
98/7 100/13 113/2
114/13 114/20 134/20}
147/8 155/18 155/21
162/24 176/14 179/22}
179/24 181/7 182/19
183/21 188/10 188/11
191/17 197/2 197/3
198/6 198/6 209/2
knowing [1] 51/17
knowingly [1] 40/23
knowledge [7] 2/1
2/16 3/7 4/14 5/4
85/23 178/7
known [7] 5/14 6/9
11/11 33/15 33/22
141/15 175/12
knows [3] 21/18
169/11 208/23
KPMG [6] 23/22 25/1
28/18 69/8 69/14
69/24
KPMG's [1] 69/21
KS [3] 101/13 101/22
103/2
L
labelling [1] 78/8
lack [8] 25/22 26/4
26/14 32/22 136/9
162/21 183/24 203/17,
Lancashire [16]
123/16 123/24 125/24}
126/14 129/9 132/23
133/17 146/24 160/2
160/8 172/10 174/1
174/3 199/15 200/5
200/12
landed [1] 71/1
landscape [2] 64/18
192/16
language [5] 78/7
163/20 163/22 181/14}
186/18
large [8] 11/12 20/23
20/25 124/10 151/3
180/23 181/1 191/19
large-scale [1] 20/23
largely [2] 7/13 39/14
last [14] 2/13 3/11
3/12 21/20 68/15
77/11 85/19 115/14
1417/5 118/1 147/15
155/11 156/9 174/6
later [7] 93/1 136/21
169/20 170/6 175/3
183/12 191/8
latitude [1] 191/9
laundering [9] 15/20
16/3 16/13 16/14
80/19 123/25 125/12
125/14 126/6
law [68] 7/18 13/24
14/25 15/2 15/6 15/8
16/5 16/11 16/15
19/19 19/23 19/25
20/4 21/25 33/12
33/23 34/20 36/2 36/4I
41/18 42/6 55/4 55/6
63/19 65/21 69/1
72/25 76/9 77/11
77/13 77/20 79/16
80/4 86/13 86/19 91/1
91/19 105/6 106/10
106/13 107/14 109/12)
109/17 109/21 110/19)
131/19 136/18 137/25]
138/12 138/15 139/15)
139/23 140/2 140/10
142/11 142/18 142/23)
143/23 144/12 154/13}
154/22 157/4 186/4
189/14 201/24 206/25)
207/13 208/3
lawyer [8] 14/3 50/25
126/22 130/14 131/17)
131/23 139/1 139/24
lawyers [3] 57/15
104/13 104/14
lay [1] 61/8
lays [1] 109/19
LEA [1] 81/4
lead [3] 83/12 153/18
154/10
leaders [2] 31/25
71/10
leadership [1] 176/1
leads [1] 42/22
learn [1] 183/25
learned [3] 27/13
27/14 158/1
learnt [1] 69/13
learnt [1] 26/8
LEAs [4] 79/17 80/20
81/5 83/2
least [7] 13/14 14/17
43/7 176/16 197/24
198/1 208/24
leave [2] 47/17
103/19
led [4] 83/3 113/21
178/2 204/10
left [6] 12/17 22/11
104/2 111/23 119/12
195/10
left-hand [1] 22/11
Legacy [1] 109/22
legal [21] 7/15 7/17
8/6 15/4 20/13 29/24
41/14 86/4 91/18
106/13 109/16 109/18)
119/21 126/18 126/25]
148/10 152/14 168/4
185/16 197/14 201/17)
legally [2] 41/16
110/21
legislation [1] 129/10
length [2] 169/4
171/22
(70) issues... - length
L
less [2] 21/11 81/3
lessons [4] 27/13
27/13 69/13 157/25
let [1] 64/25
60/7 60/25 84/17
134/25 152/22 156/6
164/10 190/25
letter [41] 82/5 83/7
83/9 123/15 123/15
124/1 125/25 126/16
126/19 131/20 132/2
135/3 136/11 137/11
141/24 142/1 144/19
147/13 147/19 149/7
151/2 151/7 151/10
151/20 151/22 152/4
154/6 162/4 162/7
162/19 163/7 168/7
169/24 170/7 170/24
200/24 201/2 201/3
letter/the [1] 144/19
letters [7] 117/25
118/2 147/7 152/6
166/15 200/6 200/21
letters/emails [1]
166/15
level [29] 18/8 20/7
22/25 23/4 36/15
38/24 43/6 43/11
46/10 50/14 54/6
57/20 59/4 82/11
88/14 89/7 89/12
89/12 92/9 92/14
92/25 96/18 96/21
98/19 99/1 100/9
107/16 146/20 168/6
levels [3] 43/19
88/16 107/21
liaise [2] 16/11
205/24
liaising [1] 184/6
liaison [3] 65/21
157/3 157/6
lies [4] 32/8 32/17
43/24 1714/1
life [4] 157/17
light [3] 8/19 146/4
148/15
like [61] 7/24 9/6
13/6 13/6 14/19 15/19
16/14 19/24 20/20
22/6 27/19 29/9 29/10
29/12 30/9 33/7 36/11
36/13 36/23 37/3 38/7
46/13 50/1 50/23 51/1
54/19 56/4 60/11 61/7
62/8 65/21 68/24 71/2
73/12 78/19 85/12
lengthy [1] 80/21
let's [13] 21/18 52/13
100/18 105/17 105/17)
144/25 147/11 147/12)
117/13 131/8 136/15
160/24 162/18 164/3
173/11 177/23 179/1
180/3 180/22 181/12
likelihood [1] 80/24
81/6 86/23 131/12
146/4 147/5 179/14
194/12 199/16
Lill [3] 14/4 126/23
126/24
limit [1] 81/18
59/9 94/22 129/16
208/7
Limited's [1] 39/14
line [24] 2/12 18/18
22/20 26/12 26/22
27/1 47/11 47/13
47/15 47/16 47/19
65/9 69/21 89/10
96/11 98/22 106/6
166/4
linear [1] 70/20
lines [8] 37/21 40/10
40/17 40/21 55/9
96/22 140/14 178/3
link [4] 15/6 22/22
31/9 97/22
linked [4] 12/11 59/7
79/19 154/13
Lisa [1] 11/14
list [3] 80/3 123/20
150/24
listed [3] 69/3 73/6
100/14
listen [1] 205/16
listened [2] 8/17 8/18
listening [1] 109/5
literally [1] 187/17
Litigation [3] 8/3
37/1 115/18
little [5] 11/6 22/11
145/15 191/9 201/23
living [1] 44/15
located [1] 3/17
location [1] 149/12
logical [1] 25/9
logs [1] 42/2
London [36] 82/8
82/14 83/7 83/10
83/11 118/23 119/5
119/8 119/9 119/23
119/25 120/6 120/10
120/14 120/15 120/18)
120/19 121/17 133/5
135/18 146/19 147/3
147/8 147/11 148/3
95/1 96/2 96/20 112/7I
145/15 146/10 152/13)
152/19 158/23 160/11
188/23 195/19 200/11
likely [10] 18/12 58/9
limited [9] 26/8 50/23
172/25 174/24 174/24)
106/18 110/25 140/16)
172/1 172/4 172/11
172/18 173/1
long [11] 28/23 32/5
43/8 57/23 109/8
41/9 77/10 118/21
207/14
longest [1] 191/3
longstanding [2]
11/7 16/13
look [49] 6/3 6/5 6/21
30/4 36/23 38/3 39/8
50/1 50/2 50/2 50/5
68/24 74/16 83/15
84/17 85/12 90/20
90/23 98/18 99/4
99/22 100/19 113/3
117/13 134/25 135/2
140/6 143/8 146/22
146/23 153/4 156/6
162/7 163/6 170/16
177/23 180/23 201/5
202/21
looked [14] 11/13
18/23 18/24 23/24
58/25 74/20 85/22
121/18 132/21 135/1
149/7 156/2 176/18
201/13
looking [27] 6/18
30/8 34/17 46/14
84/24 90/22 105/22
116/8 116/12 119/23
121/22 123/15 131/18
135/19 136/14 144/16}
145/11 154/5 154/25
158/19 158/20 159/25}
160/16 170/5 181/17
181/18 183/19
looks [5] 84/15 96/2
122/5 126/1 181/12
loopholes [1] 85/22
Lord [2] 207/13
208/14
loss [14] 52/20 79/6
80/25 82/12 85/7
85/14 115/8 115/22
117/2 125/6 125/8
130/2 130/10 155/9
losses [8] 86/16
87/10 112/7 112/10
112/19 113/1 114/20
115/19
lost [2] 78/9 78/14
lot [11] 9/10 21/6
25/7 28/24 63/12
104/12 169/5 172/19
151/10 151/12 151/13
151/19 152/18 153/16
170/16 170/21 187/11
187/21 205/13 205/15}
longer [6] 24/15 41/7
17/14 22/6 22/9 23/23
116/18 116/19 116/20
158/14 158/23 160/14
lots [2] 6/8 66/8
low [3] 18/8 67/22
73/5
lower [2] 46/9 53/6
lowest [1] 71/15
lunch [2] 105/21
111/13
lying [1] 38/5
22/2 28/19 36/25
73/10 79/6 79/18
79/19 86/25 104/3
111/2 111/3 111/5
115/17 123/4 128/11
130/25 148/5 150/14
152/21 153/1 154/16
173/5 178/17 181/10
182/16 186/24 195/4
196/9 200/7 206/11
magazine [1] 193/10
Mail [3] 179/15
179/20 179/23
main [2] 54/16
185/20
maintained [2] 24/22
45/17
maintains [1] 136/3
majority [6] 17/11
54/3 80/16 85/20
126/20 139/10
make [25] 6/7 25/7
51/24 54/10 94/23
145/20 160/7 161/8
168/19 169/5 173/3
177/6 187/1 188/13
189/11 191/6 193/22
200/10
makers [2] 165/16
189/10
makes [4] 80/14
81/20 109/16 175/4
making [11] 38/10
40/23 43/18 56/3
88/22 101/19 102/11
104/5 167/8 173/19
181/3
manage [4] 16/1 99/7
99/9 103/12
managed [1] 110/19
management [5]
26/17 27/3 45/17 71/6
181/24
manager [12] 47/11
47/13 47/15 47/17
47/19 47/22 119/41
124/20 160/18 160/21
172/21 198/15 198/15)
Lynette [1] 11/15
made [39] 4/3 6/16
42/11 46/3 51/8 69/24
165/10 167/22 168/21
36/3 37/19 38/7 42/13)
131/24 136/17 138/25}
169/13 177/11
managers [8] 15/14
26/12 26/13 26/21
26/22 27/1 27/1
105/12
managing [1] 95/7
manifestations [1]
61/15
manner [2] 73/20
109/12
manpower [1] 94/13
manual [15] 40/15
44/3 44/23 45/13
45/24 46/2 46/5 46/5
49/3 58/24 59/2 61/8
63/16 63/16 164/24
many [8] 13/17 52/10
67/10 68/4 97/13
114/5 130/25 191/1
March [4] 2/12
167/16 170/5 180/6
mark [1] 98/22
market [2] 17/13
24/21
Martin [2] 90/2 90/13
matching [1] 102/7
material [26] 9/24
9/25 36/8 42/8 42/9
42/14 42/15 42/19
42/23 43/4 50/6 88/10
123/3 123/7 139/15
140/11 141/9 142/2
143/23 144/10 152/17)
153/3 153/4 186/25
188/16 190/14
matter [19] 38/8
55/18 56/1 60/21
61/10 92/22 102/7
102/20 119/8 124/25
127/12 127/13 136/2
136/7 138/2 146/8
160/10 167/19 170/10}
matters [45] 8/1 9/7
14/8 15/22 29/25 47/1
57/11 67/7 67/15
72/15 74/9 75/21
79/12 80/23 81/18
84/8 84/11 85/8 87/15
89/17 93/14 98/15
98/19 99/3 99/9 99/16}
103/13 103/19 103/19)
109/12 126/7 139/11
145/1 150/7 156/19
184/10 185/23 186/2
186/9 186/16 188/5
197/22 205/20 205/25}
206/7
may [53] 2/12 4/22
6/19 10/14 20/13 47/9I
47/25 51/6 51/7 51/11
51/14 51/17 53/21
57/13 59/22 63/8
66/23 72/3 72/4 78/22
78/24 79/7 82/15 87/1
(71) lengthy - may
may... [29] 100/15
106/16 109/13 109/20)
110/9 115/16 118/16
118/21 123/5 129/9
135/3 139/22 148/21
150/21 151/10 153/11
160/7 164/16 171/22
179/7 179/11 180/20
182/22 198/2 200/14
200/24 204/22 207/3
207/12
maybe [3] 77/2
158/24 183/22
McEwan [1] 90/8
McInnes [1] 102/2
McKnight [1] 11/16
me [16] 3/18 14/24
61/17 88/6 119/17
119/19 130/13 171/25}
173/23 176/11 176/12)
191/16 192/20 197/5
203/24 203/25
mean [30] 6/9 9/23
41/24 47/13 49/16
52/6 58/6 60/5 60/24
60/25 64/19 68/1 70/8
71/1 71/5 78/6 78/6
89/8 97/2 102/9 121/9
121/22 122/17 123/9
123/9 155/20 162/12
173/17 184/16 190/25)
meaning [1] 207/6
meaningful [1]
150/14
means [13] 19/16
30/11 30/12 30/13
72/2 111/14 116/21
122/2 156/3 165/14
194/1 209/1 209/9
meant [8] 43/14
44/14 60/24 78/2 94/9
103/25 132/14 165/13)
meantime [1] 151/18
measure [1] 78/16
mechanism [2] 20/5
77/18
media [1] 12/12
medium [4] 95/9
110/2 110/7 110/19
medium-term [1]
95/9
meet [3] 50/23 81/10
95/8
meeting [20] 28/19
73/1 84/10 84/11
84/14 100/10 100/20
105/23 107/24 107/24}
108/12 112/1 112/4
143/15 143/20 163/14
163/15 164/11 165/4
202/19
meetings [2] 23/10
177/13
meets [1] 177/11
Mel [9] 6/11 17/2
17/117 54/1 67/4 67/8
71/9 113/22 170/19
member [5] 20/9
20/10 20/11 20/11
55/19
members [9] 6/16
12/17 20/14 23/13
35/18 78/4 79/25
175/17 184/8
mention [1] 100/18
mentioned [18] 6/8
19/12 43/5 44/3 44/22
46/13 78/11 87/23
99/23 105/12 112/9
150/7 172/4 176/12
183/22 189/16 202/24)
208/1
mentoring [1] 30/17
merits [2] 187/4
187/14
met [5] 69/25 186/10
190/16 190/16 204/12)
metadata [3] 10/13
115/9 117/21
methodologies [1]
71/3
methodology [1]
30/6
methods [1] 180/25
Metropolitan [1]
186/5
mid [4] 56/5 58/13
160/12 171/18
mid-afternoon [2]
160/12 171/18
mid-morning [2] 56/5)
58/13
Midlands [1] 133/15
might [45] 13/8 17/15
22/8 37/22 38/13 39/2
42/2 46/21 47/4 47/15)
48/24 49/12 49/17
50/17 51/5 51/20 52/6
53/7 57/13 58/12 62/4
65/2 77/6 77/17 85/11
87/23 97/10 98/5
105/18 105/24 111/12)
113/17 113/19 115/12)
123/7 136/24 152/18
163/23 171/8 171/17
181/24 186/21 190/14)
195/10 205/19
million [6] 85/3 85/9
85/15 124/14 187/19
188/1
mind [3] 51/21
171/24 209/11
minded [1] 204/21
mindedly [1] 61/7
mindset [1] 37/19
mine [1] 142/25
minimis [1] 116/23
minimum [1] 109/15
mining [1] 143/3
Minister's [1] 82/6
minuted [1] 73/2
minutes [4] 167/21
182/25 191/3 191/5
misappropriated [1]
79/1
misconduct [6]
33/13 75/14 91/19
92/6 183/10 184/18
misinterpretation [1]
127/8
missing [1] 91/11
mistake [1] 34/23
Mladenov [3] 86/15
87/9 102/4
Mm [11] 9/11 43/20
62/25 74/22 152/24
165/3 165/23 180/12
199/1 199/20 200/17
Mm-hm [14] 9/414
43/20 62/25 74/22
152/24 165/3 165/23
180/12 199/1 199/20
200/17
Mobile [1] 124/16
Mobilising [2] 75/12
92/3
model [8] 69/15
75/12 78/18 79/14
92/3 92/20 115/25
117/15
moment [15] 27/9
29/15 44/17 58/12
89/10 96/4 96/9 99/1
99/2 105/25 111/8
111/12 113/22 171/17]
188/19
monetary [1] 82/12
money [20] 15/19
16/3 16/13 16/14
72/16 72/18 80/18
80/25 87/19 101/25
103/25 104/12 105/8
112/16 113/6 114/23
123/25 125/12 125/13
126/6
MoneyGram [4]
124/9 124/16 124/23
125/11
monies [1] 86/24
monitor [2] 181/25
182/18
monitoring [5] 17/13
23/9 26/4 27/15 93/24
month [2] 125/24
174/2
monthly [2] 156/10
156/12
months [6] 6/4 29/20
29/22 93/1 155/11
156/9
moral [1] 91/18
more [55] 10/2 10/19
16/15 18/8 19/20
22/11 25/20 27/2 27/8)
40/14 50/12 51/14
61/17 67/3 70/16
71/16 72/19 78/7
81/20 84/22 86/11
88/2 88/21 88/24
94/11 105/3 105/18
106/9 107/3 108/5
124/18 127/21 128/22)
129/6 140/18 142/9
142/15 142/15 150/25}
167/9 167/11 168/23
169/5 169/14 172/19
172/21 175/4 177/20
182/3 187/10 191/4
192/2 192/21 192/21
207/20
Morley [6] 15/16
160/18 162/1 165/21
166/12 168/1
morning [8] 1/3 1/4
1/5 56/5 58/13 183/22)
204/5 209/13
most [11] 28/3 44/12
54/7 61/3 79/18 80/20)
89/25 142/11 193/23
207/13 209/7
motto [1] 73/19
MOU [1] 83/22
mounting [1] 164/4
mouth [1] 81/16
move [9] 23/22 33/7
41/19 65/21 74/15
95/9 95/23 160/11
176/6
moving [4] 13/24
41/21 175/10 182/24
MPS [1] 186/12
Mr [115] 1/4 1/6 1/9
1/13 5/10 11/3 21/19
57/5 58/22 60/3 61/3
62/15 85/17 86/15
87/9 89/21 90/1 90/2
90/8 90/10 90/11
90/25 91/15 1041/9
102/2 102/4 108/15
111/23 112/9 114/6
114/17 123/1 126/23
128/7 128/16 128/24
131/13 135/3 136/21
145/10 160/13 160/18}
160/19 161/2 161/18
161/23 161/24 162/1
162/3 165/21 165/21
166/12 166/20 167/16}
168/1 168/7 169/19
169/25 170/7 170/13
171/3 171/24 173/3
173/6 175/3 175/15
175/15 176/15 176/16
176/19 191/2 191/14
191/15 191/18 191/24I
192/6 193/3 194/17
195/16 195/19 195/20)
195/21 195/22 196/21
197/6 197/9 198/20
198/23 199/6 200/3
200/14 201/2 201/13
201/20 202/2 202/7
202/13 203/15 203/15
204/4 204/11 204/11
204/14 204/15 204/16
206/5 206/7 206/9
206/11 206/16 208/20)
209/4 209/9 210/4
210/6
Mr Bartlett [24] 1/6
1/13 5/10 58/22 60/3
111/23 162/3 168/7
171/24 191/18 192/6
195/19 197/9 198/20
198/23 199/6 201/2
201/13 201/20 202/2
202/7 202/13 206/9
206/16
Mr Blake [15] 1/4 1/9
62/15 108/15 123/1
175/3 191/24 194/17
196/21 200/3 203/15
204/4 208/20 209/9
210/4
Mr Cameron [3]
89/21 112/9 114/17
Mr Cameron's [1]
90/25
Mr Foat [6] 91/15
161/24 176/15 176/16)
176/19 209/4
Mr Ismail [3] 175/15
204/11 204/14
Mr Jacobs [17]
160/13 160/19 161/2
161/18 161/23 165/21
166/20 167/16 169/25)
170/7 170/13 175/15
204/11 204/15 204/16I
206/7 206/11
Mr Jacobs' [3]
169/19 203/15 206/5
Mr Justice [1] 128/7
Mr Justice Fraser [3]
128/16 128/24 131/13)
Mr Lill [4] 126/23
Mr McInnes [1] 102/2
Mr Mladenov [3]
86/15 87/9 102/4
Mr Morley [5] 160/18
162/1 165/21 166/12
168/1
Mr Oldnall [3] 145/10)
173/3 173/6
Mr Patterson [5]
135/3 195/20 195/21
195/22 200/14
Mr Patterson's [1]
(72) may... - Mr Patterson's
Mr Patterson's... [1]
197/6
Mr Railton [1] 193/3
Mr Read [7] 21/19
57/5 61/3 85/17 101/9
114/6 136/21
Mr Roberts [3] 90/2
90/8 90/10
Mr Roberts’ [1] 90/11
Mr Staunton [1]
17113
Mr Stein [3] 191/2
191/14 195/16
Mr Talbot [1] 11/3
MR's [3] 90/1 90/5
112/20
Ms [13] 21/21 22/2
61/2 85/19 86/4 88/19
89/22 202/10 202/10
202/12 206/15 210/8
210/10
Ms Allan [1] 202/10
Ms Gray [4] 85/19
86/4 88/19 89/22
Ms Tutin [3] 21/21
22/2 61/2
Ms Watt [3] 202/10
202/12 210/8
much [29] 1/10 2/15
5/9 7/2 10/19 14/10
22/12 23/20 38/17
47/22 54/8 58/17
63/24 66/16 73/5
73/21 74/6 76/17
76/20 77/7 77/17
104/14 111/17 127/21
163/19 175/2 201/20
208/19 209/14
muddy [1] 52/11
multiple [2] 32/2
136/8
mundane [1] 18/8
must [10] 46/3 47/11
48/12 110/19 110/20
118/16 140/1 140/4
159/18 175/21
my [65] 3/14 4/1 4/9
