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The Post Office Horizon IT Inquiry
Friday, 18 October 2024
(9.00 am)
MR BLAKE: Good morning, sir.
SIR WYN WILLIAMS: Good morning, Mr Blake. Before you begin
today's evidence session, in my haste to publicly
announce the revised arrangements for today's hearing,
l inadvertently omitted to thank Mr Bartlett for
providing two detailed witness statements and giving
oral evidence during the course of the whole of
yesterday. So I'd like to repair that omission by
thanking him publicly now.
MR BLAKE: Thank you very much.
This morning we're going to hear from Mr Foat
remotely. (Pause)
Ah, either Mr Foat is on silent, or there is nothing
in the room.
THE WITNESS: Good morning.
MR BLAKE: Ah, there we go.
BENJAMIN ANDREW FOAT (affirmed)
Questioned by MR BLAKE
MR BLAKE: Thank you very much, can you state your full
name, please.
A. My full name is Benjamin Andrew Foat.
Q. Thank you very much, Mr Foat. You have produced a very
large number of witness statements throughout the course
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A. That is correct.
Q. Thank you very much.
Mr Foat, all of those statements will be uploaded to
the Inquiry's website in due course. You are
a qualified solicitor; is that correct?
A. Correct.
Q. Before joining the Post Office, you worked in a number
of different firms in Australia and also in England.
A. That's correct.
Q. You joined the Post Office in August 2015 as Head of
Legal for Financial Services --
A. Correct.
Q. -- and you became Legal Director in 2016 and worked in
that role until 2019?
Correct, in August 2016 I was appointed Legal Director.
Thank you. During that period Jane MacLeod was General
Counsel?
oP
That's correct.
You then became General Counsel from May 2019?
Correct.
prop,
You have been on a leave of absence for health reasons
since April 2024; is that correct?
A. Well, a mixture of time to focus on the Inquiry, I was
due to give evidence in Phase 5 and 6 and, again, for
Phase 7. So it's a mixture.
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18 October 2024
of this Inquiry. I'm not going to take you to each one
individually but I'll just go through each of them to
confirm that they are all true to the best of your
knowledge and belief.
The first witness statement is POL00114188ds, that
is dated 23 March 2023.
The second is dated 21 June 2023 and has a URN of
POL00118164ds. That one, in fact, you have sworn on
your last appearance.
The third witness statement is WITN09980300, dated
22 August 2023.
The fourth is WITN09980400, dated 3 May 2024.
The sixth is dated 8 October 2024, and has a URN of
WITNO09980600.
There are also a number of interim disclosure
statements. The first of those is POLO0114170ds, dated
27 May 2022.
The second is POL00114173ds, dated 18 October 2022.
The third is POL00114176ds, dated 30 November 2022.
The fourth is POLO0114177ds, dated 12 January 2023.
Are you able to confirm that your signature appears
on all of those statements?
It does.
Can you confirm that all of those statements are true to
the best of your knowledge and belief?
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Thank you very much.
Today will be in two halves. The first will address
issues relating to Phases 5 and 6, and that deals with,
for example, the Group Litigation, the CCRC, et cetera.
The second half will address Phase 7, so the current
practice at the Post Office. Each of those will
probably last around an hour each and we will have
a break in between the two, and we will see how we go in
terms of timing. It may be that we take a third break
as well.
To start with, knowledge of Horizon issues. You
refer in your witness statement to being told that
Horizon was robust. I think you've said like an air
traffic control system. Can you assist us with who told
you that and how you were told?
So upon joining Post Office when I was working in the
Financial Service area of the business, I think the
Panorama episode had aired and there was a communication
that was issued to employees that set out Post Office's
position in relation to the matter, and over the -- and
that set out that Post Office thought that the system
was robust.
In terms of the comment about the air traffic
control, that was a statement that I heard on a number
of occasions from people. I don't recall specifically
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The Post Office Horizon IT Inquiry
the individual who said it but it was a phrase that was
used. I suspect it came from someone in the IT
Department, given the nature of it. But that was -- it
was a comment that I remembered that phrase, because it
seemed like an unusual comparison.
You also say that you knew very little of the Post
Office's role in prosecuting subpostmasters when you
joined. Was the Panorama programme the first time that
you became aware of that role?
Correct.
Was the prosecution of subpostmasters something that was
discussed in the Legal Team in the early years of your
time at the Post Office?
In 2015, not that I recall. At that point, I was very
much focused on coming up to speed of what was needed in
my Head of Legal Financial Services role, specifically
the establishment of the Banking Framework Agreement,
establishing the Post Office Insurance Intermediary
business.
So Post Office established, for the first time
an insurance intermediary that was regulated by the FCA,
and I sat on the Risk and Compliance Committee of that,
and the Executive Committee. So I don't really recall
much discussion about the Group Litigation. It was
clearly something that the organisation was involved and
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include legal manuals, so trying to make sure that the
company understood all of the legal matters that it
actually has, understand where they come from in the
business, so that the company can have a more mature
approach to the management of legal risk.
Thank you. I'm going to take you to a document from
2017 that touches on matters relating to prosecutions.
Could we bring up on to screen POL00357840. For
your assistance that's at E41. It's an email chain
from, as I say, June 2017. If we scroll down to the
bottom of the first page, we can see it's an email that
begins from Alisdair Cameron to you and he says as
follows, says:
"The guidance yesterday was that we should not
attempt to prosecute any cases where the losses had
arisen from or were identified via trading and Horizon
rather than a straight theft, until two things happen.
Firstly we complete the Deloitte work on systems
reliance. Secondly the CCRC opine. The former is fine
and I gather we are close. The second I want us to make
as a formal judgment with Paula engaged because it is
a big deal, with an open timetable and a strong sense
that this is now costing us blood.
"My preference would be to do the Deloitte work and
then seek a prosecution relying on Horizon in a single
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there were general communications, but it wasn't my
focus at that point.
In terms of the Head of Legal for Financial Services,
did any matters relating to prosecutions come up in that
particular role?
No.
No. How about the Legal Director role?
No, when I was appointed to Legal Director, I had
a discussion with Jane MacLeod about what she wanted me
to do. It was a newly established role, so the role
didn't exist prior to me doing so. She said, in terms
of the division of labour, that she would focus on the
Board issues and the Executive, and what she wanted me
to focus on was managing the Legal Team of this circa 20
lawyers and that she wanted me to focus on improving the
legal operations of the business because there, to put
it frankly, there wasn't much by way of legal
operations.
So that was the division of labour.
What do you mean by legal operations, briefly?
Legal operations is the controls and policies that
a Legal Department can put in place in order to not just
help the Legal Department but also help the business.
So that might include a central repository of contracts,
it would include contract framework agreements, it would
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sympathetic case -- admission, good evidence, not too
sympathetic a postmaster, not part of the GLO etc. And
then we will know.
“In the meantime I have a specialist team setting up
prosecutions that will never happen. We can get them
doing other stuff for now but I need to lay them off if
the prospects aren't there?"
If we scroll up, we can see a response from Jane
MacLeod. Halfway through that second paragraph, she
says:
"Since security operations transferred out of LRG
Can you assist us, what does LRG mean?
LRG is Jane MacLeod's team, so the "L" stands for Legal,
"R" stands for Risk, and "G" stands for Governance,
which in effect is meant to be secretariat.
Thank you:
"Since accurate operations transferred out of LRG
last September, we have discussed only one case that
could potentially be subject to prosecution. Most of
the prosecution team -- including the necessary legal
resource, left the business 2 years ago under the wave 1
redundancy programme.
"So one of the factors to be considered would be
whether we want to undertake our own prosecutions with
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The Post Office Horizon IT Inquiry
the likely increased cost, or whether we refer them to
the police and provide the necessary support.”
Can you assist us with why, in June 2017, you were
sent emails or copied into emails relating to the
potential resumption of prosecutions?
Yes, certainly. So I sat on Al's property Board meeting
and so, in the course of that meeting, he happened to
speak to me -- well, it was actually after the
meeting -- and he expressed the desire to resume
agent -- what was referred to as agent debt recovery,
and I think you can see from his email that he
illustrates that.
And so, because he had spoken to me, he wrote the
email to me, but then you see, of course, that it's
actually Jane who responds to him because the way that
it was structured in terms of the Group Litigation is
that Jane and Rod Williams, who was the Head of Legal
for Dispute Resolution, was in a working group and
a programme to manage the Group Litigation. And that
had a SteerCo and obviously a Board subcommittee. So
that's why Al raised the question with me but it's why
Jane actually responds.
Did you have a view in respect of Mr Cameron's proposal?
I didn't have a firm view. I felt I was a bit too
removed from the issue to be able to opine on it and
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Litigation.
I think what this email shows is that I obviously
don't know enough of the context of what's being
discussed and I'm trying to get up to speed. One of the
things I had asked Rod to do was, although I wasn't
involved -- and indeed, I had actually asked to be
involved, but if Rod could keep me up to date just on
the milestones of the GLO.
Did you work in an office with Rodric Williams?
Correct.
Did you meet regularly; did you have team discussions?
Yes, I had one-to-one discussions usually on a monthly
basis with all of my Heads of Legal. Rod predominantly
worked on the Group Litigation. However, he also was
responsible for a number of other matters, as well, and
so -- and importantly, given my focus was on legal
‘operations, I was keen to make sure that, for him as
Head of Legal for Dispute Resolution, that he was
looking at a claim protocol, for instance, so that if
claims are served on Post Office branches, how do we
make sure that we actually get to see those claims in
the Legal Department?
So there are a number of different operations that
I was requiring the Heads of Legal to undertake, for
instance making sure that all matters that they had
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Jane had answered the question, had responded in the
email.
Thank you. I think you do take some action following
this. If we could turn to POL00249526, that's your E70.
I think you forward this chain to Rodric Williams and
ask him to do some further work on it. You say:
"Can you do a [background] note on this area ...
"The questions that need to be answered including:
"The time limit on bringing a prosecution;
"The different reasons for not pursuing prosecutions
“What categories of loss should be pursued ...
"Whether the prosecutions team help with the civil
investigations that need resource ..."
Can you assist us, at this point in time, where did
Rodric Williams fall within line management: were you
managing him?
Yes, so I managed Rod holistically in terms of all of
his remit. However, the way that it works at Post
Office is that, in this particular case, because the GLO
programme wasn't a BAU matter, Rod reported directly to
Jane MacLeod on the issue. So that's why, for instance,
I'm not involved in the working groups, I'm not involved
in instructing counsel, I'm not involved in the GLO
steering committees or attending the Board on the Group
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conduct of were set out, so that we had a central
repository, and also making sure we understood where the
accountable owners were in the business, and also giving
some estimate of time, so that we could better
understand where the risk -- the legal risk of the
business sat.
So Rod was heavily involved in the GLO but he did
have number of other obligations, which I was
particularly interested in making sure continued.
Was one of his roles related to matters relating to
criminal matters?
Correct. Though I understand that Rod had a firm called
Cartwright King and that he would engage those matters.
I wasn't involved in those matters, but I understand he
reported to Jane on those.
Would he have been your principal, go-to person within
the team for matters relating to criminal prosecutions?
During my tenure, yes, that's correct.
Thank you. I'd like to take you to a document that you
will not have seen at the time it was produced. It's
POL00315631, that's your E45. This is a document that's
well familiar to the Inquiry. You may have seen it in
previous phases. It's an advice from Cartwright King,
dated 27 March 2015. It addresses what we know as
Project Zebra, the investigation relating to remote
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access. I'd just like to read to you a few passages
from this note. They say, "Note: Deloitte Report --
Questions for [the Post Office]".
I'll start at paragraph 2. They highlight at
paragraph 2 that, within the Deloitte report, it:
"identifies a method of posting ‘Balancing
Transactions’, that is, the post of '... additional
transactions centrally without the requirement for the
transactions to be accepted by the subpostmasters ..."
The paragraphs goes on to indicate that, ‘Whilst
an audit trail is asserted to be in place over these
functions, evidence of testing of these features is not
available
There are also later extracts in that report that.
are reported to be of concern. The first is:
"For balancing transactions ... we did not identify
controls to routinely monitor all centrally initiated
transactions to verify that they are alll initiated and
actioned through known governed processes.
“Controls that would detect when a person with
authorised privileged access used such access to send
a fake basket into the digital signing process could not
be evidenced to exist’.”
Then Cartwright King say this:
"This material is potentially disclosable in cases
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Was this issue, so remote access, potential
disclosure, in criminal cases, those who had been
convicted of criminal offences, was that ever brought to
your attention by Rodric Williams?
No, and I think this document is a document before I was
employed at --
Absolutely, yes. During your time though, I mean, you
had some involvement in the Group Litigation, for
example, and we'll get to that in due course. Did
Rodric Williams ever bring up this knowledge that we see
in this document?
No.
No. Looking back, what is your view of Mr Williams’
competence and credibility?
My observation that I had was he was a very experienced
litigation lawyer. I recall that I think he commenced
his legal career in New Zealand. He was also admitted
to the New York Bar. He had also practised in the
United States, and he had also practised here for number
of years, all specialising in commercial litigation.
I found him to be a very diligent and passionate lawyer.
I didn't have issues around his technical competence; in
fact, I found his technical competence to be sound.
Do you have any reflections on that now or is that still
your view?
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where a convicted defendant had raised, as a part of his
defence (either expressly or by implication), the
suggestion that:
"[The Post Office] or some other third party had
manipulated, interfered with or otherwise compromised
Horizon; or
"Horizon was created or was the victim of a system
generated but inexplicable loss/entry/transaction(s); or
"The defendant simply had no idea how the relevant
loss arose."
Reading this, the Zebra report had identified
a number of pieces of information relevant to the issue
of remote access and the discussion is as to the
disclosability of that to those who had been convicted.
Moving on to paragraph 6, it refers there to
a telephone conference with Rodric Williams of the Post
Office and Andrew Parsons of Bond Dickinson, who were:
"... informed that the Deloitte Report was correct
where it identifies a method of posting of ‘Balancing
Transactions'."
It says:
“We were instructed that it was possible to ‘inject’
a transaction unilaterally into a branch's accounting
records without the consent, approval or indeed
knowledge of the [subpostmaster] ..."
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Well, I understand that Mr Williams has identified that
there are areas that were missed and, of course, with
that in mind, obviously any lawyer, you know, would be
incredibly mindful of missing such pertinent
information, which particularly in the circumstances of
where it can lead to such devastation, and I know that
that has played on Mr Williams.
But my genuine observation of working with him is
that he is a person of integrity and he's tried to do
his best in the circumstances, but I acknowledge that
clearly issues have been missed.
I'm going to take you to a number of emails regarding
document retention that were sent by Mr Williams. Can
we start, please, with POL00255859. That's your E47.
Thank you, sir.
This is an email of 20 April 2016. We can see near the
bottom of the distribution list you were a recipient of
this email.
If we scroll down, please, it says:
"As you may be aware, 91 mostly former postmasters
have issued a High Court claim against Post Office
Limited advancing allegations about the Horizon IT
system and the Post Office's engagement with them.
A list of the 91 claimants is attached, and we have been
told that others may join the claim in due course."
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This email is 20 April 2016. Were you aware of the
Group Litigation before this email?
Yes, I would have been. At this point of time, I was
Head of Legal for Financial Services but I -- even upon
joining Post Office, I was made aware that there was
this matter. Indeed, I think I received communications
from the business in a relatively short time, having
commenced at Post Office. During this period, though,
for the reasons I've given before, I wasn't particularly
focused on this and I didn't supervise Rod at this
juncture.
Thank you. A number of instructions. The first is:
"You must not destroy or delete any documents which
may be relevant to the claim ..."
The second:
"You must not meant any existing documents that may
be relevant to the claim."
It's the third that I'd like to focus on, which is:
"You must recognise that any documents that you
create from now on may have to be disclosed to the other
side in the case. If in any doubt, think about whether
you would be happy for the email or document to be read
out loud in court.”
To what extent, at this point in time, were you live
to that third issue?
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an advice or guidance note on what is legal professional
privilege.
I don't really recall specifics about it, other
than, I mean, generally the maturity of -- or the
business's knowledge about such legal matters would have
been very limited.
From your interactions with, for example, the Executive
and the Board level, as you progressed through your
career, what was your view of their appreciation and
understanding of legal professional privilege?
I think they perhaps had a misguided understanding. So,
for instance, I think people thought that the mere fact
that you include a lawyer in correspondence, that that
may make a document become privileged. That's not
correct. Legal professional privilege is set out in the
Three Rivers decision under English law, and so, you
know, basically it's twofold: one, it arises under
litigation; and/or the provision of legal advice. And
that's the only two bases upon which -- and I'm
‘over-simplifying the topic area, of course, but that is
the two bases upon which legal professional privilege
applies.
Jane MacLeod has provided a witness statement to the
Inquiry where she says that often documents were marked
as privileged when they weren't, in fact, privileged;
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I mean, I would clearly have received the email.
I don't particularly recall reading the email, but
I understand -- I mean, in some respects, this is
a general email that would be sent to make sure that
the -- any organisation, when it's in receipt of legal
proceedings, that it makes sure it tells the business
that it needs to retain its documentation.
Do you see any issue with the third point or, in your
view, is that standard wording?
I think what Rod is -- and it's perhaps an informal
expression, but what he's articulating to the business
here is for them to be mindful that obviously when you
commit information to writing, of course that is -- that
can be disclosable and it's just reminding people of
email usage.
Was legal professional privilege more broadly something
that was well understood within the Post Office at this
time?
I don't think it was well understood -- and, forgive me,
this is going back several years. Legal professional
privilege was an area that I think training was actually
provided to certainly the Legal Department, to make sure
the lawyers understood, and I think -- there was
training and particularly when we had what we referred
to internally as the "legal academy’, we issued I think
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was that your experience?
I don't think I was involved, in terms of the disclosure
parts of the Group Litigation, because it was
essentially before my time. But as a general point,
I could imagine that that is the case: that people -
certainly if it's done by business colleagues -- though
query why business colleagues would be writing the word
"Privileged", that is something that a lawyer would
write.
Ms MacLeod has also highlighted that from April 2016,
when the business was informed that Freeths had filed
aciaim, she was more sensitive about confidentiality
and privilege issues, given the risk that the litigation
was imminent, and some updates were therefore given
verbally only from that point. Is that something that
you experienced?
Well, I - as said, as Legal Director, I really wasn't
involved in the Group Litigation programme but I was
aware of the fact that Jane would give verbal updates to
the Board. I think -- and this is probably some time
later, probably in, I think, 2018, but she was
particularly concerned around the disclosure of
information between Post Office and the shareholder
and/or UKGI. And so one of the areas that she had
highlighted to Rod -- and I think I was included in
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that -- was the need for a litigation protocol or
a document protocol between the respective
organisations, so that, if there was what's called
common interest privilege, that that could be
maintained.
Do you think that that impacted in the level of
information that was shared with UKGI?
I really don't think I could comment because I simply
wasn't there.
I'm going to return to the circular email from Rodric
Williams, I'll take you to another version of the same
email. It's POL00245909. That's your E49. We're now
on 23 November 2016.
If we scroll down or zoom out, we can see it's
exactly the same email that we've already looked at, in
terms of the 1, 2 and 3. If we scroll up we can see
it's sent by Rodric Williams to Rob Houghton and Jeff
‘Smyth; do you know who they were?
Yes, so Rob Houghton was the Chief Information IT
Officer of the company between -- and forgive me if the
dates aren't quite precise -- but I think between 2015
or 2016 and 2019, and Jeff Smyth became the Chief
Information Officer in or about 2022 onwards.
Thank you. He highlights there:
"Point number 3 in the email highlights the need for
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If we could please turn to POL00293080, that's your E57.
Moving on in time slightly in the summer of 2017, we're
now in August 2017, this is a letter to the registrar of
the Criminal Appeals Office on Post Office headed paper
sent by Mr Williams. If we scroll down, we can see he's
the author of this letter. That middle paragraph says:
"Royal Mail Group and Post Office became separate
organisations on 1 April 2012 ... and we are currently
establishing whether Royal Mail Group or Post Office
hold material in relation to this case."
So there is an appeal to the Court of Appeal in the
case of Mr Butoy, and Mr Williams appears to be dealing
with that matter. You were, by this stage, his line
manager; is that correct?
Correct.
Did you see or were you kept informed of these kinds of
developments?
No, as I said, matters that were pertaining to the Group
Litigation, that was something that he would have
separate conversations with Jane MacLeod directly on.
She would quite regularly come down to the floor, take
him into a meeting room, have conversations with him on
the matters that related to the Group Litigation.
I think, subsequently, I had seen that there -- as
part of trying to make sure that there's good legal
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care when creating documents.”
Are you aware of a concern within the Legal Team
focusing in particular on the creation of documents and
the need, for example, for things not necessarily to be
written down?
No, I was not.
The same email chain is sent in May 2017. We can have
a look at POL00415520, that's your E50. There are other
examples that I could take you to but I don't think we
need to because what's relevant really is just the point
in time. If we scroll down to page 2, we see there the
same email sent in May 2017. By this stage, were you
supervising Mr Williams?
In May 2017, yes, I -- Rod reported into me generally
but not in relation to this matter.
No, but generally, and from your observations of
Mr Williams -- because we'll see there were a number of
other occasions where the same email is forwarded -- was
he somebody who struck you as particularly concerned
about the recording or not recording of particular
information in light of legal professional privilege
concerns and in light of the litigation?
I wasn't aware of that concern. I'm not disputing what
you're saying but I personally wasn't aware of that
concern.
22
operations in the company, that it was noted -- in a --
I used to try to get the team to get monthly reports up.
to Jane MacLeod, and I have subsequently seen that there
was a reference -- I think there's a sentence in
relation to this matter -- but I was not involved in
this appeal at all and I didn't give any advice or any
decisions in respect of it.
Your references to the Group Litigation -- this is
obviously separate, this is an appeal to the Criminal
Court of Appeal -- was that also being kept separate
from your role and responsibilities?
Correct, because they were inherently linked and so
I did not have any involvement in that.
At this point in time, was there any consideration given
in your department to expertise in criminal law,
somebody who is well familiar with criminal disclosure,
for example?
At this point, my understanding was that Rod would
interact with Womble Bond Dickinson, Cartwright King and
I think there were counsel that were involved. But we
did not have a criminal lawyer and I think that part of
the reason was that, at this point, and since I had been
Legal Director, Post Office did not undertake criminal
prosecutions. But I accept your -- I accept your point.
I think you may be suggesting that it ought to have had
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its own criminal lawyer but my understanding was that,
because Post Office wasn't undertaking criminal
prosecutions, it therefore didn't have a criminal
lawyer, and we had a fairly tight inhouse Legal Team.
Do you think you had sufficient expertise within the
department to be able to be dealing with, for example,
the Criminal Cases Review Commission?
As I said, I mean, that is a matter again that Rod
worked with Jane on. I understand he did have support
through Cartwright King, who I understand are criminal
law specialists, and that he had counsel, and I never
heard from him that he felt unsupported in that way. My
observation was that there wasn't that much, in terms of
any criminal law issues, at that time, but I'm clearly
removed from the details of all of this. So I wouldn't
have had the best -- I wouldn't have been in the best
position to have made such observations.
If we could turn to POL00257831. That's your E54. This
is an appeal chain that you're not copied into, and I'm
just going to really, by way of timeline, if we scroll
down to the bottom we're now in October 2018. This is
an email from Mr Williams to individuals at UKGI. He
says:
"The purpose of this email is to let you know that
on Thursday, 11 October 2018 the Criminal Court of
25
matters with you?
Because she's the General Counsel and it was her
decision to divide the work in this way, which I don't
think is necessarily unreasonable, in the sense that the
Group Litigation was a significant matter and, as the
General Counsel now, I think she wanted to have the
Subject Matter Expert -- which internally within the
team was Rod -- and she wanted to work in that way that
she had that direct access.
Moreover, there were a significant number of legal
issues other than the Group Litigation that also needed
to be managed, which was my focus, and so that was the
basis upon which she divided the labour.
I did actually ask twice to -- I offered my services
to help on the Group Litigation but she said that that
wasn't necessary.
What was your understanding as to why that wasn't
necessary?
Because she said we already had a lot of lawyers
involved in the matter.
If we could please turn to POL00259733. That's your
E23. This is an email chain from 29 November 2018. If
we scroll down to the bottom, we can see it's an email
from Grove Road Post Office, sent to a number of people
including Paula Vennells.
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Appeal will hear an application from a former postmaster
seeking permission to appeal...”
If we scroll up, we can see that is relating to the
case of Mr Butoy, who we saw a letter in relation to
just before. It says:
"Mr Butoy's application for permission to appeal was
refused earlier today."
Then in the next paragraph it says:
"In response to Tom's enquiry from earlier this
morning, Mr Butoy has not applied to the Criminal Cases
Review Commission for a review of his conviction, ie he
is not one of the 33 Post Office prosecutions currently
being reviewed by the CCRC."
Were you aware at this stage of the significant
number of Post Office prosecutions that were being
reviewed by the CCRC?
No. My understanding at this stage -- I was aware that
the CCRC had been involved in the Group Litigation.
I think my understanding at this point was the CCRC was
waiting to understand what was happening with the Group
Litigation. I mean, I had a very limited understanding
around the process around the CCRC at this point.
As somebody who managed Mr Williams, why is it that so
much is taking place between Mr Williams and Ms MacLeod,
rather than Mr Williams discussing these kinds of
26
If we scroll down, we can see the author says:
"I have not left my position as postmaster for Hope
Farm Road and Grove Road post offices. I still hold
a valid contract for both branches. I am however
precautionarily suspended from my duties at the moment
due to your client's perception of circumstances that
Ihave, as yet, not been given the opportunity to have
a dialogue with your client's representative to put my
side of the story to your client. I have a meeting
arranged for 4 December 2018 to discuss this.
"I dispute that I owe your client the sum of
[£35,000] in fact I am currently making repayments
towards this figure from my remuneration albeit under
duress and without prejudice.
It then says:
"To this end I have registered as a secondary
claimant to the Group Litigation Order currently being
dealt with by the High Court in the matter of Bates &
Others ..."
If we scroll up, we can see a response, it's
forwarded, I think, to you by Jane MacLeod. She says:
"Please get someone to deal with this.”
If we scroll up above we see your response:
"We are on it and I'll revert back with a note to
you on how it is being managed."
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By November 2018, had you become more involved in
matters relating to the Group Litigation?
Not the Group Litigation programme itself but I think at
that stage the issues around the contracts and agent
debt had been raised, and so I think, in this respect,
it would have been either the Head of Legal for Retail
because the -- it's a current postmaster, I think, at
that point, and/or it would have gone to Rod.
Is it fair to say that by November 2018 you were aware
of issues concerning the resumption of prosecutions,
those first documents that we saw, and you were also, to
some extent, involved in matters touching on the Group
Litigation?
I don't think I was aware of the resumption of
prosecutions.
Involved in discussions relating to the resumption of
prosecutions?
I was not involved in resuming any criminal
prosecutions.
Involved in discussions relating to those: the emails
that we saw when we started today?
Sure but I was not involved in any discussions relating
to that matter. I did not instruct Cartwright King.
I did not make any decisions on that. So whilst it may
be in a document that I have been copied into, I was not
29
fit within your team?
So because Jane had said to me that Rod was spending,
understandably, a lot of time on the Group Litigation,
she -- and, of course, I needed him to do other
litigation work, we came to the view that we needed
an additional litigation lawyer to be part of the
inhouse team. So he became involved in supporting the
litigation areas within the Legal Department.
I think -- actually, no, I don't recall which law
firm he may have come from.
He says:
"I know there's a framework around information
sharing with UKGI -- my immediate thought concerns the
status of the document when it goes across in terms of
privilege and restrictions from subsequent disclosure by
them under [the Freedom of Information Act]?"
If we scroll up, we can see an email from Amy Prime,
junior solicitor at Womble Bond Dickinson. She's
responding to him, so the "Ben" referred to there is
him. She says:
"It would be easier to maintain privilege over
an advice note to [the Post Office] that is being shared
with UKGI, rather than a note to UKGI. The problem with
a note to UKGI is that they are not the lawyer's ...
client and so legal advice privilege does not apply. We
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involved in that matter whatsoever.
In relation to the GLO, by November 2018, is it fair to
summarise as some involvement on the sidelines?
Well, I may have been copied into matters that related,
if you want to say "on the sideline", but to be clear,
I did not attend the Working Group, I was not involved
in instructing any external lawyers, I was not involved
in attending the SteerCo, in which decisions were made,
and I did not attend the Board subcommittee that made
the decisions in respect of the matter.
It's not to say that I didn't have any information
about it and I absolutely was aware of the major
milestones. So, of course -- and, indeed, I actually
asked Rod to keep me up to speed on the major issues.
Thank you. 15 March 2019, so moving on a little, that
was the Common Issues Judgment, and I'd like to look at
an email of the same day, that's POLO00023809. That can
be found at your E9. If we start at the bottom of
page 3 into page 4. If we scroll up slightly we can see
it's an email from Jane MacLeod and you're copied in at
this stage:
“Please see attached a first draft of the ‘more
detailed’ briefing to go to UKGI ... tomorrow ... on the
detail of the judgment."
If we scroll up, please. Mr Beabey, where did he
30
think this would be a document prepared for the purpose
of litigation, and therefore attract litigation
privilege, but it's not 100% clear cut.”
If we scroll up, there's a response from
Mr Underwood, Mark Underwood. He says:
"Amy -- please see attached. Presumably, similar
problems arise re privilege and [Freedom of Information
Act]. Is there a way to navigate our way through those
in relation to the attached briefing which Patrick has
prepared for UKGI/Ministers?"
The response is the first email on the page.
Ms Prime says:
"Yes, the same problem arise [for] this document.
"For UKGI, is necessary to produce a separate paper
to Jane's briefing note which is being shared under the
protocol?
"For BEIS, it is not 100% clear cut that litigation
privilege would apply to this document ..."
She says below that:
"We would therefore recommend that the document does
not contain any information that would be awkward or
damaging to Post Office if it was publicly released.”
Now, that's an email chain that you're copied into.
I think you've already explained some concerns within
the Department or from Ms MacLeod relating specifically
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to UKGI. Were there concerns at this point in time in
the business with sharing certain information with UKGI
because of privilege issues?
Yes. I think Jane had concerns and I think it may have
even predated this document, but I -- my recollection
generally is that she did have concerns about
information, the way it could be communicated to UKGI
and the Government Shareholder. I think her concerns
were whether a privilege would be lost or, if
information does go to a Government department and it's
then on-forwarded or shared further, the -- of course,
as lawyers will know, that then undermines or creates
a risk that you lose confidentiality, you lose the
privileged status that is attached to the document.
Thank you. That can come down.
The 9 April 2019 was the recusal judgment. Were you
in any way involved in that matter?
No, but I was made aware of the recusal. I remember
Jane -- I remember having a conversation with Jane and
she said -- she informed me that recusal application was
going to be made in the Group Litigation. I expressed
surprise. I made the -- I actually remember the comment
saying that, "Oh, I thought it would be a high bar", and
she said, "No, actually, it's" -- and then she
articulated what the legal test was to me.
33
Irrespective of the fact that it was her job to manage
the overall risk, do you think, at this stage, you had
been given sufficient information, sufficient updates,
sufficient briefings, relating to matters such as the
Group Litigation and the CCRC?
No, because although I, from my own pro-activeness,
asked for updates, I wasn't involved in any of the
Working Group meetings, I didn't instruct counsel,
I didn't attend the Executive SteerCo that oversaw this
matter from an Executive position in the company, and
nor did I attend the Board subcommittee, which made all
of the decisions in relation to the matter.
The General Counsel ultimately has responsibility
for supporting the business to manage its legal risk and
so there is no higher person, and that was her decision
to manage it in that way. And she was supported.
I think it's important to note that she was supported by
several QCs because when I offered my support -- not
just once, twice, I recall offering it -- she was
supported by multiple Queen's Counsel, now King's
Counsel, as well as a number of barristers and a law
firm.
Thank you we'll just go to that document. It's
POL00359988, it's at your E42. It's an email from
Ms MacLeod to herself. I think she sends it to her
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So for some reason that's really the only bit that
I remember, but I was aware that the recusal application
was going to be made but, again, I didn't appoint any of
the barristers -- Lord Neuberger, Lord Grabiner,
I wasn't involved in their appointment -- and I wasn't
involved in the Board meetings.
One of your areas of responsibility as Legal Director
was managing legal risk. Do you think you were
sufficiently informed by Ms MacLeod, by those involved
in that litigation of the legal risks involved at that
stage?
It's Ms MacLeod who, as the General Counsel, ultimately
manages and supports the business to manage legal risk.
So I reported to Jane MacLeod. She was my boss and she
is an admitted solicitor and she was managing the Group
Litigation. So I -- as an independent regulated
solicitor, I didn't think it's unreasonable for the
General Counsel to take ownership of the matter and she
had a different role in the Group Litigation, in that
she would -- she attended the Common Issues trial,
I think almost every day, and she attended the Horizon
Issues trial. So that was her decision to resource the
legal matters in that way.
We're going to look at one last document before we break
and it relates to Ms MacLeod stepping down.
34
personal email account from perhaps her work email
account -- or certainly two of her own accounts. It's
subject is "Update":
"Monday
"Meeting 15/4/2019", with Mr Cameron.
I'll just read to you a few passages from that. She
says there:
"Al then said ‘I'm going to say something that will
make you angry’
"Then informed me that 'we' weren't happy with the
litigation" --
I'm sorry to interrupt. I think the connection dropped
‘out. If you're able to -- I got the beginning of the
document.
Thank you. So it's an email from Ms MacLeod to herself.
She records a meeting from 15 April 2019 with Mr Cameron,
and she sets out there in the fourth bullet point that
Mr Cameron said to her "I'm going to say something that
will make you angry":
"[They] informed me that 'we' weren't happy with the
litigation, and wanted to bring in ..."
Is that Herbert Smith?
Correct. That's what I presume, yes.
"... to run it.”
So what was Herbert Smith's role before this?
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Herbert Smith was not involved at all.
Do you know who made the decision for them to be brought
in?
l understand subsequently that the Chairman -- or,
sorry, obviously the former Chairman, the Chairman at
the time, Tim Parker, the Government Shareholder
representative, Tom Cooper, together with Al Cameron who
was the interim CEO and, of course, the subsequent CFO,
they approached two law firms one of which was Herbert
Smith, and they appointed Herbert Smith.
Thank you. That's consistent with the bullet point
below. It then says that:
"[Mr Cameron] was vague about role (taking it over,
independent or just replacing me).
"I expressed concern about the timing vis a vis
current process.
“I asked whether change that immediate effect -- it
did.
"I Asked if [Herbert Smith] were expecting to be
instructed this week -- they were. I asked whether he
wanted me involved in briefing [Herbert Smith] -- he did
and asked me to meet with them that day ..."
Can you assist us: what was the feeling within the
company, within the senior levels of the company, at
this stage, towards the way the litigation had been
37
current accountability) or a [Group Executive] member,
but no one else was close to the issues."
Was it ultimately you --
In -- sorry, in what sense?
-- who would instruct Herbert Smith or who would be the
direct liaison with Herbert Smith?
So when I became General Counsel, so obviously the Board
had made a decision to appoint HSF, and so there's
obviously an engagement letter that needs to be signed
off the back of it. But, yes, as General Counsel,
I would then, and did so, liaise with HSF.
As someone who was lower than Ms MacLeod's
accountability, did you feel comfortable taking on that
role?
Well, it was a step up, if that's the question. So yes,
I obviously was the Legal Director, and I would be --
not that I think I knew at this point but, subsequently,
Al had a conversation with me and he said that he would
like to appoint me as General Counsel.
What was your view as to whether that was a good
‘opportunity, something that you were qualified and
experienced for, or something that you weren't
sufficiently experienced for?
I knew it would be a challenging role. I have had the
benefit of having excellent previous experience, whether
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handled?
A. Well, when the Common Issues Judgment was handed down
and was communicated, I think it came as a great shock
to the organisation and I think that people such as Al,
and some members of the Board, were very disappointed in
the legal advice, in the sense that the legal advice was
simply not borne out in the judgment.
Q._ If we scroll down, there's mention of speaking to you to
give you the heads up of the proposed changes; do you
recall that conversation?
A. Yeah, I recall she asked me to go to her office and
I went into her office and she appeared upset and she
said that HSF were, in effect, replacing her role.
Q. If we scroll down, was it clear to her that she was
being replaced more broadly than just in relation to
Group Litigation?
A. Oh, yes, that, in effect -- I don't recall if these
words were used, it's hard to remember the actual
conversation -- but I think it was she felt redundant.