6/2 8/6 9/25 13/21
15/14 15/25 16/10
18/15 25/19 26/24
27/17 28/8 28/13
28/22 30/6 34/23 37/3
42/22 43/11 43/11
50/24 53/10 53/22
59/12 59/20 60/22
63/13 64/22 65/16
77/11 77/20 79/22
98/20 104/11 105/11
110/11 110/12 114/20
119/5 119/21 123/6
135/6 141/2 155/17
156/22 158/25 163/8
171/24 172/14 172/23}
174/8 183/21 190/22
191/16 191/17 197/14)
200/21 204/1 206/17
208/8 208/16 208/24
myself [3] 58/5 60/18
162/2
N
nail [1] 156/23
nailed [1] 64/21
name [16] 1/11 10/17
10/18 10/19 11/10
15/15 22/11 22/13
100/15 100/16 142/21
163/8 195/12 195/15
198/7 206/17
names [2] 6/9 10/23
naming [1] 78/8
narrative [1] 91/20
narrows [2] 54/5
54/5
national [1] 16/13
nations [2] 71/24
76/10
natural [1] 154/19
nature [5] 29/2
153/22 186/2 187/8
204/18
NBIT [31] 95/4 95/10
95/10 95/14 95/24
96/1 96/13 96/17 97/1
97/16 101/5 102/3
102/5 102/6 103/13
103/21 103/21 103/23)
104/1 189/8 189/17
189/24 191/25 192/5
192/13 192/15 192/20)
193/5 194/2 194/8
194/22
NBIT's [4] 96/10
NCA [2] 146/22
146/25
near [1] 73/17
Nearing [1] 190/2
nearly [1] 125/7
nebulous [1] 88/21
necessarily [3] 53/13
110/14 121/21
necessary [6] 24/21
43/1 72/9 93/11 97/18
174/12
necessity [1] 106/25
NED [3] 161/6 161/10
162/11
NEDs [2] 36/17 205/3)
need [34] 34/17 59/5
62/20 63/12 65/4 65/5)
68/6 81/24 83/1 95/19)
96/19 97/5 97/12
97/13 99/10 99/17
105/6 112/11 115/3
119/15 120/23 121/22)
139/8 139/10 145/15
145/18 145/21 149/18)
150/7 163/6 179/3
192/3 193/23 195/17
needed [9] 32/11
33/1 86/11 101/24
103/4 120/11 164/18
169/23 182/21
needing [1] 196/24
needs [10] 29/7 45/2
63/11 94/3 120/14
158/18 173/7 176/6
198/15 198/15
negative [2] 182/15
199/5
negligence [1] 117/3
Neil [2] 193/17 194/5
neither [2] 102/14
148/12
nervousness [1]
62/12
network [5] 9/18
11/18 93/23 95/3
192/12
never [3] 162/9
162/16 204/14
new [45] 8/11 9/22
12/10 27/3 31/13
31/23 33/21 34/22
37/4 37/16 39/6 43/21
44/19 49/2 57/16 59/2
63/20 73/22 75/12
92/3 95/16 95/21
95/24 95/25 96/1 96/6
96/10 97/10 110/10
112/20 115/24 127/21
127/24 138/9 138/13
157/24 158/17 192/12
193/3 193/17 193/22
195/20 204/7 204/8
205/10
newer [1] 189/22
news [1] 193/12
next [16] 34/17 35/10
44/18 93/7 120/21
125/24 130/15 131/7
153/8 160/1 160/1
174/2 194/1 199/7
200/8 206/14
NFA [1] 130/16
NFSP [10] 177/5
177/8 177/11 177/17
177/21 177/23 202/14
205/20 205/22 205/24
Nick [5] 114/17 135/3
171/2 171/5 181/10
Nield [1] 11/16
night [1] 147/15
nine [2] 23/19 93/1
no [119] 5/7 5/8 9/5
15/4 18/1 18/11 18/14]
18/16 19/5 21/4 22/20
22/20 23/16 24/15
26/2 26/6 26/16 37/19
39/3 39/5 39/7 41/7
41/9 47/9 49/8 49/25
51/16 52/21 53/6
53/14 56/10 59/18
61/24 62/16 65/1 65/4
73/9 74/2 75/6 75/8
76/6 76/24 77/10
78/15 83/11 83/19
85/23 86/2 88/9 92/10
94/20 96/14 98/2
99/18 100/2 100/18
103/25 104/4 108/6
108/24 109/23 112/25)
113/21 114/15 115/7
115/13 126/2 126/4
127/11 127/13 129/17
130/1 132/11 133/21
134/10 134/17 137/3
137/7 137/14 140/15
144/9 146/12 147/18
153/1 154/18 159/17
159/19 161/6 161/19
161/22 163/19 164/7
168/4 168/24 170/14
170/21 1714/7 171/15
173/11 176/9 178/19
179/6 182/13 183/6
188/2 188/2 190/20
191/4 191/8 191/23
193/9 194/20 198/17
201/16 202/5 202/8
203/1 207/14 208/15
Nobody [1] 195/1
nodded [11] 14/7
67/19 78/1 88/13
100/17 159/5 159/7
159/10 180/9 192/18
196/25
nominal [1] 19/14
nominated [1]
139/24
non [18] 19/14 21/10
23/6 23/7 27/21 27/22
77/9 77/13 81/4 90/9
121/4 160/14 165/11
177/22 178/8 180/2
202/23 208/3
non-A [2] 27/21
27/22
non-criminal [3]
19/14 21/10 77/9
Non-Executive [5]
23/7 90/9 160/14
177/22 202/23
non-investigative [1]
165/11
non-law [2] 77/13
208/3
non-LEA [1] 81/4
non-provision [1]
121/4
non-transparent [1]
178/8
none [12] 12/17
21/13 21/14 21/15
55/10 55/12 67/17
67/18 67/20 109/25
159/22 164/9
nor [4] 80/20 109/9
119/10 148/12
normal [1] 104/1
normally [1] 89/18
Northern [6] 81/6
82/18 83/20 83/21
91/11 91/13
not [279]
note [3] 92/17 130/7
175/14
noted [16] 86/10
86/16 88/19 90/25
91/15 100/25 101/16
103/2 112/17 113/10
113/13 113/25 114/6
129/9 143/22 149/23
notes [5] 112/1
129/12 129/13 149/2
168/20
nothing [2] 158/16
175/20
notified [2] 171/10
203/18
notify [1] 36/9
noting [4] 39/10
91/23 92/8 144/2
now [56] 5/24 12/18
13/24 14/3 16/20 17/8}
18/23 22/15 23/8
24/23 27/13 29/19
33/21 34/9 41/7 49/16
57/21 65/10 67/3
74/20 78/13 82/5 89/4I
89/6 92/25 92/25 93/8
96/11 105/23 117/21
128/19 137/8 142/13
144/15 153/20 160/24)
162/9 170/6 172/13
181/12 181/17 181/25}
188/5 190/7 190/16
191/7 191/24 192/24
193/2 193/15 194/3
197/16 197/18 199/10}
199/18 204/2
nowhere [1] 85/25
NR [4] 85/17 88/21
90/25 101/9
nuanced [1] 119/16
number [25] 2/18
10/23 11/8 11/12
12/24 68/24 72/8
72/14 89/9 95/25
101/6 116/22 124/11
144/18 149/3 157/16
158/21 159/2 160/15
175/4 181/1 185/1
185/14 191/24 195/9
Number 1 [1] 157/16
numbers [4] 20/25
95/5 182/2 199/23
numerous [1] 128/8
(73) Mr Patterson's... - numerous
[e)
objection [1] 108/2
objective [4] 60/20
119/7 142/15 158/5
objectivity [1] 141/2
obligation [2] 91/18
168/4
obligations [4] 24/23
41/12 41/13 185/16
observation [1]
26/19
observations [2]
69/24 187/1
obsolescence [1]
157/24
obsolescent [1]
196/23
obtain [4] 77/18
obtained [4] 47/11
79/3 154/5 185/22
obtaining [2] 97/24
145/10
obvious [7] 111/6
121/8 121/9 122/10
122/15 122/16 122/17)
obviously [8] 44/19
60/6 122/12 146/8
160/8 177/9 188/11
191/19
occasion [3] 94/23
168/5 177/13
occasions [1] 54/17
occur [1] 60/23
occurred [3] 47/10
72/4 134/18
occurrence [1]
166/16
occurring [1] 61/13
October [9] 1/1 2/5
2/6 105/23 106/2
108/13 108/16 137/8
172/7
odd [4] 1114/9
odds [1] 197/18
off [11] 55/19 106/14
106/18 111/24 113/7
114/23 116/23 116/24}
122/8 182/5 204/22
off [1] 125/10
offence [6] 47/9
47/25 49/15 72/3
131/5 164/16
offences [5] 49/1
80/15 80/19 82/11
99/6
offer [1] 29/10
offered [2] 53/8
166/16
office [231]
Office's [8] 24/18
37/10 86/10 106/12
110/1 168/8 187/12
208/5
Office-wide [1] 69/11
officer [8] 7/3 47/25
48/9 51/14 77/6 124/5)
152/21 207/14
officers [3] 48/11
57/8 91/8
offices [4] 15/23
141/11 160/23 161/14)
official [1] 208/12
often [9] 20/4 26/12
55/16 80/22 89/16
90/13 114/1 139/8
203/9
oh [2] 72/20 146/9
OIC [3] 125/14 125/10
125/12
okay [34] 2/2 3/9
6/14 22/5 27/7 37/6
39/8 49/20 55/10 58/8
58/11 68/7 68/22
70/15 72/20 73/4
100/21 155/15 189/4
192/13 192/24 193/2
193/10 195/18 195/21
196/19 196/20 198/1
198/19 199/17 203/5
204/1 208/12 208/16
Okey [1] 58/16
old [8] 66/13 127/22
138/6 138/11 142/6
142/12 196/23 198/14)
Oldnall [7] 119/16
133/25 134/1 140/20
145/10 173/3 173/6
Oldnall's [4] 31/3
134/12 143/5 144/6
omissions [1] 145/3
on [231]
once [7] 49/18 64/3
95/14 97/4 146/19
147/24 176/11
one [68] 2/13 5/7
8/11 14/17 15/14
15/25 18/20 23/16
24/1 24/11 26/1 27/22
28/2 29/21 30/4 30/15)
35/16 35/17 36/17
41/16 43/7 44/16
45/18 50/24 51/18
60/19 60/22 68/17
69/4 70/3 74/20 77/2
83/17 88/3 101/22
102/11 105/20 107/10)
119/5 121/11 122/10
122/14 122/16 133/17)
152/5 154/11 159/19
160/3 160/12 163/21
169/13 171/19 171/23)
172/10 175/19 176/16)
177/3 180/6 185/7
189/1 189/9 189/13
193/13 199/11 199/25)
202/25 205/2 205/2
ones [5] 26/25 54/9
68/3 68/9 162/25
ongoing [11] 29/3
29/11 68/17 105/17
136/10 150/21 172/12
186/1 193/19 199/11
200/19
only [20] 3/15 4/11
17/7 36/19 46/16 48/3
54/13 61/6 79/2 95/19
101/22 117/11 128/25)
130/10 139/23 150/12
183/1 184/9 188/7
197/20
onto [3] 4/18 36/22
175/11
onward [2] 75/2
91/23
onwards [5] 66/8
68/11 140/17 158/22
158/23
open [9] 37/19 42/7
61/7 67/3 81/25 86/18
119/7 189/12 204/21
open-minded [1]
204/21
open-mindedly [1]
61/7
openness [1] 54/21
operate [2] 27/17
82/21
operated [3] 37/14
145/2 148/25
operates [1] 20/18
operating [7] 69/15
78/18 79/14 92/20
115/25 117/15 128/3
operation [2] 148/12
198/13
operational [5] 43/12
75/17 97/13 104/24
138/14
operations [4] 45/22
97/23 99/4 147/21
opinion [6] 148/9
148/10 148/13 182/22
196/7 197/14
opportunity [3] 52/1
151/15 193/21
opposed [7] 59/8
71/7 72/11 77/19
126/13 130/3 178/24
opposite [1] 74/14
oppressive [1] 62/4
option [2] 99/22
113/7
options [1] 104/9
or [228]
order [24] 71/25
72/16 72/25 103/12
115/18 132/1 135/5
137/20 150/24 151/8
151/13 152/19 153/3
153/7 168/5 168/19
174/16 174/19 189/11
189/18 192/10 192/11
197/10 197/12
orderly [1] 158/8
orders [1] 190/24
ordinary [3] 152/22
153/11 162/10
organisation [20]
6/21 61/24 70/5 70/24
70/25 72/24 79/15
86/5 105/1 114/10
120/13 122/5 180/2
180/22 182/7 183/25
189/13 193/13 195/8
195/10
organisations [4] 7/9
79/19 180/3 193/14
organogram [2] 22/8
176/18
original [2] 143/11
186/24
originally [3] 163/25
180/19 180/22
originated [1] 179/14
originating [3]
139/21 140/3 140/9
origins [1] 179/17
other [65] 9/6 15/17
18/2 20/2 20/13 25/8
28/24 30/17 31/5
31/21 38/13 42/11
42/24 44/21 44/21
45/23 46/9 48/15
51/19 56/4 57/4 59/15)
60/5 61/22 61/24
63/24 65/5 68/16
70/18 72/8 72/16
77/14 82/2 94/24
98/15 99/11 103/17
107/25 109/5 113/4
115/14 115/16 126/9
129/2 130/5 131/4
131/6 135/23 138/13
144/25 147/19 149/12)
161/16 165/1 175/17
177/22 178/5 188/12
188/24 191/4 193/20
196/8 197/1 202/22
206/7
others [9] 11/9 11/16
12/16 37/9 68/13
108/4 108/4 141/13
197/2
otherwise [4] 6/20
154/13 190/14 195/5
our [48] 10/8 10/8
14/17 19/20 20/17
25/2 31/14 42/7 45/12
45/14 48/24 50/16
52/17 55/10 55/23
56/3 56/5 58/12 64/15
80/12 80/12 80/17
97/5 99/1 100/22
102/24 111/12 122/7
142/21 142/23 148/2
148/6 155/1 158/24
160/12 163/20 165/14}
169/10 171/13 171/17
174/7 177/14 177/15
178/14 188/11 193/21
193/22 206/2
ours [1] 145/15
ourselves [1] 158/15
out [68] 7/1 10/22
12/23 17/9 20/20
20/23 23/12 23/19
24/1 24/25 25/2 25/11
28/25 37/2 38/24 46/9I
46/20 49/5 57/19 59/5)
60/8 63/24 64/9 66/10
66/16 69/4 69/21
77/10 79/14 93/14
96/6 101/7 101/11
103/15 103/25 109/19}
115/3 128/15 131/14
132/1 132/7 132/11
132/22 137/12 146/13)
149/14 150/1 152/17
154/7 154/8 156/25
160/9 168/1 168/5
168/7 171/13 173/13
183/4 183/23 184/2
187/23 188/7 188/11
188/19 191/11 193/15)
198/14 207/6
outage [1] 146/10
outcome [17] 10/11
39/20 41/2 79/2
104/22 105/3 121/8
121/9 121/16 122/3
122/10 122/14 122/15)
136/15 154/21 170/25)
206/3
outcomes [6] 116/22
121/1 122/16 122/17
123/11 154/11
outlined [2] 84/19
101/15
outlining [1] 101/2
output [5] 51/22
72/23 73/4 77/2
171/12
outside [9] 19/12
26/23 49/9 51/16 61/2
79/22 94/5 105/6
165/11
outstanding [1]
174/18
outweigh [1] 130/21
over [45] 10/4 25/21
25/22 26/11 34/21
45/9 54/18 57/7 61/16)
68/17 78/17 83/2
84/12 85/18 91/1 91/4
93/17 97/15 98/14
99/8 99/16 99/25
100/22 102/1 106/1
107/25 108/24 109/6
114/12 114/12 118/1
(74) objection - over
[e)
over... [14] 128/20
130/6 131/7 134/8
136/16 139/2 149/10
158/3 165/8 167/24
169/2 171/15 184/25
186/18
over-stretched [1]
83/2
overall [3] 151/5
178/11 202/2
overarching [6]
25/22 59/18 62/19
62/24 70/8 78/14
overegging [1] 169/6
overriding [1] 72/22
oversee [1] 83/13
oversees [1] 67/4
oversight [6] 20/7
20/14 20/16 22/6
25/22 78/14
overstate [1] 120/22
overview [2] 10/7
190/9
owed [1] 87/19
Owen [1] 136/24
own [7] 17/9 75/24
81/16 159/8 199/22
207/6 207/15
owned [5] 58/9 78/21
79/16 80/2 184/17
ownership [2] 75/21
86/10
owns [1] 58/1
Pp
pack [1] 147/13
package [2] 28/16
29/8
page [86] 1/21 1/21
2/4 2/8 2/11 2/13 3/1
3/3 3/11 3/19 4/25
10/21 12/7 24/12
25/10 25/21 26/11
34/17 35/1 36/24
36/24 45/9 45/10
45/25 46/12 56/12
56/13 56/13 57/3 57/6
57/7 68/11 73/11
73/13 77/22 78/17
78/17 84/12 91/4
92/20 93/18 97/15
100/15 100/20 100/22)
100/22 100/23 102/1
105/24 106/1 109/6
112/5 115/15 123/22
125/16 128/20 129/21
130/6 131/7 131/8
132/19 132/21 132/22)
133/4 133/10 133/13
133/15 139/2 143/16
143/17 149/10 155/3
158/3 160/16 160/17
165/8 165/19 165/25
183/3 184/25 184/25
185/14 192/6
page 10 [1] 25/10
page 105 [3] 68/11
123/22 132/19
page 118 [3] 125/16
132/21 132/22
page 12 [1] 10/21
page 121 [1] 133/4
Page 125 [1] 133/10
page 126 [1] 133/13
Page 127 [1] 133/15
page 130 [1] 2/13
page 14 [2] 56/12
56/13
page 16 [1] 46/12
page 19 [2] 1/21
155/3
page 2 [4] 77/22
167/15 183/3 184/25
page 3 [3] 115/15
165/19 185/14
page 4 [5] 24/12
45/10 112/5 175/12
175/13
page 5 [4] 78/17
78/17 160/16 160/17
page 57 [2] 3/11 3/19
page 6 [6] 12/7 36/24
100/15 100/20 100/22)
100/23
page 62 [1] 2/4
Page 67 [1] 2/8
page 7 [3] 36/24
143/16 143/17
page 71 [1] 57/3
Page 77 [1] 2/11
page 9 [1] 4/25
page 99 [1] 3/3
panel [4] 186/3
186/10 187/5 187/6
panic [1] 13/5
Panther [2] 142/16
142/20
paper [16] 79/10
97/11 100/8 100/16
101/2 101/8 101/11
103/15 103/18 104/24}
113/12 113/15 113/17)
137/21 143/22 143/25)
papers [2] 87/20
187/17
paragraph [30] 2/4
2/11 3/12 3/20 9/12
12/8 17/4 19/13 24/2
33/10 37/7 66/8 69/23)
82/19 95/2 110/3
120/21 130/15 132/8
142/4 144/19 169/8
181/20 183/3 192/7
203/8 203/19 204/3
206/21 206/21
167/15 175/12 175/13)
paragraph 11 [2]
9/12 17/4
paragraph 13 [1]
12/8
paragraph 17 [1]
24/2
paragraph 20 [1]
181/20
paragraph 221 [1]
203/8
paragraph 24 [1]
203/19
paragraph 25 [1]
192/7
paragraph 31 [1]
19/13
Paragraph 4 [1]
69/23
Paragraph 4.7 [1]
82/19
paragraph 48 [1]
33/10
paragraph 6 [1] 95/2
paragraph 69 [2]
204/3 206/21
Paragraph 7 [1]
142/4
paragraph 88 [1] 2/4
paragraph 89 [1]
66/8
paragraph 92 [1]
2/11
Pardon [1] 100/12
parity [1] 78/11
Park [6] 6/11 17/2
54/1 67/4 113/22
170/19
Park's [3] 17/17 67/8
7119
part [32] 6/1 9/16
20/14 39/2 39/6 42/9
43/10 46/16 48/14
56/3 61/21 63/10 71/1
74/8 76/25 76/25 77/1
84/22 95/6 102/3
110/5 130/4 137/13
137/16 175/21 180/15}
180/19 183/5 189/15
193/11 197/5 208/24
Part 2 [1] 180/19
partially [3] 70/7
70/12 70/12
Participant [1]
206/18
Participants [1]
190/23
participating [1]
62/11
particular [47] 4/12
12/21 15/13 17/1
18/25 23/23 28/1 32/9
32/16 35/22 35/24
37/12 41/2 44/11 45/7I
55/14 60/21 64/7
67/12 90/22 106/20
110/3 118/22 121/19
139/14 143/7 146/8
153/18 154/23 160/2
174/9 176/19 185/17
189/9 206/1
particularly [8] 6/2
6/17 25/19 53/12
78/25 84/16 181/3
198/17
parties [3] 145/6
149/25 150/2
partly [1] 58/8
partner [1] 55/22
82/9 82/20 92/3
parts [2] 35/16 73/7
party [11] 13/21
19/22 41/22 42/24
55/17 110/11 135/23
137/1 147/20 149/4
154/8
pass [13] 36/3 52/6
55/15 56/2 106/7
109/10 119/22 142/2
153/15 153/22 165/15]
188/13 188/15
passage [3] 131/7
131/9 131/19
passages [1] 78/19
passed [11] 36/8
42/4 49/18 53/16 54/8)
97/17 108/8 110/6
139/22 186/5 188/5
passes [1] 186/16
passing [10] 72/15
106/14 106/19 107/9
107/14 107/17 137/24
139/15 142/10 143/23}
past [12] 6/22 12/6
21/3 61/25 67/5
162/24 164/6 166/16
166/20 167/3 167/12
205/23
patched [1] 196/23
path [4] 102/3
patterns [1] 17/14
Patterson [5] 135/3
195/20 195/21 195/22!
200/14
Patterson's [1] 197/6
paused [2] 44/17
190/3
pausing [5] 81/8 90/7I
116/11 120/1 126/19
pay [3] 101/16
103/22 113/6
payment [1] 181/5
payments [1] 122/6
PDF [1] 165/25
107/18 108/25 108/25)
127/25 132/16 135/15}
146/16 146/16 146/18)
152/10 152/10 153/13}
partnership [4] 75/12)
pejoratively [1] 78/6
pending [2] 44/18
192/21
Pensions [2] 7/9 7/23
penultimate [1]
71/20
people [34] 15/7 33/2)
38/14 38/16 39/14
40/15 50/4 50/17
50/22 51/5 52/10
54/14 56/23 59/9 61/3I
62/3 62/7 85/18 85/21
85/21 89/9 102/25
104/10 104/11 107/25)
163/22 168/19 171/9
182/6 191/10 191/19
191/21 195/9 204/23
per [7] 155/8 155/9
155/10 155/15 156/11
166/15 178/16
percentage [1] 21/5
perception [1]
130/17
percolate [1] 31/17
perfect [1] 64/23
perform [4] 3/13 4/7
24/16 97/5
performance [2]
90/15 175/24
performed [1] 91/17
perhaps [17] 32/15
44/4 44/7 44/8 58/7
59/4 65/17 67/5 70/15}
87/1 106/1 123/17
151/24 156/7 158/25
169/6 187/10
period [7] 66/20
67/13 67/13 123/3
129/18 145/18 159/12)
permanent [3]
105/10 105/13 105/14
permission [1] 141/8
permit [2] 71/23
106/14
person [16] 36/19
4TIT 47/24 48/7 50/8
51/18 55/17 119/20
119/21 125/2 162/22
162/23 195/7 195/8
195/12 195/15
personal [2] 32/9
208/25
persons [1] 46/24
perspective [3] 88/3
96/19 181/16
pertinent [1] 180/24
Peter [2] 11/1 11/9
phase [7] 2/21 11/4
41/20 90/7 95/12
181/10 190/19
Phase 2 [1] 181/10
Phase 7 [1] 190/19
phases [5] 1/15
20/19 78/4 182/14
(75) over... - phases
P
phases... [1] 183/12
Phases 5 [1] 1/15
Phoenix [17] 6/22
6/24 12/4 23/18 32/14
182/24 183/7 183/9
183/14 184/1 184/14
184/21 185/21 185/22
186/9 186/13 186/20
physical [2] 13/7
187/24
pick [1] 111/23
picture [1] 68/19
PIDA [1] 189/5
piece [3] 25/19 39/12
107/18
pin [2] 98/4 101/4
Pineapple [3] 175/10
175/12 204/23
pipeline [1] 83/25
place [37] 13/9 17/8
18/5 20/5 26/2 26/23
28/20 29/6 29/13 32/9
36/7 36/16 48/18
57/21 59/19 64/6
67/11 67/12 68/5 70/6
72/18 78/3 83/19 97/4
97/10 98/5 112/21
115/4 127/14 127/24
132/17 134/20 141/2
162/9 162/15 181/6
181/8
placed [1] 76/18
placement [1] 13/4
places [1] 72/14
placing [2] 69/1 98/8
plainly [1] 74/8
plan [9] 18/1 28/15
31/23 96/13 98/2 98/5)
146/25 177/20 180/20)
planned [2] 17/25
69/12
plans [1] 13/8
play [6] 63/10 95/6
106/13 106/24 109/18
187/20
played [1] 9/1
please [98] 1/11 1/16
1/20 2/5 2/22 2/25
4/25 10/5 11/24 12/7
13/23 22/7 23/12
23/21 24/3 24/12
25/10 25/20 26/11
34/4 46/12 48/22
56/13 57/3 58/15 69/1
74/15 77/22 78/17
81/16 84/9 84/12
88/18 91/4 92/11
92/24 93/17 97/15
100/7 100/19 102/1
102/19 105/24 109/6
111/15 112/5 114/16
115/8 118/19 122/25
123/22 123/23 125/16I
125/25 129/4 130/6
131/7 132/6 132/11
132/18 132/22 133/4
133/13 134/7 137/20
138/10 143/13 143/15)
144/4 144/14 147/10
147/19 149/10 151/7
157/8 158/3 160/16
161/1 161/23 162/4
162/7 165/8 165/17
166/4 166/9 167/13
167/15 167/21 167/24)
170/4 170/15 175/5
175/11 177/25 182/24)
184/25 185/14 206/14)
pleased [1] 204/16
pm [6] 111/18 111/20
175/7 175/9 176/2
209/15
PMs [4] 175/18
175/20 175/22 176/3
POC [1] 62/24
point [40] 7/21 25/13
26/21 27/20 42/12
57/9 58/6 69/22 71/21
73/13 73/13 83/1
83/22 84/1 84/4 84/17
86/25 89/20 90/25
97/4 98/2 98/25 99/14
100/2 101/19 104/3
105/1 110/18 110/23
112/7 124/12 131/23
162/18 163/5 172/16
174/20 182/5 185/5
187/9 198/12
pointed [1] 152/17
points [6] 25/21 27/5
28/2 154/6 154/7
154/8
POL [9] 99/13 118/2
118/3 173/16 196/2
196/9 196/15 199/2
206/23
POL00000254 [1]
57/1
POL00423697 [1]
24/3
POL00423698 [1]
114/16
POL00446706 [1]
177/25
POL00447931 [1]
10/5
POL00447947 [1]
56/8
POL00447948 [1]
100/7
POL00447971 [1]
22/7
POL00447975 [1]
69/2
POL00448014 [1]
44/4
POL00448302 [1]
175/11
POL00448310 [1]
143/14
POL00448320 [1]
92/11
POL00448321 [1]
84/9
POL00448327 [1]
92/24
POL00448345 [1]
137/20
POL00448353 [2]
34/4 204/8
POL00448354 [1]
74/16
POL00448362 [1]
115/8
POL00448649 [1]
182/25
POL00458007 [1]
184/22
POL00458015 [1]
105/21
police [160] 7/3 7/6
38/9 38/22 38/25 42/4
47/25 52/7 52/11
53/16 55/12 55/15,
55/18 60/4 66/20
67/11 67/18 67/25
72/6 72/15 7/6 77/10
77/11 79/5 79/8 79/12
79/23 80/6 81/20
82/14 82/22 83/7
83/10 83/11 83/18
85/24 88/15 97/19
97/21 97/23 97/25
98/14 98/15 98/18
99/8 99/10 99/10
99/11 106/7 106/15
106/19 107/1 107/4
107/9 107/19 109/10
113/5 118/23 119/6
119/8 119/9 119/23
119/25 120/6 120/10
120/14 120/15 120/18I
120/19 120/23 121/2
1241/6 121/15 124/17
122/12 123/24 124/25I
125/10 125/18 125/20
125/24 126/2 126/9
126/15 129/9 132/3
132/23 133/1 133/3
133/5 133/7 133/9
133/11 133/12 133/19I
135/18 135/23 136/13
139/5 139/6 142/3
143/18 143/23 144/1
145/17 145/21 146/11
146/17 146/19 146/24
147/12 148/3 150/3
150/19 151/5 151/12
151/13 152/3 152/12
152/18 152/21 153/9
153/15 153/16 153/17,
154/2 154/18 157/6
159/17 172/1 172/6
172/11 172/18 173/2
173/4 173/15 173/21
174/1 186/6 188/7
188/10 188/20 188/21
188/22 190/16 190/16
195/25 196/1 196/11
196/14 199/7 200/1
200/18 201/4 201/6
201/14 203/23 207/10
208/9 208/11
police's [5] 82/8
134/9 147/3 151/11
151/19
policeman [1] 176/5
policies [26] 33/7
33/9 33/9 33/16 34/1
38/15 43/22 44/22
45/3 45/6 45/7 56/5
57/22 58/24 65/9 79/8)
138/6 138/11 142/6
142/12 176/25 178/15}
184/15 184/17 184/17)
187/9
Policing [14] 28/13
28/15 28/20 29/8
29/14 29/23 30/7
30/10 31/8 31/19
48/12 49/23 50/3
180/16
policy [78] 3/22 4/6
33/11 33/13 33/21
33/23 33/24 34/2 34/5
34/9 34/20 34/24 36/3)
37/4 37/16 39/6 39/10
39/15 39/16 39/23
40/16 40/20 40/25
42/12 43/5 43/16 44/9)
44/19 44/23 45/5 47/8
56/6 56/8 56/20 59/5
59/20 61/8 62/19 63/7,
63/20 63/20 63/25
64/3 64/5 64/8 64/8
64/9 64/16 64/17 65/2
65/13 81/8 88/2 106/7,
106/8 106/12 106/13
106/18 106/24 107/8
107/18 109/7 109/10
109/15 110/5 138/5
138/9 138/13 138/13
138/14 139/12 139/20
177/1 177/19 186/5
204/4 204/8 205/10
poor [5] 39/19 89/11
89/17 185/12 193/6
population [1]
182/12
posed [1] 127/19
position [13] 23/14
29/5 45/7 83/5 83/13
104/6 112/15 156/15
196/4 197/16 198/10
201/9 204/20
positive [2] 29/18
105/3
possibility [1] 148/22
possible [8] 10/10
22/10 52/6 61/7
116/22 124/22 146/4
193/24
possibly [4] 19/25
150/9 158/22 158/22
post [240]
post-Horizon [1]
202/17
postmaster [34]
13/15 36/17 38/18
40/3 40/7 53/19 55/18
55/21 57/16 57/21
58/1 58/9 59/7 64/1
88/5 88/23 88/25
102/24 115/21 117/4
117/5 117/6 117/8
117/12 124/6 124/21
161/7 162/24 163/1
166/14 177/3 177/6
178/24 202/23
postmaster's [2]
53/13 88/5
postmaster-facing
[4] 13/15
postmasters [66]
9/21 10/8 10/9 12/6
13/2 17/5 17/11 19/1
37/24 39/5 39/12
39/19 39/21 40/11
42/24 52/15 53/11
54/18 54/24 59/1
59/11 59/13 59/15
59/19 65/14 75/4
75/20 80/12 81/9
81/17 85/20 86/22
88/24 91/24 102/15
102/17 112/13 112/18)
113/5 113/8 113/9
114/23 115/20 118/7
1421/1 122/7 129/11
130/9 135/8 135/11
135/13 141/18 143/9
143/11 155/4 155/15
156/16 186/24 193/23)
196/17 203/9 203/11
205/3 205/8 205/13
205/16
postmasters' [5]
57/2 75/4 75/20 86/22I
91/25
potential [15] 40/10
54/18 73/4 80/17 85/8)
85/14 95/20 95/21
101/15 109/17 119/18}
125/8 125/13 186/2
189/23
potentially [12] 49/12)
52/9 52/19 85/4 121/1
(76) phases... - potentially
P
potentially... [7]
137/17 149/19 152/1
154/1 182/3 187/20
195/9
pouch [2] 55/20
55/20
power [3] 146/10
175/17 176/2
powers [5] 135/25
148/18 149/14 149/15)
149/18
practical [3] 75/22
78/16 97/4
practice [13] 6/6
16/14 21/22 24/21
31/1 52/12 59/20
59/23 60/15 70/5
70/16 96/25 180/11
pre [7] 33/19 103/13
140/4 140/15 141/19
142/2 168/2
pre-1 January [1]
140/4
pre-2022 [1] 140/15
pre-date [1] 33/19
pre-dates [2] 141/19
142/2
pre-interview [1]
168/2
pre-NBIT [1] 103/13
preceding [1] 79/9
precise [1] 14/24
precisely [1] 95/18
predecessor [2] 58/3
58/5
predicated [1]
117/16
predominant [2] 89/2
89/9
Predominantly [2]
6/11 94/14
preferable [1] 113/10
preference [1] 201/8
prefers [1] 70/20
premises [1] 169/19
preparation [2] 102/3
137/16
prepare [1] 103/12
prepared [8] 42/19
42/23 150/18 151/21
197/7 198/11 198/25
202/4
preparing [2] 134/2
192/12
prescribes [1] 46/5
present [4] 100/9
112/2 112/5 112/25
presented [4] 121/2
152/25 162/19 202/6
preservation [1]
29/25
press [1] 193/15
presumably [8]
29/24 45/2 45/18 47/3
68/2 74/12 92/15
193/7
presumption [2]
37/15 96/5
presumptions [1]
37/20
pretty [4] 18/4 24/9
37/18 201/2
prevalent [1] 141/16
prevent [2] 9/22 13/2
preventing [1] 80/24
prevention [2] 10/2
45/16
previous [9] 20/19
34/1 39/16 92/18
129/20 152/6 182/14
203/1 208/8
previously [6] 12/15
48/17 104/4 116/12
144/24 157/2
primarily [2] 28/9
177/18
primary [1] 28/11
principal [2] 161/16
193/13
principally [6] 6/15
16/21 18/7 38/2 43/11
74/2
principle [1] 38/14
principles [5] 46/17
48/13 48/13 49/24
109/11
printout [1] 30/12
prior [13] 24/5 41/20
55/4 80/24 95/4
106/25 129/6 138/2
147/7 179/4 203/9
203/12 207/3
priorities [5] 93/7
93/12 94/25 103/10
192/8
prioritisation [3] 93/2!