Q. She then refers to another conversation with Mr Cameron
around 9.20, and it's just a passage I'd just like to
ask you about, it's the fourth bullet point:
"I asked who would instruct [Herbert Smith]/to whom
would a secondee report to? Al was unclear on this and
asked my view ~ I said it was either Ben (lower than my
38
it's as a senior associate in private practice or
teaching law at university, or publishing as well as
working in an inhouse role as -- for corporate lawyer
for a major financial services institution and, indeed,
by that point I'd also been on subsidiary executive
committees and also risk and compliance committees, and
so I've had the benefit of extensive experience but
I accept the point that it was my first General Counsel
role.
MR BLAKE: Thank you.
Sir, that might be an appropriate moment to take our
first morning break.
SIR WYN WILLIAMS: Yes, by all means.
MR BLAKE: Can we come back at quarter past?
SIR WYN WILLIAMS: Yes, by all means.
MR BLAKE: Thank you very much.
(10.06 am)
(A short break)
(10.15 am)
MR BLAKE: Thank you, sir.
Mr Foat, could we move on now to 11 May 2019. If we
could turn to POL00023233, and that's at your E8. The
Court of Appeal had refused permission to appeal in
relation to the recusal application. If we turn over to
page 2, we can see Mr Parsons providing an update on
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that at the bottom of page 2. If we scroll down
slightly, he says:
“Please find attached the Court of Appeal's decision
refusing permission to appeal ...”
Then we have your response on page 1, at the bottom
of page 1. You say:
"Thanks both -- we will need to explain the CEO and
the Board why we received advice that is again contrary
to the outcome. Can we summarise the [Court of
Appeal's] conclusions and what was it that caused there
to be a different conclusion from the advice that was
given. I am concerned that credibility is being lost so
let's be clear on how this is to be positioned.”
To what extent were you involved in the decision to
appeal to the Court of Appeal in respect of the recusal
application?
So the decision to appeal was already taken by the Board
on 20 March, so in the Board resolution -- I only know
this subsequently, of course -- but if you look in the
minutes of the Board resolution, they had made the
decision to recuse, at first instance, and should Lord
Justice Fraser now not grant permission, that the Board
authorise that recusal appeal be made. So the Board,
I understood had made that decision on 20 March.
Thank you. In respect of the refusal of permission, how
41
I think it's someone in the IT Department.
He says:
"Rob
“We have reached out to an independent test company
Ten10 to review our current and test strategies,
focusing on the Horizon/[Fujitsu] estate. We anticipate
the review will produce outputs around mid-June. We
will keep you informed and I will ask Isabel to
circulate the [Terms of Reference] for the work. If we
need to be more specific on Horizon then happy to accept
the feedback."
We can see on page 1 where this all leads to, and
it's advice from Mr Parsons from Womble Bond Dickinson,
yes, in May 2019 now, 17 May. He says:
"The work below makes me nervous. If the report
flags any risk in Horizon, we will be obliged to
disclose it to Freeths. The report landing in mid-June
would be terrible timing as it might land when Worden is
giving evidence or just as we are preparing closing
submissions. I would advise against conducting this
work whilst the Horizon trial is live.
"We will have an ongoing duty of disclosure all the
way up to the Horizon judgment being handed down (and
potentially beyond that). If we disclose the report
after the Horizon trial closes but before judgment,
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was that received within the business?
This is Lord Justice Fraser's refusal on the permission
in the --
No, I think this is appeal, isn't it? The Court of
Appeal refusing permission. If we scroll down, sorry,
‘over the bottom of page 2 into page 3?
Sure. So I think the business was disappointed and it
was disappointed because, understandably, the Board had
taken advice from Lord Neuberger, Lord Grabiner and
David Cavender QC, and I think -- importantly, I think
it was in April that HSF was appointed and so I think,
from the Board's perspective, the Board was given legal
advice that suggested the Post Office had good merits in
making the application to appeal, or making the recusal
application and the appeal, and so the Board was, again,
disappointed like they were disappointed in the Common
Issues Judgment, which is why I make the point about
being concerned of the Legal Department losing
credibility.
Could we turn to POL00042675, please. That's your B13.
If we could start on page 3. So the recusal application
having been lost and Court of Appeal having refused
permission, there's an email chain shortly after,
15 May, and it says as follows, from Mr Mitchell -- who.
was Mick Mitchell?
42
there is a risk that Freeths will seek to put in extra
submissions to the judge.
"In an ideal world from a litigation perspective,
this work would not happen until after the Horizon
judgment given is. I appreciate however that there is
a need to balance litigation risk against normal
business activity."
You respond above, saying:
“Thanks Andy -- very helpful."
Was that work undertaken?
The test?
Yes.
Yes, I understand it was in August.
So was it undertaken after the trial?
That's correct.
Yes, and was that intentionally so, in light of
Mr Parsons’ advice?
I'm not aware of that.
Is this another example of concern within the business
about creating material that would be disclosable in
litigation?
I think the point of this was just making sure that --
it's joining the -- as General Counsel, I'd say joining
the dots across the organisation. So it was just making
sure that the business -- if they don't need to do
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something and there's no obligation to do something and
that can create risks, well, then normally lawyers will
advise the accountable business owner of that. That's
not to say, if there are adverse documents that have to
be disclosed, then they will be disclosed.
But I think it’s just making sure that there was
coordination between the IT Department and the Legal
Department. My understanding is that the test did go
ahead and, if there was anything adverse, then that
would have been disclosed.
The kind of advice given by Mr Parsons there, do you
think that is appropriate, in the circumstances where
the Post Office is owned by the Government and also in
circumstances where the Post Office has historically
prosecuted people?
At the relevant time, I think I was in as General
Counsel for about two or three weeks, I'm not sure
I would necessarily have quite understood all of the
context of the question you just put but I think --
I mean, I simply asked for the legal advice and this is
legal advice that came back, and I think what they're
saying here is that looking at it, as he says, from
a litigation perspective, if you don't have to do
something, and therefore he's saying not to, but what
I'd be very clear is -- and indeed, I think it's
45
lawyer is to advise on the legal risks.
But you're right: there are other considerations
that a decision maker ought to take into account.
If you were the decision maker, what would your view be?
I'm not the decision maker.
But if you were the decision maker what would your
decision be?
It's not the role of the General Counsel to be the
decision maker.
But if you were the decision maker what would your
decision be?
I don't have a view on it. Itis not my role.
Can we turn to POL00021556, please.
This a Board meeting of 28 May 2019, if we scroll
down we can see you are in attendance as General
Counsel. How often would you attend Board meetings?
I would attend for the relevant section of the Board
meeting that would be -- would pertain to me. So when
I became General Counsel, I would attend in respect of
the Group Litigation.
Is it right that throughout your time as General
Counsel, the role was somebody who would attend the
Board but would not be a member of the Board?
That's correct. The General Counsel is not a Board
Director and so, therefore, it's not a member of the
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implicit in his point, that there is an ongoing duty of
disclosure, and so, if something does happen, it will
need to be disclosed.
Irrespective of your state of knowledge at that
particular time, you were subsequently General Counsel
for a fair amount of time, looking at your role and
looking at the Post Office, do you think it is
appropriate for that kind of a position to be taken by
the Post Office, in light of its Government ownership
and in light of its historic prosecution function?
I am not aware of any specific rules of why it wouldn't.
My understanding is that this is legal advice, it's
litigation legal advice, and so it would follow the
normal course, which is --
Irrespective of the advice that's being given, though,
in terms of a position, so let's say that advice was
adopted by the company, do you think it is appropriate
for the Post Office to adopt that position?
That's ultimately a question for the decision makers.
They would need to factor in or consider the legal
advice but they, as -- whether as Board Directors or
whether as other accountable business owners, they need
to have regard number of considerations. That would
include, for instance, the criteria or additional
elements that you have put forward, but the role of the
46
Board. It will only attend upon the invitation by the
Board and, in Post Office's case, the General Counsel
doesn't sit through the entire Board meeting. It only
attends in relation to specific agenda items.
In your view, is that usual or unusual?
I'm aware from an industry perspective there are
different models. My personal perspective is that it
does make my role more difficult not to be attending the
Board -- not a member because I'm not a Board
Director -- but not to attend the Board makes it more
challenging because you don't actually get to hear all
of the other agenda items. You don't get to hear, for
instance, you know, what is discussed about NBIT or what
is discussed about other topics, and so it just makes it
a little bit harder for that.
Do you feel that, during your time as General Counsel,
you were given sufficient information as to what was
going on at Board level?
In relation to what? Sorry.
Broadly: was your level of information regarding the
company sufficient for your role?
From time to time, I don't think it was adequate. There
are a number of occasions where certain documents
I asked for and I wasn't provided with. The model that
Post Office has does make it more difficult, unlike my
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predecessor, who was both the General Counsel and the
Company Secretary, had the benefit of being able to sit
throughout the entire Board meeting and, personally,
I do think that is a more helpful model.
Thank you. If we go over the page we see there
reference to:
"... a number of attacks on the [Post Office] brand
through the Group Litigation and with the Horizon trial
about to resume; the Daily Mail campaign to ‘Save our
Post Offices’; continued opposition in some quarters to
franchising ... and, the case brought by 123 postmasters
on employment rights. We needed to undertake a review
of postmaster remuneration which provided sustainable
solutions. Ideally, an announcement would be made in
November 2019 for introduction in April 2020, however,
this might need to be fast tracked depending on
publicity and disquiet sounding the Horizon trial."
Were you aware from within the business of
consideration being given to essentially provide good
news to counteract what was going on in the Horizon
trial?
Not specifically. We -- Post Office has
a communications department. I assume that is probably
where that -- comments are coming from.
Can we turn, please, to page 4, which is where the Group
49
system and what the issues had arisen over the period of
time covered by the case."
The suggestion there that the expert witnesses -- if
we scroll up -- may renege, do you recall a concern of
that sort?
No, my recollection, albeit this may be a subsequent
recollection, was -- there was a question mark as to
whether or not the experts had come up to proof in the
sense -- and I think what was communicated, in the
nicest possible way, perhaps both of the expert
witnesses had not put their best foot forward.
Was there a concern within the business?
Pertaining to?
That the experts would renege on their previous position
that Horizon was a robust system?
I think there was a general concern about the conclusion
that would be reached about Horizon. Horizon is
an essential system to the provision of the Post Office
services.
Yes. Can we move on to POL00091437. That's your E13.
It's 10 June 2019, an email from Rodric Williams. It's
summarising the cross-examination of the claimant's
expert, Mr Coyne. It identifies his evidence in
relation to bugs. He said:
"Mr Coyne's evidence on this seemed confusing,
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Litigation update is provided and I think that's the
agenda item for which you attended. It says there:
“Alan Watts introduced the paper and he and Ben Foat
updated the Board on recent developments. We had 21
days to make an application to the Court of Appeal for
leave to appeal”, and then it refers to new counsel.
There's a paragraph below on the recusal costs being
around £300,000.
It then goes on to say a number of points were
raised, and it's the second bullet point that I'd like
to ask you about. It says:
“Whether there was anything further we could do to
influence the outcome of the Horizon trial? It was
reported that Fujitsu's witnesses had not been strong,
while [the Post Office's] had been satisfactory. Only
the expert witnesses has yet to provide evidence and it
was important that they did not renege on their previous
position that Horizon was a robust system. It was
critical that Horizon was seen as a robust system today.
It was likely that the expert witnesses would say that
the system had bugs. This was not in dispute but the
issue was the degree to which it was a robust system
that could be relied upon and that there was nothing in
the judgment that suggested the system was unfit for
purpose today. We had looked at the evidence of the
50
ranging from 13 to 22 bugs."
Was it clear in your mind at this stage that Horizon
had bugs and those bugs were at least 13 to 22, as
suggested here?
I'm not entirely sure, but I thought I probably had the
view that the question was not so much about the bugs
itself but the impact of bugs and I -- tangentially,
I remember a reference about that there was very little
bugs given the broader context, but I wouldn't have
necessarily have known much more than that.
Given your previous understanding in terms of the air
traffic control system, the robustness of Horizon, did
there come a point at which you started to question the
line that had been taken by the business and, if so, at
what point was that?
I think it became evident only in the trial itself
that -- querying whether or not the witnesses came up to
proof, and I think it was the reporting back to the
Executive and the Board about the witnesses and the
evidence.
If we could turn, please, to POL00136421. That's your
E18. If we could start on page 7. We're now into June
2019. At the bottom of the page, it's an email from Tim
McCormack to Mr Cameron, and he emails Mr Cameron about
another computer error. We see there, if we scroll down
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slightly, he says:
"I don't know what they have brought to your
attention recently but the single-most important piece
of information you should be dealing with right now is
a new error in your computer systems that, as it stands,
cannot be introduced into the current trial but should
be."
If we scroll up, we can see Mr Cameron asks for more
detail. If we keep on scrolling up, Mr McCormack says
that:
"The error in question is serious. Details of it
are being treated as confidential ..."
There is then, if we scroll up, Mr Cameron wants to
speak to Mr McCormack. He says:
"[For your information] I will speak to him."
If we keep on scrolling up, there is a message from
Mr Mark Davies, the Director of Communications, slightly
above, at the bottom of page 5, please. He says:
"My advice is to wait before speaking to him so that
we can brief you. But if you are speaking today, please
be aware that as you do it is a direct line to likely
public comment/journalists. I'm uneasy about saying
more on email. I suggest you read this blog ... in some
depth before speaking to him. I also suggest giving
Angela a call: she has dealt with him on many occasions
53
At that point, Post Office's position was still that the
system was robust. It had received advice saying that
the witnesses had not come quite up to the proof that
was expected, but I don't think anyone was suggesting
that they wouldn't look into bugs, errors or defects.
Could we please turn to POL00280270, that's your E33.
It's an email from Al Cameron, the Interim Chief
Executive at that time of 2 August 2019. He says as
follows:
"Ben, I have been made very uncomfortable about
an issue at Little Milton Post Office ... They
approached me recently because they had been asked to
pay a significant amount ... to us. Kim Abbotts got
involved but could not explain what had happened
remotely. At my suggestion an audit was held and the
belief now seems to be that there was no loss, just
misbooking of stock and mis-remming of cash. However,
Kim has not yet been able to explain things to my
satisfaction.
"Could you please work with Kim while I am away to
understand what has happened and answer two questions.
"1. Is our understanding of what is happening in
branch sufficient for us to be able to ask for money or
suspend postmasters -- it doesn't feel like it.
"2. Secondly, should there be any implications for
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cover the last seven years."
If we keep on scrolling up, please, to page 3 --
perhaps the bottom of page 2, actually -- it seems that
all the correspondence with Mr McCormack has been kept
on file "including Rod's letters to him when he was
regularly emailing Paula".
Was there at this time, June 2019, a caution within
the business in relation to looking further, in relation
to bugs, errors and defects? We saw that Ten10 email
and the testing and the concern about carrying out
further testing at that stage. Were there wider
concerns within the business about looking too deep into
current bugs, errors and defects in the Horizon system?
No, I don't believe that's so. My understanding -- and
a lot of this I'm not actually necessarily involved
directly but it -- my understanding of this email chain
was concerned that the Comms Team were raising with Al
about discussing, had Al been the interim CEO at the
relevant time, having a conversation with Tim McCormack.
I understood that there was a long history, the details
of which I wasn't involved, but I think that's the
concern that's been raised by the Comms Team.
Was there, though, more broadly, a concern within the
business, or perhaps a lack of reflection within the
business, as to the extent of the problems with Horizon?
54
our defence of the GLO.
"Given our shareholder's focus on a rapid
settlement, I would rather you looked at the questions
without it being clear I am asking -- I haven't used the
whistleblowing process to protect privilege but I am
asking for that confidentiality and protection. You do
not therefore have my permission to discuss this
elsewhere, other than talking to Kim about the
specifics.”
A few questions on this. First of all, the
reference there is, "the shareholder's focus on a rapid
settlement"; can you assist us with what that meant as
at August 2019?
I think that was part of the change of strategy that had
been discussed by the Board with the shareholder, which
was, as opposed to what had happened in the Common
Issues Judgment, when Al was appointed as interim CEO
and after the Horizon Issues Judgment, I think there was
a concerted effort to re-examine the approach that had
been taken. Obviously the comments by Lord Justice
Fraser, both the tone of which and his findings, came as
a shock to the organisation and so there was a change of
approach to make sure that the company understood that
and, in particular, that there'd be a focus on mediation
or resolving the matter, rather than just through
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litigation.
We see an email on the same day, POL00327569. That's
your E39, from you. You forward the concern to Norton
Rose and ask for advice. I think the suggestion in
there is that it may have been raised by Mr Cameron
because he had been unsuccessful in his application to
become the CEO. What was your view of the concerns that
were being raised by Mr Cameron?
I remember the way that I treated this was to treat it
with what -- I would say a straight bat, so I treated it
as if it was a potential whistleblowing matter and,
because it provided an unusual set of circumstances that
this was the CEO purporting to make a potential Speak
Up, in circumstances where it was his own area of
responsibility, so the -- at this point, he was
responsible for the operations, where he -- the issues
around stamps and Little Milton occur. So it was
a unique situation of someone whistleblowing for which
they are themselves accountable for the work.
I was also mindful of the fact that, as the General
Counsel, I reported in to the interim CEO, and then
I was also mindful of the different hats that, at that
point, I was wearing because I inherited Jane's work,
and so I was both the whistleblowing officer but also
the General Counsel.
57
in that respect that I'd just like to look at now.
Could we please turn to POL00042755, that's your E11.
We're going back in time only slightly. We're in June
2019, if we scroll down, please, we can see advice from
Andrew Parsons of Womble Bond Dickinson. He says:
"All
"We spoke couple of weeks ago about a plan for
moving forward settlement in the Group Litigation. In
simple terms, this was to ask Freeths to provide better
claim valuation information either alongside or as
a precondition to mediation. Has that plan changed
following the Board subcommittee last week?"
He says at the bottom of that second paragraph:
"Either way, we may wish to write to Freeths sooner
rather than later about settlement.
"If we're still following the same path, I think
that HSF were preparing a first draft of a letter to
Freeths? In the meantime, we have now received advice
from Brian Altman QC on settling with convicted
claimants -- attached."
Scroll down, please:
"His conclusion is:
“In my opinion, there is some risk to including
convicted claimants in any settlement agreement or
package. At this stage, and in the abstract, I am
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And so it put me in a unique and difficult position
and so I sought external legal advice.
Irrespective of the difficult position because of
Mr Cameron's role, do you have any concern about the
difficulties in getting to grips with apparent
shortfalls?
I specifically raised -- it's not to NRF, but to Herbert
Smith, it was specifically raised with them, to make
sure that that was looked into.
Was there a concern in the business at that stage that
there may be wider problems that hadn't really been
identified?
At that stage I think they were trying to work out what
actually happened at Little Milton and, of course, it
‘was somewhat problematic, in that we had to sort of
proceed obviously with not mentioning Al, but I was able
to have a conversation with a relevant person in the
Operations Team. As I said before, HSF were actually
appointed to look into the specific issue and then,
subsequent to this issue, the issue around remming in
and stamps, et cetera, was looked into.
You've said that during this period, the summer of 2019,
there was a movement towards settlement --
Correct.
-- and it's settlement and some advice that was received
58
unable exactly to define or quantify the risk. While it
has to be a matter for others to advise and decide how
far the Post Office should go in progressing
a differential approach among the convicted Claimants
and the rest, my advice must be that reaching any
settlement agreement with the convicted Claimants should
be a red line for all the reasons given above'."
What did you understand by the risk that had been
identified by Mr Altman?
My understanding was that it - and I'm not sure if my
understanding is based on that or other advice on the
point. My understanding is that it was contrary to
public policy that you can't compensate people while
they have the conviction. So that was, I think, the
conundrum with the settlement, which is: how do we
settle the claims that the original 555, a number of
which did have criminal convictions? The vast majority
did not but there were some that did, and so I think, in
the end, the settlement agreement settled holistically
with the -- with everyone, including the convicted
criminals. But it didn't include compensation around
the overturning of their criminal convictions because
that had not yet occurred.
Did you have any concerns in respect of the advice that
had been given by Mr Altman?
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I don't have any recollection of this particular point
specifically.
That can come down, please. In terms of the settlement
and the legal costs, were you aware that a substantial
proportion of any settlement would go to pay the costs
and litigation funders on the part of the claimants?
Correct, yes.
How early were you aware of that situation?
From memory, I think there was discussions with HSF
around, I would say August, perhaps? August to
September? And certainly going into mediation, we
understood that the challenge would be around litigation
funding. I remember asking about whether or not it was
a recoverable head of loss.
I want to move on to tactics more broadly in the Group
Litigation. Can we please turn to POL00276474. If we
start on page 2. That's your E29. I won't read out
this email because it's an email that we've seen, we
dealt with it in depth with Mr Parsons. He there sets
‘out, essentially, why it was that an opinion on the
merits in the litigation hadn't been provided or
obtained originally, and it sets out there the strategy
that had been adopted.
What was your view on the strategy as set out here
and the fact that there wasn't an overall opinion on the
61
heard numerous people advise that the claimants had not
provided anything on quantum ..."
Briefly, can you assist us with what your view was
in respect of how the litigation had originally been
approached?
So as I think Andy is explaining there, I think Post
Office took a very technical and legal approach to the
matter and so, yes, it was setting out to me what had
previously occurred in the Common Issues Judgment, which
I understood took place in November 2018.
Were you concerned by the fact that there wasn't, for
example, an advice, an overall opinion on the merits of
the litigation?
Yeah, I think at this point because the strategy had
changed, it even -- it changed even in respect of the
Common Issues appeal, to narrow it down, to make sure
the tone was right, to make sure that we were looking at
mediation rather than a technical litigation defence.
I think the strategy clearly had changed in June 2019.
I think what Andy is explaining there was a look-back,
if you like, at what the previous litigation was.
If we please turn to POL00276883, that's your B68. If
we scroll down, please, it's on the same theme. It's
an email from you raising concerns in relation to the
lack of information regarding quantum that had been
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merits?
I do apologise. Which document is this one?
£29 of your bundle. It should end 6474.
Thank you.
Page 2 is the email from Mr Parsons. He sets out there
that the strategy was to contest the Common Issues trial
and he sets out the thinning the herd strategy, and he
says that:
"The strategy was never to seek an outright win
through the court process [because] that would mean
ultimately defending 500 plus individual claims ..."
He explains:
"I hope this helps explain why there hasn't been
an overall opinion on the merits of the litigation in
general."
If it assists, if we turn over the page to the first
page, you say there:
"It does leave the Post Office in a difficult
position. I remain surprised that no overall assessment
‘on merit has been undertaken when we are two trials in."
You also say that you should point out that "Al",
I think that's Al Cameron:
"... was particularly disappointed on learning that
the claimants had in fact provided a Schedule of
Information in relation to quantum. Like him, [you] had
62
provided. It seems as though there was an email, one
and a half years ago but since, notwithstanding that
email which had been forwarded to you in the chain
below, you say:
... even I have constantly heard since becoming
involved that the claimants have not provided us
anything on quantum."
It appears, in fact, that they had provided some
figures.
In what way did that, in your view, delay the
settlement of the case, the lack of information that
appeared in the business regarding the quantum of the
claim?
I'm not sure it necessarily delayed settlement, in the
sense that, for me -- and, again, I'm sure others may
have a different opinion -- but from where I was
standing, it seemed to me that the catalyst for change
was the handing down of the Common Issues Judgment and
the failed recusal application. That -- because that
was a shock and that was really the crystallisation of
change.
But what I'm saying in this particular email is that
there are things that the way that the previous lawyers,
or Womble Bond Dickinson in this case, had taken,
although they didn't -- I didn't think that they were
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doing it intentionally, I think they were making
generalised statements and, unfortunately, sometimes
those generalised statements can be misinterpreted, and
so I was just picking up the point that I had observed,
or been indeed told, that the claimants hadn't
particularised their claim when, in fact, what in
reality was, was that they had provided some information
about their claim, albeit it wasn't particularly
particularised as it ought to be in a legal claim.
So I guess what I was saying to Andy here is, "You
need to be more precise with your language because it
could mislead", and I'm conscious, obviously, as the
then General Counsel, I'm conscious to make sure that my
lawyers, you know, don't leave a false impression or
mislead the Board, notwithstanding any -- of course, no
intention to do so.
Thank you. The final topic before we move to Phase 7
and the final topic also before our next break is
records management. Could we please have a look at
POL00401613, that's your E58.
You have previously given evidence in respect of
disclosure to the Inquiry and this is a similar topic.
This is a Risk and Compliance Committee meeting in which
you were present on 10 September 2020 and it's page 2 of
those minutes that I'd like to look at. If we scroll
65
legal matters as well. It was critically important that
we have a data universe and that we understand what that
data universe is and that the business is complying with
our document retention policy and the document
preservation notices.
Thank you. Can we please turn to POL00021462 and that's
your E59. The issue is then raised on 22 September at
the Audit and Risk Committee. If we scroll over to
page §, into page 6, please, the same topic:
"The team is extremely busy dealing with requests
related to Historic Shortfall Scheme and related/linked
FOI requests.”
If we can scroll down please, it says:
"Of serious concern and Committee discussion, was
the discovery of 31,000 boxes previously unknown to the
wider organisation, which are being reviewed ... The
Committee questioned whether management had a handle on
data management controls such as archiving, and remarked
‘on the lack of accountability within [the Post Office].
"NR [I think Mr Read] remarked that this was
an unacceptable incident and that he did not expect this
to be brought to the Committee's attention by
compliance. A paper on data controls is expected at
[Group Executive] for discussion.
"The Committee recommended a data amnesty ..."
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down, please, there's the section there on "GLO/Freedom
of Information Request/GDPR". It says:
"... the team remains stretched responding to
Historic Shortfall Scheme and related/linked [Freedom of
Information] requests ... Following receipt of 41
[Freedom of Information] enquiries considered vexatious
from one journalist, 31,000 boxes of data (previously
unknown) have now been identified in storage. These are
being reviewed by legal, [Herbert Smith Freehills] and
Peters & Peters and a separate paper for [the Audit and
Risk Committee] will be prepared regarding this issue.
"The Committee recognised the need for improved data
retention/management training across the group and in
the retail network."
Can you briefly assist us with the 31,000 boxes and
how it is that they were identified?
So my understanding was that, in the course of mapping
out the relevant data repositories, that documents that
I understand came from the retail part of the business
was discovered and it hadn't otherwise been indexed, or
at least there was an issue around the indexing of the
documents, and that it hadn't been captured in the
previous reviews. And so I was extremely mindful of the
fact that -- and not just for this matter -- sorry, and
I mean the Group Litigation, but in respect of other
66
There is one more document that I'd like to take you
to and that's POL00167390. That's your E60. This is
a Board meeting, 22 September 2020. We see, if we
scroll down there, there's the Committee report from the
Audit and Risk Committee:
"Carla Stent provided a brief overview of the topics
discussed at the ARC Committee meeting held earlier in
the day including the pensions assurance update and the
identification of 31,000 boxes ..."
By this time, so we're September 2020, the Post
Office had been involved in the Group Litigation since
2016. Did the Post Office have a sufficient grip on its
‘own records, in your view, by this date?
No, it did not.
Who do you consider is responsible for that?
Well, data had sat with the CFOO, there had been a data
director in the company who reported to Al Cameron.
Data then transferred to the IT Department but, to be
fair, the accountability for data was something that was
raised, or rather the accountabilities generally, of
which data was one, was raised as an area that needed
resolution.
I wasn't aware of the state of the organisation's
data until this issue around the 31,000 boxes and then,
subsequently, all the remediation work that needed to be
68
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undertaken. But I had raised clarity around
accountabilities at a broad level and, certainly, when
I became aware of Post Office's data, and the state of
its data, specifically the data universe, I repeatedly
raised it to both the RCC, the ARC and Nick Read.
I don't think I need to take you to it, but there's
an ARC meeting on 12 November 2020, that's POL00423519,
it's your E61, but I think we can deal with that without
looking at the document. By that stage, sampling still
hadn't taken place in respect of those boxes, so we're
a couple of months later.
Do you think sufficient priority was being given
within the business to assessing that data, given that
the appeals were, at that point, going to be heard in
March 2021?
I think it's yes and no. So there were aspects where we
were encouraging all the business to make sure that they
have provided all data, to make sure that we understood
what the data universe was. At this time, Mr Salter had
a Head of Data that was in his team and, in the end,
I actually shifted some of my resources, such as my
Compliance Director and my Operations Director, to
support the accountable business owners to map out the
data universe to make sure -- and I personally went down
to the archiving unit, and I also went up to
69
MR BLAKE: Thank you very much.
Sir, we're going to move on to Phase 7 issues.
Perhaps that is a convenient moment to take a 10-minute
break.
‘SIR WYN WILLIAMS: Of course.
MR BLAKE: Could we come back at 11.15?
‘SIR WYN WILLIAMS: Okay.
(11.08 am)
(A short break)
(11.17 am)
MR BLAKE: Thank you, sir. Can you see and hear me?
SIR WYN WILLIAMS: Yes, thank you.
MR BLAKE: Can we begin our Phase 7 examination by turning
A
a
to POL00289903. That's E39 of your Phase 7 bundle.
Thank you.
This is correspondence, if we scroll down, of
7 September 2019, with Mr Watts. Was he a solicitor at
Herbert Smith Freehills?
Mr Watts is the partner.
Partner, thank you. He says in this email:
"Again, we do not want to hear anything more from
them other than an appropriate offer and settlement deed
wording. We aren't going to have sessions with them in
Chesterfield or wherever. Frankly I don't think there
is anything more to be said. As for Nick and I, we need
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Chesterfield. I walked thorough every room, together
with a third party.
I was particularly concerned from this point onwards
about the state of the data and whether or not the
organisation had got to grips on it, and I devoted more
resource from my team to facilitate that.
Do you think the company is now properly on top of its
records?
I think considerable effort has now been made.
I obviously, as you will have seen undoubtedly in the
ARC and RCC minutes, raised the legal risk around
failure to have our historical data properly managed and
the legal risks that that creates.
A substantial work and Remediation Programme has
taken place. There's now -- (audio disruption) -- of
a data director, which -- there has been establishment
of a data counsel.
Sorry, I think you cut off briefly.
Oh, I apologise. So in short, in short, a number of
remediation steps have occurred with a data director,
a data counsel, a lot more -- because of the frankly
embarrassing and unacceptable issues around disclosure,
that the Inquiry is well aware, the company is far more
cognisant about its data management and a lot more
resource has been put in place.
70
to focus on the other 10,000 postmasters who are running
the Branch Network [sorry, this is from you] and serving
customers over the busy December period. Hopefully that
gives you enough clarity to pass on to the other side."
Is this a point in time where you're discussing
settlement and providing instructions to Herbert Smith?
Correct. I think this was day 9 or day 10 of the
mediation.
Thank you. The reference there to needing to focus on
the other 10,000 postmasters, was it your view, at this
stage, that the focus of the business needed to be reset
onto existing postmasters rather than historic matters?
No, it wasn't as broad as that. What this email relates
is that the original settlement and mediation had been
set down for two days, I think the parties had
an extensive negotiation and settlement. Post Office
had provided a lot of additional information. Amanda
Jones, the Postmaster Director at Post Office, had met
with those in attendance at the mediation. Julie
Thomas, the Operations Director, had met. They'd
explained the improvements that they were making.
Post Office also accepted to meet with the claimants
for the following year to update them on progress.
My concern at this point, and this is an email
between lawyers in the matter, is that the mediation had
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gone a lot longer than it had been intended and, of
course, although the Group Litigation is clearly one of
my, you know, key matters, I am General Counsel for all
the other matters as well and I am -- I guess this is
some frustration that I'm expressing on Saturday about
trying to balance all of that.
Can we turn to POL00290399. That's your E40. If we
have a look on page 2 it's a circular that was sent by
Mr Read on 11 December within the organisation. He says
there:
"We are committed to a reset in our relationship
with postmasters, placing them alongside our customers
at the centre of our business. As we agree to close
this difficult chapter, we look forward to continuing
the hard work ahead of us in shaping a modern and
dynamic Post Office ..."
Mr Read's evidence to the Inquiry was to the effect
that you presented the issue of prosecutions to him as
a historic issue; would you agree with that?
I did see Mr Read's evidence. I categorically deny that
I told him not to dig into the past. I would not have
said that. Indeed, I don't think any General Counsel
would. But I couldn't have said it because I am clearly
on record in the documents saying that, even with the
Horizon Issues trial being undertaken, once the judgment
73
of concerns to Mr Read and to -- obviously I raised
them, as well, with the Board, and I just wasn't getting
the traction and so I didn't feel it was appropriate for
me to remain having that title when it didn't reflect
the reality.
You've referred elsewhere in your statement to
prioritisation of costs management over quality and
speed. To what extent does that feed into that issue?
It is part of the issue, particularly when I did
a review of the HMU and Inquiry programmes, when Declan
Salter, the previous director, left and just prior to
the appointment of the two new directors, and I made the
observation that there was too much focus on cost
management. Even, indeed, when the two directors were
in the role, both if them expressed the concern that
40 per cent of the time was to do with managing costs,
rather than the delivery of the programme.
Putting compensation and redress to one side because
we'll address that as a separate topic, how has that
focus on cost impacted on, for example, addressing the
concerns raised by Lord Justice Fraser?
I would say that there is genuine desire by the business
to get things done. I think the Retail Team --
I haven't been able to watch all of the evidence with
apologies, but you will have heard from Tracy Marshall
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is handed down, the issue around criminal convictions
would need to be looked into.
And that's well documented that I said that in
SteerCos, and to the Board, and I said that before
Mr Read started and I said it after Mr Read started.
So for me to have said anything contrary to that is
very odd.
You've said in your statement that there came a time at
which you became more removed from the Board: you've
used words such as "increasingly sidelined". When did
that happen and what happened to your relationship with
Mr Read?
So I was appointed as a temporary sponsor for the GLO
and Inquiry programmes but, increasingly, my direction
and advice on matters were not being taken up and
I wasn't included in meetings that I asked to be
included, such as meetings with Herbert Smith, such that
it was making it increasingly difficult for me to
maintain the veneer of the title of temporary sponsor.
And I raised this in March 2023 with Mr Read, again in
April and, ultimately, in July I said to Mr Read that
I would not continue to be the temporary sponsor of
those programmes in those circumstances.
Where does this originate from, in your view?
I made a number of recommendations and I raised a number
74
and Mel Park, I believe, and I think they have tried to
progress matters as quickly as possible. My view is
that they, like other parts of the organisation, have
been stretched and, with constant restructures and
constant cost reduction exercises, it has necessarily
meant that reprioritisation has had to be undertaken in
their areas, as indeed my own area.
Focusing now on compensation and redress, what was your
formal role in relation to compensation and redress as
at the beginning of 2020?
I was the General Counsel. At the beginning of 2020, we
would have had -- the Horizon Issues Judgment had
landed, the settlement of the original 555 had occurred,
and the establishment of the -- what we called the
post-GLE -- sorry, my apologies, the post-GLO programme,
and that programme was chaired by Nick, and the purpose
of that was to manage all of the implications that were
arising from the Common Issues Judgment appeal, ie the
Post Office was not successful in terms of the Common
Issues Judgment, and so, for -- and therefore to ensure
that it incorporated all of the components of the Common
Issues Judgment and that they were operationalised
across the business.
It included, similarly, the implications that arose
from the Horizon Issues Judgment, and so that's where
76
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you will have seen that Peters & Peters and a series of
counsel teams are appointed in respect of the criminal
work. There was also a number of workstreams, including
the settlement conformance.
So there were a number of obligations that were set
out in the settlement agreement that Post Office needed
to comply with. So it was a broad programme of work.
I'd like to ask you about the overall business's
attitude towards compensation and redress, as at that
period. If we could turn to POL00155397. That's your
E10. It's an email that the Inquiry has already been
looking at. At the bottom of page 1, it's an email from
Mark Underwood to Rodric Williams and you. Scroll down,
please. He emails saying:
"Hi Rod,
"Some comments for your consideration ..."
This is about setting up the Historic Shortfall
Scheme.
If we scroll down to the bottom, we can see the
section on fees. He says as follows:
"My strong view is that you cannot seek payment from
applicants -- however small and regardless of the
rationale behind it."
Were you aware of consideration being given at that
stage to charging fees to applicants?
77
be accepted into the Scheme."
One reading of that is that a plan is being devised
to make it more challenging for applicants to apply to
the scheme; what's your view on that?
In reality, that isn't the case, if you read the
eligibility scheme. So the eligibility scheme for the
HSS -- firstly, the HSS, just for context, was actually
part of the settlement. It was suggested by the
claimants that they thought having such a scheme was
important for other postmasters that weren't included in
the original 555. They also made the point that it was
important that such a scheme not require legal
representation because the original 555 had had to have
legal representation because, obviously, it went through
the court process.
So with that in mind, Post Office established the
scheme. The eligibility criteria for the scheme just
required that you were, in fact, obviously a postmaster,
that you say you have shortfalls and that, as per the
Horizon Issues Judgment, your shortfalls arose under
what was called HNG-X or previous versions of Horizon,
such as Legacy Online Horizon.
So in those circumstance, there is not a hurdle or
challenge to applying to the HSS.
There has been suggestion that the original forms were
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I think there was reference made in a legal advice note.
My understanding was it was in relation to the
escalation process.
Can you assist us with what you mean by that?
So my understanding in that email -- certainly -- well,
my view to Alan at the time was there should be no fees.
My understanding was that there was -- I think it was
UKGI who raised the issue generally around that in
schemes, you need to make sure that there's fraud
controls within it, and then there was a subsequent
dialogue and legal advice that Post Office obtained.
And I think what Mr Underwood is saying here is that
he wouldn't have an application fee but what he was
suggesting is a nominal fee for the -- for claims that
were not resolved by the independent claim, that it was
for the -- if they wanted to pursue it to a mediation,
which was part of the dispute resolution process.
He then continues:
"Optically, this would be extremely challenging and
would be a position that I believe the business would
struggle to maintain under political and media pressure.
I think you can achieve the same desired outcome [that
must be 'through’] having a very tight and communicated
set of eligibility criteria and requirements in terms of
the documentation applicants have to provide in order to
78
complicated. Who was responsible for that original
documentation?
Herbert Smith Freehills drafted the original scheme
documents. Obviously, Post Office is not a claims
management company, in that it sought advice from HSF as
to the establishment of the scheme. I am mindful of
also this Inquiry's previous consideration in respect of
the issue and I accept, of course, I think with the
benefit of hindsight being able to make things clearer,
being able to put things in more plain English, I think
are entirely fair observations.
If we scroll up, we can see that this email chain, it's
sent to you but also to Rodric Williams. Mr Underwood
says there:
"Hi Rod and Ben,
"Further to the below and purposely just to you --
I am not sure the workstream leads set out in Appendix 1
are set in stone yet. For example, I am not sure Nick
wants me to lead the Historical Claims workstream owing
to my prior involvement in the Complaint & Mediation
Scheme, Chairman's Inquiry and the GLO."
Rodric Williams, that's obviously a name that we've
been seeing from the very beginning of today and it's
somebody that the Inquiry has already heard from. Had
there been any prior discussion about people like Rodric
80
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Williams, who have a history in the underlying matters,
being involved in any of those matters going forward,
given their past role?
A. Yes, there had been. The challenge -- and
I particularly felt this quite acutely -- which is this
was a very complex, longstanding matter that had been
running for years and trying to get up to speed with
everything, trying to understand where all the documents
are, trying to get across the huge breadth of issues and
detail was very difficult, and so, on the one hand, it
was important to be able to have corporate memory, and
be able to have people like Rod and others support us;
equally, there needed to be a counterbalance to that.
So I felt the fact that when, obviously, Rod was
working on these matters, he was heavily overseen by
external lawyers and, indeed, the function of HSF was
overseeing the litigation, that that brought the
counterbalance.
Indeed, the external lawyers themselves actually
advised that it would be very difficult for them to do
their work if they didn't have access to those people.
Q. Do you have a view as to whether the process that was
set up was too confrontational?
A. I don't think it was intended to be confrontational. As
I said before, it was a well-intentioned scheme, in the
81
that each change to the form or criteria, or anything of
that nature, has been drafted by outside lawyers not by
POL inhouse?
A. Indeed. But I would add that those documents did go
through governance, it did go through the Board steering
committees, and UKGI and our Government Shareholder.
SIR WYN WILLIAMS: So the process is, if there's to be
a change, outside lawyers draft it and then it's
approved by the appropriate people within the Post
Office?
A. Correct. I would add that, at this point, there were
number of inhouse lawyers as well supporting the
external lawyers to do so, but the work -- I think if
I understand your question, the work itself was
undertaken directly by the external lawyers.
SIR WYN WILLIAMS: Yes, I'm not suggesting that there
wouldn't have been conversations with internal lawyers
but the actual end result is the result of work by
external lawyers and then approved by the Board or
whoever, to whomsoever the Board has delegated that
function?
A. Correct, sir.
MR BLAKE: There's been a suggestion in the Inquiry that the
view at the Post Office was that the scheme should be
run by the Department for Business and Trade. Was that
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sense that we were acting on feedback from the original
GLO 555. We sought to make a scheme whereby they didn't
need to have legal representation, like the original 555
had had. We were directly acting on that feedback. The
scheme itself was one where we would have an external,
independent -- I think it was three representatives that
would assess the claims. It provided a dispute
resolution procedure and, in fact, the structure of it
had been provided to the original 555 claimants, that
that would -- there would be that escalation procedure.
I think the fact that we understood that from
an evidential standard, that obviously it wouldn't be
the same bar as one would employ in terms of litigation,
and so I think it was well intentioned but, at the same
time, I do recognise, of course, that there are things
that could have been done better.
SIR WYN WILLIAMS: Can I just ask, I'm obviously aware that
there have been changes to the scheme -- that's the HSS
scheme -- over time. Are all those changes the work
either of Herbert Smith or some other outside firm of
solicitors?
A. Yes, there's -- we've had a number of advisers, not just
HSF, but there has also been a number of Queen's Counsel
that have also opined on matters.
‘SIR WYN WILLIAMS: The only point I'm seeking to make is
82
view ever expressed to you?
A. Yes, if I could perhaps -- what was expressed to me
wasn't necessarily that it would be BEIS or UKGI.
I think, initially, what was discussed was whether or
not it was appropriate for Post Office to run the
schemes. My understanding is that Post Office raised
that issue with UKGI and the Government Shareholder.
There was a strong observation back to the Board that
the Government Shareholder would not allow -- that the
matter had to stay with Post Office and that Post Office
had to administer the scheme.
Once that was understood, the Board then made the
decision that, if that was the case, then it would
separate these -- the compensation matters into
a separate business unit from what we call the BAU
business.
Q. In respect of Mr Read's views, were you aware of his
views as to whether it was appropriate or not for the
business to be running the scheme, as opposed the
Government?
A. I think number of representatives, including Mr Read,
including Al Cameron, advised that -- they raised the
question of, putting it in frank terms, whether the
perpetrator, so to speak, should be administering the
compensation. It was a point directly raised.
84
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Raised with whom?
The Government Shareholder and UKGI.
\s it your evidence that the Government Shareholder and
UKGI were not open to that possibility?
Correct.
MR BLAKE: Thank you.
Sir, 'm going to move on from compensation unless
you have any further questions?
SIR WYN WILLIAMS: No, thank you.
MR BLAKE:
I'd like to deal with the Pineapple email, as we
know it, that's POL00448302. I'm not sure what your
reference is for that particular document but I'm sure
it will be one that you're well familiar with, as are
we. If we scroll down further over the page, please.
So this is the Project Pineapple note from
Mr Staunton to himself. It's a note of the conversation
he had with the two Subpostmaster Non-Executive
Directors on 14 January 2024. You'll be familiar with
paragraph that addresses yourself, if we scroll down.
It says:
“Equally, Saf and Elliot are FED UP WITH THE AMOUNT
OF POWER WIELDED BY FOAT. He and other members of the
senior team act as if [postmasters] ARE GUILTY UNTIL
PROVED INNOCENT (‘as per my experience’ they both
said)."
85
given that I stopped being the sponsor of the Inquiry,
and I was conflicted, and I did not attend the Inquiry
SteerCos from July 2023.
So for half a year, I'd not been involved in the
Inquiry and yet here is an email suggesting I am, in
capitals, "WIELDING POWER", as a result of my work in
the Inquiry.
So I explained that to them. I also explained that
the reference to Steve Bradshaw was incorrect because
Steve Bradshaw and the investigators in that team had
never reported to me. They are not part of the A&CI
team, which wasn't created until 2022 and so, any
conflation between what previous investigators may have
done with my team was not right and was unfair.
And the other issues around -- I think there's
a reference to me “pushing Phoenix into the long grass",
I told them that I would show them the emails that, when
I was involved in terms of the particular investigation,
that I had, in fact, done the opposite, which was to ask
my team to strategically prioritise it, to ask my team
to progress it and, indeed, it was the actual -- the
then Inquiry Director who had overridden that direction.
And so I went through this email with the Postmaster
NEDs explaining why this was not a factually accurate
observation, and which they apologised to me for it, and
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Just pausing there, is that something that you have
said?
I have never said that people are guilty until proven
innocent. I have maintained the view throughout my
entire tenure at Post Office that we need to adhere to
the Common Issues Judgment, the Horizon Issues Judgment
and Hamilton, that people are innocent until proven
guilty, that is one need not be a senior lawyer to know
that point, and I am on record repeatedly saying due
process needs to be done but absolutely people are
innocent until proven guilty.
They continue:
"WHILST FOAT IS AT THE HELM, NOTHING WILL CHANGE."
What do you think went wrong here between you and
the Non-Executive Director Subpostmasters?
I think this came off the back of an issue with
Mr Staunton. After this email was given to me
I received an apology from the two Postmaster NEDs.
They were in the apology to me -- it was a meeting.
They said that Henry had whipped up this issue and
I said to them -- and I went through this email with
them because I wanted to explain to them that the
observations/allegations that were made in this email
were false, so that, for instance, the power that I was
wielding as a result of the Inquiry could not be right,
86
I have had seen part of their evidence, and I noted that
they did row back from -- I think clearly in this email
they mentioned "Foat", and I think in their oral
evidence they talk about "Legal" rather than myself
specifically.
Two follow-up questions from that. The first: Stephen
Bradshaw and Project Phoenix, why was it taking so much
time?
So Project Phoenix was established as a result of the
Inquiry response tracker. This was an operational
process that I put forward for the Inquiry Team to do,
so that we could track all issues that were coming from
the Inquiry. It actually wasn't just the Inquiry, it
was also as a result of lawyers as well, and that the
business, the relevant accountable business owners,
could address it.
Part of that response tracker included allegations
that had been made by certain people and, at the time,
I think the A&CI team was relatively newly established.
They had very little resource. We did communicate with
the Executive Board about the lack of resource. But
I was very clear in 2023 to JB, Sarah and Diane Wills,
to say that Phoenix had to be strategically prioritised
and, even, I think, in an email in March 2023,
I directed the Legal Director, who oversees the A&CI
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The Post Office Horizon IT Inquiry
Director, to even take other lawyers off if necessary to
make sure that Phoenix was addressed and was given the
priority that it ought to.
To be fair to the team, I do want to say they did
repeatedly raise the fact that they needed more resource
and support to the Finance Team, and to the Executive,
which I supported them in doing so.
Was there difficulty obtaining the funding for that?
Yes, they asked for it three times and it was denied
twice, and then, in the end, they did secure additional
resource towards -- I think it was August, from memory.
Who, in your view, was responsible for the delay?
I think in part it was multifaceted. I would have
thought that, had there been more resource, more
funding, that would have enabled the A&Cl team to
complete its part of the work and then, of course, it's
then handed over to HR, who then has the panel
discussions, which were, I believe, set up in October
'23.
So I don't necessarily think it is one individual
person. At the time I think one has to also acknowledge
that the HR department, you know, Karen McEwan only
started in October 2023, so I think it was difficult for
the HR team, as well, prior to that time.
So I don't think there's one individual but I do
89
this balance between corporate memory but also making
sure that there was the counterbalance of having
external people, so I can't speak more broadly for the
organisation, but I had worked on that issue in respect
of my team.
Thank you. Before I pass over to Core Participant
questions, do you have any reflections in respect of the
role of General Counsel, the role that it plays within
the business, how it might be improved?
Yeah. I think it's fair to say that being the General
Counsel in this period of Post Office's history was and
is a challenging role. One needs to be able to
challenge Board Directors, Executives but also be able
to coach your team, be able to liaise with other parts
of the business. I think having a mindset of embrace
lifelong learning, which is a value -- a personal value
and a corporate value of a previous company that
I worked at -- having that mindset, but also leading
from the front, in terms of making sure that people
understand that legal conformance is a licence to trade.
It's not optionality, it's mandatory and making sure
that the business understands it at all levels, that
complying with the law is essential to good business
practice.
25 MRBLAKE: Thank you very much.
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think a significant part of the delay was the fact that
the A&Cl team was a new team and had not been adequately
resourced, despite the fact that they did ask for that.
We heard from Mr Bartlett yesterday in respect of the
resourcing. Why do you think it is that they are not
sufficiently resourced in both yours and Mr Bartlett's
view?
I think, at the time, when -- and this is -- this is,
like many things, including in other organisations, when
you start a new function and then you start to lift
rocks, you start to try to make improvements, you try to
remediate, examine the issue and address the issue, the
workload increases. And I think, in part, it wasn't
fully understood just how many different types of
investigations would be needed from the A&Cl team.
Why didn't those investigations or why wasn't the
mechanism put in place far earlier? So I think you've
mentioned that it was in response to the Inquiry. Why
wasn't it before then? Why were people still working in
roles and why was there no investigation into those
people prior to it being raised as a matter relating to
the Inquiry?
I think -- well, certainly in respect of my team, I had
considered the issue. I had raised the issue with Nick
Read. We had looked at a number of people in roles, and
90
We have some questions from Core Participants.
We're going to take a break at 12.15 but perhaps we can
deal with -- Mr Stein isn't currently in the room. Are
there other questions or is it just Mr Stein?
Yes, Mr Henry and Mr Moloney, perhaps we can hear
from them first.
SIR WYN WILLIAMS: Yes, by all means.
Questioned by MR HENRY
MR HENRY: Mr Foat, can I understand your evidence about the
compensation forms, in particular the HSS. You said
that you didn't consider them to be, as it were,
over-technical or unfair. Am I right in thinking that?
I'm not sure I did say that. I think I acknowledged
that, in hindsight, they could have been clearer. And
I'm obviously mindful of the issues that the Inquiry has
already identified, in particular around consequential
loss.
Yes. I'm going to deal with those in submissions
because that is what the Chairman invited me to do when
I was putting that to Mr Read. But let me concentrate
‘on the issue of contemporaneous documents. The guidance
in the appendix which was drafted, as you say, by
Herbert Smith Freehills, uses the term "contemporaneous"
ten times. You acknowledge, don't you, that
historically subpostmasters were put in incredible
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The Post Office Horizon IT Inquiry 18 October 2024
difficulties by being deprived access to contemporaneous
documents?
Yes, I understand that to be the case.
Yes. I mean, because although this happened
historically, it was referred to in the Common Issues
Judgment --
Sure.
-- and you remember that?
(The witness nodded)
So that, of course, would have been nine months old, the
Common Issues Judgment, when these forms were being
discussed and when these forms were being drafted,
wouldn't it?
I imagine so, yes.
Yes. So, therefore, at 3.2.2 of the form, it says:
"Greater weight will be attached to contemporaneous
evidence, loss of earnings. This will require evidence,
preferably contemporaneous, that the subpostmaster was
suspended
This is 5.22.
"... or had their contract terminated without
sufficient notice."
Further references to "contemporaneous
correspondence" being required in relation to loss of
earnings.
93
Yes. So, therefore, I mean, in the case of Janet
Skinner, for example, she has been asked to provide
a fifth expert report. You obviously can't comment on
the circumstances of her case but that suggests, does it
not, an exacting standard being advanced on behalf of
the Post Office by its representatives?
I'm not aware of the specific details. I could suggest
that having five expert reports -- oh, sorry, you are
frozen on my screen.
Am I frozen?
Can you still hear me?
I can still hear you very well. Can you still hear me?
Yes, I can hear you. In fact, apologies, you are back
now, sorry.
Right.
So just in respect of, as a general observation,
I would -- it would seem that five experts would seem
a lot but I don't know the particulars of the claim as
to why that's been required. Obviously, I think
Mr Salter -- sorry, Mr Recaldin is going to be before
the Inquiry on Monday, but I can take that away if you
would like me to look into.
Thank you. Final thing. You accept, do you not, that
in these negotiations over compensation the Post Office
must act with the utmost good faith, and not indulge or
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Further requirement for contemporaneous documents in
respect of loss of profits, and it goes on.
I don't think I need to go through all ten
instances. But you accept don't you that subpostmasters
were at a disadvantage in providing contemporaneous
documents relating to matters which may have been, by
that time, decades old?
A. Yes, and I understand your point. I think it's helpful
to note that, in terms of the scheme, that the
evidential bar was not going to be on a litigation
standard and that, of course, it is helpful if the
postmasters do happen to have documents but it's not
saying that they -- that only reference is to be had to
that. It's, of course, if that documentation does exist
and they have it, that it would be helpful to provide
it.
Q. Moving aside now from the Historic Shortfall Scheme but,
so far as compensation is concerned, it ought not to be
an adversarial process, do you agree; it was never
designed to be an adversarial or litigation process, was
it?
A. Yes, it's -- yes, correct. It's different from
litigation in a court. So if I understand the purpose
of your question, it is different from the court
litigation process.
94
transgress into any sharp practice. That goes without
saying, does it not?
A. Correct, sir.
MR HENRY: Thank you very much.
MR BLAKE: Thank you.
SIR WYN WILLIAMS: On the issue of compensation, you will
probably have realised that, in every progress update
and in my interim report, I have been careful to quote
what both the Government and Post Office have said on
a number of occasions, namely the aim is to provide
compensation which is full and fair, all right? Forget
the prompt side of it for the moment.
When I asked questions of both Mr Staunton and,
I think, Mr Cameron in the recent phase, that is in
Phase 7, they appeared to be acknowledging that,
nonetheless, there was a balance to be struck between
the compensation payable to the postmaster and the fact
that it was coming from public funds, in other words,
public money had to be protected.
As far as you're concerned, Mr Foat -- and
I appreciate you may not be directly concerned in
individual cases in the compensation schemes which the
Post Office is administering -- do you think that there
is a balancing exercise taking place, or do you think
that the panels or negotiators or whatever the correct
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terminology may be, are seeking to fulfil the commitment
to full and fair compensation?
Thank you, sir. I think I do understand your question.
With respect to my colleagues, I think they are
conflating two separate issues. One is to do with
an overarching financial envelope that the Government
Shareholder may have set aside, as distinct from the
individual assessment of claims. The individual
assessment of claims is done with reference to three
external panel members, one being a QC (sic), one being
an accountant, one being a retailer representative.
They are then assessed with respect to principles
and, indeed, at the requirement of Government, we also
needed to do test cases, and they are with reference to
well-recognised established heads of loss. So, you
know, that would include general damages, past and
economic loss, special damages, et cetera.
So I don't see that managing public monies, although
that is a separate legal obligation on Post Office
generally, that does not pertain directly to the
individual claims assessment in these cases.
‘SIR WYN WILLIAMS: = Thank you.
MR BLAKE: Thank you, sir, if we could have questions from
Mr Moloney before we take a ten-minute break.
‘SIR WYN WILLIAMS: Certainly.
A.
97
preservation notice.
Thank you, Mr Foat. Can we just look very quickly
again, please, at one of the documents that Mr Blake
showed you this morning, which is POL00415520.
With apology, what's the bundle reference number?
MR BLAKE: It's E50 of your Phase 5/6 bundle.
MR MOLONEY: I'm grateful to Mr Blake and I apologise to
prop,
Mr Foat.
No, that's all right.
Thank you.
Yes, sir.
Thank you, Mr Foat.
The first page is simply an urging of all to read
the email carefully. At page 2 of this document, we see
the three crucial document rules which are the standard
practice, Mr Foat, and you've been taken to those.
I don't need to go into those in any detail, but if we
go on to the next page, we see, "What is a 'document'?",
and, "What are relevant’ documents?”
We see the definition of a document at number 1 but:
"Relevant documents are any document that could:
either support or undermine the case of any party to the
litigation.”
So the additional note includes advice on documents
and duty to disclose documents which exist.
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Questioned by MR MOLONEY
MR MOLONEY: Thank you, sir.
Mr Foat, can I take you back to the start of your
evidence this morning, or certainly the early part, when
Mr Blake was drawing your attention to the repeated
messages sent by Mr Williams, and cascaded through the
business about matters of privilege in respect of GLO,
ultimately.
Sure.
Mr Blake focused on the instruction that was given in
relation to the creation of documents and your evidence
was that, while you wouldn't have been supervising
Mr Williams in this work, you would have seen this as
standard practice in civil commercial litigation?
Yes, so there is a standard process around what we call
a document preservation notice and when -- not just for
this matter but when there are any -- which I think the
legal test is anticipated legal proceedings, it is
appropriate for a company -- or indeed a party -- to
issue a document preservation notice as part of --
I think, later when I became Legal Director,
I established a central repository of precedence, and
I understand that the document preservation notice,
although not necessarily Rod's, but subsequently there
is a ~ what one might say is a more enhanced document
98
You told the Inquiry this morning that, as his
supervisor, you said you knew that Mr Williams was.
relying on Cartwright King when it came to any criminal
matters?
That's what I -- yes, that's what I understood the
resource was that he was relying on.
Yes. There's no mention in this email of the Post
Office's continuing duties as a prosecutor?
That's correct.
Yes. Would you have expected anyone to whom this email
was being cascaded -- and, by that, I mean people in the
business working in other roles outside the Legal
Teams -- to be able to understand any relationship
between litigation privilege in civil claims and the
ongoing duties of the organisation as a prosecutor, from
this email?
No, I think you're quite right, sir. I think this email
was limited to a document preservation notice in
reference to the High Court litigation. So the civil
litigation, rather than a criminal matter.
Entirely. Just a question about your experience and
perhaps quite complex experience here: this was a case
involving civil litigation in a commercial context,
brought in part by individuals who had been prosecuted
by the business. So a rare species of litigation. Had
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you, at that point in your career, had experience of
commercial litigation against a prosecuting
organisation?
A. No, sir.
Q. As his line manager, did you know whether Mr Williams
had had that unusual combination of experience either?
A. I was aware that he had been handling this matter for
some years, so I was aware that he had experience. Just
to clarify, he wasn't a criminal lawyer but he had
experience of both areas of law, if I can put it in
those terms.
Q. Yes. Are you able to assist on whether, at any time
during your supervision of Mr Williams and before the
conclusion of the GLO, there was any message cascaded
through the business clarifying that, privilege aside,
Post Office may owe duties of disclosure to those who
might have the basis for a criminal appeal?
A. Not off the top of my head, sir, no. I don't recall it.
My vague recollection from 2019 was that there was
a device that -- and I think, actually, this was the
same basis upon which the CCRC proceeded -- was that it
was awaiting the outcome of the Horizon Issues Judgment.
Q. Yes.
A. I take your -- sir, if your point is that there is
an ongoing duty of care of disclosure, that is correct,
101
MR BLAKE: Thank you, sir. Could we take a ten-minute
break?
SIR WYN WILLIAMS: Yes, by all means.
MR BLAKE: Thank you very much, sir. 12.25, please.
SIR WYN WILLIAMS: Yes.
MR BLAKE: Thank you.
(12.14 pm)
(A short break)
(12.27 pm)
MR BLAKE: Thank you, Mr Foat.
Mr Stein?
Questioned by MR STEIN
MR STEIN: Mr Foat, good afternoon. Can you see and hear
me?
A. Yes, I can thank you.
Q. I'm not going to be very long, I have two areas of
questions to ask you about, so can I take you then
directly to a document I think you'll find in your
module 7 bundle at E3, and on the screen, please
FUJ00243199.
Mr Foat, this is a letter written by Mr Patterson of
Fujitsu to Mr Read. The date you'll see on the face of
the document is 17 May 2024, and I'm going to take you
to one particular part of this letter, which is at the
bottom half of that first page, please, and then under
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sir.
Q. Thank you. Just one final thing, please, Mr Foat. In
the autumn of 2020, lawyers were preparing for the
criminal appeals hearings, which were to take place in
February 2021.
A. Correct.
Q. To your knowledge, was the fact of the discovery of
31,000 boxes of materials ever revealed to the Court of
Appeal Criminal Division?
A. I think it was. It was flagged to HSF and Peters &
Peters. There were what was called tranches of
disclosure that was made and so there were a number of
QCs, there were quite a number of junior barristers, who
were conducting the exercise, and it occurred over
several months -- forgive me, I think it was around
August and I think the last disclosure was around
February.
Q. To your knowledge, did all of that disclosure in the
criminal appeal proceedings, did that follow examination
of the 31,000 boxes?
A. I would have thought so, sir, given that Peters & Peters
were directly briefed on the issue and were a part of
the resolution of that.
MR MOLONEY: Thank you very much, Mr Foat.
SIR WYN WILLIAMS: = Thank you, Mr Moloney.
102
the second point there, which is "Pursuit of Shortfalls
from Postmasters". I'll just go through this:
"It seems that the Post Office may be continuing to
pursue postmasters for shortfalls in their accounts
using Horizon data. We would have expected that the
Post Office has changed its behaviour in light of the
criticisms and is appropriately circumspect with respect
to any enforcement actions."
Then Mr Patterson goes on to say:
"It should not be relying on Horizon data as the
basis for such shortfall enforcement.”
Just as a reminder, Mr Foat, Mr Patterson is the
European Director of Fujitsu, so a very, very senior
figure within Fujitsu's operations.
Now, my first question about this letter is that,
bearing in mind the date, 17 May this year, when was it
first brought to your attention?
A. Sol was on leave at the relevant time, so I wasn't
involved in this matter. I was due to give evidence
previously and I returned to the office and the Interim
General Counsel flagged to me this broad issue. I don't
necessarily know if I've seen this letter, other than
I have seen that it has been raised in other witnesses.
Q. Right. So after 17 May, when you return from that
period of leave, this letter was brought to your
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attention but you didn't see a hard copy or a digital
copy of it; is that what you're saying it?
I don't recall. I recall the Legal Director -- or,
sorry, the now Interim General Counsel, flagging that
there had been an issue between Post Office and Fujitsu
and that there was correspondence between the CEO.
I don't know if I have the -- all of the details of it
but I am aware of this letter, if that's your question.
When it was brought to your attention at that time, on
the basis of there's been this issue between Fujitsu and
the Post Office, was it brought to your attention on the
basis of, well, this is a bit awkward, Fujitsu are not
necessarily saying that you should rely upon the Horizon
system to look at shortfalls -- in other words that this
is quite an important issue; was it brought to your
attention in that way?
Yes, it was raised with me that Post Office didn't
accept for Fujitsu to be saying that their system -- and
I think part of what Sarah said was that, you know,
obviously Post Office is paying for a system and Post
Office expects that it's fit for purpose, and so -- but
she -- the -- the conversation that I had with her is
she was reassuring me that there was this issue, it's
being looked into, that the Legal Team -- and,
I understood it, an external lawyer was involved in this
105
advice. I was telling you what Mr Bartlett said in his
evidence, Mr Foat, which is the effect of his evidence
is that they sought advice which led to this document
not going out to police investigations. Don't you agree
that seems surprising, given the background to this
matter and this scandal?
I would want to see the advice before I comment.
One of the concerns that might be said about what's
going on here is this is very much same old/same old:
information that should go to the police, so that they
can investigate either in one direction against
an individual or to consider whether their information
is correct, is being stopped at a bottleneck at the Post
Office. Well, that sounds like history repeating
itself, Mr Foat; do you agree?
No, that's absolutely not the ethos of the Post Office
Legal Team or the A&CI Team. I don't believe that
that's the case but it's a bit difficult for me to
comment on an advice I haven't seen.
Yes. In your current situation, are you able to look at
such information and consider it and then consider
whether it should be reviewed by the team supporting the
Post Office before this Inquiry, and then consider that
for disclosure purposes?
Certainly, sir. I can take that away and revert back.
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correspondence. But I'm afraid I didn't have any other
detail in respect of it.
Understood, Mr Foat. Let me press you a little bit
further. We heard yesterday from Mr Bartlett,
Mr Bartlett being the Director of Assurance & Complex
Investigations, that's John Bartlett. Now, his evidence
included a reference to this particular document and he
explained that advice had been taken, it seemed to be
from outside of the Post Office advice, which allowed
the Post Office not to disclose it to police
investigations; are you aware of that step being taken,
in other words advice being taken regarding this
correspondence leading to the outcome, which is
non-disclosure?
I'm not aware of that, sir.
Given the background history of this scandal, which in
really short terms is about non-disclosure, it's about
not giving people the right information anywhere close
to the right time, it does seem surprising that the Post
Office still seems to be keeping back information that
may be useful for the exercise of a police
investigation; do you not agree?
Sir, I'm not aware of that advice. I haven't been given
that advice. I can't comment on that.
Well, I wasn't asking you about the details of that
106
My last question concerns something slightly different.
Mr Moloney asked you some questions just before the
short break regarding the lead-up period to the appeals
in the Court of Appeal Criminal Division.
Now, at that time in the lead-up to the appeals in
the Court of Appeal criminal division, we know that
Brian Altman KC was leading on behalf of the Post
Office, responding to those appeals in the Court of
Appeal. We also know that Mr Altman had a very
long-term involvement in matters touching upon issues
that relate to this Inquiry, including at least being
engaged on issues that relate to disclosure or indeed
non-disclosure, and he's admitted that he's made
a mistake in relation to dealing with the matters of
disclosure himself.
Did he ever come to you or, to your knowledge, any
‘other member of the Legal Team and say, "I'm worried
about whether I should be, in fact, presenting matters
‘on behalf of the Post Office"?
No, he did not but it was the other way round.
I was going to ask the other way round. Thank you very
much. What was the other way round, Mr Foat?
Thank you, sir. By that I mean it was Post Office that
raised the fact of -- obviously, Brian had been
involved. Mr Altman is an extremely experienced senior
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criminal lawyer and, frankly, he had a lot of
information and memory on issues, which someone like
myself or indeed a lot of other people didn't have, so
he was valuable from that perspective. But the Board
discussed the matter and the Board determined that Zoe
Johnson QC, another very capable, experienced Queen's
Counsel, should be appointed as independent from Brian
Altman and, in addition, the Board also appointed
Sir David Calvert-Smith who would oversee and
specifically advise the Board itself, separate from
Brian Altman and Zoe Johnson QC.
So I think those measures or controls helped make
sure that there was that counterbalance that I've
referred to previously, that, even if someone had been
involved in the matter that there was independent advice
and expertise that sat independent from it and, indeed,
that there was also Sir David Calvert-Smith.
Right. To your knowledge, did Mr Altman say or express
his own concerns that "I, Brian Altman, was part of the
decision-making process and made an error in that
process on disclosure issues", and express his therefore
concerns about whether he had a conflict; was that ever
discussed with you?
No.
In the reverse, was that ever discussed with him, "Look,
109
Court of Appeal Criminal Division.
Sir, we've managed to make some checks during the
time that Mr Foat gave his answer and, in fact, those
documents were reviewed prior to the substantive hearing
of the criminal appeals.
SIR WYN WILLIAMS: Thank you, Mr Moloney. Ms Allan?
Questioned by MS ALLAN
MS ALLAN: Good afternoon, Mr Foat. My name is Christie
Allan, and I ask questions on behalf of Core Participant
Susan Sinclair, who was the first subpostmaster to
successfully appeal her conviction in Scotland.
At paragraph 231 of your fourth witness statement,
which I don't propose to turn up, you refer to steps
taken by the Post Office between 2019 and 2020 in
relation to individuals who may have been affected by
bugs, errors and defects with Horizon, especially those
convicted claimants and those who had suffered historic
shortfalls.
In that context, you describe liaising with external
advisers and criminal law experts in terms of the Post
Conviction Disclosure Exercise and as a result of
‘ongoing communication from the CCRC.
Can you confirm any proactive steps that Post Office
took, particularly in light of the Horizon Issues
Judgment in 2019, to immediately seek to rectify the
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25
Mr Altman, you're experienced, you're valuable to us
because you've done a lot of work on this", did the Post
Office ever say, "You were part and parcel of that
history of non-disclosure, should you really be part of
this"; was it ever really raised in that term?
A. So the reverse -- as I said before, the reverse is true.
Post Office recognised that he had involvement. But
just to be clear to your question, it was only until he
gave evidence at the Inquiry that I understand he
acknowledged that issue. Before that time, Mr Altman
has never -- well never to me or anyone else that I'm
aware -- has acknowledged that point, if that's -- if
that's the question.
MR STEIN: I It's part of it. Thank you, Mr Foat.
I'll just check.
Nothing else. Thank you, Mr Foat.
THE WITNESS: Thank you, sir.
MR BLAKE: Sir, we have one small matter from Mr Moloney and
then we have another small matter from Ms Allan.
Further questioned by MR MOLONEY
MR MOLONEY: Simply this, and I'm obliged to Mr Foat.
Mr Foat may remember that I asked him the question
about the 31,000 boxes and the extent to which they had
been reviewed and material from them disclosed for the
purposes of the criminal appeal proceedings before the
110
miscarriages of justice which had occurred in Scotland
as a result of its failings in its duty of disclosure?
A. So immediately after the Horizon Issues Judgment was
handed down, legal advice was immediately obtained,
setting out the potential implications to criminal
convictions. Subsequent to that, then Peters & Peters
was appointed and, as we've just heard through the
questionings with Mr Stein, there were a number of other
Queen's Counsel and judge appointed to that process.
My understanding is that Peters & Peters also
engaged with a Scottish criminal law firm and, I do
apologise, I can't recall the name of that law firm, but
those issues were then communicated back through Peters
& Peters.
Q. Perhaps I can maybe assist you with the name of that law
firm. I think that might have been BTO Solicitors;
would that be correct? Does that ring a bell?
A. I don't know but I understood that there was a Scottish
law firm to advise under Scottish law.
Q. Thank you. Did or has the Post Office engaged with the
Scottish Criminal Cases Review Commission or Crown
Office in Scotland directly to seek to rectify its
failings from the past and to identify those affected
subpostmasters in Scotland?
A. My understanding is that there has been a liaising
112
(28) Pages 109 - 112
The Post Office Horizon IT Inquiry
between the Scottish CCRC and with Peters & Peters. I'm
not across the detail but that is correct.
MS ALLAN: Okay, thank you.
‘SIR WYN WILLIAMS: = Thank you, Ms Allan.
MR BLAKE: Sir, before we finish, I remembered that when
I read out the witness statement at the very beginning
I read the first witness statement, second witness
statement, third, fourth and sixth. I forgot the fifth
witness statement, which is WITN09980500, dated 29 May
2024. Mr Foat, can you just confirm for us that your
signature appears on that statement and that it is true
to the best of your knowledge and belief?
A. It does appear on this statement and it is in accordance
with my belief. Thank you.
MR BLAKE: Thank you.
‘SIR WYN WILLIAMS: = Thank you.
Well, first of all, thank you very much, Mr Foat,
for providing all the witness statements to which you
have attested. I am grateful to you for that. I am
very sorry that in the summer, when you were ready to
give evidence, that couldn't take place. I am very
grateful to you for giving oral evidence this morning
and agreeing with arrangements for starting early in
order to facilitate what I have to do this afternoon
and, finally, I'm grateful to you for your oral evidence
113
INDEX
BENJAMIN ANDREW FOAT (affirmed) ...
Questioned by MR BLAKE ....
Questioned by MR HENRY .. 92
Questioned by MR MOLONEY ..... 98
Questioned by MR STEIN .. 103
Further questioned by MR MOLONEY .. 110
Questioned by MS ALLAN ..... 111
115
18 October 2024
today.
THE WITNESS: Thank you, sir.
‘SIR WYN WILLIAMS: I would like to say publicly that I'm
grateful to everyone who has cooperated with making
today happen, starting very early and the hearing
running very smoothly. So thanks to you all.
We now have, I think, a fortnight's break and we
resume on 4 November with Mr Recaldin, is it not,
Mr Blake?
MR BLAKE: That's correct, sir, yes.
SIR WYN WILLIAMS: All right. See you all then.
MR BLAKE: Thank you very much.