93/18 101/11
prioritise [3] 79/23
101/9 158/5
prioritised [1] 80/23
priority [3] 93/21
192/10 192/11
private [6] 7/8 24/15
65/22 71/22 76/6
80/10
privately [1] 79/16
proactively [3] 109/9
109/11 188/13
probabilities [1]
117/3
probably [11] 18/16
20/9 20/12 27/8 31/24
90/3 123/2 137/11
141/25 155/17 160/3
problem [5] 11/22
12/1 12/1 61/20 114/4
problematic [1]
51/11
problems [2] 30/20
198/18
procedural [1] 44/24
procedures [3] 31/13
33/8 57/22
proceed [1] 160/7
proceeded [3] 91/1
99/19 159/23
proceedings [3]
37/25 72/19 148/10
proceeds [7] 86/19
86/20 86/23 87/5
87/12 88/1 115/22
process [38] 6/20
17/12 21/17 22/4 25/2
26/2 27/13 30/25
32/12 35/21 56/3 61/1
65/6 67/4 70/22 88/7
88/12 88/14 90/19
99/10 103/5 103/7
107/13 116/1 117/10
117/14 137/24 138/23
140/4 140/22 141/17
157/2 160/8 171/20
188/15 188/17 189/24)
194/16
processed [1]
124/17
processes [6] 31/13
38/2 65/8 106/22
149/4 149/22
processing [1] 117/1
Procurator [1] 208/9
produce [8] 40/5
133/22 145/13 150/24
153/6 174/18 187/3
197/12
produced [17] 1/14
2/21 8/16 9/24 10/12
24/5 68/19 115/12
125/21 133/18 133/24
133/25 144/10 150/16
173/7 180/6 184/20
producing [5] 73/5
125/19 133/2 133/8
173/16
production [6] 151/8
151/12 152/19 153/3
153/7 197/10
professional [3]
19/23 32/25 46/6
professionally [1]
48/1
profile [1] 21/24
programme [3] 29/6
103/24 194/2
progress [4] 82/24
119/15 132/13 136/6
progressed [2] 71/24
78/4
progressing [4]
92/22 119/7 127/1
127/16
project [35] 4/22
6/22 6/24 12/4 23/18
24/4 32/14 96/17 97/2
142/16 142/20 142/21
175/10 175/12 179/7
179/8 180/20 180/21
182/22 182/24 183/7
183/9 183/14 184/14
184/21 185/21 186/9
186/20 188/24 189/1
189/4 189/22 190/8
190/11 204/23
Project 2 [1] 180/21
projected [1] 93/11
projects [1] 16/13
prominent [1] 182/3
prompted [1] 153/7
pronounce [1] 204/5
proper [6] 22/4 45/16
112/12 112/14 167/18}
171/21
properly [6] 30/23
41/4 69/12 102/12
166/5 189/25
property [1] 75/22
proportion [3] 21/8
67/22 67/23
proposal [12] 29/16
29/17 39/6 49/18
69/25 75/18 80/14
82/4 83/17 84/22
161/5 184/12
proposals [2] 74/23
82/17
propose [2] 191/38
206/22
proposed [9] 29/8
33/24 34/22 39/15
71/22 76/7 129/9
137/23 192/20
proposes [3] 138/14
139/14 191/2
proposing [1] 84/25
pros [1] 106/8
prosecute [4] 56/19
112/17 129/11 181/4
prosecuted [2] 114/7)
129/15
prosecuting [5]
41/15 77/3 121/3
174/21 207/23
prosecution [12]
67/20 82/10 126/5
126/5 130/1 131/12
136/13 156/20 159/23}
174/17 186/7 200/23
prosecutions [16]
8/2 24/16 65/23 67/10)
71/22 72/15 76/7
80/11 84/25 91/12
130/8 138/1 154/3
154/10 159/12 201/1
prosecutor [13]
14/21 41/5 41/7 41/9
41/10 41/21 41/21
82/22 88/16 91/17
131/21 159/17 207/9
prosecutorial [1]
135/24
prosecutors [6]
76/10 82/23 86/13
91/2 91/6 121/6
prospect [1] 130/22
protect [1] 145/16
protected [2] 80/13
168/2
protection [2] 93/25
99/5
prove [2] 130/10
176/6
proved [2] 125/6
175/18
proven [1] 150/25
provide [47] 12/9
14/10 14/14 20/6
38/25 41/18 46/2
46/25 47/1 86/12
91/18 97/20 98/13
99/15 99/25 103/14
103/24 110/21 119/19}
121/25 134/21 135/11
136/4 139/7 139/8
142/23 146/17 147/1
148/4 148/9 148/13
151/21 152/9 161/1
166/4 166/9 168/4
173/1 173/25 177/24
188/23 195/12 196/4
196/7 197/8 198/11
198/18
provided [44] 1/13
8/5 8/21 8/22 31/7
35/9 37/23 40/11
45/24 53/2 53/19
55/16 66/7 66/9 94/19
96/18 109/20 109/24
110/20 117/23 120/9
121/16 127/17 130/13)
131/16 138/19 141/10}
151/4 152/14 166/18
167/5 167/20 168/4
168/9 170/22 179/7
183/12 189/10 192/2
195/23 197/6 200/18
203/17 207/22
providers [1] 146/1
provides [8] 3/22 4/6
14/16 30/11 151/12
153/3 167/10 183/1
providing [5] 97/3
138/15 138/18 163/3
174/11
provision [14] 36/1
104/8 106/10 107/1
109/13 110/18 121/4
149/24 150/3 165/21
167/14 180/15 196/3
(77) potentially... - provision
P
provision... [1] 198/3
provisional [1] 29/17
PSNI [1] 83/23
public [12] 79/25
80/13 80/25 86/5 91/5
91/12 91/20 99/5
121/3 130/17 157/21
207/9
purpose [14] 25/17
25/24 41/1 54/19 63/2
70/17 72/20 72/22
107/5 109/13 132/2
161/9 161/11 194/25
purposely [1] 181/21
purposes [2] 190/4
192/5
pursue [6] 76/6
86/18 135/7 136/12
136/14 153/10
pursues [1] 18/13
pursuing [1] 17/20
push [1] 121/13
put [14] 13/10 29/16
36/7 45/21 60/12 77/7
81/15 141/25 173/3
173/19 187/15 192/21
203/24 203/25
putting [2] 112/20
133/17
pyramid [1] 54/5
Qu
qualification [1] 7/17
qualified [2] 24/20
48/1
qualifying [1] 189/6
quality [6] 20/5 26/6
27/7 93/21 99/25
185/6
Quarm [1] 11/9
quarterly [1] 112/3
quarters [1] 143/16
queried [3] 85/17
101/9 102/2
question [11] 37/4
61/17 64/14 72/13
108/15 110/25 132/5
155/16 174/6 194/8
205/2
Questioned [8] 1/9
191/15 202/12 206/15}
210/4 210/6 210/8
210/10
questioners [2]
191/1 191/4
questioning [1]
209/11
questions [19] 28/8
127/11 127/18 127/19}
128/5 171/20 190/22
190/23 191/18 191/24
194/18 196/21 200/2
202/13 202/16 203/24)
204/2 208/16 209/10
quicker [1] 187/10
quickly [4] 151/24
152/1 184/23 189/2
quite [6] 9/10 74/17
114/1 119/3 144/8
166/2
quote [1] 129/13
R
race [2] 4/22 179/8
racist [1] 179/18
Railton [1] 193/3
raise [2] 135/5
157/12
raised [21] 61/1
89/22 90/10 97/7
102/15 113/4 113/14
115/14 115/16 136/8
145/22 146/2 152/5
157/10 159/3 159/6
164/9 169/11 176/11
185/15 185/19
raising [2] 140/18
1814/3
range [4] 61/11 75/21
90/14 185/19
rank [1] 7/5
rapid [3] 112/10
112/19 113/1
rather [8] 7/17 87/2
92/8 100/16 113/4
120/17 181/17 197/17)
rationale [3] 13/22
76/11 139/25
reach [4] 13/17 67/23
132/3 167/16
reached [2] 67/20
122/23
read [22] 8/16 21/19
54/13 57/5 61/3 85/17)
95/1 101/9 106/3
114/6 114/18 119/2
124/3 126/16 135/3
136/21 144/18 168/1
171/2 171/5 181/10
187/14
reading [6] 110/12
118/12 122/10 132/8
172/14 197/5
realise [2] 142/24
153/25
realistic [3] 130/22
159/11 190/25
realistically [3] 154/5
154/9 168/25
reality [3] 62/5 73/4
142/1
really [14] 10/3 10/3
15/25 37/3 50/19
51/17 62/2 109/4
117/13 119/15 155/6
164/7 168/22 193/5
rearranged [1]
205/11
reason [10] 32/13
88/7 88/8 109/23
134/14 144/9 160/21
166/4 166/22 186/22
reasonable [4] 40/10
129/17 170/12 171/11
reasonably [3] 95/5
102/13 172/23
reasoning [4] 126/25
127/4 127/6 127/7
reasons [4] 164/5
196/9 203/10 207/21
reassessing [3]
194/1 194/6 194/7
recall [1] 170/17
receipt [3] 16/2 78/21
86/5
receive [1] 8/1
received [9] 42/15
56/17 146/19 176/11
176/12 177/15 189/6
197/15 205/21
receives [1] 151/14
receiving [1] 25/4
recent [5] 12/12 80/6
135/17 192/2 205/11
recently [2] 190/5
197/6
recognise [1] 178/16
recognised [1] 73/16
recognition [1] 32/25)
recommend [1]
158/4
recommendation [2]
26/18 51/24
recommendations
[8] 6/7 69/21 92/19
115/17 115/24 180/7
187/2 187/7
recommended [4]
25/6 69/14 93/10
106/24
recommending [1]
122/4
Reconciliation [1]
93/24
record [3] 139/25
203/7 204/18
recorded [4] 140/1
169/1 182/7 204/17
recording [4] 165/7
168/13 168/15 168/21
recordkeeping [2]
54/22 185/7
records [9] 24/21
144/24 145/24 150/3
150/21 150/24 151/9
152/2 196/4
recouped [1] 113/9
recourse [1] 80/10
recover [5] 72/21
72/25 86/16 87/10
115/19
recoverable [2] 85/4
85/10
recovered [1] 85/14
recoveries [4] 72/1
72/7 72/11 99/16
recovery [14] 72/16
72/18 86/17 86/17
86/24 87/6 87/10
87/15 87/19 87/21
87/25 88/7 115/9
117/16
recreate [2] 182/20
208/9
recruit [1] 69/20
recruited [2] 7/19
184/9
recruitment [1] 185/8I
redraft [1] 49/16
redress [1] 14/8
refer [6] 33/24 82/10
86/6 115/10 117/9
204/15
reference [11] 2/18
3/18 20/10 72/14
76/15 123/23 155/6
155/19 161/2 176/4
186/8
referenced [2] 86/4
119/6
references [1]
192/25
referencing [1]
101/11
referral [6] 75/14
80/24 84/4 92/5
102/23 186/11
referrals [4] 54/10
80/17 101/6 188/13
referred [10] 102/21
113/18 125/20 126/14}
133/3 133/9 172/6
177/17 185/24 205/20}
referring [6] 74/5
74/5 85/2 116/16
134/15 192/4
refers [3] 54/11 57/5
57/7
reflect [1] 110/9
reflected [2] 123/6
175/25
reflections [1] 8/20
refrain [1] 175/19
refresher [4] 28/4
28/10 29/3 29/11
refuse [1] 178/13
regard [3] 18/19 62/4
167/23
regarding [14] 89/22
124/19 125/13 125/18
133/1 133/7 137/23
148/4 150/15 168/3
168/8 173/16 196/10
202/22
regards [2] 76/20
108/22
region [2] 66/10
66/19
regular [2] 6/3
180/10
regularly [2] 19/18
116/2
regulation [2] 47/8
186/11
regulator [4] 7/9 7/23)
208/8 208/11
regulators [2] 7/11
60/5
regulatory [1] 135/24!
reinforce [1] 205/8
reinforced [1] 8/23
reinvestigate [1]
186/23
relate [8] 45/22 49/25I
55/12 68/25 70/18
160/4 194/22 195/11
related [6] 1/15 16/3
124/23 159/13 183/15)
187/17
relates [8] 39/14
65/14 86/2 114/14
118/22 130/8 189/23
199/19
relating [19] 8/2 9/8
19/1 19/3 29/25 40/24I
47/2 55/7 106/19
121/23 124/1 125/21
154/25 179/8 182/15
184/10 185/23 189/17
203/12
relation [22] 8/25
37/11 48/25 84/23
87/20 102/16 126/6
126/21 136/15 144/3
148/11 181/16 182/21
189/8 195/25 198/3
198/10 198/12 199/10)
200/16 200/25 202/6
relations [5] 52/4
185/25 186/16 188/6
188/18
relationship [3] 84/3
91/8 119/1
relatively [5] 21/1
96/10 128/19 154/2
184/23
relevancy [2] 42/1
42/10
relevant [20] 21/3
75/12 78/24 81/2 92/4I
112/16 116/17 116/17
121/4 140/25 145/18
145/19 150/17 150/17)
152/2 162/21 166/9
166/18 196/1 196/11
reliability [23] 40/24
89/22 120/24 121/7
122/3 129/25 131/10
(78) provision... - reliability
R
reliability... [16]
136/5 140/24 142/17
142/22 146/7 146/11
147/2 148/4 148/7
148/11 150/15 158/11
159/4 171/20 174/9
174/11
reliable [11] 10/9
85/20 89/25 118/15
121/21 127/21 144/8
160/5 191/17 198/25
199/4
reliance [2] 111/24
130/10
reliant [2] 145/5
149/24
relied [5] 89/24 131/2
154/17 158/17 160/9
relies [1] 159/18
reluctance [1] 208/2
rely [9] 110/15
117/18 131/12 132/9
134/9 142/19 142/22
143/10 159/20
relying [1] 167/23
remain [5] 12/16
92/20 96/7 102/17
180/10
remained [3] 57/23
86/18 89/23
remaining [2] 12/17
166/19
remarks [1] 209/12
Remediation [2] 14/5
14/6
remedy [1] 162/13
remember [4] 14/18
84/15 154/18 159/16
remit [12] 26/24 75/5
75/19 75/24 76/1
79/12 84/20 91/25
102/10 134/13 165/12)
183/5
remittance [1] 124/7
remote [5] 148/17
149/11 149/14 149/15)
154/9
remotely [1] 209/5
remove [5] 4/1 13/9
36/6 106/25 190/14
removed [3] 9/16
181/21 208/15
removing [1] 140/21
remuneration [2]
113/7 113/10
renamed [1] 9/18
repaid [1] 86/20
repairs [1] 196/24
repay [2] 115/22
115/22
repayment [3] 114/2
4117/7 117/11
repeat [1] 188/17
rephrase [1] 74/2
replace [1] 4/1
replacement [1] 96/3
replacing [1] 158/6
replied [5] 85/19
89/24 101/10 101/14
102/4
report [42] 20/8 22/2
22/15 23/8 23/22 24/4
28/19 40/5 66/2 68/25
69/3 69/4 69/9 71/10
71/11 72/6 74/16 76/9)
78/23 79/12 83/16
83/24 92/12 92/13
96/22 97/18 97/19
106/2 109/16 122/7
137/21 155/2 155/3
165/10 170/19 170/20)
179/12 180/6 184/20
185/2 207/1 207/8
reported [16] 55/6
55/12 55/18 55/19
66/20 67/11 67/15
67/18 68/3 68/4 79/5
116/16 155/23 176/20)
176/20 207/10
reporting [23] 16/9
26/4 27/16 40/4 55/4
56/1 71/8 79/8 83/13
83/22 88/23 89/1 89/3
89/11 93/1 96/22 99/9)
109/11 157/4 205/7
207/5 207/15 208/5
reports [17] 7/1 8/16
12/12 16/2 22/18 40/7
42/25 43/12 56/17
70/21 71/11 74/18
79/18 80/5 89/10
170/18 170/23
repositories [1]
151/16
represent [3] 45/12
191/21 206/17
reprioritising [3]
194/2 194/6 194/7
reputation [3] 73/18
74/1 74/13
request [7] 12/11
101/2 107/7 140/11
148/14 166/19 209/5
requested [9] 18/16
84/19 125/18 133/1
133/7 133/12 140/2
173/15 196/5
requesting [3] 16/9
124/18 139/5
requests [9] 82/7
103/2 103/5 103/7
103/18 105/2 166/14
195/25 196/15
require [1] 192/17
required [18] 24/17
24/24 29/4 32/23 33/1
44/20 69/22 80/11
94/5 95/6 96/7 102/5
103/23 144/2 148/23
151/14 174/15 182/4
requirement [4]
35/25 36/6 156/21
207/9
requirements [3]
28/25 95/8 157/25
requires [5] 83/3
93/19 106/14 109/15
136/4
requiring [1] 99/3
reservations [1]
200/15
reset [1] 97/16
Resolute [1] 73/20
resolution [5] 40/5
93/23 142/8 169/22
185/11
resolve [1] 95/20
resolved [7] 54/6
67/2 67/7 91/22 103/9
172/22 172/25
resolving [1] 143/10
resource [10] 79/24
80/21 99/2 101/3
102/4 102/8 102/12
102/13 103/14 104/3
resourced [5] 69/12
93/20 94/7 94/10
153/10
resources [1] 79/24
resourcing [5] 93/3
94/18 94/19 97/9
100/23
respect [39] 6/15
14/11 14/14 16/5
26/14 27/6 41/5 43/7
56/14 60/5 61/1 63/7
67/12 67/13 92/22
93/2 94/12 94/12
98/11 104/17 112/6
120/6 126/2 127/11
127/18 129/1 133/19
134/8 136/9 150/2
151/5 152/22 156/19
158/11 162/9 182/12
184/14 184/21 196/16)
respect of [1] 129/1
respectfully [2]
151/11 166/13
respects [1] 78/12
responded [1]
197/10
respondents [1]
155/13
response [8] 10/2
137/12 137/13 137/16
166/11 167/24 169/16}
207/19
Responsibilities [1]
10/7
responsibility [11]
17/18 32/8 32/17
36/13 38/4 43/24 63/6
63/7 76/1 171/1
176/22
responsible [18]
9/13 16/23 17/20
22/24 23/3 33/4 57/25)
62/18 63/17 63/21
63/23 73/8 74/4 111/4
113/6 176/17 176/19
181/8
rest [4] 63/1 63/3
69/20 166/14
restitution [6] 76/12
76/16 76/18 77/9
77/19 77/21
restrained [1] 125/4
restricted [1] 42/17
result [5] 50/21 95/22)
157/20 183/11 208/14,
resulted [1] 55/23
resulting [6] 51/22
80/22 121/8 121/10
122/10 165/11
results [1] 155/5
resume [1] 175/3
retail [43] 6/2 6/5 6/8
6/9 9/22 13/3 16/17
16/21 16/25 17/5
17/15 17/23 18/3
18/24 19/7 30/15 31/1
31/10 31/17 31/25
38/3 38/5 40/1 45/23
59/7 59/21 60/23
64/12 67/3 75/25 76/2
78/11 86/2 90/20
97/22 116/15 140/23
141/3 143/2 143/7
155/23 162/15 162/22}
retained [3] 24/22
42/19 145/6
retains [1] 150/20
retention [2] 42/14
43/3
return [2] 124/7
125/16
reveal [1] 42/20
revealing [1] 193/17
review [21] 6/3 13/6
17/12 25/1 57/17
96/16 116/1 117/14
127/19 151/16 181/1
186/10 186/23 186/25
187/10 187/18 188/8
193/19 193/21 204/24}
208/12