(12.44 pm)
(The hearing adjourned until Monday, 4 November 2024)
114
(29) Pages 113 - 115
MR BLAKE: [28] 1/3
1/12 1/18 1/21 40/10
40/14 40/16 40/20
7AM 74/6 71/11 74/13
83/23 85/6 85/10
91/25 96/5 97/23 99/6
103/1 103/4 103/6
103/10 110/18 113/5
113/15 114/10 114/12]
MR HENRY: [2] 92/9
96/4
MR MOLONEY: [4]
98/2 99/7 102/24
110/21
MR STEIN: [2]
103/13 110/14
MS ALLAN: [2]
111/8 113/3
SIR WYN WILLIAMS:
[23] 1/4 40/13 40/15
71/5 71/7 71/12 82/17
82/25 83/7 83/16 85/9
92/7 96/6 97/22 97/25
102/25 103/3 103/5
111/6 113/4 113/16
114/3 114/11
THE WITNESS: [3]
417 110/17 114/2
"23 [1] 89/19
‘as [1] 85/24
‘Balancing [2] 13/6
14/19
"Controls [1] 13/20
‘document [1] 99/18
‘For [1] 13/16
I'm [1] 36/8
‘In [4] 59/23
‘inject’ [1] 14/22
‘more [1] 30/22
"relevant' [1] 99/19
"Save [1] 49/9
‘through’ [1] 78/23
‘we' [2] 36/10 36/20
"Whilst [1] 13/10
wo" [3] 13/9 13/13
13/19
/
ito [1] 38/23
1
4 April [1] 23/8
10 [1] 72/7
10 June [4] 51/21
10 September [1]
65/24
10,000 [2] 72/1 72/10
10.06 [1] 40/17
10.15 [4] 40/19
100 [2] 32/3 32/17
11 December [1]
73/9
11 May [4] 40/21
11 October [1] 25/25
11.08 [1] 71/8
11.15 [1] 71/6
11.17 [4] 71/10
12 January [1] 2/20
12 November [1]
69/7
12.14 [1] 103/7
12.15 [1] 92/2
12.25 [1] 103/4
12.27 [4] 103/9
12.44 [1] 114/13
123 [1] 49/11
13 [2] 52/1 52/3
14 January 2024 [1]
85/18
15 April [1] 36/16
15 March [1] 30/15
15 May [1] 42/24
15/4/2019 [1] 36/5
17 May [4] 43/14
103/23 104/16 104/24)
18 October [1] 2/18
18 October 2024 [1]
1
2 August [1] 55/8
2 years [1] 8/22
20 [1] 6/14
20 April [2] 16/16
17/1
20 March [2] 41/18
41/24
2012 [1] 23/8
2015 [4] 3/10 5/14
12/24 21/21
2016 [8] 3/13 3/15
16/16 17/1 20/10
21/13 21/22 68/12
2017 [8] 7/7 7/10 9/3
22/7 22/12 22/14 23/2
23/3
2018 [9] 20/21 25/21
25/25 27/22 28/10
29/1 29/9 30/2 63/10
2019 [23] 3/14 3/19
21/22 30/15 33/16
36/5 36/16 40/21
43/14 47/14 49/15
51/21 52/23 54/7 55/8
56/13 58/22 59/4
63/19 71/17 101/19
111/14 111/25
2020 [9] 49/15 65/24
68/3 68/10 69/7 76/10
76/11 102/3 111/14
2021 [2] 69/15 102/5
2022 [5] 2/17 2/18
2/19 21/23 87/12
2023 [9] 2/6 2/7 2/11
2/20 74/20 87/3 88/22
88/24 89/23
2024 [8] 1/1 2/12
2/13 3/22 85/18
103/23 113/10 114/14
21 [4] 50/4
21 June [1] 2/7
22 [2] 52/1 52/3
22 August [1] 2/11
22 September [2]
67/7 68/3
23 March [1] 2/6
23 November [1]
21/13
234 [4] 111/12
27 March [41] 12/24
27 May [1] 2/17
28 May [1] 47/14
29 May [1] 113/9
29 November [1]
27/22
3
3 May [1] 2/12
3.2.2 [1] 93/15
30 November [1]
2119
300,000 [1] 50/8
31,000 [8] 66/7 66/15
67/15 68/9 68/24
102/8 102/20 110/23
33 [1] 26/12
35,000 [1] 28/12
4
4 December [1]
28/10
4 November [2]
114/8 114/14
40 per cent [1] 75/16
41 [4] 66/5
5
5.22 [1] 93/20
5/6 [1] 99/6
500 [1] 62/11
555 [7] 60/16 76/13
79/11 79/13 82/2 82/3
82/9
6
6474 [1] 62/3
7 September [1]
717
8 October [1] 2/13
9
9 April [1] 33/16
9.00 [4] 1/2
9.20 [1] 38/21
91 [2] 16/20 16/24
A
Abbotts [1] 55/13
able [19] 2/21 9/25
25/6 36/13 49/2 55/18
55/23 58/16 75/24
80/9 80/10 81/11
81/12 91/12 91/13
91/14 100/13 101/12
107/20
about [60] 4/23 5/24
6/7 6/9 16/22 17/21
19/3 19/5 20/12 21/23}
22/20 30/12 33/6
37/13 37/15 38/22
42/17 44/20 45/17
48/13 48/14 49/9
50/11 51/16 51/17
52/6 52/8 52/19 52/24
53/22 54/10 54/12
54/18 55/10 56/8 58/4)
59/7 59/15 61/13 65/8
70/4 70/24 73/5 77/8
77/17 80/25 88/4
88/21 92/9 98/7
100/21 103/17 104/15)
106/17 106/17 106/25
107/8 108/18 109/22
110/23
above [3] 28/23 44/8
53/18
above’ [1] 60/7
absence [1] 3/21
absolutely [4] 15/7
30/12 86/10 107/16
abstract [1] 59/25
academy [1] 18/25
accept [8] 24/24
24/24 40/8 43/10 80/8)
94/4 95/23 105/18
accepted [3] 13/9
72/22 79/1
access [8] 13/1
13/21 13/21 14/13
15/1 27/9 81/21 93/1
accordance [1]
113/13
account [3] 36/1 36/2!
47/3
accountabilities [2]
68/20 69/2
accountability [4]
39/1 39/13 67/19
68/19
accountable [6] 12/3
45/3 46/22 57/19
69/23 88/15
accountant [1] 97/11
accounting [1] 14/23
accounts [2] 36/2
104/4
accurate [2] 8/18
87/24
achieve [1] 78/22
acknowledge [3]
16/10 89/21 92/24
acknowledged [3]
92/13 110/10 110/12
acknowledging [1]
96/15
across [6] 31/14
44/24 66/13 76/23
81/9 113/2
act [4] 31/16 32/8
85/23 95/25
acting [2] 82/1 82/4
action [1] 10/3
actioned [1] 13/19
actions [1] 104/8
activeness [1] 35/6
activity [1] 44/7
actual [3] 38/18
83/18 87/21
actually [22] 7/3 9/8
9/15 9/22 11/6 11/21
18/21 27/14 30/13
31/9 33/22 33/24
48/11 54/3 54/15
58/14 58/18 69/21
79/7 81/19 88/13
101/20
acutely [1] 81/5
add [2] 83/4 83/11
addition [1] 109/8
additional [6] 13/7
31/6 46/24 72/17
89/10 99/24
address [5] 4/2 4/5
75/19 88/16 90/12
addressed [1] 89/2
addresses [2] 12/24
85/19
addressing [1] 75/20
adequate [1] 48/22
adequately [1] 90/2
adhere [1] 86/5
adjourned [1] 114/14
administer [1] 84/11
administering [2]
84/24 96/23
admission [1] 8/1
admitted [3] 15/17
34/15 108/13
adopt [1] 46/18
adopted [2] 46/17
61/23
advanced [1] 95/5
advancing [1] 16/22
adversarial [2] 94/19
94/20
adverse [2] 45/4 45/9
advice [49] 12/23
19/1 19/18 24/6 31/22)
31/25 38/6 38/6 41/8
41/11 42/9 42/13
(30) MR BLAKE: - advice
A
advice... [37] 43/13
44/17 45/11 45/20
45/21 46/12 46/13
46/15 46/16 46/21
53/19 55/2 57/4 58/2
58/25 59/4 59/18 60/5
60/11 60/24 63/12
74/15 78/1 78/11 80/5
99/24 106/8 106/9
106/12 106/23 106/24
107/1 107/3 107/7
107/19 109/15 112/4
advise [7] 43/20 45/3
47/1 60/2 63/1 109/10
112/19
advised [2] 81/20
84/22
advisers [2] 82/22
111/20
affected [2] 111/15
112/23
affirmed [2] 1/19
115/2
afraid [1] 106/1
after [10] 9/8 42/23
43/25 44/4 44/14
56/18 74/5 86/17
104/24 112/3
afternoon [3] 103/13
111/8 113/24
again [9] 3/24 25/8
34/3 41/8 42/15 64/15}
71/21 74/20 99/3
against [5] 16/21
43/20 44/6 101/2
107/11
agenda [3] 48/4
48/12 50/2
agent [3] 9/10 9/10
29/4
ago [3] 8/22 59/7
64/2
agree [6] 73/13 73/19)
94/19 106/22 107/4
107/15
agreeing [1] 113/23
agreement [5] 5/17
59/24 60/6 60/19 77/6
agreements [1] 6/25
Ah [2] 1/15 1/18
ahead [2] 45/9 73/15
aim [1] 96/10
air [3] 4/13 4/23
52/11
aired [1] 4/18
Al [15] 9/21 36/8 37/7
38/4 38/24 39/18
54/17 54/18 55/7
56/17 58/16 62/21
62/22 68/17 84/22
Al Cameron [1] 37/7
Al's [1] 9/6
Alan [2] 50/3 78/6
albeit [3] 28/13 51/6
65/8
Alisdair [4] 7/12
all [50] 2/3 2/22 2/24
3/3 7/2 10/18 11/13
11/25 13/17 13/18
15/20 24/6 25/15
35/11 37/1 40/13
40/15 43/12 43/22
45/18 48/11 54/4
56/10 59/6 60/7 68/25
69/17 69/18 73/3 73/6
75/24 76/17 76/21
81/8 82/19 88/12
91/22 92/7 94/3 96/11
99/9 99/13 102/18
103/3 105/7 113/17
113/18 114/6 114/11
114/11
Allan [6] 110/19
111/6 111/7 111/9
113/4 115/14
allegations [3] 16/22
86/23 88/17
allow [1] 84/9
allowed [1] 106/9
almost [1] 34/21
alongside [2] 59/10
73/12
already [7] 21/15
27/19 32/24 41/17
77/11 80/24 92/16
also [43] 2/15 3/8 5/6
6/23 11/14 12/2 12/3
13/14 15/17 15/18
15/19 20/10 24/10
27/11 29/11 40/5 40/6
45/13 53/24 57/20
57/22 57/24 62/21
65/18 69/25 72/22
77/3 79/11 80/7 80/13
82/23 82/24 87/8
88/14 89/21 91/1
91/13 91/18 97/13
108/9 109/8 109/17
112/10
although [7] 11/5
35/6 64/25 73/2 93/4
97/18 98/24
Altman [12] 59/19
60/9 60/25 108/7
108/9 108/25 109/8
109/11 109/18 109/19)
110/1 110/10
am [27] 1/2 28/4
28/12 40/17 40/19
41/12 46/11 55/20
56/4 56/5 59/25 71/8
71/10 73/3 73/4 73/23
80/6 80/17 80/18 86/9)
87/5 92/12 95/10
105/8 113/19 113/19
113/21
Amanda [1] 72/17
amnesty [1] 67/25
among [1] 60/4
amount [3] 46/6
55/13 85/21
Amy [2] 31/17 32/6
ANDREW [5] 1/19
1/23 14/17 59/5 115/2
Andy [4] 44/9 63/6
63/20 65/10
Angela [1] 53/25
angry [1] 36/19
angry’ [1] 36/9
announce [1] 1/6
announcement [1]
49/14
another [6] 21/11
38/20 44/19 52/25
109/6 110/19
answer [2] 55/21
111/3
answered [2] 10/1
10/8
anticipate [1] 43/6
al pated [1] 98/18
any [53] 6/4 7/15
15/24 16/3 17/13
17/16 17/19 17/21
18/5 18/8 24/6 24/6
24/13 24/14 25/14
29/18 29/22 29/24
30/7 30/11 32/21
33/17 34/3 35/7 43/16)
46/11 55/25 58/4
59/24 60/5 60/24 61/1
61/5 65/15 73/22
80/25 81/2 85/8 87/12
91/7 96/1 98/17 99/17
99/21 99/22 100/3
100/13 101/12 101/14
104/8 106/1 108/16
111/23
anyone [3] 55/4
100/10 110/11
anything [8] 45/9
50/12 63/2 64/7 71/21
71/25 74/6 83/1
anywhere [1] 106/18
apologies [3] 75/25
76/15 95/13
apologise [4] 62/2
70/19 99/7 112/12
apologised [1] 87/25
apology [3] 86/18
86/19 99/5
apparent [1] 58/5
appeal [34] 23/11
23/11 24/6 24/9 24/10
25/19 26/1 26/2 26/6
40/23 40/23 41/4
41/15 41/15 41/17
41/23 42/4 42/5 42/14
42/15 42/22 50/5 50/6
63/16 76/18 101/17
102/9 102/19 108/4
108/6 108/9 110/25
4111/1 111/11
Appeal's [2] 41/3
41/10
appeals [7] 23/4
69/14 102/4 108/3
108/5 108/8 111/5
appear [1] 113/13
appearance [1] 2/9
appeared [3] 38/12
64/12 96/15
appears [4] 2/21
23/12 64/8 113/11
appendix [2] 80/17
92/22
applicants [4] 77/22
77/25 78/25 79/3
application [13] 26/1
26/6 33/20 34/2 40/24
41/16 42/14 42/15
42/21 50/5 57/6 64/19)
78/13
applied [1] 26/10
applies [1] 19/22
apply [3] 31/25 32/18
79/3
applying [1] 79/24
appoint [3] 34/3 39/8
39/19
appointed [12] 3/15
6/8 37/10 42/11 56/17,
58/19 74/13 77/2
109/7 109/8 112/7
112/9
appointment [2] 34/5
75/12
appreciate [2] 44/5
96/21
appreciation [1] 19/9
approach [5] 7/5
56/19 56/23 60/4 63/7
approached [3] 37/9
55/12 63/5
appropriate [10]
40/11 45/12 46/8
46/17 71/22 75/3 83/9
84/5 84/18 98/19
appropriately [1]
104/7
approval [1] 14/24
approved [2] 83/9
83/19
April [10] 3/22 16/16
17/1 20/10 23/8 33/16}
36/16 42/11 49/15
74/21
ARC [4] 68/7 69/5
69/7 70/11
archiving [2] 67/18
69/25
are [63] 2/3 2/15 2/21
2/24 3/4 7/20 11/20
11/23 13/14 13/15
13/18 16/2 22/2 22/8
23/8 25/10 28/24
31/24 43/19 45/4 47/2I
47/15 48/6 48/23
49/24 53/12 53/20
57/19 62/20 64/23
66/8 67/16 72/1 73/11
77/2 80/11 80/18 81/9
82/15 82/19 85/13
85/21 85/23 86/3 86/7I
86/10 87/11 90/5 92/3}
95/8 95/13 97/1 97/4
97/12 97/14 98/17
99/15 99/19 99/21
101/12 105/12 106/11
107/20
area [7] 4/17 10/7
18/21 19/20 57/14
68/21 76/7
areas [7] 16/2 20/24
31/8 34/7 76/7 101/10}
103/16
aren't [3] 8/7 21/21
71/23
arise [2] 32/7 32/13
arisen [2] 7/16 51/1
arises [1] 19/17
arising [1] 76/18
arose [3] 14/10 76/24
79/20
around [27] 4/7
15/22 20/22 26/22
26/22 29/4 31/12
38/21 43/7 50/8 57/17
58/20 60/21 61/10
61/12 66/21 68/24
69/1 70/11 70/22 74/1
78/8 87/15 92/16
98/15 102/15 102/16
arranged [1] 28/10
arrangements [2] 1/6
113/23
articulated [1] 33/25
articulating [1] 18/11
as [142]
as though [1] 64/1
aside [3] 94/17 97/7
101/15
ask [16] 10/6 27/14
38/22 43/8 50/11
55/23 57/4 59/9 77/8
82/17 87/19 87/20
90/3 103/17 108/21
111/9
asked [20] 11/5 11/6
30/14 35/7 37/17
37/19 37/20 37/22
38/11 38/23 38/25
45/20 48/24 55/12
74/16 89/9 95/2 96/13
108/2 110/22
asking [4] 56/4 56/6
61/13 106/25
asks [1] 53/8
(31) advice... - asks
A
aspects [1] 69/16
asserted [1] 13/11
assess [1] 82/7
assessed [1] 97/12
assessing [1] 69/13
assessment [4]
62/19 97/8 97/9 97/21
assist [11] 4/14 8/13
9/3 10/15 37/23 56/12
63/3 66/15 78/4
101/12 112/15
assistance [1] 7/9
assists [1] 62/16
associate [1] 40/1
assume [1] 49/23
assurance [2] 68/8
106/5
at [143]
attached [8] 16/24
30/22 32/6 32/9 33/14,
41/3 59/20 93/16
attacks [1] 49/7
attempt [1] 7/15
attend [11] 30/6 30/9
35/9 35/11 47/16
A7IN7 47/19 47/22
48/1 48/10 87/2
attendance [2] 47/15
72/19
attended [3] 34/20
34/21 50/2
attending [3] 10/25
30/8 48/8
attends [1] 48/4
attention [9] 15/4
53/3 67/22 98/5
104/17 105/1 105/9
105/11 105/16
attested [1] 113/19
attitude [1] 77/9
attract [1] 32/2
audio [1] 70/15
audit [5] 13/11 55/15
66/10 67/8 68/5
August [11] 2/11
3/10 3/15 23/3 44/13
55/8 56/13 61/10
61/10 89/11 102/16
August 2015 [1] 3/10
Australia [1] 3/8
author [2] 23/6 28/1
authorise [1] 41/23
authorised [1] 13/21
autumn [1] 102/3
available [1] 13/13
awaiting [1] 101/22
aware [36] 5/9 16/20
17/1 17/5 20/19 22/2
22/23 22/24 26/14
26/17 29/9 29/14
30/12 33/18 34/2
44/18 46/11 48/6
49/18 53/21 61/4 61/8)
68/23 69/3 70/23
77/24 82/17 84/17
95/7 101/7 101/8
105/8 106/11 106/15
106/23 110/12
away [3] 55/20 95/21
107/25
awkward [2] 32/21
105/12
B
B13 [1] 42/20
B68 [1] 63/22
back [18] 15/13
18/20 28/24 39/10
40/14 45/21 52/18
59/3 63/20 71/6 84/8
86/16 88/2 95/13 98/3
106/20 107/25 112/13)
background [3] 10/7
106/16 107/5
balance [4] 44/6 73/6
91/1 96/16
balancing [2] 13/16
96/24
Banking [1] 5/17
bar [4] 15/18 33/23
82/13 94/10
barristers [3] 34/4
35/21 102/13
Bartlett [6] 1/7 90/4
106/4 106/5 106/6
107/1
Bartlett's [1] 90/6
based [1] 60/11
bases [2] 19/19
19/21
basically [1] 19/17
basis [7] 11/13 27/13
101/17 101/21 104/11
105/10 105/12
basket [1] 13/22
bat [1] 57/10
Bates [1] 28/18
BAU [2] 10/21 84/15
be [165]
Beabey [1] 30/25
bearing [1] 104/16
became [12] 3/13
3/19 5/9 21/22 23/7
31/7 39/7 47/19 52/16
69/3 74/9 98/21
because [43] 5/4
6/16 7/21 9/13 9/15
10/20 20/3 21/8 22/10
22/17 24/12 25/2 27/2
27/19 29/7 31/2 33/3
35/6 35/18 42/8 48/9
48/11 55/12 57/6
57/12 57/23 58/3
60/22 61/18 62/10
63/14 64/19 65/11
70/21 73/23 75/18
79/13 79/14 86/22
87/9 92/19 93/4 110/2
become [3] 19/14
29/1 57/7
becoming [1] 64/5
been [95] 3/21 12/16
14/14 15/2 16/11
16/24 17/3 19/6 24/22
25/16 26/18 28/7 29/5
29/6 29/25 30/4 35/3
37/25 40/5 42/22
45/10 50/14 50/15
52/14 54/4 54/18
54/22 55/10 55/12
55/18 56/15 56/20
57/5 57/6 58/11 60/8
60/25 61/21 61/23
62/13 62/20 63/4
63/25 64/3 65/5 66/8
66/20 66/22 68/11
68/16 70/9 70/16
70/25 72/14 73/1
75/24 76/4 77/11
79/25 80/23 80/25
81/4 81/6 82/9 82/16
82/18 82/23 83/2
83/17 83/23 87/4
88/18 89/14 90/2
92/14 93/10 94/6 95/2
95/19 96/8 98/12
99/16 100/24 101/7
104/23 105/5 105/10
106/8 106/23 108/24
109/14 110/24 111/15}
112/16 112/25
before [29] 1/4 3/7
15/5 17/2 17/9 20/4
26/5 34/24 36/25
43/25 53/19 53/24
58/18 65/17 65/18
74/4 81/25 90/19 91/6}
95/20 97/24 101/13
107/7 107/23 108/2
110/6 110/10 110/25
113/5
begin [2] 1/4 71/13
beginning [5] 36/13
76/10 76/11 80/23
113/6
begins [1] 7/12
behalf [4] 95/5 108/7
108/19 111/9
behaviour [1] 104/6
behind [1] 77/23
being [48] 4/12 11/3
24/10 26/13 26/15
28/17 28/25 31/22
32/15 38/15 41/12
42/18 43/23 46/15
49/2 49/19 50/7 53/12
56/4 57/8 66/9 67/16
69/12 73/25 74/15
77/24 79/2 80/9 80/10}
81/2 87/1 90/21 91/10
93/1 93/11 93/12
93/24 95/5 97/10
97/10 97/11 100/11
105/24 106/5 106/11
106/12 107/13 108/11
BEIS [2] 32/17 84/3
belief [5] 2/4 2/25
55/16 113/12 113/14
believe [5] 54/14
76/1 78/20 89/18
107/17
bell [4] 112/17
below [6] 32/19
37/12 43/15 50/7 64/4)
80/16
Ben [5] 31/19 38/25
50/3 55/10 80/15
benefit [4] 39/25 40/7I
49/2 80/9
BENJAMIN [3] 1/19
1/23 115/2
best [7] 2/3 2/25
16/10 25/16 25/16
51/11 113/12
better [3] 12/4 59/9
82/16
between [18] 4/8
20/23 21/2 21/20
21/21 26/24 45/7
72/25 86/14 87/13
91/1 96/16 100/14
105/5 105/6 105/10
111/14 113/1
beyond [1] 43/24
big [1] 7/22
bit [6] 9/24 34/1
48/15 105/12 106/3
107/18
Blake [8] 1/4 1/20
98/5 98/10 99/3 99/7
114/9 115/4
blog [1] 53/23
blood [1] 7/23
Board [55] 6/13 9/6
9/20 10/25 19/8 20/20)
30/9 34/6 35/11 38/5
39/7 41/8 41/17 41/18
41/20 41/22 41/23
42/8 42/12 42/15
46/21 47/14 47/16
47I17 47/23 47/23
47/24 48/1 48/2 48/3
48/9 48/9 48/10 48/18
49/3 50/4 52/19 56/15
59/12 65/15 68/3 74/4,
74/9 75/2 83/5 83/19
83/20 84/8 84/12
88/21 91/13 109/4
109/5 109/8 109/10
Board's [1] 42/12
Bond [6] 14/17 24/19
31/18 43/13 59/5
64/24
borne [1] 38/7
boss [1] 34/14
both [13] 28/4 41/7
49/1 51/10 56/21
57/24 69/5 75/15
85/24 90/6 96/9 96/13
101/10
bottleneck [1]
107/13
bottom [15] 7/11
16/17 25/21 27/23
30/18 41/1 41/5 42/6
52/23 53/18 54/3
59/13 77/12 77/19
103/25
boxes [9] 66/7 66/15
67/15 68/9 68/24
69/10 102/8 102/20
110/23
Bradshaw [3] 87/9
87/10 88/7
branch [2] 55/23
72/2
branch's [1] 14/23
branches [2] 11/20
28/4
brand [1] 49/7
breadth [1] 81/9
break [14] 4/8 4/9
34/24 40/12 40/18
65/18 71/4 71/9 92/2
97/24 103/2 103/8
108/3 114/7
Brian [6] 59/19 108/7
108/24 109/7 109/11
109/19
brief [2] 53/20 68/6
briefed [1] 102/22
briefing [4] 30/23
32/9 32/15 37/21
briefings [1] 35/4
briefly [4] 6/20 63/3
66/15 70/18
bring [3] 7/8 15/10
36/21
bringing [1] 10/9
broad [4] 69/2 72/13
77IT 104/21
broader [1] 52/9
broadly [6] 18/16
38/15 48/20 54/23
61/15 91/3
brought [12] 15/3
37/2 49/11 53/2 67/22
81/17 100/24 104/17
104/25 105/9 105/11
105/15
BTO [1] 112/16
bugs [12] 50/21
51/24 52/1 52/3 52/3
52/6 52/7 52/9 54/9
54/13 55/5 111/16
bullet [4] 36/17 37/11
38/22 50/10
bundle [5] 62/3 71/14
(32) aspects - bundle
B
bundle... [3] 99/5
99/6 103/19
business [57] 4/17
5/19 6/16 6/23 7/4
8/22 12/3 12/6 17/7
18/6 18/11 20/6 20/7
20/11 33/2 34/13
35/14 42/1 42/7 44/7
44/19 44/25 45/3
46/22 49/18 51/12
52/14 54/8 54/12
54/24 54/25 58/10
64/12 66/19 67/3
69/13 69/17 69/23
72/11 73/13 75/22
76/23 78/20 83/25
84/15 84/16 84/19
88/15 88/15 91/9
91/15 91/22 91/23
98/7 100/12 100/25
101/15
business's [2] 19/5
77/18
busy [2] 67/10 72/3
but [124]
Butoy [3] 23/12 26/4
26/10
Butoy's [1] 26/6
c
call [3] 53/25 84/15
98/15
called [5] 12/12 21/3
76/14 79/21 102/11
Calvert [2] 109/9
109/17
Calvert-Smith [2]
109/9 109/17
came [10] 5/2 31/5
38/3 45/21 52/17
56/21 66/19 74/8
86/16 100/3
Cameron [18] 7/12
36/5 36/16 36/18 37/7
37/13 38/20 52/24
52/24 53/8 53/13 55/7I
57/5 57/8 62/22 68/17
84/22 96/14
Cameron's [2] 9/23
58/4
campaign [1] 49/9
can [78] 1/21 2/24
4/14 6/22 7/4 7/11 8/5)
8/8 8/13 9/3 9/11 10/7
10/15 16/6 16/13
16/16 18/14 21/14
21/16 22/7 23/5 26/3
27/23 28/1 28/20
30/17 30/19 31/17
33/15 37/23 40/14
40/25 41/9 43/12 45/2)
47/13 47/15 49/25
51/20 53/8 53/20
56/12 59/4 61/3 61/16)
63/3 65/3 66/15 67/6
67/13 69/8 71/11
71/13 73/7 77/19 78/4
78/22 80/12 82/17
92/2 92/5 92/9 95/11
95/12 95/12 95/13
95/21 98/3 99/2
101/10 103/13 103/15)
103/17 107/11 107/25)
111/23 112/15 113/10)
can't [5] 60/13 91/3
95/3 106/24 112/12
cannot [2] 53/6 77/21
capable [1] 109/6
capitals [1] 87/6
captured [1] 66/22
care [2] 22/1 101/25
career [3] 15/17 19/9
101/1
careful [1] 96/8
carefully [1] 99/14
Carla [1] 68/6
carrying [1] 54/10
Cartwright [7] 12/13
12/23 13/24 24/19
25/10 29/23 100/3
cascaded [3] 98/6
100/11 101/14
case [21] 8/1 8/19
10/20 17/21 20/5
23/10 23/12 26/4 48/2
49/11 51/2 64/11
64/24 79/5 84/13 93/3
95/1 95/4 99/22
100/22 107/18
cases [9] 7/15 13/25
15/2 25/7 26/10 96/22
97/14 97/21 112/21
cash [1] 55/17
catalyst [1] 64/17
categorically [1]
73/20
categories [1] 10/12
caused [1] 41/10
caution [1] 54/7
Cavender [1] 42/10
CCRC [11] 4/4 7/19
26/13 26/16 26/18
26/19 26/22 35/5
101/21 111/22 113/1
cent [1] 75/16
central [3] 6/24 12/1
98/22
centrally [2] 13/8
13/17
centre [1] 73/13
CEO [8] 37/8 41/7
54/18 56/17 57/7
57/13 57/21 105/6
certain [3] 33/2 48/23
88/18
certainly [11] 9/6
18/22 20/6 36/2 61/11
69/2 78/5 90/23 97/25
98/4 107/25
cetera [3] 4/4 58/21
97/17
CFO [1] 37/8
CFOO [1] 68/16
chain [10] 7/9 10/5
22/7 25/19 27/22
32/23 42/23 54/16
64/3 80/12
chaired [1] 76/16
Chairman [4] 37/4
37/5 37/5 92/19
Chairman's [1] 80/21
challenge [4] 61/12
79/24 81/4 91/13
challenging [5] 39/24I
48/11 78/19 79/3
91/12
change [8] 37/17
56/14 56/22 64/17
64/21 83/1 83/8 86/13
changed [5] 59/11
63/15 63/15 63/19
104/6
changes [3] 38/9
82/18 82/19
chapter [1] 73/14
charging [1] 77/25
check [1] 110/15
checks [1] 111/2
Chesterfield [2] 70/1
71124
Chief [3] 21/19 21/22
55/7
Christie [4] 111/8
CI [7] 87/11 88/19
88/25 89/15 90/2
90/15 107/17
circa [1] 6/14
circular [2] 21/10
73/8
circulate [1] 43/9
circumspect [1]
104/7
circumstance [1]
79/23
circumstances [9]
16/5 16/10 28/6 45/12
45/14 57/12 57/14
74/23 95/4
civil [5] 10/13 98/14
100/14 100/19 100/23
claim [13] 11/19
16/21 16/25 17/14
17/17 20/12 59/10
64/13 65/6 65/8 65/9
78/15 95/18
claimant [1] 28/17
claimant's [1] 51/22
claimants [14] 16/24
59/20 59/24 60/4 60/6
61/6 62/24 63/1 64/6
65/5 72/22 79/9 82/9
111/17
claims [12] 11/20
11/21 60/16 62/11
78/14 80/4 80/19 82/7
97/8 97/9 97/21
100/14
clarify [1] 101/9
clarifying [1] 101/15
clarity [2] 69/1 72/4
clear [10] 30/5 32/3
32/17 38/14 41/13
45/25 52/2 56/4 88/22
110/8
clearer [2] 80/9 92/14
clearly [8] 5/25 16/11
18/1 25/14 63/19 73/2}
73/23 88/2
client [3] 28/9 28/11
31/25
client's [2] 28/6 28/8
close [4] 7/20 39/2
73/13 106/18
closes [1] 43/25
closing [1] 43/19
coach [1] 91/14
cognisant [1] 70/24
colleagues [3] 20/6
20/7 97/4
combination [1]
101/6
come [12] 6/4 7/3
23/21 31/10 33/15
40/14 51/8 52/13 55/3)
61/3 71/6 108/16
comfortable [1]
39/13
coming [4] 5/15
49/24 88/12 96/18
commenced [2]
15/16 17/8
comment [9] 4/23
5/4 21/8 33/22 53/22
95/3 106/24 107/7
107/19
comment/journalists
[4] 53/22
comments [3] 49/24
56/20 77/16
commercial [4]
15/20 98/14 100/23
101/2
Commission [3] 25/7
26/11 112/21
commit [1] 18/13
commitment [1] 97/1
committed [1] 73/11
Committee [12] 5/22
5/23 65/23 66/11
66/12 67/8 67/14
67/17 67/25 68/4 68/5)
68/7
Committee's [1]
67/22
committees [4]
10/25 40/6 40/6 83/6
common [16] 21/4
30/16 34/20 38/2
42/16 56/16 62/6 63/9)
63/16 64/18 76/18
76/19 76/21 86/6 93/5I
93/11
Comms [2] 54/17
54/22
communicate [1]
88/20
communicated [5]
33/7 38/3 51/9 78/23
112/13
communication [2]
4/18 111/22
communications [4]
6/1 17/6 49/23 53/17
company [18] 7/2 7/4
21/20 24/1 35/10
37/24 37/24 43/4
46/17 48/21 49/2
56/23 68/17 70/7
70/23 80/5 91/17
98/19
comparison [1] 5/5
compensate [1]
60/13
compensation [16]
60/21 75/18 76/8 76/9
77/9 84/14 84/25 85/7I
92/10 94/18 95/24
96/6 96/11 96/17
96/22 97/2
competence [3]
15/14 15/22 15/23
Complaint [1] 80/20
complete [2] 7/18
89/16
complex [3] 81/6
100/22 106/5
compliance [5] 5/22
40/6 65/23 67/23
69/22
complicated [1] 80/1
comply [1] 77/7
complying [2] 67/3
91/23
components [1]
76/21
compromised [1]
14/5
computer [2] 52/25
53/5
concentrate [1]
92/20
concern [18] 13/15
22/2 22/23 22/25
37/15 44/19 51/4
51/12 51/16 54/10
54/22 54/23 57/3 58/4I
58/10 67/14 72/24
75/15
(33) bundle... - concern
Cc
concerned [10]
20/22 22/19 41/12
42/18 54/17 63/11
70/3 94/18 96/20
96/21
concerning [1] 29/10
concerns [17] 22/22
31/13 32/24 33/1 33/4
33/6 33/8 54/12 57/7
60/24 63/24 75/1
75/21 107/8 108/1
109/19 109/22
concerted [1] 56/19
conclusion [4] 41/11
51/16 59/22 101/14
conclusions [1]
41/10
conduct [1] 12/1
conducting [2] 43/20
102/14
conference [1] 14/16
confidential [1]
53/12
confidentiality [3]
20/12 33/13 56/6
confirm [5] 2/3 2/21
2/24 111/23 113/10
conflating [1] 97/5
conflation [1] 87/13
conflict [1] 109/22
conflicted [1] 87/2
conformance [2]
77/4 91/20
confrontational [2]
81/23 81/24
confusing [1] 51/25
connection [1] 36/12
conscious [2] 65/12
65/13
consent [1] 14/24
consequential [1]
92/16
consider [7] 46/20
68/15 92/11 107/12
107/21 107/21 107/23}
considerable [1]
70/9
consideration [5]
24/14 49/19 77/16
77/24 80/7
considerations [2]
46/23 47/2
considered [3] 8/24
66/6 90/24
consistent [1] 37/11
constant [2] 76/4
76/5
constantly [1] 64/5
contain [1] 32/21
contemporaneous
[8] 92/21 92/23 93/1
93/16 93/18 93/23
94/1 94/5
contest [1] 62/6
context [6] 11/3
45/19 52/9 79/7
100/23 111/19
continue [2] 74/22
86/12
continued [2] 12/9
49/10
continues [1] 78/18
continuing [3] 73/14
100/8 104/3
contract [3] 6/25
28/4 93/21
contracts [2] 6/24
29/4
contrary [3] 41/8
60/12 74/6
control [3] 4/14 4/24
52/12
controls [6] 6/21
13/17 67/18 67/23
78/10 109/12
conundrum [1] 60/15
convenient [1] 71/3
conversation [9]
33/19 38/10 38/19
38/20 39/18 54/19
58/17 85/16 105/22
conversations [3]
23/20 23/22 83/17
convicted [9] 14/1
14/14 15/3 59/19
59/24 60/4 60/6 60/20
111/17
conviction [4] 26/11
60/14 111/11 111/21
convictions [4] 60/17I
60/22 74/1 112/6
Cooper [1] 37/7
cooperated [1] 114/4
coordination [1] 45/7
copied [6] 9/4 25/19
29/25 30/4 30/20
32/23
copy [2] 105/1 105/2
Core [3] 91/6 92/1
111/9
corporate [4] 40/3
81/11 91/1 91/17
correct [37] 3/1 3/5
3/6 3/9 3/12 3/15 3/18
3/20 3/22 5/10 11/10
12/12 12/18 14/18
19/15 23/14 23/15
24/12 36/23 44/15
47/24 58/24 61/7 72/7
83/11 83/22 85/5
94/22 96/3 96/25
100/9 101/25 102/6
107/13 112/17 113/2
114/10
correspondence [7]
19/13 54/4 71/16
93/24 105/6 106/1
106/13
cost [4] 9/1 75/13
75/20 76/5
costing [1] 7/23
costs [5] 50/7 61/4
61/5 75/7 75/16
could [40] 7/8 8/20
10/4 11/7 12/4 13/22
20/5 21/4 21/8 22/9
23/1 25/18 27/21 33/7
40/21 40/22 42/20
42/21 50/12 50/23
52/21 52/22 55/6
55/14 55/20 59/2
65/12 65/19 71/6
77/10 82/16 84/2
86/25 88/12 88/16
92/14 95/7 97/23
99/21 103/1
couldn't [2] 73/23
113/21
counsel [45] 3/17
3/19 10/24 24/20
25/11 27/2 27/6 34/12
34/18 35/8 35/13
35/20 35/21 39/7
39/10 39/19 40/8
44/23 45/17 46/5 47/8
47/16 47/19 47/22
47/24 48/2 48/16 49/1
50/6 57/21 57/25
65/13 70/17 70/21
73/3 73/22 76/11 77/2
82/23 91/8 91/11
104/21 105/4 109/7
112/9
counteract [1] 49/20
counterbalance [4]
81/13 81/18 91/2
109/13
couple [2] 59/7 69/11
course [27] 1/9 1/25
3/4 9/7 9/14 15/9 16/2
16/25 18/13 19/20
30/13 31/4 33/11 37/8
41/19 46/14 58/14
65/15 66/17 71/5 73/2
80/8 82/15 89/16
93/10 94/11 94/14
court [23] 16/21
17/23 23/11 24/10
25/25 28/18 40/23
41/3 41/9 41/15 42/4
42/22 50/5 62/10
79/15 94/23 94/24
100/19 102/8 108/4
108/6 108/8 111/1
covered [1] 51/2
Coyne [1] 51/23
Coyne's [1] 51/25
create [2] 17/20 45/2
created [2] 14/7
87/12
creates [2] 33/12
70/13
creating [2] 22/1
44/20
creation [2] 22/3
98/11
credibility [3] 15/14
41/12 42/19
criminal [40] 12/11
12/17 15/2 15/3 23/4
24/9 24/15 24/16
24/21 24/23 25/1 25/2,
25/3 25/7 25/10 25/14)
25/25 26/10 29/18
60/17 60/22 74/1 77/2
100/3 100/20 101/9
101/17 102/4 102/9
102/19 108/4 108/6
109/1 110/25 111/1
111/5 111/20 112/5
112/11 112/21
criminals [1] 60/21
criteria [4] 46/24
78/24 79/17 83/1
criticisms [1] 104/7
cross [1] 51/22
cross-examination
[1] 51/22
Crown [1] 112/21
crucial [1] 99/15
crystallisation [1]
64/20
current [8] 4/5 29/7
37/16 39/1 43/5 53/6
54/13 107/20
currently [5] 23/8
26/12 28/12 28/17
92/3
customers [2] 72/3
73/12
cut [3] 32/3 32/17
70/18
D
Daily [4] 49/9
damages [2] 97/16
97/17
damaging [1] 32/22
data [31] 66/7 66/12
66/18 67/2 67/3 67/18
67/23 67/25 68/16
68/16 68/18 68/19
68/21 68/24 69/3 69/4
69/4 69/13 69/18
69/19 69/20 69/24
70/4 70/12 70/16
70/17 70/20 70/21
70/24 104/5 104/10
date [4] 11/7 68/13
103/22 104/16
dated [11] 2/6 2/7
2/10 2/12 2/13 2/16
2/18 2/19 2/20 12/24
113/9
dates [1] 21/21
David [3] 42/10 109/9)
109/17
Davies [1] 53/17
day [7] 30/17 34/21
37/22 57/2 68/8 72/7
72/7
days [2] 50/5 72/15
deal [6] 7/22 28/22
69/8 85/10 92/3 92/18
dealing [5] 23/12
25/6 53/4 67/10
108/14
deals [1] 4/3
dealt [3] 28/18 53/25
61/19
debt [2] 9/10 29/5
decades [1] 94/7
December [3] 28/10
72/13 73/9
decide [1] 60/2
decision [22] 19/16
27/3 34/22 35/15 37/2I
39/8 41/3 41/14 41/17I
41/21 41/24 46/19
47/13 47/4 47/5 47/6
47/7 47/9 47/10 47/11
84/13 109/20
decision-making [1]
109/20
decisions [5] 24/7
29/24 30/8 30/10
35/12
Declan [1] 75/10
deed [1] 71/22
deep [1] 54/12
defects [4] 54/9
54/13 55/5 111/16
defence [3] 14/2 56/1
63/18
defendant [2] 14/1
14/9
defending [1] 62/11
define [1] 60/1
definition [1] 99/20
degree [1] 50/22
delay [3] 64/10 89/12
90/1
delayed [1] 64/14
delegated [1] 83/20
delete [1] 17/13
delivery [1] 75/17
Deloitte [5] 7/18 7/24
13/2 13/5 14/18
denied [1] 89/9
deny [1] 73/20
department [18] 5/3
6/22 6/23 11/22 18/22
24/15 25/6 31/8 32/25
33/10 42/18 43/1 45/7I
45/8 49/23 68/18
83/25 89/22
(34) concerned - department
D
depending [1] 49/16
deprived [1] 93/1
depth [2] 53/24 61/19)
describe [1] 111/19
designed [1] 94/20
desire [2] 9/9 75/22
desired [1] 78/22
despite [1] 90/3
destroy [1] 17/13
detail [6] 30/24 53/9
81/10 99/17 106/2
113/2
detailed [1] 1/8
detailed’ [1] 30/23
details [6] 25/15
53/11 54/20 95/7
105/7 106/25
detect [1] 13/20
determined [1] 109/5
devastation [1] 16/6
developments [2]
23/17 50/4
device [1] 101/20
devised [1] 79/2
devoted [1] 70/5
dialogue [2] 28/8
78/11
Diane [1] 88/22
Dickinson [6] 14/17
24/19 31/18 43/13
59/5 64/24
did [58] 6/4 9/23
10/15 11/9 11/11
11/11 12/7 13/16 15/9}
23/16 24/13 24/21
24/23 25/9 27/14
29/23 29/24 30/6 30/9
30/25 33/6 35/11
37/18 37/21 39/11
39/13 45/8 50/17
52/12 60/8 60/17
60/18 60/18 60/24
64/10 67/21 68/12
68/14 73/20 74/10
75/9 83/4 83/5 87/2
88/2 88/20 89/4 89/10)
90/3 92/13 101/5
102/18 102/19 108/16
108/20 109/18 110/2
112/20
didn't [24] 6/11 9/24
15/22 17/10 24/6 25/3}
30/11 34/3 34/17 35/8
35/9 60/21 64/25
64/25 75/3 75/4 81/21
82/2 90/16 92/11
105/1 105/17 106/1
109/3
different [12] 3/8
10/10 11/23 34/19
41/11 48/7 57/22
64/16 90/14 94/22
94/24 108/1
differential [1] 60/4
difficult [11] 48/8
48/25 58/1 58/3 62/18
73/14 74/18 81/10
81/20 89/23 107/18
difficulties [2] 58/5
93/1
difficulty [1] 89/8
dig [1] 73/21
digital [2] 13/22
105/1
diligent [1] 15/21
direct [3] 27/9 39/6
53/21
directed [1] 88/25
direction [3] 74/14
87/22 107/11
directly [11] 10/21
23/20 54/16 82/4
83/15 84/25 96/21
97/20 102/22 103/18
112/22
director [27] 3/13
3/15 6/7 6/8 20/17
24/23 34/7 39/16
47/25 48/10 53/17
68/17 69/22 69/22
70/16 70/20 72/18
72/20 75/11 86/15
87/22 88/25 89/1
98/21 104/13 105/3
106/5
directors [5] 46/21
75/12 75/14 85/18
91/13
disadvantage [1]
94/5
disappointed [6]
38/5 42/7 42/8 42/16
42/16 62/23
disclosability [1]
14/14
disclosable [3] 13/25
18/14 44/20
disclose [4] 43/17
43/24 99/25 106/10
disclosed [6] 17/20
45/5 45/5 45/10 46/3
110/24
disclosure [25] 2/15
15/2 20/2 20/22 24/16
31/15 43/22 46/2
65/22 70/22 101/16
101/25 102/12 102/16)
102/18 106/14 106/17)
107/24 108/12 108/13}
108/15 109/21 110/4
111/21 112/2
discovered [1] 66/20
discovery [2] 67/15
102/7
discuss [2] 28/10
56/7
discussed [12] 5/12
8/19 11/4 48/13 48/14
56/15 68/7 84/4 93/12,
109/5 109/23 109/25
discussing [3] 26/25
54/18 72/5
discussion [6] 5/24
6/9 14/13 67/14 67/24
80/25
discussions [7]
11/11 11/12 29/16
29/20 29/22 61/9
89/18
dispute [6] 9/18
11/18 28/11 50/21
78/17 82/7
disputing [1] 22/23
division [6] 6/12 6/19
102/9 108/4 108/6
1141/1
do [63] 6/10 6/20
7/24 10/3 10/6 10/7
11/5 11/20 15/24 16/9
18/8 21/6 21/18 25/5
31/4 34/8 35/2 37/2
38/9 44/25 45/1 45/11
45/23 46/7 46/17
48/16 49/4 50/12 51/4
53/21 56/6 58/4 60/15
62/2 65/16 68/15
69/12 70/7 71/21
75/16 81/20 81/22
82/15 83/13 86/14
88/11 89/4 89/25 90/5)
91/7 92/19 94/12
94/19 95/23 96/23
96/24 97/3 97/5 97/14
106/22 107/15 112/11
113/24
document [40] 7/6
12/19 12/21 15/5 15/5
15/11 16/13 17/22
19/14 21/2 29/25
31/14 32/1 32/13
32/18 32/20 33/5
33/14 34/24 35/23
36/14 62/2 67/4 67/4
68/1 69/9 85/12 98/16
98/20 98/23 98/25
99/14 99/15 99/20
99/21 100/18 103/18
103/23 106/7 107/3
documentation [4]
18/7 78/25 80/2 94/14]
documented [1] 74/3
documents [27]
17/13 17/16 17/19
19/24 22/1 22/3 29/11
45/4 48/23 66/18
66/22 73/24 80/4 81/8
83/4 92/21 93/2 94/1
94/6 94/12 98/11 99/3)
99/19 99/21 99/24
99/25 111/4
does [18] 2/23 8/13
31/25 32/20 33/10
46/2 48/8 48/25 62/18
74/24 75/8 94/14 95/4)
96/2 97/20 106/19
112/17 113/13
doesn't [2] 48/3
55/24
doing [4] 6/11 8/6
65/1 89/7
don't [44] 4/25 5/23
11/3 18/2 18/19 19/3
20/2 21/8 22/9 27/3
29/14 31/9 38/17
44/25 45/23 47/12
48/11 48/12 48/22
53/2 54/14 55/4 61/1
65/14 69/6 71/24
73/22 81/24 89/20
89/25 92/24 94/3 94/4,
95/18 97/18 99/17
101/18 104/21 105/3
105/7 107/4 107/17
111/13 112/18
done [8] 20/6 75/23
82/16 86/10 87/14
87/19 97/9 110/2
dots [1] 44/24
doubt [1] 17/21
down [38] 7/10 16/19
21/14 22/5 22/11 23/5)
23/21 25/21 27/23
28/1 33/15 34/25 38/2,
38/8 38/14 41/1 42/5
43/23 47/15 52/25
59/4 59/21 61/3 63/16
63/23 64/18 66/1
67/13 68/4 69/24
71/16 72/15 74/1
77/13 77/19 85/14
85/19 112/4
draft [3] 30/22 59/17
83/8
drafted [4] 80/3 83/2
92/22 93/12
drawing [1] 98/5
dropped [1] 36/12
due [7] 3/4 3/24 15/9
16/25 28/6 86/9
104/19
duress [1] 28/14
during [9] 1/9 3/16
12/18 15/7 17/8 48/16}
58/22 101/13 111/2
duties [4] 28/5 100/8
100/15 101/16
duty [5] 43/22 46/1
99/25 101/25 112/2
dynamic [1] 73/16
E
E10 [4] 77/11
E11 [1] 59/2
E13 [1] 51/20
E18 [1] 52/22
E23 [4] 27/22
E29 [2] 61/17 62/3
E3 [1] 103/19
E33 [1] 55/6
E39 [2] 57/3 71/14
E40 [1] 73/7
E41 [4] 7/9
E42 [1] 35/24
E45 [1] 12/21
E47 [1] 16/14
E49 [1] 21/12
E50 [2] 22/8 99/6
E54 [1] 25/18
E57 [1] 23/1
E58 [1] 65/20
E59 [1] 67/7
E60 [1] 68/2
E61 [1] 69/8
E70 [4] 10/4
E8 [1] 40/22
E9 [1] 30/18
each [5] 2/1 2/2 4/6
4IT 83/1
earlier [4] 26/7 26/9
68/7 90/17
early [5] 5/12 61/8
98/4 113/23 114/5
earnings [2] 93/17
93/25
easier [1] 31/21
economic [1] 97/17
effect [6] 8/16 37/17
38/13 38/17 73/17
107/2
effort [2] 56/19 70/9
either [10] 1/15 14/2
29/6 38/25 59/10
59/14 82/20 99/22
101/6 107/11
elements [1] 46/25
eligibility [4] 78/24
79/6 79/6 79/17
Elliot [1] 85/21
else [3] 39/2 110/11
110/16
elsewhere [2] 56/8
75/6
email [70] 7/9 7/11
9/11 9/14 10/2 11/2
16/16 16/18 17/1 17/2)
17/22 18/1 18/2 18/4
18/15 21/10 21/12
21/15 21/25 22/7
22/12 22/18 25/22
25/24 27/22 27/23
30/17 30/20 31/17
32/11 32/23 35/24
(35) depending - email
E
email... [38] 36/1
36/1 36/15 42/23
51/21 52/23 53/23
54/9 54/16 55/7 57/2
61/18 61/18 62/5
63/24 64/1 64/3 64/22
71/20 72/13 72/24
77/11 77/12 78/5
80/12 85/10 86/17
86/21 86/23 87/5
87/23 88/2 88/24
99/14 100/7 100/10
100/16 100/17
emailing [1] 54/6
emails [7] 9/4 9/4
16/12 29/20 52/24
77/14 87/17
embarrassing [1]
70/22
embrace [1] 91/15
employ [1] 82/13
employed [1] 15/6
employees [1] 4/19
employment [1]
49/12
enabled [1] 89/15
encouraging [1]
69/17
end [6] 28/16 60/19
62/3 69/20 83/18
89/10
enforcement [2]
104/8 104/11
engage [1] 12/13
engaged [4] 7/21
108/12 112/11 112/20)
engagement [2]
16/23 39/9
England [1] 3/8
English [2] 19/16
80/10
enhanced [1] 98/25
enough [2] 11/3 72/4
enquiries [1] 66/6
enquiry [1] 26/9
ensure [1] 76/20
entire [3] 48/3 49/3
86/5
entirely [3] 52/5
80/11 100/21
entry [1] 14/8
envelope [1] 97/6
episode [1] 4/18
equally [2] 81/13
85/21
error [4] 52/25 53/5
53/11 109/20
errors [4] 54/9 54/13
55/5 111/16
escalation [2] 78/3
82/10
especially [1] 111/16
essential [2] 51/18
91/23
essentially [3] 20/4
49/19 61/20
established [7] 5/20
6/10 79/16 88/9 88/19
97/15 98/22
establishing [2] 5/18
23/9
establishment [4]
5/17 70/16 76/14 80/6
estate [1] 43/6
estimate [1] 12/4
et [3] 4/4 58/21 97/17
et cetera [3] 4/4
58/21 97/17
ete [1] 8/2
ethos [1] 107/16
European [1] 104/13
even [10] 17/4 33/5
63/15 63/15 64/5
73/24 75/14 88/24
89/1 109/14
ever [9] 15/3 15/10
84/1 102/8 108/16
109/22 109/25 110/3
110/5
every [3] 34/21 70/1
96/7
everyone [2] 60/20
114/4
everything [1] 81/8
evidence [31] 1/5 1/9
3/24 8/1 13/12 43/19
50/16 50/25 51/23
51/25 52/20 65/21
73/17 73/20 75/24
85/3 88/1 88/4 92/9
93/17 93/17 98/4
98/11 104/19 106/6
107/2 107/2 110/9
113/21 113/22 113/25)
evidenced [1] 13/23
evident [1] 52/16
evidential [2] 82/12
94/10
exacting [1] 95/5
exactly [2] 21/15
60/1
examination [3]
51/22 71/13 102/19
examine [2] 56/19
90/12
example [11] 4/4
15/9 19/7 22/4 24/17
25/6 44/19 63/12
75/20 80/18 95/2
examples [1] 22/9
excellent [1] 39/25
executive [14] 5/23
6/13 19/7 35/9 35/10
39/1 40/5 52/19 55/8
67/24 85/17 86/15
88/21 89/6
Executives [1] 91/13
exercise [4] 96/24
102/14 106/21 111/21
exercises [1] 76/5
exist [3] 6/11 94/14
99/25
exist’ [1] 13/23
existing [2] 17/16
72/12
expect [1] 67/21
expected [4] 55/4
67/23 100/10 104/5
expecting [1] 37/19
expects [1] 105/21
experience [9] 20/1
39/25 40/7 100/21
100/22 101/1 101/6
101/8 101/10
experience’ [1] 85/24I
experienced [7]
15/15 20/16 39/22
39/23 108/25 109/6
110/1
expert [8] 27/7 50/16
50/20 51/3 51/10
51/23 95/3 95/8
expertise [3] 24/15
25/5 109/16
experts [4] 51/8
51/14 95/17 111/20
explain [5] 41/7
55/14 55/18 62/13
86/22
explained [5] 32/24
72/21 87/8 87/8 106/8
explaining [3] 63/6
63/20 87/24
explains [1] 62/12
express [2] 109/18
109/21
expressed [6] 9/9
33/21 37/15 75/15
84/1 84/2
expressing [1] 73/5
expression [1] 18/11
expressly [1] 14/2
extensive [2] 40/7
72/16
extent [6] 17/24
29/12 41/14 54/25
75/8 110/23
external [12] 30/7
58/2 81/16 81/19 82/5
83/13 83/15 83/19
91/3 97/10 105/25
111/19
extra [1] 44/1
extracts [1] 13/14
extremely [4] 66/23
67/10 78/19 108/25
F
face [1] 103/22
facilitate [2] 70/6
113/24
fact [28] 2/8 15/23
19/12 19/25 20/19
28/12 35/1 57/20
61/25 62/24 63/11
64/8 65/6 66/24 79/18
81/14 82/8 82/11
87/19 89/5 90/1 90/3
95/13 96/17 102/7
108/18 108/24 111/3
factor [1] 46/20
factors [1] 8/24
factually [1] 87/24
failed [1] 64/19
failings [2] 112/2
112/23
failure [1] 70/12
fair [9] 29/9 30/2 46/6
68/19 80/11 89/4
91/10 96/11 97/2
fairly [1] 25/4
faith [1] 95/25
fake [1] 13/22
fall [1] 10/16
false [2] 65/14 86/24
familiar [4] 12/22
24/16 85/13 85/18
far [5] 60/3 70/23
90/17 94/18 96/20
Farm [1] 28/3
fast [1] 49/16
FCA [1] 5/21
features [1] 13/12
February [2] 102/5
102/17
FED [1] 85/21
fee [2] 78/13 78/14
feed [1] 75/8
feedback [3] 43/11
82/1 82/4
feel [4] 39/13 48/16
55/24 75/3
feeling [1] 37/23
fees [3] 77/20 77/25
78/6
felt [5] 9/24 25/12
38/19 81/5 81/14
few [3] 13/1 36/6
56/10
fifth [2] 95/3 113/8
figure [2] 28/13
104/14
figures [1] 64/9
file [1] 54/5
filed [1] 20/11
final [4] 65/17 65/18
95/23 102/2
finally [1] 113/25
Finance [1] 89/6
financial [7] 3/11
4/17 5/16 6/3 17/4
40/4 97/6
find [2] 41/3 103/18
findings [1] 56/21
fine [1] 7/19
finish [1] 113/5
firm [9] 9/24 12/12
31/10 35/22 82/20
412/11 112/12 112/16
112/19
firms [2] 3/8 37/9
first [26] 2/5 2/16 4/2
5/8 5/20 7/11 13/15
17/12 29/11 30/22
32/11 40/8 40/12
41/21 56/10 59/17
62/16 88/6 92/6 99/13}
103/25 104/15 104/17
111/10 113/7 113/17
firstly [2] 7/18 79/7
fit [2] 31/1 105/21
five [2] 95/8 95/17
flagged [2] 102/10
104/21
flagging [1] 105/4
flags [1] 43/16
floor [1] 23/21
Foat [37] 1/13 1/15
1/19 1/23 1/24 3/3
40/21 50/3 85/22
86/13 88/3 92/9 96/20
98/3 99/2 99/8 99/12
99/16 102/2 102/24
103/10 103/13 103/21
104/12 106/3 107/2
107/15 108/22 110/14}
110/16 110/21 110/22)
111/3 111/8 113/10
113/17 115/2
focus [16] 3/23 6/2
6/12 6/14 6/15 11/16
17/18 27/12 56/2
56/11 56/24 72/1 72/9I
72/11 75/13 75/20
focused [3] 5/15
17/10 98/10
focusing [3] 22/3
43/6 76/8
FOI [1] 67/12
follow [3] 46/13 88/6
102/19
follow-up [1] 88/6
following [5] 10/3
59/12 59/16 66/5
72/23
follows [4] 7/13
42/24 55/9 77/20
foot [1] 51/11
Forget [1] 96/11
forgive [3] 18/19
21/20 102/15
forgot [1] 113/8
form [2] 83/1 93/15
formal [2] 7/21 76/9
former [4] 7/19 16/20
26/1 37/5
forms [4] 79/25
92/10 93/11 93/12
(36) email... - forms
F
fortnight's [1] 114/7
forward [8] 10/5
46/25 51/11 57/3 59/8)
73/14 81/2 88/11
forwarded [4] 22/18
28/21 33/11 64/3
found [3] 15/21 15/23)
30/18
fourth [6] 2/12 2/20
36/17 38/22 111/12
113/8
framework [3] 5/17
6/25 31/12
franchising [1] 49/11
frank [1] 84/23
frankly [4] 6/17 70/21
71/24 109/1
Fraser [3] 41/22
56/21 75/21
Fraser's [1] 42/2
fraud [1] 78/9
Freedom [5] 31/16
32/7 66/1 66/4 66/6
Freehills [4] 66/9
71/18 80/3 92/23
Freeths [6] 20/11
43/17 44/1 59/9 59/14
59/18
Friday [1] 1/1
front [1] 91/19
frozen [2] 95/9 95/10
frustration [1] 73/5
FUJ00243199 [1]
103/20
Fujitsu [7] 43/6
103/22 104/13 105/5
105/10 105/12 105/18
Fujitsu's [2] 50/14
104/14
fulfil [4] 97/4
full [4] 1/21 1/23
96/11 97/2
fully [1] 90/14
function [4] 46/10
81/16 83/21 90/10
functions [1] 13/12
funders [1] 61/6
funding [3] 61/13
89/8 89/15
funds [1] 96/18
further [13] 10/6
33/11 50/12 54/8
54/11 80/16 85/8
85/14 93/23 94/1
106/4 110/20 115/12
G
gather [1] 7/20
gave [2] 110/9 111/3
GDPR [1] 66/2
general [39] 3/16
3/19 6/1 18/4 20/4
27/2 27/6 34/12 34/18
35/13 39/7 39/10
39/19 40/8 44/23
45/16 46/5 47/8 47/15
47/19 47/21 47/24
48/2 48/16 49/1 51/16
57/20 57/25 62/15
65/13 73/3 73/22
76/11 91/8 91/10
95/16 97/16 104/21
105/4
generalised [2] 65/2
65/3
generally [7] 19/4
22/14 22/16 33/6
68/20 78/8 97/20
generated [1] 14/8
genuine [2] 16/8
75/22
get [12] 8/5 11/4
11/21 15/9 24/2 24/2
28/22 48/11 48/12
75/23 81/7 81/9
getting [2] 58/5 75/2
give [6] 3/24 20/19
24/6 38/9 104/19
113/21
given [33] 5/3 11/16
17/9 20/13 20/14
24/14 28/7 35/3 41/12
42/12 44/5 45/11
46/15 48/17 49/19
52/9 52/11 56/2 60/7
60/25 65/21 69/12
69/13 77/24 81/3
86/17 87/1 89/2 98/10
102/21 106/16 106/23
107/5
gives [1] 72/4
giving [6] 1/8 12/3
43/19 53/24 106/18
113/22
GLE [1] 76/15
GLO [14] 8/2 10/20
10/24 11/8 12/7 30/2
56/1 66/1 74/13 76/15
80/21 82/2 98/7
101/14
GLO/Freedom [1]
66/1
go [19] 1/18 2/2 4/8
12/16 30/23 33/10
35/23 38/11 45/8 49/5
60/3 61/5 83/4 83/5
94/3 99/17 99/18
104/2 107/10
go-to [1] 12/16
goes [6] 13/10 31/14
50/9 94/2 96/1 104/9
going [30] 1/13 2/1
7/6 16/12 18/20 21/10)
25/20 33/21 34/3
34/24 36/8 36/18
48/18 49/20 59/3
61/11 69/14 71/2
71/23 81/2 85/7 92/2
92/18 94/10 95/20
103/16 103/23 107/4
107/9 108/21
gone [2] 29/8 73/1
good [12] 1/3 1/4
1/17 8/1 23/25 39/20
42/13 49/19 91/23
95/25 103/13 111/8
got [3] 36/13 55/13
70/5
governance [2] 8/15
83/5
governed [1] 13/19
Government [14]
33/8 33/10 37/6 45/13
46/9 83/6 84/7 84/9
84/20 85/2 85/3 96/9
97/6 97/13
Grabiner [2] 34/4
42/9
grant [1] 41/22
grass [1] 87/16
grateful [5] 99/7
113/19 113/22 113/25)
114/4
great [1] 38/3
Greater [1] 93/16
grip [1] 68/12
grips [2] 58/5 70/5
group [44] 4/4 5/24
9/16 9/18 9/19 10/25
11/14 15/8 17/2 20/3
20/18 23/7 23/9 23/18
23/23 24/8 26/18
26/20 27/5 27/11
27/15 28/17 29/2 29/3
29/12 30/6 31/3 33/21
34/15 34/19 35/5 35/8
38/16 39/1 47/20 49/8
49/25 59/8 61/15
66/13 66/25 67/24
68/11 73/2
groups [1] 10/23
Grove [2] 27/24 28/3
guess [2] 65/10 73/4
guidance [3] 7/14
19/1 92/21
guilty [4] 85/23 86/3
86/8 86/11
H
had [160]
hadn't [6] 58/11
61/21 65/5 66/20
66/22 69/10
half [4] 4/5 64/2 87/4
103/25
Halfway [1] 8/9
halves [1] 4/2
Hamilton [1] 86/7
hand [1] 81/10
handed [5] 38/2
43/23 74/1 89/17
112/4
handing [1] 64/18
handle [1] 67/17
handled [1] 38/1
handling [1] 101/7
happen [7] 7/17 8/5
44/4 46/2 74/11 94/12
114/5
happened [7] 9/7
55/14 55/21 56/16
58/14 74/11 93/4
happening [2] 26/20
55/22
happy [4] 17/22
36/10 36/20 43/10
hard [3] 38/18 73/15
105/1
harder [1] 48/15
has [45] 2/7 2/13 7/3
16/1 16/7 19/23 20/10}
26/10 32/9 35/13
45/14 48/25 49/22
50/16 53/25 54/4
55/18 55/21 59/11
60/2 62/20 70/9 70/14
70/16 70/25 75/19
76/5 76/6 77/11 79/25)
80/24 82/23 83/2
83/20 89/17 89/21
92/15 95/2 104/6
104/23 110/11 110/12}
112/20 112/25 114/4
hasn't [1] 62/13
haste [1] 1/5
hats [1] 57/22
have [148]
haven't [4] 56/4
75/24 106/23 107/19
having [13] 17/7
33/19 39/25 42/22
42/22 54/19 75/4
78/23 79/9 91/2 91/15)
91/18 95/8
he [83] 7/12 9/7 9/9
9/11 9/13 9/13 11/14
11/18 12/7 12/13
12/14 12/16 15/15
15/16 15/17 15/18
15/19 16/9 21/24
22/19 23/19 25/9
25/11 25/12 25/22
26/11 30/25 31/7
31/10 31/11 32/5
37/20 37/21 39/18
39/18 41/2 43/2 43/14,
45/22 50/3 51/24
52/24 53/1 53/14
53/18 54/5 55/8 57/6
57/15 57/16 59/5
59/13 61/19 62/5 62/7,
62/7 62/12 67/21
71/17 71/20 73/9
77/14 77/20 78/13
78/13 78/18 81/15
85/17 85/22 100/6
101/7 101/8 101/9
101/9 106/7 108/16
108/20 109/1 109/4
109/22 110/7 110/8
110/9
he's [6] 16/9 18/11
23/5 45/24 108/13
108/13
head [10] 3/10 5/16
6/3 9/17 11/18 17/4
29/6 61/14 69/20
101/18
headed [1] 23/4
heads [4] 11/13
11/24 38/9 97/15
health [1] 3/21
hear [12] 1/13 26/1
48/11 48/12 71/11
71/21 92/5 95/11
95/12 95/12 95/13
103/13
heard [10] 4/24 25/12
63/1 64/5 69/14 75/25]
80/24 90/4 106/4
1412/7
hearing [4] 1/6 111/4
114/5 114/14
hearings [1] 102/4
heavily [2] 12/7
81/15
held [2] 55/15 68/7
HELM [1] 86/13
help [4] 6/23 6/23
10/13 27/15
helped [1] 109/12
helpful [5] 44/9 49/4
94/8 94/11 94/15
helps [1] 62/13
Henry [4] 86/20 92/5
92/8 115/6
her [16] 27/2 33/8
34/22 35/1 35/15
35/25 36/1 36/2 36/18
38/11 38/12 38/13
38/14 95/4 105/22
111/11
Herbert [18] 36/22
36/25 37/1 37/9 37/10}
37/19 37/21 38/23
39/5 39/6 58/7 66/9
71/18 72/6 74/17 80/3
82/20 92/23
Herbert Smith [2]
39/6 72/6
herd [1] 62/7
here [11] 15/19 18/12
45/22 52/4 61/24
65/10 78/12 86/14
87/5 100/22 107/9
herself [2] 35/25
36/15
Hi [2] 77/15 80/15
(87) fortnight’s - Hi
H
high [4] 16/21 28/18
33/23 100/19
higher [1] 35/15
highlight [1] 13/4
highlighted [2] 20/10
20/25
highlights [2] 21/24
21/25
him [23] 1/11 9/15
10/6 10/17 11/17
15/21 16/8 23/22
23/22 25/12 31/4
31/19 31/20 53/15
53/19 53/24 53/25
54/5 62/25 73/18
73/21 109/25 110/22
himself [2] 85/16
108/15
hindsight [2] 80/9
92/14
his [26] 9/11 10/19
12/10 14/1 15/17
15/22 15/23 16/10
23/13 26/11 46/1
51/23 56/21 57/6
57/14 59/22 69/20
84/17 100/1 101/5
106/6 107/1 107/2
109/19 109/21 111/3
historic [8] 46/10
66/4 67/11 72/12
73/19 77/17 94/17
411/17
historical [2] 70/12
80/19
historically [3] 45/14
92/25 93/5
history [6] 54/20 81/1
91/11 106/16 107/14
110/4
HMU [1] 75/10
HNG [1] 79/21
HNG-X [1] 79/21
hold [2] 23/10 28/3
holistically [2] 10/18
60/19
hope [2] 28/2 62/13
Hopefully [1] 72/3
Horizon [43] 4/11
4/13 7/16 7/25 14/6
14/7 16/22 34/21 43/6)
43/10 43/16 43/21
43/23 43/25 44/4 49/8)
49/17 49/20 50/13
50/18 50/19 51/15
51/17 51/17 52/2
52/12 54/13 54/25
56/18 73/25 76/12
76/25 79/20 79/21
79/22 86/6 101/22
104/5 104/10 105/13
111/16 111/24 112/3
Houghton [2] 21/17
21/19
hour [1] 4/7
how [17] 4/8 4/15 6/7
11/20 14/9 28/25
41/13 41/25 47/16
60/2 60/15 61/8 63/4
66/16 75/19 90/14
91/9
however [7] 10/19
11/14 28/4 44/5 49/15
55/17 77/22
HR [3] 89/17 89/22
89/24
HSF [11] 38/13 39/8
39/11 42/11 58/18
59/17 61/9 80/5 81/16)
82/23 102/10
HSS [5] 79/7 79/7
79/24 82/18 92/10
huge [1] 81/9
hurdle [1] 79/23
l absolutely [1] 30/12
l accept [4] 24/24
24/24 40/8 80/8
I acknowledge [1]
16/10
I acknowledged [1]
92/13
I actually [3] 30/13
33/22 69/21
Lalso [3] 53/24 69/25
87/8
lam [20] 28/4 28/12
41/12 46/11 55/20
56/4 56/5 59/25 73/3
73/4 73/23 80/6 80/17
80/18 86/9 87/5 105/8
113/19 113/19 113/21
l apologise [2] 70/19
99/7
l appreciate [2] 44/5
96/21
Task [1] 111/9
lasked [7] 37/17
37/19 37/20 38/23
48/24 74/16 96/13
lassume [1] 49/23
lattend [1] 35/11
I became [4] 39/7
47/19 69/3 98/21
I believe [3] 76/1
78/20 89/18
lean [7] 95/12 95/13
95/21 101/10 103/15
107/25 112/15
I can't [3] 91/3
106/24 112/12
I categorically [1]
73/20
I comment [1] 107/7
I could [5] 20/5 21/8
22/9 84/2 95/7
I couldn't [1] 73/23
I devoted [1] 70/5
I did [10] 24/13 27/14
29/23 29/24 30/6 30/9
73/20 75/9 87/2 92/13,
I didn't [12] 9/24
15/22 17/10 24/6
30/11 34/3 34/17 35/8
35/9 64/25 75/3 106/1
I directed [1] 88/25
I dispute [1] 28/11
Ido [7] 49/4 62/2
82/15 89/4 89/25 97/3,
112/11
I don't [33] 4/25 5/23
18/2 18/19 19/3 20/2
22/9 27/3 29/14 31/9
47/12 48/22 53/2
54/14 55/4 61/1 69/6
71/24 73/22 81/24
89/20 89/25 94/3
95/18 97/18 99/17
101/18 104/21 105/3
105/7 107/17 111/13
112/18
l established [1]
98/22
l explained [1] 87/8
l expressed [2] 33/21
37/15
I felt [2] 9/24 81/14
I forgot [1] 113/8
I found [2] 15/21
15/23
I frozen [1] 95/10
I gather [1] 7/20
I got [1] 36/13
I guess [2] 65/10
73/4
Ihad [12] 6/8 11/5
11/6 15/15 23/24
24/22 26/21 69/1
90/23 90/24 91/4
105/22
Ihave [18] 8/4 24/3
28/2 28/7 28/9 28/16
29/25 39/24 55/10
64/5 86/3 86/4 88/1
96/8 103/16 104/23
105/7 113/24
I haven't [4] 56/4
75/24 106/23 107/19
I heard [1] 4/24
I hope [1] 62/13
l imagine [1] 93/14
l inadvertently [1]
1/7
linherited [1] 57/23
I just [2] 75/2 82/17