reviewed [6] 73/9
126/18 126/25 130/25}
166/6 186/7
reviewing [2] 57/16
140/21
reviews [1] 186/20
revisit [1] 58/22
revolves [1] 161/9
right [56] 9/6 11/3
12/14 14/4 15/10
15/21 16/20 17/9
22/20 25/14 33/17
34/22 36/5 49/16
59/25 61/6 61/19
63/17 65/23 68/9
T4I17 74/23 108/18
117/21 120/4 120/5
125/17 132/24 133/6
170/16 171/24 172/9
172/14 174/6 175/2
175/6 176/17 179/13
183/7 185/2 191/6
191/8 192/19 195/1
195/18 197/19 198/10}
199/10 199/17 199/25)
203/3 206/14 207/24
208/22 209/2 209/11
right-hand [2] 11/3
25/14
rightly [2] 121/5
159/19
rights [3] 86/22
93/25 180/4
rigour [2] 142/16
142/22
rise [2] 112/19 113/1
risk [16] 9/19 11/18
18/7 20/17 25/23
71/15 71/16 78/13
98/8 109/20 110/2
110/7 110/19 139/16
157/19 157/22
risky [1] 158/2
Robert [1] 11/6
Roberts [5] 90/2 90/2
90/8 90/10 90/13
Roberts’ [1] 90/11
robust [5] 106/22
117/17 128/19 128/23)
129/6
robust' [1] 141/14
robustness [9]
125/18 125/22 128/20)
133/1 133/7 133/19
133/23 148/7 173/16
role [15] 5/17 5/18
6/2 9/1 9/17 9/22 15/7
15/25 24/10 52/17
87/22 97/6 119/21
208/5 208/8
roles [9] 7/13 12/25
13/1 13/10 13/15 19/1
77/13 77/14 183/5
rolled [1] 96/6
rolling [1] 95/4
rollout [7] 95/10
97/14 97/16 98/6
101/5 103/13 103/23
room [1] 187/25
root [3] 6/21 77/8
87/10
rooting [1] 167/6
(79) reliability... - rooting
R
round [1] 175/4
routine [1] 154/2
row [1] 22/12
Royal [3] 179/15
179/20 179/23
rule [2] 156/25
156/25
ruled [1] 127/23
run [7] 55/19 65/6
107/24 108/19 108/23
1411/7 124/5
running [3] 28/6
95/14 108/20
rush [1] 191/9
s
Saf [5] 175/10 175/16)
190/5 202/24 203/6
safe [1] 13/6
safeguard [1] 116/14
safety [1] 131/1
said [27] 9/18 11/25
13/25 25/11 48/17
51/19 65/25 66/3 73/1
108/1 108/19 113/22
115/4 118/5 136/11
145/7 150/22 158/25
163/24 176/13 181/20
198/23 198/24 199/2
199/3 201/14 205/11
sake [1] 190/18
same [27] 20/7 21/4
54/20 68/21 70/17
71/6 71/8 86/25 91/8
92/21 96/7 98/19 99/1
101/8 123/25 124/12
124/19 133/5 133/11
133/14 133/15 140/4
145/8 146/24 158/18
189/20 190/4
sample [5] 3/13 6/4
6/6 167/1 180/23
Sarah [16] 8/8 8/9
22/15 22/22 22/24
33/6 73/7 73/9 84/13
84/19 92/16 100/9
101/14 143/19 176/20
176/21
sat [1] 170/20
satisfaction [1]
64/22
satisfied [1] 156/23
satisfy [2] 132/9
160/4
save [1] 209/7
saved [1] 53/9
saving [2] 104/18
104/19
savings [1] 101/17
saw [16] 66/15 85/25
91/10 92/18 96/22
115/13 122/21 137/4
137/10 137/11 138/8
138/21 147/15 153/21
169/16 176/18
say [87] 3/12 9/13
9/21 10/3 12/8 15/10
15/21 16/5 16/23 17/4
18/12 19/13 21/4
21/20 22/20 22/22
27/19 32/8 32/10
32/14 32/17 34/8 35/2
35/20 37/7 38/6 38/11
41/10 41/24 43/24
49/17 49/19 50/21
50/23 51/11 52/13
58/23 65/12 65/15
66/19 70/12 71/1
74/17 75/6 96/9 98/8
104/14 114/14 118/4
118/16 120/8 126/10
128/2 128/5 129/8
129/22 130/6 144/9
147/5 147/19 147/25
148/18 151/17 152/23)
155/8 156/9 157/12
162/12 162/16 163/10)
164/2 164/10 164/21
164/22 171/14 171/2
171/22 173/14 174/15)
191/12 193/25 196/13)
198/18 201/22 204/6
204/12 205/15
saying [25] 51/12
110/5 111/6 122/11
132/6 132/11 134/14
1414/5 170/7 173/18
174/18 186/23 191/7
192/7 194/5 197/7
197/20 198/14 198/17,
200/22 200/22 201/7
201/8 206/10 207/19
says [77] 2/5 10/6
35/1 46/14 46/23
56/15 57/9 59/2 69/7
69/23 71/20 73/14
79/14 80/8 80/14 82/4
82/19 84/12 84/16
86/9 92/17 93/5 93/18)
97/16 98/12 99/5
101/1 103/16 106/11
109/6 110/17 112/8
113/3 113/24 114/19
120/21 124/4 126/17
128/16 128/21 128/24)
129/14 130/15 130/23)
135/4 138/10 139/4
139/13 139/17 139/19}
140/8 142/4 144/20
149/10 151/7 156/6
156/7 156/12 157/16
160/19 161/23 162/41
163/7 165/9 165/24
166/12 167/17 168/1
175/15 178/4 178/10
183/7 185/18 195/24
200/24 201/18 203/6
scale [5] 20/23 20/25
21/4 21/7 93/22
scaled [1] 102/2
scaling [1] 102/7
scandal [13] 9/1 74/4
130/7 130/17 130/18
130/20 154/11 154/16
154/22 191/20 193/12]
193/14 202/17
scenario [1] 51/23
scene [1] 112/2
schedule [6] 172/4
172/7 172/8 172/14
174/19 199/19
scheme [1] 70/19
scientific [1] 180/25
scope [1] 183/9
Scotland [14] 81/3
82/17 83/20 84/2
106/7 106/19 107/9
206/20 207/5 207/9
207/16 208/2 208/9
208/11
Scotland's [1]
207/13
screen [6] 36/22 56/7
123/17 155/1 155/9
175/11
scroll [57] 24/12
25/20 27/5 27/18
34/20 39/18 45/9
45/25 57/7 69/6 70/14
71/13 71/20 73/12
74/25 75/15 77/22
78/20 84/18 85/16
88/18 91/4 92/19
93/17 95/1 100/19
100/24 112/4 113/24
126/17 128/1 129/4
131/8 133/4 133/13
138/10 139/2 140/8
140/13 147/25 151/3
151/7 151/24 152/1
156/4 156/12 157/11
161/23 162/1 164/22
164/25 165/4 165/8
166/11 167/13 167/24
175/14
Scrolling [2] 148/16
166/3
scrutiny [1] 57/20
search [1] 188/3
second [18] 2/12
2/21 3/12 9/12 10/15
11/24 18/18 36/22
66/2 99/14 123/17
125/17 132/24 133/6
183/3 189/15 204/3
206/21
section [18] 39/9
46/13 48/21 49/4
93/17 97/15 115/15
124/3 128/16 128/20
128/24 131/16 133/10
139/19 148/16 167/21
179/23 185/17
sections [3] 45/22
57/18 128/15
sector [1] 7/9
security [14] 9/9
10/22 10/24 12/10
12/15 13/7 18/24
18/25 58/6 66/14 74/3}
74/3 74/9 189/17
see [43] 10/23 11/22
12/1 22/8 22/11 22/13}
23/12 24/8 24/13
25/20 34/7 34/17 38/4
41/13 45/9 46/1 57/5
57/7 69/7 72/14 73/14,
74/25 75/24 84/11
87/22 88/17 92/19
93/17 109/6 112/5
119/6 124/1 125/16
137/7 139/2 155/24
157/12 179/2 181/1
187/14 199/18 203/3
209/13
seeing [5] 54/11 90/5
90/17 112/10 112/19
seek [7] 31/5 55/25
71/25 72/10 76/12
79/2 159/20
seeking [10] 69/20
72/7 76/16 82/20
110/15 110/23 136/12)
168/12 174/8 195/5
seeks [1] 79/10
seem [10] 114/14
194/9 194/12 197/17
198/2 198/16 198/19
201/19 202/2 202/3
seemed [3] 25/7 25/9
208/1
seems [10] 17/6
77122 87/12 127/5
136/7 166/19 194/10
194/13 198/13 202/18
seen [20] 25/8 52/8
61/15 72/18 88/20
88/25 90/14 115/16
119/2 136/21 142/9
144/17 150/5 152/6
155/2 165/5 165/20
197/1 198/8 198/9
Sefton [1] 11/15
SEG [16] 6/17 20/9
20/11 20/11 22/22
35/6 35/11 35/14
43/25 73/1 87/20
89/12 137/23 143/25
173/10 189/10
selective [1] 189/11
self [1] 80/10
self-sufficiency [1]
80/10
send [1] 124/16
senior [15] 6/16
15/14 20/13 43/11
44/1 89/7 137/22
160/18 160/20 169/13}
169/14 175/18 189/10}
199/3 207/13
sense [6] 25/7 42/6
145/13 172/13 173/18)
184/7
senses [1] 120/2
sensitive [6] 6/25
49/22 62/4 64/25 78/5
78/7
sensitively [1]
205/21
sensitivities [2] 64/7
111/6
sensitivity [3] 54/21
61/25 110/13
sent [5] 83/7 83/9
144/20 166/15 167/2
sentence [4] 2/4 3/11
3/19 122/11
separate [3] 6/24
59/5 179/7
separately [2] 5/24
74119
separation [1] 185/8
September [8] 4/19
44/11 65/23 75/16
92/12 123/24 172/10
195/24
series [2] 197/18
203/16
serious [5] 50/12
135/6 136/8 153/15
197/21
seriousness [1]
50/14
service [13] 10/6
10/9 20/6 82/10 89/3
91/6 93/11 101/3
126/5 126/5 157/17
186/6 190/12
services [7] 19/23
145/5 149/24 157/15
157/21 158/6 174/24
session [2] 31/19
31/24
sessions [1] 14/18
set [12] 24/1 25/2
37/2 51/18 66/10
101/11 103/14 112/2
115/25 128/15 131/14)
168/7
sets [16] 10/22 24/25
25/10 32/2 46/20
62/24 63/4 64/9 69/4
69/21 79/14 101/7
115/3 149/14 150/1
183/4
setting [2] 43/13
193/15
settle [2] 60/19 96/17
(80) round - settle
Ss
seven [1] 48/12
several [2] 71/10
122/17
SG [2] 84/19 88/19
share [3] 144/12
147/19 200/10
shared [8] 86/11
101/16 109/14 109/20}
112/22 134/5 139/11
187/4
shareholder [2]
80/12 112/3
sharing [2] 40/2
107/3
she [6] 22/2 22/18
71/10 71/11 103/6
103/6
she's [1] 17/2
Sherratt [2] 101/13
104/23
short [6] 58/19 95/9
111/19 128/7 160/12
175/8
shortage [1] 125/5
shortfall [12] 16/4
55/13 124/22 130/3
130/4 162/13 162/13
162/20 163/24 164/4
169/22 202/6
shortfalls [18] 15/23
16/19 19/3 19/7 37/11
37/24 38/3 95/20
112/10 113/8 114/14
128/10 130/9 135/14
141/18 149/6 163/11
201/1
shorthand [1] 48/7
shortly [2] 151/4
172/11
should [49] 3/12
13/13 13/14 17/21
22/1 32/1 32/15 38/17,
40/2 42/18 42/19
42/19 42/23 44/8 45/7)
A7IN7 47/19 47/20
54/12 69/9 72/6 79/5
101/17 102/5 109/25
122/2 122/5 122/8
132/13 140/5 140/10
141/5 141/6 144/12
149/23 155/17 155/25
156/15 156/25 158/5
159/19 164/24 184/12)
187/22 200/25 201/4
201/14 202/5 209/10
shouldn't [10] 42/17
51/12 81/24 108/6
109/4 144/12 146/12
201/16 201/18 207/24
show [6] 42/23 42/25
42/25 118/2 123/4
204/18
showed [1] 120/10
shown [6] 37/12
123/7 141/20 154/16
179/4 203/11
shows [2] 67/1 67/2
sick [1] 47/17
side [8] 6/25 11/3
22/12 25/14 50/6 71/9
116/14 133/17
Sight [1] 66/2
sign [3] 83/21 106/14
106/18
sign-off [2] 106/14
106/18
signature [3] 1/23
3/5 5/2
signed [2] 122/8
131/20
significance [2]
31/22 173/12
significant [15] 6/20
25/13 42/11 42/13
52/20 95/5 95/11
95/25 122/8 127/5
142/5 142/11 142/14
153/25 171/21
significantly [2]
80/25 81/18
similar [8] 72/8 74/18
76/23 82/17 103/2
134/2 149/7 203/23
Simon [8] 31/3
119/16 133/25 134/1
134/12 140/20 143/5
144/5
simpler [1] 105/18
simplest [1] 167/5
simply [4] 97/10
102/6 178/17 205/8
since [17] 8/13 11/5
11/8 11/12 56/21
66/12 66/23 68/5
77/13 81/13 103/20
104/8 115/20 117/22
147/8 193/2 200/6
Sinclair [1] 206/18
Singh [1] 14/1
single [7] 34/2 71/7
83/22 84/1 84/4
119/11 138/12
sir [31] 1/3 4/1 4/8
21/15 22/4 58/12
58/21 61/5 61/24
62/16 68/12 68/21
108/17 111/12 111/21
171/17 172/5 172/8
172/15 172/21 173/22!
174/15 175/1 175/4
190/22 191/13 191/16)
202/10 206/13 208/21
209/14
sit [8] 12/10 15/24
17/2 44/21 81/22
191/8 191/10 209/1
sits [4] 14/6 22/22
29/14 140/9
sitting [2] 102/24
209/3
situation [7] 54/23
60/6 85/18 124/24
195/19 202/3 202/7
situations [1] 63/14
six [3] 168/16 168/22
169/1
skewed [2] 190/1
194/23
skewer [1] 195/3
skewing [4] 194/24
195/7 195/13 195/15
skilled [4] 80/21
Skinner [1] 11/14
skip [1] 184/23
slightly [12] 74/15
74/23 76/14 84/18
98/25 111/9 111/25
126/17 169/6 175/14
192/14 198/2
small [3] 21/2 21/6
182/19
smaller [2] 54/8
66/16
so [353]
software [1] 149/5
solely [2] 142/17
159/18
solicitors [2] 22/1
186/11
solution [1] 158/8
solutions [2] 113/4
113/8
solve [1] 176/3
some [52] 7/15 8/18
11/17 12/14 14/17
17/15 35/8 35/16
36/25 40/1 42/5 43/6
43/17 44/17 50/10
61/14 63/14 66/7 68/1
78/14 90/7 95/13
98/10 102/22 104/7
108/3 110/9 118/13
120/2 120/10 126/7
134/25 135/2 148/20
162/5 171/9 173/23
177/22 182/14 185/21
186/18 186/22 189/17
190/22 192/2 199/12
200/5 200/13 202/21
203/4 205/9 205/10
somebody [7] 47/3
50/9 51/11 53/4 64/11
131/18 167/7
someone [11] 21/25
47/15 47/17 61/23
64/11 71/11 79/4 84/5
179/22 189/5 201/16
something [51] 15/1
16/18 20/15 25/8 30/9}
31/2 32/21 38/13
39/23 41/17 43/14
46/22 47/4 48/16
48/18 49/7 50/11 51/8)
53/8 53/15 55/4 55/9
55/15 60/12 62/7
63/15 63/21 70/8
70/24 86/1 87/3 94/13)
95/13 96/17 106/5
121/22 127/14 134/5
141/5 141/24 143/8
144/13 146/10 147/16)
153/24 155/5 155/25
167/2 170/1 186/21
203/5
sometimes [5] 20/3
51/5 77/16 80/4 145/8
somewhere [2] 54/13)
81/7
soon [3] 24/10 29/11
53/6
sorry [38] 6/24 8/10
13/20 15/5 18/14
18/15 21/14 21/16
27121 34/23 44/22
62/15 64/7 68/4 68/8
70/14 72/13 83/9
87/15 89/8 89/16 90/4
99/12 100/13 100/22
105/24 108/12 108/14}
110/7 123/1 123/9
125/3 153/21 155/16
155/17 166/24 177/16}
206/9
sort [13] 6/15 50/6
54/5 54/22 62/12 80/1
118/2 118/4 134/13
140/22 171/9 183/22
199/12
sought [8] 75/1 106/4I
106/18 109/25 110/4
117/12 137/23 182/9
sound [1] 91/3
sounds [2] 187/10
195/19
source [2] 134/16
143/11
space [9] 6/5 17/16
17/23 40/1 42/22
47/20 59/21 60/23
143/2
speak [14] 7/1 23/5
23/10 52/2 53/11
54/17 88/20 89/3
89/10 120/12 177/8
177/9 177/11 190/12
speaking [3] 61/3
66/9 90/1
Specialist [3] 207/5
207/15 208/5
specific [7] 65/4
89/13 89/13 91/13
146/11 156/17 198/22)
specifically [4] 37/10
130/8 145/17 184/9
specified [1] 126/12
specify [1] 167/21
speed [2] 25/12
190/3
spend [1] 46/13
spending [1] 104/12
split [1] 179/15
spoke [5] 70/8 101/2
104/14 106/5 153/19
spoken [7] 31/11
62/8 91/5 147/7
147/24 176/25 200/13)
staff [27] 6/16 19/15
19/18 20/14 23/13
28/13 39/14 50/23
63/12 75/3 75/4 75/20
75/20 79/11 80/12
86/22 88/23 88/25
91/24 91/25 106/23
169/14 185/12 185/13}
186/25 196/17 206/23}
staffed [2] 75/16 95/8)
staffing [2] 94/14
102/10
stage [16] 34/8 35/2
43/8 67/20 67/23
93/13 96/5 96/14 98/3
108/20 122/2 127/14
127/16 153/8 164/8
183/2
stakeholders [1]
193/20
stamp [1] 114/12
stance [1] 197/22
stand [2] 49/3 188/25)
standard [3] 24/19
57/2 199/8
standards [5] 45/15
46/6 63/4 109/15
204/13
stands [1] 160/6
start [14] 17/23 48/23}
51/5 69/2 95/16 98/2
98/25 114/22 160/16
165/18 172/24 192/14)
194/1 194/6
started [4] 28/22
81/13 183/19 187/16
starting [3] 31/25
197/19 208/23
state [2] 41/9 187/12
statement [99] 1/18
1/25 2/13 2/16 2/21
3/7 3/11 3/16 4/14
4/19 5/4 9/12 9/21
11/24 12/7 13/25
15/18 17/5 17/7 18/6
19/13 24/2 27/25 28/9)
33/10 36/23 36/24
37/2 40/20 45/7 55/21
56/11 62/22 66/4 66/7I
66/22 66/24 68/20
116/6 121/17 121/25
123/18 123/20 123/21
(81) seven - statement
Ss
statement... [55]
125/18 125/19 125/21
126/8 132/18 133/1
133/2 133/7 133/8
133/19 133/23 134/2
134/4 134/8 134/13
136/4 136/6 141/24
144/6 145/10 145/14
145/15 145/20 146/2
148/4 148/6 150/14
152/16 153/1 153/6
165/25 173/1 173/3
173/6 173/12 173/15
173/17 173/20 174/1
174/19 179/8 179/13
181/20 192/3 192/6
192/24 195/20 195/23}
197/6 197/12 198/18
199/11 203/6 203/19
204/4
statements [11] 1/14
43/1 97/25 121/4
154/21 174/23 196/5
196/6 197/8 198/4
199/18
states [1] 157/23
stating [1] 136/5
statistics [1] 159/22
status [9] 44/7 111/1
136/19 157/18 161/10}
189/19 207/20 207/22)
207/25
statute [1] 24/24
Staunton [2] 108/21
171/3
stay [2] 49/24 73/11
stead [1] 47/16
steal [1] 114/6
Stein [5] 191/2
191/14 191/15 195/16}
210/6
step [2] 21/20 199/7
Stepping [1] 158/19
Steve [2] 11/10
175/23
stick [1] 137/18
still [26] 8/9 11/17
12/24 19/1 19/3 26/23}