I knew [2] 39/17
39/24
I know [2] 16/6 31/12
I made [3] 33/22
74/25 75/12
I make [1] 42/17
I managed [1] 10/18
I may [1] 30/4
I mean [12] 15/7 18/1
18/3 19/4 25/8 26/21
45/20 66/25 93/4 95/1
100/11 108/23
I need [3] 8/6 69/6
94/3
I needed [1] 31/4
I never [1] 25/11
I noted [1] 88/1
I obviously [3] 11/2
39/16 70/10
I offered [2] 27/14
35/18
lonly [1] 41/18
lowe [1] 28/11
I particularly [1] 81/5
I pass [1] 91/6
I personally [2] 22/24)
69/24
I presume [1] 36/23
I probably [1] 52/5
I put [1] 88/11
I raised [3] 74/20
74/25 75/1
lread [2] 113/6 113/7,
I really [2] 20/17 21/8
I recall [5] 5/14 15/16
35/19 38/11 105/3
l received [2] 17/6
86/18
Iremain [1] 62/19
I remember [6] 33/18)
33/19 34/2 52/8 57/9
61/13
I remembered [2] 5/4I
113/5
l repeatedly [1] 69/4
I reported [2] 34/14
57/21
I returned [1] 104/20
Iright [1] 92/12
I said [11] 23/18 25/8
38/25 58/18 74/3 74/4,
74/5 74/21 81/25
86/21 110/6
I sat [2] 5/22 9/6
I say [1] 7/10
I should [1] 108/18
I simply [2] 21/8
45/20
I sought [1] 58/2
I specifically [1] 58/7
I still [1] 28/3
I suggest [1] 53/23
I supported [1] 89/7
I suspect [1] 5/2
I take [3] 98/3 101/24
103/17
I think [132]
I thought [2] 33/23
52/5
I told [2] 73/21 87/17
I treated [2] 57/9
57/10
I understand [16]
12/12 12/14 16/1 18/3)
25/9 25/10 37/4 44/13}
66/19 83/14 92/9 93/3
94/8 94/23 98/23
110/9
l understood [6]
41/24 54/20 63/10
100/5 105/25 112/18
lused [1] 24/2
I walked [1] 70/1
I want [2] 7/20 61/15
I wanted [1] 86/22
Iwas [50] 3/15 3/23
4/16 5/14 6/8 9/24
41/17 11/24 12/8 15/5}
17/3 17/5 20/2 20/18
20/25 22/6 24/5 26/17)
29/14 29/18 29/22
29/25 30/6 30/7 33/18}
34/2 45/16 57/20
57/22 57/23 57/24
58/16 64/16 65/4
65/10 66/23 70/3
74/13 76/11 86/24
87/2 87/18 88/22
92/20 101/7 101/8
104/18 104/19 107/1
108/21
I wasn't [13] 11/5
12/14 17/9 22/23 34/5}
34/5 35/7 48/24 54/21
68/23 74/16 104/18
106/25
I went [3] 38/12
86/21 87/23
I will [2] 43/8 53/15
I won't [1] 61/17
I worked [1] 91/18
I would [22] 17/3
18/1 39/11 39/16
43/20 45/18 47/17
47/19 56/3 57/10
61/10 73/21 74/22
75/22 83/4 83/11
87/17 89/13 95/17
102/21 107/7 114/3
I wouldn't [3] 25/15
25/16 52/9
I'd [16] 1/10 12/19
13/1 17/18 30/16
38/21 40/5 44/23
45/25 50/10 59/1
65/25 68/1 77/8 85/10}
87/4
Ni [7] 2/2 13/4 21/14
28/24 36/6 104/2
110/15
I'm [51] 2/1 7/6 10/23
10/23 10/24 11/4
(G8) high -'m
I'm... [45] 16/12
19/19 21/10 22/23
25/14 25/19 36/12
36/18 44/18 45/17
47/5 48/6 48/9 52/5
53/22 54/15 60/10
64/14 64/15 64/22
65/12 65/13 73/5
82/17 82/25 83/16
85/7 85/11 85/12
92/13 92/15 92/18
95/7 99/7 103/16
103/23 106/1 106/15
106/23 108/17 110/11
110/21 113/1 113/25
114/3
I've [4] 17/9 40/7
104/22 109/13
I, [1] 35/6
I, from [1] 35/6
idea [1] 14/9
ideal [1] 44/3
Ideally [1] 49/14
identification [1]
68/9
identified [8] 7/16
14/11 16/1 58/12 60/9)
66/8 66/16 92/16
identifies [3] 13/6
14/19 51/23
identify [2] 13/16
112/23
ie [2] 26/11 76/18
ie he [1] 26/11
ie the [1] 76/18
if [113] 7/10 8/6 8/8
10/4 11/7 11/19 16/19
17/21 20/6 21/3 21/14}
21/16 21/20 22/11
23/1 23/5 25/18 25/20
26/3 27/21 27/22 28/1
28/20 28/23 30/5
30/18 30/19 30/25
31/17 32/4 32/22 33/9
36/13 37/19 38/8
38/14 38/17 39/15
40/21 40/24 41/1
41/19 42/5 42/21 43/9)
43/15 43/24 44/25
45/4 45/9 45/23 46/2
47/4 47/6 47/10 47/14
49/5 51/3 52/14 52/21
52/22 52/25 53/8 53/9)
53/13 53/16 53/20
54/2 57/11 59/4 59/16
60/10 61/16 62/16
62/16 63/21 63/22
63/22 65/25 67/8
67/13 68/3 71/16 73/7
75/15 77/10 77/19
78/16 79/5 80/12
81/21 83/7 83/13 84/2
84/13 85/14 85/19
85/23 89/1 94/11
94/14 94/23 95/21
97/23 99/17 101/10
101/24 104/22 105/7
105/8 109/14 110/12
110/12
illustrates [1] 9/12
imagine [2] 20/5
93/14
immediate [2] 31/13
37/17
immediately [3]
111/25 112/3 112/4
imminent [1] 20/14
impact [1] 52/7
impacted [2] 21/6
75/20
implication [1] 14/2
implications [4]
55/25 76/17 76/24
112/5
implicit [1] 46/1
important [8] 35/17
50/17 53/3 67/1 79/10)
79/12 81/11 105/15
importantly [2] 11/16
42/10
impression [1] 65/14
improved [2] 66/12
91/9
improvements [2]
72/21 90/11
improving [1] 6/15
inadvertently [1] 1/7
incident [1] 67/21
include [7] 6/24 6/25
7/1 19/13 46/24 60/21
97/16
included [7] 20/25
74/16 74/17 76/24
79/10 88/17 106/7
includes [1] 99/24
including [12] 8/21
10/8 27/25 54/5 59/23
60/20 68/8 77/3 84/21
84/22 90/9 108/11
incorporated [1]
76/21
incorrect [1] 87/9
increased [1] 9/1
increases [1] 90/13
increasingly [3]
74/10 74/14 74/18
incredible [1] 92/25
incredibly [1] 16/4
indeed [19] 11/6
14/24 17/6 30/13 40/4
45/25 65/5 73/22
75/14 76/7 81/16
81/19 83/4 87/21
97/13 98/19 108/12
109/3 109/16
independent [8]
34/16 37/14 43/4
78/15 82/6 109/7
109/15 109/16
indexed [1] 66/20
indexing [1] 66/21
indicate [1] 13/10
individual [9] 5/1
62/11 89/20 89/25
96/22 97/8 97/8 97/21
107/12
individually [1] 2/2
individuals [3] 25/22
100/24 111/15
indulge [1] 95/25
industry [1] 48/6
inexplicable [1] 14/8
influence [1] 50/13
informal [1] 18/10
information [36]
14/12 16/5 18/13
20/23 21/7 21/19
21/23 22/21 30/11
31/12 31/16 32/7
32/21 33/2 33/7 33/10
35/3 48/17 48/20 53/4
53/15 59/10 62/25
63/25 64/11 65/7 66/2
66/5 66/6 72/17
106/18 106/20 107/10
107/12 107/21 109/2
informed [8] 14/18
20/11 23/16 33/20
34/9 36/10 36/20 43/8)
inherently [1] 24/12
inherited [1] 57/23
inhouse [5] 25/4 31/7]
40/3 83/3 83/12
initially [1] 84/4
initiated [2] 13/17
13/18
innocent [4] 85/24
86/4 86/7 86/11
Inquiry [31] 2/1 3/23
12/22 19/24 65/22
70/23 73/17 74/14
75/10 77/11 80/21
80/24 83/23 86/25
87/1 87/2 87/5 87/7
87/22 88/10 88/11
88/13 88/13 90/18
90/22 92/15 95/21
100/1 107/23 108/11
110/9
Inquiry's [2] 3/4 80/7
instance [8] 10/22
11/19 11/25 19/12
41/21 46/24 48/13
86/24
instances [1] 94/4
institution [1] 40/4
instruct [4] 29/23
35/8 38/23 39/5
instructed [2] 14/22
37/20
instructing [2] 10/24
30/7
instruction [1] 98/10
instructions [2]
17/12 72/6
insurance [2] 5/18
5/21
integrity [1] 16/9
intended [2] 73/1
81/24
intention [1] 65/16
intentionally [2]
44/16 65/1
intentioned [2] 81/25
82/14
interact [1] 24/19
interactions [1] 19/7
interest [1] 21/4
interested [1] 12/9
interfered [1] 14/5
interim [9] 2/15 37/8
54/18 55/7 56/17
57/21 96/8 104/20
105/4
intermediary [2] 5/18
5/21
internal [1] 83/17
internally [2] 18/25
27/7
interrupt [1] 36/12
into [33] 9/4 13/22
14/23 22/14 23/22
25/19 29/25 30/4
30/19 32/23 38/12
42/6 47/3 52/22 53/6
54/12 55/5 58/9 58/19)
58/21 61/11 67/9
73/21 74/2 75/8 79/1
84/14 87/16 90/20
95/22 96/1 99/17
105/24
introduced [2] 50/3
53/6
introduction [1]
49/15
investigate [1]
107/11
investigation [4]
12/25 87/18 90/20
106/22
investigations [6]
10/14 90/15 90/16
106/6 106/11 107/4
investigators [2]
87/10 87/13
invitation [1] 48/1
invited [1] 92/19
involved [45] 5/25
10/23 10/23 10/24
11/6 11/7 12/7 12/14
20/2 20/18 24/5 24/20)
26/18 27/20 29/1
29/12 29/16 29/18
29/20 29/22 30/1 30/6
30/7 31/7 33/17 34/5
34/6 34/9 34/10 35/7
37/1 37/21 41/14
54/15 54/21 55/14
64/6 68/11 81/2 87/4
87/18 104/19 105/25
108/25 109/15
involvement [6] 15/8
24/13 30/3 80/20
108/10 110/7
involving [1] 100/23
Irrespective [4] 35/1
46/4 46/15 58/3
is [266]
Isabel [1] 43/8
isn't [3] 42/4 79/5
92/3
issue [40] 9/25 10/22
14/12 15/1 17/25 18/8)
50/22 55/11 58/19
58/20 58/20 66/11
66/21 67/7 68/24
73/18 73/19 74/1 75/8
75/9 78/8 80/8 84/7
86/16 86/20 90/12
90/12 90/24 90/24
91/4 92/21 96/6 98/20
102/22 104/21 105/5
105/10 105/15 105/23)
110/10
issued [3] 4/19 16/21
18/25
issues [52] 4/3 4/11
6/13 15/22 16/11
20/13 25/14 27/11
29/4 29/10 30/14
30/16 33/3 34/20
34/22 38/2 39/2 42/17
51/1 56/17 56/18
57/16 62/6 63/9 63/16)
64/18 70/22 71/2
73/25 76/12 76/18
76/20 76/22 76/25
79/20 81/9 86/6 86/6
87/15 88/12 92/15
93/5 93/11 97/5
101/22 108/10 108/12)
109/2 109/21 111/24
112/3 112/13
it [304]
it's [79] 3/25 7/9 7/11
9/14 9/21 12/20 12/23}
17/18 18/5 18/10
18/14 19/17 20/6
21/12 21/14 21/17
27/23 28/20 29/7
30/11 30/20 32/3
33/10 33/24 34/12
34/17 35/17 35/23
35/24 35/24 36/2
36/15 38/18 38/21
38/22 40/1 43/1 43/13)
44/23 45/6 45/25
46/12 47/8 47/25
(39) I'm... - it's
I
it's... [35] 50/10
51/21 51/21 52/23
55/7 58/7 58/25 61/18
63/23 63/23 65/24
69/8 69/16 73/8 7/11
77/12 80/12 80/23
83/8 85/16 89/16
91/10 91/21 91/21
94/8 94/12 94/14
94/22 94/22 99/6
105/21 105/23 106/17;
107/18 110/14
item [1] 50/2
items [2] 48/4 48/12
its [15] 18/7 25/1
35/14 46/9 46/10
68/12 69/4 70/7 70/24
89/16 95/6 104/6
4112/2 112/2 112/22
itself [7] 29/3 52/7
52/16 82/5 83/14
107/15 109/10
J
juncture [1] 17/11
June [10] 2/7 7/10
9/3 43/7 43/17 51/21
52/22 54/7 59/3 63/19)
June 2017 [1] 9/3
junior [2] 31/18
102/13
just [50] 2/2 6/22
11/7 13/1 18/14 22/10
25/20 26/5 35/19
35/23 36/6 37/14
38/15 38/21 38/21
43/19 44/22 44/24
45/6 45/19 48/14
55/16 56/25 59/1 65/4)
66/24 75/2 75/11 79/7
79/17 80/16 82/17
82/22 86/1 88/13
90/14 92/4 95/16
98/16 99/2 100/21
101/8 102/2 104/2
104/12 108/2 110/8
110/15 112/7 113/10
justice [5] 41/22 42/2
56/20 75/21 112/1
Jane [22] 3/16 6/9
8/8 8/14 9/15 9/17
9/22 10/1 10/22 12/15)
19/23 20/19 23/20
24/3 25/9 28/21 30/20
31/2 33/4 33/19 33/19)
34/14
Jane's [2] 32/15
57/23
Janet [1] 95/1
January [2] 2/20
85/18
JB [1] 88/22
Jeff [2] 21/17 21/22
job [1] 35/1
John [1] 106/6
Johnson [2] 109/6
109/11
join [1] 16/25
joined [2] 3/10 5/8
joining [5] 3/7 4/16
17/5 44/23 44/23
Jones [1] 72/18
journalist [1] 66/7
journalists [1] 53/22
judge [2] 44/2 112/9
judgment [29] 7/21
30/16 30/24 33/16
38/2 38/7 42/17 43/23}
43/25 44/5 50/24
56/17 56/18 63/9
64/18 73/25 76/12
76/18 76/20 76/22
76/25 79/20 86/6 86/6
93/6 93/11 101/22
111/25 112/3
Julie [1] 72/19
July [2] 74/21 87/3
K
Karen [1] 89/22
KC [1] 108/7
keen [1] 11/17
keep [6] 11/7 30/14
43/8 53/9 53/16 54/2
keeping [1] 106/20
kept [3] 23/16 24/10
54/4
key [1] 73/3
Kim [4] 55/13 55/18
55/20 56/8
kind [2] 45/11 46/8
kinds [2] 23/16 26/25
King [7] 12/13 12/23
13/24 24/19 25/10
29/23 100/3
King's [1] 35/20
knew [4] 5/6 39/17
39/24 100/2
know [28] 8/3 11/3
12/24 16/3 16/6 19/17
21/18 25/24 31/12
33/12 37/2 41/18
48/13 53/2 65/14 73/3
85/11 86/8 89/22
95/18 97/16 101/5
104/22 105/7 105/19
108/6 108/9 112/18
knowledge [12] 2/4
2/25 4/11 14/25 15/10
19/5 46/4 102/7
102/18 108/16 109/18)
113/12
known [2] 13/19
52/10
L
labour [3] 6/12 6/19
27/13
lack [5] 54/24 63/25
64/11 67/19 88/21
land [1] 43/18
landed [1] 76/13
landing [1] 43/17
language [1] 65/11
large [1] 1/25
last [8] 2/9 4/7 8/19
34/24 54/1 59/12
102/16 108/1
later [5] 13/14 20/21
59/15 69/11 98/21
law [16] 19/16 24/15
25/11 25/14 31/9
35/21 37/9 40/2 91/23
101/10 111/20 112/11
112/12 112/15 112/19}
112/19
lawyer [15] 15/16
15/21 16/3 19/13 20/8}
24/21 25/1 25/4 31/6
40/3 47/1 86/8 101/9
105/25 109/1
lawyer's [1] 31/24
lawyers [21] 6/15
18/23 27/19 30/7
33/12 45/2 64/23
65/14 72/25 81/16
81/19 83/2 83/8 83/12
83/13 83/15 83/17
83/19 88/14 89/1
102/3
lay [4] 8/6
lead [4] 16/6 80/19
108/3 108/5
lead-up [2] 108/3
108/5
leading [3] 91/18
106/13 108/7
leads [2] 43/12 80/17
learning [2] 62/23
91/16
least [3] 52/3 66/21
108/11
leave [6] 3/21 50/6
62/18 65/14 104/18
104/25
led [1] 107/3
left [3] 8/22 28/2
75/11
Legacy [1] 79/22
legal [95] 3/11 3/13
3/15 5/12 5/16 6/3 6/7
6/8 6/14 6/16 6/17
6/20 6/21 6/22 6/23
7/1 7/2 7/5 8/14 8/21
9/17 11/13 11/16
11/18 11/22 11/24
12/5 15/17 17/4 18/5
18/16 18/20 18/22
18/25 19/1 19/5 19/10)
19/15 19/18 19/21
20/17 22/2 22/21
23/25 24/23 25/4
27/10 29/6 31/8 31/25
33/25 34/7 34/8 34/10)
34/13 34/23 35/14
38/6 38/6 39/16 42/12
42/18 45/7 45/20
45/21 46/12 46/13
46/20 47/1 58/2 61/4
63/7 65/9 66/9 67/1
70/11 70/13 78/1
78/11 79/12 79/14
82/3 88/4 88/25 91/20
97/19 98/18 98/18
98/21 100/12 105/3
105/24 107/17 108/17}
112/4
let [3] 25/24 92/20
106/3
let's [2] 41/13 46/16
letter [11] 23/3 23/6
26/4 39/9 59/17
103/21 103/24 104/15)
104/22 104/25 105/8
letters [1] 54/5
level [5] 19/8 21/6
48/18 48/20 69/2
levels [2] 37/24
91/22
liaise [2] 39/11 91/14
liaising [2] 111/19
112/25
liaison [1] 39/6
licence [1] 91/20
lifelong [1] 91/16
lift [1] 90/10
light [7] 22/21 22/22
44/16 46/9 46/10
104/6 111/24
like [28] 1/10 4/13
5/5 12/19 13/1 17/18
30/16 38/21 39/19
42/16 50/10 55/24
59/1 62/25 63/21
65/25 68/1 76/3 77/8
80/25 81/12 82/3
85/10 90/9 95/22
107/14 109/2 114/3
likely [3] 9/1 50/20
53/21
limit [1] 10/9
limited [4] 16/22 19/6
26/21 100/18
line [6] 10/16 23/13
52/14 53/21 60/7
101/5
linked [3] 24/12 66/4
67/11
list [2] 16/17 16/24
litigation [80] 4/4
5/24 9/16 9/19 11/1
11/14 15/8 15/16
15/20 17/2 19/18 20/3}
20/13 20/18 21/1
22/22 23/19 23/23
24/8 26/18 26/21 27/5I
27/11 27/15 28/17
29/2 29/3 29/13 31/3
31/5 31/6 31/8 32/2
32/2 32/17 33/21
34/10 34/16 34/19
35/5 36/11 36/21
37/25 38/16 44/3 44/6I
44/21 45/23 46/13
47/20 49/8 50/1 57/1
59/8 61/6 61/12 61/16I
61/21 62/14 63/4
63/13 63/18 63/21
66/25 68/11 73/2
81/17 82/13 94/10
94/20 94/23 94/25
98/14 99/23 100/14
100/19 100/20 100/23)
100/25 101/2
little [9] 5/6 30/15
48/15 52/8 55/11
57/17 58/14 88/20
106/3
live [2] 17/24 43/21
long [4] 54/20 87/16
103/16 108/10
long-term [1] 108/10
longer [1] 73/1
longstanding [1]
81/6
look [17] 22/8 30/16
34/24 41/19 55/5
58/19 59/1 63/20
65/19 65/25 73/8
73/14 95/22 99/2
105/14 107/20 109/25)
looked [8] 21/15
50/25 56/3 58/9 58/21
74/2 90/25 105/24
looking [10] 11/19
15/13 45/22 46/6 46/7I
54/8 54/12 63/17 69/9)
7712
Lord [8] 34/4 34/4
41/21 42/2 42/9 42/9
56/20 75/21
Lord Grabiner [2]
34/4 42/9
Lord Justice Fraser
[1] 75/21
Lord Justice Fraser'sI
[1] 42/2
Lord Neuberger [2]
34/4 42/9
lose [2] 33/13 33/13
losing [1] 42/18
loss [11] 10/12 14/8
14/10 55/16 61/14
92/17 93/17 93/24
94/2 97/15 97/17
loss/entry/transactio
n[1] 14/8
(40) it's.
.. - loss/entry/transaction
L
losses [1] 7/15
lost [3] 33/9 41/12
42/22
lot [11] 27/19 31/3
54/15 70/21 70/24
72/17 73/1 95/18
109/1 109/3 110/2
loud [4] 17/23
lower [2] 38/25 39/12
LRG [4] 8/11 8/13
8/14 8/18
MacLeod [18] 3/16
6/9 8/9 10/22 19/23
20/10 23/20 24/3
26/24 28/21 30/20
32/25 34/9 34/12
34/14 34/25 35/25
36/15
MacLeod's [2] 8/14
39/12
made [27] 17/5 25/17
30/8 30/9 33/18 33/21
33/22 34/3 35/11 37/2
39/8 41/20 41/23
41/24 49/14 55/10
70/9 74/25 75/12 78/1
79/11 84/12 86/23
88/18 102/12 108/13
109/20
Mail [3] 23/7 23/9
49/9
maintain [3] 31/21
74/19 78/21
maintained [2] 21/5
86/4
major [3] 30/12 30/14)
40/4
majority [1] 60/17
make [33] 7/1 7/20
11/17 11/21 18/4
18/22 19/14 23/25
29/24 36/9 36/19
42/17 48/8 48/25 50/5)
56/23 57/13 58/8
63/16 63/17 65/13
69/17 69/18 69/24
78/9 79/3 80/9 82/2
82/25 89/2 90/11
109/12 111/2
maker [6] 47/3 47/4
47/5 47/6 47/9 47/10
makers [1] 46/19
makes [4] 18/6 43/15
48/10 48/14
making [17] 11/25
12/2 12/9 28/12 42/14
42/14 44/22 44/24
45/6 65/1 72/21 74/18)
91/1 91/19 91/21
109/20 114/4
manage [6] 9/19
34/13 35/1 35/14
35/16 76/17
managed [6] 10/18
26/23 27/12 28/25
70/12 111/2
management [10]
7/5 10/16 65/19 66/13
67/17 67/18 70/24
75/7 75/14 80/5
manager [2] 23/14
101/5
manages [1] 34/13
managing [6] 6/14
10/17 34/8 34/15
75/16 97/18
mandatory [1] 91/21
manipulated [1] 14/5
manuals [1] 7/1
many [3] 53/25 90/9
90/14
map [1] 69/23
mapping [1] 66/17
March [8] 2/6 12/24
30/15 41/18 41/24
69/15 74/20 88/24
mark [4] 32/5 51/7
53/17 77/13
marked [1] 19/24
Marshall [1] 75/25
material [4] 13/25
23/10 44/20 110/24
materials [1] 102/8
matter [36] 4/20
10/21 17/6 22/15
23/13 24/5 25/8 27/5
27/7 27/20 28/18
29/23 30/1 30/10
33/17 34/18 35/10
35/12 56/25 57/11
60/2 63/8 66/24 72/25)
81/6 84/10 90/21
98/17 100/20 101/7
104/19 107/6 109/5
109/15 110/18 110/19)
matters [36] 6/4 7/2
7/7 11/15 11/25 12/10)
12/11 12/13 12/14
12/17 19/5 23/18
23/23 27/1 29/2 29/12
30/4 34/23 35/4 67/1
72/12 73/3 73/4 74/15)
76/2 81/1 81/2 81/15
82/24 84/14 94/6 98/7,
100/4 108/10 108/14
108/18
mature [1] 7/4
maturity [1] 19/4
may [44] 2/12 2/17
3/19 4/9 12/22 16/20
16/25 17/14 17/16
17/20 19/14 22/7
22/12 22/14 24/25
29/24 30/4 31/10 33/4
40/21 42/24 43/14
43/14 47/14 51/4 51/6
57/5 58/11 59/14
64/15 87/13 94/6
96/21 97/1 97/7
101/16 103/23 104/3
104/16 104/24 106/21
110/22 111/15 113/9
May 2017 [1] 22/14
maybe [1] 112/15
McCormack [5]
52/24 53/9 53/14 54/4
54/19
McEwan [1] 89/22
me [55] 6/9 6/11 6/13
6/15 9/8 9/13 9/14
9/21 11/7 18/19 21/20
22/14 30/14 31/2
33/20 33/25 36/10
36/20 37/14 37/21
37/22 38/11 39/18
39/19 43/15 47/18
55/12 58/1 63/8 64/15
64/17 71/11 74/6
74/18 75/4 80/19 84/2
86/17 86/19 87/11
87/16 87/25 92/19
92/20 95/11 95/12
95/22 102/15 103/14
104/21 105/17 105/23
106/3 107/18 110/11
mean [16] 6/20 8/13
15/7 18/1 18/3 19/4
25/8 26/21 45/20
62/10 66/25 78/4 93/4
95/1 100/11 108/23
means [4] 40/13
40/15 92/7 103/3
meant [4] 8/16 17/16
56/12 76/6
meantime [2] 8/4
59/18
measures [1] 109/12
mechanism [1] 90/17,
media [1] 78/21
mediation [10] 56/24
59/11 61/11 63/18
72/8 72/14 72/19
72/25 78/16 80/20
meet [3] 11/11 37/22
72/22
meeting [16] 9/6 9/7
9/9 23/22 28/9 36/5
36/16 47/14 47/18
48/3 49/3 65/23 68/3
68/7 69/7 86/19
meetings [5] 34/6
35/8 47/16 74/16
7417
Mel [1] 76/1
member [5] 39/1
47/23 47/25 48/9
108/17
members [3] 38/5
85/22 97/10
memory [5] 61/9
81/11 89/11 91/1
109/2
mention [2] 38/8
100/7
mentioned [2] 88/3
90/18
mentioning [1] 58/16
mere [1] 19/12
merit [1] 62/20
merits [5] 42/13
61/21 62/1 62/14
63/12
message [2] 53/16
101/14
messages [1] 98/6
met [2] 72/18 72/20
method [2] 13/6
14/19
Mick [4] 42/25
mid [2] 43/7 43/17
mid-June [2] 43/7
43/17
middle [1] 23/6
might [9] 6/24 40/11
43/18 49/16 91/9
98/25 101/17 107/8
112/16
milestones [2] 11/8
30/13
Milton [3] 55/11
57/17 58/14
mind [4] 16/3 52/2
79/16 104/16
mindful [7] 16/4
18/12 57/20 57/22
66/23 80/6 92/15
mindset [2] 91/15
91/18
Ministers [1] 32/10
minute [3] 71/3 97/24)
103/1
minutes [3] 41/20
65/25 70/11
mis [1] 55/17
mis-remming [1]
55/17
misbooking [1]
55/17
miscarriages [1]
112/1
misguided [1] 19/11
misinterpreted [1]
65/3
mislead [2] 65/12
65/15
missed [2] 16/2
16/11
missing [1] 16/4
mistake [1] 108/14
Mitchell [2] 42/24
42/25
mixture [2] 3/23 3/25
model [2] 48/24 49/4
models [1] 48/7
modern [1] 73/15
module [1] 103/19
Moloney [10] 92/5
97/24 98/1 102/25
108/2 110/18 110/20
111/6 115/8 115/12
moment [4] 28/5
40/11 71/3 96/12
Monday [3] 36/4
95/21 114/14
money [2] 55/23
96/19
monies [1] 97/18
monitor [1] 13/17
monthly [2] 11/12
24/2
months [3] 69/11
93/10 102/15
more [31] 7/4 18/16
20/12 29/1 38/15
43/10 48/8 48/10
48/25 49/4 52/10 53/8
53/23 54/23 61/15
65/11 68/1 70/5 70/21
70/23 70/24 71/21
71/25 74/9 79/3 80/10}
89/5 89/14 89/14 91/3}
98/25
Moreover [1] 27/10
morning [10] 1/3 1/4
1/13 1/17 26/10 40/12)
98/4 99/4 100/1
113/22
most [2] 8/20 53/3
mostly [1] 16/20
move [6] 40/21 51/20
61/15 65/17 71/2 85/7I
movement [1] 58/23
moving [5] 14/15
23/2 30/15 59/8 94/17
Mr [148]
Mr Altman [7] 60/9
60/25 108/9 108/25
109/18 110/1 110/10
Mr Bartlett [5] 1/7
90/4 106/4 106/5
107/1
Mr Bartlett's [1] 90/6
Mr Beabey [1] 30/25
Mr Blake [7] 1/4 1/20
98/5 98/10 99/3 114/9
115/4
Mr Butoy [3] 23/12
26/4 26/10
Mr Butoy's [1] 26/6
Mr Cameron [12]
36/5 36/16 36/18
37/13 38/20 52/24
52/24 53/8 53/13 57/5I
57/8 96/14
Mr Cameron's [2]
9/23 58/4
(41) losses - Mr Cameron's
Mr Coyne [1] 51/23
Mr Coyne's [1] 51/25
Mr Foat [30] 1/13
1/15 1/24 3/3 40/21
92/9 96/20 98/3 99/2
99/8 99/12 99/16
102/2 102/24 103/10
103/13 103/21 104/12)
106/3 107/2 107/15
108/22 110/14 110/16}
110/21 110/22 111/3
111/8 113/10 113/17
Mr Henry [3] 92/5
92/8 115/6
Mr Mark [4] 53/17
Mr McCormack [3]
53/9 53/14 54/4
Mr Mitchell [1] 42/24
Mr Moloney [8] 92/5
97/24 98/1 102/25
108/2 110/18 111/6
115/8
Mr Parsons [5] 40/25)
43/13 45/11 61/19
62/5
Mr Parsons' [1]
44/17
Mr Patterson [3]
103/21 104/9 104/12
Mr Read [11] 67/20
73/9 74/5 74/5 74/12
74/20 74/21 75/1
84/21 92/20 103/22
Mr Read's [3] 73/17
73/20 84/17
Mr Recaldin [2]
95/20 114/8
Mr Salter [2] 69/19
95/20
Mr Staunton [3]
85/16 86/17 96/13
Mr Stein [4] 92/3
92/4 103/11 112/8
Mr Underwood [3]
32/5 78/12 80/13
Mr Watts [2] 71/17
71/19
Mr Williams [16]
16/1 16/7 16/13 22/13}
22/17 23/5 23/12
25/22 26/23 26/24
26/25 98/6 98/13
100/2 101/5 101/13
Mr Williams' [1]
15/13
Ms [15] 20/10 26/24
32/12 32/25 34/9
34/12 34/25 35/25
36/15 39/12 110/19
111/6 111/7 113/4
115/14
Ms Allan [3] 110/19
111/6 113/4
Ms MacLeod [8]
20/10 26/24 32/25
34/9 34/12 34/25
35/25 36/15
Ms MacLeod's [1]
39/12
Ms Prime [1] 32/12
much [24] 1/12 1/21
1/24 3/2 4/1 5/15 5/24
6/17 25/13 26/24
40/16 52/6 52/10 71/1
75/13 88/7 91/25 96/4
102/24 103/4 107/9
108/22 113/17 114/12)
multifaceted [1]
89/13
multiple [4] 35/20
must [6] 17/13 17/16
17/19 60/5 78/23
95/25
my [86] 1/5 1/23 5/16
6/1 7/24 11/13 11/16
12/18 15/15 16/8 20/4
24/18 25/1 25/12
26/17 26/19 27/12
27/14 28/2 28/5 28/8
28/13 31/13 33/5
34/14 35/6 35/18
38/25 38/25 40/8 45/8)
46/12 47/12 48/7 48/8
48/25 51/6 53/19
54/14 54/16 55/15
55/18 56/7 59/23 60/5)
60/10 60/10 60/12
65/13 66/17 69/21
69/21 69/22 70/6
72/24 73/3 74/14 76/2
76/7 76/15 77/21 78/2
78/5 78/6 78/7 80/20
84/6 85/24 86/4 87/6
87/14 87/20 87/20
90/23 91/5 95/9 96/8
97/4 101/18 101/19
104/15 108/1 111/8
112/10 112/25 113/14}
myself [2] 88/4 109/3
name [6] 1/22 1/23
80/22 111/8 112/12
112/15
namely [1] 96/10
narrow [1] 63/16
nature [2] 5/3 83/2
navigate [1] 32/8
NBIT [1] 48/13
near [1] 16/16
necessarily [12] 22/4
27/4 45/18 52/10
54/15 64/14 76/5 84/3
89/20 98/24 104/22
105/13
necessary [6] 8/21
9/2 27/16 27/18 32/14
89/1
NEDs [2] 86/18 87/24
need [26] 8/6 10/8
10/14 21/1 21/25 22/4]
22/10 41/7 43/10 44/6
44/25 46/3 46/20
46/22 49/16 65/11
66/12 69/6 71/25 74/2
78/9 82/3 86/5 86/8
94/3 99/17
needed [13] 5/15
27/11 31/4 31/5 49/12
68/21 68/25 72/11
77/6 81/13 89/5 90/15
97/14
needing [1] 72/9
needs [4] 18/7 39/9
86/10 91/12
negotiation [1] 72/16
negotiations [1]
95/24
negotiators [1] 96/25
nervous [1] 43/15
network [2] 66/14
72/2
Neuberger [2] 34/4
42/19
never [8] 8/5 25/11
62/9 86/3 87/11 94/19
110/11 110/11
new [7] 15/17 15/18
50/6 53/5 75/12 90/2
90/10
newly [2] 6/10 88/19
news [1] 49/20
next [3] 26/8 65/18
99/18
nicest [1] 51/10
Nick [5] 69/5 71/25
76/16 80/18 90/24
nine [1] 93/10
no [38] 6/6 6/7 6/8
14/9 15/5 15/12 15/13
22/6 22/16 23/18
26/17 31/9 33/18
33/24 35/6 35/15 39/2
42/4 45/1 51/6 54/14
55/16 62/19 65/15
68/14 69/16 72/13
78/6 85/9 90/20 99/9
100/7 100/17 101/4
101/18 107/16 108/20}
109/24
nodded [1] 93/9
nominal [1] 78/14
non [6] 85/17 86/15
106/14 106/17 108/13
110/4
non-disclosure [4]
106/14 106/17 108/13
110/4
Non-Executive [2]
85/17 86/15
nonetheless [1]
96/16
nor [1] 35/11
normal [2] 44/6
46/14
normally [1] 45/2
Norton [1] 57/3
not [152]
note [15] 10/7 13/2
13/2 19/1 28/24 31/22}
31/23 31/24 32/15
35/17 78/1 85/15
85/16 94/9 99/24
noted [2] 24/1 88/1
nothing [4] 1/15
50/23 86/13 110/16
notice [6] 93/22
98/16 98/20 98/23
99/1 100/18
notices [1] 67/5
notwithstanding [2]
64/2 65/15
November [11] 2/19
21/13 27/22 29/1 29/9)
30/2 49/15 63/10 69/7,
114/8 114/14
November 2018 [1]
30/2
now [34] 1/11 7/23
8/6 15/24 17/20 21/12,
23/3 25/21 27/6 32/23
35/20 40/21 41/22
43/14 52/22 53/4
55/16 59/1 59/18 66/8
70/7 70/9 70/15 76/8
94/17 95/14 104/15
105/4 106/6 108/5
114/7
NR [1] 67/20
NRF [1] 58/7
number [38] 1/25
2/15 3/7 4/24 11/15
11/23 12/8 14/12
15/19 16/12 17/12
21/25 22/17 26/15
27/10 27/24 35/21
46/23 48/23 49/7 50/9
60/16 70/19 74/25
74/25 77/3 77/5 82/22
82/23 83/12 84/21
90/25 96/10 99/5
99/20 102/12 102/13
112/8
number 1 [1] 99/20
number 3 [1] 21/25
numerous [1] 63/1
oO.