30/7 34/7 43/9 68/18
86/16 95/23 98/1
98/18 100/5 104/6
108/9 108/15 113/23
137/19 158/21 159/2
175/23 200/7 203/11
205/12
stitched [1] 126/20
stock [4] 95/4 95/21
114/12 169/23
stole [1] 86/22
stone [1] 98/3
stood [1] 169/2
stop [6] 9/13 162/21
164/16 164/19 164/19)
176/2
stopped [2] 9/15
164/1
straight [1] 67/5
straightforward [1]
167/9
strategic [8] 6/17
20/9 91/7 96/16
153/17 153/22 173/10)
193/19
strategical [1] 16/16
streamline [1]
138/23
streamlining [1]
138/15
strength [1] 82/23
stretched [1] 83/2
strictly [1] 41/14
stripping [1] 208/4
strong [5] 82/10
182/22 200/15 201/2
201/3
strongly [2] 12/4
158/4
structurally [1] 96/24
structure [4] 12/11
36/7 86/10 108/24
structured [1] 60/20
struggle [2] 80/4
107/25
Stuart [4] 14/4
stuff [3] 51/4 70/21
126/20
style [1] 203/23
sub [1] 16/6
subject [9] 2/15 4/15
21/19 46/22 46/23
55/22 66/3 131/3
172/2
subjects [1] 195/18
submission [3] 16/2
143/25 186/3
submit [1] 173/4
submitted [6] 80/5
126/4 170/18 170/19
173/21 174/21
submitting [1] 16/5
subpostmaster [16]
12/25 17/8 38/11
38/12 52/13 55/8 57/1
90/9 160/14 161/3
161/5 162/10 162/18
182/10 182/12 206/19)
subpostmaster-facin
g [1] 12/25
subpostmasters [18]
11/20 13/11 17/21
18/13 19/3 38/10
52/16 52/18 54/15
60/7 63/9 156/14
156/20 159/9 177/2
177/21 184/6 191/22
subsequent [3]
51/10 138/1 204/22
subsequently [2]
8/20 201/17
subset [1] 54/8
substantial [1]
140/19
substantive [4] 1/20
2/25 3/24 26/18
subteam [1] 15/13
successful [3] 146/5
154/10 159/11
successfully [1]
206/19
succinctly [1] 144/5
such [20] 8/2 14/8
15/22 18/4 30/1 30/23}
31/10 48/3 64/5 65/2
133/18 135/9 136/6
148/13 148/14 149/18
150/13 161/8 178/5
196/6
sufficiency [1] 80/10
sufficient [11] 38/25
80/20 81/10 87/17
94/18 114/4 114/8
127/18 148/13 169/24
174/20
sufficiently [9] 80/20
96/12 96/24 96/25
97/8 153/9 153/10
153/14 192/16
suggest [5] 12/4
12/12 35/17 136/22
166/13
suggested [4] 87/1
87/9 167/4 176/16
suggesting [2]
131/24 131/25
suggestion [5] 17/6
47/9 52/21 161/12
162/20
suggests [5] 10/13
115/9 151/11 158/16
168/14
summarise [3] 49/17
179/13 185/4
summarised [1]
68/10
summary [14] 22/3
25/11 37/12 68/13
75/15 106/4 106/11
136/25 138/4 172/20
173/14 183/2 198/9
204/1
summed [1] 97/21
summer [1] 137/8
supplier [1] 189/23
suppliers [1] 154/8
supply [1] 165/25
support [30] 9/19
9/21 10/6 11/18 35/14
41/18 45/14 78/8
97/21 98/13 99/15
101/5 103/24 106/15
115/23 117/6 126/9
134/24 135/9 135/10
135/12 143/18 143/22)
144/1 158/7 162/25
166/14 180/3 197/8
198/15
supported [6] 17/5
19/14 91/21 99/17
108/3 208/15
supporting [5] 13/2
118/23 142/9 150/23
174/23
supportive [1]
177/15,
supports [1] 79/4
sure [28] 10/17 18/4
21/11 31/3 32/9 32/10)
35/14 35/15 44/14
52/13 59/3 62/10
66/23 72/13 96/16
113/18 118/10 122/24}
126/12 127/16 137/5
172/22 183/21 190/11
193/22 199/14 204/5
208/7
surfaced [1] 190/5
surprise [1] 122/19
surprised [1] 57/24
surprising [3] 57/20
147/18 155/5
surrounds [1] 134/11
survey [6] 159/8
178/1 178/2 178/22
178/24 182/11
surveyed [1] 156/14
Susan [1] 206/18
suspect [4] 51/14
64/11 125/12 195/13
suspected [24] 33/13}
47/3 47/8 47/24 48/25)
49/15 49/15 50/10
57/11 72/5 75/14 76/8
78/23 80/15 86/6
91/19 92/5 97/17 99/6)
125/13 161/18 170/1
207/2 207/7
suspects [1] 107/2
suspended [5]
102/17 102/17 102/24,
184/13 203/9
suspension [1]
203/11
suspicion [7] 52/23
53/6 72/3 79/4 102/22,
164/7 164/15
Suspicions [1] 40/23
suspicious [1] 16/2
sympathy [1] 61/15
system [77] 30/12
30/21 30/22 30/24
72/10 72/17 72/21
72/23 76/13 76/19
77/1 77/7 77/15 77/18)
82/25 95/17 95/24
96/1 97/1 97/10 98/10
98/21 110/10 112/20
119/14 121/2 122/3
127/5 127/21 127/22
127/24 128/9 128/12
128/13 128/18 129/2
129/5 129/16 130/11
141/6 144/23 145/1
145/4 145/9 146/23
148/2 148/8 148/11
148/19 149/12 149/17
149/24 150/16 150/21
150/23 152/2 154/19
154/21 155/1 157/11
157/14 157/25 158/11
158/18 159/2 159/4
159/6 181/24 192/13
196/23 197/8 198/13
198/14 198/16 198/18)
199/9 202/4
systemic [1] 121/23
systems [6] 47/2
149/4 149/22 151/5
154/17 187/13
T
table [1] 132/20
TABLED [1] 143/22
Tactical [1] 84/11
tailor [1] 209/10
take [52] 18/5 23/18
23/20 23/25 24/13
29/13 36/16 37/3
39/25 56/5 58/5 58/12)
59/19 60/7 60/25
63/15 64/24 78/3
78/19 81/18 85/13
85/22 88/6 103/6
105/25 111/12 112/7
113/7 114/22 115/3
118/22 123/22 132/17
156/21 156/22 157/8
159/17 160/12 162/9
162/15 167/19 168/22)
171/17 172/14 172/18
178/3 178/6 181/15
182/5 187/23 188/14
202/21
taken [23] 13/16 43/8
55/21 57/19 67/10
67/12 83/19 87/20
92/22 96/12 116/14
118/8 126/2 127/14
131/2 135/12 169/1
169/5 169/21 187/11
187/21 193/21 203/15}
takes [4] 17/7 26/23
93/8 181/8
taking [7] 5/24 13/9
24/10 48/18 57/21
181/6 183/1
Talbot [1] 11/3
talk [12] 9/6 40/25
42/8 42/14 51/1 56/4
(82) statement... - talk
T
talk... [6] 157/5
177/12 186/22 192/14}
200/9 204/4
talked [2] 177/8
177/13
talking [10] 29/20
102/20 104/23 107/25
192/5 193/4 194/23
197/1 206/5 206/6
talks [1] 203/20
target [7] 69/14 98/6
115/24 117/15 171/9
171/12 171/14
targets [2] 171/5
17116
task [2] 102/8 102/13
tasked [2] 48/23
124/24
TC [1] 166/5
team [209] 5/11 5/25
6/8 6/10 9/9 9/9 9/13
9/19 10/22 11/18
11/20 12/10 12/15
12/18 12/21 13/24
13/24 14/11 14/14
14/17 14/18 14/25
15/2 15/3 15/4 15/5
15/5 15/11 15/14
15/19 15/24 16/1 16/8
16/8 16/10 16/11
16/17 16/21 16/25
17/5 17/13 17/17
17/20 18/1 18/3 18/6
18/12 18/17 18/23
18/24 18/24 18/25
19/4 19/7 19/10 19/17)
19/18 19/20 20/24
21/6 21/23 22/8 22/25
23/4 23/14 23/18 25/6
25/18 25/19 25/24
26/24 27/17 28/22
30/3 30/6 30/15 30/21
31/4 31/4 31/10 31/18
31/25 36/3 38/5 40/2
40/5 41/11 43/10
45/21 45/21 46/8
48/23 48/24 50/24
52/19 53/2 53/3 54/17
59/12 61/22 61/22
63/13 63/16 63/21
63/23 64/12 64/13
64/15 64/16 66/14
66/17 67/8 68/5 70/3
71/10 71/10 74/4 74/8
74/9 75/10 75/25 76/2
76/2 78/11 82/13
82/16 83/8 83/11 86/2
90/1 90/5 98/9 98/10
98/20 101/10 102/3
102/5 102/7 102/10
102/13 102/23 104/8
104/10 104/21 105/11
112/20 115/10 115/24)
116/3 116/4 117/6
117/23 119/5 119/22
124/9 124/13 124/17
124/20 136/2 136/3
136/7 139/7 140/23
141/2 141/4 143/5
143/7 150/22 155/23
156/22 160/15 160/19)
162/15 162/22 162/22)
162/24 162/25 163/4
164/6 165/12 166/15
166/20 167/3 167/9
167/12 169/10 170/9
171/8 175/18 176/1
176/17 178/12 181/21
184/2 184/8 185/22
185/25 186/10 186/17)
186/20 187/15 188/6
189/21 190/4 190/6
190/13 202/4 204/24
208/13
team's [5] 6/2 9/25
22/6 56/8 75/24
teams [42] 6/3 6/8
6/11 9/7 10/7 15/17
18/23 26/7 26/12 27/8)
27/10 27/21 27/22
31/9 31/17 31/21
31/21 32/3 38/3 45/23
45/23 46/9 59/15
62/21 63/25 67/3
70/17 71/8 71/14
90/20 93/24 94/1
97/13 97/23 99/1
99/11 99/13 105/1
116/15 178/5 199/25
201/25
teamwork [1] 178/11
technical [3] 31/5
97/2 157/22
technically [2] 54/9
158/2
techniques [1] 82/2
technologically [1]
167/11
technology [3] 142/9
193/22 194/16
tell [8] 3/17 13/16
50/17 51/18 83/24
107/23 142/20 176/3
tells [1] 68/15
templates [1] 45/14
temporary [2] 105/14
105/19
ten [1] 191/3
tensions [1] 108/25
tenure [1] 207/3
term [4] 72/8 95/9
104/7 105/15
terminology [1]
179/18
terms [49] 14/25
15/17 16/12 16/18
19/12 20/10 20/25
25/3 27/10 28/10 31/7
43/5 49/4 49/19 51/5
64/20 78/12 83/22
84/20 85/2 92/20
94/18 96/11 96/20
97/3 97/5 98/12
107/13 121/22 129/18
140/20 140/24 145/16}
149/11 152/17 154/2
159/21 166/19 176/15}
177/10 177/19 180/4
183/7 184/1 184/18
185/15 185/15 186/8
190/9
terribly [2] 175/22
175/25
terrorism [1] 15/20
test [9] 42/4 42/10
132/17 143/5 154/1
158/18 189/4 199/8
199/12
tested [3] 113/12
121/15 141/14
testimony [1] 46/25
testing [4] 87/24
99/15 142/17 142/21
text [4] 126/21
than [31] 7/17 10/2
10/19 18/2 21/11
38/13 44/8 50/12
51/14 72/19 77/10
87/2 88/24 92/9 94/11
100/16 113/5 118/21
120/17 127/22 128/23}
129/2 129/6 149/12
150/25 175/3 181/17
187/10 191/4 191/8
198/4
thank [99] 1/7 1/10
1/13 2/10 2/15 2/18
3/15 4/5 4/13 5/9 5/21
6/12 7/2 7/15 7/19
7/21 7/24 8/9 9/4
10/21 13/23 14/10
14/20 14/23 14/25
15/17 16/17 17/4
19/12 22/9 22/12
22/24 23/12 23/20
24/12 25/10 25/20
27/25 29/23 33/7
33/16 34/14 36/21
37/7 39/18 40/8 42/11
44/3 45/9 45/25 47/6
47/22 56/4 58/11
58/17 58/21 62/14
68/23 71/4 71/13 72/7
73/11 76/5 84/9 85/16
86/3 88/17 89/20 91/4
100/7 105/20 110/25
111/11 111/17 113/24
119/2 123/15 124/3
131/9 143/13 147/21
151/25 165/17 171/16}
175/2 176/25 180/17
188/23 190/21 191/13}
191/16 202/9 206/8
208/12 208/16 208/17
208/18 208/19 209/14
Thanks [1] 22/5
that [1376]
that's [152] 2/2 3/9
3/14 4/10 4/13 4/22
5/16 5/23 8/9 9/9
11/10 11/25 12/8
12/20 13/4 13/12 15/2}
17/22 18/14 18/14
19/22 20/17 21/3 22/4}
22/22 23/5 25/24
26/18 26/23 27/11
29/23 31/7 32/16
33/14 33/18 33/22
36/9 36/11 36/19 38/2
39/4 42/15 42/24
43/23 44/4 44/7 44/20
47/3 48/4 48/7 48/7
53/8 53/9 53/17 56/7
57/1 57/3 59/25 62/5
66/6 68/6 69/3 69/18
70/15 71/12 71/18
72/22 75/9 83/6 83/16
83/23 84/4 85/6 87/3
87/8 87/19 88/3 89/4
89/21 90/2 90/19
92/17 97/7 98/3 98/19
99/12 101/7 101/13
101/19 102/20 106/20}
112/9 113/21 114/25
116/4 116/6 116/21
122/15 125/2 126/23
129/7 132/14 132/19
134/13 135/19 136/20
143/14 145/20 149/7
152/10 153/5 154/9
154/22 157/2 160/2
160/10 161/10 162/7
162/15 165/18 169/11
171/3 173/13 173/22
178/21 179/8 184/1
184/2 185/9 185/14
187/8 187/23 188/11
188/16 189/7 189/7
194/25 195/15 195/19)
197/24 197/25 198/1
198/21 199/16 200/12)
201/21 201/23 202/7
204/1 204/8 205/12
208/21
theft [10] 66/1 66/11
80/18 88/21 97/17
99/6 123/25 125/14
126/7 152/22
theft/frauds [1] 97/17]
their [62] 9/16 9/22
15/15 15/25 17/7 17/9}
23/24 24/2 25/6 30/6
30/16 31/5 35/22 40/4
40/6 41/11 41/20
42/10 45/24 47/16
48/4 53/19 58/9 64/1
65/6 69/9 81/9 84/6
106/15 107/12 113/7
117/4 130/9 136/15
139/25 143/4 147/8
151/5 152/6 152/11
153/19 160/5 166/15
178/6 180/1 180/6
182/6 186/6 186/25
190/13 197/13 197/22)
198/12 199/22 201/8
201/8 201/9 201/9
203/3 203/12 205/11
209/10
them [78] 5/24 9/16
10/1 10/4 11/17 12/24}
13/10 16/3 20/8 23/9
23/19 23/24 25/12
26/1 27/15 29/16 30/4
30/11 30/14 31/21
35/8 41/22 42/8 42/10I
42/25 42/25 49/10
50/22 51/9 51/13
52/24 52/24 52/25
53/9 53/12 54/19
54/20 59/16 64/25
68/1 80/22 81/22
81/22 82/1 83/22
83/24 83/25 86/13
86/23 97/18 124/21
126/6 134/16 134/19
137/25 140/21 143/8
153/23 155/7 157/6
163/2 164/5 167/6
174/4 178/17 178/20
187/4 187/15 187/18
188/13 188/13 188/16
189/2 200/7 200/9
200/10 206/1 206/2
thematic [3] 16/16
184/20 185/2
themes [3] 185/6
185/12 189/9
themselves [3] 39/21
153/16 160/4
then [110] 2/11 2/13
6/6 8/13 9/16 9/17
16/10 16/17 22/2 31/3}
31/20 31/20 32/14
32/19 41/22 42/8
42/10 45/22 46/8
46/20 47/17 49/10
51/3 51/6 51/7 51/19
52/1 54/4 54/6 54/7
54/8 54/9 63/1 64/3
65/21 69/5 73/9 73/11
77/13 79/14 80/1
80/14 80/24 81/21
82/6 82/9 82/17 85/25
86/6 86/9 86/15 95/21
97/18 97/20 99/24
100/8 103/16 103/20
105/14 107/11 107/19}
(83) talk... - then
T
then... [49] 115/3
116/20 117/13 117/22)
119/22 121/16 128/5
129/21 134/22 139/17
140/13 141/1 144/20
146/12 146/22 150/1
153/4 156/6 160/5
160/10 162/11 165/6
167/15 167/19 168/14}
168/21 170/20 171/13}
173/10 174/6 174/24
178/10 185/11 186/15}
186/16 187/1 187/6
188/7 188/8 188/14
192/9 192/11 192/14
193/25 196/13 197/1
197/5 199/7 200/9
theoretically [1] 52/9
there [250]
there's [35] 2/2 15/18
18/1 27/2 42/21 52/14)
52/21 64/22 65/8 66/3
68/16 72/14 75/18
76/14 80/1 87/17
97/15 105/6 105/20
112/6 113/21 123/23
133/10 140/22 148/16)
148/22 158/16 163/19
165/6 182/14 184/20
185/11 187/19 198/17)
205/12
thereafter [1] 128/14
therefore [9] 35/19
45/5 96/6 116/9
120/14 129/17 192/11
198/25 207/23
these [38] 11/17
24/18 25/12 32/5
43/21 48/13 54/12
65/9 68/9 74/18 79/2
79/12 80/19 80/23
93/12 94/8 103/5
103/7 112/1 113/12
115/5 124/19 127/18
139/11 141/23 141/23}
147/7 155/4 155/22
156/10 157/9 158/1
182/25 196/10 197/22
200/19 201/5 203/7
they [200] 6/3 6/3 6/4
6/5 8/12 9/16 9/21
13/5 13/10 13/14
13/22 15/21 15/24
16/1 16/11 16/15 17/2)
17/9 18/25 20/3 20/6
20/8 21/4 23/9 23/10
23/11 29/17 29/24
31/20 32/11 33/10
33/19 33/20 35/19
36/13 38/18 40/2 40/3,
40/5 40/6 40/6 41/19
42/9 42/23 45/23 47/4
47/5 49/24 49/25 50/8)
50/14 50/16 50/18
50/20 50/20 51/7
51/12 51/13 52/1
52/14 53/12 53/21
54/9 54/23 56/24 58/8)
59/15 59/21 60/11
60/24 62/6 63/13
64/13 64/15 65/25
66/14 66/14 66/15
70/21 74/12 74/17
74/18 78/6 79/5 81/23
81/24 82/3 82/24
83/12 83/12 83/13
83/14 83/24 89/16
90/16 90/20 90/22
90/23 91/6 105/12
105/13 107/2 107/10
107/17 108/5 108/5
108/7 108/9 109/4
112/9 116/18 116/18
116/20 117/9 118/4
118/5 118/17 118/18
119/10 119/12 119/13)
120/13 124/9 126/7
132/5 134/23 143/10
144/5 144/10 144/12
145/13 146/21 146/23)
147/3 147/19 149/19
150/10 151/17 152/9
152/19 153/5 153/18
153/25 154/3 155/22
156/2 156/9 157/12
160/3 160/7 162/11
162/14 163/2 166/16
167/4 170/20 170/22
17716 177/12 178/6
178/17 180/2 181/1
184/7 184/8 184/8
184/9 184/10 186/23
186/25 187/3 187/3
187/6 187/16 187/16
188/12 188/14 188/16)
189/5 190/7 191/11
193/12 193/15 197/2
197/3 197/8 197/10
197/13 197/15 198/21
199/22 200/3 200/11
200/24 204/25 205/17,
205/18 206/1 206/3
208/11
they'd [2] 9/15 126/4
they'll [3] 31/20 53/1
53/4
they're [21] 12/20
15/24 17/14 30/7
51/14 62/6 152/8
154/12 157/5 171/24
176/14 180/2 184/7
184/13 194/7 198/11
198/14 198/17 198/21
200/7 205/4
they've [11] 9/18
29/8 35/8 51/8 105/2
152/17 184/18 188/1
193/15 199/22 201/25)
thing [7] 54/22 96/4
96/6 96/10 140/22
171/25 202/5
things [27] 13/6 13/6
14/19 15/19 16/14
28/24 42/3 45/11 50/1
51/11 60/10 64/24
64/24 72/16 75/3
94/15 96/20 115/3
121/11 167/16 171/23
182/18 183/2 188/25
194/15 195/23 205/18!
think [213]
thinking [6] 59/4 68/9)
100/13 123/5 123/8
199/12
third [12] 4/19 22/12
50/11 84/17 112/7
135/23 145/6 149/4
149/25 150/2 154/7
183/8
this [272]
this' [1] 176/3
Thomas [1] 11/14
thorough [1] 91/3
those [120] 2/15 6/17
7/13 8/12 10/4 12/5
12/12 12/17 12/22
13/9 13/21 16/23 17/3}
18/11 20/7 24/24
26/20 27/6 28/2 33/16
34/1 35/7 35/20 37/2
37/3 37/4 37/12 38/22
40/7 42/3 44/21 45/14
46/7 49/23 50/7 51/22
52/8 54/5 54/21 54/24
55/1 55/9 55/12 55/14
58/24 62/12 65/12
66/25 67/7 67/23 68/1
75/24 76/2 80/19
83/19 84/7 89/14
90/21 92/13 96/13
98/18 102/14 103/10
104/9 105/11 108/3
108/6 110/12 111/1
114/6 114/13 119/22
121/19 121/20 122/22I
131/1 132/9 132/9
134/23 140/25 141/4
141/20 143/2 143/6
143/7 143/12 146/1
150/24 153/11 154/14
156/8 159/3 159/13
159/22 175/21 177/13
178/16 179/4 179/14
180/24 182/18 185/9
185/10 188/3 188/20
190/22 192/24 194/15}
199/8 199/19 199/25
200/6 201/6 201/10
201/24 201/24 202/21
204/12 206/1 209/12
though [11] 34/19
52/12 56/11 122/10
126/1 131/1 158/19
159/22 176/18 198/2
198/16
thought [8] 32/11
66/14 73/25 87/17
144/10 158/10 184/4
201/4
threat [2] 168/23
168/24
three [16] 1/13 15/7
46/20 75/2 121/3
127/10 141/4 141/20
143/16 156/9 156/13
169/2 185/5 189/1
191/2 191/11
three-quarters [1]
143/16
threshold [3] 98/8
132/4 132/6
through [56] 8/12
10/8 15/11 16/8 16/8
16/10 16/10 17/11
17/11 17/12 24/1
24/14 25/12 25/12
27/15 31/15 33/2
35/20 37/3 42/8 65/6
67/4 67/8 70/22 76/12,
76/18 78/19 82/24
83/15 87/6 88/6 89/3
89/10 90/19 116/20
117/9 121/14 125/11
140/23 143/11 151/4
151/24 152/1 153/4
164/11 166/25 167/25)
184/23 186/4 187/5
188/3 190/12 196/3
196/14 196/21 197/20}
throughout [3] 39/20
63/1 202/18
thrown [1] 188/1
Thursday [1] 1/1
tier [19] 30/15 31/1
53/1 53/5 53/6 53/11
53/18 53/22 53/24
53/25 53/25 54/7 54/8)
70/22 70/22 70/22
98/10 98/20 116/19
Tier 1 [3] 53/24 70/22
116/19
Tier 2 [5] 53/18 53/22)
53/25 54/7 70/22
Tier 3 [6] 30/15 31/1
53/11 53/25 54/8
70/22
tiers [1] 53/24
time [60] 7/21 8/7
10/13 13/21 19/15
23/25 35/9 46/14
66/22 67/12 67/13
68/19 69/22 70/15
74/15 85/7 89/2 89/3
89/4 90/18 96/11
99/21 100/2 103/18
108/2 110/13 111/25
112/17 112/25 114/11
114/16 114/19 115/5
115/6 115/13 115/21
116/17 121/19 123/3
130/18 137/2 137/4
140/25 141/1 142/6
148/14 148/21 150/17
151/14 162/15 166/15)
170/12 170/19 170/21
174/3 176/8 176/19
186/22 193/2 200/13
timeline [2] 8/25
137/18
timelines [1] 188/9
times [4] 128/23
144/18 152/10 178/12)
timescale [1] 173/24
timing [1] 113/19
timings [2] 190/24
191/17
T™M [1] 102/2
today [7] 7/24 106/5
113/18 138/9 163/5
180/17 202/18
today's [1] 205/8
together [3] 45/21
126/20 152/11
told [6] 13/4 50/14
88/5 119/13 147/3
190/15
tomorrow [3] 208/23
209/3 209/8
tone [1] 169/10
too [10] 6/23 45/24
52/10 76/17 76/20
777 T7IN1T 87/1 138/6
200/9
took [6] 28/20 28/23
90/25 170/16 203/16
204/4
tool [4] 26/17 27/4
109/18 110/18
tools [5] 81/23
142/25 143/3 143/6
143/12
top [6] 22/9 22/10
53/5 57/5 100/25
155/25
topic [2] 160/11
160/12
topics [1] 168/6
total [1] 85/14
totality [4] 58/10
totalled [1] 85/9
touch [2] 9/7 124/21
touches [1] 86/25
towards [5] 37/21
40/21 41/19 193/4
194/17
trace [1] 196/21
trade [1] 182/5
traditional [1] 79/20
(84) then... - traditional
ti [2] 31/20 125/23
trained [3] 30/3
30/22 48/1
training [36] 7/15
TINT 8/20 8/24 14/14
14/18 23/23 26/14
27/2 28/1 28/2 28/4
28/10 28/11 28/16
29/2 29/3 29/3 29/5
29/8 29/10 30/11
30/16 31/7 31/14
31/19 31/20 31/24
32/6 46/4 53/2 116/18
180/7 180/10 180/13
185/8
transaction [14] 30/5
30/18 116/8 116/12
116/18 116/25 134/17
134/17 134/22 134/22)
139/9 144/24 145/24
146/20
transactional [1]
146/23
transactions [20]
90/22 121/18 121/20
121/21 124/11 124/16
124/19 124/23 134/20}
140/25 145/19 146/11
149/1 149/20 150/11
152/10 158/15 160/4
198/22 199/8
transfer [1] 134/17
transferred [1]
125/11
transition [2] 158/8
192/12
transparency [4]
43/2 43/3 54/21
151/19
transparent [2] 178/8I
204/10
treating [1] 54/24
trends [1] 36/14
triage [3] 26/2 27/17
97/18
trial [1] 66/1
trialling [1] 20/15
tried [1] 187/25
trilateral [1] 119/23
tripwires [1] 143/8
true [7] 1/25 2/16 3/7
4/14 5/4 12/20 85/7
trust [1] 205/13
trusted [1] 10/9
truth [2] 41/2 174/17
try [3] 52/10 187/20
188/3
trying [7] 28/25 60/12!
62/6 114/22 121/13
131/24 188/19
turn [52] 1/16 1/20
2/22 2/25 4/25 10/5
10/21 11/24 12/7 22/2
22/7 24/3 25/10 34/4
44/4 46/12 56/12 57/3
64/12 64/13 69/2
78/17 84/9 92/11
92/24 97/15 100/7
100/15 105/24 112/5
114/16 115/8 115/15
118/19 122/25 123/23}
132/18 134/7 137/20
143/13 143/15 144/14)
147/10 157/8 165/17
167/15 170/4 175/13
177/25 182/24 185/13)
206/22
Tutin [3] 21/21 22/2
61/2
two [47] 6/47/11
7/11 13/18 17/10
20/15 23/5 28/13
28/18 29/21 30/5
30/15 33/9 34/1 35/9
35/16 35/17 49/6 50/7
56/4 81/7 88/16 93/7
98/10 98/20 102/10
104/7 104/9 105/11
107/7 115/14 121/11
129/2 134/23 156/9
160/1 170/18 171/20
171/23 172/13 178/3
188/20 188/23 189/9
191/4 199/5 206/7
two-fold [1] 107/7
two-tier [1] 98/10
type [9] 20/2 47/10
50/18 51/22 51/25
59/9 116/18 188/18
188/18
types [7] 36/1 46/15
46/20 49/6 54/12
80/18 80/19
Typically [1] 81/2
U
UK [5] 71/25 75/13
76/11 92/4 119/21
ultimate [1] 92/21
ultimately [10] 16/24
17/2 21/20 21/20 31/2
63/23 73/8 78/3 114/6
117/16
Um [4] 76/22
unable [2] 39/21
148/9
unacceptable [1]
176/6
unblemished [3]
73/18 74/1 74/13
uncomfortable [1]
63/14
unconscious [2]
180/7 181/2
under [28] 6/11 6/23
17/2 20/24 27/7 39/17)
41/16 46/25 48/18
48/25 50/18 59/3
59/25 60/10 61/18
66/16 86/18 100/6
108/16 134/12 149/1
149/21 150/12 165/4
165/5 167/19 168/4
194/9
underlines [1]
156/21
underlying [3] 30/20
108/2 142/9
undermining [1]
130/21
underpinning [1]
157/18
understand [39] 9/17)
13/1 14/2 16/12 16/20
21/17 30/23 31/18
32/11 54/3 60/1 61/1
61/19 62/1 70/18
72/13 84/5 105/16
107/22 108/1 120/13
141/18 148/1 152/12
152/19 156/3 157/6
163/22 164/4 166/2
166/17 166/25 171/23}
179/2 186/13 191/22
192/19 200/8 204/20
understanding [19]
8/25 9/25 18/15 30/14
53/10 53/22 59/20
90/18 96/20 101/24
110/12 115/4 115/5
151/20 168/6 174/14
178/14 183/23 203/10
understands [1] 97/8
understood [2] 32/21
62/22
undertake [3] 25/1
46/7 84/25
undertaken [4] 83/15
95/24 150/13 208/13
undertaking [1]
83/23
undertook [2] 85/1
85/24
underway [3] 99/22
190/1 190/2
underwent [1]
202/23
unexpected [1]
105/2
unexplained [2]
128/9 155/10
unfair [2] 103/1
201/23
unfortunately [1]
79/17
unfounded [1] 205/1
unified [1] 34/2
Unique [1] 2/18
unit [10] 5/15 5/21
14/5 14/6 69/6 69/10
73/16 84/3 100/23
163/9
Universal [3] 160/23
161/3 163/12
unjustified [1]
206/12
unknown [1] 148/22
unless [1] 110/20
unlikely [2] 116/10
142/2
unnecessarily [1]
138/7
unofficially [1] 80/2
unredacted [1]
151/23
unreliable [13] 90/6
90/17 108/9 109/24
110/10 118/5 118/17
119/14 141/6 145/20
198/24 199/4 200/22
unsafe [1] 131/4
unsure [1] 108/4
until [6] 102/17
114/23 147/15 170/24}
175/18 209/16
unwieldy [1] 138/7
up [51] 7/1 21/8 23/5
24/10 27/5 27/18 28/5)
31/9 34/9 36/22 43/13)
44/12 56/7 57/16
70/14 71/9 88/20 89/3
89/10 95/14 102/2
102/7 105/25 111/23
115/25 117/25 123/17]
154/22 155/1 161/21
161/23 162/1 166/11
167/13 175/11 175/16}
17718 17719 177/11
177/16 178/8 180/10
190/10 190/11 190/12)
196/24 197/11 200/9
201/25 203/7 206/22
update [2] 115/9
190/8
updates [1] 188/23
updating [1] 157/23
upfront [2] 29/11
50/20
uploaded [2] 2/19
4/17
upon [11] 9/7 131/2
131/12 142/19 142/22)
143/10 151/16 154/17,
158/17 160/10 183/8
upsurge [1] 182/22
urgently [1] 122/4
URN [1] 4/17
us [73] 7/5 9/23
13/16 19/16 29/17
35/22 36/15 38/23
45/15 49/4 49/9 49/20
51/2 53/24 54/10 64/5)
67/14 68/4 68/15
70/23 71/8 72/2 73/6
73/25 79/21 83/5
86/18 86/21 89/14
91/7 92/7 93/8 94/9
99/20 102/21 104/2
104/12 107/5 107/15
108/20 110/3 115/11
116/13 119/9 136/18
137/9 140/18 1441/7
142/20 142/21 144/4
146/22 147/4 153/22
154/24 157/5 162/11
162/12 164/9 165/13
170/22 170/23 175/23)
176/3 177/17 177/18
188/25 189/2 190/8
194/24 204/21 205/20)
206/2
us' [1] 175/19
use [25] 21/18 26/12
26/16 26/21 72/10
78/7 81/22 89/25
103/22 111/8 118/3
128/12 129/19 130/18)
132/12 136/16 136/18)
136/18 149/18 163/20)
169/10 181/14 190/4
196/16 200/15
used [19] 27/1 46/8
72/8 77/8 82/2 118/6
118/6 118/10 120/25
128/13 131/6 136/22
142/25 143/1 143/7
179/18 200/23 200/25)
201/9
useful [3] 131/21
131/25 186/18
users [1] 158/1
uses [1] 175/25
using [8] 87/18 87/25)
104/15 111/10 122/6
148/1 163/22 180/25
usual [5] 93/19 94/6
101/10 142/10 184/11
Vv
validated [1] 27/11
validation [1] 160/8
validity [1] 143/6
value [9] 85/7 85/14
98/8 99/8 116/23
124/11 153/24 182/7
190/14
Values [1] 45/12
variety [2] 24/16
772
various [21] 7/8 9/6
18/23 19/1 33/7 51/3
54/12 60/9 61/15
65/13 78/4 115/3
128/15 150/20 152/1
154/6 157/13 176/25
180/25 183/4 189/24
varying [1] 157/23
vast [4] 17/10 54/3
(85) train - vast
Vv
vast... [2] 80/16
85/19
verification [1]
154/14
versa [1] 61/9
version [14] 4/4 4/9
34/7 44/11 44/11
44/12 49/3 110/6
111/7 128/4 134/4
140/14 141/12 148/5
versions [6] 44/16
128/12 129/8 129/20
130/18 131/2
very [50] 1/10 2/15
5/9 7/2 14/10 22/12
23/20 24/13 25/17
31/6 47/22 52/20 54/9
56/5 57/24 58/17
60/17 61/11 62/3
72/20 73/21 90/13
107/23 108/19 111/17)
134/1 134/2 163/4
166/23 170/21 170/21
175/2 180/1 180/20
182/19 182/22 190/9
191/17 191/19 193/5
197/21 197/24 198/1
200/15 201/19 204/16
205/21 208/19 208/22
209/14
vexed [1] 202/18
via [6] 20/4 79/3
86/16 177/21 177/21
181/5
vice [1] 61/9
victim [10] 16/7
82/21 106/16 107/2
119/18 120/3 120/4
136/16 136/19 163/20)
view [47] 13/13 25/4
26/20 28/1 33/4 43/8
57/25 60/23 72/10
72/17 74/12 76/17
81/15 86/11 87/13
87/25 90/16 94/21
97/4 101/17 104/20
114/20 114/22 120/16)
134/7 136/11 145/7
146/6 152/4 154/4
156/15 158/22 159/15)
161/20 164/7 164/12
167/1 169/8 169/21
176/13 178/4 178/20
180/24 183/18 184/12)
196/5 198/12
viewed [4] 78/22
79/15 108/9 108/10
views [6] 51/18 61/12!
107/12 107/12 108/1
196/15
virtual [6] 70/2 70/19
71/5 71/9 71/12 77/24
ibility [4] 155/22
vision [2] 10/8 24/18
Voice [1] 177/6
volume [3] 43/10
43/12 71/15
volumes [3] 20/25
21/1 36/14
voluntarily [2] 53/8
117/12
voluntary [4] 110/22
151/22 163/13 163/15)
volunteered [1]
53/21
vulnerable [1] 50/4
WwW
waiting [4] 29/9
29/16 29/18 66/15
waits [1] 186/14
Wales [5] 81/5 82/4
83/14 153/19 174/22
Walton [2] 118/25
118/25
want [23] 23/22
35/18 35/20 41/19
42/9 50/19 60/19
81/15 98/4 102/11
111/25 118/3 118/10
121/14 162/14 162/16)
169/10 171/23 191/9
200/23 202/21 207/19
209/2
wanted [15] 85/2
88/6 91/7 107/20
108/5 120/11 124/9
126/7 134/3 138/23
143/2 146/23 173/7
173/13 208/11
wanting [1] 207/22
warehouse [1]
152/25
warning [1] 209/7
was [315]
wasn't [13] 13/19
32/19 39/16 107/24
110/8 110/11 114/15
176/16 182/13 194/19)
200/18 200/22 201/7
watch [1] 191/16
Watt [3] 202/10
202/12 210/8
way [38] 9/4 11/7
27/7 50/10 52/2 60/13
62/22 68/17 78/14
79/20 82/20 84/15
86/24 94/2 94/4 103/7
104/11 104/21 107/8
107/8 110/9 116/20
143/16 155/3 170/1
178/7 179/1 187/20
187/21 187/25 193/24)
197/20 198/19 204/11
205/4 205/13 205/15
205/24
ways [3] 23/5 150/19
178/14
we [494]
we'd [5] 18/18 29/12
42/5 65/5 141/25
we'll [21] 23/23 25/12
31/14 39/8 39/8 53/17,
56/25 72/14 73/3
73/13 94/15 105/20
108/11 118/12 140/6
151/3 165/7 174/6
175/2 184/23 198/18
we're [45] 1/5 6/14
18/11 20/15 21/1 21/3
21/6 23/16 27/2 27/9
29/9 29/18 31/2 31/12
41/9 41/14 54/11 62/2
65/9 74/15 74/20
83/21 84/5 92/24
92/25 104/12 110/14
121/13 134/14 137/8
137/19 144/15 144/15]
144/16 156/23 157/4
162/17 180/15 188/15}
188/19 194/10 194/13
201/25 206/5 207/23
we've [46] 9/9 18/23
18/24 20/19 23/24
25/11 27/3 27/16
27/18 28/7 28/12 29/7
29/17 43/12 43/17
55/6 55/11 55/17
55/20 58/25 67/15
68/3 68/14 90/7
105/22 119/2 132/21
134/25 135/19 136/21
144/18 152/14 155/2
157/2 158/20 167/25
176/25 177/13 177/15}
197/18 198/1 199/10
200/5 200/7 201/24
204/14
website [2] 2/20 4/18
week [5] 35/10
115/14 169/20 177/12
194/1
Weekly [1] 193/10
weeks [2] 44/18
118/1
weeks' [1] 35/9
well [55] 4/9 8/12
10/23 11/10 20/13
29/3 29/21 31/6 39/8
41/9 41/14 42/5 43/23
52/17 53/7 53/21 56/2
61/14 68/8 70/18 71/6}
73/14 78/23 79/22
83/14 83/17 85/13
88/15 98/24 108/19
110/15 144/21 146/18}
149/25 155/21 156/5
156/6 157/4 161/9
162/13 164/14 175/12
179/22 187/13 190/25I
191/6 193/10 197/10
198/23 201/17 201/17
201/21 201/23 204/16
208/22
well-known [1]
175/12
went [3] 67/5 103/5
137/12
were [106] 5/17 7/19
7/21 8/21 8/21 18/4
20/8 28/24 37/9 39/21
40/9 45/19 48/23
49/13 56/23 57/15
58/22 66/13 66/14
78/6 84/24 84/25 85/3
85/8 85/18 85/20 86/7
86/21 87/1 88/23 90/5)
90/17 90/22 91/6
94/11 94/24 97/13
100/10 100/20 101/19)
103/3 105/13 105/13
107/10 107/25 108/1
108/4 108/6 108/14
108/25 109/3 110/12
110/23 111/9 113/10
114/11 114/18 119/13}
120/9 121/21 122/1
123/4 123/8 128/9
131/3 131/10 136/14
137/1 142/7 142/12
142/25 143/3 144/5
146/21 147/14 154/20}
157/10 167/4 168/18
170/5 170/22 176/8
182/16 183/2 184/7
184/8 185/1 185/10
185/14 185/19 189/5
189/10 189/18 193/13
194/23 200/19 203/24}
203/25 205/1 205/16
205/19 205/20 205/21
206/3 207/18 207/21
weren't [6] 109/4
112/2 137/13 162/11
172/18 184/8
West [2] 133/13
133/15
what [198] 3/24 5/21
5/24 6/9 6/12 6/18 7/5
8/19 8/20 9/8 9/23
12/1 12/3 13/2 13/4
13/13 13/13 18/7 18/9)
19/16 21/8 21/22 23/9)
25/4 28/25 29/10 30/1
30/11 30/12 30/12
30/20 32/10 32/12
34/8 35/2 35/22 36/11
38/6 41/13 41/24 42/8)
42/9 43/21 47/13
49/17 49/18 51/17
51/19 52/23 53/16
53/24 54/19 55/3 59/6)
59/23 60/18 60/24
60/24 61/12 62/2 62/4
63/25 64/10 64/19
66/25 67/25 69/5
69/22 71/4 71/9 72/2
72/9 74/5 76/9 78/2
85/11 85/13 87/8
87/22 87/25 88/3 89/6I
89/8 89/14 90/17
90/20 91/7 91/10
91/11 94/9 96/1 96/1
96/2 96/19 97/4 98/6
98/7 98/12 99/3 102/9I
102/11 102/12 102/13)
104/17 104/23 105/9
107/12 108/7 108/12
108/22 109/13 110/25}
112/6 116/13 116/15
116/19 116/21 120/11
120/11 121/9 122/1
122/11 123/9 132/14
134/14 134/19 136/11
136/20 140/6 141/3
142/20 145/7 145/11
145/14 145/16 145/17)
146/7 147/8 152/4
152/8 152/12 152/21
153/1 153/5 153/5
153/11 154/20 155/20)
156/3 156/6 159/15
163/15 164/4 164/13
164/21 165/13 167/4
169/12 169/16 170/1
170/22 170/24 173/13}
173/17 175/22 176/13)
176/13 176/14 178/20)
179/2 179/22 180/1
180/20 180/21 181/11
184/16 186/25 187/3
188/9 188/11 189/19
190/9 191/25 192/7
193/23 194/8 195/14
195/15 198/1 198/21
202/2 202/18 204/11
204/18 204/22 205/15}
206/2 207/21
what's [15] 15/15
36/9 48/6 49/4 61/19
82/5 87/13 100/3
104/11 136/11 145/7
164/10 169/21 184/12!