obligation [2] 45/1
97/19
obligations [2] 12/8
77/5
obliged [2] 43/16
110/21
observation [7]
15/15 16/8 25/13
75/13 84/8 87/25
95/16
observations [4]
22/16 25/17 80/11
86/23
observations/allegati
ons [1] 86/23
observed [1] 65/4
obtained [3] 61/22
78/11 112/4
obtaining [1] 89/8
obviously [26] 9/20
11/2 16/3 18/12 24/9
37/5 39/7 39/9 39/16
56/20 58/16 65/12
70/10 75/1 79/14
79/18 80/4 80/22
81/14 82/12 82/17
92/15 95/3 95/19
105/20 108/24
occasions [5] 4/25
22/18 48/23 53/25
96/10
occur [1] 57/17
occurred [6] 60/23
63/9 70/20 76/13
102/14 112/1
October [7] 1/1 2/13
2/18 25/21 25/25
89/18 89/23
October 2018 [1]
25/21
odd [1] 74/7
off [6] 8/6 39/10
70/18 86/16 89/1
101/18
offences [1] 15/3
offer [1] 71/22
offered [2] 27/14
35/18
offering [1] 35/19
office [94] 3/7 3/10
4/6 4/16 4/21 5/13
5/18 5/20 10/20 11/9
11/20 13/3 14/4 14/17)
16/21 17/5 17/8 18/17)
20/23 23/4 23/4 23/7
23/9 24/23 25/2 26/12I
26/15 27/24 31/22
32/22 38/11 38/12
42/13 45/13 45/14
46/7 46/9 46/18 48/25
49/7 49/22 51/18
55/11 60/3 62/18 63/7
67/19 68/11 68/12
72/16 72/18 72/22
73/16 76/19 77/6
78/11 79/16 80/4
83/10 83/24 84/5 84/6I
84/10 84/10 86/5 95/6I
95/24 96/9 96/23
97/19 101/16 104/3
(42) Mr Coyne - office
[e)
office... [22] 104/6
104/20 105/5 105/11
105/17 105/20 105/21
106/9 106/10 106/20
107/14 107/16 107/23)
108/8 108/19 108/23
110/3 110/7 111/14
111/23 112/20 112/22)
Office's [9] 4/19 5/7
16/23 48/2 50/15 55/1
69/3 91/11 100/8
officer [3] 21/20
21/23 57/24
offices [1] 28/3
Offices' [1] 49/10
often [2] 19/24 47/16
oh [4] 33/23 38/17
70/19 95/8
Okay [2] 71/7 113/3
old [4] 93/10 94/7
107/9 107/9
old/same [1] 107/9
omission [1] 1/10
omitted [1] 1/7
on [186]
on-forwarded [1]
33/11
once [3] 35/19 73/25
84/12
one [43] 2/1 2/8 8/19
8/24 11/4 11/12 11/12
12/10 19/17 20/24
26/12 34/7 34/24 37/9
39/2 62/2 64/1 66/7
68/1 68/21 73/2 75/18
79/2 81/10 82/5 82/13}
85/13 86/8 89/20
89/21 89/25 91/12
97/5 97/10 97/10
97/11 98/25 99/3
102/2 103/24 107/8
107/11 110/18
ongoing [5] 43/22
46/1 100/15 101/25
111/22
Online [1] 79/22
only [14] 8/19 19/19
20/15 34/1 41/18 48/1
48/3 50/15 52/16 59/3
82/25 89/22 94/13
110/8
onto [1] 72/12
onwards [2] 21/23
70/3
open [2] 7/22 85/4
operational [1] 88/10
operationalised [1]
76/22
operations [14] 6/16
6/18 6/20 6/21 8/11
8/18 11/17 11/23 24/1
57/16 58/18 69/22
72/20 104/14
opine [2] 7/19 9/25
opined [1] 82/24
opinion [6] 59/23
61/20 61/25 62/14
63/12 64/16
opportunity [2] 28/7
39/21
opposed [2] 56/16
84/19
opposite [1] 87/19
opposition [1] 49/10
Optically [1] 78/19
optionality [1] 91/21
or [103] 1/15 7/16 9/1
9/4 10/25 14/2 14/4
14/5 14/6 14/7 14/8
14/24 15/24 17/13
17/22 18/8 19/1 19/4
19/18 20/24 21/1
21/14 21/22 21/23
22/20 23/9 23/16 24/6
29/8 32/21 32/25 33/9)
33/11 33/12 36/2 37/4
37/14 39/1 39/5 39/22
40/1 40/2 42/14 43/19
45/17 46/20 46/21
46/24 48/5 48/13 51/8
52/17 54/24 55/5
55/23 56/25 59/10
59/24 60/1 60/11
61/13 61/21 64/24
65/5 65/14 66/20
68/20 70/4 71/24 72/7
79/21 79/23 82/20
83/1 83/1 83/19 84/3
84/4 84/18 90/16 92/4
92/12 93/21 94/20
95/25 96/24 96/25
96/25 98/4 98/19
99/22 105/1 105/3
107/12 107/17 108/12)
108/16 109/3 109/12
109/18 110/11 112/20)
112/21
oral [4] 1/9 88/3
113/22 113/25
order [4] 6/22 28/17
78/25 113/24
organisation [12]
5/25 18/5 38/4 44/24
56/22 67/16 70/5 73/9
76/3 91/4 100/15
101/3
organisation's [1]
68/23
organisations [3]
21/3 23/8 90/9
original [11] 60/16
72/14 76/13 79/11
79/13 79/25 80/1 80/3)
82/1 82/3 82/9
originally [2] 61/22
63/4
originate [1] 74/24
other [44] 8/6 11/15
12/8 14/4 17/20 19/3
22/8 22/18 27/11 31/4
46/22 47/2 48/12
48/14 56/8 60/11
66/25 71/22 72/1 72/4
72/10 73/4 76/3 79/10
82/20 85/22 87/15
89/1 90/9 91/14 92/4
96/18 100/12 104/22
104/23 105/14 106/1
106/12 108/17 108/20
108/21 108/22 109/3
112/8
others [5] 16/25
28/19 60/2 64/15
81/12
otherwise [2] 14/5
66/20
ought [5] 24/25 47/3
65/9 89/3 94/18
our [16] 8/25 32/8
40/11 43/5 49/9 55/22
56/1 56/2 65/18 67/4
70/12 71/13 73/11
73/12 73/13 83/6
out [29] 4/19 4/21
8/11 8/18 12/1 17/23
19/15 21/14 36/13
36/17 38/7 43/4 54/10
58/13 61/17 61/20
61/22 61/24 62/5 62/7
62/21 63/8 66/18
69/23 77/6 80/17
107/4 112/5 113/6
outcome [5] 41/9
50/13 78/22 101/22
106/13
outputs [1] 43/7
outright [1] 62/9
outside [5] 82/20
83/2 83/8 100/12
106/9
over [21] 4/20 13/11
19/20 31/21 37/13
40/24 42/6 49/5 51/1
54/1 62/16 67/8 72/3
75/7 82/19 85/14
89/17 91/6 92/12
95/24 102/14
over-simplifying [1]
19/20
over-technical [1]
92/12
overall [6] 35/2 61/25
62/14 62/19 63/12
77/8
overarching [1] 97/6
overridden [1] 87/22
oversaw [1] 35/9
oversee [1] 109/9
overseeing [1] 81/17
overseen [1] 81/15
oversees [1] 88/25
overturning [1] 60/22!
overview [1] 68/6
owe [2] 28/11 101/16
owing [1] 80/19
own [8] 8/25 25/1
35/6 36/2 57/14 68/13)
76/7 109/19
owned [1] 45/13
owner [1] 45/3
owners [4] 12/3
46/22 69/23 88/15
ownership [2] 34/18
46/9
P
package [1] 59/25
page [34] 7/11 22/11
30/19 30/19 32/11
40/25 41/1 41/5 41/6
42/6 42/6 42/21 43/12)
49/5 49/25 52/22
52/23 53/18 54/2 54/3)
61/17 62/5 62/16
62/17 65/24 67/9 67/9
73/8 77/12 85/14
99/13 99/14 99/18
103/25
page 1 [4] 41/5 41/6
43/12 77/12
page 2 [10] 22/11
40/25 41/1 42/6 54/3
61/17 62/5 65/24 73/8
99/14
page 3 [4] 30/19 42/6
42/21 54/2
page 4 [2] 30/19
49/25
page 5 [2] 53/18 67/9
page 6 [1] 67/9
page 7 [1] 52/22
panel [2] 89/17 97/10
panels [1] 96/25
Panorama [2] 4/18
5/8
paper [5] 23/4 32/14
50/3 66/10 67/23
paragraph [10] 8/9
13/4 13/5 14/15 23/6
26/8 50/7 59/13 85/19)
111/12
paragraph 2 [2] 13/4
13/5
paragraph 231 [1]
111/12
paragraph 6 [1]
14/15
paragraphs [1] 13/10
parcel [1] 110/3
Park [1] 76/1
Parker [1] 37/6
Parsons [7] 14/17
40/25 43/13 45/11
59/5 61/19 62/5
Parsons' [1] 44/17
part [28] 8/2 14/1
23/25 24/21 31/6
56/14 61/6 66/19 75/9
78/17 79/8 87/11 88/1
88/17 89/13 89/16
90/1 90/13 98/4 98/20I
100/24 102/22 103/24)
105/19 109/19 110/3
110/4 110/14
Participant [2] 91/6
111/9
Participants [1] 92/1
particular [14] 6/5
10/20 22/3 22/20 46/5I
56/24 61/1 64/22
85/12 87/18 92/10
92/16 103/24 106/7
particularised [2]
65/6 65/9
particularly [13] 12/9
16/5 17/9 18/2 18/24
20/22 22/19 62/23
65/8 70/3 75/9 81/5
111/24
particulars [1] 95/18
parties [1] 72/15
partner [2] 71/19
71/20
parts [3] 20/3 76/3
91/14
party [4] 14/4 70/2
98/19 99/22
pass [2] 72/4 91/6
passage [1] 38/21
passages [2] 13/1
36/6
passionate [1] 15/21
past [5] 40/14 73/21
81/3 97/16 112/23
path [1] 59/16
Patrick [1] 32/9
Patterson [3] 103/21
104/9 104/12
Paula [3] 7/21 27/25
54/6
Pause [1] 1/14
pausing [1] 86/1
pay [2] 55/13 61/5
payable [1] 96/17
paying [1] 105/20
payment [1] 77/21
pensions [1] 68/8
people [25] 4/25
18/14 19/12 20/5
27/24 38/4 45/15
60/13 63/1 80/25
81/12 81/21 83/9 86/3I
86/7 86/10 88/18
90/19 90/21 90/25
91/3 91/19 100/11
106/18 109/3
per [3] 75/16 79/19
85/24
(43) office... - per
P
perception [1] 28/6
perhaps [13] 18/10
19/11 36/1 51/10 54/3
54/24 61/10 71/3 84/2
92/2 92/5 100/22
112/15
period [9] 3/16 17/8
51/1 58/22 72/3 77/10
91/11 104/25 108/3
permission [10] 26/2
26/6 40/23 41/4 41/22
41/25 42/2 42/5 42/23
56/7
perpetrator [1] 84/24
person [6] 12/16
13/20 16/9 35/15
58/17 89/21
personal [3] 36/1
48/7 91/16
personally [3] 22/24
49/3 69/24
perspective [6]
42/12 44/3 45/23 48/6
48/7 109/4
pertain [2] 47/18
97/20
pertaining [2] 23/18
51/13
pertinent [1] 16/4
Peters [16] 66/10
66/10 77/1 77/1
102/10 102/11 102/21
102/21 112/6 112/6
112/10 112/10 112/13}
112/14 113/1 113/1
phase [10] 3/24 3/25
4/5 65/17 71/2 71/13
71/14 96/14 96/15
99/6
Phase 5 [1] 3/24
Phase 7 [7] 3/25 4/5
65/17 71/2 71/13
71/14 96/15
phases [2] 4/3 12/23
Phases 5 [1] 4/3
Phoenix [5] 87/16
88/7 88/9 88/23 89/2
phrase [2] 5/1 5/4
picking [1] 65/4
piece [1] 53/3
pieces [1] 14/12
Pineapple [2] 85/10
85/15
place [11] 6/22 13/11
26/24 63/10 69/10
70/15 70/25 90/17
96/24 102/4 113/21
placing [1] 73/12
plain [1] 80/10
plan [3] 59/7 59/11
79/2
played [1] 16/7
plays [1] 91/8
please [38] 1/22
16/14 16/19 23/1
27/21 28/22 30/22
30/25 32/6 41/3 42/20
47/13 49/25 52/21
53/18 53/20 54/2 55/6)
55/20 59/2 59/4 59/21
61/3 61/16 63/22
63/23 65/19 66/1 67/6
67/9 67/13 77/14
85/14 99/3 102/2
103/4 103/19 103/25
plus [1] 62/11
pm [3] 103/7 103/9
114/13
point [52] 5/14 6/2
10/15 17/3 17/24 18/8)
20/4 20/15 21/25
22/10 24/14 24/18
24/22 24/24 26/19
26/22 29/8 33/1 36/17
37/11 38/22 39/17
40/5 40/8 42/17 44/22
46/1 50/10 52/13
52/15 55/1 57/15
57/23 60/12 61/1
62/21 63/14 65/4
69/14 70/3 72/5 72/24
79/11 82/25 83/11
84/25 86/9 94/8 101/1
101/24 104/1 110/12
points [1] 50/9
POL [1] 83/3
POL00021462 [1]
67/6
POL00021556 [1]
47/113
POL00023233 [1]
40/22
POL00023809 [1]
30/17
POL00042675 [1]
42/20
POL00042755 [1]
59/2
POL00091437 [1]
51/20
POL00114170ds [1]
2/16
POL00114173ds [1]
2/18
POL00114176ds [1]
2119
POL00114177ds [1]
2/20
POL00114188ds [1]
2/5
POL00118164ds [1]
2/8
POL00136421 [1]
52/21
POL00155397 [1]
77/10
POL00167390 [1]
68/2
POL00245909 [1]
21/12
POL00249526 [1]
10/4
POL00255859 [1]
16/14
POL00257831 [1]
25/18
POL00259733 [1]
27/21
POL00276474 [1]
61/16
POL00276883 [1]
63/22
POL00280270 [1]
55/6
POL00289903 [1]
71/14
POL00290399 [1]
73/7
POL00293080 [1]
23/1
POL00315631 [1]
12/21
POL00327569 [1]
57/2
POL00357840 [1]
POL00359988 [1]
35/24
POL00401613 [1]
65/20
POL00415520 [2]
22/8 99/4
POL00423519 [1]
69/7
POL00448302 [1]
85/11
police [5] 9/2 106/10
106/21 107/4 107/10
policies [1] 6/21
policy [2] 60/13 67/4
political [1] 78/21
position [14] 4/20
25/17 28/2 35/10 46/8
46/16 46/18 50/18
51/14 55/1 58/1 58/3
62/19 78/20
positioned [1] 41/13
possibility [1] 85/4
possible [3] 14/22
51/10 76/2
post [103] 3/7 3/10
4/6 4/16 4/19 4/21 5/6
5/13 5/18 5/20 10/19
11/20 13/3 13/7 14/4
14/16 16/21 16/23
17/5 17/8 18/17 20/23
23/4 23/7 23/9 24/23
25/2 26/12 26/15
27/24 28/3 31/22
32/22 42/13 45/13
45/14 46/7 46/9 46/18
7/8
48/2 48/25 49/7 49/10)
49/22 50/15 51/18
55/1 55/11 60/3 62/18)
63/6 67/19 68/10
68/12 69/3 72/16
72/18 72/22 73/16
76/15 76/15 76/19
77/6 78/11 79/16 80/4
83/9 83/24 84/5 84/6
84/10 84/10 86/5
91/11 95/6 95/24 96/9)
96/23 97/19 100/7
101/16 104/3 104/6
105/5 105/11 105/17
105/20 105/20 106/9
106/10 106/19 107/13
107/16 107/23 108/7
108/19 108/23 110/2
110/7 111/14 111/20
111/23 112/20
post-GLE [1] 76/15
post-GLO [1] 76/15
posting [2] 13/6
14/19
postmaster [10] 8/2
26/1 28/2 29/7 49/13
72/18 79/18 86/18
87/23 96/17
postmasters [12]
16/20 49/11 55/24
72/1 72/10 72/12
73/12 79/10 85/23
94/12 104/2 104/4
potential [5] 9/5 15/1
57/11 57/13 112/5
potentially [3] 8/20
13/25 43/24
power [3] 85/22
86/24 87/6
practice [6] 4/6 40/1
91/24 96/1 98/14
99/16
practised [2] 15/18
15/19
precautionarily [1]
28/5
precedence [1]
98/22
precise [2] 21/21
65/11
precondition [1]
59/11
predated [1] 33/5
predecessor [1] 49/1
predominantly [1]
11/13
preferably [1] 93/18
preference [1] 7/24
prejudice [1] 28/14
prepared [3] 32/1
32/10 66/11
preparing [3] 43/19
59/17 102/3
present [1] 65/24
presented [1] 73/18
presenting [1]
108/18
preservation [6] 67/5)
98/16 98/20 98/23
99/1 100/18
press [1] 106/3
pressure [1] 78/21
Presumably [1] 32/6
presume [1] 36/23
previous [13] 12/23
39/25 50/17 51/14
52/11 63/21 64/23
66/23 75/11 79/21
80/7 87/13 91/17
previously [6] 63/9
65/21 66/7 67/15
104/20 109/14
Prime [2] 31/17
32/12
principal [1] 12/16
principles [1] 97/12
prior [7] 6/11 75/11
80/20 80/25 89/24
90/21 111/4
prioritisation [1] 75/7I
prioritise [1] 87/20
prioritised [1] 88/23
priority [2] 69/12
89/3
private [1] 40/1
privilege [21] 18/16
18/21 19/2 19/10
19/15 19/21 20/13
21/4 22/21 31/15
31/21 31/25 32/3 32/7I
32/18 33/3 33/9 56/5
98/7 100/14 101/15
privileged [6] 13/21
19/14 19/25 19/25
20/8 33/14
pro [1] 35/6
pro-activeness [1]
35/6
proactive [1] 111/23
probably [6] 4/7
20/20 20/21 49/23
52/5 96/7
problem [2] 31/23
32/13
problematic [1]
58/15
problems [3] 32/7
54/25 58/11
procedure [2] 82/8
82/10
proceed [1] 58/16
proceeded [1]
101/21
proceedings [4] 18/6
98/18 102/19 110/25
process [19] 13/22
26/22 37/16 56/5
62/10 78/3 78/17
(44) perception - process
P
process... [12] 79/15
81/22 83/7 86/10
88/11 94/19 94/20
94/25 98/15 109/20
109/21 112/9
processes [1] 13/19
produce [2] 32/14
43/7
produced [2] 1/24
12/20
professional [7]
18/16 18/20 19/1
19/10 19/15 19/21
22/21
profits [1] 94/2
programme [11] 5/8
8/23 9/19 10/21 20/18
29/3 70/14 75/17
76/15 76/16 77/7
programmes [3]
74/14 74/23 75/10
progress [4] 72/23
76/2 87/21 96/7
progressed [1] 19/8
progressing [1] 60/3
Project [4] 12/25
85/15 88/7 88/9
prompt [1] 96/12
proof [3] 51/8 52/18
55/3
properly [2] 70/7
70/12
property [1] 9/6
proportion [1] 61/5
proposal [1] 9/23
propose [1] 111/13
proposed [1] 38/9
prosecute [1] 7/15
prosecuted [2] 45/15
100/24
prosecuting [2] 5/7
101/2
prosecution [6] 5/11
7/25 8/20 8/21 10/9
46/10
prosecutions [17]
6/4 7/7 8/5 8/25 9/5
10/10 10/13 12/17
24/24 25/3 26/12
26/15 29/10 29/15
29/17 29/19 73/18
prosecutor [2] 100/8
100/15
prospects [1] 8/7
protect [1] 56/5
protected [1] 96/19
protection [1] 56/6
protocol [4] 11/19
21/1 21/2 32/16
PROVED [1] 85/24
proven [3] 86/3 86/7
86/11
provide [8] 9/2 49/19
50/16 59/9 78/25
94/15 95/2 96/10
provided [18] 18/22
19/23 48/24 49/13
50/1 57/12 61/21
62/24 63/2 64/1 64/6
64/8 65/7 68/6 69/18
72/17 82/7 82/9
providing [5] 1/8
40/25 72/6 94/5
113/18
provision [2] 19/18
51/18
public [5] 53/22
60/13 96/18 96/19
97/18
publicity [1] 49/17
publicly [4] 1/5 1/11
32/22 114/3
publishing [1] 40/2
purporting [1] 57/13
purpose [6] 25/24
32/1 50/25 76/16
94/23 105/21
purposely [1] 80/16
purposes [2] 107/24
110/25
pursue [2] 78/16
104/4
pursued [1] 10/12
pursuing [1] 10/10
Pursuit [1] 104/1
pushing [1] 87/16
put [14] 6/16 6/22
28/8 44/1 45/19 46/25)
51/11 58/1 70/25
80/10 88/11 90/17
92/25 101/10
putting [3] 75/18
84/23 92/20
Q
Qc [5] 42/10 59/19
97/10 109/6 109/11
QCs [2] 35/18 102/13
qualified [2] 3/5
39/21
quality [1] 75/7
quantify [1] 60/1
quantum [5] 62/25
63/2 63/25 64/7 64/12
quarter [1] 40/14
quarters [1] 49/10
Queen's [4] 35/20
82/23 109/6 112/9
query [1] 20/7
querying [1] 52/17
question [20] 9/21
10/1 39/15 45/19
46/19 51/7 52/6 52/13
53/11 83/14 84/23
94/24 97/3 100/21
104/15 105/8 108/1
110/8 110/13 110/22
questioned [13] 1/20
67/17 92/8 98/1
103/12 110/20 111/7
115/4 115/6 115/8
115/10 115/12 115/14
questionings [1]
112/8
questions [15] 10/8
13/3 55/21 56/3 56/10
85/8 88/6 91/7 92/1
92/4 96/13 97/23
103/17 108/2 111/9
quickly [2] 76/2 99/2
quite [9] 21/21 23/21
45/18 55/3 81/5
100/17 100/22 102/13
105/15
quote [1] 96/8
Ro
raise [1] 89/5
raised [30] 9/21 14/1
29/5 50/10 54/22 57/5)
57/8 58/7 58/8 67/7
68/20 68/21 69/1 69/5
70/11 74/20 74/25
75/1 75/21 78/8 84/6
84/22 84/25 85/1
90/21 90/24 104/23
105/17 108/24 110/5
raising [2] 54/17
63/24
ranging [1] 52/1
rapid [2] 56/2 56/11
rare [1] 100/25
rather [12] 7/17
26/25 31/23 56/3
56/25 59/15 63/18
68/20 72/12 75/17
88/4 100/20
rationale [1] 77/23
RCC [2] 69/5 70/11
re [2] 32/7 56/19
re-examine [1] 56/19
reached [2] 43/4
51/17
reaching [1] 60/5
read [22] 13/1 17/22
36/6 53/23 61/17
67/20 69/5 73/9 74/5
74/5 74/12 74/20
74/21 75/1 79/5 84/21
90/25 92/20 99/13
103/22 113/6 113/7
Read's [3] 73/17
73/20 84/17
reading [3] 14/11
18/2 79/2
ready [1] 113/20
realised [1] 96/7
reality [3] 65/7 75/5
79/5
really [12] 5/23 19/3
20/17 21/8 22/10
25/20 34/1 58/11
64/20 106/17 110/4
110/5
reason [2] 24/22 34/1
reasons [4] 3/21
10/10 17/9 60/7
reassuring [1]
105/23
Recaldin [2] 95/20
114/8
recall [16] 4/25 5/14
5/23 15/16 18/2 19/3
31/9 35/19 38/10
38/11 38/17 51/4
101/18 105/3 105/3
112/12
receipt [2] 18/5 66/5
received [8] 17/6
18/1 41/8 42/1 55/2
58/25 59/18 86/18
recent [2] 50/4 96/14
recently [2] 53/3
55/12
recipient [1] 16/17
recognise [2] 17/19
82/15
recognised [3] 66/12
97/15 110/7
recollection [5] 33/5
51/6 51/7 61/1 101/19
recommend [1]
32/20
recommendations
[1] 74/25
recommended [1]
67/25
record [2] 73/24 86/9
recording [2] 22/20
22/20
records [5] 14/24
36/16 65/19 68/13
70/8
recoverable [1]
61/14
recovery [1] 9/10
rectify [2] 111/25
112/22
recusal [11] 33/16
33/18 33/20 34/2
40/24 41/15 41/23
42/14 42/21 SO/7
64/19
recuse [1] 41/21
red [1] 60/7
redress [4] 75/18
76/8 76/9 77/9
reduction [1] 76/5
redundancy [1] 8/23
redundant [1] 38/19
refer [3] 4/12 9/1
111/13
reference [16] 24/4
43/9 49/6 52/8 56/11
72/9 78/1 85/12 87/9
87/16 94/13 97/9
97/14 99/5 100/19
106/7
references [2] 24/8
93/23
referred [6] 9/10
18/24 31/19 75/6 93/5}
109/14
refers [3] 14/15
38/20 50/6
reflect [1] 75/4
reflection [1] 54/24
reflections [2] 15/24
91/7
refusal [2] 41/25 42/2)
refused [3] 26/7
40/23 42/22
refusing [2] 41/4
42/5
regard [1] 46/23
regarding [7] 16/12
48/20 63/25 64/12
66/11 106/12 108/3
regardless [1] 77/22
registered [1] 28/16
registrar [1] 23/3
regularly [3] 11/11
23/21 54/6
regulated [2] 5/21
34/16
relate [2] 108/11
108/12
related [6] 12/10
23/23 30/4 66/4 67/11
67/11
related/linked [2]
66/4 67/11
relates [2] 34/25
7213
relating [16] 4/3 6/4
TIT 9/4 12/10 12/17
12/25 26/3 29/2 29/16
29/20 29/22 32/25
35/4 90/21 94/6
relation [23] 4/20
22/15 23/10 24/5 26/4I
30/2 32/9 35/12 38/15
40/24 48/4 48/19
51/24 54/8 54/8 62/25
63/24 76/9 78/2 93/24)
98/11 108/14 111/15
relationship [3]
73/11 74/11 100/13
relatively [2] 17/7
88/19
released [1] 32/22
relevant [13] 14/9
14/12 17/14 17/17
22/10 45/16 47/17
54/19 58/17 66/18
88/15 99/21 104/18
reliance [1] 7/19
relied [1] 50/23
(45) process... - relied
R
rely [1] 105/13
relying [4] 7/25 100/3
100/6 104/10
remain [2] 62/19 75/4
remains [1] 66/3
remarked [2] 67/18
67/20
remediate [1] 90/12
remediation [3]
68/25 70/14 70/20
remember [10] 33/18
33/19 33/22 34/2
38/18 52/8 57/9 61/13,
93/8 110/22
remembered [2] 5/4
113/5
reminder [1] 104/12
reminding [1] 18/14
remit [1] 10/19
remming [2] 55/17
58/20
remote [3] 12/25
14/13 15/1
remotely [2] 1/14
55/15
removed [3] 9/25
25/15 74/9
remuneration [2]
28/13 49/13
renege [3] 50/17 51/4
51/14
repair [1] 1/10
repayments [1]
28/12
repeated [1] 98/5
repeatedly [3] 69/4
86/9 89/5
repeating [1] 107/14
replaced [1] 38/15
replacing [2] 37/14
38/13
report [12] 13/2 13/5
13/14 14/11 14/18
38/24 43/15 43/17
43/24 68/4 95/3 96/8
reported [9] 10/21
12/15 13/15 22/14
34/14 50/14 57/21
68/17 87/11
reporting [1] 52/18
reports [2] 24/2 95/8
repositories [1]
66/18
repository [3] 6/24
12/2 98/22
representation [3]
79/13 79/14 82/3
representative [3]
28/8 37/7 97/11
representatives [3]
82/6 84/21 95/6
reprioritisation [1]
76/6
Request [1] 66/2
Request/GDPR [1]
66/2
requests [3] 66/5
67/10 67/12
require [2] 79/12
93/17
required [3] 79/18
93/24 95/19
requirement [3] 13/8
94/1 97/13
requirements [1]
78/24
requiring [1] 11/24
reset [2] 72/11 73/11
resolution [8] 9/18
11/18 41/18 41/20
68/22 78/17 82/8
102/23
resolved [1] 78/15
resolving [1] 56/25
resource [11] 8/22
10/14 34/22 70/6
70/25 88/20 88/21
89/5 89/11 89/14
100/6
resourced [2] 90/3
90/6
resources [1] 69/21
resourcing [1] 90/5
respect [28] 9/23
24/7 29/5 30/10 41/15)
41/25 47/19 59/1
60/24 63/4 63/15
65/21 66/25 69/10
77/2 80/7 84/17 90/4
90/23 91/4 91/7 94/2
95/16 97/4 97/12 98/7,
104/7 106/2
respective [1] 21/2
respects [1] 18/3
respond [1] 44/8
responded [1] 10/1
responding [3] 31/19
66/3 108/8
responds [2] 9/15
9/22
response [10] 8/8
26/9 28/20 28/23 32/4
32/11 41/5 88/10
88/17 90/18
responsibilities [1]
24/11
responsibility [3]
34/7 35/13 57/15
responsible [5]
11/15 57/16 68/15
80/1 89/12
rest [1] 60/5
restrictions [1] 31/15
restructures [1] 76/4
result [8] 83/18 83/18)
86/25 87/6 88/9 88/14
111/21 112/2
resume [3] 9/9 49/9
114/8
resuming [1] 29/18
resumption [4] 9/5
29/10 29/14 29/16
retail [4] 29/6 66/14
66/19 75/23
retailer [1] 97/11
retain [1] 18/7
retention [3] 16/13
66/13 67/4
retention/manageme
nt [1] 66/13
return [2] 21/10
104/24
returned [1] 104/20
revealed [1] 102/8
reverse [3] 109/25
110/6 110/6
revert [2] 28/24
107/25
review [8] 25/7 26/11
26/11 43/5 43/7 49/12
75/10 112/21
reviewed [7] 26/13
26/16 66/9 67/16
107/22 110/24 111/4
reviews [1] 66/23
revised [1] 1/6
right [16] 47/2 47/21
53/4 63/17 86/25
87/14 92/12 95/15
96/11 99/9 100/17
104/24 106/18 106/19}
109/18 114/11
rights [1] 49/12
ring [1] 112/17
risk [23] 5/22 7/5
8/15 12/5 12/5 20/13
33/13 34/8 34/13 35/2
35/14 40/6 43/16 44/1
44/6 59/23 60/1 60/8
65/23 66/11 67/8 68/5)
70/11
risks [4] 34/10 45/2
47/1 70/13
Rivers [1] 19/16
Road [3] 27/24 28/3
28/3
Rob [3] 21/17 21/19
43/3
robust [7] 4/13 4/22
50/18 50/19 50/22
51/15 55/2
robustness [1] 52/12
rocks [1] 90/11
Rod [22] 9/17 10/18
10/21 11/5 11/7 11/13
12/7 12/12 17/10
18/10 20/25 22/14
24/18 25/8 27/8 29/8
30/14 31/2 77/15
80/15 81/12 81/14
Rod's [2] 54/5 98/24
Rodric [13] 10/5
10/16 11/9 14/16 15/4}
15/10 21/10 21/17
51/21 77/13 80/13
80/22 80/25
role [31] 3/14 5/7 5/9
5/16 6/5 6/7 6/10 6/10
24/11 34/19 36/25
37/13 38/13 39/14
39/24 40/3 40/9 46/6
46/25 47/8 47/12
47/22 48/8 48/21 58/4
75/15 76/9 81/3 91/8
91/8 91/12
roles [4] 12/10 90/20
90/25 100/12
room [4] 1/16 23/22
70/1 92/3
Rose [1] 57/4
round [3] 108/20
108/21 108/22
routinely [1] 13/17
row [1] 88/2
Royal [2] 23/7 23/9
rules [2] 46/11 99/15
run [3] 36/24 83/25
84/5
running [4] 72/1 81/7
84/19 114/6
Soo
Saf [1] 85/21
said [41] 4/13 5/1
6/11 20/17 23/18 25/8)
27/15 27/19 31/2
33/20 33/24 36/8
36/18 38/13 38/25
39/18 51/24 58/18
58/22 71/25 73/22
73/23 74/3 74/4 74/5
74/6 74/8 74/21 81/25)
85/25 86/2 86/3 86/20)
86/21 92/10 96/9
100/2 105/19 107/1
107/8 110/6
Salter [3] 69/19
75/11 95/20
same [17] 21/11
21/15 22/7 22/12
22/18 30/17 32/13
57/2 59/16 63/23 67/9
78/22 82/13 82/14
101/21 107/9 107/9
sampling [1] 69/9
Sarah [2] 88/22
105/19
sat [5] 5/22 9/6 12/6
68/16 109/16
satisfaction [1]
55/19
satisfactory [1]
50/15
Saturday [1] 73/5
saw [4] 26/4 29/11
29/21 54/9
say [34] 5/6 7/10 10/6
13/2 13/24 29/9 30/5
30/11 36/8 36/18 41/6
44/23 45/4 46/16 50/9
50/20 57/10 61/10
62/17 62/21 64/4
75/22 79/19 88/23
89/4 91/10 92/13
92/22 98/25 104/9
108/17 109/18 110/3
114/3
saying [18] 22/24
33/23 44/8 45/22
45/24 53/22 55/2
64/22 65/10 73/24
77/14 78/12 86/9
94/13 96/2 105/2
105/13 105/18
says [43] 7/12 7/13
8/10 14/21 16/19
19/24 23/6 25/23 26/5I
26/8 28/1 28/15 28/21
31/11 31/20 32/5
32/12 32/19 36/7
37/12 41/2 42/24 43/2
43/14 45/22 50/2
50/11 53/1 53/9 53/14}
53/18 55/8 59/5 59/13
62/8 66/2 67/13 71/20
73/9 77/20 80/14
85/20 93/15
scandal [2] 106/16
107/6
Schedule [1] 62/24
scheme [24] 66/4
67/11 77/18 79/1 79/4
79/6 79/6 79/9 79/12
79/17 79/17 80/3 80/6I
80/21 81/25 82/2 82/5
82/18 82/19 83/24
84/11 84/19 94/9
94/17
schemes [3] 78/9
84/6 96/22
Scotland [4] 111/11
112/14 112/22 112/24
Scottish [5] 112/11
112/18 112/19 112/21
113/1
screen [3] 7/8 95/9
103/19
scroll [39] 7/10 8/8
16/19 21/14 21/16
22/11 23/5 25/20 26/3}
27/23 28/1 28/20
28/23 30/19 30/25
31/17 32/4 38/8 38/14)
41/1 42/5 47/14 51/4
52/25 53/8 53/13 59/4I
59/21 63/23 65/25
67/8 67/13 68/4 71/16
77/13 77/19 80/12
(46) rely - scroll
Ss
scroll... [2] 85/14
85/19
scrolling [3] 53/9
53/16 54/2
second [10] 2/7 2/18
4/5 7/20 8/9 17/15
50/10 59/13 104/1
113/7
secondary [1] 28/16
secondee [1] 38/24
Secondly [2] 7/19
55/25
secretariat [1] 8/16
Secretary [1] 49/2
section [3] 47/17
66/1 77/20
secure [1] 89/10
security [1] 8/11
see [46] 4/8 7/11 8/8
9/11 9/14 11/21 15/10
16/16 18/8 21/14
21/16 22/11 22/17
23/5 23/16 26/3 27/23
28/1 28/20 28/23
30/19 30/22 31/17
32/6 40/25 43/12
47/15 49/5 52/25 53/8
57/2 59/4 68/3 71/11
73/20 77/19 80/12
97/18 99/14 99/18
99/20 103/13 103/22
105/1 107/7 114/11
seeing [1] 80/23
seek [6] 7/25 44/1
62/9 77/21 111/25
112/22
seeking [3] 26/2
82/25 97/1
seem [3] 95/17 95/17
106/19
seemed [4] 5/5 51/25
64/17 106/8
seems [6] 54/3 55/16
64/1 104/3 106/20
107/5
seen [13] 12/20
12/22 23/24 24/3
50/19 61/18 70/10
77/1 88/1 98/13
104/22 104/23 107/19)
send [4] 13/21
sends [1] 35/25
senior [6] 37/24 40/1
85/23 86/8 104/13
108/25
sense [7] 7/22 27/4
38/6 39/4 51/9 64/15
82/1
sensitive [1] 20/12
sent [114] 9/4 16/13
18/4 21/17 22/7 22/12)
23/5 27/24 73/8 80/13
98/6
sentence [1] 24/4
separate [12] 23/7
23/20 24/9 24/10
32/14 66/10 75/19
84/14 84/15 97/5
97/19 109/10
September [7] 8/19
61/11 65/24 67/7 68/3
68/10 71/17
series [1] 77/1
serious [2] 53/11
67/14
served [1] 11/20
Service [1] 4/17
services [7] 3/11
5/16 6/3 17/4 27/14
40/4 51/19
serving [1] 72/2
session [1] 1/5
sessions [1] 71/23
set [14] 4/19 4/21
12/1 19/15 57/12
61/24 72/15 77/5
78/24 80/17 80/18
81/23 89/18 97/7
sets [5] 36/17 61/19
61/22 62/5 62/7
setting [4] 8/4 63/8
TTT 112/5
settle [1] 60/16
settled [1] 60/19
settlement [22] 56/3
56/12 58/23 58/25
59/8 59/15 59/24 60/6
60/15 60/19 61/3 61/5)
64/11 64/14 71/22
7216 72/14 72/16
76/13 77/4 77/6 79/8
settling [1] 59/19
seven [1] 54/1
several [3] 18/20
35/18 102/15
shaping [1] 73/15
shared [4] 21/7 31/22
32/15 33/11
shareholder [10]
20/23 33/8 37/6 56/15
83/6 84/7 84/9 85/2
85/3 97/7
shareholder's [2]
56/2 56/11
sharing [2] 31/13
33/2
sharp [1] 96/1
she [50] 6/9 6/11
6/12 6/13 6/15 8/9
19/24 20/12 20/21
20/24 23/21 27/6 27/8)
27/9 27/13 27/15
27/19 28/21 31/4
31/20 32/19 33/6
33/20 33/20 33/24
33/24 34/14 34/14
34/15 34/18 34/20
34/20 34/21 35/16
35/17 35/19 35/25
36/6 36/16 36/17
38/11 38/12 38/12
38/14 38/19 38/20
53/25 95/2 105/22
105/23
she's [2] 27/2 31/18
shifted [1] 69/21
shock [3] 38/3 56/22
64/20
short [8] 17/7 40/18
70/19 70/19 71/9
103/8 106/17 108/3
shortfall [5] 66/4
67/11 77/17 94/17
104/11
shortfalls [7] 58/6
79/19 79/20 104/1
104/4 105/14 111/18
shortly [4] 42/23
should [20] 7/14
10/12 41/21 53/4 53/6
55/25 60/3 60/6 62/3
62/21 78/6 83/24
84/24 104/10 105/13
107/10 107/22 108/18}
109/7 110/4
show [1] 87/17
showed [1] 99/4
shows [1] 11/2
sic [1] 97/10
side [5] 17/21 28/9
72/4 75/18 96/12
sideline [1] 30/5
sidelined [1] 74/10
sidelines [1] 30/3
signature [2] 2/21
113/11
signed [1] 39/9
significant [5] 26/14
27/5 27/10 55/13 90/1
signing [1] 13/22
silent [1] 1/15
similar [2] 32/6 65/22
similarly [1] 76/24
simply [6] 14/9 21/8
38/7 45/20 99/13
110/21
since [7] 3/22 8/11
8/18 24/22 64/2 64/5
68/11
Sinclair [1] 111/10
single [2] 7/25 53/3
gle-most [1] 53/3
sir [33] 1/3 16/15
40/11 40/20 71/2
71/11 83/22 85/7 96/3
97/3 97/23 98/2 99/11
100/17 101/4 101/18
101/24 102/1 102/21
103/1 103/4 106/15
106/23 107/25 108/23}
109/9 109/17 110/17
110/18 111/2 113/5
114/2 114/10
Sir David [2] 109/9
109/17
sit [2] 48/3 49/2
situation [3] 57/18
61/8 107/20
sixth [2] 2/13 113/8
Skinner [1] 95/2
slightly [7] 23/2
30/19 41/2 53/1 53/17)
59/3 108/1
small [3] 77/22
110/18 110/19
Smith [19] 36/22
37/1 37/10 37/10
37/19 37/21 38/23
39/5 39/6 58/8 66/9
71/18 72/6 74/17 80/3)
82/20 92/23 109/9
109/17
Smith's [1] 36/25
smoothly [1] 114/6
Smyth [2] 21/18
21/22
so [159]
solicitor [5] 3/5 31/18)
34/15 34/17 71/17
solicitors [2] 82/21
112/16
solutions [1] 49/14
some [28] 10/3 10/6
12/4 14/4 15/8 18/3
20/14 20/20 29/12
30/3 32/24 34/1 38/5
49/10 53/23 58/25
59/23 60/18 64/8 65/7,
69/21 73/5 77/16
82/20 92/1 101/8
108/2 111/2
somebody [5] 22/19
24/16 26/23 47/22
80/24
someone [7] 5/2
28/22 39/12 43/1
57/18 109/2 109/14
something [17] 5/11
5/25 18/16 20/8 20/15)
23/19 36/8 36/18
39/21 39/22 45/1 45/1
45/24 46/2 68/19 86/1
108/1
sometimes [1] 65/2
somewhat [1] 58/15
sooner [1] 59/14
sorry [14] 36/12 37/5
39/4 42/5 48/19 66/24
70/18 72/2 76/15 95/8)
95/14 95/20 105/4
113/20
sort [2] 51/5 58/15
sought [4] 58/2 80/5
82/2 107/3
sound [1] 15/23
sounding [1] 49/17
sounds [1] 107/14
speak [6] 9/8 53/14
53/15 57/13 84/24
91/3
speaking [4] 38/8
53/19 53/20 53/24
special [1] 97/17
specialising [1]
15/20
specialist [1] 8/4
specialists [1] 25/11
species [1] 100/25
specific [5] 43/10
46/11 48/4 58/19 95/7)
specifically [10] 4/25
5/16 32/25 49/22 58/7
58/8 61/2 69/4 88/5
109/10
specifics [2] 19/3
56/9
speed [5] 5/15 11/4
30/14 75/8 81/7
spending [1] 31/2
spoke [1] 59/7
spoken [1] 9/13
sponsor [4] 74/13
74/19 74/22 87/1
stage [17] 22/12
23/13 26/14 26/17
29/4 30/21 34/11 35/2I
37/25 52/2 54/11
58/10 58/13 59/25
69/9 72/11 77/25
stamps [2] 57/17
58/21
standard [7] 18/9
82/12 94/11 95/5
98/14 98/15 99/15
standing [1] 64/17
stands [4] 8/14 8/15
8/15 53/5
start [11] 4/11 13/4
16/14 30/18 42/21
52/22 61/17 90/10
90/10 90/11 98/3
started [5] 29/21
52/13 74/5 74/5 89/23}
starting [2] 113/23
114/5
state [5] 1/21 46/4
68/23 69/3 70/4
statement [14] 2/5
2/10 4/12 4/24 19/23
74/8 75/6 111/12
113/6 113/7 113/8
113/9 113/11 113/13
statements [9] 1/8
1/25 2/16 2/22 2/24
3/3 65/2 65/3 113/18
States [1] 15/19
(47) scroll... - States
Ss
status [2] 31/14
33/14
Staunton [3] 85/16
86/17 96/13
stay [1] 84/10
SteerCo [3] 9/20 30/8)
35/9
SteerCos [2] 74/4
87/3
steering [2] 10/25
83/5
Stein [6] 92/3 92/4
103/11 103/12 112/8
115/10
Stent [1] 68/6
step [2] 39/15 106/11
Stephen [1] 88/6
stepping [1] 34/25
steps [3] 70/20
111/13 111/23
Steve [2] 87/9 87/10
still [10] 15/24 28/3
55/1 59/16 69/9 90/19
95/11 95/12 95/12
106/20
stock [1] 55/17
stone [1] 80/18
stopped [2] 87/1
107/13
storage [1] 66/8
story [1] 28/9
straight [2] 7/17
57/10
strategically [2]
87/20 88/23
strategies [1] 43/5
strategy [8] 56/14
61/22 61/24 62/6 62/7
62/9 63/14 63/19
stretched [2] 66/3
76/4
strong [4] 7/22 50/14
77/21 84/8
struck [2] 22/19
96/16
structure [1] 82/8
structured [1] 9/16
struggle [1] 78/21
stuff [1] 8/6
subcommittee [4]
9/20 30/9 35/11 59/12
subject [3] 8/20 27/7
36/3
submissions [3]
43/20 44/2 92/18
subpostmaster [4]
14/25 85/17 93/18
111/10
subpostmasters [7]
5/7 5/11 13/9 86/15
92/25 94/4 112/24
subsequent [6]
31/15 37/8 51/6 58/20
78/10 112/6
subsequently [8]
23/24 24/3 37/4 39/17
41/19 46/5 68/25
98/24
subsidiary [1] 40/5
substantial [2] 61/4
70/14
substantive [1] 111/4I
successful [1] 76/19
successfully [1]
111/11
such [17] 13/21 16/4
16/6 19/5 25/17 35/4
38/4 67/18 69/21
74/10 74/17 74/17
79/9 79/12 79/22
104/11 107/21
suffered [1] 111/17
sufficient [10] 25/5
35/3 35/3 35/4 48/17
48/21 55/23 68/12
69/12 93/22
sufficiently [3] 34/9
39/23 90/6
suggest [3] 53/23
53/24 95/7
suggested [4] 42/13
50/24 52/4 79/8
suggesting [5] 24/25
55/4 78/14 83/16 87/5)
suggestion [6] 14/3
51/3 55/15 57/4 79/25
83/23
suggests [1] 95/4
sum [1] 28/11
summarise [2] 30/3
41/9
summarising [1]
51/22
summer [3] 23/2
58/22 113/20
supervise [1] 17/10
supervising [2]
22/13 98/12
supervision [1]
101/13
supervisor [1] 100/2
support [7] 9/2 25/9
35/18 69/23 81/12
89/6 99/22
supported [4] 35/16
35/17 35/20 89/7
supporting [4] 31/7
35/14 83/12 107/22
supports [1] 34/13
sure [41] 7/1 11/17
11/21 11/25 12/2 12/9)
18/4 18/6 18/22 23/25)
29/22 42/7 44/22
44/25 45/6 45/17 52/5)
56/23 58/9 60/10
63/16 63/17 64/14
64/15 65/13 69/17
69/18 69/24 78/9
80/17 80/18 85/11
85/12 89/2 91/2 91/19
91/21 92/13 93/7 98/9
109/13
surprise [1] 33/22
surprised [1] 62/19
surprising [2] 106/19
107/5
Susan [1] 111/10
suspect [1] 5/2
suspend [1] 55/24
suspended [2] 28/5
93/19
sustainable [1] 49/13}
sworn [1] 2/8
sympathetic [2] 8/1
8/2
system [18] 4/14
4/21 14/7 16/23 50/18
50/19 50/21 50/22
50/24 51/1 51/15
51/18 52/12 54/13
55/2 105/14 105/18
105/20
systems [2] 7/18
53/5
T
tactics [1] 61/15
take [27] 2/1 4/9 7/6
10/3 12/19 16/12
21/11 22/9 23/21
34/18 40/11 47/3 68/1
69/6 71/3 89/1 92/2
95/21 97/24 98/3
101/24 102/4 103/1
103/17 103/23 107/25}
113/21
taken [14] 41/17 42/9
46/8 52/14 56/20
64/24 69/10 70/15
74/15 99/16 106/8
106/11 106/12 111/14]
taking [5] 26/24
37/13 39/13 88/7
96/24
talk [1] 88/4
talking [1] 56/8
tangentially [1] 52/7
teaching [1] 40/2
team [45] 5/12 6/14
8/4 8/14 8/21 10/13
11/11 12/17 22/2 24/2
25/4 27/8 31/1 31/7
54/17 54/22 58/18
66/3 67/10 69/20 70/6
75/23 85/23 87/10
87/12 87/14 87/20
87/20 88/11 88/19
89/4 89/6 89/15 89/24
90/2 90/2 90/15 90/23
91/5 91/14 105/24
107/17 107/17 107/22
108/17
teams [2] 77/2
100/13
technical [5] 15/22
15/23 63/7 63/18
92/12
telephone [1] 14/16
telling [1] 107/1
tells [1] 18/6
temporary [3] 74/13
74/19 74/22
ten [4] 92/24 94/3
97/24 103/1
Ten10 [2] 43/5 54/9
tenure [2] 12/18 86/5
term [3] 92/23 108/10}
110/5
terminated [1] 93/21
terminology [1] 97/1
terms [25] 4/9 4/23
6/3 6/11 9/16 10/18
20/2 21/16 25/13
31/14 43/9 46/16
52/11 59/9 61/3 76/19)
78/24 82/13 84/23
87/18 91/19 94/9
101/11 106/17 111/20}
terrible [1] 43/18
test [7] 33/25 43/4
43/5 44/11 45/8 97/14)
98/18
testing [3] 13/12
54/10 54/11
than [20] 7/17 19/4
26/25 27/11 31/23
38/15 38/25 39/12
52/10 56/8 56/25
59/15 63/18 71/22
72/12 73/1 75/17 88/4)
100/20 104/22
thank [70] 1/7 1/12
1/21 1/24 3/2 3/16 4/1
7/6 8/17 10/3 12/19
16/15 17/12 21/24
30/15 33/15 35/23
36/15 37/11 40/10
40/16 40/20 41/25
49/5 62/4 65/17 67/6
71/1 71/11 71/12
71/15 71/20 72/9 85/6)
85/9 91/6 91/25 95/23
96/4 96/5 97/3 97/22
97/23 98/2 99/2 99/10)
99/12 102/2 102/24
102/25 103/1 103/4
103/6 103/10 103/15
108/21 108/23 110/14}
110/16 110/17 111/6
112/20 113/3 113/4
113/14 113/15 113/16}
113/17 114/2 114/12
thanking [1] 1/11
thanks [3] 41/7 44/9
114/16
that [784]
that I [3] 65/4 87/1
110/22
that's [67] 3/9 3/18
7/9 9/21 10/4 10/22
12/18 12/21 12/21
16/14 19/14 19/19
21/12 22/8 23/1 25/18
27/21 30/17 32/23
34/1 36/23 37/11
39/15 40/22 42/20
44/15 45/3 46/15
46/19 47/24 50/1
51/20 52/21 54/14
54/21 54/22 55/6 57/2
59/2 61/17 62/22
63/22 65/20 67/6 68/2I
68/2 69/7 71/14 73/7
74/3 76/25 77/10
80/22 82/18 85/11
95/19 99/9 100/5
100/5 100/9 105/8
106/6 107/16 107/18
110/12 110/13 114/10)
theft [4] 7/17
their [17] 19/9 34/5
50/17 51/11 51/14
60/22 65/6 65/8 76/7
81/3 81/21 88/1 88/3
93/21 104/4 105/18
107/12
them [27] 2/2 8/5 8/6
9/1 16/23 18/12 31/16
37/2 37/22 58/8 71/22
71/23 72/23 73/12
75/2 75/15 81/20
86/21 86/22 86/22
87/8 87/17 87/17 89/7I
92/6 92/11 110/24
theme [1] 63/23
themselves [2] 57/19
81/19
then [52] 3/19 7/25
8/3 9/14 13/24 26/8
28/15 33/11 33/12
33/24 36/8 36/10
37/12 38/20 39/11
41/5 43/10 45/2 45/5
45/9 50/6 50/9 53/13
57/21 58/19 65/13
67/7 68/18 68/24
78/10 78/18 83/8
83/19 84/12 84/13
87/22 89/10 89/16
89/17 89/17 90/10
90/19 97/12 103/17
103/25 104/9 107/21
107/23 110/19 112/6
112/13 114/11
there [143]
there'd [1] 56/24
there's [21] 23/25
24/4 31/12 32/4 38/8
(48) status - there's
T
there's... [16] 39/8
42/23 45/1 50/7 66/1
68/4 69/6 70/15 78/9
82/22 83/7 83/23
87/15 89/25 100/7
105/10
therefore [11] 20/14
25/3 32/2 32/20 45/24
47/25 56/7 76/20
93/15 95/1 109/21
these [12] 13/11
13/12 23/16 26/25
38/17 66/8 81/15
84/14 93/11 93/12
95/24 97/21
they [73] 2/3 7/3
11/25 13/2 13/4 13/18}
19/11 19/25 21/18
24/12 31/24 36/20
37/9 37/10 37/20
41/20 42/16 44/25
45/5 46/20 46/21
46/22 50/17 53/2 55/5
55/11 55/12 57/19
58/13 60/14 64/8
64/25 64/25 65/1 65/7
66/16 69/17 72/21
76/1 76/3 76/22 78/16
79/9 79/11 81/21 82/2
84/22 85/24 86/12
86/19 86/20 87/11
87/25 88/2 88/3 88/4
88/20 89/4 89/5 89/9
89/10 90/3 90/5 92/14,
94/13 94/15 96/15
97/4 97/12 97/14
107/3 107/10 110/23
They'd [1] 72/20
they're [1] 45/21
thing [2] 95/23 102/2
things [10] 7/17 11/5
22/4 55/18 64/23
75/23 80/9 80/10
82/15 90/9
think [166]
thinking [1] 92/12
thinning [1] 62/7
third [9] 2/10 2/19 4/9
14/4 17/18 17/25 18/8}
70/2 113/8
this [205]
Thomas [1] 72/20
thorough [1] 70/1
those [41] 2/16 2/22
2/24 3/3 4/6 11/21
12/13 12/14 12/15
14/14 15/2 29/11
29/20 32/8 34/9 52/3
65/3 65/25 69/10
72/19 74/23 74/23
79/23 81/2 81/21
82/19 83/4 90/16
90/20 92/18 99/16
99/17 101/11 101/16
108/8 109/12 111/3
111/16 111/17 112/13)
112/23
though [7] 12/12
15/7 17/8 20/6 46/15
54/23 64/1
thought [8] 4/21
19/12 31/13 33/23
52/5 79/9 89/14
102/21
three [6] 19/16 45/17
82/6 89/9 97/9 99/15
through [21] 2/2 8/9
13/19 19/8 25/10 32/8)
48/3 49/8 56/25 62/10
79/14 83/5 83/5 86/21
87/23 94/3 98/6
101/15 104/2 112/7
112/13
throughout [4] 1/25
47/21 49/3 86/4
Thursday [1] 25/25
tight [2] 25/4 78/23
Tim [3] 37/6 52/23
54/19
time [55] 3/23 5/8
5/13 5/20 10/9 10/15
12/4 12/20 15/7 17/3
17/7 17/24 18/18 20/4
20/20 22/11 23/2
24/14 25/14 31/3 33/1
37/6 45/16 46/5 46/6
47/21 48/16 48/22
48/22 51/2 54/7 54/19
55/8 59/3 68/10 69/19
72/5 74/8 75/16 78/6
82/15 82/19 88/8
88/18 89/21 89/24
90/8 94/7 101/12
104/18 105/9 106/19
108/5 110/10 111/3
timeline [1] 25/20
times [2] 89/9 92/24
timetable [1] 7/22
timing [3] 4/9 37/15
43/18
title [2] 74/19 75/4
today [9] 4/2 26/7
29/21 50/19 50/25
53/20 80/23 114/1
114/5
today's [2] 1/5 1/6
together [2] 37/7
70/1
told [8] 4/12 4/14
4/15 16/25 65/5 73/21
87/17 100/1
Tom [1] 37/7
Tom's [1] 26/9
tomorrow [1] 30/23
tone [2] 56/21 63/17
too [5] 8/1 9/24 54/12
75/13 81/23
took [3] 63/7 63/10
111/24
top [2] 70/7 101/18
topic [6] 19/20 65/17
65/18 65/22 67/9
75/19
topics [2] 48/14 68/6
touches [1] 7/7
touching [2] 29/12
108/10
towards [5] 28/13
37/25 58/23 77/9
89/11
track [1] 88/12
tracked [1] 49/16
tracker [2] 88/10
88/17
traction [1] 75/3
Tracy [1] 75/25
trade [2] 83/25 91/20
trading [1] 7/16
traffic [3] 4/14 4/23
52/12
trail [1] 13/11
training [3] 18/21
18/24 66/13
tranches [1] 102/11
transaction [2] 14/8
14/23
transactions [4] 13/8
13/9 13/16 13/18
Transactions’ [2]
13/7 14/20
transferred [3] 8/11
8/18 68/18
transgress [1] 96/1
treat [1] 57/9
treated [3] 53/12
57/9 57/10
trial [13] 34/20 34/22
43/21 43/25 44/14
49/8 49/17 49/21
50/13 52/16 53/6 62/6
73/25
trials [1] 62/20
tried [2] 16/9 76/1
true [4] 2/3 2/24
110/6 113/11
try [3] 24/2 90/11
90/11
trying [8] 7/1 11/4
23/25 58/13 73/6 81/7
81/8 81/9
turn [19] 10/4 23/1
25/18 27/21 40/22
40/24 42/20 47/13
49/25 52/21 55/6 59/2
61/16 62/16 63/22
67/6 73/7 77/10
111/13
turning [1] 71/13
twice [3] 27/14 35/19
89/10
two [19] 1/8 4/2 4/8
7/17 19/19 19/21 36/2
37/9 45/17 55/21
62/20 72/15 75/12
75/14 85/17 86/18
88/6 97/5 103/16
twofold [1] 19/17
types [1] 90/14
U
UKGI [19] 20/24 21/7
25/22 30/23 31/13
31/23 31/23 31/24
32/10 32/14 33/1 33/2
33/7 78/8 83/6 84/3
84/7 85/2 85/4
UKGI/Ministers [1]
32/10
ultimately [7] 34/12
35/13 39/3 46/19
62/11 74/21 98/8
unable [1] 60/1
unacceptable [2]
67/21 70/22
unclear [1] 38/24
uncomfortable [1]
55/10
under [10] 8/22
19/16 19/17 28/13
31/16 32/15 78/21
79/20 103/25 112/19
underlying [1] 81/1
undermine [1] 99/22
undermines [1]
33/12
understand [26] 7/3
12/5 12/12 12/14 16/1
18/3 25/9 25/10 26/20}
37/4 44/13 55/21 60/8)
66/19 67/2 81/8 83/14
91/20 92/9 93/3 94/8
94/23 97/3 98/23
100/13 110/9
understandably [2]
31/3 42/8
understanding [24]
19/10 19/11 24/18
25/1 26/17 26/19
26/21 27/17 45/8
46/12 52/11 54/14
54/16 55/22 60/10
60/11 60/12 66/17
78/2 78/5 78/7 84/6
112/10 112/25
understands [1]
91/22
understood [19] 7/2
12/2 18/17 18/19
18/23 41/24 45/18
54/20 56/23 61/12
63/10 69/18 82/11
84/12 90/14 100/5
105/25 106/3 112/18
undertake [4] 8/25
11/24 24/23 49/12
undertaken [7] 44/10
44/14 62/20 69/1
73/25 76/6 83/15
undertaking [1] 25/2
Underwood [5] 32/5
32/5 77/13 78/12
80/13
undoubtedly [1]
70/10
uneasy [1] 53/22
unfair [2] 87/14
92/12
unfit [1] 50/24
unfortunately [1]
65/2
unilaterally [1] 14/23
unique [2] 57/18 58/1
unit [2] 69/25 84/15
United [1] 15/19
universe [5] 67/2
67/3 69/4 69/19 69/24I
university [1] 40/2
unknown [2] 66/8
67/15
unless [1] 85/7
unlike [1] 48/25
unreasonable [2]
27/4 34/17
unsuccessful [1]
57/6
unsupported [1]
25/12
until [11] 3/14 7/17
44/4 68/24 85/23 86/3)
86/7 86/11 87/12
110/8 114/14
unusual [4] 5/5 48/5
57/12 101/6
up [45] 5/15 6/4 7/8
8/4 8/8 11/4 11/7
15/10 21/16 24/2 26/3}
28/20 28/23 30/14
30/19 30/25 31/17
32/4 38/9 39/15 43/23
51/4 51/8 52/17 53/8
53/9 53/13 53/16 54/2I
55/3 57/14 65/4 69/25
74/15 77/17 80/12
81/7 81/23 85/21
86/20 88/6 89/18
108/3 108/5 111/13
update [6] 36/3 40/25)
50/1 68/8 72/23 96/7
updated [1] 50/4
updates [4] 20/14
20/19 35/3 35/7
uploaded [1] 3/3
upon [10] 4/16 17/4
19/19 19/21 27/13
48/1 50/23 101/21
105/13 108/10
upset [1] 38/12
urging [1] 99/13
(49) there's... - urging
U
URN [2] 2/7 2/13
us [18] 4/14 7/20
7/23 8/13 9/3 10/15
37/23 55/13 55/23
56/12 63/3 64/6 66/15)
73/15 78/4 81/12
110/14 113/10
usage [1] 18/15
used [6] 5/2 13/21
24/2 38/18 56/4 74/10}
useful [1] 106/21
uses [1] 92/23
using [1] 104/5
usual [1] 48/5
usually [1] 11/12
utmost [1] 95/25
Vv
vague [2] 37/13
101/19
valid [1] 28/4
valuable [2] 109/4
110/1
valuation [1] 59/10
value [3] 91/16 91/16
91/17
vast [1] 60/17
veneer [1] 74/19
Vennells [1] 27/25
verbal [1] 20/19
verbally [1] 20/15
verify [1] 13/18
version [1] 21/11
versions [1] 79/21
very [48] 1/12 1/21
1/24 1/24 3/2 4/1 5/6
5/14 15/15 15/21 19/6
26/21 38/5 40/16 44/9
45/25 52/8 55/10 63/7)
71/1 74/7 78/23 80/23
81/6 81/10 81/20
88/20 88/22 91/25
95/12 96/4 99/2
102/24 103/4 103/16
104/13 104/13 107/9
108/9 108/21 109/6
113/6 113/17 113/20
113/21 114/5 114/6
114/12
vexatious [1] 66/6
via [1] 7/16
victim [1] 14/7
view [30] 9/23 9/24
15/13 15/25 18/9 19/9
31/5 38/25 39/20 47/4
47/12 48/5 52/6 57/7
61/24 63/3 64/10
68/13 72/10 74/24
76/2 77/21 78/6 79/4
81/22 83/24 84/1 86/4
89/12 90/7
views [2] 84/17 84/18]
vis [2] 37/15 37/15
vis a vis [1] 37/15
Ww
wait [1] 53/19
waiting [1] 26/20
walked [1] 70/1
want [7] 7/20 8/25
30/5 61/15 71/21 89/4
107/7
wanted [9] 6/9 6/13
6/15 27/6 27/8 36/21
37/21 78/16 86/22
wants [2] 53/13
80/19
was [426]
wasn't [35] 6/1 6/17
10/21 11/5 12/14 17/9)
20/17 21/9 22/23
22/24 25/2 25/13
27/16 27/17 34/5 34/5)
35/7 48/24 54/21
61/25 63/11 65/8
68/23 72/13 74/16
75/2 84/3 87/12 88/13
90/13 90/16 90/19
101/9 104/18 106/25
watch [1] 75/24
Watts [3] 50/3 71/17
7119
wave [1] 8/22
way [24] 6/17 9/15
10/19 25/12 25/20
27/3 27/8 32/8 32/8
33/7 33/17 34/23
35/16 37/25 43/23
51/10 57/9 59/14
64/10 64/23 105/16
108/20 108/21 108/22)
we [216]
we'll [4] 15/9 22/17
35/23 75/19
we're [13] 1/13 21/12
23/2 25/21 34/24
52/22 59/3 59/3 59/16
68/10 69/10 71/2 92/2
we've [6] 21/15 61/18
80/22 82/22 111/2
112/7
wearing [1] 57/23
website [1] 3/4
week [2] 37/20 59/12
weeks [2] 45/17 59/7
weight [1] 93/16
well [37] 3/23 4/10
9/8 11/15 12/22 16/1
18/17 18/19 20/17
24/16 30/4 35/21 38/2
39/15 40/2 45/2 67/1
68/16 70/23 73/4 74/3
75/2 78/5 81/25 82/14
83/12 85/13 88/14
89/24 90/23 95/12
97/15 105/12 106/25
107/14 110/11 113/17I
well-recognised [1]
97/15
went [7] 38/12 69/24
69/25 79/14 86/14
86/21 87/23
were [109] 4/15 6/1
7/16 9/3 10/16 12/1
12/3 14/17 14/22 16/2I
16/13 16/17 17/1
17/24 19/24 20/14
21/18 22/12 22/17
23/13 23/16 23/18
24/12 24/20 24/20
26/14 26/15 27/10
29/9 29/11 30/8 33/1
33/9 33/16 34/8 37/19
37/20 38/5 38/13
38/18 39/21 41/14
42/16 46/5 47/4 47/6
47/10 48/17 49/18
50/9 52/3 54/11 54/17,
57/8 58/13 58/18
59/17 60/18 61/4 61/8
63/11 63/17 64/25
65/1 65/24 66/16
69/14 69/16 69/17
72/21 74/15 75/14
76/17 76/22 77/5 77/5
77/24 78/15 79/18
79/25 82/1 82/4 83/11
84/17 85/4 86/19
86/23 86/24 88/12
89/18 90/19 92/11
92/25 93/11 93/12
94/5 102/3 102/4
102/11 102/12 102/13
102/14 102/22 102/22}
110/3 111/4 112/8
112/13 113/20
weren't [5] 19/25
36/10 36/20 39/22
79/10
what [90] 5/15 6/9
6/13 6/20 8/13 9/10
10/12 11/2 12/24
15/13 17/24 18/10
18/11 18/24 19/1 19/9
22/23 26/20 27/17
33/25 36/23 36/25
37/23 39/4 39/20
41/10 41/14 45/21
45/24 47/4 47/6 47/10
48/13 48/13 48/17
48/19 49/20 51/1 51/9
52/15 53/2 55/14
55/21 55/22 56/12
56/16 57/7 57/10
58/13 60/8 61/24 63/3,
63/8 63/20 63/21
64/10 64/22 65/6
65/10 67/2 69/19
72/13 74/11 75/8 76/8
76/14 78/4 78/12
78/13 79/21 84/2 84/4
84/15 85/11 86/14
87/13 92/19 96/9
98/15 98/25 99/18
99/19 100/5 100/5
102/11 105/2 105/19
107/1 108/22 113/24
what's [6] 11/3 21/3
22/10 79/4 99/5 107/8
whatever [1] 96/25
whatsoever [1] 30/1
when [45] 4/16 5/7
6/8 13/20 18/5 18/12
18/24 19/25 20/11
22/1 29/21 31/14
35/18 38/2 39/7 43/18
47/18 54/5 56/17
62/20 65/6 69/2 74/10)
75/4 75/9 75/10 75/14
81/14 87/17 90/8 90/9
92/19 93/11 93/12
96/13 98/4 98/16
98/17 98/21 100/3
104/16 104/24 105/9
113/5 113/20
where [26] 7/3 7/15
10/15 12/2 12/5 14/1
14/19 16/6 19/24
22/18 30/25 43/12
45/12 45/14 48/23
49/24 49/25 57/14
57/16 64/16 69/16
72/5 74/24 76/25 81/8)
82/5
whereby [1] 82/2
wherever [1] 71/24
whether [28] 8/25 9/1
10/13 17/21 23/9 33/9)
37/17 37/20 39/20
39/25 46/21 46/22
50/12 51/8 52/17
61/13 67/17 70/4
81/22 84/4 84/18
84/23 101/5 101/12
107/12 107/22 108/18}
109/22
which [69] 8/16 12/8
16/5 17/13 17/18
19/19 19/21 27/3 27/7
27/12 27/13 30/8 31/9)
32/9 32/15 35/11 37/9)
42/17 46/14 49/13
49/25 50/2 50/22
52/13 54/21 56/15
56/21 57/18 60/15
60/17 62/2 63/9 64/3
65/23 67/16 68/21
70/16 74/9 78/17 81/5)
87/12 87/19 87/25
89/7 89/18 91/16
92/22 94/6 96/11
96/22 98/17 99/4
99/15 99/25 101/21
102/4 103/24 104/1
106/9 106/13 106/16
107/2 107/3 109/2
110/23 111/13 112/1
113/9 113/18
while [5] 50/15 55/20
60/1 60/13 98/12
whilst [3] 29/24
43/21 86/13
whipped [1] 86/20
whistleblowing [4]
56/5 57/11 57/18
57/24
who [41] 4/14 5/1
9/15 9/17 14/14 14/17
15/2 21/18 22/19
24/16 25/10 26/4
26/23 34/12 37/2 37/7I
38/23 39/5 39/5 39/12)
42/24 47/22 49/1
68/15 68/17 72/1 78/8
80/1 81/1 87/22 88/25I
89/12 89/17 100/24
101/16 102/13 109/9
111/10 111/15 111/17)
114/4
whoever [1] 83/20
whole [1] 1/9
whom [3] 38/23 85/1
100/10
whomsoever [1]
83/20
why [21] 9/3 9/21
9/21 10/22 20/7 26/23}
27/17 41/8 42/17
46/11 61/20 62/13
87/24 88/7 90/5 90/16)
90/16 90/18 90/19
90/20 95/19
wider [3] 54/11 58/11
67/16
WIELDED [1] 85/22
wielding [2] 86/25
87/6
will [35] 3/3 4/2 4/2
4/5 4/6 4/7 4/8 8/3 8/5
12/20 26/1 33/12 36/8}
36/19 41/7 43/7 43/8
43/8 43/16 43/22 44/1
45/2 45/5 46/2 48/1
53/15 66/11 70/10
75/25 77/1 85/13
86/13 93/16 93/17
96/6
Williams [30] 9/17
10/5 10/16 11/9 14/16)
15/4 15/10 16/1 16/7
16/13 21/11 21/17
22/13 22/17 23/5
23/12 25/22 26/23
26/24 26/25 51/21
77/13 80/13 80/22
81/1 98/6 98/13 100/2I
101/5 101/13
Williams’ [1] 15/13
(60) URN - Williams*
Ww
Wills [1] 88/22
win [1] 62/9
wish [1] 59/14
within [27] 10/16
12/16 13/5 18/17 22/2)
25/5 27/7 31/1 31/8
32/24 37/23 37/24
42/1 44/19 49/18
51/12 54/7 54/12
54/23 54/24 67/19
69/13 73/9 78/10 83/9
91/8 104/14
without [7] 13/8
14/24 28/14 56/4 69/8
93/21 96/1
WITN09980300 [1]
2/10
WITN09980400 [1]
2/12
WITN09980500 [1]
113/9
WITN09980600 [1]
2/14
witness [13] 1/8 1/25
2/5 2/10 4/12 19/23
93/9 111/12 113/6
113/7 113/7 113/9
113/18
witnesses [9] 50/14
50/16 50/20 51/3
51/11 52/17 52/19
55/3 104/23
Womble [5] 24/19
31/18 43/13 59/5
64/24
won't [1] 61/17
word [1] 20/7
Worden [1] 43/18
wording [2] 18/9
71123
words [5] 38/18
74/10 96/18 105/14
106/12
work [31] 7/18 7/24
10/6 11/9 27/3 27/8
31/5 36/1 43/9 43/15
43/21 44/4 44/10
55/20 57/19 57/23
58/13 68/25 70/14
73/15 77/3 77/7 81/21
82/19 83/13 83/14
83/18 87/6 89/16
98/13 110/2
worked [6] 3/7 3/13
11/14 25/9 91/4 91/18
working [10] 4/16
9/18 10/23 16/8 30/6
35/8 40/3 81/15 90/19
100/12
workload [1] 90/13
works [1] 10/19
workstream [2]
80/17 80/19
workstreams [1]
77/3
world [1] 44/3
worried [1] 108/17
would [107] 6/12
6/25 6/25 7/24 8/24
12/13 12/16 13/20
16/3 17/3 17/22 18/1
18/4 19/5 20/7 20/8
20/19 23/19 23/21
24/18 29/6 29/8 31/21
32/1 32/18 32/20
32/21 33/9 33/23
34/20 38/23 38/24
39/5 39/5 39/11 39/16
39/18 39/24 43/18
43/20 44/4 44/20
45/10 45/18 46/13
46/20 46/23 47/4 47/6
47/10 47/16 47/17
47/18 47/18 47/19
47/22 47/23 49/14
50/20 51/14 51/17
56/3 57/10 61/5 61/10
61/12 62/10 73/19
73/21 73/23 74/2
74/22 75/22 76/12
78/19 78/20 78/20
81/20 82/5 82/7 82/10
82/10 82/13 83/4
83/11 84/3 84/9 84/13)
87/17 89/13 89/15
90/15 93/10 94/15
95/17 95/17 95/17
95/22 97/16 98/13
100/10 102/21 104/5
107/7 109/9 112/17
114/3
wouldn't [10] 25/15
25/16 46/11 52/9 55/5)
78/13 82/12 83/17
93/13 98/12
write [2] 20/9 59/14
writing [2] 18/13 20/7,
written [2] 22/5
103/21
wrong [1] 86/14
wrote [1] 9/13
Y
Yeah [3] 38/11 63/14
91/10
year [3] 72/23 87/4
104/16
years [8] 5/12 8/22
15/20 18/20 54/1 64/2
81/7 101/8
yes [55] 9/6 10/18
11/12 12/18 15/7 17/3
21/19 22/14 32/13
33/4 36/23 38/17
39/10 39/15 40/13
40/15 43/14 44/12
44/13 44/16 51/20
61/7 63/8 69/16 71/12
81/4 82/22 83/16 84/2
89/9 92/5 92/7 92/18
93/3 93/4 93/14 93/15
94/8 94/22 94/22 95/1
95/13 98/15 99/11
100/5 100/7 100/10
101/12 101/23 103/3
103/5 103/15 105/17
107/20 114/10
yesterday [4] 1/10
7/14 90/4 106/4
yet [6] 28/7 50/16
55/18 60/23 80/18
87/5
York [1] 15/18
you [344]
you'll [3] 85/18
103/18 103/22
you're [13] 22/24
25/19 30/20 32/23
36/13 47/2 72/5 85/13
96/20 100/17 105/2
110/1 110/1
you've [9] 4/13 32/24
58/22 74/8 74/9 75/6
90/17 99/16 110/2
your [126]
yours [1] 90/6
yourself [1] 85/19
Zo
Zealand [1] 15/17
Zebra [2] 12/25 14/11
Zoe [2] 109/5 109/11
zoom [1] 21/14
(51) Wills - zoom