205/11
whatever [3] 41/18
43/1 176/12
whatsoever [1] 202/5)
when [65] 5/19 8/1
10/12 10/16 14/23
18/12 19/22 29/13
32/15 32/21 40/5
41/24 43/5 46/3 48/5
48/11 48/20 48/23
49/3 51/13 56/1 60/2
61/2 61/8 61/12 61/13}
61/22 65/2 65/12
70/12 71/1 79/12
86/11 86/22 95/23
(86) vast... - when
Ww
when... [30] 96/9
98/4 104/14 105/2
105/5 115/11 115/13
126/10 130/20 137/4
137/9 139/11 142/12
147/5 153/17 153/19
154/18 158/25 162/12
163/3 164/19 164/22
171/9 176/10 183/14
187/8 187/16 202/19
203/17 206/5
whenever [1] 103/23
where [75] 6/19 7/21
12/9 13/10 14/18 16/6
19/20 27/13 32/8
43/24 44/21 49/3
54/17 55/18 55/20
56/18 57/11 59/14
64/1 64/11 64/13 72/3
78/25 79/1 79/3 90/20)
91/1 97/19 97/21
101/5 101/24 103/19
104/2 105/5 106/16
107/1 109/8 109/22
109/23 109/25 111/23
113/11 113/25 115/21
123/22 128/7 128/20
128/24 129/24 130/3
130/10 131/4 1341/5
132/19 132/22 133/18}
138/23 140/2 143/6
154/3 154/22 167/16
1470/7 171/1 171/12
172/17 173/14 177/12)
182/15 183/2 188/14
188/25 190/10 194/10
194/13
whereas [1] 88/14
whereby [1] 202/3
whether [52] 30/5
30/6 32/1 38/25 48/14
50/8 50/11 53/15
55/14 56/24 59/23
61/21 68/17 76/17
79/6 85/17 87/25 96/9
99/22 102/2 107/16
112/12 120/3 121/18
121/23 122/5 122/7
130/19 135/13 146/14}
148/3 148/24 154/12
156/24 158/17 161/20
163/2 164/12 169/25
173/4 173/20 177/21
181/2 181/8 184/4
187/23 189/5 189/23
189/25 193/5 193/6
205/3
which [89] 2/4 8/11
12/12 12/18 16/17
17/20 21/19 29/8
29/17 37/19 39/16
40/15 40/20 46/6 51/2
53/6 60/6 60/22 62/1
65/19 69/25 70/20
73/20 79/25 80/19
80/21 81/12 81/25
89/24 93/20 99/18
101/4 103/24 104/4
104/25 106/9 109/19
114/20 116/15 118/22)
121/12 121/12 122/1
123/18 124/5 124/22
125/5 126/14 129/1
131/11 131/20 131/20)
131/23 134/11 134/12)
135/6 139/15 140/19
145/1 147/18 148/21
149/5 150/5 150/21
152/14 166/16 167/23)
168/3 168/7 170/12
171/21 172/2 173/7
181/21 183/21 187/4
189/1 189/16 191/16
192/24 193/10 196/7
201/17 204/23 205/24
206/11 206/21 208/25
209/1
whichever [1] 18/17
while [2] 171/24
193/19
whilst [12] 12/16
24/15 66/14 85/19
89/23 90/25 95/18
101/22 117/14 175/20)
184/13 196/2
whistleblower [1]
189/6
whistleblowing [1]
1/15
who [78] 8/5 8/7
10/22 11/3 12/15
15/13 16/23 17/1
17/14 19/6 22/1 22/15
23/3 23/5 23/8 30/11
30/13 30/18 32/17
33/4 35/5 36/15 37/24
46/9 46/24 47/3 47/24
49/8 49/11 50/8 50/17)
52/18 53/4 54/8 55/21
57/15 57/25 58/1 58/3
62/7 62/17 71/11 80/2
85/21 85/24 88/22
91/8 97/17 108/20
111/3 112/5 114/6
118/25 119/23 120/2
124/21 126/10 131/18)
146/13 147/1 147/22
153/19 161/6 162/3
1714/1 175/22 178/17
179/24 181/8 188/7
189/5 193/3 194/24
195/10 198/4 202/23
206/18 209/9
who's [3] 10/22
146/13 182/19
whoever [2] 77/2
105/7
whole [3] 122/3
141/5 197/18
wholly [4] 78/21
whose [2] 15/7 50/9
why [37] 13/16 13/19
13/22 28/23 34/12
35/15 43/7 64/5 64/9
64/16 70/12 71/12
73/25 85/2 92/7 94/21
96/15 104/20 107/22
111/2 111/9 120/8
120/16 122/22 126/14
140/16 152/19 162/16
169/8 170/14 179/2
181/6 183/18 187/11
187/21 200/18 201/5
wide [2] 6/19 69/11
wider [4] 31/9 123/5
123/8 208/13
WIELDED [1] 175/17
will [115] 2/19 4/17
10/10 15/10 17/20
20/8 20/12 27/8 31/12
31/15 31/17 31/20
31/23 32/1 35/12
35/14 35/19 39/16
40/21 41/10 41/22
41/25 42/3 42/10
42/13 43/6 44/15
44/19 45/5 49/4 49/6
49/10 49/19 49/24
49/24 50/8 50/14 53/7
53/15 55/25 56/18
56/19 59/11 59/12
59/19 60/23 65/7
65/13 67/23 75/16
79/23 82/23 82/24
82/24 83/1 83/24 95/4
95/6 95/10 95/22
95/24 96/10 97/18
97/20 97/22 99/9
99/10 114/7 119/2
119/22 120/3 121/5
123/2 123/4 133/24
134/8 134/10 135/10
135/11 136/6 139/8
139/10 142/1 142/19
146/5 153/9 154/22
154/23 157/3 157/5
158/7 159/17 159/25
162/2 167/18 168/9
168/15 173/21 175/20}
180/15 182/19 188/21
188/21 191/3 193/23
194/1 196/6 197/11
199/4 200/9 200/9
200/10 203/9 209/4
209/12
willing [4] 91/6 157/5
168/20 196/2
Willow [2] 188/24
189/4
Willow2 [4] 189/8
194/19 194/21 194/22,
Willow3 [2] 189/22
190/7
Willows [2] 189/1
194/18
win [1] 205/13
wise [3] 21/5 167/11
168/15
wish [2] 162/6 168/6
wishes [1] 209/10
within [71] 6/24 6/25
12/10 12/16 12/19
15/1 15/24 17/15
17/17 19/17 19/18
26/22 27/17 30/25
31/1 38/3 38/15 40/1
43/10 43/18 46/9 48/2
49/9 59/20 62/11
63/13 64/20 70/23
74/7 75/4 79/11 79/23
82/13 83/11 87/18
91/25 93/12 98/10
99/1 105/1 105/11
110/10 114/10 116/15}
120/12 122/22 126/22)
134/12 136/18 142/16}
149/17 150/23 151/14,
155/23 160/18 160/23}
161/14 163/12 163/17
163/19 179/20 179/22)
179/23 181/13 182/21
184/2 190/13 192/5
194/9 195/8 208/13
without [12] 35/19
36/4 80/10 89/13
122/12 136/5 141/7
172/19 172/21 178/7
203/10 207/9
WITN11170100 [1]
203/8
WITN11180100 [1]
203/20
WITN11180104 [2]
160/16 165/18
WITN11180102 [1]
162/8
WITN11180103 [1]
167/15
WITN11180104 [1]
170/4
WITN11190100 [1]
2/19
WITN11190200 [5]
4I17 11/25 36/23
123/18 132/19
witness [76] 1/13
9/12 11/4 14/7 15/18
17/4 19/13 27/25 28/8}
33/10 36/22 42/25
46/21 46/24 47/4 49/8)
49/22 50/9 51/6 51/13
51/15 55/21 62/22
66/4 67/19 68/20 78/1
88/13 97/24 100/17
121/4 121/17 121/25
123/17 123/20 126/8
134/2 136/4 144/6
145/14 145/14 145/20)
146/2 146/22 146/25
147/1 147/13 148/6
152/5 152/8 152/8
152/15 153/5 153/6
159/5 159/7 159/10
173/1 173/6 173/11
174/1 174/23 176/16
179/7 180/9 190/18
192/18 196/5 196/6
196/25 197/12 197/14)
197/15 203/6 203/19
204/3
witnesses [8] 43/17
50/4 50/5 50/17 51/19I
57/4 115/14 115/16
won't [10] 52/16
52/21 53/12 53/13
58/25 59/2 104/11
136/22 146/1 209/1
wondering [1] 193/6
Woodley [1] 136/24
word [5] 4/1 71/4
120/4 136/16 136/18
wording [6] 74/18
76/14 132/24 140/5
140/7 205/9
words [11] 68/16
72/8 81/15 81/17
123/10 133/5 133/12
133/14 133/16 141/23)
172/23
work [47] 6/2 6/11
6/23 12/3 17/15 18/16I
19/3 19/7 19/14 22/7
27/21 27/23 28/11
28/25 31/15 31/16
43/10 43/12 43/13
52/12 78/15 82/8
85/25 91/6 95/11
99/21 101/10 104/13
104/17 113/17 113/20)
140/20 141/17 144/2
146/13 150/22 166/16)
178/5 178/14 184/11
188/19 191/11 192/15}
192/17 192/20 198/15)
208/12
workable [1] 154/20
worked [10] 6/4 7/8
7/11 12/15 31/6 44/16I
113/13 125/10 141/11
143/5
working [7] 55/11
82/20 84/2 112/20
178/7 178/15 199/5
working/policies [1]
178/15
world [1] 73/16
worried [1] 88/7
worry [1] 50/20
(87) when... - worry
WwW
worrying [1] 178/21
worst [1] 51/23
worst-case [1] 51/23
worth [2] 39/10
124/16
would [204] 9/6 12/4
16/7 16/8 16/10 16/23
17/22 17/23 18/4
18/12 18/16 18/17
18/20 18/22 19/21
20/10 20/10 21/4
21/11 21/22 21/22
21/23 22/22 29/1 29/2
29/4 29/9 29/10 30/9
32/8 32/17 34/17
35/17 36/3 36/6 36/7
36/8 36/9 36/11 36/12
36/13 38/6 38/7 41/18
42/6 42/7 48/20 49/8
49/14 50/1 50/23 51/1
51/8 51/23 51/24 52/1
52/11 54/19 54/23
56/2 56/2 58/3 58/3
59/15 60/19 61/3 61/4,
62/8 62/8 62/20 63/10
63/12 63/13 63/13
64/4 64/15 65/1 65/16
65/16 68/6 69/12
71/12 80/16 80/18
81/22 81/25 84/8 85/9
85/21 85/23 86/21
88/1 88/7 88/9 89/17
89/18 89/25 91/2 91/8
91/16 96/5 96/7 96/7
96/19 97/5 97/12
97/13 98/2 98/6 98/13
98/14 98/24 99/17
99/24 101/9 101/25
102/17 106/9 106/24
107/12 108/7 108/8
110/7 110/7 113/13
114/20 118/9 119/19
120/13 120/20 121/12)
121/13 121/21 121/22
122/3 122/4 125/6
131/12 131/21 136/17)
137/15 138/17 138/19
140/14 141/10 142/23
145/15 145/19 146/7
148/8 149/18 150/7
150/22 151/15 152/12)
152/19 152/21 153/1
153/6 153/7 153/25
155/22 156/2 159/13
160/24 161/24 162/9
162/16 162/22 162/25}
162/25 163/2 163/22
164/3 164/16 167/6
167/8 168/18 168/20
168/22 168/25 169/4
169/5 171/2 171/14
173/11 174/22 177/23}
180/23 181/21 183/9
187/9 187/16 192/9
195/14 197/13 200/11
201/4 204/11 205/2
205/6 205/7 205/15
205/17
wouldn't [14] 15/4
15/21 32/19 38/12
53/19 59/15 61/24
63/23 72/24 90/14
97/12 155/24 162/11
171/14
write [4] 50/22
110/11 116/23 116/24)
writing [5] 29/12 40/7I
66/22 66/23 135/5
written [8] 99/21
106/3 109/7 130/20
137/22 168/20 198/8
198/9
wrong [2] 32/12
176/17
wrongdoing [1]
50/10
wrongful [1] 8/2
wrongfully [1]
206/18
Y
yeah [6] 21/16 22/5
60/25 68/22 126/24
199/24
year [22] 2/23 4/20
9/3 28/22 65/17 65/18)
65/19 65/20 103/5
105/15 122/21 126/1
135/4 137/21 147/12
160/1 170/6 172/17
184/23 192/25 207/3
207/13
years [19] 7/4 13/17
13/18 28/18 29/20
29/21 57/21 61/16
65/9 77/12 85/19 93/7)
101/16 103/11 158/21
159/2 160/1 172/13
192/9
yes [208] 1/17 1/22
3/2 3/4 3/21 3/24 4/7
4/8 4/21 4/24 5/1 5/18
7/4 7/14 8/4 8/15 9/15)
11/19 11/23 13/1
13/12 14/2 14/5 14/13
15/7 15/12 16/22
17/19 18/22 19/17
20/1 20/22 21/5 21/15)
22/4 23/11 23/18
25/19 26/1 27/23 28/4
28/7 28/17 31/22 32/7
33/15 33/24 34/3 34/6)
34/11 34/15 34/22
35/20 36/8 37/18 38/6
39/1 39/25 40/12
40/17 40/25 42/5 44/2
44/7 45/4 45/6 47/5
47/20 47/22 48/10
48/22 50/13 52/5 52/9
54/16 55/2 57/14 58/8}
59/13 59/17 60/14
61/14 62/7 63/5 63/18
63/22 64/3 64/4 65/11
65/24 66/13 66/23
67/9 67/16 68/12
70/11 74/24 75/11
75/25 76/21 77/4
79/22 80/7 84/15 87/7
87/11 87/22 91/14
92/23 93/4 93/9 95/16)
98/17 100/25 101/1
101/21 102/20 104/16
106/21 107/11 108/17]
109/2 111/14 111/14
111/16 113/21 116/5
116/7 118/16 120/7
122/14 122/16 122/18}
122/20 123/11 123/14
124/2 124/15 125/3
125/3 132/5 133/24
135/21 136/24 136/24
136/25 137/17 138/22
139/1 139/2 141/22
143/21 144/5 145/10
145/14 145/25 146/3
147/16 149/9 155/14
156/18 157/4 161/15
164/20 164/21 164/22
165/14 169/15 169/20
170/3 171/4 171/19
172/5 172/7 172/8
172/9 172/21 173/9
174/5 175/1 175/3
177/23 178/23 178/25I
179/10 179/16 181/23
184/3 186/19 192/1
192/25 193/1 194/11
197/3 197/4 197/23
198/1 199/13 201/12
202/11 204/8 206/1
206/7 206/8 206/13
207/11 207/18 208/21
yesterday [2] 54/1
113/22
yet [12] 3/17 29/5
43/22 64/5 64/21
67/21 96/17 159/22
173/5 173/20 177/19
180/13
Yorkshire [1] 133/13
you [555]
you'd [2] 27/19 93/13
you'll [6] 144/17
159/2 167/25 187/14
191/11 192/19
you're [30] 19/8 28/3
29/16 34/22 41/7
44/13 51/13 52/13
67/13 68/18 69/3
98/18 104/21 122/11
145/10 145/11 152/25)
156/1 158/12 158/20
164/10 170/8 192/4
192/7 194/3 199/4
199/12 206/5 207/4
207/12
you've [39] 6/8 7/8
9/18 13/25 15/17 18/6
19/12 24/1 27/25
31/10 33/8 37/2 43/5
44/3 44/22 56/20 60/4;
65/25 66/3 66/7 92/21
104/3 108/19 123/6
147/23 171/21 179/7
179/12 181/20 187/13}
188/7 192/2 197/1
197/5 198/4 199/2
200/2 202/16 203/15
your [206] 1/10 1/23
2/1 2/16 3/5 3/7 4/14
5/2 5/4 7/2 7/25 8/20
9/12 9/21 11/24 12/7
12/21 13/13 13/25
14/11 14/14 14/23
15/2 15/18 16/8 17/4
18/1 18/6 18/6 18/12
18/15 18/20 19/4
19/13 20/24 21/8
21/23 21/25 22/6
22/11 22/13 22/25
23/4 23/10 23/14 24/2
24/9 25/4 25/18 25/24,
26/20 27/25 28/1 30/3)
30/21 31/18 33/4
33/10 33/19 36/3
36/22 36/24 37/2
37/16 41/13 43/8 46/8
51/14 53/2 53/3 56/8
56/11 57/25 58/3 58/6
60/1 61/21 62/22
62/22 62/23 63/2 63/4
63/6 63/6 63/16 63/21
63/23 64/16 66/4 66/7,
66/17 68/5 68/10
68/20 72/9 72/17
74/12 75/9 75/24 76/2
77/14 77/17 80/6
81/15 81/16 81/16
86/11 87/13 87/25
90/18 93/3 94/21
95/23 98/9 100/15
100/16 101/10 101/17)
101/19 102/12 104/20)
104/21 111/1 115/4
115/10 116/4 118/12
119/21 120/16 122/23}
123/12 123/17 123/20
123/21 132/18 134/7
136/11 137/6 139/7
139/24 144/25 145/7
146/5 147/12 150/21
152/4 156/15 158/22
159/15 159/21 160/15]
160/18 161/1 161/25
162/8 163/5 163/7
164/7 166/14 167/18
168/12 169/8 169/13
169/14 169/21 169/24)
170/10 171/8 172/4
172I/7 172/14 173/15
174/8 174/13 176/13
176/17 178/3 178/20
179/5 179/12 181/20
181/20 182/5 182/18
183/5 183/18 184/2
184/12 192/3 192/5
192/6 192/20 192/24
198/4 198/23 199/2
199/10 199/18 201/15}
202/2 202/4 204/3
205/9 206/21 207/3
208/13
yourself [5] 22/21
23/17 73/6 123/16
138/24
z
zoom [3] 22/10 23/12
132/21
(88) worrying - zoom